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                                   Before the

                       Federal Communications Commission

                             Washington, D.C. 20554

   In the Matter of )


   Drexel University ) File No. EB-11-PA-0195

   Licensee of Radio Station KLZ411 )

   Philadelphia, Pennsylvania ) NOV No. V201232400002



                              NOTICE OF VIOLATION

   Released:  October 7, 2011

   By the District Director, Philadelphia Office, Northeast Region,
   Enforcement Bureau:

    1. This is a Notice of Violation ("Notice") issued pursuant to section
       1.89 of the Commission's Rules to Drexel University, licensee of
       Private Land Mobile Station KLZ411 in Philadelphia, Pennsylvania.

    2. On September 29, 2011, an agent of the Enforcement Bureau's
       Philadelphia Office monitored radio transmissions on the frequency
       451.275 MHz from Station KLZ411 located at 34th and Race Streets,
       Philadelphia, Pennsylvania and observed the following violations:

     a. 47 C.F.R. S: 90.425(a): "Except as provided for in paragraphs (d) and
        (e) of this section, each station or system shall be identified by
        the transmission of the assigned call sign during each transmission
        or exchange of transmissions, or once each 15 minutes (30 minutes in
        the Public Safety Pool) during periods of continuous operation. The
        call sign shall be transmitted by voice in the English language or by
        International Morse Code in accordance with paragraph (b) of this
        section. If the station is employing either analog or digital voice
        scrambling, or non-voice emission, transmission of the required
        identification shall be in the unscrambled mode using A3E, F3E or G3E
        emissions, or International Morse, with all encoding disabled."
        Between 11:54 a.m. and 12:14 p.m. on September 29, 2011, the agent
        observed that Station KLZ411 did not transmit its call sign
        identification on the frequency 451.275 MHz using A3E, F3E or G3E

     b. 47 C.F.R. S: 1.903(a): "Stations in the Wireless Radio Services must
        be used and operated only in accordance with the rules applicable to
        their particular service as set forth in this title and with a valid
        authorization granted by the Commission under the provisions of this
        part, except as specified in paragraph (b) of this section." At the
        time of inspection, Drexel was operating a repeater station on the
        frequency 451.275 MHz from an unauthorized location.

    3. Pursuant to Section 403 of the Communications Act of 1934, as amended,
       and section 1.89 of the Commission's Rules, Drexel University must
       submit a written statement concerning this matter within 20 days of
       release of this Notice. The response must fully explain each
       violation, must contain a statement of the specific action(s) taken to
       correct each violation and preclude recurrence, and should include a
       time line for completion of pending corrective action(s). The response
       must be complete in itself and signed by Drexel University. All
       replies and documentation sent in response to this Notice should be
       marked with the File No. and NOV No. specified above, and mailed to
       the following address:

   Federal Communications Commission

   Philadelphia Office

   One Oxford Valley Building, Suite 404

   2300 East Lincoln Highway

   Langhorne, Pennsylvania 19047

    4. This Notice shall be sent to by Certified Mail/Return Receipt
       Requested and regular mail to Drexel University at its address of

    5. The Privacy Act of 1974 requires that we advise you that the
       Commission will use all relevant material information before it,
       including any information disclosed in your reply, to determine what,
       if any, enforcement action is required to ensure compliance. Any false
       statement made knowingly and willfully in reply to this Notice is
       punishable by fine or imprisonment under Title 18 of the U.S. Code.


   Gene J. Stanbro

   District Director

   Northeast Region

   Enforcement Bureau

   47 C.F.R. S: 1.89.

   Drexel University asserts that it was in compliance with the requirements
   of section 90.425(a) of the rules by transmitting the call sign
   identification by voice in the English language across the repeater
   system. However, all transmissions from the 451.275 MHz including the call
   sign identification were in a digital format using FXD and FXE emissions.
   Because Station KLZ411 employs non-voice emission, Drexel University must
   transmit the call sign by voice in the English language using A3E, F3E or
   G3E emissions or in International Morse Code.

   The license authorizes Drexel University to operate its 451.275 MHz
   station from 32nd and Chestnut Streets, Philadelphia, Pennsylvania at the
   coordinates 39-57-08.4 North Latitude 075-09-49.6 West Longitude. Drexel
   University was actually operating the 451.275 MHz station from 34th and
   Race Streets, Philadelphia, Pennsylvania near the coordinates 39-57-30
   North Latitude 075-11-29 West Longitude.

   47 U.S.C. S: 403.

   P.L. 93-579, 5 U.S.C. S: 552a(e)(3).

   18 U.S.C. S: 1001 et seq.

   Federal Communications Commission


                       Federal Communications Commission