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Federal Communications Commission
Washington, D.C. 20554
In the Matter of )
File No. EB-04-TC-067
Channel 51 of San Diego, Inc. )
Facility ID No. 10238
Licensee of KUSI-TV )
NAL/Acct. No. 200532170007
San Diego, CA )
Apparent Liability for Forfeiture )
Adopted: September 17, 2008 Released: September 17, 2008
By the Chief, Enforcement Bureau:
1. In this Forfeiture Order ("Order"), we issue a monetary forfeiture in
the amount of twenty-five thousand dollars ($25,000) against Channel
51 of San Diego, Inc. ("Channel 51" or "KUSI" or the "Station") for
willfully or repeatedly violating section 713 of the Communications
Act of 1934, as amended (the "Act"), and section 79.2(b)(1)(i) of the
Commission's rules. Channel 51 violated the Act and the Commission's
rules by failing in a timely manner to make accessible to persons with
hearing disabilities emergency information that it provided aurally in
its programming for KUSI during a wildfire emergency in the San Diego,
California area on October 26 and October 27, 2003.
2. The facts and circumstances surrounding this case are set forth in the
Notice of Apparent Liability previously issued by the Enforcement
Bureau ("Bureau") and need not be reiterated at length. After
receiving a complaint, the Bureau sent an inquiry to Channel 51
concerning allegations that KUSI may have failed to make information
on wildfires in the San Diego area on October 26 and October 27, 2003,
accessible to persons with hearing disabilities. To assist its
evaluation of these allegations, the Bureau directed Channel 51 to
provide, among other things, videotapes of its coverage of the
wildfires on KUSI. Channel 51 filed a response to the LOI on July 9,
2004, and subsequently provided the videotapes. Upon review of the
videotapes, the Bureau found that Channel 51 failed to provide visual
presentation of emergency information about the wildfires on numerous
occasions where the information had been aurally presented. The Bureau
elected, however, to propose a forfeiture for only those apparent
violations where Channel 51 provided visual presentation of emergency
information, if at all, after a delay of greater than 30 minutes after
the same information was provided aurally. Under this approach, the
Bureau identified 22 examples where Channel 51 left persons with
hearing disabilities without the same critical information the station
gave to its listening audience. The Bureau further determined that a
strict application of the $8,000 base forfeiture amount for the 22
apparent violations of section 79.2(b)(1)(i) would result in a total
proposed forfeiture "that is excessive in light of the circumstances
presented." Accordingly, on February 23, 2005, the Bureau issued a
Notice of Apparent Liability for Forfeiture proposing that Channel 51
pay a forfeiture of twenty-five thousand dollars ($25,000) for
apparently failing in a timely manner to make accessible to persons
with hearing disabilities emergency information that it provided
aurally. Channel 51 filed a complete response to the NAL on May 10,
3. Section 713 of the Act requires the Commission to prescribe rules on
Video Programming Accessibility. Pursuant to section 713, the
Commission adopted section 79.2 which requires that video programming
distributors providing emergency information in the audio portion of
programming must provide persons with hearing disabilities with the
same access to such information that distributors provide to other
viewers, either through a method of closed captioning or by using
another method of visual presentation. The Commission defined
emergency information as "information, about a current emergency, that
is intended to further the protection of life, health, safety, and
property, i.e., critical details regarding the emergency and how to
respond to the emergency." As examples of critical details, the
Commission cited "evacuation orders, detailed descriptions of the
areas to be evacuated, ...approved shelters or the way to take shelter
in one's home,...road closures." As discussed in the NAL, the
Commission mandated equal accessibility because emergency information
is of "equal or greater importance to persons with hearing disability
and television plays a critical role in its dissemination."
4. In its NAL Response, Channel 51 makes several general arguments
challenging the Commission's proposed finding that the 22 cited
examples found in the NAL were violations of the Commission's rules.
In addition, Channel 51 specifically addresses each of the 22 cited
examples with either a reiteration of the station's general arguments
and/or contentions of the facts surrounding the apparent violations
described. For the reasons discussed below, we generally disagree with
the arguments put forth by the Station.
A. General Arguments
5. Before addressing each of the specific alleged rule violations cited
in the NAL, Channel 51 contends that professional journalists must act
as "filters" in deciding what information constitutes the "critical
details" of an emergency within the meaning of section 79.2. According
to the Station, the Commission should therefore accord substantial
deference to the "filtering" of news by these professionals in order
to effectively implement the Commission's rules. The Station argues
that this "filtering" role allows it to determine which information is
sufficiently important and sufficiently confirmed to justify providing
that information to persons with hearing disabilities. Specifically,
the Station maintains that if information regarding an emergency is
not provided as a part of an official order or from an official
requesting help in disseminating the information to the public, then
the information need not be visually presented even if it has been
provided aurally. As a basis for this position, the Station contends
that it would be dangerous to provide this information to persons with
hearing disabilities unless a responsible authority was employing the
media to communicate a specific order to evacuate a specific location.
The Station, however, makes much of its role disseminating this
information to the hearing public and obviously did so with the intent
of aiding in the protection of the life, health, and property of
viewers during the emergency created by the wildfires. In fact,
without receiving police orders, Channel 51 did broadcast aural advice
that persons should evacuate when they saw flames near their houses.
The Station does not explain why it believes it was not "dangerous"
and "irresponsible" to provide unfiltered information about the
wildfires to the public at large, but it would have been "dangerous"
and "irresponsible" to have provided this same information visually to
persons with hearing disabilities.
6. Although we generally agree that deference should be given to Channel
51 in how to meet the requirements of section 79.2 of our rules, we
cannot defer to a decision not to provide the very critical details
noted in our rules. The Commission's rules define emergency
information as the critical details regarding the emergency and how to
respond to the emergency. The rules offer as examples of those
critical details evacuations orders and areas being evacuated.
Contrary to Channel 51's representations, the rule does not limit
emergency information to only those evacuation orders that a public
official has asked the station to disseminate. Rather, the
Commission's rules emphasize the potentially broad spectrum of
critical details that may represent emergency information. The
apparent violations cited in the NAL reflect the type of critical
details the Commission intended to be aurally and visually presented
to viewers, e.g., road closures, areas being evacuated, evacuation
sites, etc. The Station's rationale that it would be "dangerous" and
"irresponsible" not to filter these details for persons with hearing
disabilities while providing them to the public at large is untenable.
If the aural reports of evacuations were safe enough to provide to the
hearing members of the public, these same reports should have been
furnished to persons with hearing disabilities so those individuals
could protect themselves. The Commission simply cannot support a
decision to withhold from persons with hearing disabilities those very
critical details concerning the emergency that Channel 51 provided to
7. Channel 51 further contends that the Station was required to confirm
emergency information presented aurally before presenting it visually
because the journalistic core obligation of providing accurate
information was heightened by the "special obligation" to hearing
impaired viewers imposed by section 79.2. The Station also asserts
that there is a fundamental journalistic difference between presenting
information aurally and visually. The station claims that viewers give
more weight to visual presentations, treating them as though they have
the force of written text. The Station, however, offers no support for
this proposition. Section 79.2 imposes an obligation to provide
hearing impaired viewers access to emergency information at the same
time it is made available to other viewers. Thus, the rule in no way
allows or encourages programmers to hold back emergency information
from hearing impaired viewers. In the Second Report and Order, the
Commission reiterated the importance of providing all viewers with
accurate information regarding an emergency. Therefore, if the Station
had any concerns about the accuracy of the emergency information being
presented, Channel 51 had an option, and in fact a duty under its
journalistic obligation, to hold back the visual and aural
presentations until the emergency information had been confirmed.
Channel 51, however, clearly believed the emergency information was
accurate and important enough to provide to hearing members of the
public. Since this information is of equal or greater importance to
hearing impaired viewers, they should have been furnished and
entrusted with the same emergency information. As a result of its
decision to not visually present emergency information that had been
aurally presented, the Station failed to meet its obligation to
hearing impaired viewers.
8. While we appreciate that programmers make good-faith judgments in
times of emergency, the resulting decisions should conform to the
Commission's rules. The importance of providing critical details to
hearing and hearing impaired persons is too important for programmers
to assume that such decisions will never be challenged by the
Commission. As previously discussed in the NAL, it is not reasonable
to assume that the Commission's statement in the Second Report and
Order indicates the Commission will completely defer to the judgment
of programmers in terms of whether particular details of an emergency
need to be made accessible to hearing impaired viewers. Such an
expansive interpretation would swallow the rule, render it
ineffective, and could potentially leave hearing impaired viewers at
risk during future emergencies since programmers would have no
incentive to establish measures that would ensure their ability to
provide emergency information to hearing and hearing impaired viewers
at nearly the same time. For these reasons, we disagree with the
Station's argument that the Commission should not subsequently
challenge decisions made by programmers during emergency broadcasts.
9. Finally, the Station contends that it did in fact provide extensive
visual presentations of emergency information during its coverage on
October 26 and 27. For example, Channel 51 outlines that it made
extensive use of full screen maps, visual displays of road closings
and live shots. As explained in the NAL, however, in order for a video
programming distributor to meet its obligation to provide persons with
hearing disabilities with the same access to emergency information as
provided to listeners, that visual presentation of that emergency
information must be "simultaneous or nearly simultaneous" to the aural
presentation of that information. To accommodate for the circumstances
facing KUSI in providing emergency coverage during the wildfires, we
stated that we would not find violations if visual information was
provided within 30 minutes either before or after the same information
was provided aurally. Although we note the Station's attempts to
provide some visual presentation of emergency information, we believe
that Channel 51 will most improve emergency coverage when it adheres
to a policy consistent with the Commission's rules-all emergency
information should be presented in a manner that provides hearing and
hearing impaired viewers with the same access to the information.
B. Specific Rule Violations
10. We now turn to the arguments Channel 51 makes in response to the rule
violations cited in the NAL. Eleven of the apparent rule violations
cited in the NAL concern evacuation orders, five concern road
closures, four concern shelter information, and four concern air
quality advisories. Of these violations, the Station believes that
only one is a violation of section 79.2. To avoid repetition, we
address several examples from the general groups below.
11. Apparent Violations 1, 3, 5, 6, 8, 9, 11, 12, 18, 19, 21 listed in the
Appendix of the NAL all involve evacuation orders. By way of example,
we will address Apparent Violations 8 and 9 from this subset.
Violation 8 addressed Channel 51's apparent failure to provide a
visual presentation of evacuations of Hidden Trails Road, Rancho San
Pasqual and Cloverdale in Escondido. The station aurally provided this
emergency information at 3:41 p.m. on October 26, 2003, but did not
provide the information visually until 10:21 p.m. that evening. The
Station contends that its actions did not violate section 79.2 of the
Commission's rules because the evacuation information was obtained
from an AP wire and not from law enforcement officials conducting the
evacuations. Because the information was not confirmed by the news
department with the responsible authorities and because the
evacuations reported by the Associated Press appeared to have taken
already taken place, the Station contends that the information
amounted to "nothing more than a general news report of the fact that
there had been some evacuation in the area of Escondido." The station
argues that these types of "general news reports" do not fall within
section 79.2 and do not warrant posting on a full screen board or by
other visual means.
12. Violation 9 addresses the Station's apparent failure to provide a
visual presentation of evacuations on Mission Gorge Road. According to
the Station, this failure is not a violation of section 79.2 because
the evacuation information was obtained by one of its reporters who
happened to be on the scene when the police announced a mandatory
evacuation. The Station reasons that this information was known to
KUSI only because it had a reporter in the area when the police came
through to inform residents of the need to evacuate. The Station
states that it did not have any information concerning how extensive
the evacuation area was, what specific areas within the area were
being evacuated, what routes residents were to use to evacuate, and
where they should evacuate to. The Station further contends that more
importantly it did not receive a specific request from the public
officials conducting the evacuation to broadcast the evacuation
information and that the evacuation was carried out by the public
officials without need for assistance from the media.
13. As stated above, section 79.2 does not limit emergency information
only to evacuation orders that a public official has asked the media
to disseminate. Furthermore, regarding Violation 8, we note that the
Station's actions did not portray its broadcast of the evacuation
order as "business as usual" or that that its newscasters were merely
reporting a general news story. For at least two days the Station
canceled all of its regular programming and focused exclusively on the
wildfires. The newscasters presented the information concerning the
evacuation in an authoritative manner telling viewers that "Escondido
now has evacuations going on." Regarding Violation 9, there obviously
was no question of the Station needing to confirm the evacuation
information with authorities; the Station's newscaster was on the
scene and literally heard the police announcement that evacuations
where taking place in the area. The Station does not contend that it
was merely passing on a general news report, but clearly provided the
information aurally to give viewers critical details of the emergency
situation, i.e., a mandatory evacuation order, so they could take
appropriate action. The information described in Violations 8 and 9
fall squarely within the scope section 79.2. We therefore conclude
that Channel 51 violated section 79.2 by denying the Station's hearing
impaired viewers access to the same critical details concerning these
emergency situations that it gave its hearing viewers.
14. Apparent Violations 2, 4, 7, and 14 all involve road closures. By way
of an example we will address Violations 2 and 14 from this subset.
Violation 2 addresses the Station's apparent failure to provide
individuals with hearing disabilities the same critical information it
provided to hearing listeners regarding the closure of Scripps Poway
Parkway. At approximately 8:14 a.m. on October 26, 2003, a newscaster
on location stated that Scripps Poway Parkway was closed. According to
the Station, its failure to make a visual presentation of this
information does not violate section 79.2 because the road closure
information at issue was not provided to the reporter by the
authorities, was not personally witnessed by the reporter, and seems
to be based on information the reporter obtained from members of the
public. The Station further states that it was reasonable and proper
not to visually present this information because it was unclear
exactly what road was closed, Scripps Poway Parkway or 67; the road
closure information was not "official information," and the
information was not confirmed by its news department.
15. Violation 14 addresses the Station's apparent failure to provide
individuals with hearing disabilities the same critical information it
provided to hearing listeners regarding the closure of Routes I-8,
I-15, 52, 163, 94, and 67. The Station aurally provided this
information at 9:54 p.m. on October 26, 2003; it provided visual
presentation of some of the emergency information at 10:43 p.m., but
did not provide visual presentation of the remaining emergency
information until 12:11 a.m. on October 27, 2003. The Station contends
that it did not violate section 79.2 by failing to make a visual
presentation of this information because the road closure information
had been visually presented approximately fifteen times earlier during
the day. The Station further reasons that the NAL interprets section
79.2 to require that "emergency information must be timed so that
either (1) the visual and auditory information airs at the same time,
or (2) the visual information airs within a short time after the
auditory." The Station believes that not only is this finding
arbitrary, but it is not how a good broadcast news operation rotates
the scheduling of emergency information for broadcast. The Station
states that it is desirable, in the majority of instances, to stagger
the visual and auditory presentation of the same information so that
the information will appear at a greater number of times during the
broadcast, thereby reaching a greater number of viewers.
16. We disagree with the Station's reasoning concerning Violations 2 and
14. First, in regard to Violation 2, the news reporter on location
said as follows: "We know that Scripps Poway Parkway is blocked off
and the CHP is sending people, uh, you can get through Poway Road to
67 and then it's sort of clear down to 67 or up from North through but
it is closed at Scripps Poway Parkway." If the Station had concerns
about the accuracy of the information it should had withheld the aural
along with the visual presentation until the emergency information
could be confirmed. Instead it aired the aural information without so
much of a warning that the information was unconfirmed by public
officials or its news department. The Station believed that the road
closure information was accurate and important enough to provide its
hearing viewers, therefore, under section 79.2 this information should
have been presented in an accessible format for its hearing impaired
17. Secondly, section 79.2 requires that all emergency information be
presented in a manner that provides hearing and hearing impaired
viewers with the same access to the information, whether the visual
presentation is aired shortly before, along with, or shortly after the
auditory presentation. The Station's reasoning, in regard to Violation
14, fails to recognize that without visual presentation of the
emergency information each time the information is aired even if
staggered, the auditory presentation does not allow persons with
hearing disabilities to receive the emergency information. While this
approach may provide hearing viewers with more access to emergency
information, it does not provide hearing impaired viewers with the
same access in violation of section 79.2. We therefore conclude that
Channel 51 violated section 79.2 of the Commission's rules by failing
to provide a visual presentation of the emergency information aurally
regarding road closures described in Violations 2 and 14 of the NAL.
18. We see no need to address the remainder of the Station's arguments
regarding the specific violations set forth in the Appendix of the
NAL. Essentially, the Station repeated in whole or in part the general
arguments addressed we have already addressed at length. In addition,
we note that in the NAL we found that $8,000 was the proper base
forfeiture amount for violations of 79.2(b)(1)(i) of the Commission's
rules. We determined, however, that a strict application of $8,000 for
each of the 22 apparent violations would result in a total proposed
forfeiture that is excessive in light of the circumstances presented.
Furthermore, in determining the total number of apparent violations,
we took into consideration the circumstances facing KUSI in providing
emergency coverage during the wildfires. For example, we did not
propose forfeitures for all of Channel 51's failures to provide visual
presentation of emergency information, including failures relating to
specific critical details identified in our rules, such as school
closings and how to obtain relief assistance. We also determined not
to find violations if visual information was provided within 30
minutes either before or after the same information was provided
aurally. Applying the $8,000 base forfeiture amount to just the
specific violations addressed above still results in a forfeiture
amount that is significantly less than the $160,000 that could have
been proposed for these violations. Furthermore, assessing the full
$8,000 for a limited number of violations is consistent with past
Commission orders. We, therefore, see no reason to reduce the
forfeiture amount proposed in the NAL and find that the Station is
liable for a forfeiture amount of $25,000.
IV. ordering clauses
19. ACCORDINGLY, IT IS ORDERED, pursuant to Section 503(b) of the
Communications Act of 1934, as amended, Section 1.80(f)(4) of the
Commission's rules, and authority delegated by Sections 0.111 and
0.311 of the Commission's rules, that Channel 51 of San Diego, Inc. IS
LIABLE FOR A MONETARY FORFEITURE in the amount of twenty-five thousand
dollars ($25,000) for willful or repeated violations of section 713 of
the Act, 47 U.S.C. S: 713, and section 79.2(b)(1)(i) of the
Commission's rules, 47 C.F.R. S: 79.2(b)(1)(i), as described in the
20. Payment of the forfeiture shall be made in the manner provided for in
section 1.80 of the Commission's rules, 47 C.F.R. S: 1.80, within
twenty (20) days of the release date of this Order. If the forfeiture
is not paid within the period specified, the case may be referred to
the Department of Justice for collection pursuant to section 504(a) of
the Act. Payment of the forfeiture must be made by check or similar
instrument, payable to the order of the Federal Communications
Commission. The payment must include the NAL/Account Number and FRN
Number referenced above. Payment by check or money order may be mailed
to Federal Communications Commission, P.O. Box 979088, St. Louis, MO
63197-9000. Payment by overnight mail may be sent to U.S. Bank -
Government Lockbox #979088, SL-MO-C2-GL, 1005 Convention Plaza, St.
Louis, MO 63101. Payment by wire transfer may be made to ABA Number
021030004, receiving bank TREAS/NYC, and account number 27000001. For
payment by credit card, an FCC Form 159 (Remittance Advice) must be
submitted. When completing the FCC Form 159, enter the NAL/Account
number in block number 23A (call sign/other ID), and enter the letters
"FORF" in block number 24A (payment type code). Channel 51 of San
Diego, Inc. will also send electronic notification on the date said
payment is made to Johnny.firstname.lastname@example.org. Requests for full payment
under an installment plan should be sent to: Chief Financial Officer
-- Financial Operations, 445 12th Street, S.W., Room 1-A625,
Washington, D.C. 20554. Please contact the Financial Operations
Group Help Desk at 1-877-480-3201 or Email: ARINQUIRIES@fcc.gov with
any questions regarding payment procedures.
21. IT IS FURTHER ORDERED that a copy of this Order shall be sent by
Certified Mail, Return Receipt Requested to J. Brian DeBoice, Esq.,
Cohn and Marks LLP, 1920 N Street, N.W., Suite 300, Washington, D.C.
FEDERAL COMMUNICATIONS COMMISSION
Kris A. Monteith
Chief, Enforcement Bureau
See 47 U.S.C. S: 503(b)(4)(A). The Commission has authority under this
section of the Act to assess a forfeiture penalty against a broadcast
licensee if the Commission determines that the licensee has "willfully or
repeatedly" failed to comply with the provisions of the Act or with any
rule, regulation, or order issued by the Commission under the Act. For a
violation to be willful, it need not be intentional. Southern California
Broadcasting Co., 6 FCC Rcd 4387 (1991).
47 U.S.C. S: 613.
47 C.F.R. S: 79.2(b)(1)(i).
Channel 51 of San Diego, Inc., Notice of Apparent Liability for
Forfeiture, 20 FCC Rcd 3969 (2005) ("NAL").
Letter from Colleen K. Heitkamp, Chief, Telecommunications Consumers
Division, Enforcement Bureau, FCC, to Michael D. McKinnon, Vice President
and Station Manager, KUSI News (May 26, 2004) ("LOI").
Letter from Robert B. Jacobi, Counsel for Channel 51, to Peter G. Wolfe,
Senior Attorney, FCC (July 9, 2004) ("LOI Response").
NAL, 20 FCC Rcd at 3974, para. 11.
Id. at 3975, para. 15.
Letter to Colleen Heitkamp, Chief, Telecommunications Consumers Division,
Enforcement Bureau, Federal Communications Commission, from J. Brian
DeBoice, Cohn & Marks (May 10, 2005)("NAL Response").
47 U.S.C. S: 613.
47 C.F.R. S: 79.2(b)(1)(i).
47 C.F.R. S: 79.2(a)(2).
Note to 47 C.F.R. S: 79.2(a)(2).
NAL, 20 FCC Rcd at 3972, para. 6 (citing the Second Report and Order, 15
FCC Rcd 6615, 6619-6620).
NAL Response at vi.
Id. at 4-5.
Id. at 4-6.
Id. at 6-11.
NAL Response at 10, 33, 48 (arguing that the Commission's rules only
require visual presentation of evacuation information when the information
is provided to the Station in an official evacuation order).
Id. at 7-9, 32-33, 56, 80 (arguing the station was not asked by an
official to disseminate evacuation information to the public).
Id. at 10-11.
Id. at 4. KUSI refers to an award received from the International
Association of Fire Fighters that reads "The news team stayed on the air
for up to 19 hours a day, tracking the path of the flames, reporting the
valiant efforts of the fire fighters to control the blazes, and relaying
vital instructions from public safety officials to citizens on evacuation
routes and more. The video is indicative of the support that KUSI
Television regularly provides to members of San Diego, CA local 45." See
also NAL Response at 83-87.
This statement was made at 12:55 p.m. on October 26. It should be noted
that the tape containing this advice was not provided to the Bureau in
response to its Letter of Inquiry, and was not available at the time the
Bureau released its NAL. If the tape (and seven others) had been provided
on a timely basis, more violations might have been found.
See 47 C.F.R. S: 79.2(a)(2).
Id.; see also Note to 47 C.F.R. S: 79.2(a)(2).
NAL Response at 14.
Id. at 12 (noting that the force of the visual presentation is like a
"call to action").
See Second Report and Order, 15 FCC Rcd 6615.
Second Report and Order, 15 FCC Rcd at 6619 (noting the importance of
providing accurate information was addressed in the Report and Order and
Further Notice of Proposed Rulemaking).
See NAL, 20 FCC Rcd at 3974, para. 12 (quoting the Second Report and
Order, 15 FCC Rcd 6615 at 6617).
NAL Response at 15-18.
NAL, 20 FCC Rcd at 3974, para. 11.
See NAL Response at 6; See also NAL, 20 FCC Rcd 3969, at Appendix A. We
note that Apparent Violation 1 addresses both a road closure and an
evacuation order violation and Apparent Violation 11 addresses both an
evacuation order and emergency shelter violation.
NAL Response at 76-77. The station acknowledges that it failed to visually
display a warning from the County Board of Supervisors that residents of
parts of Eastern County should disinfect their water. In regard to
Apparent Violation 10, we agree with the Station that in there is no need
to visually present information given by a public official regarding
details of an emergency situation when station reporters immediately
recognize that the information is erroneous.
NAL, 20 FCC Rcd 3969, at Appendix A.
NAL Response at 54.
NAL Response at 55.
Id. at 55-56.
Id. at 54.
NAL Response at 34; see also, NAL, 20 FCC Rcd 3969, at Appendix A.
NAL Response at 34-36.
NAL, 20 FCC Rcd 3969, at Appendix A.
NAL Response at 63.
Id. at 63-64.
NAL, 20 FCC Rcd at 3974, para. 11.
See for example Fox Television, Inc. Licensee of WTTG (TV) Washington, DC,
DA 05-1513, Apparent Liability for Forfeitre, 20 FCC Rcd. 9847 (2005);
Waterman Broadcasting Corp. of Florida, Inc., DA 05- 2258, Apparent
Liability for Forfeiture, 20 FCC Rcd. 13534 (2005).
47 U.S.C. S: 503(b).
47 C.F.R. S: 1.80(f)(4).
47 C.F.R. S:S: 0.111and .0.311.
(...continued from previous page)
Federal Communications Commission DA 08-2107
Federal Communications Commission DA 08- 2107