Federal Communications Commission DA 13-2007
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
CSSI NON-PROFIT EDUCATIONAL 
BROADCASTING CORPORATION
Licensee of Noncommercial Educational FM 
Stations KYQX(FM), Weatherford, Texas,
KMQX(FM), Weatherford, Texas,
KEQX(FM), Stephenville, Texas,
KQXS(FM), Stephenville, Texas,
KSQX(FM), Springtown, Texas, and
KQXE(FM), Eastland, Texas
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File No.:  EB-08-IH-1459 
NAL/Acct. No.:  201332080017
FRN No.:  0005813795
Facility ID No.:  62040
Facility ID No.:  89176
Facility ID No.:  89619
Facility ID No.:  89698
Facility ID No.:  62041
Facility ID No.:  89692
ORDER
Adopted:  September 30, 2013 Released:  September 30, 2013
By the Acting Chief, Enforcement Bureau: 
1. In this Order, we adopt the attached Consent Decree entered into between the 
Enforcement Bureau (Bureau) and CSSI Non-Profit Educational Broadcasting Corporation, Inc., licensee 
of the above-captioned Stations (CSSI).  The Consent Decree terminates the Bureau’s investigation of 
CSSI for possible violations of a 2007 Consent Decree,1 Section 399B of the Communications Act of 
1934, as amended,2 and Sections 73.503 and 73.3527 of the Commission’s rules,3 by broadcasting 
prohibited advertisements over Station KYQX(FM), Weatherford, Texas and by failing to make available 
and maintain complete public inspection files for its captioned Stations.
2. The Bureau and CSSI have negotiated the terms of the Consent Decree that resolves this 
matter, including a detailed, three-year compliance plan requirement.  A copy of the Consent Decree is 
attached hereto and incorporated by reference.  
3. After reviewing the terms of the Consent Decree and evaluating the facts before us, we 
find that the public interest will be served by adopting the Consent Decree and terminating the 
investigation.
4. In the absence of material new evidence relating to this matter, we conclude that our 
investigation raises no substantial or material questions of fact as to whether CSSI possesses the basic 
  
1 CSSI Non-Profit Educational Broadcasting Corporation, Order and Consent Decree, 22 FCC Rcd 3314 (Enf. Bur. 
2007) (2007 Consent Decree).  
2 47 U.S.C. § 399b.
3 47 C.F.R. §§ 73.503(d), 73.3527.
Federal Communications Commission DA 13-2007
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qualifications, including those related to character, to hold or obtain any Commission license or 
authorization. 
5. Accordingly, IT IS ORDERED that, pursuant to Sections 4(i), 4(j), and 503(b) of the 
Communications Act of 1934, as amended,4 and Sections 0.111 and 0.311 of the Rules,5 the Consent 
Decree attached to this Order IS ADOPTED.
6. IT IS FURTHER ORDERED that the above-captioned investigation, as to the Stations 
and/or CSSI, IS TERMINATED.
7. IT IS FURTHER ORDERED that any third-party complaints and allegations against 
the Stations and/or CSSI related to the above-captioned investigation that are pending before the Bureau 
as of the date of this Consent Decree ARE DISMISSED.
8. IT IS FURTHER ORDERED that a copy of this Order and Consent Decree shall be 
sent by both First Class U.S. Mail and Certified Mail, Return Receipt Requested, to Charles H. Beard, 
President, and Melinda Beard, Secretary, CSSI Non-Profit Educational Broadcasting Corporation, 905 
Palo Pinto Street, Weatherford, Texas 76086; and to CSSI’s counsel, Lee G. Petro, Esquire, Drinker 
Biddle & Reath LLP, 1500 K Street, N.W., Washington, D.C. 20005-1209.  A copy of this Order and 
Consent Decree also shall be sent by First Class Mail to complainant’s counsel, Erwin G. Krasnow, 
Esquire, Garvey Schubert Barer, 1000 Potomac Street, N.W., Fifth Floor, Washington, D.C. 20007.
FEDERAL COMMUNICATIONS COMMISSION
Robert H. Ratcliffe
Acting Chief, Enforcement Bureau
  
4 See 47 U.S.C. §§ 154(i), 154(j), 503(b).  
5 See 47 C.F.R. §§ 0.111, 0.311.
Federal Communications Commission DA 13-2007
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
CSSI NON-PROFIT EDUCATIONAL 
BROADCASTING CORPORATION
Licensee of Noncommercial Educational FM 
Stations KYQX(FM), Weatherford, Texas,
KMQX(FM), Weatherford, Texas,
KEQX(FM), Stephenville, Texas,
KQXS(FM), Stephenville, Texas,
KSQX(FM), Springtown, Texas, and
KQXE(FM), Eastland, Texas
)
)
)
)
)
)
)
)
)
)
)
)
File No.:  EB-08-IH-1459 
NAL/Acct. No.:  201332080017
FRN No.:  0005813795
Facility ID No.:  62040
Facility ID No.:  89176
Facility ID No.:  89619
Facility ID No.:  89698
Facility ID No.:  62041
Facility ID No.:  89692
CONSENT DECREE
1. The Enforcement Bureau of the Federal Communications Commission and CSSI Non-
Profit Educational Broadcasting Corporation (CSSI), by their authorized representatives, enter into this 
Consent Decree for the purpose of terminating the Bureau’s investigation into whether CSSI violated a 
2007 Consent Decree,1 Section 399B of the Communications Act of 1934, as amended,2 and Sections 
73.503 and 73.3527 of the Commission’s rules,3 by broadcasting prohibited advertisements over Station 
KYQX(FM), Weatherford, Texas and by failing to make available and maintain complete public 
inspection files for its captioned stations.  
I.         DEFINITIONS
2. For the purposes of this Consent Decree, the following definitions shall apply:
(a) “Act” means the Communications Act of 1934, as amended, 47 U.S.C. § 151 et seq.
(b) “Adopting Order” means an Order of the Bureau adopting the terms of this Consent 
Decree without change, addition, deletion, or modification.
(c) “Bureau” means the Enforcement Bureau of the Federal Communications Commission.
(d) “Commission” and “FCC” mean the Federal Communications Commission and all of its 
bureaus and offices.
  
1 CSSI Non-Profit Educational Broadcasting Corporation, Order and Consent Decree, 22 FCC Rcd 3314 (Enf. Bur. 
2007) (2007 Consent Decree).  
2 47 U.S.C. § 399b.
3 47 C.F.R. §§ 73.503(d), 73.3527.
Federal Communications Commission DA 13-2007
2
(e) “Communications Laws” mean, collectively, the Act, the Rules, and published and 
promulgated orders and decisions of the Commission to which Licensee is subject by 
virtue of being a Commission licensee, including, but not limited to Sections 73.503(d) 
and 73.3527 of the Commission’s rules.
(f) “Compliance Officer” means the individual designated in Paragraph 11 of this Consent 
Decree as the person responsible for administration of the Compliance Plan.
(g) “Compliance Plan” means the compliance obligations, program, and procedures 
described in this Consent Decree at Paragraph 12.
(h) “Compliance Report” or “Compliance Reports” means the report(s) described in this 
Consent Decree at Paragraph 14.  
(i) “Complaint” means the third-party complaint4 received by, or in the possession of, the 
Commission or Bureau, as of the Effective Date, alleging violations of the Underwriting 
Laws and Public File Rule by the above-captioned stations.
(j) “2007 Consent Decree” means the Order and Consent Decree entered into by the 
Enforcement Bureau and CSSI Non-Profit Educational Broadcasting Corporation,
Licensee of Noncommercial Educational Stations KSQX(FM), Springtown, Texas, 
KMQX(FM), Weatherford, Texas, and KYQX(FM), Weatherford, Texas, on February 
15, 2007.5
(k) “Covered Employee” means all employees and agents of Licensee who perform, or 
supervise, oversee, or manage the performance of, duties related to Licensee’s 
responsibilities under the Public File Rule and/or the Underwriting Laws, including but 
not limited to, any Licensee employees with on-air duties or programming 
responsibilities.
(l) “Effective Date” means the date on which the Bureau releases the Adopting Order.
(m) “Investigation” means the investigation commenced by the Bureau’s October 28, 20096
and May 6, 2010 Letters of Inquiry7 regarding whether Licensee violated the 
Underwriting Laws in connection with its operation of Station KYQX(FM) on various 
  
4 Complaint of Graham Newspapers, Inc. (Jun. 13, 2008) (on file in EB-08-IH-1459).  At the time that the 
Complaint was filed, Graham was the licensee of Stations KSWA(AM) and KWKQ(FM), Graham, Texas, and 
Stations KLXK(FM) and KROO(AM), Breckenridge, Texas.  The licenses for these stations were subsequently 
assigned to a liquidating trust in connection with the bankruptcy of Graham’s parent company, Affiliated Media, 
Inc., File Nos. BAL-20100127ADA and BALH-20100127ADB, granted Feb. 24, 2010 and consummated Mar. 17, 
2010.  
5 See supra note 1.  
6 Letter from Kenneth M. Scheibel, Jr., Assistant Chief, Investigations and Hearings Division, FCC Enforcement 
Bureau, to CSSI Non-Profit Educational Broadcasting Corporation (Oct. 28, 2009) (on file in EB-08-IH-1459). 
7 Letter from Anjali K. Singh, Acting Assistant Division Chief, Investigations and Hearings Division, FCC 
Enforcement Bureau, to CCSI Non-Profit Educational Broadcasting Corporation (May 6, 2011) (on file in EB-08-
IH-1459). 
Federal Communications Commission DA 13-2007
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dates from December 1, 2007, through May 6, 2010, and Licensee’s compliance with the 
Public File Rule on various dates in 2008. 
(n) “Licensee” means CSSI Non-Profit Educational Broadcasting Corporation. 
(o) “NAL” means the Notice of Apparent Liability for Forfeiture issued by the Chief, 
Investigations and Hearings Division, to CSSI Non-Profit Educational Broadcasting 
Corporation, on March 25, 2013.8
(p) “Operating Procedures” means the standard, internal operating procedures and 
compliance policies established by Licensee to implement the Compliance Plan.
(q) “Parties” means Licensee and the Bureau, and each of which is a “Party.”
(r) “Public File Rule” means Section 73.3527 of the Rules.  
(s) “Rules” means the Commission’s regulations found in Title 47 of the Code of Federal 
Regulations.
(t) “Stations” means noncommercial educational radio Stations KYQX(FM), Weatherford, 
Texas, Facility ID No. 62040, KMQX(FM), Weatherford, Texas, Facility ID No. 89176, 
Station KEQX(FM), Stephenville, Texas, Facility ID No. 89619, KQXS(FM), 
Stephenville, Texas, Facility ID No. 89698, KSQX(FM), Springtown, Texas, Facility ID 
No. 62041, and KQXE(FM), Eastland, Texas, Facility ID No. 89692.
(u) “Underwriting Laws” means 47 U.S.C. § 399b and 47 C.F.R. § 73.503(d).
II. BACKGROUND
3. The Underwriting Laws define advertisements as program material broadcast “in 
exchange for any remuneration” and intended to “promote any service, facility, or product,” of for-profit 
entities.9 Section 399B(b)(2) specifically provides that noncommercial educational stations may not 
broadcast advertisements.10 Although contributors of funds to such stations may receive on-air 
acknowledgements of their support, the Commission has held that such acknowledgements may be made 
for identification purposes only, and should not promote the contributors’ products, services, or 
businesses.11 Specifically, such announcements may not contain comparative or qualitative descriptions, 
price information, calls to action, or inducements to buy, sell, rent, or lease.12 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 and is consistent with the Underwriting 
  
8 CSSI Non-Profit Educational Broadcasting Corporation, Notice of Apparent Liability for Forfeiture, 28 FCC Rcd 
3087 (Enf. Bur. 2013) (NAL).  
9 47 U.S.C. § 399b(a).    
10 47 U.S.C. § 399b(b)(2).
11 See Commission Policy Concerning the Noncommercial Nature of Educational Broadcasting Stations, Public 
Notice (1986), republished, 7 FCC Rcd 827 (1992) (1986 Public Notice).
12 See id.  
Federal Communications Commission DA 13-2007
4
Laws and decisions establishing compliant underwriting announcements.13 Consequently, the 
Commission expects licensees to exercise reasonable “good faith” judgment in this area, and affords some 
latitude to the judgments of licensees who do so.14 With regard to the Public File Rule, licensees must 
maintain files of documents specified by Commission rules and must make such files available for public 
inspection at any time during regular business hours.15
4. The Commission received a Complaint alleging, among other things, that CSSI violated 
the Underwriting Laws and the terms of the 2007 Consent Decree by airing a number of announcements 
on Station KYQX(FM) on March 12 and 13, 2008, that constituted advertisements.  In addition, the 
Complaint alleged that CSSI failed to adhere to the 2007 Consent Decree’s Compliance Plan 
requirements.16 The Complaint also alleged that CSSI violated its Public Inspection File obligations on 
June 6, 2008, by failing to make available the Stations’ six public files and to maintain in such files all 
documents as specified by Commission rules.17 In response, the Bureau issued Letters of Inquiry 
directing CSSI to submit, among other things, sworn written statements relating to its compliance with the 
Underwriting Laws, the Public File Rule, and the 2007 Consent Decree.18
5. CSSI responded on December 7, 2009, and June 11, 2010.19 In general, CSSI admits that 
it broadcast certain complained-of underwriting announcements over Station KYQX(FM) between March 
1, 2008, and April 30, 2010, and provided recordings and/or confirmed the accuracy of transcripts of the 
complained-of announcements submitted with the Complaint.20 CSSI argues, however, that the 
complained-of underwriting announcements did not violate the Underwriting Laws and that it did not 
violate the terms of the 2007 Consent Decree.  CSSI also contends that on June 6, 2008, it did not deny 
access to the Stations’ public files, and that the public files contained all required documents.21  
6. After conducting a comprehensive review and analysis of the record, the Bureau issued 
an NAL to CSSI, finding it apparently liable for the willful violation of the Public File Rule based on its 
failure to make available the Stations’ public inspection files on June 6, 2008.22 The NAL also 
specifically noted that the Bureau would address in a separate item the underwriting allegations, because 
  
13 See Xavier University, Memorandum Opinion and Order, 5 FCC Rcd 4920, 4921, para. 6 (1990) (citing 1986 
Public Notice).
14 See id.  
15 47 C.F.R. §§ 73.3527(a)(2), 73.3527(e), 73.3527(c)(1).    
16 See Complaint.   
17 See id.
18 See supra notes 6 & 7.   
19 Letter from Charles H. Beard, President, CSSI Non-Profit Educational Broadcasting Corporation to Marlene H. 
Dortch, Secretary, Federal Communications Commission (Dec. 7, 2009) (on file in EB-08-IH-1459); Erratum from 
Charles H. Beard, President, CSSI Non-Profit Educational Broadcasting Corporation to Marlene H. Dortch, 
Secretary, Federal Communications Commission (Dec. 11, 2009) (on file in EB-08-IH-1459); Letter from Charles 
H. Beard, President, CSSI Non-Profit Educational Broadcasting Corporation to Marlene H. Dortch, Secretary, 
Federal Communications Commission (June 11, 2010) (on file in EB-08-IH-1459) (LOI Responses).
20 LOI Responses.
21 Id.  
22 NAL, 28 FCC Rcd at 3087.  
Federal Communications Commission DA 13-2007
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those allegations concerned only Station KYQX(FM).23 Thereafter, the Parties agreed to enter this 
Consent Decree.  
III. TERMS OF AGREEMENT
7. Adopting Order.  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.
8. Jurisdiction.  Licensee agrees that the Bureau has jurisdiction over it and the matters 
contained in this Consent Decree and that the Bureau has the authority to enter into and adopt this 
Consent Decree.  
9. Effective Date; Violations; Termination of 2007 Consent Decree. The Parties agree 
that on the Effective Date as defined herein, this Consent Decree shall become effective and the 2007 
Consent Decree shall terminate.  As of the Effective Date, the Adopting Order and this Consent Decree 
shall have the same force and effect as any other order of the Commission.  Any violation of the Adopting 
Order or of the terms of this Consent Decree shall constitute a separate violation of a Commission order, 
entitling the Commission to exercise any rights and remedies attendant to the enforcement of a 
Commission order.
10. Termination of Investigation.  In express reliance on the covenants and representations 
in this Consent Decree and to avoid further expenditure of public resources, the Bureau agrees to 
terminate the Investigation.  In consideration for terminating the Investigation, Licensee agrees to the 
terms, conditions, and procedures contained herein.  The Bureau further agrees that, in the absence of 
material new evidence, the Bureau will not use the facts developed in the Investigation through the 
Effective Date, or the existence of this Consent Decree, to institute, on its own motion, any new 
proceeding, formal or informal, or take any action on its own motion against Licensee concerning the 
matters that were the subject of the Investigation.  The Bureau also agrees that it will not, in the absence 
of material new evidence, use the facts developed in the Investigation through the Effective Date, or the 
existence of this Consent Decree, to institute on its own motion any proceeding, formal or informal, or 
take any action on its own motion against Licensee with respect to Licensee’s basic qualifications, 
including its character qualifications, to be a Commission licensee or to hold Commission licenses or 
authorizations. 
11. Compliance Officer.  Within thirty (30) calendar days after the Effective Date, Licensee 
shall designate an individual to serve as its Compliance Officer, who shall be responsible for 
administering the Compliance Plan.  The Compliance Officer, if not an FCC regulatory counsel or in-
house counsel, shall be a senior corporate manager with the requisite corporate and organizational 
authority to serve as its Compliance Officer.  The Compliance Officer, if not an FCC regulatory counsel 
or in-house counsel, shall consult and be assisted by outside regulatory counsel and shall be responsible 
for developing, implementing, and administering a company-wide Compliance Plan and ensuring that 
Licensee complies with the terms and conditions of the Compliance Plan and this Consent Decree.  In 
addition to possessing the general knowledge of the Act and the Rules necessary to discharge his/her 
duties under this Consent Decree, the Compliance Officer shall have specific knowledge of the 
Underwriting Laws and Public File Rule before assuming his/her duties.    
  
23 Id. at 3087 n. 3.   
Federal Communications Commission DA 13-2007
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12. Compliance Plan.  For purposes of settling the matters set forth herein, Licensee agrees that 
it shall, within sixty (60) calendar days of the Effective Date, implement a company-wide Compliance 
Plan designed to prevent the broadcast of material in violation of the Underwriting Laws and ensure 
future compliance with the Public File Rule, the Communications Laws, and the terms and conditions of 
this Consent Decree.  The Compliance Plan shall include, at a minimum, the following components: 
a. Consultation with Counsel.  If the Compliance Officer is not an FCC regulatory counsel 
or in-house counsel, Licensee shall consult with outside FCC regulatory counsel 
regarding Licensee’s overall compliance with the Underwriting Laws and Public File 
Rule.  Such consultations shall occur on a biannual basis, if not more frequently.  
b. Operating Procedures.  Within sixty (60) calendar days after the Effective Date, 
Licensee shall establish Operating Procedures that all Covered Employees must follow to 
help ensure Licensee’s compliance with the Communications Laws, including the 
Underwriting Laws and the Public File Rule.  Licensee’s Operating Procedures shall 
include internal procedures and policies specifically designed to ensure that Licensee 
complies with the Underwriting Laws and the Public File Rule.  Licensee shall use a 
multi-level review procedure for underwriting content to be aired on the Stations.  The 
Compliance Officer, or a management-level employee of Licensee directly supervised by 
the Compliance Officer, shall review all scripts of underwriting announcements prior to 
broadcast.  Licensee shall develop an Underwriting Compliance Checklist that describes 
the steps that a Covered Employee must follow to ensure that all material approved for 
broadcast is consistent with relevant past Commission precedent regarding the 
Underwriting Laws.  Licensee also shall develop a Public Inspection File Compliance 
Checklist that describes the steps that a Covered Employee must follow to ensure 
compliance with the Public File Rule.  At a minimum, the Public Inspection File 
Compliance Checklist shall require Covered Employees to ensure that public inspection 
files of Licensee’s stations are available for inspection at any time during regular 
business hours and contain all documents required by the Public File Rule.    
c. Compliance Manual.  Within sixty (60) calendar days of the Effective Date, Licensee 
shall develop and distribute a Compliance Manual to all Covered Employees.  The 
Compliance Manual shall explain the Public File Rule and the Underwriting Laws and set 
forth the Operating Procedures that the Covered Employees shall follow to help ensure 
Licensee’s compliance with the Communications Laws, including the Underwriting Laws 
and the Public File Rule.  Licensee shall periodically review and revise the Compliance 
Manual as necessary to ensure the information set forth therein remains current and 
complete.  Licensee shall distribute any revisions to the Compliance Manual promptly to 
all Covered Employees.  
d. Compliance Training Program.  Within ninety (90) calendar days of the Effective Date, 
Licensee shall train any Covered Employee on the Operating Procedures, as well as 
acceptable underwriting content that complies with the Underwriting Laws, and 
compliance with the Public File Rule.  Licensee also shall train any new Covered 
Employee, within thirty (30) days of that employee’s becoming a Covered Employee, on 
the Operating Procedures, as well as acceptable underwriting content that complies with 
the Underwriting Laws, and compliance with the Public File Rule. As part of such 
training, Covered Employees shall be advised of Licensee’s obligation to report any 
noncompliance with the Underwriting Laws and Public File Rule under Paragraph 13 of 
this Consent Decree and shall be instructed on how to disclose noncompliance to the 
Federal Communications Commission DA 13-2007
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Compliance Officer.  In addition, Licensee shall conduct annual training regarding 
existing guidelines and, where applicable, pertinent changes to the Underwriting Laws 
and Public File Rule.  Licensee shall periodically review and revise the Compliance 
Training Program as necessary to ensure that it remains current and complete and to 
enhance its effectiveness.
e. Compliance Education Program.  Licensee shall implement and maintain a plan to 
educate prospective underwriters about appropriate underwriting content and about how 
Licensee incorporates such underwriting content in the announcements that it prepares 
for underwriter approval and eventual broadcast over the Stations.  To that end, Licensee 
shall summarize the Underwriting Laws for each prospective client before accepting any 
contract with a prospective client to air underwriting announcements over any of the 
Stations, and shall prepare the underwriting announcement for the underwriter’s review.  
Licensee shall not broadcast over any Station any announcement that does not comply 
with the Underwriting Rules.
13. Reporting Noncompliance.  Licensee shall report any instance of noncompliance with 
the Underwriting Laws and Public File Rule as reflected in the Communications Laws, relevant past 
Commission precedent and with the terms and conditions of this Consent Decree within thirty (30) 
calendar days after discovery of such noncompliance.  Such reports shall include a detailed explanation 
of:  (i) each instance of noncompliance; (ii) the steps that Licensee has taken or will take to remedy such 
noncompliance; (iii) the schedule on which such remedial actions will be taken; and (iv) the steps that 
Licensee has taken or will take to prevent the recurrence of any such noncompliance.  All reports of 
noncompliance shall be submitted to the Chief, Investigations and Hearings Division, Enforcement 
Bureau, Federal Communications Commission, Room 4-C330, 445 12th Street, S.W., Washington, D.C. 
20554, with a copy submitted electronically to Jeffrey J. Gee at Jeffrey.Gee@fcc.gov, Kenneth M. 
Scheibel, Jr. at Kenneth.Scheibel@fcc.gov, Dana E. Leavitt at Dana.Leavitt@fcc.gov, and Melanie 
Godschall at Melanie.Godschall@fcc.gov.  
14. Compliance Reports.  Licensee shall file Compliance Reports with the Commission 
ninety (90) days after the Effective Date, twelve (12) months after the Effective Date, twenty-four (24) 
months after the Effective Date, and thirty-six (36) months after the Effective Date. 
a. Each Compliance Report shall include a detailed description of Licensee’s efforts during 
the relevant period to comply with the terms and conditions of this Consent Decree, the 
Underwriting Laws, and the Public File Rule.  In addition, each Compliance Report shall 
include a certification by the Compliance Officer, as an agent and on behalf of Licensee, 
stating that the Compliance Officer has personal knowledge that Licensee (i) has 
established and implemented the Compliance Plan; (ii) has utilized the Operating 
Procedures since the implementation of the Compliance Plan, intended to ensure 
compliance with the terms and conditions of this Consent Decree, the Underwriting 
Laws, and the Public File Rule consistent with relevant past Commission precedent; and 
(iii) is not aware of any instances of noncompliance with the terms and conditions of this 
Consent Decree, including the reporting obligations set forth in Paragraph 13 hereof, the 
Underwriting Laws, and the Public File Rule.
Federal Communications Commission DA 13-2007
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b. The Compliance Officer’s certification shall be accompanied by a statement explaining 
the basis for such certification and must comply with Section 1.16 of the Rules24 and be 
subscribed to as true under penalty of perjury in substantially the form set forth therein. 
c. If the Compliance Officer cannot provide the requisite certification, the Compliance 
Officer, as an agent and on behalf of Licensee, shall provide the Commission with a 
detailed explanation of the reason(s) why and describe fully:  (i) each instance of 
noncompliance with this Consent Decree, the Underwriting Laws, and the Public File 
Rule; and (ii) the steps that Licensee has taken or will take to remedy such 
noncompliance, including the schedule on which proposed remedial actions will be taken; 
and (iii) the steps that Licensee has taken or will take to prevent the recurrence of any 
such noncompliance, including the schedule on which such preventive action will be 
taken. 
d. All Compliance Reports shall be submitted to the Chief, Investigations and Hearings 
Division, Enforcement Bureau, Federal Communications Commission, Room 4-C330, 
445 12th Street, S.W., Washington, D.C. 20554, with a copy submitted electronically to 
Jeffrey J. Gee at Jeffrey.Gee@fcc.gov, Kenneth M. Scheibel, Jr. at 
Kenneth.Scheibel@fcc.gov, Dana E. Leavitt at Dana.Leavitt@fcc.gov, and Melanie 
Godschall at Melanie.Godschall@fcc.gov.  
15. Termination Date.  Unless stated otherwise, the requirements set forth in Paragraphs 11 
through 14 of this Consent Decree shall expire thirty-six (36) months after the Effective Date.
16. Underwriting and  Public Inspection File Complaints; Subsequent Investigations.   
Except as set forth in Paragraph 10 of this Consent Decree, nothing in this Consent Decree shall prevent 
the Commission or its delegated authority from adjudicating complaints filed pursuant to the 
Underwriting Laws and the Public File Rule against Licensee or its affiliates for alleged violations of the 
Act or the Commission’s rules or for any other type of alleged misconduct, regardless of when such 
misconduct took place.  The Commission’s adjudication of any such complaints will be based solely on 
the record developed in that proceeding.  Except as expressly provided in this Consent Decree, this 
Consent Decree shall not prevent the Commission from investigating new evidence of noncompliance by 
Licensee with the Act or the Rules.  
17. Voluntary Contribution.  Licensee has provided sufficient evidence of financial 
hardship and agrees that it shall make a voluntary contribution to the United States Treasury in the 
amount of Four Thousand Five Hundred dollars ($4,500.00) in twelve (12) quarterly installments 
(“Installment Payments”), each in the amount of Three Hundred Seventy-Five Dollars ($375.00), with the 
first to be due thirty (30) days following the Effective Date and the remaining eleven (11) to be due on the 
first day of each third successive month.  Licensee acknowledges and agrees that upon execution of this 
Consent Decree, the Voluntary Contribution and each Installment Payment shall become a “Claim” or 
“Debt” as defined in 31 U.S.C. § 3701(b)(1).  Upon an Event of Default by Nonpayment (as described 
below in paragraph 18), all procedures for collection as permitted by law may, at the Commission’s 
discretion, be initiated.  In addition, Licensee agrees that it will make the first and all subsequent 
Installment Payments in United States Dollars without further demand or notice by the dates specified 
above.  Licensee shall also send electronic notification of payment to Jeffrey J. Gee at 
  
24 See 47 C.F.R. § 1.16.
Federal Communications Commission DA 13-2007
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Jeffrey.Gee@fcc.gov, Kenneth M. Scheibel, Jr. at Kenneth.Scheibel@fcc.gov, Dana E. Leavitt at 
Dana.Leavitt@fcc.gov, and Melanie Godschall at Melanie.Godschall@fcc.gov on the date said payment 
is made.  The payment must be made by check or similar instrument, wire transfer, or credit card, and 
must include the NAL/Account number and FRN referenced above.  Regardless of the form of payment, a 
completed FCC Form 159 (Remittance Advice) must be submitted.25 When completing the FCC Form 
159, Licensee shall 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 based on 
the form of payment selected:26
? 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 the 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 the 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.  If assistance is needed, Licensee shall contact the Financial Operations Group Help 
Desk by phone, 1-877-480-3201, or by e-mail, ARINQUIRIES@fcc.gov, for answers to 
questions regarding payment. 
18. Event of Default by Nonpayment.  Licensee agrees that an Event of Default by 
Nonpayment shall occur upon the failure by Licensee to pay the full amount of any Installment Payment 
on or before the due date specified in this Consent Decree.  
19. Interest, Charges for Collection, and Acceleration of Maturity Date.  Upon an Event 
of Default by Nonpayment under this Consent Decree, automatically and without further notice, the then 
entire unpaid amount of the Voluntary Contribution shall accrue interest computed using the U.S. Prime 
Rate in effect on the date of the Event of Default by Nonpayment plus 4.75 percent from the date of the 
Event of Default until payment in full.
20. Upon an Event of Default, the then unpaid amount of the Voluntary Contribution, 
together with interest, as aforesaid, any penalties permitted and/or required by the law, including but not 
limited to 31 U.S.C. § 3717 and administrative charge(s), plus the costs of collection, litigation, and 
attorneys’ fees, is accelerated and shall become immediately due and payable, without notice, 
presentment, demand, protest, or notice of protest of any kind, all of which are waived by Licensee.
  
25 An FCC Form 159 and detailed instructions for completing the form may be obtained at 
http://www.fcc.gov/Forms/Form159/159.pdf.
26 Should Licensee have questions regarding payment procedures, it should contact the Financial Operations Group 
Help Desk by phone at 1-877-480-3201, or by e-mail at ARINQUIRIES@fcc.gov.
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21. Waivers.  Licensee 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 the Bureau issues an Adopting Order as defined 
herein.  Licensee shall retain the right to challenge Commission interpretation of the Consent Decree or 
any terms contained herein. 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 Licensee nor the Commission shall 
contest the validity of the Consent Decree or the Adopting Order, and Licensee shall waive any statutory 
right to a trial de novo.  Licensee hereby agrees to waive any claims it may otherwise have under the 
Equal Access to Justice Act, 5 U.S.C. § 504 and 47 C.F.R. § 1.1501 et seq., relating to the matters 
addressed in this Consent Decree.
22. Severability.  The Parties agree that if any of the provisions of the Adopting Order or the 
Consent Decree shall be invalid or unenforceable, such invalidity or unenforceability shall not invalidate 
or render unenforceable the entire Adopting Order or Consent Decree, but rather the entire Adopting 
Order or Consent Decree shall be construed as if not containing the particular invalid or unenforceable 
provision or provisions, and the rights and obligations of the Parties shall be construed and enforced 
accordingly.  In the event that this Consent Decree in its entirety is rendered invalid by any court of 
competent jurisdiction, it shall become null and void and may not be used in any manner in any legal 
proceeding.  
23. Subsequent Rule or Order.  The Parties agree that if any provision of the Consent 
Decree conflicts with any subsequent rule or order adopted by the Commission (except an order 
specifically intended to revise the terms of this Consent Decree to which Licensee does not expressly 
consent) that provision will be superseded by such Commission rule or order.
24. Successors and Assigns.  Licensee agrees that the provisions of this Consent Decree 
shall be binding on its successors, assigns, and transferees.     
25. Admission of Liability.    Notwithstanding any of Licensee’s prior submissions in this 
proceeding, Licensee admits, for Commission civil enforcement purposes and in express reliance on the 
provisions of Paragraph 10 herein, that its actions with respect to the broadcast of certain underwriting 
announcements, as referenced in Paragraph 4 of this Consent Decree, violated the Underwriting Laws in 
force at the time of such actions, and that its actions on June 6, 2008, denied access to the Stations’ public 
files and thus violated the Public File Rule in force at the time of such actions.
26. Final Settlement.  The Parties agree and acknowledge that this Consent Decree shall 
constitute a final settlement between the Parties with respect to the Investigation and the NAL.
27. Modifications.  This Consent Decree cannot be modified without the advance written 
consent of both Parties.
28. Paragraph Headings.  The headings of the paragraphs in this Consent Decree are 
inserted for convenience only and are not intended to affect the meaning or interpretation of this Consent 
Decree.
29. Authorized Representative.  Each party represents and warrants to the other that it has 
full power and authority to enter into this Consent Decree.  The individual signing this Consent Decree on 
behalf of Licensee represents and warrants that he is authorized by Licensee to execute this Consent 
Decree and to bind Licensee to the obligations set forth herein.  The FCC signatory represents that he is 
signing this Consent Decree in his official capacity and that he is authorized to execute this Consent 
Decree.
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30. Counterparts.  This Consent Decree may be signed in any number of counterparts 
(including by facsimile), each of which, when executed and delivered, shall be an original, and all of 
which counterparts together shall constitute one and the same fully executed instrument.
________________________________
Robert H. Ratcliffe  
Acting Chief
Enforcement Bureau 
________________________________
Date
________________________________
Charles H. Beard
President
CSSI Non-Profit Educational Broadcasting Corporation