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

In the Matter of                )
                                )
Johannus Orgelbouw b.v.         )    File No. EB-03-TS-089
The Netherlands                 )    NAL/Acct. No. 200432100006
                                )    FRN # 0009-7508-60
                                )    
                                   
      NOTICE OF APPARENT LIABILITY FOR FORFEITURE AND ORDER

Adopted:   November 4, 2003             Released:   November   6, 
2003

By the Chief, Enforcement Bureau:

                        I.  INTRODUCTION

     1.        In this Notice of Apparent Liability for 
Forfeiture and Order (``NAL''), we find Johannus Orgelbouw b.v. 
(``Johannus'') apparently liable for a forfeiture in the amount 
of seven thousand dollars ($7,000) for importing and marketing 
radio frequency devices which do not comply with the Commission's 
technical standards in repeated violation of Section 302(b) of 
the Communications Act of 1934, as amended (``Act''),1 and 
Section 2.803(a) of the Commission's Rules (``Rules'').2  The 
noted violations involve Johannus's importing and marketing 
digital electronic organs that do not comply with the technical 
requirements set forth in Part 15 of the Rules.  In addition, we 
order Johannus, pursuant to Section 2.956(a)(1) of the Rules,3 to 
submit to the Enforcement Bureau a copy of the verification 
records for each model of organ which it imports into the United 
States in the next two years.    
                         II.  BACKGROUND

     2.        On March 27, 2003, the Enforcement Bureau received 
a complaint alleging that Johannus was importing digital 
electronic organs that were not in compliance with the 
Commission's rules.4  The complainant asserted that other digital 
electronic organ companies were suffering competitive harm 
because Johannus, through its failure to comply with the 
Commission's rules, was able to produce digital electronic organs 
less expensively.   
     3.        On June 18, 2003, the Enforcement Bureau issued a 
letter of inquiry to Johannus.5  Johannus submitted a response to 
the letter of inquiry on June 26, 2003,6 and submitted follow-up 
responses on July 10,7 July 30,8 and September 2, 2003.9  In its 
responses, Johannus stated that it imports about three to 13 
organs a month into the U.S. and Canada.10  Johannus stated that 
it investigated as a result of the FCC inquiry and found that 
some of its organs were radiating signals in excess of the 
radiated emission limits in the Commission's rules due to a 
design change.11  According to Johannus, this change was 
installed in organs manufactured between July and October, 
2002,12 and some of those organs have been recently imported and 
marketed in the United States.13  Johannus further indicated that 
this design change was a temporary one forced by a shortage of 
certain parts and that it no longer manufactures organs with this 
design change.14  Along with its September 2, 2003, letter, 
Johannus provided a copy of a partial report from a testing 
laboratory which indicates that, based on measurements made on 
August 19, 2003, the Johannus ``Rembrandt 3900'' digital organ is 
in conformance with the radiated and conducted emission limits 
for Class A digital devices set forth in the FCC rules.15  
Johannus stated that this organ is one of its largest models and 
asserted that its other organs, which use fewer interference 
causing components, must be in compliance as well.16    
                        III.  DISCUSSION

     4.        Section 302(b) of the Act provides that ``[n]o 
person shall manufacture, import, sell, offer for sale, or ship 
devices or home electronic equipment and systems, or use devices, 
which fail to comply with regulations promulgated pursuant to 
this section.''  Section 2.803(a)(2) of the Rules provides that:  
          Except as provided elsewhere  in this section,  no 
          person shall sell or lease,  or offer for sale  or 
          lease (including advertising  for sale or  lease), 
          or import, ship, or distribute for the purpose  of 
          selling or leasing or offering for sale or  lease, 
          any radio  frequency device  unless ...  [i]n  the 
          case of a device  that is not  required to have  a 
          grant of  equipment  authorization issued  by  the 
          Commission,  but  which   must  comply  with   the 
          specified technical standards  prior to use,  such 
          device   also   complies   with   all   applicable 
          administrative  (including  verification  of   the 
          equipment or authorization under a Declaration  of 
          Conformity, where  required), technical,  labeling 
          and identification requirements specified in  this 
          chapter.

It is undisputed that Johannus imports, and markets in the  U.S., 
the Johannus organs at  issue here.  It  is also undisputed  that 
these devices are digital devices and therefore must comply  with 
the technical requirements  set forth  in Part 15  of the  Rules, 
including the radiated emission  limits.  Johannus admitted  that 
it imported and marketed in the U.S. at least one model of  organ 
(involving more  than one  organ) that  did not  comply with  the 
FCC's radiated  emission  limits  as  recently  as  July  2003.17  
Accordingly, based on  the evidence before  us, we conclude  that 
Johannus apparently repeatedly18 violated  Section 302(b) of  the 
Act and  Section  2.803(a)(2)  of  the  Rules  by  importing  and 
marketing digital electronic organs which do not comply with  the 
radiated emission  limits  set forth  in  Section 15.109  of  the 
Rules.19

     5.        Section 503(b) of the Act authorizes the 
Commission to assess a forfeiture for each willful or repeated 
violation of the Act or of any rule, regulation, or order issued 
by the Commission under the Act.20  In exercising such authority, 
we are to take into account ``the nature, circumstances, extent, 
and gravity of the violation and, with respect to the violator, 
the degree of culpability, any history of prior offenses, ability 
to pay, and such other matters as justice may require.''21
     6.        Pursuant to The Commission's Forfeiture Policy 
Statement and Amendment of Section 1.80 of the Rules to 
Incorporate the Forfeiture Guidelines (``Forfeiture Policy 
Statement'')22 and Section 1.80 of the Rules,23 the base 
forfeiture amount for importation or marketing of unauthorized or 
non-compliant equipment is $7,000.  Accordingly, we are proposing 
a forfeiture in the amount of $7,000.   We caution Johannus that 
any subsequent importing and marketing of non-compliant digital 
electronic organs will result in further sanctions, including 
substantially higher forfeiture penalties.
     7.         Additionally, while Johannus suggested in its LOI 
responses that its digital electronic organs are Class A digital 
devices, we disagree.  Rather, we believe that the devices are 
appropriately classified as Class B digital devices and therefore 
must comply with the more stringent emission limits applicable to 
Class B digital devices.  Section 15.3(h) of the Rules defines a 
Class A digital device as ``[a] digital device that is marketed 
for use in a commercial, industrial, or business environment, 
exclusive of a device which is marketed for use by the general 
public or is intended to be used in the home.''24  Section 
15.3(i) defines a Class B digital device as ``[a] digital device 
that is marketed for use in a residential environment 
notwithstanding use in commercial, business and industrial 
environments. Examples of such devices include, but are not 
limited to, personal computers, calculators, and similar 
electronic devices that are marketed for use by the general 
public.''25  Among other places, Johannus markets its organs on a 
web site, www.johannus.com.  This web site contains information 
for eight series of organs.  These series are named the Opus, 
Sweelinck, Rembrandt, Monarke, American Classic-V, Majestic, 
Sovereign, and Chamber organ.  The Johannus web site states that 
the Opus series organs ``are designed for living room and 
chapel''; the Monarch series organs ``find a place in both living 
rooms and churches''; the Majestic and Sovereign series organs 
are ``designed for both home practice purposes and church''; and 
the Chamber organ ``has been designed for both small and medium 
sized churches (and home use).''  Thus, Johannus is clearly 
marketing these devices for use in a residential environment.  
Accordingly, these devices are Class B digital devices and must 
comply with the more stringent Class B technical requirements.  
     8.        Furthermore, we note that compliance with the FCC 
rules is not simply a matter of importing equipment that meets 
the applicable technical standards.  The rules also contain, 
among other things, requirements concerning labeling of 
radiofrequency devices26 and requirements that certain 
information concerning radiofrequency devices be provided to the 
users in the user manual or instruction manual.27  The 
complainant alleged that Johannus has not been in compliance with 
the labeling and user manual requirements.  Our review of the 
user manual posted on Johannus' website confirms that Johannus is 
not in compliance with the user manual requirements.  We caution 
Johannus that, before importing or marketing any of its digital 
electronic organs in the U.S., it must ensure that it complies 
with these requirements as well.  Failure to do so may result in 
separate enforcement action.
     9.        Finally, pursuant to Section 2.956(a)(1) of the 
Rules, we order Johannus to submit to the Enforcement Bureau a 
copy of the verification records required to be maintained under 
Section 2.955 of the Rules28 for each separate model of digital 
electronic organ, including both existing models and any new 
models, which it imports into the United States within the next 
two years following the release of this NAL.  Such records must 
be submitted no later than fifteen (15) days from the date of 
importation of each model of digital electronic organ into the 
U.S.  Each unit of equipment imported must be identical to the 
unit tested, within the variation which can be expected due to 
quantity production and testing on a statistical basis.  Any 
modification or change that adversely affects the emanation 
characteristics of the modified equipment will require a new 
verification and the submission of that new verification to the 
Enforcement Bureau.  Failure to submit these required 
verification records may result in further enforcement action.         
                      IV.  ORDERING CLAUSES

     10.       Accordingly, IT IS ORDERED that, pursuant to 
pursuant to Section 503(b) of the Act  and Sections 0.111, 0.311 
and 1.80 of the Rules,29 Johannus Orgelbouw b.v. IS hereby 
NOTIFIED of its APPARENT LIABILITY FOR A FORFEITURE in the amount 
of seven thousand dollars ($7,000) for repeatedly violating 
Section 302(b) of the Act and Section 2.803(a) of the Rules.
     11.       IT IS FURTHER ORDERED THAT, pursuant to Section 
1.80 of the Rules, within thirty days of the release date of this 
Notice of Apparent Liability for Forfeiture and Order, Johannus 
Orgelbouw b.v. SHALL PAY the full amount of the proposed 
forfeiture or SHALL FILE a written statement seeking reduction or 
cancellation of the proposed forfeiture.
     12.       Payment of the forfeiture may be made by mailing a 
check or similar instrument, payable to the order of the Federal 
Communications Commission, to the Forfeiture Collection Section, 
Finance Branch, Federal Communications Commission, P.O. Box 
73482, Chicago, Illinois 60673-7482.  The payment must include 
the FCC Registration Number (FRN) and the NAL/Acct. No. 
referenced in the caption. 
     13.       The response, if any, must be mailed to the Office 
of the Secretary, Federal Communications Commission, 445 12th 
Street, S.W., Washington, D.C. 20554, ATTN: Enforcement Bureau - 
Spectrum Enforcement Division, and must include the NAL/Acct. No. 
referenced in the caption.
     14.       The Commission will not consider reducing or 
canceling a forfeiture in response to a claim of inability to pay 
unless the petitioner submits:  (1) federal tax returns for the 
most recent three-year period; (2) financial statements prepared 
according to generally accepted accounting; or (3) some other 
reliable and objective documentation that accurately reflects the 
petitioner's current financial status.  Any claim of inability to 
pay must specifically identify the basis for the claim by 
reference to the financial documentation submitted.
     15.       Requests for payment of the full amount of this 
NAL under an installment plan should be sent to: Chief, Revenue 
and Receivable Operations Group, 445 12th Street, S.W., 
Washington, D.C. 20554.30
     16.       Under the Small Business Paperwork Relief Act of 
2002, Pub L. No. 107-198, 116 Stat. 729 (June 28, 2002), the FCC 
is engaged in a two-year tracking process regarding the size of 
entities involved in forfeitures.  If you qualify as a small 
entity and if you wish to be treated as a small entity for 
tracking purposes, please so certify to us within thirty (30) 
days of this NAL, either in your response to the NAL or in a 
separate filing to be sent to the Enforcement Bureau - Spectrum 
Enforcement Division.  Your certification should indicate whether 
you, including your parent entity and its subsidiaries, meet one 
of the definitions set forth in the list provided by the FCC's 
Office of Communications Business Opportunities (``OCBO'') set 
forth in Attachment A of this NAL.  This information will be used 
for tracking purposes only.  Your response or failure to respond 
to this question will have no effect on your rights and 
responsibilities pursuant to Section 503(b) of the Act.  If you 
have questions regarding any of the information contained in 
Attachment A, please contact OCBO at (202) 418-0990.
     17.       IT IS FURTHER ORDERED that, for two years from the 
date of release of this Notice of Apparent Liability for 
Forfeiture and Order, Johannus Orgelbouw b.v. must submit the 
records described in paragraph 9 no later than fifteen (15) days 
from the date of importation of each model of digital electronic 
organ into the U.S.  These records must be submitted to:  Federal 
Communications Commission, Enforcement Bureau, Spectrum 
Enforcement Division, 445 12th Street, S.W., Washington, D.C. 
20554, Attention:  Kathryn Berthot, Room 7-C802.
     18.       IT IS FURTHER ORDERED that a copy of this Notice 
of Apparent Liability for Forfeiture and Order shall be sent by 
first class mail and certified mail return receipt requested to 
Gert A. Van de Weerd, President, Johannus Orgelbouw b.v., 
Keplerlaan 2, 6726 BS EDE, The Netherlands.
  

                         FEDERAL COMMUNICATIONS COMMISSION
                         


                         David H. Solomon
                         Chief, Enforcement Bureau

Attachment A


                FCC List of Small Entities

   As described below, a ``small entity'' may be a small 
                       organization,
  a small governmental jurisdiction, or a small business.

(1)  Small Organization 
Any not-for-profit enterprise that is independently owned 
and operated and 
is not dominant in its field.

  
(2)  Small Governmental Jurisdiction
Governments of cities, counties, towns, townships, villages, 
school districts, or 
special districts, with a population of less than fifty 
thousand.


(3)  Small Business
Any business concern that is independently owned and 
operated and 
is not dominant in its field, and meets the pertinent size 
criterion described below.
  

      Industry Type          Description of Small Business 
                                     Size Standards
                 Cable Services or Systems
                            Special Size Standard - 
Cable Systems                Small Cable Company has 400,000 
                            Subscribers Nationwide or Fewer
Cable and Other Program 
Distribution                     $12.5 Million in Annual 
                                    Receipts or Less

Open Video Systems 
       Common Carrier Services and Related Entities
Wireline Carriers and 
Service providers 
                                1,500 Employees or Fewer
Local Exchange Carriers, 
Competitive Access 
Providers, Interexchange 
Carriers, Operator Service 
Providers, Payphone 
Providers, and Resellers


Note:  With the exception of Cable Systems, all size 
standards are expressed in either millions of dollars or 
number of employees and are generally the average annual 
receipts or the average employment of a firm.  Directions 
for calculating average annual receipts and average 
employment of a firm can be found in 
13 CFR 121.104 and 13 CFR 121.106, respectively.





                  International Services
International Broadcast 
Stations






                                $12.5 Million in Annual 
                                    Receipts or Less
International Public Fixed 
Radio (Public and Control 
Stations)
Fixed Satellite 
Transmit/Receive Earth 
Stations
Fixed Satellite Very Small 
Aperture Terminal Systems
Mobile Satellite Earth 
Stations
Radio Determination 
Satellite Earth Stations
Geostationary Space Stations
Non-Geostationary Space 
Stations
Direct Broadcast Satellites
Home Satellite Dish Service
                    Mass Media Services
Television Services

                             $12 Million in Annual Receipts 
                                        or Less
Low Power Television 
Services and Television 
Translator Stations
TV Auxiliary, Special 
Broadcast and Other Program 
Distribution Services
Radio Services
                             $6 Million in Annual Receipts 
                                        or Less
Radio Auxiliary, Special 
Broadcast and Other Program 
Distribution Services
Multipoint Distribution      Auction Special Size Standard -
Service                      Small Business is less than 
                            $40M in annual gross revenues 
                            for three preceding years
          Wireless and Commercial Mobile Services
Cellular Licensees
                                1,500 Employees or Fewer
220 MHz Radio Service - 
Phase I Licensees
220 MHz Radio Service -      Auction special size standard -
Phase II Licensees           Small Business is average gross 
                            revenues of $15M or less for 
                            the preceding three years 
                            (includes affiliates and 
                            controlling principals)
                            Very Small Business is average 
                            gross revenues of $3M or less 
                            for the preceding three years 
                            (includes affiliates and 
                            controlling principals)
700 MHZ Guard Band Licensees


Private and Common Carrier 
Paging
Broadband Personal 
Communications Services          1,500 Employees or Fewer
(Blocks A, B, D, and E)
Broadband Personal           Auction special size standard -
Communications Services      Small Business is $40M or less 
(Block C)                    in annual gross revenues for 
                            three previous calendar years
                            Very Small Business is average 
                            gross revenues of $15M or less 
                            for the preceding three 
                            calendar years (includes 
                            affiliates and persons or 
                            entities that hold interest in 
                            such entity and their 
                            affiliates)
Broadband Personal 
Communications Services 
(Block F)
Narrowband Personal 
Communications Services


Rural Radiotelephone Service     1,500 Employees or Fewer
Air-Ground Radiotelephone 
Service
800 MHz Specialized Mobile   Auction special size standard -
Radio                        Small Business is $15M or less 
                            average annual gross revenues 
                            for three preceding calendar 
                            years
900 MHz Specialized Mobile 
Radio
Private Land Mobile Radio        1,500 Employees or Fewer
Amateur Radio Service                      N/A
Aviation and Marine Radio 
Service                          1,500 Employees or Fewer
Fixed Microwave Services
                            Small Business is 1,500 
Public Safety Radio Services employees or less
                            Small Government Entities has 
                            population of less than 50,000 
                            persons
Wireless Telephony and 
Paging and Messaging             1,500 Employees or Fewer
Personal Radio Services                    N/A
Offshore Radiotelephone          1,500 Employees or Fewer
Service
Wireless Communications      Small Business is $40M or less 
Services                     average annual gross revenues 
                            for three preceding years
                            Very Small Business is average 
                            gross revenues of $15M or less 
                            for the preceding three years 

39 GHz Service
                            Auction special size standard 
                            (1996) -
Multipoint Distribution      Small Business is $40M or less 
Service                      average annual gross revenues 
                            for three preceding calendar 
                            years
                            Prior to Auction -
                            Small Business has annual 
                            revenue of $12.5M or less
Multichannel Multipoint 
Distribution Service             $12.5 Million in Annual 
                                    Receipts or Less
Instructional Television 
Fixed Service
                            Auction special size standard 
                            (1998) -
Local Multipoint             Small Business is $40M or less 
Distribution Service         average annual gross revenues 
                            for three preceding years
                            Very Small Business is average 
                            gross revenues of $15M or less 
                            for the preceding three years 
                            First Auction special size 
                            standard (1994) -
                            Small Business is an entity 
                            that, together with its 
                            affiliates, has no more than a 
218-219 MHZ Service          $6M net worth and, after 
                            federal income taxes (excluding 
                            carryover losses) has no more 
                            than $2M in annual profits each 
                            year for the previous two years
                            New Standard - 
                            Small Business is average gross 
                            revenues of $15M or less for 
                            the preceding three years 
                            (includes affiliates and 
                            persons or entities that hold 
                            interest in such entity and 
                            their affiliates)
                            Very Small Business is average 
                            gross revenues of $3M or less 
                            for the preceding three years 
                            (includes affiliates and 
                            persons or entities that hold 
                            interest in such entity and 
                            their affiliates)
Satellite Master Antenna 
Television Systems               $12.5 Million in Annual 
                                    Receipts or Less
24 GHz - Incumbent Licensees     1,500 Employees or Fewer
24 GHz - Future Licensees    Small Business is average gross 
                            revenues of $15M or less for 
                            the preceding three years 
                            (includes affiliates and 
                            persons or entities that hold 
                            interest in such entity and 
                            their affiliates)
                            Very Small Business is average 
                            gross revenues of $3M or less 
                            for the preceding three years 
                            (includes affiliates and 
                            persons or entities that hold 
                            interest in such entity and 
                            their affiliates)
                       Miscellaneous
On-Line Information Services  $18 Million in Annual Receipts 
                                        or Less
Radio and Television 
Broadcasting and Wireless 
Communications Equipment          750 Employees or Fewer
Manufacturers
Audio and Video Equipment 
Manufacturers
Telephone Apparatus 
Manufacturers (Except            1,000 Employees or Fewer
Cellular)
Medical Implant Device            500 Employees or Fewer
Manufacturers
Hospitals                     $29 Million in Annual Receipts 
                                        or Less
Nursing Homes                    $11.5 Million in Annual 
                                    Receipts or Less
Hotels and Motels             $6 Million in Annual Receipts 
                                        or Less
Tower Owners                 (See Lessee's Type of Business)




_________________________

  1 47 U.S.C. § 302a(b).

  2 47 C.F.R. § 2.803(a).

  3 47 C.F.R. § 2.956(a)(1).

  4  Specifically, the  complainant stated  that it  purchased  a 
Johannus Rembrandt  Model  370  organ,  tested  the  device,  and 
concluded that  it  did not  comply  with the  radiated  emission 
limits for Class B digital devices.  The complainant also alleged 
that the Johannus organs do not comply with the Part 15  labeling 
and user manual requirements.

  5  Letter to  Johannus Orgelbouw  b.v.  from Joseph  P.  Casey, 
Chief, Technical and Public  Safety Division, Enforcement  Bureau 
(June 18, 2003).

  6 Letter  to Enforcement  Bureau, Technical  and Public  Safety 
Division,  from  Gert  A.  Van  de  Weerd,  President,   Johannus 
Orgelbouw b.v. (June 26, 2003).  

  7 Letter  to Enforcement  Bureau, Technical  and Public  Safety 
Division,  from  Gert  A.  Van  de  Weerd,  President,   Johannus 
Orgelbouw b.v. (July 10, 2003) (``July 10 Letter'').

  8 Letter  to Enforcement  Bureau, Technical  and Public  Safety 
Division,  from  Gert  A.  Van  de  Weerd,  President,   Johannus 
Orgelbouw b.v. (July 30, 2003) (``July 30 Letter'').

  9 Letter  to Enforcement  Bureau, Technical  and Public  Safety 
Division,  from  Gert  A.  Van  de  Weerd,  President,   Johannus 
Orgelbouw b.v. (September 2, 2003) (``September 2 Letter'').

  10 September 2 Letter (``We sell and install about 3-13  organs 
a month in the  USA and Canada, mainly  to churches, but also  to 
concert halls and cemeteries.'').

  11 July  30 Letter (``As far  as we know  today, the source  of 
the violation is a  modification on the CPU  board.  We added  an 
extra track of 3,4 volt  power supply.  Unfortunately this  track 
became an antenna.  Neutral  and Line Disturbance tests  remained 
ok, while the test of  the Horizontal Polarization showed only  a 
small  violation  on  229,4  MHz  of  -1.54  dB.   The   Vertical 
Polarization test however showed the bad results.'').

  12 July  10 Letter (``We believe  that the modifications  which 
are the reason, that some of our organs were violating FCC rules, 
have been done between July and October 2002.  The  modifications 
have been built in limited numbers of organs.  Some of them  have 
been shipped to the US and probably  you have seen a test of  one 
of them.'').  In its July 10 Letter, Johannus also provided  test 
results for one of its organs which showed that the organ was not 
in compliance  with  the radiated  emission  limits for  Class  A 
digital devices.  Johannus did not  specify which organ model  it 
tested, but it appears  that the non-compliant  organ was one  of 
its Rembrandt model organs, which  Johannus states is one of  its 
best selling organs in the U.S.

  13 July  30 Letter (``If  necessary we will  be able to  modify 
the suspected organs by exchanging the CPU boards.  Also the  few 
organs (About 7-10 pieces are far  I can find out at the  moment.  
However, some of them must  be ok.) who are on  the way - on  the 
ocean or in the  USA -, can easily  be modified when they  arrive 
and we also have discovered, which of them are faulty.'').  

  14 July 10 Letter.

  15 September 2 Letter.

  16 Id.

  17 See footnotes 11-12, supra.

  18  Section 312(f)(2)  of the  Act provides  that ``[t]he  term 
`repeated,' ... means the commission or omission of such act more 
than once or, if such  commission or omission is continuous,  for 
more than one day.''  47 U.S.C. § 312(f)(2).

  19 47  C.F.R. § 15.109.  Based  on Johannus's responses to  our 
LOI, it appears that Johannus  imported and marketed organs  that 
did not  comply with  the radiated  emission limits  for Class  A 
digital devices.  However, as explained  in paragraph 7, we  find 
that Johannus's organs are actually  Class B digital devices  and 
therefore must  comply with  the more  stringent emission  limits 
applicable to such devices. 

  20 47 U.S.C. § 503(b).

  21 47 U.S.C. § 503(b)(2)(D).

  22  12 FCC  Rcd 17087  (1997),  recon. denied  15 FCC  Rcd  303 
(1999).

  23 47 C.F.R. § 1.80.

  24 47 C.F.R. § 15.3(h).

  25 47 C.F.R. § 15(i).

  26 See 47 C.F.R. § 15.19.

  27 See 47 C.F.R. § 15.105.

  28 47 C.F.R. § 2.955.

  29 47 C.F.R. § 0.111, 0.311 and 1.80.

  30 See 47 C.F.R. § 1.1914.