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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-014
Licensee of Radio Station WBTE(AM)           )
Facility ID # 172               )         NOV No. V20053264004
Windsor, North Carolina         )

                       NOTICE OF VIOLATION

                                             Released: July 27, 

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 14, 2005, an agent of the Commission's Norfolk 
     Office of the Enforcement Bureau inspected radio station 
     WBTE(AM) located in Windsor, North Carolina and observed the 
     following violations:

               2.a.      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...(c) [t]he licensee 
                 must establish monitoring procedures and 
                 schedules for the station...''  Although 
                 the Commission authorized Station WBTE(AM) 
                 to broadcast from latitude 35 58' 00" 
                 North and longitude 076 56' 54" West 
                 (NAD27), the station was actually 
                 broadcasting from a location more than 0.5 
                 km from its authorized coordinates.  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.b.      47 C.F.R.  73.1560(a)(1):  
                 ``...]T]he antenna input power of an AM 
                 station as determined by the procedures 
                 specified in  73.51 must be maintained as 
                 near as is practicable to the authorized 
                 antenna input power and may not be less 
                 than 90% nor more than 105% of the 
                 authorized power.''  The Commission 
                 authorized Station WBTE(AM) to broadcast 
                 during daytime only.  However, the station 
                 broadcast up to 139 watts after sunset on 
                 March 9, 13 and 14, 2005.  Additionally, 
                 during the inspection on March 14, 2005, 
                 the station operated at more than 230% of 
                 its authorized power.

               2.c.      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...''  Station staff were not 
                 aware of the requirements for equipment 
                 performance or spurious and harmonic 
                 measurements; nor could they make copies 
                 of those measurements available. 

               2.d.      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.e.      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 public 
                 inspection file of Station WBTE(AM):   

                  2.e.i.      A copy of the current FCC 
                    authorization.  ( 73.3526(e)(1))
                  2.e.ii.     Contour maps.  ( 
                  2.e.iii.    Ownership reports and related 
                    materials.  ( 73.3526(e)(5))
                  2.e.iv.     Political file.  ( 
                  2.e.v.      Letters and e-mail from the 
                    public.  ( 73.3526(e)(9)) 
             Radio issues/programs lists.  
                    ( 73.3526(e)(12))
                  2.e.vii.    Local public notice 
                    announcements.  ( 73.3526(e)(13))

  3.      In addition to the violations noted above, provide a 
     statement describing the status of ownership and control of 
     the Station WBTE(AM) facilities in March 2005.  Include an 
     explanation as to what might have caused three different 
     station managers to claim that Willis Broadcasting 
     Corporation sold Station WBTE(AM) in 2002, and why during 
     inspections in 2004 and 2005, all Station WBTE(AM) staff 
     admitted to being volunteers for entities other than Willis 
     Broadcasting Corporation.  

  4.      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

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

  6.      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.