Federal Communications Commission
Washington, D.C. 20554
OMB 3060-1033
September 2003
FCC 396-C
FOR FCC USE ONLY
Multi-Channel Video Program Distributor EEO Program Annual Report

Read INSTRUCTIONS Before Filling Out Form

FOR COMMISSION USE ONLY
FILE NO.

B396 - 20080929AAI
SECTION I IDENTIFYING INFORMATION
A. Name of  Operator:
WAVEDIVISION VI, LLC
MSO Name:
WAVE BROADBAND
B. Employment Unit's Mailing Address
401 KIRKLAND PARKPLACE
SUITE 500
City
KIRKLAND
State
WA
Zip Code
98033-
E-Mail Address (if available) 
FCC Registration Number:
0015637911
Emp. Unit ID # 12131
Application Purpose
New Program Report
Amendment to Program Report
Supplemental Investigation Sheet (SIS) Attached
C. County and State in which unit's employment office is located
PLACER, WA
D. Category of Respondent (check applicable box)

Fewer than six (6) full-time employees during the selected payroll period: Complete Sections I, II and V
Six (6) or more full-time employees during the selected payroll period: Complete ALL sections of the Form 396-C and the Supplemental Investigation Sheet, if attached

E. Pay Period Covered by this Report (inclusive dates) 9/1/2008-9/14/2008
F. Attachments: (See "Exhibit" buttons, below.)

SECTION II COMMUNITY INFORMATION

System Communities Comprising Local Employment Unit
Ident No.
Name of Community
Location (State)
Type

Review the list of communities served on the previous year's submission and attach as Exhibit A any additions or deletions, using the format noted above. NOTE: APPLICABLE ONLY TO CABLE OPERATORS AND NOT TO OTHER MVPD UNITS.

[Exhibit 1]



SECTION III EEO POLICY AND PROGRAM REQUIREMENTS

Check YES or NO to each of the following questions. If answer to any question below is NO, attach as Exhibit B an explanation.
[Exhibit 2]

1.
Have you complied with the outreach provisions of the FCC's MPVD Equal Employment Opportunity Rule, 47 C.F.R. Section 76.75(b), during the twelve month period prior to filing this form?
Yes No
2. Do you disseminate widely your EEO Program to job applicants, employees, and those with whom you regularly do business? Yes No
3. Do you contact organizations, media, educational institutions, and other potential sources of applicants for referrals whenever job vacancies are available in your organization? Yes No
4. Do you undertake to offer promotions to positions of greater responsibility in a nondiscriminatory manner? Yes No
5. To the extent possible, do you seek out entrepreneurs in a nondiscriminatory manner and encourage them to conduct business with all parts of your organization? Yes No
6. Do you analyze the results of your efforts to recruit, hire, promote, and use services in a nondiscriminatory manner and use these results to evaluate and improve your EEO program? Yes No
7. Do you define the responsibility of each level of management to ensure a positive application and vigorous enforcement of your policy of equal employment opportunity and maintain a procedure to review and control managerial and supervisory performance? Yes No
8. Do you conduct a continuing program to exclude every form of prejudice or discrimination based upon race, color, religion, national origin, age, or sex from your personnel policies and practices and working conditions? Yes No
9. Do you conduct a continuing review of job structure and employment practices and maintain positive recruitment training, job design, and other measures needed to ensure genuine equality of opportunity to participate fully in all organizational units,occupations, and levels of responsibility? Yes No

SECTION IV ADDITIONAL INFORMATION

You may provide as Exhibit C any additional information that you believe might be useful in evaluating your efforts to comply with the Commission's EEO provisions. There is no requirement to provide additional data or information.
[Exhibit 3]



SECTION V CERTIFICATION

This report must be certified as follows:
A.   By the individual owning the reporting system if individually owned;
B.   By a partner, if a partnership; or
C.   By an officer, if a corporation or association.

I certify that to the best of my knowledge, information and belief, all statements contained in this report are true and correct.

Signed
Title
CHIEF OPERATING OFFICER
Date
09/26/2008
Name of Respondent
STEVE FRIEDMAN
Telephone No. (include area code)
4258961882

WILLFUL FALSE STATEMENTS ON THIS FORM ARE PUNISHABLE BY FINE AND/OR IMPRISONMENT (U.S. CODE, TITLE 18, SECTION 1001), AND/OR REVOCATION OF ANY STATION LICENSE OR CONSTRUCTION PERMIT (U.S. CODE, TITLE 47, SECTION 312(a)(1)), AND/OR FORFEITURE (U.S. CODE, TITLE 47, SECTION 503).



FORM FCC 396-C - SUPPLEMENTAL INVESTIGATION SHEET

Part I Employee Job Descriptions

Give brief job descriptions for employees in the job categories specified below. The number specified in the box indicates the number of different job descriptions that are to be submitted for each category. Job descriptions should include the position title and a brief description of the major duties and responsibilities of the individual(s) in the position.

1.
Officials and Managers
 
[Exhibit 4]
2.
Professionals

 

[Exhibit 5]
3.
Technicians
 
[Exhibit 6]
4. Sales Workers
 
[Exhibit 7]
5.
Office and Clerical
 
[Exhibit 8]
6.
Craft Workers (skilled)
 
[Exhibit 9]
7.
Operatives (semi-skilled)
 3
[Exhibit 10]
8.
Laborers (unskilled)
 
[Exhibit 11]
9.
Service Workers
 
[Exhibit 12]

Part II Inquiries Concerning EEO Program and Practices

Submit responses to the inquiries indicated by a "check" Responses should be brief, but must provide sufficient information to describe the employment unit's activity and efforts in the area of inquiry.

1.
Describe the employment unit's efforts to comply with the outreach provisions of 47 C.F.R. Section 76.75(b).
[Exhibit 13]
2.
Describe the employment unit's efforts to disseminate widely its equal employment opportunity program to job applicants, employees, and those with whom it regularly does business.
[Exhibit 14]
3.
Name the organizations, media, educational institutions, and other recruitment sources used to attract applicants whenever job vacancies become available.
[Exhibit 15]
4.
Explain the employment unit's efforts to promote in a nondiscriminatory manner to positions of greater responsibility.
[Exhibit 16]
5.
Describe the employment unit's efforts to encourage entrepreneurs to conduct business in a nondiscriminatory manner with all parts of its operation and provide an analysis of the results of those efforts.
[Exhibit 17]
6.
Report the findings of the employment unit's analysis of its efforts to recruit, hire and promote in a nondiscriminatory manner and explain any difficulties encountered in implementing its EEO program.
[Exhibit 18]
7.
Describe the responsibility of each level of the employment unit's management with respect to application and enforcement of its EEO policy and explain the procedure for review and control of managerial and supervisory performance.
[Exhibit 19]
8.
Describe the manner in which the employment unit conducts its continuing review of job structure and employment practices.
[Exhibit 20]
9.
Other Inquiries:
[Exhibit 21]

Part III EEO Public File Report

Attach a copy of the EEO public file report from the previous year. Cable entities are required to place annually such information as is required by 47 C.F.R. Section 76.1702 in their public files.

[Exhibit 22]

EMP UNIT ID: 12131
MSO NAME: WAVE BROADBAND
 
OPR NAME: WAVEDIVISION VI, LLC

Approved by OMB
3060-1033



Exhibits
Attachment 10
Description
System Technician I
Retention Specialist
Broadband Technician II


Exhibit 13
Description:
EFFORTS TO COMPLY WITH SECTION 76.75(B)

WAVE BROADBAND WIDELY DISSEMINATES NOTICES OF JOB VACANCIES TO ALL SEGMENTS OF THE COMMUNITIES IN WHICH IT HAS OPERATIONS, INCLUDING LOCAL JOB BANKS AND ORGANIZATIONS FOCUSING ON MINORITY GROUPS AND WOMEN, IN ADDITION TO POSTING ALL JOB VACANCIES ON OUR WEBSITE AT WWW.WAVEBROADBAND.COM. FOR THIS RECENTLY-ACQUIRED EMPLOYMENT UNIT, WAVE BROADBAND CONTINUES TO SEARCH OUT AND IDENTIFY ADDITIONAL ORGANIZATIONS TO WHICH TO DISSEMINATE VACANCIES.

IN ADDITION, THIS EMPLOYMENT UNIT PERFORMED THE FOLLOWING OUTREACH INITIATIVES BETWEEN OCTOBER 2007 AND SEPTEMBER 2008:

ESTABLISHMENT OF TRAINING PROGRAMS DESIGNED TO ENABLE UNIT PERSONNEL TO ACQUIRE SKILLS THAT COULD QUALIFY THEM FOR HIGHER LEVEL POSITIONS, 47 C.F.R. 76.75(B)(2)(VIII): WAVE BROADBAND HAS ESTABLISHED TRAINING PROGRAMS TO QUALIFY UNIT PERSONNEL FOR HIGHER LEVEL POSITIONS, AND SUPPORTS THE EFFORTS OF EMPLOYEES TO FURTHER THEIR EDUCATION IN AREAS WHICH WILL BENEFIT THEIR WORK WITH THE COMPANY, OR WHICH ARE REQUIRED FOR ADVANCEMENT TO HIGHER LEVEL POSITIONS. FOR EXAMPLE, WAVE BROADBAND SUPPORTS AND ENCOURAGES CONTINUING EDUCATION THROUGH NATIONAL CABLE TELEVISION INSTITUTE (NCTI) COURSES AND THE SOCIETY OF CABLE TELECOMMUNICATIONS ENGINEERS (SCTE) CERTIFICATION PROGRAMS. THE COMPANY PAYS FOR UNIT EMPLOYEES TO PARTICIPATE IN ALL COURSES BY THESE TWO INDUSTRY PROFESSIONAL ORGANIZATIONS. THESE COURSES PROVIDE THE SKILLS AND KNOWLEDGE REQUIRED FOR ADVANCEMENT IN MANY OF THIS UNITS JOB CLASSIFICATIONS.

PARTICIPATION IN TWO JOB FAIRS BY UNIT PERSONNEL WHO HAVE SUBSTANTIAL RESPONSIBILITY IN THE MAKING OF HIRING DECISIONS, 47 C.F.R. 76.75(B)(2)(I): THIS EMPLOYMENT UNIT PARTICIPATED IN LOCAL JOB FAIRS WITH THE SACRAMENTO JOB JOURNAL AND THE PLACER COUNTY BUSINESS ADVANTAGE NETWORK JOB FAIR IN AUGUST 2008. UNIT PERSONNEL INVOLVED INCLUDED THE HR ADMINISTRATOR AND THE REGIONAL TECHNICAL MANAGER.

PARTICIPATION IN OTHER ACTIVITIES REASONABLY CALCULATED TO FURTHER THE GOAL OF DISSEMINATING INFORMATION AS TO MVPD EMPLOYMENT OPPORTUNITIES TO CANDIDATES WHO MIGHT OTHERWISE BE UNAWARE OF SUCH OPPORTUNITIES, 47 C.F.R. 76.75(B)(2)(XVI): THIS EMPLOYMENT UNIT PARTICIPATES IN COMMUNITY EVENTS TO PROMOTE OUR COMPANY'S PRODUCTS, AND AT THE SAME TIME DISSEMINATES INFORMATION ON EMPLOYMENT OPPORTUNITIES AND CAREERS AT WAVE BROADBAND. TWO OF THESE EVENTS WERE THE ROCKLIN JUBILEE IN JUNE 2008 AND THE WOODLAND FAIR AUGUST 2008. UNIT PERSONNEL INVOLVED INCLUDED THE HR ADMINISTRATOR AND THE SALES AND MARKETING DIRECTOR.


Attachment 13


Exhibit 14
Description:
EFFORTS TO WIDELY DISSEMINATE EEO PROGRAM

WAVE BROADBAND DISPLAYS ITS EQUAL EMPLOYMENT OPPORTUNITY STATEMENT ON BOTH ITS WEBSITE AND HIRING APPLICATIONS. MANAGEMENT TRAINING ON HIRING PRACTICES INCLUDES CLEAR INFORMATION ON WAVE BROADBAND'S COMPLIANCE WITH NON-DISCRIMINATORY HIRING PRACTICES AND REGULATIONS. NEW EMPLOYEES AND CURRENT EMPLOYEES RECEIVE ANNUAL PREVENTION OF HARASSMENT AND DISCRIMINATION TRAINING ON AN ON-GOING BASIS. IN ADDITION, WAVE BROADBAND PROMINENTLY POSTS EEO NOTICES IN ALL ITS FACILITIES INFORMING EMPLOYEES AND APPLICANTS OF THEIR EEO RIGHTS, AND THEIR RIGHT TO NOTIFY THE EEOC, FCC OR OTHER APPROPRIATE AGENCY IF THEY BELIEVE THEY HAVE BEEN DISCRIMINATED AGAINST.

Attachment 14


Exhibit 16
Description:
EFFORTS TO PROMOTE IN A NONDISCRIMINATORY MANNER

TO ENCOURAGE NON-DISCRIMINATORY PROMOTIONS, WAVE BROADBAND DISTRIBUTES NEARLY ALL JOB POSTINGS INTERNALLY, AND EVALUATES INTERNAL EMPLOYEE APPLICANTS FOR A SUCCESSFUL JOB SKILL MATCH. EVALUATIONS ARE CONDUCTING USING THE SAME NON-DISCRIMINATORY GUIDELINES AS STANDARD HIRING PRACTICE. EMPLOYEES ARE PROVIDED WITH TRAINING OPPORTUNITIES TO INCREASE SKILL SET THROUGH A COMPANY-SPONSORED EDUCATION REIMBURSEMENT PROGRAM, COMPANY-PAID NATIONAL CABLE TELEVISION INSTITUTE AND SOCIETY OF CABLE TELECOMMUNICATIONS ENGINEERS COURSES, AND CAREER GUIDANCE FROM THE LEADERSHIP TEAM.




Attachment 16


Attachment 22
Description
Public file report