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                         Before the
                   Washington, D.C.  20554

In the Matter of                   )    File No. x18ed0002
KANZA, Inc.                        )    Ref. Facility ID 
                              )    KRLI(FM), Malta Bend, MO


     Adopted: March 23, 2000                 Released: March 
24, 2000

By the Chief, Enforcement Bureau:

     1.  In this Order, we adopt a Consent Decree 
terminating an investigation into whether KANZA, Inc. 
(``KANZA'') complied with Section 310(d) of the 
Communications Act of 1934, as amended (the ``Act''), 47 
U.S.C.  310(d)1 and the Commission's time brokerage 

     2.  On October 22, 1999, the Chief, Mass Media Bureau, 
released a Notice of Apparent Liability (``NAL''), DA 99-
2259.  The NAL determined that it appeared KANZA, not the 
licensee of record, Miles Carter, controlled KRLI(FM), Malta 
Bend, Missouri.  The Bureau asserted that it appeared that: 
1) KRLI had no employees; 2) KRLI was operated in 
conjunction with KANZA stations KAOL(AM), KNZU(FM) and 
WHB(AM) out of a common main studio location; 3) KANZA 
employed Miles Carter; and 4) KANZA directly paid for 
various KRLI expenses, including property insurance on 
station equipment, utilities, telephone, news programming, 
promotions/advertisements, and maintenance of station 
equipment.  After considering the circumstances in light of 
the Commission's Forfeiture Policy Statement,2 which 
provides a base forfeiture of $8,000 for an unauthorized 
transfer of control, the Chief, Mass Media Bureau, proposed 
a forfeiture of $8,000. In addition, the Chief, Mass Media 
Bureau, directed that the parties submit within 30 days of 
the date of the NAL a plan to come into compliance with the 
Commission's rules and policies concerning control. 

     3.  On November 22, 1999, KANZA filed a response to the 
NAL, in which it contended that its involvement with KRLI 
was no more extensive than what had been found legal in 
other time brokerage cases.  Nevertheless, KANZA also 
submitted an ``Amended and Restated Time Brokerage 
Agreement'' (``Amended Agreement'') dated November 16, 
1999.3  The Amended Agreement revised a Time Brokerage 
Agreement between KANZA and Miles Carter, which had been 
entered into on October 17, 1996, shortly before KRLI 
commenced broadcasting.  Among other things, the Amended 
Agreement provides that, except for expenses related to 
programming created and provided by KANZA, Miles Carter 
shall be responsible for paying all direct operating costs 
of the station.  In addition, the Amended Agreement provides 
that Miles Carter shall employ at KRLI a general manager and 
any other personnel required by the Commission's rules and 

     4. The staff and KANZA have negotiated the terms of a 
Consent Decree that would terminate this proceeding.  A copy 
of the Consent Decree is attached hereto and incorporated by 

     5.  We have reviewed the terms of the Consent Decree 
and evaluated the facts before us. We believe that the 
public interest would be served by approving the Consent 
Decree and terminating this proceeding.

     6.  Accordingly, IT IS ORDERED, pursuant to Sections 
4(i) and 4(j) of the Communications Act of 1934, as amended, 
47 U.S.C  154(i) and 154(j), and the authority delegated 
in Sections 0.111 and 0.311of the Commission's rules, 47 
C.F.R.  0.111 and 0.311, that the attached Consent Decree 
is hereby ADOPTED.4  

     7.  IT IS FURTHER ORDERED that the above captioned 
forfeiture proceeding IS TERMINATED. 


                         David H. Solomon
                         Chief, Enforcement Bureau


1  See also 47 C.F.R.  73.3540. 

2  12 FCC Rcd 17087 (1997), recon. denied, FCC 99-407, 
released December 28, 1999. 

3  A companion Notice of Apparent Liability, DA 99-2258, 
released October 22, 1999, was sent to Miles Carter.  By 
letter dated November 22, 1999, Miles Carter advised, inter 
alia, that he had resigned from KANZA's employ and had paid 
the forfeiture.     
4  In this regard, the voluntary contribution referenced in 
the Consent Decree shall be paid by a check or money order 
drawn to the order of the Federal Communications Commission.  
Reference should be made on the check or money order to 
``Acct. No. x18ed0002.''  The remittance is to be paid to: 
Forfeiture Collection Section, Finance Branch, Federal 
Communications Commission, P.O. Box 73482, Chicago, Illinois