Click here for Adobe Acrobat version
Click here for Microsoft Word version

This document was converted from Microsoft Word.

Content from the original version of the document such as
headers, footers, footnotes, endnotes, graphics, and page numbers
will not show up in this text version.

All text attributes such as bold, italic, underlining, etc. from the
original document will not show up in this text version.

Features of the original document layout such as
columns, tables, line and letter spacing, pagination, and margins
will not be preserved in the text version.

If you need the complete document, download the
Microsoft Word or Adobe Acrobat version.


                                   Before the

                       Federal Communications Commission

                             Washington, D.C. 20554

     In the Matter of                 )                                      
                                          File No.: EB-FIELDSCR-12-00005158  
     Steckline Communications, Inc.   )                                      
                                          NOV No.: V201332560005             
     Licensee of Radio Station KQAM   )                                      
                                          Facility ID No.: 61362             
     Wichita, Kansas                  )                                      

                              NOTICE OF VIOLATION

   Released: November 8, 2012

   By the District Director, Kansas City 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 (Rules) to Steckline Communications, Inc.,
       licensee of Station KQAM in Wichita, Kansas.  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 violation(s)
       noted herein.

    2. On October 22, 2012, an agent of the Commission's Kansas City Office 
       inspected Station KQAM located at 1632 S. Maize Rd., Wichita, Kansas,
       and observed the following violation(s):

          47 C.F.R.S:73.1560(a): "AM stations...(1)... the antenna input     
          power of an AM station ... must be maintained as near as is        
          practicable to the authorized antenna input power and my not be    
          less than 90% nor more than 105% of the authorized power. (2)      
     a.   Whenever the transmitter of an AM station cannot be placed into    
          the specified operating mode at the time required, transmissions   
          of the station must be immediately terminated." At the time of     
          inspection, the nighttime power was set for 5.8amps common point   
          current, which is 156% of authorized nighttime power.              

          47 C.F.R.S:73.61(a): "Each AM station using a directional antenna  
          must make field strength measurements at the monitoring point      
          locations specified in the instrument of authorization, as often   
          as necessary to ensure that the field at those points does not     
          exceed the values specified in the station authorization... The    
          results of the measurements are to be entered into the station     
          log."  Prior to the inspection, the last monitoring point          
     b.   readings were taken on September 26, 2012 by a consulting group.   
          Those readings were not entered into the station logs. The         
          measurements taken by that consulting group found one reading in   
          excess of the authorized limits and no efforts were made to        
          correct this out of tolerance condition until after the            
          inspection. At the time of inspection, several directional         
          parameters were out of tolerance and no efforts were being made    
          to check the monitoring points to ensure the station was within    
          authorized limits                                                  

          47 C.F.R.S:73.62(a): "Each AM station operating a directional      
          antenna must maintain the indicated relative amplitudes of the     
          antenna monitor currents within 5% of the values specified         
          therein.  Directional antenna relative phase currents must be      
     c.   maintained to within 3 deg. of the values specified on the         
          instrument of authorization." At the time of inspection, the       
          current ratio for tower number 4 during daytime operation was      
          10.6% higher than that authorized. For nighttime operation, the    
          current ratio for tower numbers 1, 4, and 5 were 22.1%, 23.2% and  
          24.7%,  respectively, in deviation from that authorized.           

          47 C.F.R.S:73.1820(a): "Entries must be made in the station log    
          either manually by a person designated by the licensee who is in   
          actual charge of the transmitting apparatus, or by automatic       
          devices... Indications of operating parameters that are required   
          to be logged must be logged prior to any adjustment of the         
          equipment. Where adjustments are made to restore parameters to     
          their proper operating values, the corrected indications must be   
          logged and accompanied, if any parameter deviation was beyond a    
          prescribed tolerance, by a notation describing the nation of the   
          corrective action. Indications of all parameters whose values are  
     d.   affected by the modulation of the carrier must be read without     
          modulation. The actual time of observation must be included in     
          each log entry."  At the time of inspection, the licensee was not  
          maintaining station logs for anything other than Emergency Alert   
          System equipment. The directional parameters for both daytime and  
          nighttime operation were out of tolerance and there were no logs   
          documenting when this began. In addition, the last monitoring      
          point readings taken in September 2012 by a consulting firm had    
          not been entered into the station logs, they were not available    
          at the time of inspection and those readings, when they were       
          submitted later, indicated out of tolerance conditions.            

          47 C.F.R.S:73.3526(e)(12): "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    
     e.   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. The      
          lists described in this paragraph shall be retained in the public  
          inspection file until final action has been taken on the           
          station's next license renewal application." At the time of        
          inspection the stations issues-programs list consisted of a list   
          of issues only. The station did not maintain a list of programs    
          aired to address those issues.                                     

    3. Pursuant to Section 308(b) of the Communications Act of 1934, as
       amended, and Section 1.89 of the Rules, Steckline Communications,
       Inc., must submit a written statement concerning this matter within
       twenty (20) days of release of this Notice. The response must (i)
       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.

    4. In accordance with Section 1.16 of the Rules, we direct Steckline
       Communications, 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 Steckline Communications, Inc. with personal
       knowledge of the representations provided in Steckline Communications,
       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.
       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

   Kansas City Office

   520 N.E. Colbern Rd.

   2nd Floor

   Lees Summit, MO  64086-4711

    5. This Notice shall be sent to Steckline Communications, Inc. at its
       address of record.

    6. 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. 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.


   Ronald D. Ramage

   District Director

   Kansas City Office

   South Central Region

   Enforcement Bureau

   47 C.F.R. S: 1.89.

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

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

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

   Section 1.16 of the 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).

   18 U.S.C. S: 1001 et seq.

                       Federal Communications Commission


                       Federal Communications Commission