Federal Communications Commission DA 15-1172
Before the
Federal Communications Commission
Washington, D.C.  20554
In re Application of  
WLFA(FM), Asheville, North Carolina
For Consent to Assignment of License
from Asheville Educational Association, Inc., 
Assignor, to Radio Training Network, Inc., 
Assignee
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NAL/Acct. No. MB-201541410032
FRN: 0009306697
Facility ID No. 2922
File No. BALED-20150313AAW
ORDER
Adopted:  October 21, 2015 Released:   October 22, 2015
By the Chief, Media Bureau:
1. In this Order, we adopt the attached Consent Decree entered into by the Media Bureau
(“Bureau”), Asheville Educational Association, Inc., (“AEA”), and Radio Training Network, Inc. 
(“RTN”).  The Consent Decree resolves issues arising from the Bureau’s review of the captioned 
application, as amended,
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for Commission consent to the proposed assignment of license of Station
WLFA(FM), Asheville, North Carolina (the “Station”) from AEA to RTN (“Application”).  In particular, 
the Consent Decree resolves the Bureau’s investigation of the applicants’ compliance with Sections 
73.3540 and 73.503(c) of the Commission’s Rules (“Rules”) and Section 310 of the Communications Act 
of 1934, as amended (the “Act”).
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2. The Consent Decree stipulates that AEA violated Section 73.503(c) of the Rules, and that 
AEA and RTN violated Section 310 of the Act and Section 73.3540 of the Rules.
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  The Consent Decree 
also requires, among other things, that AEA and RTN will collectively make a ten thousand dollar 
($10,000) civil penalty payment to the United States Treasury.  A copy of the Consent Decree is attached 
hereto and incorporated by reference.  
3. After reviewing the terms of the Consent Decree, we find that the public interest will be 
served by its approval and by terminating all pending proceedings relating to the Bureau’s investigation 
of potential violations of the Rules and the Act in connection with the Application. 
                                                     
1
The Application was amended: 1) on April 29, 2015, to include an exhibit in support of RTN’s multiple ownership 
certification and a revised draft security agreement; and 2) on June 12, 2015, to notify that “the parties terminated 
the previously listed time brokerage agreement as of June 9, 2015. The Station has now been taken temporarily 
silent by the assignee (see File No. BLSTA-20150609AAR, granted July 1, 2015, with an expiration date of 
December 28, 2015, See Letter from Lisa Scanlan, Assistant Chief, Audio Division, Media Bureau to Asheville 
Educational Association, Inc., Ref. 1800B3-DW (MB Jul. 1, 2015)).  The assignee will return the Station to the air 
upon the approval and closing of this transaction.” Exhibit 1, Application, as amended June 12, 2015.    
2
47 U.S.C. §310.
3
46 C.F.R. § 73.3540.
Federal Communications Commission DA 15-1172
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4. Based on the record before us, we conclude that nothing in that record creates a 
substantial or material question of fact as to whether AEA or RTN possesses the basic qualifications to be 
a Commission licensee.
5. ACCORDINGLY, IT IS ORDERED that, pursuant to Section 4(i) of the 
Communications Act of 1934, as amended,
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and by the authority delegated by Sections 0.61 and 0.283 of 
the Rules,
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the Consent Decree attached hereto IS ADOPTED without change, addition, or modification.
6. IT IS FURTHER ORDERED that the investigation by the Media Bureau of the matters 
noted above IS TERMINATED.
7. IT IS FURTHER ORDERED that copies of this Order shall be sent, by First Class and 
Certified Mail, Return Receipt Requested, to Ms. Janice Brantley, Vice President, Asheville Educational 
Association, Inc., P.O. Box 3172, Asheville, North Carolina 28802, and to AEA’s counsel, John C. Trent, 
Esq., Putbrese Hunsaker & Trent, P.C., 200 South Church Street, Woodstock, Virginia 22664; and to Mr. 
James L. Campbell, President, Radio Training Network, Inc., P.O. Box 7217, Lakeland, Florida 33807, 
and to RTN’s counsel, A. Wray Fitch, III, Esq., Gammon & Grange, P.C., 8280 Greensboro Drive, 7
th
Floor, McLean, Virginia 22102.
FEDERAL COMMUNICATIONS COMMISSION
William T. Lake
Chief, Media Bureau
                                                     
4
47 U.S.C. § 4(i).
5
47 C.F.R. §§ 0.61, 0.283. 
Federal Communications Commission DA 15-1172
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CONSENT DECREE
I. Introduction
1. This Consent Decree is entered into by and between the Media Bureau of the Federal 
Communications Commission, Asheville Educational Association, Inc., licensee and proposed assignor of 
noncommercial educational FM Station WLFA(FM), Asheville, North Carolina (Facility ID No. 2922); 
and Radio Training Network, Inc., proposed assignee, for the purpose of terminating the Bureau’s 
Investigation concerning compliance with Sections 73.503(c) and 73.3540 of the Commission’s Rules, 47 
C.F.R. §§ 73.503(c), 73.3540, and Section 310 of the Communication Act of 1934, as amended, 47 
U.S.C. § 310.
II. Definitions
2. For 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 the order of the Bureau adopting this Consent Decree;
(c) “Application” means the FCC Form 314 application, as amended, for consent to 
assign the Station license from AEA to RTN (File No. BALED-20150313AAW);   
(d) “Bureau” means the Media Bureau of the Commission;
(e) “Commission” or “FCC” means the Federal Communications Commission;
(f) “Compliance Plan” means the compliance plan set forth in the Appendix hereto;
(g) “Effective Date” means the date on which the Bureau releases the Order;
(h) “Investigation” means the Bureau’s investigation of information contained in the 
Application;   
(i) “Licensee” or “AEA” refers to Asheville Educational Association, Inc.;
(j) “Parties” means AEA, RTN, and the Bureau;
(k) “RTN” means Radio Training Network, Inc., proposed assignee of the Station;
(l) “Rules” means the Commission’s Rules, found in Title 47 of the Code of Federal
Regulations;
(m) “Station” means Station WLFA(FM), Asheville, North Carolina (Facility ID. No. 
2922);  
(n) “TBA” means the time brokerage agreement executed on August 1, 2003, 
between AEA and RTN concerning the Station; and
Federal Communications Commission DA 15-1172
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(o) “Violations” means the payments AEA received pursuant to the TBA in violation 
of Section 73.503(c) of the Rules and the failure of AEA to retain complete 
control of Station operations subsequent to the implementation of the TBA in 
violation of Section 73.3540 of the Rules and Section 310(d) of the Act.
III. Background
3. Section 73.503(c) of the Rules provides that:
A noncommercial educational FM broadcast station may broadcast 
programs produced by, or at the expense of, or furnished by persons 
other than the licensee, if no other consideration than the furnishing of 
the program and the costs incidental to its production and broadcast are 
received by the licensee.  The payment of line charges by another station 
network, or someone other than the licensee on a noncommercial 
educational FM broadcast station, or general contributions to the 
operating costs of a station, shall not be considered as being prohibited 
by this paragraph.
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Time Brokerage Agreements are not precluded by any Commission rule or policy, so long as the 
ownership rules are not violated and the participating licensee maintains ultimate control over its 
facilities;
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the licensee maintains such control when it holds ultimate responsibility for essential station 
matters such as programming, personnel, and finances.
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4. Under the terms of the TBA, executed on August 1, 2003, AEA agreed to receive from 
RTN a series of escalating monthly payments that were unrelated to “costs incidental to its production and 
broadcast” in violation of Section 73.503(c) of the Rules.  Specifically, the TBA provided for an initial 
monthly payment of $6,750, for the first (2003) year of the TBA; which increased by five percent per 
annum in years two through five; in September 2008, after the start of license renewal term, the monthly 
payments increased to $8,614.89; and thereafter, increased by five per cent per annum in successive 
years.
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  In addition, the executed TBA effected an unauthorized transfer of control of the Station license 
in violation of Section 73.3540 of the Rules and Section 310 of the Act.  In particular, pursuant to the 
TBA, AEA improperly delegated core licensee responsibilities including the requirement to retain Station 
                                                     
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47 C.F.R § 73.503(c).
7
2002 Biennial Regulatory Review – Review of the Commission’s Broadcast Ownership Rules and Other Rules 
Adopted Pursuant to Section 202 of the Telecommunications Act of 1996, Report and Order and Notice of Proposed 
Rule Making, 18 FCC Rcd 13620, 13743 (2003) (subsequent history omitted).
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47 U.S.C. § 310(d); 47 C.F.R. § 73.3540(a).  See also Solar Broadcasting Co., Inc., Memorandum Opinion and 
Order, 17 FCC Rcd 5467, 5486 (2002) (“Although a licensee may delegate certain functions to an agent or 
employee on a day-to-day basis, ultimate responsibility for essential station matters, such as personnel, 
programming and finances, is nondelegable.”); Radio Moultrie, Inc., Order to Show Cause and Notice of 
Opportunity for Hearing, 17 FCC Rcd 24304, 24306-07 (2002) (stating that “the Commission looks not only to who 
executes the programming, personnel, and finance responsibilities, but also to who establishes the policies governing 
those three areas.”); Choctaw Broadcasting Corp., Memorandum Opinion and Order, 12 FCC 8534, 8538-39 (1997) 
(“[A] licensee involved in an LMA is not relieved of its responsibility to retain ultimate control.”). 
9
See TBA at 3 ¶ 3.1, Exhibit 17, Application, as amended on April 29, 2015.
Federal Communications Commission DA 15-1172
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employees at the main studio
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and the need to maintain and repair Station equipment.
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5. On March 13, 2015, AEA and RTN jointly filed the Application which included the 
TBA.  In response, the Commission staff commenced its Investigation of the TBA.  Subsequently, on 
June 9, 2015, AEA and RTN terminated the TBA
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and the Station went silent pursuant to a granted 
Special Temporary Authority request.
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6. Because of the compliance issues raised by the TBA, the Parties have negotiated this 
Consent Decree to terminate the Bureau’s Investigation.  
IV. Agreement
7. The Parties acknowledge that any proceedings that might result from the Violations
would be time-consuming and require a substantial expenditure of public and private resources.  In order 
to conserve such resources, resolve the matter, and promote the Station’s compliance with the Rules, the 
Parties are entering into this Consent Decree, in consideration of the mutual commitments made herein.
8. The Parties agree to be legally bound by the terms and conditions of this Consent Decree.  
AEA and RTN further agree that the Bureau has jurisdiction over the matters contained in this Consent 
Decree and the authority to enter into and adopt this Consent Decree.
9. The Parties agree that this Consent Decree shall become effective on the Effective Date 
as defined herein.  Upon the Effective Date, the Adopting Order and this Consent Decree shall have the 
same force and effect as any other order of the Commission.  AEA and RTN 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 either AEA or RTN fails to satisfy any 
condition or Commission Rule, in the absence of Commission alteration of the condition or Rule, AEA or 
RTN will be deemed noncompliant and may be subject to possible enforcement action, including, but not 
limited to, revocation of the relief, designation of the matter for hearing, letters of admonishment and/or 
forfeitures.  Any violation of the Adopting Order or 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 enforcement of a Commission order.
10. 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 the termination of the Investigation, AEA and RTN agree to the terms, conditions, and 
procedures contained herein.  The Bureau further agrees that, in the absence of new material evidence, it 
will not use the Violations in any action against AEA and RTN, provided that AEA and RTN satisfies all 
of its obligations under this Consent Decree.  In the event that either AEA or RTN fails to satisfy any of 
                                                     
10
Id. at 2 ¶ 2.3.  A licensee is required to staff its main studio with at least two employees, one of whom must be 
managerial.  See 47 C.F.R. § 73.1125, as interpreted by Jones Easter of the Outer Banks, Inc., Memorandum 
Opinion and Order, 6 FCC Rcd 2615 (1991), clarified, Memorandum Opinion and Order, 7 FCC Rcd 6800 (1992).  
This staffing requirement applies even when the station is operated pursuant to a TBA.  See, e.g., KRLI, Malta Bend, 
Missouri, Letter, 14 FCC 17731, 17734 (MMB 1999).       
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Id. at 3 ¶ 2.4.
12
See Application, as amended on June 12, 2015.
13
See File No. BLSTA-20150609AAR, granted on July 1, 2015.  See Letter from Lisa Scanlan, Assistant Chief, 
Audio Division, Media Bureau to Asheville Educational Association, Inc., Ref. 1800B3-DW (MB Jul. 1, 2015).
Federal Communications Commission DA 15-1172
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its obligations under this Consent Decree, the Bureau may take any enforcement action available pursuant 
to the Act and the Rules with respect to each Violation, and/or the violation of this Consent Decree.
11. AEA stipulates that it violated Section 73.503(c) of the Rules by accepting the TBA fees.  
In addition, AEA and RTN stipulate that each violated Section 310(d) of the Act and Section 73.3540 of 
the Rules by allowing RTN to assume control of the Station without prior Commission authorization.  
12. AEA and RTN agree to collectively pay a civil penalty to the United States Treasury in 
the amount of Ten Thousand Dollars ($10,000), within thirty (30) calendar days after the Effective Date.  
Licensee will also send electronic notification of payment to Kim Varner at Kim.Varner@fcc.gov and 
Michael Wagner at Michael Wagner@fcc.gov on the date said payment is made.  Such payment will be 
made, without further protest or recourse to a trial de novo, by a check or similar instrument, wire transfer 
or credit card and must include the Account Number and FRN referenced in the caption to the Order.  
Regardless of the form of payment, a completed FCC Form 159 (Remittance Advice) must be
submitted.
  
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.
13. The Bureau finds that its Investigation raises no substantial and material questions of fact 
as to whether AEA or RTN possesses the basic qualifications, including those relating to character, to 
hold or obtain a Commission license or authorization. Accordingly, the Bureau agrees to grant the 
Application, after the Effective Date, provided that the following conditions have been met: 1) the civil 
penalty payment, referenced in paragraph 12 of this Decree, has been fully and timely satisfied; and 2) 
there are no issues other than the Violations that would preclude grant of the Application. 
14. Licensee agrees that it will abide by the Compliance Plan set forth in the Appendix 
hereto.  Licensee further agrees, to the extent that it has not already done so, to implement the
Compliance Plan at the Station no later than thirty (30) days after the Effective Date and to keep such 
Compliance Plan in effect for three (3) years after the Effective Date.
15. AEA and RTN each agree to waive any and all rights it may have to seek administrative 
or judicial reconsideration, review, appeal, or stay, or to otherwise challenge the validity of this Consent 
Decree and the Adopting Order, provided the Consent Decree is adopted without change, addition or 
Federal Communications Commission DA 15-1172
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modification.  If any Party (or the United States on behalf of the Commission), brings a judicial action to 
enforce the terms of the Consent Decree or Adopting Order, no Party will contest the validity of the 
Consent Decree or Adopting Order, and AEA and RTN will waive any statutory right to a trial de novo.  
AEA and RTN each further agree to waive any claims it may otherwise have under the Equal Access to 
Justice Act, 5 U.S.C. Section 504 and 47 C.F.R. Section 1.1501 et seq., relating to the matters herein.
16. The Parties agree that if a court of competent jurisdiction renders any of the provisions of 
this Consent Decree invalid or unenforceable, such invalidity or unenforceability shall not invalidate or 
render unenforceable the Consent Decree, but rather the entire 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 will become null and void and may 
not be used in any manner in any legal proceeding.
17. The Parties agree that if any provision of this 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), such provision will be 
superseded by such Commission rule or order.
18. The Consent Decree will be binding on Licensee’s successors-in-interest and assigns.   
Licensee agrees that any future application to assign or transfer control of the Station will include a 
statement executed by an authorized representative of the proposed assignee or transferee consenting to 
assumption of the responsibilities and duties set forth in this Consent Decree with regard to the Station.
19. The Parties agree and acknowledge that this Consent Decree shall constitute a final 
settlement between AEA, RTN and the Bureau concerning the Violations discussed herein.
20. This Consent Decree cannot be modified or amended without the advance written consent 
of all Parties.
21. Each Party represents and warrants to the other Party that it has full power and authority 
to enter into this Consent Decree.  Each person signing this Consent Decree on behalf of a Party hereby 
represents that he or she is fully authorized by the Party to execute this Consent Decree and to bind the 
Party to its terms and conditions.
22. This Consent Decree may be signed in counterparts and/or by telecopy and, when so 
executed, the counterparts, taken together, will constitute a legally binding and enforceable instrument 
whether executed by telecopy or by original signatures.
MEDIA BUREAU
FEDERAL COMMUNICATIONS COMMISSION
By:  ____________________________________
       William T. Lake, Chief 
Date:  __________________________________
Federal Communications Commission DA 15-1172
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ASHEVILLE EDUCATIONAL ASSOCIATION, 
INC.
By: _________________________________________
       Janice Brantley, Vice President, Asheville
       Educational Association, Inc.      
Date:  __________________________________
RADIO TRAINING NETWORK, INC.
By: _________________________________________
       James L. Campbell, President, Radio Training
       Network, Inc.
          
Date:  __________________________________
Federal Communications Commission DA 15-1172
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APPENDIX
COMPLIANCE PLAN FOR STATION WLFA(FM)
Within 30 days of the resumption of operation by the Station from the silent authority approved in 
BLSTA-20150609AAR, the licensee, including the current licensee AEA and any successor-in-interest 
licensee(s), of Station WLFA(FM) will institute the following procedures with regard to the Station to 
ensure compliance with the Commission’s Rules and the Communications Act of 1934, as amended.  
Unless otherwise provided, all terms defined in the Consent Decree apply to this Compliance Plan.
1. Licensee will conduct training for all Station employees and management on compliance 
with FCC Rules applicable to Station operations.  It will designate its Station Manager as a Compliance 
Officer responsible for responding to Station employee questions and consulting with outside counsel 
familiar with Communications law regarding compliance matters.  Licensee will conduct refresher 
training for Station employees and management at least once every twelve (12) months, and will train any 
new Station employee within five (5) business days of commencement of his or her duties at the Station. 
2. Licensee will engage FCC Counsel on an ongoing basis to provide guidance on FCC 
compliance issues, regular updates, and notices on developments in communications law applicable to the 
Station and the Station’s operations, and to review applications and reports prior to filing with the FCC.  
In regard to the last matter, Licensee recognizes and acknowledges that any and all information provided 
to the FCC must completely and candidly set forth all relevant facts and circumstances, regardless of 
whether such submission may disclose a violation of the Act or Rules.
3. Licensee will maintain control of the programming, personnel, and finances of the Station 
and shall provide an affidavit or declaration to the Bureau, signed by Licensee’s president, certifying that, 
since the commencement of this Compliance Plan or the filing of the last such report, if any, the Station
has maintained such control and is in compliance with the Consent Decree, on or before December 31 
(but no earlier than December 1) of each year of the three-year term of this Compliance Plan as provided 
in Paragraph 14 of the accompanying Consent Decree.  In the event that Licensee is unable to so certify, it 
will disclose the reasons therefore and indicate what steps it has taken to render its operation of the 
Station in compliance with the Act, the Rules, and FCC Policy.