Federal Communications Commission DA 16-861
1
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
SOO LINE CORPORATION
Parent Company of Various Subsidiary 
Companies d/b/a Canadian Pacific
Holding Various Authorizations in the Wireless 
Radio Services
)
)
)
)
)
)
)
File No.:  EB-IHD-15-00019370
Acct. No.:  201632080008
FRN:  0021842406
ORDER
Adopted:  August 15, 2016, Released:  August, 15, 2016
By the Chief, Enforcement Bureau:
1. The Enforcement Bureau (Bureau) of the Federal Communications Commission 
(Commission) has resolved its investigation into whether Soo Line Corporation (CP) acquired wireless 
radio licenses without Commission approval and constructed, operated, modified, and relocated wireless 
radio stations absent any Commission authorization.  We take this action as part of our obligation to 
prevent unlicensed radio operations from potentially interfering with licensed radio communications in 
the United States, facilitate the efficient administration of wireless radio authorizations, and stop the 
unauthorized transfer of radio authorizations to a potentially unqualified party or in a manner that might 
otherwise be inconsistent with the public interest.  For a number of years CP has operated more than a 
hundred unauthorized radio facilities to monitor and support its railroad operations.  Some of these 
unauthorized operations date back a substantial period of time, and continued unabated until 2015.  In 
addition, CP failed to obtain Commission consent before acquiring ownership and control of more than 
thirty radio authorizations.  CP acknowledges that the scope and duration of its violations are substantial.  
To resolve the Bureau's investigation, the Company will pay a civil penalty of $1,210,000, maintain 
internal compliance procedures the Company instituted prior to the investigation, and implement a three-
year compliance plan with additional compliance reporting obligations.  
2. After reviewing the terms of the Consent Decree and evaluating the facts before us, we 
find that the public interest would be served by adopting the Consent Decree and terminating the 
referenced investigation regarding CP’s compliance with Section 310(d) of the Communications Act of 
1934, as amended,
1
and Section 1.948 of the Commission’s rules,
2
pertaining to unauthorized transfers of 
control and assignments of licenses; and Section 301 of the Act
3
and Section 1.903 of the Rules,
4
pertaining to unauthorized operation of stations and station equipment.
3. In the absence of material new evidence relating to this matter, we do not set for hearing 
the question of CP’s basic qualifications to hold or obtain any Commission license or authorization.
5
                                                     
1
47 U.S.C. § 310(d).
2
47 CFR § 1.948.
3
47 U.S.C. § 301.
4
47 CFR § 1.903.
5
See 47 CFR § 1.93(b).
Federal Communications Commission DA 16-861
2
4. Accordingly, IT IS ORDERED that, pursuant to Section 4(i) of the Act
6
and the 
authority delegated by Sections 0.111 and 0.311 of the Rules,
7
the attached Consent Decree IS 
ADOPTED and its terms incorporated by reference.
5. IT IS FURTHER ORDERED that the above-captioned matter IS TERMINATED in 
accordance with the terms of the attached Consent Decree
6. 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 William M. Tuttle, Vice President 
Corporate, Canadian Pacific, 7550 Ogden Dale Road S.E., Calgary, AB T2C 4X9
Canada, and to T.J. Litwiler, Esq., Fletcher & Sippel, LLC, 29 North Wacker Drive, Chicago, Illinois  
60606-2832.
FEDERAL COMMUNICATIONS COMMISSION
Travis LeBlanc
Chief
Enforcement Bureau
                                                     
6
47 U.S.C. § 154(i).
7
47 CFR §§ 0.111, 0.311.
                                                    Federal Communications Commission                          DA 16-861
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of
SOO LINE CORPORATION
Parent Company of Various Subsidiary 
Companies d/b/a Canadian Pacific
Holding Various Authorizations in the Wireless 
Radio Services
)
)
)
)
)
)
)
File No.:  EB-IHD-15-00019370
Acct. No.:  201632080008
FRN:  0021842406
CONSENT DECREE
1. The Enforcement Bureau of the Federal Communications Commission and Soo Line 
Corporation (CP), by their authorized representatives, hereby enter into this Consent Decree for the 
purpose of terminating the Enforcement Bureau’s investigation into whether the Company’s subsidiaries 
violated Section 310(d) of the Communications Act of 1934, as amended,
1
and Section 1.948 of the 
Commission’s rules,
2
pertaining to unauthorized transfers of control and assignments of licenses in 
connection with the acquisition of two American railroad lines that held authorizations for wireless radio 
services; and Section 301 of the Act
3
and Section 1.903 of the Rules,
4
pertaining to unauthorized 
operation of stations and station equipment. 
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.  
(e) “Communications Laws” means, collectively, the Act, the Rules, and the published 
and promulgated orders and decisions of the Commission to which CP is subject by 
virtue of its business activities, including but not limited to the wireless radio service 
Rules.
(f) “CP” or “Company” means Soo Line Corporation, its U.S. subsidiaries, affiliates, 
predecessors-in-interest, and successors-in-interest, and, where relevant, its indirect, 
intermediate parent Canadian Pacific Railway Company.
(g) “Compliance Plan” means the compliance obligations, program, and procedures 
described in this Consent Decree at paragraph 14.  
                                                     
1
47 U.S.C. § 310(d).
2
47 CFR § 1.948.
3
47 U.S.C. § 301.
4
47 CFR § 1.903.
                                                    Federal Communications Commission                          DA 16-861
2
(h) “Covered Employees” means all employees and agents of the Company who 
perform, supervise, oversee, or manage the performance of duties that relate to CP’s 
responsibilities under the Communications Laws, including Sections 310(d) and 301 
of the Act, and Sections 1.948 and 1.903 of the Rules.
(i) “Effective Date” means the date by which the Bureau and CP have signed the 
Consent Decree.  
(j) “Investigation” means the investigation commenced by the Bureau in File No. EB-
IHD-15-00019370 regarding whether CP violated  provisions of the Communication 
Laws relating to unauthorized transfer and operations of stations and station 
equipment. 
(k) “Operating Procedures” means the standard, internal operating procedures and 
compliance policies established by CP to implement the Compliance Plan.  
(l) “Parties” means CP and the Bureau, each of which is a “Party.” 
(m) “Rules” means the Commission’s regulations found in Title 47 of the Code of 
Federal Regulations.
(n) “Unauthorized Transfer and Operations Rules” means Section 310(d) of the 
Communications Act of 1934, as amended,
5
and Section 1.948 of the Commission’s 
rules,
6
pertaining to unauthorized transfers of control and assignments of licenses; 
and Section 301 of the Act
7
and Section 1.903 of the Rules,
8
and other provisions of 
the Act, the Rules, and Commission orders related to the wireless radio services. 
II. BACKGROUND
3. Section 310(d) of the Act states that “[n]o construction permit or station license, or any 
rights thereunder, shall be transferred, assigned, or disposed of in any manner, voluntarily or 
involuntarily, directly or indirectly, or by transfer of control of any corporation holding such permit or 
license, to any person except upon application to the Commission and upon finding by the Commission 
that the public interest, convenience, and necessity will be served thereby.”
9
  Section 1.948 of the Rules 
similarly requires Commission consent prior to a transfer of control or assignment of license.
10
  In 
addition, Section 301 of the Act and Section 1.903(a) of the Rules prohibit the use or operation of any 
radio transmitting equipment within the United States, except under and in accordance with the Act and 
with a Commission-granted authorization.
11
    
4. Canadian Pacific Railway Company (CPR) is a major North American rail carrier, 
headquartered in Calgary, Alberta, which, with its U.S. subsidiaries, operates approximately 14,000 route 
miles of track across Canada and the upper Midwestern and northeastern United States.  Originally built 
between 1881 and 1885, it was Canada's first transcontinental railway.
12
The parent holding company, 
Canadian Pacific Railway Limited (CPRL), is a publicly-traded Canadian company whose stock is listed 
on the Toronto and New York stock exchanges.  CPRL controls CPR, a Canadian company which 
                                                     
5
47 U.S.C. § 310(d).
6
47 CFR § 1.948.
7
47 U.S.C. § 301.
8
47 CFR § 1.903.
9
47 U.S.C. § 310(d).
10
47 CFR § 1.948.
11
47 U.S.C. § 301, 47 CFR § 1.903(a).
12
See http://www.cpr.ca/en/about-cp/our-history.
                                                    Federal Communications Commission                          DA 16-861
3
conducts rail operations in Canada.  CPRL also controls (through CPR and several wholly-owned 
intermediate holding companies) Soo Line Corporation, which is the holding company for CP's three U.S. 
rail operating subsidiaries: Soo Line Railroad Company (Soo), Dakota, Minnesota & Eastern Railroad 
Corporation (DM&E), and Delaware & Hudson Railway Company, Inc. (D&H).
13
  For railroad regulatory 
purposes, those three subsidiaries report to the U.S. Surface Transportation Board on a consolidated basis 
under the Soo Line Corporation name.
14
5. On October 30, 2008, the Company acquired two American railroad lines: DM&E and 
Iowa, Chicago & Eastern Railroad Corporation (IC&E), a wholly owned indirect subsidiary of DM&E, 
both of which held FCC authorizations in the wireless radio services.
15
  Radio transmitting devices are
widely used in the railroad industry for voice and data transmissions related to the safe operation of 
freight and passenger trains. In 2015, CP discovered that in the course of these transactions, it had 
acquired control of various wireless radio devices utilized by these smaller railroads in the wireless radio 
services without prior Commission consent.
16
  The Company commenced a comprehensive internal audit 
of all of its FCC authorizations, and voluntarily disclosed its violations to the Commission.
17
  The Bureau 
then commenced its Investigation of CP’s compliance with applicable provisions of the Act and Rules 
related to the transfer and operation of wireless radio services authorized by the FCC.
6. The Investigation revealed that CP consummated two substantial and one pro forma 
transactions,
18
involving more than thirty wireless radio licenses, without having obtained prior 
Commission consent.
19
The substantial unauthorized transactions dated back to 2008, and a further pro 
forma transaction occurred two months after CP acquired control of the railroads.
20
Both DM&E and 
IC&E were FCC licensees, and no transfer of control authority was sought from the FCC at the time of 
the substantial October 30, 2008 transaction, or the subsequent pro forma transaction.
21
  The Investigation 
also revealed that CP had constructed, relocated, modified, and/or operated more than a hundred wireless 
facilities without approval from the FCC.
22
  The earliest of the unauthorized radio operations dated back 
                                                     
13
See Letter from Thomas J. Litwiler, counsel for CP, to Gary Oshinsky, Attorney Advisor, FCC Enforcement 
Bureau at 1 (Jan. 14, 2016) (on file in EB-IHD-15-00019370) (Letter); E-mail from Thomas J. Litwiler, counsel for 
CP, to Jeffrey Tobias, Attorney Advisor, FCC Wireless Telecommunications Bureau (June 8, 2015) (on file in EB-
IHD-15-00019370) (June 8, 2015 E-mail).
14
FCC wireless radio authorizations for Soo are held by its licensee subsidiary Soo System Radio Communications 
Corporation.  See Letter at 1; June 8, 2015 E-mail.  DM&E and D&H each hold FCC wireless radio authorizations 
in their own names.
15
See Letter at 2.  
16
Both the substantial and pro forma transactions also involved wireless radio transmitters that had never been 
licensed by the FCC.  See id.
17
See June 8, 2015 E-mail.  In the context of the Positive Train Control implementation by Congress, the Company 
previously entered a Memorandum of Understanding with the FCC involving the implementation of compliance 
procedures which required, inter alia, the appointment of an official compliance Officer, and creation of a 
compliance manual.  Id.
18
Substantial transfers involve the transfer of license ownership, while pro forma transfers involve only the transfer 
of control of licenses.  See 47 U.S.C. § 310(d); 47 CFR § 1.948.
19
See Letter at 1.
20
See June 8, 2015 E-mail.  On December 31, 2008, IC&E was merged into DM&E, with DM&E as the surviving 
corporation.  Id.
21
See June 8, 2015 E-mail.  DM&E held 16 FCC licenses at the time of the transaction (all “Industrial/Business 
Pool” licenses), of which seven remain in active use today. IC&E held 15 FCC licenses at the time of the 
transaction (14 Industrial/Business Pool licenses and one “Location Narrowband” license), of which all remain 
active today.  Id.
22
See id.; see also Letter, Attachment at 1-12.
                                                    Federal Communications Commission                          DA 16-861
4
to 1979.  All of the unauthorized operations continued unabated until 2015, when the Commission’s 
Wireless Telecommunications Bureau granted CP’s multiple applications for remedial authorization.
23
  
7. The Investigation did not reveal any evidence of complaints about interference from CP’s 
unauthorized operations, and the Company indicates that the radio facilities it constructed, relocated, 
modified, and operated without Commission authorization were at all times intended to enhance the 
safety of its rail system.
24
CP reported its violations upon discovery, and the Company acknowledges that 
the scope and duration of its noncompliance was substantial.  To resolve the Bureau’s Investigation, the 
Parties now enter this Consent Decree to ensure CP’s future compliance with all applicable 
Communications Laws. 
III. TERMS OF AGREEMENT
8. Adopting Order.  The provisions of this Consent Decree shall be incorporated by the 
Bureau in an Adopting Order.
9. Jurisdiction.  The Company 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.
10. Effective Date.  The Parties agree that this Consent Decree shall become effective on the 
Effective Date as defined herein.  As of the Effective Date, the Parties agree that this Consent Decree 
shall have the same force and effect as any other order of the Commission.  
11. 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 the termination of the Investigation, the Company agrees 
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 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 the Company concerning the matters that were 
the subject of the Investigation.
25
  The Bureau also agrees that, in the absence of new material evidence, it 
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 proceeding, formal or informal, or to set for hearing 
the question of the Company’s basic qualifications to be a Commission licensee or hold Commission 
licenses or authorizations.
26
12. Admission of Liability.  CP admits, solely for the purpose of this Consent Decree and 
for Commission civil enforcement purposes, and in express reliance on the provisions of paragraph 11
herein, that its actions described in paragraphs 4 through 7 of this Consent Decree violated Sections 
310(d) and 301 of the Act, and Sections 1.948 and 1.903 of the Rules.  
13. Compliance Officer.  Within thirty (30) calendar days after the Effective Date, to the 
extent it has not already done so under its current compliance procedures, the Company shall designate a 
senior corporate manager with the requisite corporate and organizational authority to serve as a 
                                                     
23
See Letter at 2.  A number of unauthorized devices controlled by CP’s D&H subsidiary were ultimately licensed 
by Norfolk Southern Railway Company, as part of a previously scheduled transaction. Id. 
24
CP indicates that it uses its radio facilities to, among other things, support dispatch operations and intra-yard 
communications, detect defects on rail cars, monitor the location of rail cars, and detect and change the position of 
tracks. See June 8, 2015 E-mail. 
25
The Parties understand and agree, that future, isolated, instances of unauthorized operations, which pre-date this 
Consent Decree, but which are discovered after the Effective Date, will be considered covered by the terms herein 
including under paragraphs 17 and 18. 
26
See 47 CFR § 1.93(b).
                                                    Federal Communications Commission                          DA 16-861
5
Compliance Officer and to discharge the duties set forth below.  The person designated as the Compliance 
Officer shall be responsible for developing, implementing, and administering the Compliance Plan and 
ensuring that the Company complies with the terms and conditions of the Compliance Plan and this 
Consent Decree.  In addition to the general knowledge of the Communications Laws necessary to 
discharge his/her duties under this Consent Decree, the Compliance Officer shall have specific knowledge 
of Sections 310(d) and 301 of the Act, and Sections 1.948 and 1.903 of the Rules prior to assuming 
his/her duties. 
14. Compliance Plan.  The Bureau recognizes that on May 16, 2014, the Company 
implemented, and has since maintained, comprehensive compliance procedures, under which it has 
engaged in compliance reporting to the FCC.
27
  For purposes of settling the matters set forth herein, the 
Company agrees that it shall continue to maintain its existing compliance procedures.  In addition, within 
ninety (90) calendar days after the Effective Date, the Company shall develop and implement the 
measures described below, if not already in place, to ensure future compliance with the Communications 
Laws and with the terms and conditions of this Consent Decree.  With respect to Sections 310(d) and 301 
of the Act and Sections 1.948 and 1.903 of the Rules, the Company will implement, at a minimum, the 
following procedures:
(a) Operating Procedures.  Within sixty (60) calendar days after the Effective Date, 
the Company shall establish Operating Procedures that all Covered Employees shall 
follow to help ensure the Company’s compliance with Sections 310(d) and 301 of 
the Act and Sections 1.948 and 1.903 of the Rules.  The Company’s Operating 
Procedures shall include internal procedures and policies specifically designed to 
ensure that the Company complies with Sections 310(d) and 301 of the Act and 
Sections 1.948 and 1.903 of the Rules. The Company shall also develop a 
Compliance Checklist that describes the steps that a Covered Employee must follow 
to ensure compliance with Sections 310(d) and 301 of the Act and Sections 1.948 
and 1.903 of the Rules.
(b) Compliance Manual.  Within ninety (90) calendar days after the Effective Date, the 
Compliance Officer shall develop and distribute a Compliance Manual to all 
Covered Employees.  The Compliance Manual shall explain the Communications 
Laws that apply to the Company, including Sections 310(d) and 301 of the Act and 
Sections 1.948 and 1.903 of the Rules, and set forth the Operating Procedures that 
Covered Employees shall follow to help ensure the Company’s compliance with 
Sections 310(d) and 301 of the Act and Sections 1.948 and 1.903 of the Rules.  The 
Company shall periodically review and revise the Compliance Manual as necessary 
to ensure that the information set forth therein remains current and accurate.  The 
Company shall distribute any revisions to the Compliance Manual promptly to all
Covered Employees.  
(c) Compliance Training Program.  The Company shall establish and implement a 
Compliance Training Program on compliance with the Communications Laws, 
including Sections 310(d) and 301 of the Act and Sections 1.948 and 1.903 of the 
Rules, and the Operating Procedures.  As part of the Compliance Training Program, 
Covered Employees shall be advised of the Company’s obligation to report any 
noncompliance with Sections 310(d) and 301 of the Act and Sections 1.948 and 
1.903 of the Rules under paragraph 15 of this Consent Decree and shall be 
instructed on how to disclose noncompliance to the Compliance Officer.  All 
Covered Employees shall be trained pursuant to the Compliance Training Program 
                                                     
27
See June 8, 2015 E-mail; Letter, Certification. As an initial step in the implementation of its compliance effort, CP 
designated William M. Tuttle, CP’s General Counsel U.S., to serve as the Company’s Compliance Officer to review 
and oversee all of its FCC licensing matters.  Id.
                                                    Federal Communications Commission                          DA 16-861
6
within one hundred twenty (120) calendar days after the Effective Date except that
any person who becomes a Covered Employee at any time after the initial 
Compliance Training Program shall be trained within thirty (30) calendar days after 
the date such person becomes a Covered Employee.  The Company shall repeat 
compliance training on an annual basis, and shall periodically review and revise the 
Compliance Training Program as necessary to ensure that it remains current and 
complete and to enhance its effectiveness. 
15. Reporting Noncompliance.  The Company shall report any noncompliance with 
Sections 310(d) and 301 of the Act and Sections 1.948 and 1.903 of the Rules and with the terms and 
conditions of this Consent Decree within fifteen (15) calendar days after discovery of such 
noncompliance.  Such reports shall include a detailed explanation of: (i) each instance of noncompliance; 
(ii) the steps that the Company 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 the Company has taken or will take to 
prevent the recurrence of any such noncompliance.  All reports of noncompliance shall be submitted to 
the Chief, Investigations & Hearings Division, Enforcement Bureau, Federal Communications 
Commission, Room 4-C330, 445 12th Street, SW, Washington, DC 20554, with a copy submitted 
electronically to Jeffrey J. Gee at Jeffrey.Gee@fcc.gov, and Gary Oshinsky at Gary.Oshinsky@fcc.gov.  
16. Compliance Reports.  The Company shall file Compliance Reports with the 
Commission one hundred twenty (120) calendar 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 the Company’s
efforts during the relevant period to comply with the terms and conditions of this 
Consent Decree, Sections 310(d) and 301 of the Act, and Sections 1.948 and 1.903 
of the Rules.  In addition, each Compliance Report shall include a certification by 
the Compliance Officer, as an agent of and on behalf of the Company, stating that 
the Compliance Officer has personal knowledge that the Company: (i) has
established and implemented the Compliance Plan; (ii) has utilized the Operating 
Procedures since the implementation of the Compliance Plan; 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 15 of this Consent 
Decree.
(b) The Compliance Officer’s certification shall be accompanied by a statement 
explaining the basis for such certification and shall comply with Section 1.16 of the 
Rules and be subscribed to as true under penalty of perjury in substantially the form 
set forth therein.
28
(c) If the Compliance Officer cannot provide the requisite certification, the Compliance 
Officer, as an agent of and on behalf of the Company, shall provide the Commission 
with a detailed explanation of the reason(s) why and describe fully: (i) each 
instance of noncompliance; (ii) the steps that the Company 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 the Company 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 & Hearings 
Division, Enforcement Bureau, Federal Communications Commission, Room 4-
-C330, 445 12th Street, SW, Washington, DC 20554, with a copy submitted 
                                                     
28
47 CFR § 1.16.
                                                    Federal Communications Commission                          DA 16-861
7
electronically to Jeffrey J. Gee at Jeffrey.Gee@fcc.gov, and Gary Oshinsky at 
Gary.Oshinsky@fcc.gov.
17. Termination Date. Unless stated otherwise, the requirements set forth in paragraphs 13 
through 16 of this Consent Decree shall expire thirty-six (36) months after the Effective Date.
18. Civil Penalty.  The Company will pay a civil penalty to the United States Treasury in the 
amount of one million, two hundred and ten thousand dollars ($1,210,000) within thirty (30) calendar 
days after the Effective Date.  The Company shall send electronic notification of payment to Jeffrey J. 
Gee at Jeffrey.Gee@fcc.gov, and Gary Oshinsky at Gary.Oshinsky@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.
29
  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.
Questions regarding payment procedures should be addressed to the Financial Operations Group Help 
Desk by phone, 1-877-480-3201, or by e-mail, ARINQUIRIES@fcc.gov.
19. Waivers.  As of the Effective Date, the Company 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.  The Company 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 
Consent Decree or the Adopting Order, neither the Company nor the Commission shall contest the 
validity of the Consent Decree or the Adopting Order, and the Company shall waive any statutory right to 
a trial de novo.  The Company hereby agrees to waive any claims they may otherwise have under the 
Equal Access to Justice Act
30
relating to the matters addressed in this Consent Decree.
20. Severability.  The Parties agree that if any of the provisions of the Consent Decree shall 
be held unenforceable by any court of competent jurisdiction, such unenforceability shall not render 
unenforceable the entire Consent Decree, but rather the entire Consent Decree shall be construed as if not 
containing the particular unenforceable provision or provisions, and the rights and obligations of the 
                                                     
29
An FCC Form 159 and detailed instructions for completing the form may be obtained at 
http://www.fcc.gov/Forms/Form159/159.pdf.
30
See 5 U.S.C. § 504; 47 CFR §§ 1.1501-1.1530.
                                                    Federal Communications Commission                          DA 16-861
8
Parties shall be construed and enforced accordingly.  
21. Invalidity.  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.
22. 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 the Company does not expressly 
consent) that provision will be superseded by such Rule or Order.
23. Successors and Assigns.  The Company agrees that the provisions of this Consent 
Decree shall be binding on its successors, assigns, and transferees.  
24. Final Settlement.  The Parties agree and acknowledge that this Consent Decree shall 
constitute a final settlement between the Parties with respect to the Investigation.    
25. Modifications.  This Consent Decree cannot be modified without the advance written 
consent of both Parties.
26. 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.
27. Authorized Representative.  Each Party represents and warrants to the other 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.
28. Counterparts.  This Consent Decree may be signed in counterpart (including 
electronically or by facsimile).  Each counterpart, when executed and delivered, shall be an original, and 
all of the counterparts together shall constitute one and the same fully executed instrument.
________________________________
Travis LeBlanc 
Chief
Enforcement Bureau
______________________________
Date
________________________________
Steven Nettleton
Vice President Operations East
Soo Line Corporation
________________________________
Date