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Before the
Federal Communications Commission
Washington, D.C. 20554
)
In the Matter of ) File No. EB-09-SE-191
Champaign Telephone Company d/b/a ) NAL/Acct. No. 201132100016
CT Communications, Inc. ) FRN No. 0002926582
)
ORDER AND Notice of apparent Liability for forfeiture
Adopted: December 30, 2010 Released: December 30, 2010
By the Acting Chief, Spectrum Enforcement Division, Enforcement Bureau:
I. introduction
1. In this Notice of Apparent Liability for Forfeiture ("NAL"), we find
that the Champaign Telephone Company d/b/a CT Communications, Inc., a
reseller of mobile wireless services through its operating division, CT
Wireless (collectively, "CT Communications"), apparently willfully
violated the wireless handset hearing aid compatibility status report
filing requirements set forth in section 20.19(i)(1) of the Commission's
Rules ("Rules"). For this apparent violation, we propose a forfeiture in
the amount of six thousand dollars ($6,000). We also direct CT
Communications to file the required wireless handset hearing aid
compatibility status report within thirty (30) days after the release of
this NAL.
II. BACKGROUND
2. In the 2003 Hearing Aid Compatibility Order, the Commission adopted
several measures to enhance the ability of consumers with hearing loss to
access digital wireless telecommunications. The Commission established
technical standards that digital wireless handsets must meet to be
considered compatible with hearing aids operating in acoustic coupling and
inductive coupling (telecoil) modes. The Commission further established,
for each standard, deadlines by which manufacturers and service providers
were required to offer specified numbers or percentages of digital
wireless handsets per air interface that are compliant with the relevant
standard if they did not come under the de minimis exception. In February
2008, as part of a comprehensive reconsideration of the effectiveness of
the hearing aid compatibility rules, the Commission released an order
that, among other things, adopted new compatible handset deployment
benchmarks beginning in 2008.
3. Of primary relevance here, the Commission also adopted reporting
requirements to ensure that it could monitor the availability of these
handsets and to provide valuable information to the public concerning the
technical testing and commercial availability of hearing aid-compatible
handsets, including on the Internet. The Commission initially required
manufacturers and digital wireless service providers to report every six
months on efforts toward compliance with the hearing aid compatibility
requirements for the first three years of implementation (May 17, 2004,
November 17, 2004, May 17, 2005, November 17, 2005, May 17, 2006 and
November 17, 2006), and then annually thereafter through the fifth year of
implementation (November 19, 2007 and November 17, 2008). In its 2008
Hearing Aid Compatibility First Report and Order, the Commission extended
these reporting requirements with certain modifications on an open ended
basis, beginning January 15, 2009. The Commission also made clear that
these reporting requirements apply to manufacturers and service providers
that fit within the de minimis exception.
4. CT Communications, a reseller of wireless service through its
subdivision CT Wireless, failed to file the required hearing aid
compatibility status report for the period from July 1, 2008 through
December 31, 2008 (due January 15, 2009). The Wireless Telecommunications
Bureau referred CT Communications's apparent violation of the reporting
requirements to the Enforcement Bureau for possible enforcement action. On
November 24, 2009, the Enforcement Bureau's Spectrum Enforcement Division
("Division") issued a Letter of Inquiry ("LOI") to CT Communications, via
its subdivision, CT Wireless. CT Communications responded on December 3,
2009. In its LOI Response, CT Communications states that it has partnered
with Zefcom LLC d/b/a Telispire PCS ("Telispire") to provide wireless
service to customers, and claims that, as such, Telispire filed its
January 15, 2009 hearing aid compatibility status report on behalf of both
CT Communications and Telispire.
III. DISCUSSION
A. Failure to File Timely Hearing Aid Compatibility Status Report
5. Section 20.19(i)(1) of the Rules requires service providers to submit
hearing aid compatibility status reports on January 15, 2009 (covering the
six-month period ending December 31, 2008) and then annually thereafter.
These reports are necessary to enable the Commission to perform its
enforcement function and evaluate whether CT Communications is in
compliance with Commission mandates that were adopted to facilitate the
accessibility of hearing aid-compatible wireless handsets. These reports
also provide valuable information to the public concerning the technical
testing and commercial availability of hearing aid-compatible handsets.
To date, Commission records show no January 15, 2009 status report on file
for CT Communications. While Commission records do confirm that Telispire
filed a hearing aid compatibility status report on January 15, 2009,
Telispire's report fails to satisfy CT Communications's filing
requirements. The report makes no reference to CT Communications and
therefore does not provide a discernible way for the Commission or
consumers to determine the number, model, or technical standards of the
wireless hearing aid-compatible handsets that CT Communications offered -
thus frustrating the main objectives of the filing requirement. Regardless
of any contractual arrangement between Telispire and CT Communications
resulting from their joint efforts to provide wireless service, the
relevant Commission rules and orders make it clear that the filing
obligation ultimately rests with CT Communications. Moreover, even if
there was a contractual arrangement for Telispire to also file a 2009
Report that included CT Communications, CT Communications would be
responsible for the acts or omissions of its employees or third party
contractors. Accordingly, we find that CT Communications failed to timely
file the hearing aid compatibility status report due on January 15, 2009
in apparent willful violation of the requirements set forth in section
20.19(i)(1) of the Rules.
B. Proposed Forfeiture
6. Under section 503(b)(1)(B) of the Act, any person who is determined by
the Commission to have willfully or repeatedly failed to comply with any
provision of the Act or any rule, regulation, or order issued by the
Commission shall be liable to the United States for a forfeiture penalty.
To impose such a forfeiture penalty, the Commission must issue a notice of
apparent liability and the person against whom such notice has been issued
must have an opportunity to show, in writing, why no such forfeiture
penalty should be imposed. The Commission will then issue a forfeiture if
it finds by a preponderance of the evidence that the person has violated
the Act or a Commission rule. Under this standard, we conclude that CT
Communications is apparently liable for forfeiture for its failure to
timely file the required hearing aid compatibility status report in
apparent willful violation of section 20.19(i)(1) of the Rules.
7. The Commission's Forfeiture Policy Statement and section 1.80(b) of the
Rules set a base forfeiture amount of $3,000 for the failure to file
required forms or information. While the base forfeiture guidelines lend
some predictability to the forfeiture process, the Commission retains the
discretion to depart from these guidelines and issue forfeitures on a
case-by-case basis, under its general forfeiture authority contained in
section 503 of the Act. In exercising such discretion, we are required 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."
8. We have exercised our discretion to set a higher base forfeiture amount
for violations of the wireless hearing aid compatibility reporting
requirements. In the American Samoa Telecommunications Authority NAL, we
found that status reports are essential to the implementation and
enforcement of the hearing aid compatibility rules. The Commission relies
on these reports to provide consumers with information regarding the
technical specifications and commercial availability of hearing
aid-compatible digital wireless handsets and to hold the digital wireless
industry accountable to the increasing number of consumers with hearing
loss. We noted that when setting an $8,000 base forfeiture for violations
of the hearing aid-compatible handset labeling requirements, the
Commission emphasized that individuals with hearing loss could only take
advantage of critically important public safety benefits of digital
wireless services if they had access to accurate information regarding
hearing aid compatibility features of handsets. We also noted that the
Commission has adjusted the base forfeiture upward when noncompliance with
filing requirements interferes with the accurate administration and
enforcement of Commission rules. Because the failure to file hearing aid
compatibility status reports implicates similar public safety and
enforcement concerns, we exercised our discretionary authority and
established a base forfeiture amount of $6,000 for failure to file hearing
aid compatibility reports. Consistent with ASTCA, we believe the
established $6,000 base forfeiture for each hearing aid compatibility
reporting violation should apply here.
9. Failure to file these reports, as is the case here, can have an adverse
impact on the Commission's ability to ensure the commercial availability
of hearing aid-compatible digital wireless handsets, to the detriment of
consumers. Furthermore, in ASTCA, we made clear that failure to file a
hearing aid compatibility status report constitutes a continuing violation
that continues until the violation is cured. CT Communications's failure
to file the 2009 report on time had an adverse impact on the Commission's
ability to monitor and ensure the commercial availability of hearing
aid-compatible digital wireless handsets. We do not believe that the
circumstances presented warrant any downward adjustment of the proposed
forfeiture amount. It is well established that a violator's lack of
knowledge or erroneous beliefs are not a mitigating factor warranting a
forfeiture reduction. Accordingly, we propose a forfeiture of $6,000
against CT Communications for apparently willfully failing to timely file
its January 15, 2009 hearing aid compatibility status report in violation
of section 20.19(i)(1) of the Rules.
10. Finally, it appears that CT Communications still has not filed its
hearing aid compatibility status report for the six-month period ending
December 31, 2008, which was due on January 15, 2009. This report is
necessary to enable the Commission to monitor the commercial availability
of hearing aid-compatible handsets and to assess CT Communications's
compliance with the hearing aid compatibility handset requirements during
that period. We accordingly direct CT Communications to submit the report
within thirty (30) days after the release of this NAL.
IV. ORDERING clauses
11. Accordingly, IT IS ORDERED that, pursuant to section 503(b) of the
Act, and sections 0.111, 0.311, and 1.80 of the Rules, Champaign Telephone
Company d/b/a CT Communications, Inc. is NOTIFIED of its APPARENT
LIABILITY FOR A FORFEITURE in the amount of six thousand dollars ($6,000)
for its failure to file the required hearing aid compatibility status
report in apparent willful violation of the requirements set forth in
section 20.19(i)(1) of the Rules.
12. IT IS FURTHER ORDERED that, pursuant to section 1.80 of the Rules,
within thirty (30) days of the release date of this Notice of Apparent
Liability for Forfeiture, Champaign Telephone Company d/b/a CT
Communications, Inc. SHALL PAY the full amount of the proposed forfeiture
or SHALL FILE a written statement seeking reduction or cancellation of the
proposed forfeiture.
13. Payment of the forfeiture must be made by check or similar instrument,
payable to the order of the Federal Communications Commission. The payment
must include the NAL/Account Number and FRN Number referenced above.
Payment by check or money order may be mailed to Federal Communications
Commission, P.O. Box 979088, St. Louis, MO 63197-9000. Payment by
overnight mail may be sent to U.S. Bank - Government Lockbox #979088,
SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO 63101. Payment by wire
transfer may be made to ABA Number 021030004, receiving bank TREAS/NYC,
and account number 27000001. For payment by credit card, an FCC Form 159
(Remittance Advice) must be submitted. When completing the FCC Form 159,
enter the NAL/Account number in block number 23A (call sign/other ID), and
enter the letters "FORF" in block number 24A (payment type code). Requests
for full payment under an installment plan should be sent to: Chief
Financial Officer - Financial Operations, 445 12th Street, S.W., Room
1-A625, Washington, D.C. 20554. Please contact the Financial Operations
Group Help Desk at 1-877-480-3201 or Email: ARINQUIRIES@fcc.gov with any
questions regarding payment procedures. Champaign Telephone Company d/b/a
CT Communications, Inc. also shall send electronic notification to Pamera
Hairston at Pamera.Hairston@fcc.gov and to Nissa Laughner at
Nissa.Laughner@fcc.gov on the date said payment is made.
14. The written statement seeking reduction or cancellation of the
proposed forfeiture, if any, must include a detailed factual statement
supported by appropriate documentation and affidavits pursuant to sections
1.80(f)(3) and 1.16 of the Rules. The written statement 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. The statement should also be e-mailed to Pamera Hairston at
Pamera.Hairston@fcc.gov and to Nissa Laughner at Nissa.Laughner@fcc.gov.
15. 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 practices;
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.
16. IT IS FURTHER ORDERED that, pursuant to sections 4(i) and 4(j) of the
Act and section 20.19(i) of the Rules, Champaign Telephone Company d/b/a
CT Communications, Inc. SHALL SUBMIT the report described in paragraph 10
within thirty (30) days of the release of this NAL. The report 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. A copy of the report must also be emailed to
Pamera Hairston at Pamera.Hairston@fcc.gov, Nissa Laughner at
Nissa.Laughner@fcc.gov, Winsel Black at Winsel.Black@fcc.gov, and James
Swartz at James.Swartz@fcc.gov.
17. IT IS FURTHER ORDERED that a copy of this Notice of Apparent Liability
for Forfeiture shall be sent by first class mail and certified mail return
receipt requested to Michael Conrad, President and General Manager,
Champaign Telephone Company d/b/a CT Communications, Inc., 126 Scioto
Street, Urbana, Ohio 43078.
FEDERAL COMMUNICATIONS COMMISSION
Ricardo M. Durham
Acting Chief
Spectrum Enforcement Division
Enforcement Bureau
CT Communications also holds domestic section 214 authorizations.
47 C.F.R. S: 20.19(i)(1).
The Commission adopted these requirements for digital wireless telephones
under the authority of the Hearing Aid Compatibility Act of 1988, codified
at section 710(b)(2)(C) of the Communications Act of 1934, as amended
("Act"), 47 U.S.C. S: 610(b)(2)(C). See Section 68.4(a) of the
Commission's Rules Governing Hearing Aid-Compatible Telephones, Report and
Order, 18 FCC Rcd 16753, 16787 P: 89 (2003); Erratum, 18 FCC Rcd 18047
(2003) ("Hearing Aid Compatibility Order"); Order on Reconsideration and
Further Notice of Proposed Rulemaking, 20 FCC Rcd 11221 (2005) ("Hearing
Aid Compatibility Reconsideration Order").
See Hearing Aid Compatibility Order, 18 FCC Rcd at 16777 P: 56; 47 C.F.R.
S: 20.19(b)(1), (2).
The term "air interface" refers to the technical protocol that ensures
compatibility between mobile radio service equipment, such as handsets,
and the service provider's base stations. Currently, the leading air
interfaces include Code Division Multiple Access (CDMA), Global System for
Mobile Communications (GSM), Integrated Digital Enhanced Network (iDEN)
and Wideband Code Division Multiple Access (WCDMA) a/k/a Universal Mobile
Telecommunications System (UMTS).
See Hearing Aid Compatibility Order, 18 FCC Rcd at 16780 P: 65; 47 C.F.R.
S: 20.19(c), (d). The de minimis exception originally provided that
manufacturers or mobile service providers that offer two or fewer digital
wireless handset models per air interface are exempt from the hearing aid
compatibility deployment requirements, and manufacturers or mobile service
providers that offer three digital wireless handset models per air
interface must offer at least one compliant model. 47 C.F.R. S: 20.19(e).
We note that the Commission recently limited the de minimis exception to
an initial two-year period for manufacturers and service providers that do
not qualify as "small entities." See Amendment of the Commission's Rules
Governing Hearing Aid-Compatible Mobile Handsets, Policy Statement and
Second Report and Order and Further Notice of Proposed Rulemaking, 25 FCC
Rcd 11167, 11180-11189 P:P: 35-59 (2010) ("Hearing Aid Compatibility
Second Report and Order").
See Amendment of the Commission's Rules Governing Hearing Aid-Compatible
Mobile Handsets, First Report and Order, 23 FCC Rcd 3406 (2008) ("Hearing
Aid Compatibility First Report and Order"), Order on Reconsideration and
Erratum, 23 FCC Rcd 7249 (2008).
See id. at 3443 P: 91.
Hearing Aid Compatibility Order, 18 FCC Rcd at 16787 P: 89; see also
Wireless Telecommunications Bureau Announces Hearing Aid Compatibility
Reporting Dates for Wireless Carriers and Handset Manufacturers, Public
Notice, 19 FCC Rcd 4097 (Wireless Tel. Bur. 2004).
See Hearing Aid Compatibility First Report and Order 23 FCC Rcd at 3445-46
P:P: 97-99.
Id. at 3446 P: 99; see also Hearing Aid Compatibility Second Report and
Order, 18 FCC Rcd at 11180-11189 P:P: 35-59 (2010).
See Letter from Kathryn S. Berthot, Chief, Spectrum Enforcement Division,
Enforcement Bureau, Federal Communications Commission, to Michael Conrad,
Chief Executive Officer, CT Wireless (November 24, 2009).
See Letter from Michael Conrad, President and General Manager, CT
Communications, Inc., to Samantha Peoples, Program Analyst, Spectrum
Enforcement Division, Enforcement Bureau, Federal Communications
Commission (December 3, 2009) ("LOI Response").
Id. at 1.
See Telispire's Hearing Aid Compatibility Status Report (filed January 15,
2009) ("2009 Report") at
http://fjallfoss.fcc.gov/ecfs/document/view?id=6520193653.
Id.
47 C.F.R. S: 20.19(i)(1).
See Hearing Compatibility First Report and Order, 23 FCC Rcd at 3441 P: 91
(stating that the hearing aid compatibility status reports will assist the
Commission in monitoring the progress of implementation of the hearing
aid-compatible digital wireless handset deployment requirements in section
20.19 of the Rules, and that the reports will provide valuable information
to the public concerning hearing aid-compatible handsets); Hearing Aid
Compatibility Reconsideration Order, 20 FCC Rcd at 11240 P: 41 (same);
Hearing Aid Compatibility Order, 18 FCC Rcd at 16787 P: 89 (same).
The 2009 Report filed by Telispire via ECFS lists only Zefcom LLC d/b/a
Telispire under the Section I. Company Information. See 2009 Report. The
report lists handset models and the months in which the models were
offered, but provides no information or indicia that any company other
than Telispire offered the listed handsets during the months reported.
Furthermore, the cover letter accompanying the 2009 report states that
Zefcom LLC d/b/a/ Telispire PCS submits "its" Hearing Aid Compatibility
Status report for Hearing Aid Compatibility Status Report. See Letter from
Kenneth C. Johnson, Esquire, to Marlene H. Dortch, Secretary, Federal
Communications Commission (January 15, 2009).
See 47 C.F.R. S: 20.19(i)(1) (stating that "[s]ervice providers shall
submit reports on efforts toward compliance with the [hearing aid
compatibility requirements]"); see e.g., Lightyear Network Solutions, LLC,
Order and Notice of Apparent Liability for Forfeiture, DA 10-2226 P: 6
(Enf. Bur., Spectrum Enf. Div. rel. Nov. 22, 2010).
See, e.g., Eure Family Limited Partnership, Memorandum Opinion and Order,
17 FCC Rcd 21861, 21863-64 (2002); MTD, Inc., Memorandum Opinion and
Order, 6 FCC Rcd 34, 35 (1991); Wagenvoord Broadcasting Co., Memorandum
Opinion and Order, 35 FCC 2d 361 (1972).
Section 312(f)(1) of the Act defines "willful" as "the conscious and
deliberate commission or omission of [any] act, irrespective of any intent
to violate" the law. 47 U.S.C. S: 312(f)(1). The legislative history of
section 312(f)(1) of the Act clarifies that this definition of willful
applies to both sections 312 and 503(b) of the Act, H.R. Rep. No. 97-765,
97th Cong. 2d Sess. 51 (1982), and the Commission has so interpreted the
term in the section 503(b) context. See Southern California Broadcasting
Co., Memorandum Opinion and Order, 6 FCC Rcd 4387, 4388 P: 5 (1991),
recon. denied, 7 FCC Rcd 3454 (1992) ("Southern California"); see also
Telrite Corporation, Notice of Apparent Liability for Forfeiture, 23 FCC
Rcd 7231, 7237 P: 12 (2008) ("Telrite"); Regent USA, Notice of Apparent
Liability for Forfeiture, 22 FCC Rcd 10520, 10523 P: 9 (2007); San Jose
Navigation, Inc., Forfeiture Order, 22 FCC Rcd 1040, 1042 P: 9 (2007),
consent decree ordered, Order and Consent Decree, 25 FCC Rcd 1494 (2010).
47 C.F.R. S: 20.19(i)(1).
47 U.S.C. S: 503(b)(1)(B); 47 C.F.R. S: 1.80(a)(1).
47 U.S.C. S: 503(b); 47 C.F.R. S: 1.80(f).
See, e.g., SBC Communications, Inc., Forfeiture Order, 17 FCC Rcd 7589,
7591 P: 4 (2002).
47 C.F.R. S: 20.19(i)(1).
The Commission's Forfeiture Policy Statement and Amendment of Section 1.80
of the Rules to Incorporate the Forfeiture Guidelines, Report and Order,
12 FCC Rcd 17087, 17114, recon. denied, 15 FCC Rcd 303 (1999) ("Forfeiture
Policy Statement"); 47 C.F.R. S: 1.80(b), Note to paragraph (b)(4):
Section I. Base Amounts for Section 503 Forfeitures.
See Forfeiture Policy Statement, 12 FCC Rcd at 17099 P: 22, 17101 P: 29.
See also 47 C.F.R. S:1.80(b)(4) ("The Commission and its staff may use
these guidelines in particular cases [and] retain the discretion to issue
a higher or lower forfeiture than provided in the guidelines, to issue no
forfeiture at all, or to apply alternative or additional sanctions as
permitted by the statute.") (emphasis added).
47 U.S.C. S: 503(b)(2)(E). See also 47 C.F.R. S: 1.80(b)(4), Note to
paragraph (b)(4): Section II. Adjustment Criteria for Section 503
Forfeitures.
See American Samoa Telecommunications Authority, Notice of Apparent
Liability for Forfeiture, 23 FCC Rcd 16432 (Enf. Bur., Spectrum Enf. Div.
2008), response pending ("ASTCA NAL").
Id. at 16436-47 P: 10.
Id.
Id.
Id.
Id. at 16437 P: 11. See also Telrite, 23 FCC Rcd at 7244-45 P: 30
(determining that the failure to file Telecommunications Reporting
Worksheets is a continuing violation); Compass Global, Inc., Notice of
Apparent Liability for Forfeiture and Order, 23 FCC Rcd 6125, 6138 P: 29
(2008) (same); VCI Company, Notice of Apparent Liability for Forfeiture
and Order, 22 FCC Rcd 15933, 15940 P: 20 (2007) (determining that the
failure to file Lifeline and Linkup Worksheets is a continuing violation).
See, e.g., Profit Enterprises, Inc., Notice of Apparent Liability for
Forfeiture, 8 FCC Rcd 2846, 2846 P: 5 (1993) (denying the mitigation
claim of a manufacturer/distributor who thought that the equipment
certification and marketing requirements were inapplicable, stating that
its "prior knowledge or understanding of the law is unnecessary to a
determination of whether a violation existed ... ignorance of the law is
[not] a mitigating factor"); Lakewood Broadcasting Service, Inc.,
Memorandum Opinion and Order, 37 FCC 2d 437, 438 P: 6 (1972) (denying a
mitigation claim of a broadcast licensee who asserted an unfamiliarity
with the station identification requirements, stating that licensees are
expected "to know and conform their conduct to the requirements of our
rules"); Kenneth Paul Harris, Sr., Notice of Apparent Liability for
Forfeiture, 15 FCC Rcd 12933, 12935 P: 7 (Enf. Bur. 2000) (denying a
mitigation claim of a broadcast licensee, stating that its ignorance of
the law did not excuse the unauthorized transfer of the station); Maxwell
Broadcasting Group, Inc., Memorandum Opinion and Order, 8 FCC Rcd 784, 784
P: 2 (Mass Med. Bur. 1993) (denying a mitigation claim of a noncommercial
broadcast licensee, stating that the excuse of "inadverten[ce], due to
inexperience and ignorance of the rules ... are not reasons to mitigate a
forfeiture" for violation of the advertisement restrictions).
47 C.F.R. S: 20.19(i)(1).
47 U.S.C. S: 503(b).
47 C.F.R. S:S: 0.111, 0.311, 1.80.
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Federal Communications Commission DA 10-2435
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Federal Communications Commission DA 10-2435