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COMPLIANCE PLAN OF VERMONT STATE COLLEGES.
Vermont State Colleges, or its successor-in-i-interest, as appropriate, will institute the following
procedures to ensure compliance with the Commission's Public File Rule. Unless otherwise
provided, all terms defined in the Consent Decree apply to this Compliance Plan.
As of the Execution Date of the Consent Decree the Station has filed with the Commission an
ownership report reflecting the Licensee's ownership as of 60 days or less of the filing due date
for the Station's 2007 biennial ownership report pursuant to the Ownership Report Rule. The
Licensee filed its biennial ownership report for 2009 with the Commission on or before
December 1, 2009, and shall timely prepare and file with the Commission all future ownership
reports as required pursuant to the Ownership Report Rule. Copies of all ownership reports shall
be timely placed in the Station's public file upon their filing with the Commission.
II. A. The program hosts and other appropriate staffof the Station will log all broadcasts of
public affairs programming. These logs will be compiled into quarterly issues/programs
lists, which will be timely placed in the public file ofthe Station.
B. All such quarterly issues/programs lists will be signed and dated by their preparer before
they are placed in the public file.
C. Late-filed lists will be reviewed and signed by the Station's management and
accompanied with a statement indicating the nature of the document, the date placed in
the public file, and the reason for the late filing.
D. The Station's management will emphasize to all staff volunteers the absolute requirement
to follow all the Rules, regulations, and policies and will fully explain the obligations
imposed by the Public File Rule to each staff volunteer charged with maintenance of the
Station's public files. Should the Station's licensee or its management learn that the
Public File Rule has been violated, the staff volunteer responsible will be reprimanded
and may be asked not to return to his volunteer position.
II. For a period of three years from the Effective Date, Licensee or successor licensee, as
appropriate, will conduct in-house audits of the Station's public file as detailed below. The three-
year period will terminate on the successful completion of the third annual public file audit
pursuant to Item II(C). The second and third audits pursuant to Item (C) will be due on the
anniversary of the first audit. The audits of the public file shall be performed as follows:
A. Quarterly audits, by telephone or facsimile, will be conducted by Licensee's counsel or
an authorized representative of the Vermont Association of Broadcasters under the
Alternative Broadcast Inspection Program;
B. A semi-annual review will be conducted by the Station's management; and
C. Annual, in-person, audits of the Station's public file will be conducted by an authorized
representative of the Vermont Association of Broadcasters under the Alternative
Broadcast Inspection Program. The first annual audit shall be completed ndt less than six
(6) months and not more than nine (9) months following the Effective Date.
,i'A l CA ments o Cl lli i~A r mkI..
United States. Federal Communications Commission. FCC Record, Volume 26, No. 7, Pages 4843 to 5761, March 28-April 08, 2011. Washington D.C.. UNT Digital Library. http://digital.library.unt.edu/ark:/67531/metadc52169/. Accessed May 4, 2015.