Click here for Adobe Acrobat version
Click here for Microsoft Word version
********************************************************
NOTICE
********************************************************
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-07-IH-5266
)
CESAR CHAVEZ FOUNDATION NAL/Account No.:
) 201032080018
Licensee of Noncommercial Educational
Station ) FRN: 0006911408
KUFW(FM), Woodlake, California ) Facility ID No.: 21210
)
)
FORFEITURE ORDER
Adopted: May 17, 2012 Released: May 17, 2012
By the Chief, Enforcement Bureau:
I. INTRODUCTION
1. In this Forfeiture Order, we impose a monetary forfeiture of twelve
thousand five hundred dollars ($12,500) against Cesar Chavez Foundation
(Licensee), licensee of noncommercial educational Station KUFW(FM),
Woodlake, California (Station), for violating Section 399B of the
Communications Act of 1934, as amended (Act), and Section 73.503(d) of the
Commission's rules by broadcasting prohibited advertisements over the
Station.
II. BACKGROUND
2. On August 30, 2006, the Enforcement Bureau's San Francisco Field
Office (Field) conducted an inspection of the Station and recorded a
segment of its programming that appeared to include commercial
advertisements. On January 24, 2007, the Field issued a letter of
inquiry to the Licensee inquiring about a potential technical
violation and referencing the broadcasting of commercials on the
Station. The Field also translated and transcribed the recording and
referred the matter to the Enforcement Bureau's Investigations and
Hearings Division (Division) for further investigation. Thereafter,
the Division sent letters of inquiry to the Licensee on August 26,
2008, and May 18, 2009. The Licensee responded to the Division's
inquiries on September 24, 2008, June 17, 2009, and August 27, 2009.
On June 15, 2010, the Bureau issued a Notice of Apparent Liability for
Forfeiture (NAL) on the underwriting violations referred to the
Division, finding that the Licensee had apparently violated the
Commission's underwriting laws by broadcasting four separate
advertisements over two thousand (2,000) times in total from March
2006 through December 2006, and proposing a monetary forfeiture of
twelve thousand five hundred dollars ($12,500).
3. On August 9, 2010, the Licensee responded to the NAL, requesting that
we cancel the forfeiture. In support of its request for cancellation,
the Licensee contends that it made good faith efforts to comply with
the Commission's underwriting laws, that the announcements in fact
comply with Commission rules and precedent, including Xavier
University, that the Commission has not previously prohibited the
language used in the announcements at issue here, and that none of the
announcements contained calls to action. The Licensee also questions
the propriety of the Field's inspection and the Field's and Division's
subsequent investigations. The Licensee claims that the Commission has
stated that it would "act on complaints, but not monitor stations" for
underwriting rule violations, and therefore, the Licensee implies that
the Field's monitoring and Field's and Division's investigations and
forfeiture assessment were somehow improper.
4. The Licensee also requests, in the alternative, that we reduce the
forfeiture. In support of this request, and related to its argument
above regarding the Bureau's investigation, the Licensee states that
the Field did not mention the underwriting announcements to the
Licensee during its August 30, 2006 inspection of the Station or in
its January 24, 2007 letter of inquiry, and that had it done so, the
Licensee would have ceased broadcasting such announcements and its
violation would not have been so aggravated. The Licensee also asserts
that the forfeiture is excessive in light of its good faith efforts.
III. DISCUSSION
5. The proposed forfeiture amount in this case was assessed in accordance
with Section 503(b) of the Communications Act, Section 1.80 of the
Commission's rules, and the Commission's forfeiture guidelines set
forth in its Forfeiture Policy Statement. In assessing forfeitures,
Section 503(b) of the Act requires that we 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 other matters as justice may
require. As discussed further below, we have examined the Licensee's
response to the NAL pursuant to the aforementioned statutory factors,
our rules, and the Forfeiture Policy Statement, and we find that
cancellation is not appropriate in this case. We find that twelve
thousand five hundred dollars ($12,500) is the appropriate forfeiture
amount in this case, as explained below.
6. As the NAL described, the Act defines advertisements as program
material broadcast "in exchange for any remuneration" and intended to
"promote any service, facility, or product" of for-profit entities.
The pertinent statute specifically provides that noncommercial
educational stations may not broadcast advertisements. Although
contributors of funds to such stations may receive on-air
acknowledgements, the Commission has held that such acknowledgements
may be made for identification purposes only, and should not promote
the contributors' products, services, or businesses. Specifically,
such advertisements may not contain comparative or qualitative
descriptions, price information, calls to action, or inducements to
buy, sell, rent, or lease. At the same time, however, the Commission
has acknowledged that it is at times difficult to distinguish between
language that promotes versus that which merely identifies the
underwriter. Consequently, the Commission expects that licensees
exercise reasonable "good faith" judgment in this area, and affords
some latitude to the judgments of licensees who do so. In this case,
as described in detail below, the Licensee repeatedly broadcast
promotional advertisements that were clearly aimed at inducing the
purchase of goods or services from several for-profit entities.
A. The Licensee Willfully and Repeatedly Broadcast Prohibited
Advertisements.
7. We find that the Bureau's proposed forfeiture is consistent with
Commission precedent and policy and affirm the findings in the NAL.
Specifically, the Licensee willfully and repeatedly broadcast
advertisements in violation of Section 399B of the Act and Section
73.503(d) of the Commission's rules. The Licensee does not dispute the
key facts in this case. Specifically, the Licensee does not deny that
the Station broadcast the advertisements described in the NAL and set
forth in the attachment thereto, nor does the Licensee deny that it
received consideration for the airing of the advertisements. Instead,
the Licensee asserts that it made good faith efforts to comply and
that its advertisements comported with Commission precedent. In making
this claim however, the Licensee misinterprets the relevant case law.
8. Specifically, the NAL's analysis is fully consistent with the
Commission's findings in Xavier University (Xavier). As described
above, in Xavier, the Commission made clear that it will not deem
announcements impermissible where the "language at issue . . . is not
clearly promotional as opposed to identifying and . . . the licensee
exercised reasonable, good faith judgment regarding the language." In
this case, as discussed below, additional Commission precedent
supports our finding that the advertisements at issue here were
promotional in nature, as opposed to identifying. Thus, our proposed
forfeiture here is consistent with Xavier and other Commission
precedent.
9. Even if we agreed that the Licensee made "good faith" efforts at
compliance, the language used in the advertisements was clearly
promotional, and the Licensee's explanations to the contrary are not
persuasive. Although the Licensee argues that none of the
announcements included calls to action, the Commission's underwriting
laws are not limited to restricting calls to action. As noted above,
on-air acknowledgements also may not contain comparative or
qualitative descriptions, price information, or inducements to buy,
sell, rent or lease. As noted in the NAL, the advertisements at issue
contained several such elements.
10. For example, the NAL explained that the Mario's Auto Sales
announcement included favorable and qualitative expressions, and also
included an inducement. In its NAL Response, the Licensee claims that
phrases used in the announcement, such as "beautiful Harley Davidson
light trucks," and "we have it here," are descriptive and not
promotional. The Licensee also claims that the phrase "whatever
vehicle with no down payment" is not an inducement because "there is
no time limit on the sales term." The Licensee's arguments do not
persuade us because we have, in other instances, found similar
descriptions to be promotional in nature, and thus, prohibited them.
Furthermore, the Licensee fails to provide any support for its theory
that an inducement must include a time limit. To the contrary, we have
found violations of the rules in comparable cases in which licensees
broadcast inducements to patronage, regardless of whether the language
at issue included a time limit.
11. The NAL also explained that the Big Brand Tire advertisements included
comparative phrasing, qualitative statements, and inducements. In its
NAL Response, the Licensee addresses some, but not all, of the
language described in and found prohibited by the NAL. Specifically,
the Licensee claims that the terms "unique," "latest line of rims,"
and "latest technique in mounting" are simply descriptive and not
promotional. We disagree. In addition, the Licensee fails to provide
any arguments to rebut the conclusion in the NAL that other terms are
also problematic such as "will make you stand out," "we have the most
recent selection when it comes to rims from A to Z," "we don't give
you a cat for a rabbit here," and "knows about tires." Overall, the
Licensee has failed to convince us that the language in the Big Brand
Tires advertisements is permissible. We have previously found similar
language prohibited in underwriting precedent, and we continue to do
so here.
12. With respect to the Muebleria La Tapatia announcement, the NAL
explained that the announcement contained expressions that attempt to
distinguish the company from its competitors and contain qualitative
statements and inducements. The Licensee argues that this announcement
contains language similar to the language in Xavier, and therefore,
that it is permissible. The Licensee fails to address the inducements,
such as "the hottest prices are at MLT" or "MLT offers you easy
credit," which the advertisement contains. Contrary to the Licensee's
contentions, the Bureau has previously sanctioned comparable language,
and thus, we continue to find such inducement language to be
prohibited.
B. The Bureau Properly Assessed the Forfeiture Amount.
13. We find that the NAL appropriately applied the Forfeiture Policy
Statement and the statutory factors in arriving at the forfeiture
amount in this case. The forfeiture in this case was determined by
considering factors such as the timeframe at issue, and the number and
repetition of advertisements. The combination of these factors led the
Bureau to conclude that a forfeiture in the amount of twelve thousand
five hundred dollars ($12,500) was appropriate. The Licensee, however,
requests a reduction in the forfeiture. We reject the Licensee's
argument that its good faith effort at compliance renders the
forfeiture "excessive." The Commission expects such effort from all
licensees. Consequently, we find that no reduction is warranted and
the appropriate forfeiture amount is twelve thousand five hundred
dollars ($12,500).
C. The Bureau Properly Conducted its Investigation.
14. Additionally, the Licensee asserts that the Commission's recording of
underwriting announcements during its inspection was improper, and
claims that the "Commission said it would . . . act on complaints, but
not monitor stations." The Licensee fails, however, to cite Commission
policy or precedent to support these statements. We remind the
Licensee that the Act gives the Commission, and the Bureau by
delegation, broad authority to investigate the entities that it
regulates. A cornerstone of the Commission's ability to ensure
compliance is through conducting field inspections. The Licensee has
not provided any authority to support its proposition that the
Commission should ignore any violations that come to its attention,
unless those violations originated in the form of a complaint. To the
contrary, the Commission must evaluate possible violations of the Act
and our Rules to protect "the primary educational, instructional, and
cultural character of public broadcasting programming." Consequently,
we reject the Licensee's contention that the Bureau improperly
conducted and relied upon field monitoring and recording in connection
with both the investigation and our finding that the Licensee aired
prohibited underwriting advertisements.
15. We also uphold the manner in which the Field and the Division
conducted their respective investigations of the potential
underwriting violations at issue in this case. The Licensee claims
that the Field should have warned the Licensee, either during the
August 30, 2006 inspection, or via its January 24, 2007 letter of
inquiry, that the Bureau considered the underwriting announcements to
be prohibited. The Licensee further claims that such warning would
have caused the Licensee to cease such broadcasts earlier. We note,
however, that the Field's letter of inquiry references the
broadcasting of commercial announcements on the Station. Even if the
original letter of inquiry did not reference the broadcast of
commercial announcements, that would not excuse the Licensee's
liability, and the Licensee does not cite to any precedent to the
contrary. The Licensee is responsible for the magnitude of its
violation, and we reject any assertion otherwise.
16. We further reject any assertion that, if the Field or Division had
acted differently, the Licensee could have taken actions that would
have mitigated the sanctions imposed here. Any such actions would
have occurred after the Field commenced its inspection. As the
Commission has repeatedly stated, remedial efforts that a licensee
undertakes after the Commission commences an investigation are not
mitigating. Thus, even if the Licensee had taken such actions, we
would not credit the Licensee for such remedial efforts by reducing
the forfeiture.
IV. ORDERING CLAUSES
17. ACCORDINGLY, IT IS ORDERED that, pursuant to Section 503(b) of the
Communications Act of 1934, as amended, and Section 1.80 of the
Commission's rules, Cesar Chavez Foundation IS LIABLE FOR A MONETARY
FORFEITURE in the amount of twelve thousand five hundred dollars
($12,500) for willfully and repeatedly broadcasting advertisements in
violation of Section 399B of the Act, as amended, and Section
73.503(d) of the Commission's rules. Payment of the forfeiture shall
be made in the manner provided for in Section 1.80 of the Commission's
rules, within thirty (30) days of the release date of this Forfeiture
Order. If the forfeiture is not paid within the period specified, the
case may be referred to the Department of Justice for collection
pursuant to Section 504(a) of the Act.
18. 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 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. All payments
must be accompanied by an FCC Form 159 (Remittance Advice). 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. The Licensee will also send electronic
notification on the date said payment is made to
Terry.Cavanaugh@fcc.gov, Jeffrey.Gee@fcc.gov, Anjali.Singh@fcc.gov,
and Melissa.Marshall@fcc.gov.
19. IT IS FURTHER ORDERED that a copy of this Forfeiture Order shall be
sent, by Certified Mail/Return Receipt Requested, to Cesar Chavez
Foundation, P.O. Box 62, Keene, California 93531, and George R.
Borsari, Jr. Esq. and Anne Thomas Paxson Esq., Borsari & Paxson, 5335
Wisconsin Avenue, N.W., Suite 440, Washington, D.C. 20015.
FEDERAL COMMUNICATIONS COMMISSION
P. Michele Ellison
Chief
Enforcement Bureau
By letter dated September 2, 2011, counsel to Cesar Chavez Foundation
notified the Commission of the corporate name change of the licensee of
Station KUFW(FM), Woodlake, California, from National Farm Workers Service
Center, Inc. to Cesar Chavez Foundation. See Letter from Anne Thomas
Paxson, Borsari & Paxson, to Marlene H. Dortch, Secretary, Federal
Communications Commission (Sept. 2, 2011). There was no change in the
ownership structure, principals, contact persons, or official mailing
address for the renamed entity. See id.
See 47 U.S.C. S: 399b(a).
See 47 C.F.R. S: 73.503(d).
See National Farmworkers Service Center, Inc., Notice of Apparent
Liability for Forfeiture, 25 FCC Rcd 7486 (Enf. Bur. 2010) (NAL). The
announcements were excerpted in the attachment to the NAL.
See Letter from Thomas N. Van Stavern, District Director, San Francisco
Office, Western Region, Enforcement Bureau, Federal Communications
Commission, to National Farm Workers Service Center (Jan. 24, 2007).
See Letter from Kenneth M. Scheibel, Jr., Assistant Chief, Investigations
and Hearings Division, Enforcement Bureau, Federal Communications
Commission, to National Farm Workers Service Center, Inc. (Aug. 26, 2008)
(on file in EB-07-IH-5266); Letter from Kenneth M. Scheibel, Jr.,
Assistant Chief, Investigations and Hearings Division, Enforcement Bureau,
Federal Communications Commission, to National Farm Workers Service
Center, Inc. (May 18, 2009) (on file in EB-07-IH-5266).
See Letter from George R. Borsari, Jr., Attorney for National Farm Workers
Service Center, Inc., to Marlene H. Dortch, Secretary, Federal
Communications Commission (Sept. 24, 2008) (on file in EB-07-IH-5266);
Letter from George R. Borsari, Jr., Attorney for National Farm Workers
Service Center, Inc., to Marlene H. Dortch, Secretary, Federal
Communications Commission (June 17, 2009) (on file in EB-07-IH-5266);
Supplemental Letter from Anne Thomas Paxson, Attorney for National Farm
Workers Service Center, Inc., to Anita Patankar-Stoll, Attorney Advisor,
Investigations and Hearings Division, Enforcement Bureau, Federal
Communications Commission (Aug. 27, 2009) (on file in EB-07-IH-5266).
See NAL, 25 FCC Rcd at 7486.
See Letter from George R. Borsari, Jr., Attorney for National Farm Workers
Service Center, Inc., to P. Michele Ellison, Chief, Enforcement Bureau,
Federal Communications Commission (Aug. 9, 2010) (on file in
EB-07-IH-5266) (NAL Response).
See id. at 1.
See id. at 1-5 (citing Xavier University, Letter of Admonition (Mass Med.
Bur. Nov. 14, 1989), recons. granted, Memorandum Opinion and Order, 5 FCC
Rcd 4920 (1990) (Xavier)).
See id. at 4.
See id.
See id. at 5-7.
Id. at 6.
See id. at 1.
See id. at 5-8.
The Licensee also asserts that the Bureau cannot consider deterrence as a
factor in issuing fines. See id. at 8.
See 47 U.S.C. S: 503(b).
See 47 C.F.R. S: 1.80.
See 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 (1997), recons. denied, 15 FCC Rcd 303 (1999)
(Forfeiture Policy Statement).
See 47 U.S.C. S: 503(b)(2)(E).
47 U.S.C. S: 399b(a).
See id.
See Commission Policy Concerning the Noncommercial Nature of Educational
Broadcasting Stations, Public Notice (1986), republished, 7 FCC Rcd 827
(1992) (Public Notice).
See id.
See Xavier, 5 FCC Rcd at 4921 (citing Commission Policy Concerning the
Noncommercial Nature of Educational Broadcasting Stations, Memorandum
Opinion and Order, 90 FCC 2d 895, 911 (1982), recons., 97 FCC 2d 255
(1984); Public Notice, supra note 25).
Id.
See 47 U.S.C. S: 399b(a).
See 47 C.F.R. S: 73.503(d).
See NAL Response at 1-5.
See Xavier, 5 FCC Rcd at 4921.
Id. See also Tri-State Inspirational Broadcasting Corporation, Memorandum
Opinion and Order, 16 FCC Rcd 16800, 16800 (Enf. Bur. 2001) (Tri-State)
(although the licensee believed that announcements were within the bounds
of the rules, the Bureau found them to contain language that attempted to
distinguish the underwriters and their products from competitors, and
promoted those same entities in qualitative ways).
The Licensee itself acknowledges that a licensee's compliance efforts that
fall short do not excuse a violation. See NAL Response at 2.
See Public Notice, 7 FCC Rcd at 827-28.
See NAL, 25 FCC Rcd at 7489.
NAL Response at 4.
Id.
Indeed, we previously admonished the Licensee (under its former name) with
respect to comparable pricing information. See National Farm Workers
Service Center, Inc., Letter, 9 FCC Rcd 6855, 6855 (Mass Med. Bur. 1994)
(admonishing licensee for three announcements containing language
regarding the availability of some type of financing or credit ("layaway,"
"special financing," and "different plans for financing")). See, e.g.,
Ministerio Radial Cristo Viene Pronto, Inc., Notice of Apparent Liability
for Forfeiture, 24 FCC Rcd 241, 243 (Enf. Bur. 2009) (subsequent history
omitted) (Ministerio) (finding prohibited announcements that contained
language such as "unique environment" and "best cleaning system");
Kosciusko Educational Broadcasting Foundation, Letter, 5 FCC Rcd 7106
(Mass Media Bur. 1990) (Kosciusko) (finding prohibited announcements that
included language such as "stop by and see the beautiful selection,"
"[t]hat gives you the best possible selection to choose from," and "[t]hey
have special, low-rate financing and dealer discounts and factory special
value discount option packages"); Lancaster Educational Broadcasting
Foundation, Notice of Apparent Liability for Forfeiture, 24 FCC Rcd 1384,
1386-88 (Enf. Bur. 2009) (subsequent history omitted) (Lancaster) (finding
language such as "to see for yourself, come drive it," and "your best
choices are here" prohibited); Christian Voice of Central Ohio, Inc.,
Notice of Apparent Liability for Forfeiture, 19 FCC Rcd 23663 (Enf. Bur.
2004) (subsequent history omitted) (finding prohibited language such as
"we're all about family," and "we love selling real estate").
See, e.g., Lancaster, 24 FCC Rcd at 1386-87 (finding prohibited
"competitively low interest rate," "ultimate flexibility," and "tax
advantages not available on other types of credit"); Ministerio, 24 FCC
Rcd at 243-44 & Attachment (finding prohibited "finance it for 12, 14, or
up to 18 months without interest," "without interest," and "10%
discounts").
See NAL, 25 FCC Rcd at 7489.
NAL Response at 4.
NAL, 25 FCC Rcd at 7489.
See, e.g., Lancaster, 24 FCC Rcd at 1387 (finding language such as "free
checking account" and "free use of a debit card" prohibited) & Attachment
(finding prohibited "ultimate flexibility for your borrowing needs" and
"other money saving bundle packages"); Jones College, Notice of Apparent
Liability for Forfeiture, 24 FCC Rcd 231, 233 & Attachment (Enf. Bur.
2009) (subsequent history omitted) (Jones College) (finding prohibited
announcements for Annabelle's Gifts and Home Furnishing Gallery, which
gave descriptions of privacy glass, and Donovan Heat and Air, which
described "air diagnostics" and carbon monoxide checks); Tri-State, 16 FCC
Rcd at 16805 (finding prohibited an announcement for Heil Heating and
Cooling, which described the underwriter as keeping up with technology);
Kosciusko, 5 FCC Rcd at 7106 (finding an announcement violative that
included the language: "They don't use high pressure sale tactics or
gimmicks. They just give you honest, down-to-earth prices with courteous,
dependable service.").
See NAL, 25 FCC Rcd at 7489-7490.
See NAL Response at 5.
NAL, 25 FCC Rcd at 7489-7490.
See, e.g., Kosciusko, 5 FCC Rcd at 7106 (finding prohibited the following
language: "They have special, low-rate financing and dealer discounts and
factory special value discount option packages").
See NAL, 25 FCC Rcd at 7490.
See id. The Licensee claims that in the NAL, the Bureau erroneously
increased the forfeiture in order to deter comparable behavior in other
licensees. See NAL Response at 8. Although that was not a central
consideration in this case, the Bureau is fully within its authority to
consider deterrence as a factor in determining an appropriate forfeiture
amount, as the Forfeiture Policy Statement explicitly discusses. See
Forfeiture Policy Statement, 12 FCC Rcd at 17098.
See NAL Response at 1.
Id. at 8.
Id. at 6.
See id.
See 47 U.S.C. S:S: 154(i), 154(j), 403; 47 C.F.R. S:S: 0.111, 0.311.
See, e.g., Allcom, Notice of Apparent Liability for Forfeiture and Order,
25 FCC Rcd 9124, 9126 (Enf. Bur. 2010).
See, e.g., Norfolk Southern Railway Company KFR86 Atlanta, Georgia, Order,
11 FCC Rcd 519 (Compliance & Information Bur. 1996).
Reverend Theodore M. Schultz, File No. EB-02-IH-0128, Letter (Enf. Bur.
May 30, 2002).
See NAL Response at 5-8.
See supra note 5.
Cf. Pacific Broadcasting Corp., Memorandum Opinion and Order, 47 F.C.C.2d
818 (Brdcst. Bur. 1974) (holding that licensees must accept the penalty
for not following Commission rules, whether or not they are warned of the
consequences for failure to comply).
See, e.g., Jones College, 24 FCC Rcd at 236; Hispanic Broadcast System,
Inc., Forfeiture Order, 20 FCC Rcd 12008, 12009 (Enf. Bur. 2005).
See 47 U.S.C. S: 503(b); 47 C.F.R. S: 1.80.
See 47 U.S.C. S: 399b; 47 C.F.R. S: 73.503(d).
See 47 C.F.R. S: 1.80.
See 47 U.S.C. S: 504(a).
Federal Communications Commission _DA 12-772
1
5
Federal Communications Commission _DA 12-772