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Federal Communications Commission
Washington, D.C. 20554
In the Matter of ) File No.: EB-SED-13-00008489
TowerCom III, LLC ) Acct No.: 201432100015
) FRN: 0006877302
Adopted: March 27, 2014 Released: March 28, 2014
By the Acting Chief, Enforcement Bureau:
1. The Enforcement Bureau (Bureau) of the Federal Communications
Commission (Commission) has settled its investigation into whether
TowerCom III, LLC (TowerCom) complied with Commission rules requiring
that parties applying to construct antenna structures consider whether
the proposed construction would affect the environment or historic
properties. Under these rules, an antenna structure applicant must
evaluate the potential adverse effects its proposals will have on the
environment or historic properties and mitigate any effects prior to
construction. TowerCom performed the required evaluation prior to
construction of the subject structure, but submitted an antenna
structure registration to the Commission that indicated incorrectly
that the proposed structure would have no significant environmental
impact. The company subsequently disclosed this error to the
Commission voluntarily and agreed to implement a robust three-year
plan to ensure future compliance with these important requirements.
2. In this Order, we adopt the attached Consent Decree entered into
between the Bureau and TowerCom. The Consent Decree resolves and
terminates the Bureau's investigation into TowerCom's compliance with
Sections 1.1307(a)(4) and 1.1312(a) of the Commission's rules (Rules)^
pertaining to the required assessment of the potential effect on the
environment or historic properties of the construction of a wireless
3. The Bureau and TowerCom have negotiated a Consent Decree that resolves
this matter. A copy of the Consent Decree is attached hereto and
incorporated herein by reference.
4. After reviewing the terms of the Consent Decree and evaluating the
facts before us, we find that the public interest would be served by
adopting the Consent Decree and terminating the investigation.
5. In the absence of material new evidence relating to this matter, we
conclude that our investigation raises no substantial or material
questions of fact as to whether TowerCom possesses the basic
qualifications, including those related to character, to hold or
obtain any Commission license or authorization.
6. Accordingly, IT IS ORDERED that, pursuant to Sections 4(i), 4(j), and
503(b) of the Communications Act of 1934, as amended,^ and Sections
0.111 and 0.311 of the Rules,^ the Consent Decree attached to this
Order IS ADOPTED.
7. IT IS FURTHER ORDERED that the above-captioned investigation IS
8. IT IS FURTHER ORDERED that a copy of this Order and Consent Decree
shall be sent by first class mail and certified mail, return receipt
requested, to David Shields, Executive Vice President, TowerCom III,
LLC, 12276 San Jose Blvd., Suite 122, Jacksonville, FL 32223; and to
Jason S. Smith, Esq., Hellman Yates & Tisdale, PA, Counsel for
TowerCom III, LLC, 145 King Street, Suite 102, Charleston, South
FEDERAL COMMUNICATIONS COMMISSION
Acting Chief, Enforcement Bureau
Federal Communications Commission
Washington, D.C. 20554
In the Matter of ) File No.: EB-SED-13-00008489
TowerCom III, LLC ) Acct No.: 201432100015
) FRN: 0006877302
The Enforcement Bureau of the Federal Communications Commission and
TowerCom III, LLC, by their authorized representatives, hereby enter into
this Consent Decree for the purpose of terminating the Enforcement
Bureau's investigation into possible violations of Sections 1.1307(a)(4)
and 1.1312(a) of the Commission's rules^ pertaining to the required
assessment of the potential effect on the environment of the construction
of a wireless communications facility.
1. For the purposes of this Consent Decree, the following definitions
a. "Act" means the Communications Act of 1934, as amended, 47 U.S.C.
S 151 et seq.
b. "Adopting Order" means an order of the Bureau adopting the terms of
this Consent Decree without change, addition, deletion, or
c. "Bureau" means the Enforcement Bureau of the Federal Communications
d. "Commission" and "FCC" mean the Federal Communications Commission and
all of its bureaus and offices.
e. "Communications Laws" means, collectively, the Act, the Rules, and the
published and promulgated orders and decisions of the Commission to
which TowerCom is subject by virtue of its business activities,
including but not limited to, the Environmental Laws.
f. "Compliance Plan" means the compliance obligations, programs, and
procedures described in this Consent Decree at paragraph 10.
g. "Covered Employees" means all employees and agents of TowerCom who
perform, or supervise, oversee, or manage the performance of, duties
that relate to TowerCom's responsibilities under the Environmental
h. "Effective Date" means the date on which the Bureau releases the
i. "Environmental Rules" means Sections 1.1307(a)(4) and 1.1312(a) of the
Rules and other Communications Laws implementing the National
Environmental Policy Act of 1969, as amended,^ and the National
Historic Preservation Act.^
j. "TowerCom" means TowerCom III, LLC, and parent and affiliate
companies, including TowerCom, LLC, TowerCom IV, LLC, and TowerCom V,
k. "Investigation" means the investigation commenced by the Bureau in
response to a referral from the Wireless Telecommunications Bureau
regarding TowerCom's possible violations of Sections 1.1307(a)(4) and
1.1312(a) of the Rules.^
l. "Operating Procedures" means the standard, internal operating
procedures and compliance policies established by TowerCom to
implement the Compliance Plan.
m. "Parties" means TowerCom and the Bureau, each of which is a "Party."
n. "Rules" means the Commission's regulations found in Title 47 of the
Code of Federal Regulations.
2. Section 1.1307(a)(4) of the Rules requires applicants and licensees to
consider whether their proposed facilities would affect properties
listed or eligible for listing ("historic properties") in the National
Register of Historic Places ("National Register"). This obligation
expressly applies to facilities for which no pre-construction
authorization is required.^ In considering the potential effects on
historic properties, applicants and licensees must, under Section
1.1307(a)(4) of the Rules, follow the prescribed procedures
established by the Programmatic Agreements for collocated antennas^
and for historic preservation review.^ The Collocation Agreement and
the Nationwide Agreement^ are designed to tailor and streamline in the
context of communications tower and antenna construction the review
and consultation procedures required by the NHPA,^ and the
implementing regulations issued by the Advisory Council on Historic
Preservation ("Advisory Council").^
3. TowerCom owns wireless telecommunications towers in the southeast
region of the United States. In July 2010, TowerCom filed with the FCC
and submitted to the Georgia State Historic Preservation Officer
(Georgia SHPO) an FCC Form 620 (FCC Wireless Telecommunications Bureau
New Tower Submission Packet) that indicated construction of a proposed
antenna structure in Woodbury, Georgia (Woodbury Tower) would have no
adverse effect on historic properties. The Georgia SHPO responded on
August 11, 2010, finding that the proposed Woodbury Tower would have
an adverse effect on several historic properties. After the Georgia
SHPO determined that alternatives to avoid or minimize the adverse
effects were not feasible, TowerCom, the Commission, and the Georgia
SHPO executed on February 9, 2011, a Memorandum of Agreement that
required TowerCom to mitigate the adverse effects to historic
properties from construction of the Woodbury Tower, and to submit an
Environmental Assessment (EA) for the site within thirty (30) days.^
4. On April 14, 2011, TowerCom submitted an application on FCC Form 854
for an Antenna Structure Registration (ASR) for the Woodbury Tower.^
Although TowerCom previously had assessed the potential effects on
historic properties as required by the Nationwide Agreement, and the
underlying facts would have supported the issuance of a Finding of No
Significant Impact (FONSI), TowerCom's ASR application incorrectly
indicated that construction of the Woodbury Tower would have no
significant environmental impact. The ASR for the Woodbury Tower was
issued on April 14, 2011. Construction of the Woodbury Tower was
completed on April 27, 2011. On July 26, 2012, TowerCom disclosed the
error to the Commission's Wireless Telecommunications Bureau, and
submitted a corrected ASR application with the required EA.^ The
Wireless Telecommunications Bureau subsequently referred this matter
to the Enforcement Bureau for investigation. The Enforcement Bureau
and TowerCom entered into a tolling agreement to toll the statute of
III. TERMS OF AGREEMENT
5. Adopting Order. The Parties agree that the provisions of this Consent
Decree shall be subject to final approval by the Bureau by
incorporation of such provisions by reference in the Adopting Order.
6. Jurisdiction. TowerCom agrees that the Bureau has jurisdiction over it
and the matters contained in this Consent Decree and that the Bureau
has the authority to enter into and adopt this Consent Decree.
7. Effective Date; Violations. The Parties agree that this Consent Decree
shall become effective on the Effective Date as defined herein. As of
the Effective Date, the Adopting Order and this Consent Decree shall
have the same force and effect as any other order of the Commission.
of the Adopting Order or of the terms of this Consent Decree shall
constitute a separate violation of a Commission order, entitling the
Commission to exercise any rights and remedies attendant to the
enforcement of a Commission order.
8. Termination of Investigation. In express reliance on the covenants and
representations in this Consent Decree and to avoid further
expenditure of public resources, the Bureau agrees to terminate the
Investigation. In consideration for the termination of the
Investigation, TowerCom agrees to the terms, conditions, and
procedures contained herein. The Bureau further agrees that in the
absence of new material evidence, the Bureau will not use the facts
developed in the Investigation through the Effective Date, or the
existence of this Consent Decree, to institute on its own motion any
new proceeding, formal or informal, or take any action on its own
motion against TowerCom concerning the matters that were the subject
of the Investigation. The Bureau also agrees that it will not, in the
absence of new material evidence, use the facts developed in the
Investigation through the Effective Date, or the existence of this
Consent Decree, to institute on its own motion any proceeding, formal
or informal, or take any action on its own motion against TowerCom
with respect to TowerCom's basic qualifications, including its
character qualifications, to be a Commission licensee.
9. Compliance Officer. Within thirty (30) calendar days after the
Effective Date, TowerCom shall designate a senior corporate manager
with the requisite corporate and organizational authority to serve as
Compliance Officer and to discharge the duties set forth below. The
person designated as the Compliance Officer shall be responsible for
developing, implementing, and administering the Compliance Plan and
ensuring that TowerCom complies with the terms and conditions of the
Compliance Plan and this Consent Decree. In addition to the general
knowledge of the Communications Laws necessary to discharge his/her
duties under this Consent Decree, the Compliance Officer shall have
specific knowledge of the Environmental Rules prior to assuming
10. Compliance Plan. For purposes of settling the matters set forth
herein, TowerCom agrees that it shall within sixty (60) calendar days
after the Effective Date, develop and implement a Compliance Plan
designed to ensure future compliance with the Communications Laws and
with the terms and conditions of this Consent Decree. With respect to
the Environmental Rules, TowerCom shall implement the following
a. Operating Procedures on Environmental Rules. Within sixty (60)
calendar days after the Effective Date, TowerCom shall establish
Operating Procedures that all Covered Employees must follow to help
ensure TowerCom's compliance with the Environmental Rules. TowerCom's
Operating Procedures shall include internal procedures and policies
specifically designed to ensure that (i) TowerCom performs the
required review of the potential effects on the environment of any
proposed facilities, including facilities for which no
pre-construction authorization is required, prior to the initiation of
construction of such proposed facilities; and (ii) timely files with
the Commission all information required by the Environmental Rules.
TowerCom's Operating Procedures shall incorporate a Compliance
Checklist that describes the steps that a Covered Employee must follow
to determine whether construction of the proposed facility is
categorically excluded from environmental processing under Section
1.1306 of the Rules^ or may have a significant environmental effect,
as defined in Section 1.1307 of the Rules.^
b. Compliance Manual. Within sixty (60) calendar days after the Effective
Date, the Compliance Officer shall develop and distribute a Compliance
Manual to all Covered Employees. The Compliance Manual shall explain
the Environmental Rules and set forth the Operating Procedures that
Covered Employees shall follow to help ensure TowerCom's compliance
with the Environmental Rules. TowerCom shall periodically review and
revise the Compliance Manual as necessary to ensure that the
information set forth therein remains current and complete. TowerCom
shall distribute any revisions to the Compliance Manual promptly to
all Covered Employees.
c. Compliance Training. TowerCom shall establish and implement a
Compliance Training Program on compliance with the Environmental Rules
and the Operating Procedures. As part of the Compliance Training
Program, Covered Employees shall be advised of TowerCom's obligation
to report any noncompliance with the Environmental Rules under
paragraph 11 of this Consent Decree and shall be instructed on how to
disclose noncompliance to the Compliance Officer. All Covered
Employees shall be trained pursuant to the Compliance Training Program
within sixty (60) calendar days after the Effective Date, except that
any person who becomes a Covered Employee at any time after the
Effective Date shall be trained within thirty (30) calendar days after
the date such person becomes a Covered Employee. TowerCom shall repeat
the compliance training on an annual basis, and shall periodically
review and revise the Compliance Training Program as necessary to
ensure that it remains current and complete and to enhance its
11. Reporting Noncompliance. TowerCom shall report any noncompliance with
the Environmental Rules and with the terms and conditions of this
Consent Decree within fifteen (15) calendar days after its discovery
of such noncompliance. Such reports shall include a detailed
explanation of (i) each instance of noncompliance; (ii) the steps that
TowerCom has taken or will take to remedy such noncompliance; (iii)
the schedule on which such proposed remedial actions will be taken;
and (iv) the steps that TowerCom has taken or will take to prevent the
recurrence of any such noncompliance. All reports of noncompliance
shall be submitted to the Chief, Spectrum Enforcement Division,
Enforcement Bureau, Federal Communications Commission, 445 12^th
Street, S.W., Rm. 3-C366, Washington, DC 20554, with copies submitted
electronically to Linda Nagel at Linda.Nagel@fcc.gov and to Ricardo
Durham at Ricardo.Durham@fcc.gov.
12. Compliance Reports. TowerCom shall file Compliance Reports with the
Commission ninety (90) calendar days after the Effective Date, twelve
(12) months after the Effective Date, twenty-four (24) months after
the Effective Date, and thirty-six months (36) after the Effective
a. Each Compliance Report shall include a detailed description of
TowerCom's efforts during the relevant period to comply with the terms
and conditions of this Consent Decree and the Environmental Rules. In
addition, each Compliance Report shall include a certification by the
Compliance Officer, as an agent of and on behalf of TowerCom, stating
that the Compliance Officer has personal knowledge that TowerCom (i)
has established and implemented the Compliance Plan; (ii) has utilized
the Operating Procedures since the implementation of the Compliance
Plan; and (iii) is not aware of any instances of noncompliance with
the terms and conditions of this Consent Decree, including the
reporting obligations set forth in paragraph 11 hereof.
b. The Compliance Officer's certification shall be accompanied by a
statement explaining the basis for such certification and must comply
with Section 1.16 of the Rules^ and be subscribed to as true under
penalty of perjury in substantially the form set forth therein.
c. If the Compliance Officer cannot provide the requisite certification,
the Compliance Officer, as an agent of and on behalf of TowerCom,
shall provide the Commission with a detailed explanation of the
reason(s) why and describe fully (i) each instance of noncompliance;
(ii) the steps that TowerCom has taken or will take to remedy such
noncompliance, including the schedule on which proposed remedial
actions will be taken; and (iii) the steps that TowerCom has taken or
will take to prevent the recurrence of any such noncompliance,
including the schedule on which such preventive action will be taken.
d. All Compliance Reports shall be submitted to Chief, Spectrum
Enforcement Division, Enforcement Bureau, Federal Communications
Commission, 445 12^th Street, S.W., Rm. 3-C366, Washington, DC 20554.
All Compliance Reports also shall be submitted electronically to Linda
Nagel at Linda.Nagel@fcc.gov and to Ricardo Durham at
13. Termination Date. Unless stated otherwise, the obligations set forth
in paragraphs 9 through 12 of this Consent Decree shall expire
thirty-six (36) months after the Effective Date.
14. Voluntary Contribution. TowerCom agrees that it will make a voluntary
contribution to the United States Treasury in the amount of six
thousand five hundred dollars ($6,500) within thirty (30) calendar
days after the Effective Date. TowerCom shall also send electronic
notification of payment to Linda Nagel at Linda.Nagel@fcc.gov, to
Ricardo Durham at Ricardo.Durham@fcc.gov, and to Samantha Peoples at
Sam.Peoples@fcc.gov on the date said payment is made. The payment must
be made by check or similar instrument, wire transfer, or credit card,
and must include the NAL/Account Number and FRN referenced above.
Regardless of the form of payment, a completed FCC Form 159
(Remittance Advice) must be submitted.^ When completing the FCC Form
159, enter the Account Number in block number 23A and enter the
letters "FORF" in block number 24A (payment type code). Below are
additional instructions that TowerCom should follow based on the form
of payment it selects:
* Payment by check or money order must be made payable to the order of
the Federal Communications Commission. Such payments (along with the
completed Form 159) must be mailed to Federal Communications
Commission, P.O. Box 979088, St. Louis, MO 63197-9000, or sent
via overnight mail to U.S. Bank - Government Lockbox #979088,
SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO 63101.
* Payment by wire transfer must be made to ABA Number 021030004,
receiving bank TREAS/NYC, and Account Number 27000001. To complete
the wire transfer and ensure appropriate crediting of the wired funds,
a completed Form 159 must be faxed to U.S. Bank at (314) 418-4232 on
the same business day the wire transfer is initiated.
* Payment by credit card must be made by providing the required credit
card information on FCC Form 159 and signing and dating the Form 159
to authorize the credit card payment. The completed Form 159 must then
be mailed to Federal Communications Commission, P.O. Box 979088, St.
Louis, MO 63197-9000, or sent via overnight mail to U.S. Bank -
Government Lockbox #979088, SL-MO-C2-GL, 1005 Convention Plaza, St.
Louis, MO 63101.
If TowerCom has questions regarding payment procedures, it should contact
the Financial Operations Group Help Desk by phone, 1-877-480-3201, or by
15. Waivers. TowerCom waives any and all rights it may have to seek
administrative or judicial reconsideration, review, appeal, or stay,
or to otherwise challenge or contest the validity of this Consent
Decree and the Adopting Order, provided the Bureau issues an Adopting
Order as defined herein. TowerCom shall retain the right to challenge
Commission interpretation of the Consent Decree or any terms contained
herein. If either Party (or the United States on behalf of the
Commission) brings a judicial action to enforce the terms of the
Adopting Order, neither TowerCom nor the Commission shall contest the
validity of the Consent Decree or of the Adopting Order, and TowerCom
shall waive any statutory right to a trial de novo. TowerCom hereby
agrees to waive any claims it may have under the Equal Access to
Justice Act,^ relating to the matters addressed in this Consent
16. Invalidity. In the event that this Consent Decree in its entirety is
rendered invalid by any court of competent jurisdiction, it shall
become null and void and may not be used in any manner in any legal
17. Subsequent Rule or Order. The Parties agree that if any provision of
the Consent Decree conflicts with any subsequent rule or order adopted
by the Commission (except an order specifically intended to revise the
terms of this Consent Decree to which TowerCom does not expressly
consent) that provision will be superseded by such rule or Commission
18. Successors and Assigns. TowerCom agrees that the provisions of this
Consent Decree shall be binding on its successors, assigns, and
19. Final Settlement. The Parties agree and acknowledge that this Consent
Decree shall constitute a final settlement between the Parties with
respect to the Investigation. The Parties further agree that this
Consent Decree does not constitute either an adjudication on the
merits or a factual or legal finding or determination regarding any
compliance or noncompliance with the Communications Laws.
20. Modifications. This Consent Decree cannot be modified without the
advance written consent of both Parties.
21. Paragraph Headings. The headings of the paragraphs in this Consent
Decree are inserted for convenience only and are not intended to
affect the meaning or interpretation of this Consent Decree.
22. Authorized Representative. The individual signing this Consent Decree
on behalf of TowerCom represents and warrants that he is authorized by
TowerCom to execute this Consent Decree and to bind the company to the
obligations set forth herein. The FCC signatory represents that he is
signing this agreement in his official capacity and that he is
authorized to execute this Consent Decree.
23. Counterparts. This Consent Decree may be signed in any number of
counterparts (including by facsimile), each of which, when executed
and delivered, shall be an original, and all of which counterparts
together shall constitute one and the same fully executed instrument.
Executive Vice President
TowerCom III, LLC
^ 47 C.F.R. SS 1.1307(a)(4), 1.1312(a).
^ 47 U.S.C. SS 154(i), 154(j), 503(b).
^ 47 C.F.R. SS 0.111, 0.311.
^ 47 C.F.R. SS 1.1307(a)(4), 1.1312(a).
^ National Environmental Policy Act of 1969, Pub. L. No. 91-190, 83 Stat.
852 (1970), as amended (codified at 42 U.S.C. SS 4321-4347).
^ National Historic Preservation Act, Pub. L. No. 89-665, 80 Stat. 915
(codified at 16 U.S.C. S 470 et seq) (NHPA).
^ See 47 C.F.R. SS 1.1307(a)(6), 1.1312(a).
^ 47 C.F.R. S 1.1312(a) ("In the case of facilities for which no
Commission authorization prior to construction is required by the
Commission's rules and regulations, the licensee or applicant shall
initially ascertain whether the proposed facility may have a significant
environmental impact as defined in S 1.1307 of this part.").
^ See 47 C.F.R. Part 1, App. B ("Collocation Agreement"); see also
Wireless Telecommunications Bureau Announces Execution of Programmatic
Agreement with respect to Collocating Wireless Antennas on Existing
Structures, Public Notice, 16 FCC Rcd 5574 (WTB 2001), recons. denied, 20
FCC Rcd 4084 (WTB 2005).
^ See 47 C.F.R. Part 1, App. C ("Nationwide Agreement"); see also
Nationwide Programmatic Agreement Regarding the Section 106 National
Historic Preservation Act Review Process, Report and Order, WT Docket No.
03-128, 20 FCC Rcd 1073 (2004), clarified, 20 FCC Rcd 17995 (2005), aff'd,
CTIA-The Wireless Ass'n. v. FCC, No. 05-1008 (D.C. Cir. Sept. 26, 2006)
("Nationwide Agreement Report and Order").
^ Section 1.1307(a)(4) of the Rules incorporates by reference the
Collocation Agreement and the Nationwide Agreement. The Nationwide
Agreement attaches standardized packets for review of collocated antenna
construction (FCC Form 621) and new tower construction (FCC Form 620). See
Nationwide Agreement Report and Order, 20 FCC Rcd at 1180-1201, Appendix
B, Attachments 3 and 4.
^ The NHPA requires that a federal agency consider the effects of its
federal undertakings, including actions that it authorizes or approves, on
historic properties prior to issuing federal licenses, permits, or
approvals. See 16 U.S.C. SS 470f, 470w(7). In considering such effects,
the NHPA further requires the federal agency to consider the views of
expert agencies. Specifically, the NHPA requires the federal agency to
consider the views of the Advisory Council on Historic Preservation, the
agency tasked with the responsibility for implementing the NHPA, the
appropriate State Historic Preservation Officer, and, if affected historic
properties are of religious or cultural significance to Indian Tribes or
Native Hawaiian organizations, their representatives. See 16 U.S.C. SS
470a(a)(3), (d)(6)(B), 470f, 470i. Consistent with the Advisory Council on
Historic Preservation's regulations, the Commission's Environmental Rules
delegate the task of identification and initial consideration of the
effects that proposed facilities may have on historic properties,
including identifying and ensuring contact is made with potentially
affected Indian Tribes, to its licensees, permittees and applicants, but
the Commission remains ultimately responsible for enforcement of the
Environmental Rules. See 47 C.F.R. S 1.1307(a)(4); see also 36 C.F.R. S
800.2(a)(3); Nationwide Agreement Report and Order, 20 FCC Rcd at 1076-77
^ See 36 C.F.R. S 800.1 et seq. Under the NHPA and the Advisory Council's
implementing regulations, a federal agency may, with the agreement of the
Advisory Council and the relevant State Historic Preservation Officer or
the National Conference of State Historic Preservation Officers, adopt
Programmatic Agreements to tailor the historic preservation review and
consultation procedures, as well as exempt actions that are unlikely to
affect historic properties. See 16 U.S.C. S 470v; 36 C.F.R. S
^ See Memorandum of Agreement Between the Federal Communications
Commission and the Georgia State Historic Preservation Officer Regarding a
Proposed Southerlinc/TowerComIII, LLC Tower in Meriwether County, Georgia,
dated February 17, 2011 at 2.
^ See File No. A1278581 (filed Apr. 14, 2011).
^ See File No. A0780894 (filed July 26, 2012). The Woodbury Tower was
subsequently sold to SBA Communications Corporation. See ASR No. 1278581.
^ See, e.g., Tolling Agreement Extension, File No. EB-SED-13-00008489,
executed by and between John D. Poutasse, Chief, Spectrum Enforcement
Division, Enforcement Bureau, and Jason S. Smith, counsel for TowerCom
III, LLC (Dec. 20, 2013) (on file in EB-SED-13-00008489).
^ 47 C.F.R. S 1.1306.
^ Id. S 1.1307.
^ Id. S 1.16.
^ An FCC Form 159 and detailed instructions for completing the form may be
obtained at http://www.fcc.gov/Forms/Form159/159.pdf.
^ Equal Access to Justice Act, Pub L. No. 96-481, 94 Stat. 2325 (1980)
(codified at 5 U.S.C. S 504); see also 47 C.F.R. SS 1.1501-1.1530.
Federal Communications Commission DA 14-261
Federal Communications Commission DA 14-261