Federal Communications Commission DA 08-24
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Cooperative Light & Power Association
Two Harbors, Minnesota
)
)
)
)
)
File No. EB-06-SE-324
NAL/Acct. No. 200732100024
FRN: 0002653921
ORDER
Adopted: January 8, 2008 Released: January 10, 2008 
By the Chief, Enforcement Bureau:
1. In this Order, we adopt the attached Consent Decree entered into between the 
Enforcement Bureau (“Bureau”) of the Federal Communications Commission (“FCC” or “Commission”) 
and Cooperative Light & Power Association (“CLP”).  The Consent Decree terminates the Bureau’s 
enforcement proceeding relating to CLP’s compliance with Section 301 of the Communications Act of
1934, as amended (“Act”)1, and Sections 1.903 and 1.949(a) of the Commission’s Rules (“Rules”).2
2. The Bureau and CLP have negotiated the terms of a Consent Decree that would resolve 
these matters and terminate the enforcement proceeding.  A copy of the Consent Decree is attached hereto 
and incorporated by reference.
3. Based on the record before us, we conclude that no substantial or material questions of 
fact exist with respect to this matter as to whether CLP possesses the basic qualifications, including those 
related to character, to hold or obtain any FCC license or authorization.
4. After reviewing the terms of the Consent Decree, we find that the public interest would 
be served by adopting the Consent Decree and terminating the enforcement proceeding.
5. Accordingly, IT IS ORDERED, pursuant to Sections 4(i) and 503(b) of the Act,3 and the 
authority delegated by Sections 0.111 and 0.311 of Rules,4 the Consent Decree attached to this Order IS 
ADOPTED.
6. IT IS FURTHER ORDERED that the above-captioned enforcement proceeding IS
TERMINATED.
7. IT IS FURTHER ORDERED that CLP shall make its voluntary contribution to the 
United States Treasury, as specified in the Consent Decree, by credit card through the Commission’s Debt 
  
1 47 U.S.C. § 301.
2 47 U.S.C. § 1.903 and 1.949(a).
3 47 U.S.C. §§ 154(i) and 503(b).
4 47 U.S.C. § 154(i); 47 C.F.R. §§ 0.111, 0.311.
Federal Communications Commission DA 08-24
2
and Credit Management Center at (202) 418-1995, or by mailing a check or similar instrument, payable to 
the order of the Federal Communications Commission, to the Federal Communications Commission, P.O. 
Box 358340, Pittsburgh, PA 15251-8340.  Payment by overnight mail may be sent to Mellon Bank/LB 
358340, 500 Ross Street, Room 1540670, Pittsburgh, PA 15251.  Payment by wire transfer may be made 
to ABA Number 043000261, receiving bank Mellon Bank, and account number 911-6106.  The payment 
should reference NAL/Acct. No. 200732100024 and FRN # 0002653921. 
8. IT IS FURTHER ORDERED that a copy of this Order and Consent Decree shall be 
sent by first class mail and certified mail, return receipt requested, to Steve Wattnem, General Manager, 
Cooperative Light & Power Association, Two Harbors, Minnesota 55616 and Counsel Richard D. 
Rubino, Esq., Counsel for Cooperative Light & Power, Blooston, Mordkofsky, Dickens, Duffy & 
Prendergast, LLP, 2120 L Street, NW, Suite 300, Washington, DC 20037.
FEDERAL COMMUNICATIONS COMMISSION
Kris Anne Monteith
Chief, Enforcement Bureau
Federal Communications Commission DA 08-24
1
CONSENT DECREE
I. INTRODUCTION
1. This Consent Decree is entered into by the Enforcement Bureau (“Bureau”) of the 
Federal Communications Commission (“FCC” or “Commission”) and Cooperative Light & Power 
Association (“CLP”) for the purpose of terminating an enforcement proceeding relating to CLP's 
compliance with Section 301 of the Communications Act of 1934, as amended, (“Act”),1 and Sections 
1.903 and 1.949(a) of the Commission’s Rules (“Rules”),2 regarding its failure to file timely renewal 
applications for Private Land Mobile Radio Service (“PLMRS”) stations and the operation of the stations 
without authorization after expiration of its licenses.
II.  DEFINITIONS
2. For purposes of this Consent Decree, the following definitions shall apply:
a. “Act” means the Communications Act of 1934, as amended, Title 47 of the United States 
Code.
b. “Adopting Order” means an order of the Bureau adopting the terms and conditions of this 
Consent Decree.
c. “Bureau” means the Commission’s Enforcement Bureau.
d. “CLP” means Cooperative Light & Power Association, its subsidiaries, affiliates and any 
successors or assigns.
e. “Commission” or “FCC” means the Federal Communications Commission.
f. “Effective Date” means the date the Adopting Order is released by the Bureau.
g. “Enforcement Proceeding” means the investigation of the alleged Rule violations by CLP
culminating in the Notice of Apparent Liability for Forfeiture.
h. “Licenses” means Private Land Mobile Radio Service stations WYU920, WYU921, 
WFK224 and KA40187.
i. “Notice of Apparent Liability for Forfeiture” or “NAL” means Cooperative Light & 
Power Association, Notice of Apparent Liability for Forfeiture, 22 FCC Rcd 6710 (Enf. 
Bur., Spectrum Enf. Div., 2007).
j. “Parties” means CLP and the Bureau.
k. “PLMRS” means Private Land Mobile Radio Service.
l. “Radio Facilities” means the facilities authorized under the Licenses.
m. “Rules” means the Commission’s Rules found in Title 47 of the Code of Federal 
Regulations.
III. BACKGROUND
3. CLP is a Minnesota-based rural electric cooperative. 
4. On July 17, 2004, CLP’s licenses for Private Land Mobile Radio Service stations 
WYU920, WYU921, WFK224 and KA40187 expired. On October 16, 2006, CLP filed a request with 
the FCC’s Wireless Telecommunications Bureau (“WTB”) for Special Temporary Authority (“STA”) to 
continue operation of the radio facilities previously authorized under the licenses for stations WYU920, 
  
1 47 U.S.C. § 301.
2 47 C.F.R. §§ 1.903 and 1.949(a).
Federal Communications Commission DA 08-24
2
WYU921, WFK224 and KA40187.  The WTB granted CLP an STA effective July 11, 2006 under call 
sign WQFG667 without prejudice to any enforcement action related to the unauthorized operations.  
Permanent authority was granted effective October 30, 2006 under call sign WQFX519.  On April 5, 
2007, the Enforcement Bureau’s Spectrum Enforcement Division issued a Notice of Apparent Liability
for Forfeiture proposing a $20,800 forfeiture against CLP.
IV.  TERMS OF AGREEMENT
5. The Parties agree that the provisions of this Consent Decree shall be subject to final 
approval by the Bureau by incorporation of such provisions by reference in the Adopting Order.
6. The Parties agree that this Consent Decree shall become binding on the Parties on the 
Effective Date.  Upon release, the Adopting Order and this Consent Decree shall have the same force and 
effect as any other final order of the Commission and any violation of the terms or conditions of this 
Consent Decree shall constitute a violation of a Commission order.
7. The Parties agree that this Consent Decree shall constitute a final settlement between 
CLP and the Bureau regarding the matters that were the subject of the Enforcement Proceeding.  
8. The Parties agree that this Consent Decree shall not constitute an adjudication on the 
merits or a factual or legal determination regarding any compliance or noncompliance with the Act or the 
Rules.  The Parties further agree that this Consent Decree is for settlement purposes only and that by 
agreeing to this Consent Decree, CLP does not admit or deny any noncompliance, violation, or liability 
associated with or arising from its acts or omissions involving the Act or the Rules that are the subject of 
this Consent Decree.
9. CLP agrees to make a voluntary contribution to the United States Treasury in the amount 
of sixteen thousand dollars ($16,000) within 30 calendar days after the Effective Date.  Payment shall be 
made without further protest or recourse, by credit card through the Commission’s Debt and Credit 
Management Center at (202) 418-1995, or by mailing a check or similar instrument, payable to the order 
of the Federal Communications Commission, to the Federal Communications Commission, P.O. Box 
358340, Pittsburgh, PA 15251-8340.  Payment by overnight mail may be sent to Mellon Bank/LB 
358340, 500 Ross Street, Room 1540670, Pittsburgh, PA 15251.  Payment by wire transfer may be made 
to ABA Number ABA Number 043000261, receiving bank Mellon Bank, and account number 911-6106.
10. CLP agrees to implement a Compliance Program to ensure compliance with the 
Communications Act and the Commission’s rules and regulations.  A summary of the Compliance 
Program is attached to this Consent Decree as Attachment A.
11. Within thirty days after the Effective Date of the Adopting Order, CLP will submit a 
statement from an officer of CLP certifying that CLP has implemented the Compliance Program.  The 
compliance statement shall be submitted to Kathryn S. Berthot, Chief, Spectrum Enforcement Division, 
Enforcement Bureau, Federal Communications Commission, 445 12th Street, S.W., Washington, D.C.  
20554. 
12. In reliance upon the representations contained herein, and to avoid further expenditure of 
scarce public resources, the Bureau agrees to terminate the Enforcement Proceeding.
13. In consideration for the termination by the Bureau of the Enforcement Proceeding and in 
accordance with the terms of this Consent Decree, CLP agrees to the terms, conditions and procedures 
contained herein.
Federal Communications Commission DA 08-24
3
14. The Bureau agrees that, in the absence of new material evidence, it will not entertain, or 
institute on its own motion, any new proceeding, formal or informal, or take any action on its own motion 
against CLP for any alleged violations of the Act or the Commission’s Rules regarding the matters which 
were the subject of the Enforcement Proceeding.  The Bureau also agrees that, in the absence of new 
material evidence, it will not initiate or recommend to the Commission any new proceeding, formal or 
informal, against CLP regarding the matters that were the subject of the Enforcement Proceeding.  The 
Bureau further agrees that, in the absence of new material evidence, it will not use the facts developed in 
the Enforcement Proceeding through the Effective Date to initiate on its own motion, or recommend to 
the Commission, any proceeding, formal or informal, or take any action on its own motion against CLP
with respect to CLP’s basic qualifications to hold Commission licenses or authorizations.  Nothing in this 
Consent Decree shall prevent the Commission from instituting investigations or enforcement proceedings 
against CLP in the event of any other alleged misconduct that violates this Consent Decree or that violates 
any provision of the Act or the Rules.
15. The Parties agree that each is required to comply with each individual condition of this 
Consent Decree.  Each specific condition is a separate condition of the Consent Decree as approved.  To 
the extent that CLP fails to satisfy any condition, in the absence of Commission alteration of the 
condition, it will be deemed noncompliant and may be subject to possible future enforcement action with 
respect to such failure to satisfy the condition.
16. CLP acknowledges that the Bureau has jurisdiction over it and the matters contained in 
this Consent Decree and the authority to enter into and adopt this Consent Decree.
17. CLP waives any and all rights it may have to seek administrative or judicial 
reconsideration, review, appeal or stay, or to otherwise challenge or contest the validity of this Consent 
Decree and the Adopting Order, provided that the Adopting Order adopts the Consent Decree without 
change, addition or modification.
18. The Parties agree that the effectiveness of this Consent Decree is expressly contingent 
upon the issuance of the Adopting Order, provided the Adopting Order adopts the Consent Decree 
without change, addition or modification.
19. The Parties agree that if any court of competent jurisdiction renders this Consent Decree 
invalid, it shall become null and void and may not be used in any manner in any legal proceeding.
20. The Parties agree that if either party (or the United States on behalf of the Commission)
brings a judicial action to enforce the terms of the Adopting Order, neither CLP nor the Commission shall 
contest the validity of the Consent Decree or the Adopting Order and CLP and the Commission shall 
waive any statutory right to a trial de novo with respect to any matter upon which the Adopting Order is 
based, and shall consent to a judgment incorporating the terms of the Consent Decree.
21. CLP agrees to waive any claims it may otherwise have under the Equal Access to Justice 
Act, Title 5 U.S.C. §504 and 47 C.F.R. §1.1501 et. seq. relating to matters discussed in this Consent 
Decree.
22. The Parties agree that the terms and conditions of this Consent Decree shall remain in 
effect for a period of twenty-four (24) months from the Effective Date.
23. This Consent Decree cannot be modified without the advance written consent of both 
Parties.
Federal Communications Commission DA 08-24
4
24. This Consent Decree may be signed in counterparts.
For the Enforcement Bureau:
By: _____________________ ____________
Kris Anne Monteith Date
Bureau Chief
For Cooperative Light & Power Association:
By: _____________________ ____________
Steve Wattnem Date
General Manager
Federal Communications Commission DA 08-24
5
Attachment A
Summary of Section 301 Compliance Program
of
Cooperative Light & Power Association
To assure compliance with Section 301 of the Communications Act of 1934, as amended and the Federal 
Communications Commission ("FCC") rules and regulations, the Cooperative Light & Power Association 
(“CLP” or the “Company”) Compliance and Education Program (the "Program") will be established.  The 
Program will be administered by the Legal Department of CLP in consultation with outside counsel.
Program operations will be described in a compliance manual addressing four areas:  database, education, 
review and monitoring, and compliance oversight by the General Manager for Cooperative Light & 
Power Association.
Database:  With the assistance of outside telecommunications counsel, CLP shall develop and maintain 
information about the Company’s telecommunications licenses and other telecommunications 
information.  This information may be maintained in the form of an electronic database or in a manual 
facilities listing that is periodically updated.  This information shall be made available to the Company’s 
personnel who are responsible for maintaining the telecommunications licenses.  The Company, either 
directly or through its outside telecommunications counsel, shall maintain a tickler listing to prompt the 
timely filing of license renewal applications.  The Company will establish the database within 30 days of 
the Consent Decree’s Effective Date.
Education:  With the assistance of outside telecommunications counsel, the Company shall develop an 
education program for the Company’s managers and other parties responsible for the purchase, 
acquisition, and sale of radio equipment as well as entities and other properties which may include 
telecommunications assets.  The Company will implement the education program within thirty (30) days 
of the Consent Decree’s Effective Date.  The education program will emphasize the need to make timely 
application for FCC new radio facilities, modifications to existing radio facilities, renewal of radio 
licenses and to the extent ownership changes may occur, applications for prior consent to changes in 
ownership or control of telecommunications licenses.  The Program will be supplemented by memoranda 
and other information updates provided by outside telecommunications counsel on a periodic basis, which 
are designed to keep the Company informed of FCC policy and regulatory compliance requirements.
Review and Monitoring:  The General Manager for the Cooperative Light & Power Association will 
review the Program annually in order to ensure that it is maintained in a proper manner and continues to 
address the objectives set forth herein.