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                                   Before the

                       Federal Communications Commission

                             Washington, D.C. 20554

   In the Matter of )


   Susan L. Uecker, Receiver ) File No. EB-11-SF-0182

   Licensee of Radio Station KTRB(AM) )

   Facility ID # 66246 ) NOV No. V201232960011

   San Francisco, California )


                              NOTICE OF VIOLATION

                                                  Released: December 21, 2011

   By the District Director, San Francisco Office, Western Region,
   Enforcement Bureau:

    1. This is a Notice of Violation ("Notice") issued pursuant to Section
       1.89 of the Commission's Rules, to Susan L. Uecker, Receiver
       ("Uecker"), licensee of radio station KTRB(AM) in San Francisco,
       California. This Notice may be combined with a further action, if
       further action is warranted.

    2. On October 13, 2011, the San Francisco Office received a complaint
       that radio station KPAM, in Troutdale, Oregon, was experiencing
       interference from KTRB, a co-channel station (860 kHz), in San
       Francisco, California.

    3. On October 21, 2011, agents of the Enforcement Bureau's San Francisco
       Office investigated the allegation. During the course of the
       investigation, the agents inspected radio station KTRB(AM) located at
       San Francisco, California, and observed the following violations:

     a. 47 C.F.R. S: 11.52(d): "EAS Participants must monitor two EAS
        sources. The monitoring assignments of each broadcast station and
        cable system and wireless cable system are specified in the State EAS
        Plan and FCC Mapbook. They are developed in accordance with FCC
        monitoring priorities." At the time of the inspection, agents
        observed that station KTRB(AM) was monitoring only one EAS assigned
        source, the LP-1 (Local Primary), KCBS 740 kHz.

     b. 47 C.F.R. S: 11.61(b): "Tests of EAS Procedures. Entries shall be
        made in EAS Participant records, as specified in S:S:11.35(a) and
        11.54(b)(13)." At the time of inspection, there were no entries in
        the KTRB(AM)'s logs that the required monthly test (RMT) for October,
        November, and December of 2010, and January, March, and April of 2011
        were received.

     c. 47 C.F.R. S: 73.57(d): "Each remote reading ammeter shall be accurate
        to within 2 percent of the value read on its corresponding regular
        ammeter." At the time of inspection, agents observed that the remote
        antenna ammeter reading was 8.30 amps and the regular antenna ammeter
        reading was 8.75 amps during the nighttime mode of operation, a
        difference of 5.14 percent.

     d. 47 C.F.R. S: 73.1350(c): "The licensee must establish monitoring
        procedures and schedules for the station and the indicating
        instruments employed must comply with S:73.1215." At the time of
        inspection, there were no records that KTRB(AM) monitoring procedures
        and schedules were established, and that the indicating instruments
        were monitored.

     e. 47 C.F.R. S: 73.1400: "The licensee of an AM, FM, TV or Class A TV
        station is responsible for assuring that at all times the station
        operates within tolerances specified by applicable technical rules
        contained in this part and in accordance with the terms of the
        station authorization. Any method of complying with applicable
        tolerances is permissible." At the time of inspection, agents
        determined that KTRB(AM) station authorized power in the daytime mode
        was out of tolerance, the station failed to ensure that technical
        parameters were within tolerances and transmission system operation
        was monitored either at the main studio, transmitter site, or other

     f. 47 C.F.R. S: 73.1560(a)(1): "Except as provided for in paragraph (d)
        of this section, the antenna input power of an AM station as
        determined by the procedures specified in Section 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." At the time of inspection, agents determined that
        KTRB(AM) was operating at 84.1% of the authorized power in the
        daytime mode.

     g. 47 C.F.R. S: 73.1590(a)(6): "The licensee of each AM, FM, TV and
        Class A TV station, except licensees of Class D non-commercial
        educational FM stations authorized to operate with 10 watts or less
        output power, must make equipment performance measurements for each
        main transmitter... Annually, for AM stations, with not more than 14
        months between measurements." At the time of inspection, KTRB(AM)
        failed to ensure that measurements were conducted.

     h. 47 C.F.R. S: 73.1800(a): "The licensee of each station must maintain
        a station log as required by Section 73.1820. This log shall be kept
        by station employees competent to do so, having actual knowledge of
        the facts required. All entries, whether required or not by the
        provisions of this part, must accurately reflect the station
        operation. Any employee making a log entry shall sign the log,
        thereby attesting to the fact that the entry, or any correction or
        addition made thereto, is an accurate representation of what
        transpired." At the time of the inspection, there was no station log
        of KTRB(AM) station's operation.

     i. 47 C.F.R. S: 73.3526(e)(5) & (e)(8): "Contents of the file. The
        material[s] to be retained in the public inspection file [are] ...(5)
        Ownership reports and related materials.  A copy of the most recent,
        complete ownership report filed with the FCC for the station,
        together with any statements filed with the FCC certifying that the
        current report is accurate, and together with all related material.
        These materials shall be retained until a new, complete ownership
        report is filed with the FCC, at which time a copy of the new report
        and any related materials shall be placed in the file. The permittee
        or licensee must retain in the public file either a copy of the
        contracts listed in such reports in accordance with
        S:73.3615(a)(4)(i), or an up-to-date list of such contracts.
        Licensees or permittees who choose to retain a list of contracts must
        provide a copy of any contracts to requesting parties within 7 days.
        ...(8) The public and broadcasting. At all times, a copy of the most
        recent version of the manual entitled "The Public and Broadcasting."
        At the time of inspection, agents determined that KTRB(AM) public
        inspection file was missing the ownership reports and related
        materials, and a copy of the public and broadcasting manual.

     j. 47 C.F.R. S: 73.3526(c)(1): "Access to material in the file. The file
        shall be available for public inspection at any time during regular
        business hours. All or part of the file may be maintained in a
        computer database, as long as a computer terminal is made available,
        at the location of the file, to members of the public who wish to
        review the file." At the time of inspection, agents determined that
        the KTRB(AM) public inspection file was located inside the locked and
        secured building facility at 300 Broadway Street, San Francisco,
        California and there was no information posted identifying this
        facility as the studio location of KTRB(AM).

    4. As the nation's emergency warning system, the Emergency Alert System
       is critical to public safety, and we recognize the vital role that
       broadcasters play in ensuring its success. The Commission takes
       seriously any violations of the Rules implementing the EAS and expects
       full compliance from its regulatees. We also must investigate
       violations of other rules that apply to broadcast licensees. Pursuant
       to Section 403 of the Communications Act of 1934, as amended, and
       Section 1.89 of the Commission's Rules, we seek additional information
       concerning the violations and any remedial actions the station may
       have taken.  Therefore, Susan L. Uecker, Receiver, must submit a
       written statement concerning this matter within twenty (20) days of
       release of this Notice. The response (i) must fully explain each
       violation, including all relevant surrounding facts and circumstances,
       (ii) must contain a statement of the specific action(s) taken to
       correct each violation and preclude recurrence, and (iii) must include
       a time line for completion of any pending corrective action(s). The
       response must be complete in itself and must not be abbreviated by
       reference to other communications or answers to other notices.

    5. In accordance with Section 1.16 of the Commission's Rules, we direct
       Susan L. Uecker, Receiver, to support her response to this Notice with
       an affidavit or declaration under penalty of perjury, signed and dated
       by Susan L. Uecker, Receiver, verifying the truth and accuracy of the
       information therein, and confirming that all of the information
       requested by this Notice which is in the licensee's possession,
       custody, control, or knowledge has been produced. To knowingly and
       willfully make any false statement or conceal any material fact in
       reply to this Notice is punishable by fine or imprisonment under Title
       18 of the U.S. Code.

    6. 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 address:

   Federal Communications Commission

   San Francisco Office

   5653 Stoneridge Drive, Suite 105

   Pleasanton, CA 94588-8543

    7. This Notice shall be sent to Susan L. Uecker, Receiver, at her address
       of record.

    8. The Privacy Act of 1974 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.


   Thomas N. Van Stavern

   District Director

   San Francisco District Office

   Western Region

   Enforcement Bureau

   47 C.F.R. S: 1.89.

   47 C.F.R. S: 1.89(a).

   47 U.S.C. S: 403.

   47 C.F.R. S: 1.89(c).

   Section 1.16 of the Commission's Rules provides that "[a]ny document to be
   filed with the Federal Communications Commission and which is required by
   any law, rule or other regulation of the United States to be supported,
   evidenced, established or proved by a written sworn declaration,
   verification, certificate, statement, oath or affidavit by the person
   making the same, may be supported, evidenced, established or proved by the
   unsworn declaration, certification, verification, or statement in writing
   of such person . . . . Such declaration shall be subscribed by the
   declarant as true under penalty of perjury, and dated, in substantially
   the following form . . . : `I declare (or certify, verify, or state) under
   penalty of perjury that the foregoing is true and correct. Executed on
   (date). (Signature)'." 47 C.F.R. S: 1.16.

   18 U.S.C. S: 1001 et seq. See also 47 C.F.R. S: 1.17.

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

   Federal Communications Commission


                       Federal Communications Commission