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Federal Communications Commission DA 17-272
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
Global Paratransit Inc.
)
)
) File No.: EB-FIELDWR-16-00021401
) NAL/Acct. No.: 201732900004
) FRN: 0005746409
NOTICE OF APPARENT LIABILITY FOR FORFEITURE
Adopted: March 22, 2017 Released: March 23, 2017
By the Regional Director, Region Three, Enforcement Bureau:
I. INTRODUCTION
1. We propose a penalty of $13,000 against Global Paratransit Inc. (Global or Company) for
apparently failing to operate its private land mobile radio (PLMR) station, Call Sign WPPY512, in
accordance with the Commission’s narrowbanding rules, failing to transmit its station identification, and
failing to respond to a Commission communication.  Because Global was required to modify its station to
operate on a narrowband basis as of January 1, 2013, and did not do so, it created the potential for harmful
interference, including potential interference to public safety operations in nearby frequency bands.  
Global failed to narrowband its operations despite the fact that the Commission provided land          
mobile licensees with significant advance notice of the requirement.  Due to the length of time that Global
had notice of the requirement to narrowband, and its failure to do so, we find this rule violation egregious
and subject to an upward adjustment.  Global also acted egregiously by operating on a wideband basis
after surrendering its authorization to do so, which is also subject to an upward adjustment. Global’s
apparent violations thus deserve a significant penalty.
II. BACKGROUND
A. Narrowbanding Requirement
2. In 2003, the Commission adopted the Narrowbanding Second Report and Order1
imposing a ten-year deadline of January 1, 2013, for licensees operating in the 150-174 MHz and
421-512 MHz bands to migrate their signals to 12.5 kHz or narrower bandwidths.2  The Commission
adopted the narrowbanding requirement to reduce congestion and increase efficiency in a number of
frequency bands, including the frequency band in which Global operates.3
3. In addition to providing PLMR licensees with notice ten years in advance of the
narrowbanding rule change, the Commission consistently reminded licensees of the upcoming
1 See Implementation of Sections 309(j) and 337 of the Communications Act of 1934 as Amended; Promotion of
Spectrum Efficient Technologies on Certain Part 90 Frequencies, Second Report and Order and Second Further
Notice of Proposed Rulemaking, 18 FCC Rcd 3034 (2003) (Narrowbanding Second Report and Order); see also
Implementation of Sections 309(j) and 337 of the Communications Act of 1934 as Amended; Promotion of Spectrum
Efficient Technologies on Certain Part 90 Frequencies, Third MemorandumOpinion and Order, Third Further
Notice of Proposed Rule Making and Order, 19 FCC Rcd 25045 (2004) (Narrowbanding Third MO&O).
2 Narrowbanding Second Report and Order, 18 FCC Rcd at 3038, para. 12; see also Narrowbanding Third MO&O,
19 FCC Rcd at 25050, para. 9.
3 Narrowbanding Second Report and Order, 18 FCC Rcd at 3038, para. 12, 3044, para. 24.
Federal Communications Commission DA 17-272
2
narrowbanding obligations through public notices issued in 2009,4 2010,5 2011,6 and four times in 2012.7
The Commission also provided three post-transition public notices regarding the narrowband transition.8
B. Investigative History
4. Global is taxicab service provider located in Gardena, California, and holds a license for
WPPY512, a land mobile station that operates on frequencies in the 450-470 MHz band.9  According to
Global’s license, it uses the frequencies to dispatch taxicabs. Global filed a renewal application for this
station on February 19, 2015.10  Less than two weeks later, on March 3, 2015, the Commission’s Wireless
Telecommunications Bureau (WTB) returned Global’s renewal application, stating that it would dismiss
the application unless Global amended it: “Because your application is for a license that contains both
wideband and narrowband emission designators and the wideband designators are impermissible, the
application is being returned to have the wideband emission designators removed.”11  On May 1, 2015,
Global filed a license modification application to delete wideband emission designators from its license,
and filed an amendment to its renewal application to remove the wideband emissions designator on all
frequencies on its license for WPPY512. Global’s license modification application and its application for
renewal, as amended, were granted on May 5, 2015.12
4 Licensees, Frequency Coordinators, and Equipment Manufacturers Reminded of Narrowband Migration
Deadlines in the 150-174 MHz and 421-512 MHz Bands, Public Notice, 24 FCC Rcd 14511 (WTB 2009).
5 See, e.g., The Office of Engineering and Technology, Wireless Telecommunications Bureau, and Public Safety and
Homeland Security Bureau Remind Licensees, Frequency Coordinators, and Equipment Manufacturers of
Narrowband Migration Deadlines in the 150-174 MHz and 421-512 MHz Bands, Public Notice, 25 FCC Rcd 16990
(OET/WTB/PSHSB2010).
6 Wireless Telecommunications Bureau, Public Safety and Homeland Security Bureau, and Office of Engineering
and Technology Provide Reminder of January 1, 2013 Deadline for Transition to Narrowband in the 150-174 MHz
and 421-512 MHz Bands and Guidance for Submission of Requests for Waiver and Other Matters, Public Notice, 26
FCC Rcd 9647 (2011).
7 Less Than One Year Remains For Land Mobile Radio Licensees In the 150-174 MHz And 421-512 MHz Bands To
Transition To Narrowband Operations, Public Notice, 27 FCC Rcd 138 (WTB/PSHSB/OET 2012);Wireless
Telecommunications Bureau and Public Safety and Homeland Security Bureau Provide Supplemental Guidance for
Licensees in the 150-174 MHz and 421-512 MHz Bands Seeking Waivers of the January 1, 2013 Narrowbanding
Deadline, Public Notice 27 FCC Rcd 1936 (WTB/PSHSB 2012); Enforcement Bureau Reminds Private Land
Mobile Licensees and Equipment Manufacturers of the January 1, 2013 Deadline for Transitioning to Narrowband
Technology, Enforcement Advisory, 27 FCC Rcd 10160 (EB 2012);Wireless Telecommunications Bureau, Public
Safety and Homeland Security Bureau, and Office of Engineering and Technology Provide Reminder of January 1,
2013 Deadline for Transition to Narrowband Operations in the 150-174 MHz and 421-470 MHz Bands, Public
Notice, 27 FCC Rcd 14896 (WTB/PSHSB/OET 2012).
8 Telecommunications Bureau, Public Safety and Homeland Security Bureau, and Office of Engineering and
Technology Provide Guidance on Compliance With Narrowband Requirement Now in Effect for Private Land
Mobile Radio Operations in the 150-174 MHz and 421-470 MHz Bands, Public Notice, 28 FCC Rcd 2296
(WTB/PSHSB/OET 2013);Wireless Telecommunications Bureau and Public Safety and Homeland Security Bureau
Provide Additional Guidance Regarding Post-Narrowbanding License Renewal Procedures for Private Land Mobile
Radio Operators in the 150-174 MHz and 421-470 MHz Bands, Public Notice, 29 FCC Rcd 2088 (WTB/PSHSB
2014)’Wireless Telecommunications Bureau and Public Safety and Homeland Security Bureau Provide     
Additional Guidance Regarding Post-Narrowbanding Licensing Procedures for Private Land Mobile Radio
Operators in the 150-174 MHz and 421-470 MHz Bands, Public Notice, 31 FCC Rcd 127 (WTB/PSHSB 2016).
9 SeeGlobal Paratransit Inc.,WPPY512, http://wireless2.fcc.gov/UlsApp/UlsSearch/license.jsp?licKey=1821922.
10 See ULS File No. 0006677831.
11 Notice of Return to Lee Habibi, Global Paratransit, Inc., dated March 3, 2015, ULS File No. 0006677831.
12 ULS File Nos. 0006677831 and 0006786823.
Federal Communications Commission DA 17-272
3
5. On January 12, 2016, the Enforcement Bureau’s Los Angeles Office received an email
from an anonymous source asserting that Global had failed to narrowband equipment transmitting on the
frequency 452.775 MHz operating under its license for call sign WPPY512. On January 25, 2016, an
agent from the Commission’s Los Angeles office monitored Global’s communications on 452.775 MHz
and observed that WPPY512 did not operate with 12.5 kHz channelization, as required by the narrowband
requirement.
6. On April 1, 2016, an agent from the Commission’s Los Angeles Office contacted Global
to schedule an inspection of its radio equipment. Global referred the Commission agent to a company
called Mobile Relay Associates (MRA), which Global called its “service provider.” MRA provides
commercial space and maintenance services to Global for its transmitting equipment. In light of Global’s
request to contact MRA and MRA’s access to Global’s equipment, the Commission Agent contacted
MRA and scheduled an inspection of Global’s station for April 4, 2016.
7. On April 4, 2016, two Commission agents monitored and inspected radio station
WPPY512. The agents found that WPPY512 was not operating in compliance with the narrowbanding
requirement. The agents also interviewed a representative of MRA, who was present during the
inspection. That representative told the agents that Global had failed to narrowband its radio station
equipment operating on the frequency 452.775 MHz. Additionally, one of the agents observed that
WPPY512 failed to transmit its station identification.
8. On May 13, 2016, the Los Angeles Office issued a Notice of Violation (NOV) to Global
for violation of the Commission’s rules governing bandwidth limits (i.e., narrowbanding), and station
identification rules applicable to land mobile licensees. On May 16, 2016, the Commission received
notification that the NOV had been delivered to Global.13  Global never responded to the NOV.14
III. DISCUSSION
9. We find that Global apparently willfully and repeatedly violated several provisions in
Part 90 of the Commission’s rules and Section 1.903(a) of the Commission’s rules, by failing to
narrowband its operations, thereby failing to operate in accordance with the rules applicable to its
particular service.15  Global also apparently violated the rules requiring it to transmit its call sign, and to
respond to Commission communications.16  Each of these violations is discussed in further detail below.
A. Global Apparently Violated Section 90.209(b)(5) and 1.903(a) by Failing to Operate
Within the Applicable Bandwidth Limits
10. Section 90.209(b)(5) requires licensees to comply with bandwidth limits applicable to its
equipment and the frequencies on which it operates. In the 450-470 MHz band, in which Global operates,
the channel bandwidth limit is 12.5 kHz, as noted above. As of January 1, 2013, the Commission’s
narrowbanding rules prohibit operation using a 25 kHz bandwidth in the 450-470 MHz frequency band,
for which Global holds a license. When the agents measured the bandwidth of WPPY512 in January
2016, and again during their inspection in April 2016, they found that Global was operating with a
25 kHz bandwidth, in clear violation of the Rule.  In addition, during the station inspection, Global’s
maintenance contractor, MRA, also said that the station failed to narrowband in accordance with the
13 See certified mail receipt, on file in EBATS File No. EB-FIELDWR-16-00021401.
14 Commission agents contacted Global by telephone on September 12 and September 13, 2016. They were directed
to leave a voice mail message for someone named “Mr. Lee,” which they did. The agents’ calls were not returned.
15 47 CFR § 1.903(a) (“Stations in the Wireless Radio Services must be used and operated only in accordance with
the rules applicable to their particular service as set forth in this title and with a valid authorization granted by the
Commission under the provisions of this part…”).
16 47 CFR §§ 90.425; 1.89(b).
Federal Communications Commission DA 17-272
4
Commission’s narrowbanding rule.17  Accordingly, we find that Global apparently violated Section
90.209(b)(5) of the Commission’s rules for failing to operate within the bandwidth limits applicable to the
450-470 MHz frequency band.
11. In addition, Section 1.903 of the Commission’s rules requires stations in the Wireless
Radio Services be “used and operated only in accordance with the rules applicable to their particular
service …”18  In response to Global’s initial renewal application in March 2015, which included both
narrowband and wideband emission designators, the Commission specifically told Global its renewal
application would be rejected if it included the prohibited wideband designation. Global then amended
the application to delete the wideband designation—leaving only the narrowband designators—thus
representing to the Commission that it would only operate WPPY512 on narrowband.  Global was
subsequently granted the renewal license.  Global, however, apparently disregarded what it told the
Commission and continued to operate in violation of the narrowband requirement, as verified by the
agents through testing in January 2016. Thus, Global’s operations did not match the terms of its license.
Accordingly, we find that Global also apparently violated Section 1.903(a) of the Commission’s rules by
failure to narrowband its operations, and, so doing, failed to comply with its license terms.
B. Global Apparently Violated Section 90.425 by Failing to Transmit its Station
Identification
12. The agents also monitored Global’s transmissions to determine if WPPY512 was
transmitting its station identification, as required by Section 90.425 of the Commission’s rules.19  The
agents found that station WPPY512 was not transmitting its station identification. We conclude that
Global apparently violated Section 90.425 by failing to transmit its call sign as required by the
Commission’s rules.
C. Global Apparently Violated Section 1.89(b) by Failing to Respond to the Bureau’s
NOV
13. In addition to its ongoing operational rule violations, Global apparently violated Section
1.89(b) of the Commission’s rules. Section 403 of the Act authorizes the Commission to institute on its
own motion any inquiry into, inter alia, any matter relating to the enforcement of the Act or the
Commission’s rules. Section 308 of the Act provides that the Commission “during the term of any such
licenses, may require from ... a licensee further written statements of fact to enable it to determine
whether ... such license [should be] revoked ....”  Section 1.89 of the Commission’s rules states that
licensees must submit a written answer to a NOV to the office originating the NOV within 10 days of
receipt of the NOV or within such period as may be specified.20  The agents issued a NOV on May 13,
2016, and obtained confirmation that Global received the NOV when it obtained the signed certified mail
receipt. The Commission has not received a response to the NOV, as required by Section 1.89(b) of the
Commission’s rules.
D. Proposed Forfeiture
14. Section 503(b) of the Act authorizes the Commission to impose a forfeiture against any
entity that “willfully or repeatedly fail[s] to comply with any of the provisions of [the Act] or of any rule,
regulation, or order issued by the Commission.”21  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
17 See paras. 6-7, supra.
18 47 CFR § 1.903(a).
19 47 CFR § 90.425.
20 47 CFR § 1.89(b).
21 47 U.S.C. § 503(b).
Federal Communications Commission DA 17-272
5
law.22    The Commission may also assess a forfeiture for violations that are merely repeated, and not
willful. The term “repeated” means the commission or omission of such act more than once or for more
than one day.23    Based on the record before us, Global’s apparent violations of the Act and the
Commission’s rules are both willful and repeated.
15. Here, Section 503(b)(2)(D) of the Act authorizes us to assess a forfeiture against Global
of up to $19,246 for each day of a continuing violation, up to a statutory maximum of $144,344 for a
single act or failure to act.24 In exercising our forfeiture authority, we must consider 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.”25
In addition, the Commission has established forfeiture guidelines; they establish base penalties for certain
violations and identify criteria that we consider when determining the appropriate penalty in any given
case.26 Under these guidelines, we may adjust a forfeiture upward for violations that are egregious,
intentional, or repeated, or that cause substantial harm or generate substantial economic gain for the
violator.27  As discussed above, we find that Global is apparently liable for three violations: (1) failure to
comply with the narrowbanding requirement; (2) failure to transmit station identification; and (3) failure
to respond to Commission communications. We propose forfeitures for each of these apparent violations
below.
22 47 U.S.C. § 312(f)(1).
23 47 U.S.C. § 312(f)(2).
24 See 47 U.S.C. § 503(b)(2)(D); 47 CFR §§ 1.80(b)(7), (9). These amounts reflect inflation adjustments to the
forfeitures specified in Section 503(b)(2)(D) ($10,000 per violation or per day of a continuing violation and $75,000
per any single act or failure to act). The Federal Civil Penalties Inflation Adjustment Act of 1990, Pub. L. No. 101-
410, 104 Stat. 890, as amended by the Debt Collection Improvement Act of 1996, Pub. L. No. 104-134, Sec. 31001,
110 Stat. 1321 (DCIA), as further amended by the Federal Reports Elimination Act of 1998, Pub. L. No. 105-362,
Sec. 1301, 112 Stat. 3280, and as further amended by the Federal Civil Penalties Inflation Adjustment Act
Improvements Act of 2015, Sec. 701, Pub. L. No. 114-74, 129 Stat. 599 (2015 Inflation Adjustment Act)
(collectively, Federal Civil Penalties Inflation Adjustment Act, as amended), codified as amended at 28 U.S.C. §
2461 note, required the Commission to adjust its penalties for inflation and publish interim final rules with the initial
penalty adjustment amounts by July 1, 2016 and new penalty levels must take effect no later than August 1, 2016.
See 28 U.S.C. § 2461 note. The Commission published those interim final rules on June 30, 2016.  See Amendment
of Section 1.80(b) of the Commission’s Rules, Adjustment of Civil Monetary Penalties to Reflect Inflation, Order, 31
FCC Rcd 6793 (EB 2016); see also Adjustment of Civil Monetary Penalties to Reflect Inflation, 81 Fed. Reg. 42554
(June 30, 2016) (setting August 1, 2016, as the effective date for the increases). The Federal Civil Penalties Inflation
Adjustment Act of 1990, as amended, also requires agencies, starting in 2017, to adjust annually the civil     
monetary penalties covered thereunder, and to publish each such annual adjustment by January 15 of each year. 28
U.S.C. § 2461 note, citing the Federal Civil Penalties Inflation Adjustment Act of 1990 as amended, § 4(a). See also
Office of Mgmt. & Budget, Exec. Office of the President, Memorandum for the Heads of Executive Departments and
Agencies re Implementation of the 2017 annual adjustment pursuant to the Federal Civil Penalties Inflation
Adjustment Act Improvements Act of 2015, M-17-11, Dec. 16, 2016 at 1,
ttps://www.whitehouse.gov/sites/default/files/omb/memoranda/2017/m-17-11_0.pdf. The Bureau released the order
making the 2017 annual adjustment on December 30, 2016. See Amendment of Section 1.80(b) of the Commission’s
Rules, Adjustment of Civil Monetary Penalties to Reflect Inflation, Order, 31 FCC Rcd 13485 (EB 2016); see also
Adjustment of Civil Monetary Penalties to Reflect Inflation, 82 Fed. Reg. 8170 (Jan. 24, 2017) (setting January 24,
2017, as the effective date for the increases). The 2015 Inflation Adjustment Act provides that the new penalty
levels shall apply to penalties assessed after the effective date of the increase, “including [penalties] whose
associated violation predated such increase.” See 28 U.S.C. § 2461 note, citing the Federal Civil Penalties Inflation
Adjustment Act, as amended, § 6.
25 47 U.S.C. § 503(b)(2)(E).
26 47 CFR § 1.80(b)(8), Note to paragraph (b)(8).
27 Id.
Federal Communications Commission DA 17-272
6
16. First, Global is apparently liable for failure to comply with the Commission’s
narrowbanding requirement. Although the Forfeiture Policy Statement does not establish a forfeiture
amount for failure to comply with the narrowbanding requirement, it does state that, “any omission of a
specific rule violation ... should not signal that the Commission considers any unlisted violation as
nonexistent or unimportant.”28  In cases in which the Commission has not established a base forfeiture
amount for a particular apparent violation, it has looked to the base forfeitures established or issued in
analogous cases for guidance.29  In one such case, the Bureau found that an earth station operator had
increased the bandwidth of its transmissions beyond that permitted by its license, and proposed a
forfeiture amount of $4,000 for that violation.30  Accordingly, we propose a base forfeiture amount of
$4,000 for Global’s apparent narrowbanding violation.
17. Second, Global failed to transmit its station identification, as required by Section
90.425(a).31  Section 1.80(b) of the Commission’s rules sets a base forfeiture of $1,000 for failure to
transmit station identification for each violation or each day of a continuing violation.
18. Third, Section 1.80(b) of the Commission’s rules sets a base forfeiture of $4,000 for
failure to respond to Commission communication for each violation or each day of a continuing violation.
Pursuant to Section 308 of the Act and Section 1.89 of the Commission’s rules, the Los Angeles Office
issued an NOV, confirmed the Global received the NOV, and Global did not respond. Therefore, we
propose a base forfeiture of $4,000 for Global’s apparent willful and repeated violation of Section 308 of
the Act and Section 1.89 of the Commission’s rules for failure to respond to Commission correspondence.
19. Combining all the base forfeiture amounts enumerated above, the total base forfeiture
amount for Global’s apparent violations is $9,000. We have discretion, however, to depart from the
Commission’s forfeiture guidelines, taking into account the particular facts of each individual case.32
20. Given the totality of the circumstances, and consistent with the Forfeiture Policy
Statement, we conclude that two significant upward adjustments of the proposed forfeiture amount for the
narrowbanding violation ($4,000 proposed base forfeiture) are warranted. First, the Commission initially
adopted the narrowbanding requirement for the frequencies in question in 2003.33 The Commission
subsequently issued a number of additional orders and reminders to licensees about the narrowbanding
28 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, 17099, para. 22 (1997) (Forfeiture Policy Statement),
recons. denied, 15 FCC Rcd 303 (1999).
29 See, e.g., Terracom, Inc. and YourTel America, Inc., Notice of Apparent Liability for Forfeiture, 29 FCC Rcd
13325, 13342, para. 47 (2014); SBC Communications Inc., Order on Review, 17 FCC Rcd 4043, 4051-52, para. 20
(2002).
30 American General Finance, Inc. Licensee of Earth Stations E950320, E950321, E950322, E950323, Evansville,
Indiana, Notice of Apparent Liability for Forfeiture, 21 FCC Rcd 6935, 6938-39, para. 8 (EB 2006).
31 47 CFR § 90.425(a).
32 Forfeiture Policy Statement, 12 FCC Rcd at 17098–99, para. 22 (1997) (noting that “[a]lthough we have adopted
the base forfeiture amounts as guidelines to provide a measure of predictability to the forfeiture process, we retain
our discretion to depart from the guidelines and issue forfeitures on a case-by-case basis, under our general
forfeiture authority contained in Section 503 of the Act”).
33 Narrowbanding Second R&O, 18 FCC Rcd 3034; 3038, para. 12; 47 CFR §§ 90.203(j), 90.209(b)(5); see also
Narrowbanding Third MO&O, 19 FCC Rcd 25045, 25049-50, para. 9.
Federal Communications Commission DA 17-272
7
requirement.34  As a licensee, Global is required to be aware of the Commission’s rules.35  Yet after ten
years’ advance notice, Global has operated in violation of those rules for a period of more than four years.
As noted above, Global demonstrated that it had actual notice of the narrowbanding requirements when it
amended its renewal application. Due to the length of time that Global had notice of the requirement to
narrowband its operation an upward adjustment is appropriate.36  In this case, we find that an upward
adjustment of the proposed forfeiture amount for the narrowbanding violation, or $2,000, is appropriate.
21. Second, we also find that Global’s failure to modify its operations to be consistent with its
license terms is egregious.  When Global modified its license and amended its renewal application to
reflect the modification, i.e., to delete its wideband authorization, it surrendered the authority to operate on
a wideband basis. Once Global’s license was modified, it was obliged to implement conforming changes
to its operating parameters. Global’s decision to continue to operate on a wideband basis after    
modifying its license to surrender the authority to do so is egregious, and so warrants an additional $2,000
upward adjustment. After applying the Forfeiture Policy Statement, Section 1.80 of the Commission’s
rules, and the two upward adjustments discussed above, we propose a total forfeiture of $13,000 for
which Global is apparently liable.
IV. CONCLUSION
22. We have determined that Global apparently willfully and repeatedly violated Sections
1.903(a), 90.209(b)(5), 90.425, and 1.89(b) of the Commission’s rules.  As such, Global is apparently
liable for a forfeiture of $13,000.
34 See, e.g., The Office of Engineering and Technology, Wireless Telecommunications Bureau, and Public Safety and
Homeland Security Bureau Remind Licensees, Frequency Coordinators, and Equipment Manufacturers of
Narrowband Migration Deadlines in the 150-174 MHz and 421-512 MHz Bands, Public Notice, 25 FCC Rcd 16990
(OET/WTB/PSHSB 2010);Wireless Telecommunications Bureau, Public Safety and Homeland Security Bureau,
and Office of Engineering and Technology Provide Reminder of January 1, 2013 Deadline for Transition to
Narrowband in the 150-174 MHz and 421-512 MHz Bands and Guidance for Submission of Requests for Waiver
and Other Matters, Public Notice, 26 FCC Rcd 9647 (2011); Less Than One Year Remains For Land Mobile Radio
Licensees In the 150-174 MHz And 421-512 MHz Bands To Transition To Narrowband Operations, Public Notice,
27 FCC Rcd 138 (2012); Enforcement Bureau Reminds Private Land Mobile Licensees and Equipment
Manufacturers of the January 1, 2013 Deadline for Transitioning to Narrowband Technology, Enforcement
Advisory, 27 FCC Rcd 10160 (EB 2012); Telecommunications Bureau, Public Safety and Homeland Security
Bureau, and Office of Engineering and Technology Provide Guidance on Compliance With Narrowband
Requirement Now in Effect for Private Land Mobile Radio Operations in the 150-174 MHz and 421-470 MHz Bands,
Public Notice, 28 FCC Rcd 2296 (WTB/PSHSB/OET 2013);Wireless Telecommunications Bureau and Public
Safety and Homeland Security Bureau Provide Additional Guidance Regarding Post-Narrowbanding License
Renewal Procedures for Private Land Mobile Radio Operators in the 150-174 MHz and 421-470 MHz Bands,
Public Notice, 29 FCC Rcd 2088 (WTB/PSHSB 2014).
35 “Licensees, however, are expected to know and comply with the Rules…” American Samoa Telecommunications
Authority, Forfeiture Order, 22 FCC Rcd 13174, 13179, para. 8 (2012), citing Forfeiture Policy Statement, 12 FCC
Rcd at 17099, para. 22 (“[t]he Commission expects [each licensee], and it is each licensee’s obligation, to know and
comply with all of the Commission’s rules”).
36 While section 503(b)(6) of the Act bars the Commission from proposing a forfeiture for violations that occurred
more than a year prior to the issuance of an NAL, we may consider the fact that Global’s misconduct occurred over
an extended period to place “the violations in context, thus establishing the licensee’s degree of culpability and the
continuing nature of the violations.” Roadrunner Transportation Inc., Forfeiture Order, 15 FCC Rcd 9669, 9671-72,
para. 8 (2000). The forfeiture amount we propose herein relates only to Global’s apparent violations that occurred
within the past year.
Federal Communications Commission DA 17-272
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V. ORDERING CLAUSES
23. Accordingly, IT IS ORDERED that, pursuant to Section 503(b) of the Act37 and
Sections 1.80 of the Commission’s rules,38 Global Paratransit Inc. is hereby NOTIFIED of this
APPARENT LIABILITY FOR A FORFEITURE in the amount of thirteen thousand dollars ($13,000)
for willful and repeated violations of Sections 1.903(a), 90.209(b)(5), 90.425, and 1.89(b) of the
Commission’s rules.39
24. IT IS FURTHER ORDERED that, pursuant to Section 1.80 of the Commission’s
rules,40 within thirty (30) calendar days of the release date of this Notice of Apparent Liability for
Forfeiture, Global Paratransit Inc. SHALL PAY the full amount of the proposed forfeiture or SHALL
FILE a written statement seeking reduction or cancellation of the proposed forfeiture consistent with
paragraph 27 below.
25. Payment of the forfeiture must be made by check or similar instrument, wire transfer, or
credit card, and must include the NAL/Account Number and FRN referenced above. Global Paratransit,
Inc. shall send electronic notification of payment to Janet Moran at Janet.Moran@fcc.gov on the date said
payment is made. Regardless of the form of payment, a completed FCC Form 159 (Remittance Advice)
must be submitted.41  When completing the FCC Form 159, enter the Account Number in block number
23A (call sign/other ID) and enter the letters “FORF” in block number 24A (payment type code). Below
are additional instructions that should be followed based on the form of payment selected:
• Payment by check or money order must be made payable to the order of the Federal
Communications Commission.  Such payments (along with the completed Form 159) must be
mailed to Federal Communications Commission, P.O. Box 979088, St. Louis, MO 63197-
9000, or sent via overnight mail to U.S. Bank – Government Lockbox #979088, SL-MO-C2-
GL, 1005 Convention Plaza, St. Louis, MO 63101.
• Payment by wire transfer must be made to ABA Number 021030004, receiving bank
TREAS/NYC, and Account Number 27000001. To complete the wire transfer and ensure
appropriate crediting of the wired funds, a completed Form 159 must be faxed to U.S. Bank
at (314) 418-4232 on the same business day the wire transfer is initiated.
• Payment by credit card must be made by providing the required credit card information on
FCC Form 159 and signing and dating the Form 159 to authorize the credit card payment.
The completed Form 159 must then be mailed to Federal Communications Commission, P.O.
Box 979088, St. Louis, MO 63197-9000, or sent via overnight mail to U.S. Bank –
Government Lockbox #979088, SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO
63101.
26. Any request for making full payment over time under an installment plan should be sent
to: Chief Financial Officer—Financial Operations, Federal Communications Commission, 445 12th
Street, SW, Room 1-A625, Washington, DC 20554.42  Questions regarding payment procedures should be
directed to the Financial Operations Group Help Desk by phone, 1-877-480-3201, or by e-mail,
ARINQUIRIES@fcc.gov.
37 47 U.S.C. § 503(b).
38 47 CFR § 1.80.
39 47 CFR §§ 1.903(a), 90.209(b)(5), 90.425, 1.89(b).
40 47 CFR § 1.80.
41 An FCC Form 159 and detailed instructions for completing the form may be obtained at
http://www.fcc.gov/Forms/Form159/159.pdf.
42 See 47 CFR § 1.1914.
Federal Communications Commission DA 17-272
9
27. 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 1.16 and 1.80(f)(3) of the Commission’s rules.43  The written statement must be mailed to the
Office of the Secretary, Federal Communications Commission, 445 12th Street, SW, Washington, DC
20554, ATTN: Enforcement Bureau – Office of the Field Director, and must include the NAL/Account
Number referenced in the caption. The statement must also be e-mailed to Janet Moran at
Janet.Moran@fcc.gov.
28. 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.
29. 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 Reza Nasrollahy,
Global Paratransit, Inc., 400 W. Compton Blvd., Gardena, CA 90238.
FEDERAL COMMUNICATIONS COMMISSION
Lark Hadley
Regional Director
Region Three
Enforcement Bureau
43 47 CFR §§ 1.16, 1.80(f)(3).