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                                   Before the

                       Federal Communications Commission

                             Washington, D.C. 20554

   In the Matter of )


   Real Life Broadcasting, Inc. ) File No. EB-FIELDNER-12-00002778

   Licensee of Station WIFI )

   Facility ID # 55310 )

   Florence, New Jersey ) NOV No. V201232400046



                              NOTICE OF VIOLATION

   Released: September 14, 2012

   By the District Director, Philadelphia Office, Northeast Region,
   Enforcement Bureau:

    1. This is a Notice of Violation (Notice) issued pursuant to Section 1.89
       of the Commission's rules (Rules), to Real Life Broadcasting, Inc.
       (Real Life), licensee of AM Station WIFI in Florence, Pennsylvania.
       Pursuant to Section 1.89(a) of the Rules, issuance of this NOV does
       not preclude the Enforcement Bureau from further action if warranted,
       including issuing a Notice of Apparent Liability for Forfeiture for
       the violations noted herein.

    2. On June 13, 2012, agents of the Enforcement Bureau's Philadelphia
       Office inspected AM Station WIFI located at 2025 Columbus Road,
       Burlington, New Jersey and observed the following violations:

     a. 47 C.F.R. S: 11.35(a): "...EAS Participants 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, EAS Participants must determine the cause of any
        failure to receive the required tests or activations specified in
        S:11.61(a)(1) and (a)(2). Appropriate entries indicating reasons why
        any tests were not received must be made in the broadcast station
        logs as specified in S:S:73.1820 and 73.1840 of this chapter... " For
        the period between April 2, 2012 and June 12, 2012, Real Life failed
        to ensure that Station WIFI was receiving and transmitting the
        required weekly tests and required monthly tests. Furthermore, at the
        time of the inspection, there were no entries in the station's log
        indicating reasons why Station WIFI did not receive the Required
        Monthly Tests during this period.

     b. 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...." At the time of inspection, Real Life was not monitoring a
        New Jersey Network Station as required in the New Jersey State EAS

     c. 47 C.F.R. S: 73.62(a): "Each AM station operating a directional
        antenna must maintain the relative amplitudes of the antenna
        currents, as indicated by the antenna monitor, within 5% of the
        values specified on the instrument of authorization. Directional
        antenna relative phase must be maintained within 3 degrees of the
        values specified on the instrument of authorization." At the time of
        inspection, Station WIFI was operating out of tolerance with its
        authorized directional antenna parameters.

     d. 47 C.F.R. S: 73.1560(a)(1): "[t]he antenna input power of an AM
        station as determined by the procedures specified in S: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 authorization for Station WIFI specifies a
        daytime antenna input power of 5250 Watts and a nighttime antenna
        input power of 540 Watts. Agents made numerous field strength
        measurements that revealed Station WIFI operated with its daytime
        power between 8:30 p.m. and 10:30 p.m. on June 6, 2012 and June 7,
        2012. The agents also determined that Station WIFI was operating
        after 10:30 p.m. on June 6, 2012 and June 7, 2012 with an antenna
        input power of 210 Watts or 39% of that authorized.

     e. 47 C.F.R. S: 73.1590(a)(6): "(a) 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 as follows:... (6) Annually, for AM stations, with
        not more than 14 months between measurements." At the time of the
        inspection, Real Life could not produce any equipment performance
        measurements for Station WIFI.

     f. 47 C.F.R. S:S: 73.1870(a)(1) & (a)(3): "The licensee of each AM, FM,
        TV or Class A TV station must designate a person to serve as the
        station's chief operator... The designation of the chief operator
        must be in writing and posted with the station's license." The agents
        found no written designation of a chief operator for the station.

     g. 47 C.F.R. S: 73.1870(c)(3): "(c) The chief operator is responsible
        for completion of the following duties specified in this paragraph
        below. ... (3) Review 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 had not
        signed the EAS logs for over six months.

     h. 47 C.F.R. S:S: 73.3526(e)(8), (e)(12), (e)(14): "Contents of the
        file. The material[s] to be retained in the public inspection file
        [are]...(8) The public and broadcasting. At all times, a copy of the
        most recent version of the manual entitled "The Public and
        Broadcasting."... (12) Radio issues/programs lists. For commercial AM
        and FM broadcast stations, every three months a list of programs that
        have provided the station's most significant treatment of community
        issues during the preceding three month period. The list for each
        calendar quarter is to be filed by the tenth day of the succeeding
        calendar quarter (e.g., January 10 for the quarter October-December,
        April 10 for the quarter January-March, etc.). The list shall include
        a brief narrative describing what issues were given significant
        treatment and the programming that provided this treatment. The
        description of the programs shall include, but shall not be limited
        to, the time, date, duration, and title of each program in which the
        issue was treated... (14) Radio and television time brokerage
        agreements. For commercial radio and television stations, a copy of
        every agreement or contract involving time brokerage of the
        licensee's station or of another station by the licensee, whether the
        agreement involves stations in the same markets or in differing
        markets, with confidential or proprietary information redacted where
        appropriate. These records shall be retained as long as the contract
        or agreement is in force." At the time of the inspection, the public
        file was missing The Public and Broadcasting, the radio
        issues/programs lists for the 3rd and 4th Quarters of 2011 and 1st
        Quarter of 2012, and the Time Brokerage Agreement between Real Life
        and Florence Broadcast Partners.

    3. 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.

    4. Pursuant to Section 308(b) 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 taken. Therefore, Real Life Broadcasting 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
       Real Life Broadcasting, Inc. to support its response to this Notice
       with an affidavit or declaration under penalty of perjury, signed and
       dated by an authorized officer of Real Life Broadcasting, Inc. with
       personal knowledge of the representations provided in Real Life
       Broadcasting, Inc.'s response, 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

   Philadelphia Office

   One Oxford Valley Building, Suite 404

   2300 East Lincoln Highway

   Langhorne, Pennsylvania 19047

    7. This Notice shall be sent to Real Life Broadcasting, Inc. at its
       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.


   David C. Dombrowski

   District Director

   Philadelphia District Office

   Northeast Region

   Enforcement Bureau

   47 C.F.R. S: 1.89.

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

   The determination was based on a common point current meter reading of 2.0
   Amps when the station's transmitter was temporarily switched to nighttime

   47 U.S.C. S: 308(b).

   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