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 Before  the  Federal  Communications  Commission 
 Washington,  D.  C.  20554 


 In  the  Matter  of 
 WCPC  Broadcasting  Co.,  Inc.  Licensee  of  AM  Radio  Station  WCPC 
 Houston,  Mississippi 


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 )  ) 
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 File  Number  EB-  02-  OR-  0202 
 NAL/  Acct.  No.  200232620010 
 FRN  0003-  7893-  85 


 NOTICE  OF  APPARENT  LIABILITY  FOR  FORFEITURE 
 Released:  August  21,  2002 
 By  the  Enforcement  Bureau,  New  Orleans  Office: 
 I.  INTRODUCTION 
 1.  In  this  Notice  of  Apparent  Liability  for  Forfeiture  (“  NAL”),  we  find  WCPC  Broadcasting  Co.,  Inc.,  licensee  of  AM  radio  station  WCPC,  Houston,  Mississippi,  apparently  liable  for  a  forfeiture  in  the 
 amount  of  seven  thousand  dollars  ($  7,000)  for  willful  and  repeated  violation  of  Section  73.49  of  the  Commission’s  Rules  (“  Rules”).  1  Specifically,  we  find  WCPC  Broadcasting  Co.,  Inc.  apparently  liable  for 
 failing  to  enclose  four  of  its  antenna  structures  within  effective  locked  fences  or  other  enclosures. 
 II.  BACKGROUND 
 2.  On  June  27,  2002,  agents  from  the  FCC  Enforcement  Bureau’s  New  Orleans  Field  Office  inspected  the  antenna  structures  of  radio  station  WCPC(  AM),  Houston,  Mississippi.  The  agents  observed 
 that  there  was  no  fence  around  one  antenna  structure,  broken  fencing  around  a  second  structure,  and  missing  fencing  sections  around  two  other  antenna  structures.  All  antenna  structures  had  radio  frequency 
 potential  at  the  base. 
 III.  DISCUSSION 
 3.  Section  73.49  of  the  Rules  requires  that  antenna  towers  having  radio  frequency  potential  at  the  base  be  enclosed  within  effective  locked  fences  or  other  enclosures.  On  June  27,  2002,  four  of  WCPC’s 
 antenna  towers  were  not  enclosed  within  effective  locked  fences  or  other  enclosures. 
 4.  Based  on  the  evidence  before  us,  we  find  that  on  June  27,  2002,  WCPC  Broadcasting  Co.,  Inc.  willfully  2  and  repeatedly  3  violated  Section  73.49  of  the  Rules  by  failing  to  provide  effective  locked  fences 


 1  47  C.  F.  R.  §  73.49. 
 2  Section  312(  f)(  1)  of  the  Act,  47  U.  S.  C.  §  312(  f)(  1),  which  applies  to  violations  for  which  forfeitures  are  assessed 
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 or  other  enclosures  around  their  antenna  structures. 
 5.  Pursuant  to  Section  1.80(  b)(  4)  of  the  Rules,  the  base  forfeiture  amount  for  AM  tower  fencing  violations  is  $7,000.  4  In  assessing  the  monetary  forfeiture  amount,  we  must  also  take  into  account  the 
 statutory  factors  set  forth  in  Section  503(  b)(  2)(  D)  of  the  Communications  Act  of  1934,  as  amended  (“  Act”),  which  include  the  nature,  circumstances,  extent,  and  gravity  of  the  violation,  and  with  respect  to 
 the  violator,  the  degree  of  culpability,  any  history  of  prior  offenses,  ability  to  pay,  and  other  such  matters  as  justice  may  require.  5  Considering  the  entire  record  and  applying  the  factors  listed  above,  this  case 
 warrants  a  $7,000  forfeiture. 
 IV.  ORDERING  CLAUSES 
 6.  Accordingly,  IT  IS  ORDERED  THAT,  pursuant  to  Section  503(  b)  of  the  Act,  6  and  Sections  0.111,  0.311  and  1.80  of  the  Rules,  7  WCPC  Broadcasting  Co.,  Inc.  is  hereby  NOTIFIED  of  this 
 APPARENT  LIABILITY  FOR  A  FORFEITURE  in  the  amount  of  seven  thousand  dollars  ($  7,000)  for  willful  and  repeated  violation  of  Section  73.49  of  the  Rules  by  failing  to  provide  effective  locked  fences 
 for  its  antenna  towers. 
 7.  IT  IS  FURTHER  ORDERED  THAT,  pursuant  to  Section  1.80  of  the  Rules,  within  thirty  days  of  the  release  date  of  this  NAL,  WCPC  Broadcasting  Co.,  Inc.  SHALL  PAY  the  full  amount  of  the 
 proposed  forfeiture  or  SHALL  FILE  a  written  statement  seeking  reduction  or  cancellation  of  the  proposed  forfeiture. 


 8.  Payment  of  the  forfeiture  may  be  made  by  mailing  a  check  or  similar  instrument,  payable  to  the  order  of  the  Federal  Communications  Commission,  to  the  Forfeiture  Collection  Section,  Finance 
 Branch,  Federal  Communications  Commission,  P.  O.  Box  73482,  Chicago,  Illinois  60673-  7482.  The  payment  should  note  the  NAL/  Acct.  No.  and  FRN  referenced  above.  Request  for  payment  of  the  full 
 amount  of  this  NAL  under  an  installment  plan  should  be  sent  to:  Chief,  Revenue  and  Receivable 


 under  Section  503(  b)  of  the  Act,  provides  that  “[  t]  he  term  ‘willful,  ’  when  used  with  reference  to  the  commission  or  omission  of  any  act,  means  the  conscious  and  deliberate  commission  or  omission  of  such  act,  irrespective  of  any 
 intent  to  violate  any  provision  of  this  Act  ….”  See  Southern  California  Broadcasting  Co.,  6  FCC  Rcd  4387  (1991). 
 3  The  term  “repeated,”  when  used  with  reference  to  the  commission  or  omission  of  any  act,  “means  the  commission 
 or  omission  of  such  act  more  than  once  or,  if  such  commission  or  omission  is  continuous,  for  more  than  one  day.”  47  U.  S.  C.  §  312(  f)(  2). 


 4  47  C.  F.  R.  §  1.80(  b)(  4). 
 5  47  U.  S.  C.  §  503(  b)(  2)(  D). 
 6  47  U.  S.  C.  §  503(  b). 
 7  47  C.  F.  R.  §§  0.111,  0.311,  1.80. 
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 Operations  Group,  445  12  th  Street,  S.  W.,  Washington,  D.  C.  20554.  8 
 9.  The  response,  if  any,  must  be  mailed  to  Federal  Communications  Commission,  Office  of  the  Secretary,  445  12  th  Street,  SW,  Washington,  DC  20554,  Attn:  Enforcement  Bureau-  Technical  &  Public 
 Safety  Division,  and  MUST  INCLUDE  THE  NAL/  Acct.  No.  referenced  above. 
 10.  The  Commission  will  not  consider  reducing  or  canceling  a  forfeiture  in  response  to  a  claim  of  inability  to  pay  unless  the  petitioner  submits:  (1)  federal  tax  returns  for  the  most  recent  three-  year  period; 
 (2)  financial  statements  prepared  according  to  generally  accepted  accounting  practices  (“  GAAP”);  or  (3)  some  other  reliable  and  objective  documentation  that  accurately  reflects  the  petitioner’s  current  financial 
 status.  Any  claim  of  inability  to  pay  must  specifically  identify  the  basis  for  the  claim  by  reference  to  the  financial  documentation  submitted. 


 11.  IT  IS  FURTHER  ORDERED  THAT  a  copy  of  this  NAL  shall  be  sent  by  regular  mail  and  Certified  Mail  Return  Receipt  Requested  to  WCPC  Broadcasting  Co.,  Inc.,  1189  Highway  15  North, 
 Houston,  Mississippi  38851. 


 FEDERAL  COMMUNICATIONS  COMMISSION 


 James  C.  Hawkins  District  Director,  New  Orleans  Office 
 Enforcement  Bureau 


 8  See  47  C.  F.  R.  §  1.1914. 
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