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                                      THE FACTS

         The station is organized with the General Manager as the Chief Executive Officer.

(See Table of Organization, Er.Ex. 1, Tr. 72). under the General Manager are various

departments: Programming headed by the Program Director is responsible for all the station's

Programming.  The Program Director and General Manager are paid and excluded from the unit.

(Tr. 33-35).  Programming is in turn divided into departments by interest: Public Affairs; Arts 

and Culture, News.  These three departments each have directors - all three are paid and in the

bargaining unit.  A number of paid employees are on-air hosts and producers of programs in these

departments and report to the department heads and the Program Director. In the News Department

there are paid employees who function as editors, reporters and producers. In addition, there is 

an Operations Department that maintains the studio facilities, does production work and 

engineering and console board operation for the broadcasts. (Tr. 36-38).  The head of the 

department, the Operations Director, is in the bargaining unit.  He supervises the chief

engineer, operations assistant, two production engineers, and receptionist and maintenance

engineer, all of whom are paid and in the bargaining unit.

         The Development Director is in charge of direct mail, renewals of subscriptions

(i.e., contributions from the listening public) telemarketing and off-air fundraising.  The

Development Director is excluded from the unit.  She oversees a paid 

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