Federal Communications Commission DA 10-634 
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Christian Radio Fellowship
Licensee of Station WFTF(FM)
Rutland, Vermont
and
FM Translator Station W220AX
Ludlow, Vermont
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NAL/Acct. No. MB-200741410415, MB-
200741410414 
FRN: 0013161880
Facility ID No. 11099
File No. BRFT-20060821ABK
Facility ID No. 11095
File No. BRED-20060822AJB
FORFEITURE ORDER
Adopted:  April 13, 2010 Released:  April 14, 2010
By the Chief, Audio Division, Media Bureau:
I. INTRODUCTION
1. In this Forfeiture Order, we issue a monetary forfeiture in the amount of seven thousand 
five hundred dollars ($7,500) to Christian Radio Fellowship (“Licensee”), licensee of Station WFTF(FM), 
Rutland, Vermont, and FM translator station W220AX, Ludlow, Vermont (“Stations”), for willfully 
violating Section 73.3539 of the Commission’s Rules (“Rules”), by failing to timely file license renewal 
applications for the Stations, and willfully and repeatedly violating Section 301 of the Communications 
Act of 1934, as amended (“Act”), by engaging in unauthorized operation of the Stations after their 
authorizations had expired.1
II. BACKGROUND
2. On November 15, 2007, the Bureau issued two separate Notices of Apparent Liability for 
Forfeiture (“NALs”) in the amount of seven thousand dollars ($7,000) and five hundred dollars ($500), 
respectively, to Licensee for these violations.2 As noted in the NALs, Licensee’s renewal applications for 
the Stations’ license term were due on December 1, 2005, four months prior to the April 1, 2006, 
expiration date.3  Licensee did not file the application for Station WFTF(FM) until August 21, 2006 and 
did not file the application for Station W220AX until August 22, 2006.  Licensee provided no explanation 
for the untimely filing of the renewal applications or its failure to request special temporary authorization 
(“STA”) to continue the Stations’ operations after its licenses had expired.  In response to the NALs, 
Licensee submitted two letters (collectively, “Requests”) on December 10, 2007.  
  
1 47 C.F.R. § 73.3539; 47 U.S.C. § 301.
2 Christian Radio Fellowship, Memorandum Opinion and Order and Notice of Apparent Liability for Forfeiture, 22 
FCC Rcd 19857 (MB 2007) (for Station WFTF(FM)); Christian Radio Fellowship, Memorandum Opinion and 
Order and Notice of Apparent Liability for Forfeiture, 22 FCC Rcd 19853 (MB 2007) (for Station W220AX).  The 
Commission granted the license renewal applications on November 15, 2007.
3 See 47 C.F.R. §§ 73.1020, 73.3539(a).
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III. DISCUSSION
3. The forfeiture amount proposed in this case was assessed in accordance with Section 
503(b) of the Act,4 Section 1.80 of the Rules,5 and the Commission’s Forfeiture Policy Statement.6 In 
assessing forfeitures, Section 503(b)(2)(E) 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 such other matters as justice may require.7  
4. Licensee requests that the forfeiture be cancelled on the grounds that it thought it had 
correctly filed the renewal applications on October 19, 2005.  It asserts that the renewal applications for 
the Stations were created on that date and mistakenly assumed that “Pending” status in the Commission’s 
online filing system indicated that the applications had been successfully filed.8 As the Commission has 
held, however, violations resulting from inadvertent error or failure to become familiar with the FCC's 
requirements are willful violations.9  In the context of a forfeiture action, “willful” does not require a 
finding that the rule violation was intentional.  Rather, the term “willful” means that the violator knew 
that it was taking (or, in this case, not taking) the action in question, irrespective of any intent to violate 
the Rules.10 Moreover, the Commission has specifically ruled that confusion or difficulties with the 
Commission’s electronic filing system are not grounds for reduction or cancellation of a forfeiture.11  
Accordingly, we find this argument without merit.  
5. We have considered Licensee’s Requests and the record of this case in light of the above 
statutory factors, our Rules, and the Forfeiture Policy Statement.  We conclude that, in each of these 
situations, Licensee willfully12 violated Section 73.3539 of the Rules and willfully and repeatedly13
  
4 47 U.S.C. § 503(b).
5 47 C.F.R. § 1.80. 
6 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), recon. denied, 15 FCC Rcd 303 (1999).  
7 47 U.S.C. § 503(b)(2)(E).
8 Requests at 1.
9 See PJB Communications of Virginia, Inc., Memorandum Opinion and Order, 7 FCC Rcd 2088, 2088 (1992);  
Southern California Broadcasting Co., Memorandum Opinion and Order, 6 FCC Rcd 4387, 4387 (1991), recon. 
denied, 7 FCC Rcd 3454 (1992) (“Southern California”) (stating that “inadvertence … is at best, ignorance of the 
law, which the Commission does not consider a mitigating circumstance”); Standard Communications Corp., 
Memorandum Opinion and Order, 1 FCC Rcd 358, 358 (1986) (stating that “employee acts or omissions, such as 
clerical errors in failing to file required forms, do not excuse violations”). 
10 See Five Star Parking d/b/a Five Star Taxi Dispatch, Forfeiture Order, 23 FCC Rcd 2649, 2651 (EB 2008) 
(declining to reduce or cancel forfeiture for late-filed renewal based on licensee’s administrative error); Southern 
California, 6 FCC Rcd at 4387.  See also Domtar Industries, Inc., Notice of Apparent Liability for Forfeiture, 21 
FCC Rcd 13811, 13815 (EB 2006) (“ignorance of or unfamiliarity with the Commission’s requirements is not a 
mitigating factor and does not warrant a forfeiture reduction”); National Weather Networks, Inc., Notice of Apparent 
Liability for Forfeiture, 21 FCC Rcd 3922, 3925 (EB 2006) (“negligence does not mitigate a Commission rule 
violation”).  
11 See Muskegon Training and Educational Center, Forfeiture Order, 23 FCC Rcd 11241, 11242-43 (MB 2008).
12 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. § 312(f)(1).  The legislative history of Section 312(f)(1) 
of the Act clarifies that this definition of willful applies to Sections 312 and 503(b) of the Act, H.R. REP. No. 97-
765, 51 (Conf. Rep.), and the Commission has so interpreted the terms in the Section 503(b) context.  See Southern 
California, 6 FCC Rcd at 4387-88.
Federal Communications Commission DA 10-634
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violated Section 301 of the Act14 and that no mitigating circumstances warrant cancellation or further 
reduction of the proposed forfeiture amount.15  
IV. ORDERING CLAUSES
6. Accordingly, IT IS ORDERED, pursuant to Section 503(b) of the Communications Act 
of 1934, as amended, and Sections 0.283 and 1.80 of the Commission’s Rules,16 that Christian Radio 
Fellowship SHALL FORFEIT to the United States the sum of seven thousand five hundred dollars 
($7,500) for willfully violating Section 73.3539 of the Commission’s Rules and for willfully and 
repeatedly violating Section 301 of the Communications Act of 1934, as amended.
7. Payment of the forfeiture shall be made in the manner provided for in Section 1.80 of the 
Commission's Rules within 30 days of the release 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.17 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/Acct. No. and FRN No. referenced in the caption above.  Payment by check or money order may be 
mailed to Federal Communications Commission, at 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, BNF: FCC/ACV--27000001 and account number as expressed 
on the remittance instrument.  If 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).18  Requests for payment of the full amount of the forfeiture under an installment plan should be 
sent to: Associate Managing Director-Financial Operations, Room 1-A625, 445 12th Street, S.W., 
Washington, D.C. 20554.19
  
(...continued from previous page)
13 Section 312(f)(2) of the Act defines “repeated” as “the commission or omission of [any] act more than once or, if 
such commission or omission is continuous, for more than one day.” 47 U.S.C. § 312(f)(2).  See also Southern 
California, 6 FCC Rcd at 4388 (applying this definition of repeated to Sections 312 and 503(b) of the Act). 
14 47 C.F.R § 73.3539; 47 U.S.C. § 301.
15 A forfeiture amount of five hundred dollars ($500) is proper for Station W220AX, given the Commission's recent 
decisions assessing forfeitures in the amount of $500 against licensees of translator stations for violations of Section 
73.3539 of the Rules and Section 301 of the Act, based on the station’s status as a provider of secondary FM 
translator service. See, e.g., KSOP, Inc., Memorandum Opinion and Order and Notice of Apparent Liability for 
Forfeiture, 22 FCC Rcd 20950, 20952 (MB 2007) (issuing NAL in the amount of $500 for licensee's failure to 
timely file a license renewal application and for unauthorized operation of its translator station).
16 47 U.S.C. § 503(b); 47 C.F.R. §§ 0.283, 1.80.
17 47 U.S.C. § 504(a).
18 See 47 C.F.R. § 1.1914.
19 Id.
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8. IT IS FURTHER ORDERED, that a copy of this Forfeiture Order shall be sent by 
Certified Mail Return Receipt Requested to Mr. Ronald Systo, Christian Radio Fellowship, 2 Meadow 
Lane, Rutland, Vermont 05701.
FEDERAL COMMUNICATIONS COMMISSION
Peter H. Doyle
Chief, Audio Division 
Media Bureau