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

In the Matter of                )
Willis Broadcasting Corporation )         File No. EB-05-NF-016
Licensee of Radio Station WURB(FM)           )
Facility ID # 173 and Owner of ASR # 1006369 )    NOV         No. 
Windsor, North Carolina         )

                       NOTICE OF VIOLATION

                                             Released: July 14, 

By the Resident Agent, Norfolk Office, South Central Region, 
Enforcement Bureau:

  1.      This is a Notice of Violation (``Notice'') issued 
     pursuant to Section 1.89 of the Commission's Rules,1 to 
     Willis Broadcasting Corporation, licensee of radio station 

  2.      On March 15, 2005, an agent of the Commission's Norfolk 
     Office inspected radio station WURB(FM) located in Windsor, 
     North Carolina, and observed the following violations:

               2.a.      47 C.F.R.  11.35(a):  ``Broadcast 
                 stations and cable systems and wireless 
                 cable systems are responsible for ensuring 
                 that EAS Encoders, EAS Decoders and 
                 Attention Signal generating and receiving 
                 equipment used as part of the EAS are 
                 installed so that the monitoring and 
                 transmitting functions are available 
                 during the times the stations and systems 
                 are in operation.  Additionally, broadcast 
                 stations and cable systems and wireless 
                 cable systems must determine the cause of 
                 any failure to receive the required tests 
                 or activations specified in 11.61(a) (1) 
                 and (2).  Appropriate entries must be made 
                 in the broadcast station log as specified 
                 in 73.1820 and 73.1840 of this 
                 chapter...''  At the time of inspection, 
                 the station's EAS equipment was programmed 
                 with the incorrect time.  In addition, the 
                 station failed to document or investigate 
                 its missed required monthly test (``RMT'') 

               2.b.      47 C.F.R.  11.61(a):  EAS 
                 ``[t]ests shall be made at regular 
                 intervals as indicated in paragraphs 
                 (a)(1) and (a)(2) of this section.''  At 
                 the time of inspection, the station had no 
                 record of any RMT transmissions after 
                 November, 2004. 

               2.c.      47 C.F.R.  17.49:  ``The owner of 
                 each antenna structure which is registered 
                 with the Commission and has been assigned 
                 lighting specifications referenced in this 
                 part must maintain a record of any 
                 observed or otherwise known extinguishment 
                 or improper functioning of a structure 
                 light and include the following 
                 information for each such event:  (a) The 
                 nature of such extinguishment or improper 
                 functioning.  (b) The date and time the 
                 extinguishment or improper operation was 
                 observed or otherwise noted.  (c) Date and 
                 time of FAA notification, if applicable.  
                 (d) The date, time and nature of 
                 adjustments, repairs, or replacements 
                 made.''  A station technician stated that 
                 he was aware that the two side-mounted red 
                 lights at ? the height of their antenna 
                 structure were extinguished.  There was no 
                 record of this extinguishment. 

               2.d.      47 C.F.R.  17.57:  ``The owner 
                 must also immediately notify the 
                 Commission using FCC Form 854 upon any 
                 change in structure height or change in 
                 ownership information.''  The antenna 
                 structure registration database did not 
                 contain the current contact telephone 
                 number or the correct antenna structure 

               2.e.      47 C.F.R.  73.1350:  ``(a) Each 
                 licensee is responsible for maintaining 
                 and operating its broadcast station in a 
                 manner which complies with the technical 
                 rules set forth elsewhere in this part and 
                 in accordance with the terms of the 
                 station authorization...(b)(2) [t]he 
                 transmitter control personnel must have 
                 the capability to turn the transmitter off 
                 at all times...(c) [t]he licensee must 
                 establish monitoring procedures and 
                 schedules for the station...''  While the 
                 FCC authorized WURB(FM) to broadcast from 
                 latitude 36 04' 06" North and longitude 
                 076 58' 35" West (NAD27), the station was 
                 actually broadcasting from a location more 
                 than 0.8 km from its authorized 
                 coordinates.  In addition, at the time of 
                 inspection, the station's chief operator 
                 did not know how to determine or how to 
                 control the station's operating power, nor 
                 did she know how to stop transmissions.  
                 In addition, the station had not 
                 established monitoring procedures and 
                 schedules to determine compliance with 
                 73.1560 regarding operating power and 
                 73.1570 regarding modulation levels. 

               2.f.      47 C.F.R.  73.1560(b):  ``...[T]he 
                 transmitter output power of an FM 
                 station...must be maintained as near as 
                 practicable to the authorized transmitter 
                 output power and may not be less than 90% 
                 nor more than 105% of the authorized 
                 power.''  At the time of inspection, the 
                 station was operating at 141% of its 
                 authorized transmitter output power.

               2.g.      47 C.F.R. 73.1590:``(a) The 
                 licensee of each AM, FM, TV and Class A TV 
                 station...must make equipment performance 
                 measurements for each main transmitter as 
                 follows: (1) Upon initial installation of 
                 a new or replacement main 
                 transmitter...(d) [t]he data required by 
                 paragraphs (b) and (c) of this section, 
                 together with a description of the 
                 equipment and procedure used in making the 
                 measurements, signed and dated by the 
                 qualified person(s) making the 
                 measurements, must be kept on file at the 
                 transmitter or remote control point for a 
                 period of 2 years, and on request must be 
                 made available during that time to duly 
                 authorized representatives of the FCC.''  
                 The station stated that it had recently 
                 replaced its main transmitter, but did not 
                 have any record of the replacement. 
                 Equipment Performance Measurements failed 
                 to identify (e.g., by providing the 
                 manufacturer, FCCID, model number and 
                 serial number of) the transmitter that was 

               2.h.      47 C.F.R.  73.1870(c)(3):  The 
                 chief operator is responsible for 
                 ``[r]eview of the station records at least 
                 once each week to determine if required 
                 entries are being made correctly.  
                 Additionally, verification must be made 
                 that the station has been operated as 
                 required by the rules or the station 
                 authorization.  Upon completion of the 
                 review, the chief operator or his designee 
                 must date and sign the log, initiate any 
                 corrective action which may be necessary, 
                 and advise the station licensee of any 
                 condition which is repetitive.''  At the 
                 time of inspection, the chief operator was 
                 not signing the station logs to indicate 
                 that they had been reviewed.

               2.i.      47 C.F.R. 73.3526(c):  Material 
                 in the public inspection file ``shall be 
                 available for public inspection at any 
                 time during regular business hours.''  At 
                 the time of inspection, the following 
                 items were missing from the WURB(FM) 
                 public inspection file:   

                  2.i.i.      A copy of the current FCC 
                    authorization.  ( 73.3526(e)(1))
                  2.i.ii.     Letters and e-mail from the 
                    public.  ( 73.3526(e)(9)) 
                  2.i.iii.    Radio issues/programs lists.  
                    ( 73.3526(e)(12))

  3.      Pursuant to Section 308(b) of the Communications Act of 
     1934, as amended,2 and Section 1.89 of the Commission's 
     Rules, Willis Broadcasting Corporation, must submit a 
     written statement concerning this matter within twenty (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 a principal or 
     officer of the licensee.  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 

                 Federal Communications Commission
                 Norfolk Office
                 1457 Mt. Pleasant Rd., Ste. 113
                 Chesapeake, VA 23322

  4.      This Notice shall be sent to Willis Broadcasting 
     Corporation at its address of record.

  5.      The Privacy Act of 19743 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.4

                              FEDERAL COMMUNICATIONS COMMISSION

                              Joseph P. Husnay
                              Resident Agent
                              Norfolk District Office
                              South Central Region
                              Enforcement Bureau

Willis Broadcasting Corporation
645 Church Street
Suite 400
Norfolk VA  23510


147 C.F.R.  1.89.

247 U.S.C.  308(b).

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

418 U.S.C.  1001 et seq.