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                          Before the
                Federal Communications Commission
                     Washington, D.C. 20554

In the Matter of

Christian Broadcasting Corporation           )                    
File No. EB-00-OR-117
WBOK (AM)                          )                NAL/Acct. 
No. 200132620002
New Orleans, Louisiana                  )    


                                    Released:   January 3, 2001
By the Enforcement Bureau, New Orleans Field Office:

                        I.  INTRODUCTION

     1.   In this Notice of Apparent Liability for  Forfeiture, 
we find  that  Christian Broadcasting  Corporation  ("Christian 
Broadcasting"), licensee  of  AM broadcast  station  WBOK,  has 
apparently  violated  sections  1.89(b)  and  17.4(a)  of   the 
Commission's  Rules  ("Rules")   by  failing   to  respond   to 
Commission correspondence  and  for  failing  to  register  its 
antenna structure.1  We conclude that Christian Broadcasting is 
apparently liable for  a forfeiture in  the amount of  fourteen 
thousand dollars ($14,000).

                         II.  BACKGROUND

     2.   On July 7,  2000, an  agent of  the Commission's  New 
Orleans Field Office (``Field  Office'') inspected the  antenna 
structure of  radio station  WBOK.  This  structure is  greater 
than  200  feet  in  height  and  is  painted  and  lighted  in 
accordance with  the Rules.  During the  inspection, the  agent 
determined that  there was  no antenna  structure  registration 
number displayed near the base  of the structure, and a  search 
of the Commission's  records revealed no  indication that  this 
structure had been registered.  On  July 11, 2000, a Notice  of 
Violation (``NOV'') was mailed to Christian Broadcasting citing 
these deficiencies.  No reply to this notice was received.   On 
July 31,  2000, a  letter was  sent by  Certified Mail,  Return 
Receipt   Requested    to   Christian    Broadcasting.     This 
correspondence stated that  no reply had  been received to  the 
NOV issued on July 11, 2000,  and included a copy of this  NOV.  
Additionally, the  letter  cautioned  the  licensee  concerning 
failure  to  reply  to  Commission  correspondence.   A  signed 
Certified Mail Receipt evidenced  delivery of this letter.   No 
reply to  this  correspondence or  the  original NOV  has  been 

                       III.  DISCUSSION

     3.   Section 1.89(b) of  the Rules  requires licensees  to 
respond in writing  within ten  days from receipt  of a  notice 
from the Commission.2

     4.   Section  17.4(a)  of  the  Rules  requires   existing 
antenna structures  that  were assigned  painting  or  lighting 
requirements prior  to July  1, 1996,  be registered  with  the 
Commission prior to July 1,  1998.3   The antenna structure  of 
station WBOK is governed under this section.

     5.    Christian Broadcasting  is the  licensee of  station 
WBOK licensed to  New Orleans,  Louisiana.  Commission  records 
indicate that the owner of Christian Broadcasting is Bishop  L. 
E. Willis, Sr.  According to  Commission records, Bishop L.  E. 
Willis,  Sr.  is   also  the  owner   of  Willis   Broadcasting 
Corporation.  Bishop  L.   E.  Willis,   Sr.,  through   Willis 
Broadcasting Corporation  (``Willis''),  had been  notified  at 
least  twice  of  violations  regarding  each  of  these   rule 
sections.  Willis was issued  Notices of Violation for  failure 
to register  antenna structures  on  June 2,  1999  (KEAZ/KDLA, 
DeRidder, LA), and on July 20, 1999 (WJNS-FM, Yazoo City,  MS).  
Willis was issued warnings for failure to respond to Commission 
Notices on April 20, 1999 (KLPL AM & FM, Lake Providence,  LA), 
June 21, 1999  (KEAZ/KDLA DeRidder,  LA), July  9, 1999  (KVLA, 
Vidalia, LA), and September 23, 1999 (WJNS-FM, Yazoo City, MS).  
In fact, no responses have been received concerning any of  the 
17 pieces of correspondence from the Commission associated with 
the inspections of these stations.

     6.   Based on the evidence before us, we find that on July 
7, 2000, Christian Broadcasting Corporation willfully4 violated 
Sections 1.89(b) and 17.4(a) of the Rules by failing to respond 
to Commission correspondence  and for failing  to register  its 
antenna structure.

     7.   Pursuant to Section 1.80 of the Rules, Guidelines for 
Assessing Forfeiture, the base amount for failure to respond to 
official Commission  correspondence  is $4,000,  and  the  base 
forfeiture amount for failure to register antenna structures is 
$3,000 (failure to file required  forms or information).5   The 
total base  forfeiture  for  both  violations  is  $7,000.   In 
assessing the  monetary   forfeiture  amount,  we   must   also  
take into account  the  statutory  factors  set forth in 

Section  503(b)(2)(D)  of  the   Communications  Act  of   1934 
(``Act''), as amended, which include the nature, circumstances, 
extent, and gravity  of the violation(s),  and with respect  to 
the violator, the degree of  culpability, any history of  prior 
offenses, ability to pay, and other such matters as justice may 
require.6  Applying  Section 1.80  of the  Rules and  statutory 
factors to the instant case, an upward adjustment is  warranted 
due to  the  owner's  history of  non-compliance  and  flagrant 
disregard  for  the  Commission's  rules.  Therefore,  we  find 
Christian Broadcasting liable for a forfeiture in the amount of 

                      IV.  ORDERING CLAUSES

     8.   Accordingly, IT IS ORDERED THAT, pursuant to  Section 
503(b) of the Act,7 and Sections  0.111, 0.311 and 1.80 of  the 
Commission's  Rules,8  Christian  Broadcasting  Corporation  is 
the amount of fourteen thousand dollars ($14,000) for violating 
Sections 1.89(b)  and 17.4(a)  of  the Commission's  Rules,  47 
C.F.R.  1.89(b) and 17.4(a). 

     9.   IT IS FURTHER ORDERED,  pursuant to Sections 1.80  of 
the Rules,  within thirty  days  of the  release date  of  this 
NOTICE   OF   APPARENT   LIABILITY,   Christian    Broadcasting 
Corporation,  SHALL  PAY  the  full  amount  of  the   proposed 
forfeiture or SHALL FILE a written statement seeking  reduction 
or cancellation of the proposed forfeiture.

     10.  Payment of the  forfeiture may be  made by mailing  a 
check or  similar  instrument,  payable to  the  order  of  the 
Federal Communications Commission, to the Forfeiture Collection 
Section, Finance  Branch,  Federal  Communications  Commission, 
P.O. Box  73482,  Chicago, Illinois  60673-7482.   The  payment 
should note the NAL/Acct. No. 200132620002.

     11.  The response if any must  be mailed to Office of  the 
Secretary, Federal Communications Commission, 445 12th  Street, 
S.W., Washington, D.C. 20554, ATTN: Enforcement Bureau -  TPSD, 
NAL/Acct. No. 200132620002 and  must include the NAL/Acct.  No. 

     12.  The  Commission   will  not   consider  reducing   or 
canceling a forfeiture in response  to a claim of inability  to 
pay unless the petitioner submits: (1) federal tax returns  for 
the most  recent three-year  period; (2)  financial  statements 
prepared according to generally accepted accounting  practices; 
or (3)  some other  reliable and  objective documentation  that 
accurately reflects the petitioner's current financial  status.  
Any claim of  inability to pay  must specifically identify  the 
basis for the claim by reference to the financial documentation 

     13.  Requests for  payment  of  the full  amount  of  this 
Notice of Apparent Liability  under an installment plan  should 
be sent to: Chief, Credit and Debt Management Center, 445  12th 
Street, S.W., Washington, D.C. 20554.9

     14.  IT IS FURTHER ORDERED THAT  a copy of this NOTICE  OF 
APPARENT LIABILITY  shall be  sent  by Certified  Mail,  Return 
Receipt Requested, to  Christian Broadcasting Corporation,  645 
Church Street, Suite 400, Norfolk, Virginia 23510.


                         James C. Hawkins
                         District Director
                         New Orleans Field Office 



1  47 C.F.R.  1.89(b) and 17.4(a)

2  47 C.F.R.   1.89(b)

3  47 C.F.R. 17.4(a)

4  Section 312(f)(1) of the Act, 47 U.S.C.  312(f)(1), which 
applies to Section 503(b) of the Act, provides that ``[t]he 
term `willful', when used with reference to the commission or 
omission of any act, means the conscious and deliberate 
commission or omission of such act, irrespective of any intent 
to violate any provision of this Act ....''  See Southern 
California Broadcasting Co., 6 FCC Rcd 4387 (1991).

5  47 C.F.R.  1.80

6  47 U.S.C.  503(b)(2)(D)

7  47 U.S.C.  503(b)

8  47 C.F.R.  0.111, 0.311, 1.80

9  See 47 C.F.R.  1.1914