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Those assignments were consummated on March 26, 1996. On April 8, 1999, the Commission granted the  ! applications to assign the licenses for stations KCIT(TV) and KJTLTV to Mission Broadcasting of Amarillo, Inc. and Mission Broadcasting of Wichita Falls, Inc., respectively (File Nos. BALCT981228IE and BALCT981228IK).  to ensure that the management  !/personnel at their respective stations were aware of, and had established procedures to comply  !<with, the children's television commercial limits. Based on these considerations, we determined  ![that "two separate but related serious failures of licensee responsibility with regard to the  !children's television commercial limits vitiate[d] any mitigating effect that might arise from the  !plicensees' overall record of compliance with other Commission rules," and ordered Petitioners to forfeit $15,000 each to the United States. ",-(-(ZZL"Ԍ x6. Now, in their Joint Petition, Petitioners ask that we reconsider the conclusions reached  X4 !Rin KCIT/KJTL Order and reduce the forfeitures against them accordingly. Specifically, they  !"contend that a licensee's failure to comply with the children's television commercial limits, even  !if the failure is repeated, does not itself demonstrate that the licensee had no compliance program  !4in place. Asserting that they did not willfully neglect their responsibilities as Commission  !licensees, Petitioners state that they had programs designed to monitor compliance with the  !commercial limits in place at their stations at the time the overages occurred. However, given  !the small size of the markets in which the stations are located and the economics of operating  !Ismallmarket stations, Petitioners claim that the best compliance program each station was able  X34 !to implement highly depended upon the personnel charged with monitoring the program.3 yO ' ! ԍ Petitioners maintain that the size of the market in which a station provides service and the economics of  !o operating a smallmarket station are factors which the Commission has previously considered in reducing forfeitures,  ! particularly when the station is losing money. Along this line, they claim that stations KCIT(TV) and KJTLTV  !! were losing money, and state that their "review of financial spreadsheets from this period reveals that the combined  ! net loss for the stations in 1992 was over $400,000." However, to the extent Petitioners assert that stations  ! KCIT(TV) and KJTLTV were experiencing financial hardship at the time the overages occurred, thereby preventing  !g the implementation of more effective compliance programs, they provide no documentation in support of that  {O$' ! assertion. Compare Delta Radio Corp., 12 FCC Rcd 22030 (CIB 1997) and Benito Rish, 10 FCC Rcd 2861 (1995)  ! (licensees asserting inability to pay as a basis for reduction of fofeitures assessed against them submitted supporting documentation of financial hardship). As a  !consequence, Petitioners maintain, the stations' overages resulted from human error in managing  !the existing compliance programs. Thus, Petitioners contend, it is error to subject stations  !KCIT(TV) and KJTLTV to forfeiture amounts based on an assumption that the stations lacked  !compliance programs when the overages, instead, reflect a shortcoming in the programs themselves.  x7. Petitioners also request that we reconsider our conclusion that the number of overages  !reported by stations KCIT(TV) and KJTLTV vitiated the mitigating effect of the licensees' past  !record of compliance with the Commission's Rules. Referring to the "Bureau's admitted failure"  !to consider their history of compliance in assessing the forfeiture amounts at issue, Petitioners  !argue that a reduction in the amount of the forfeiture is warranted based on that consideration.  X4|DISCUSSION  x8. Preliminarily, we note that it is, in fact, the efficacy of a licensee's compliance  !program, not the mere presence of a program, that we look to when assessing a forfeiture for  !Rviolations of the children's television commercial limits. To wit, it was the deficiencies in the  !<Petitioners' compliance programs, not the lack of a program at each station, that we recognized  X~4 !"in KCIT NAL and KJTL NAL, when we stated that "initially [KCIT Company and BSP] did not  Xi4 !}establish an effective program to monitor compliance with the Commission's commercial limits."  XT4 ![emphasis added]i Tb  {Og&'ԍ KCIT NAL, 9 FCC Rcd 1827; KJTL NAL, 9 FCC Rcd 1829.i  Clearly, the compliance programs at stations KCIT(TV) and KJTLTV were  !}not effective, as the stations violated the commercial limits on 75 and 70 occasions, respectively,"= ,-(-(ZZ"  !<during a tenmonth period. That the violations went undiscovered until after the Petitioners had  !filed their renewal applications, where they had initially certified to compliance with the  ! commercial limits, further attests to the shortcomings in both the Petitioners' compliance  !programs and the procedures for monitoring those programs. Indeed, the Petitioners concede to  !Ethe shortcomings in their compliance programs and argue, not that the Commission acted, or  !would have acted, inappropriately in considering the efficacy of their compliance programs to  !Idetermine the forfeiture amounts, but that it was error to base the forfeitures on the assumption  X_4 !that the stations lacked such programs. In KCIT NAL and KJTL NAL, because we considered  XJ4 !gwhether Petitioners established effective compliance programs to determine the forfeiture amounts  !at issue here, we acted appropriately and in a manner consistent with Commission precedent. In  X 4 !this regard, we note here, as we did in KCIT NAL and KJTL NAL, the Commission's expectation  !that, in delaying the effective date of Section 73.670, broadcasters and cable operators would  !<have additional time within which to hone their plans to ensure compliance with the commercial  X 4 !limits. See id., citing Children's Television Programming, 6 FCC Rcd 5529, 5530 n.10 (1991).  !The fact that, even with the benefit of that additional time, Petitioners' programs had  X 4 !Eshortcomings which resulted in a high number of violations at their stations does not warrant reduction in the forfeiture amounts.  x9. Next, we disagree with Petitioners' assertion that we failed to consider their history  XS4 !of compliance with the Commission's Rules. Rather, in KCIT/KJTL Order, we appropriately  !/considered Petitioners' past records of compliance in the context of their requests for reduction  !pof the forfeiture amounts. However, based on the facts and circumstances of the instant cases,  !we determined that, on balance, Petitioners' overall history of compliance with the Commission's  !IRules neither necessitated nor justified a reduction of the specified forfeiture amounts. Initially,  !we note that Section 503 of the Communications Act affords the Commission a great deal of  X4 !qdiscretion in determining forfeiture amounts.s ^ {OD' ! ԍ See Triple X Broadcasting Co., Inc., 46 RR2d 788, 789 (B/C Bur. 1979), citing Brennan Broadcasting Co.,  {O' ! 25 FCC 2d 400 (1970); Southern California Broadcasting Co. (KIEV(AM)), 6 FCC Rcd 4387, 4388 (1991), recon.  {O'denied, 7 FCC Rcd 3454 (1992).s Further, while Section 503(b)(2) of the  !pCommunications Act requires us to consider a licensee's history of prior offenses in determining  !a forfeiture amount, it does not mandate that we mitigate a forfeiture amount should the licensee  !have no history of prior offenses. A licensee's compliance history must be considered along with  !uthe other factors set forth in Section 503(b)(2), namely, but not limited to, the number and  !/duration of the commercial overages, the period of time over which they occurred and whether  !the licensee had established an effective compliance program. Given the high number of total  X*4 !/overages in each case, the duration of those overages, see supra nn.1 and 2, the extended ten !month period over which they occurred without detection and the deficiency in the Petitioners'  !compliance programs, it was within our discretion to determine that a forfeiture in the amount  !Vof $15,000 against each licensee was appropriate. In view of these same considerations, and in  !light of the separate but related failures of licensee responsibility with respect to the children's  !ctelevision commercial limits due to the fact that the Petitioners were commonly controlled at the  X"4 !qtime the violations on each station occurred, see supra  5 and n.7, we likewise acted"" ,-(-(ZZ "  X4 !appropriately in KCIT/KJTL Order by finding that Petitioners' "unblemished" records of  X4 !&compliance with the Commission did not warrant a reduction of the assessed forfeiture amounts. \ yOd' ! ԍ In fact, had Petitioners' records of compliance not been "unblemished," it is possible that higher forfeiture  {O,' ! amounts would have been assessed for their stations' violations of the children's television commercial limits. See  {O'Forfeiture Guidelines, 12 FCC Rcd at 171001.  X4 !For these reasons, we affirm our decision in KCIT/KJTL Order that, given the totality of the facts  !pand circumstances in the instant cases, Petitioners' history of compliance with the Commission's Rules does not warrant a reduction in the amount of the forfeitures.  !  Xz4whCONCLUSIONc  x10. Therefore, we conclude that the arguments contained in the Joint Petition for  X54 !cReconsideration of our decision in KCIT Acquisition Co. (KCIT(TV))/BSP Broadcasting, Inc.  X 4 !(KJTLTV), 12 FCC Rcd 20376 (MMB 1997), affirming the $15,000 forfeitures assessed in KCIT  X 4 !Acquisition Co., 9 FCC Rcd 1827 (1994) and BSP Broadcasting, Inc., 9 FCC Rcd 1829 (1994), do not warrant or necessitate a reduction of those forfeiture amounts.  xu11. Accordingly, IT IS ORDERED THAT the Joint Petition for Reconsideration filed by KCIT Acquisition Company and BSP Broadcasting, Inc. IS DENIED.  x12. IT IS FURTHER ORDERED THAT, pursuant to Section 503(b) of the  !_Communications Act of 1934, as amended, 47 U.S.C.  503(b), KCIT Acquisition Company  !uFORFEIT to the United States the sum of fifteen thousand dollars ($15,000) for repeated  !yviolations of Section 73.670 of the Commission's Rules, 47 C.F.R.  73.670. Payment of the  !forfeiture may be made by mailing to the Commission a check or similar instrument payable to  !_the Federal Communications Commission. With regard to this forfeiture against KCIT(TV),  !KCIT Acquisition Company may take any of the actions set forth in Section 1.80 of the  !Commission's Rules, 47 C.F.R.  1.80, as summarized in the attachment to this Memorandum Opinion and Order.  x13. IT IS FURTHER ORDERED THAT, pursuant to Section 503(b) of the  !4Communications Act of 1934, as amended, 47 U.S.C.  503(b), BSP Broadcasting, Inc.,  !uFORFEIT to the United States the sum of fifteen thousand dollars ($15,000) for repeated  !yviolations of Section 73.670 of the Commission's Rules, 47 C.F.R.  73.670. Payment of the  !forfeiture may be made by mailing to the Commission a check or similar instrument payable to  !the Federal Communications Commission. With regard to this forfeiture against KJTLTV, BSP Broadcasting, Inc., may take any of the actions set forth in Section 1.80 of the Commission's " ,-(-(ZZ"  !ERules, 47 C.F.R.  1.80, as summarized in the attachment to this Memorandum Opinion and Order. ` `  ,hh]FEDERAL COMMUNICATIONS COMMISSION ` `  ,hh]Roy J. Stewart ` `  ,hh]Chief, Mass Media Bureau