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


 In  the  Matter  of 
 Rama  Communications,  Inc.  Licensee  of  WLAA(  AM)  in  Winter  Garden,  Florida 
 Orlando,  Florida 


 )  ) 
 )  ) 
 )  ) 


 File  Number  EB-  02-  TP-  550 
 NAL/  Acct.  No.  200432700011 
 FRN  0005008016 


 NOTICE  OF  APPARENT  LIABILITY  FOR  FORFEITURE 
 Released:  March  5,  2004 
 By  the  Enforcement  Bureau,  Tampa  Office: 
 I.  INTRODUCTION 
 1.  In  this  Notice  of  Apparent  Liability  for  Forfeiture  (“  NAL”),  we  find  Rama  Communications,  Inc.  (“  Rama”),  licensee  of  radio  station  WLAA,  Winter  Garden,  Florida,  apparently  liable  for  a  forfeiture 
 in  the  amount  of  eighteen  thousand  dollars  ($  18,000)  for  willful  and  repeated  violation  of  Sections  11.35(  a)  and  73.3526(  c)(  1)  of  the  Commission’s  Rules  (“  Rules”).  1  Specifically,  we  find  Rama 
 Communications,  Inc.  apparently  liable  for  failure  to  have  the  Emergency  Alert  System  (“  EAS”)  transmitting  functions  available  during  times  the  station  is  in  operation,  and  failure  to  make  available 
 upon  request  the  complete  public  inspection  file  during  regular  business  hours. 
 II.  BACKGROUND 
 2.  On  June  3,  2003,  the  FCC  Enforcement  Bureau’s  Tampa  Office  (“  Tampa  Office”)  received  a  complaint  alleging  that  WLAA  failed  to  reduce  transmitter  power  at  the  required  times  as  specified  in  the 
 station  authorization. 
 3.  On  June  13,  2003,  the  agents  from  the  Tampa  Office  inspected  radio  station  WLAA  during  regular  business  hours.  The  agents  met  with  the  station’s  general  manager  and  the  chief  operator  who 
 assisted  the  agents  during  the  inspection.  During  the  inspection,  station  personnel  twice  attempted  to  run  an  EAS  test  using  the  shared  EAS  equipment  with  co-  located  and  co-  owned  station  WOKB.  During  both 
 attempts,  the  tests  were  successfully  transmitted  over  station  WOKB  but  failed  to  be  transmitted  over  WLAA.  The  station  logs  showed  no  entries  of  EAS  tests  since  December  30,  2002,  and  no  entries 
 showing  the  EAS  equipment  had  been  removed  from  service  for  repairs.  Station  personnel  could  not  produce  the  following  items  for  public  inspection:  a  copy  of  the  current  FCC  license;  contour  maps 
 showing  current  station  coverage;  most  recent  ownership  report  (last  one  available  was  submitted  on  January  3,  2001);  annual  employment  reports;  issues/  program  lists;  and  the  local  public  notice 
 announcement. 
 1  47  C.  F.  R.  §§  11.35(  a)  and  73.3526(  c)(  1). 
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 4.  On  July  25,  2003,  a  follow-  up  investigation  further  revealed  that  the  entire  public  file  was  not  available  at  the  main  studio.  A  sign  posted  outside  WLAA’s  main  studio  read:  “Effective  June  20,  2003, 
 WOKB/  WLAA  public  files  are  located  at  3765  N.  John  Young  Pkwy,  Orlando,  FL  for  public  view,  Monday-  Friday  between  10  AM-  5  PM.” 


 III.  DISCUSSION 
 5.  Section  11.35(  a)  of  the  Rules  requires  the  licensee  of  a  broadcast  station  to  ensure  that  EAS  Encoders,  EAS  Decoders  and  Attention  Signal  generating  and  receiving  equipment  used  as  part  of  the  EAS 
 are  installed  so  that  the  monitoring  and  transmitting  functions  are  available  during  the  times  the  stations  and  are  in  operation.  At  the  time  of  inspection  on  June  13,  2003,  the  station’s  EAS  equipment  was  not  capable 
 of  generating  the  attention  signal  over  station  WLAA.  According  to  the  station’s  logs,  the  station  had  conducted  no  EAS  tests  since  December  30,  2002.  The  logs  contained  no  entries  showing  the  EAS 
 equipment  had  been  removed  for  repair. 
 6.  Section  73.3526(  a)(  2)  of  the  Rules  2  requires  that  every  permittee  or  licensee  of  an  AM,  FM,  TV  or  Class  A  TV  station  in  the  commercial  broadcast  services  shall  maintain  a  public  inspection  file  containing 
 the  material,  relating  to  that  station,  described  in  paragraphs  (e)(  1)  through  (e)(  10)  and  paragraph  (e)(  13)  of  this  section.  Section  73.3526(  b)  of  the  Rules  3  requires  the  public  inspection  file  be  maintained  at  the 
 station’s  main  studio.  Section  73.3526(  c)(  1)  of  the  Rules  requires  the  file  be  available  for  public  inspection  at  any  time  during  regular  business  hours.  At  the  time  of  inspection  during  regular  business  hours  on  July 
 13,  2003,  the  following  items  were  unavailable  for  inspection:  a  copy  of  the  current  FCC  license,  contour  maps  showing  current  station  coverage,  ownership  report,  annual  employment  report,  issues/  program  lists 
 and  the  local  public  notice  announcement.  During  the  inspection  on  July  25,  2003,  the  entire  public  inspection  file  was  not  available  at  the  main  studio  location. 


 7.  Based  on  the  evidence  before  us,  we  find  Rama  willfully  and  repeatedly  violated  Sections  11.35(  a)  and  73.3526(  c)(  1)  of  the  Rules  for  failure  to  have  the  EAS  transmitting  functions  available 
 during  times  the  station  is  in  operation,  and  failure  to  make  available  upon  request  the  entire  public  inspection  file  during  regular  business  hours. 


 8.  Pursuant  to  Section  1.80(  b)(  4)  of  the  Rules,  4  the  base  forfeiture  amount  for  failure  to  maintain  operational  EAS  equipment  is  $8,000,  and  for  failure  to  maintain  required  records  in  the  public 
 inspection  file  is  $10,000.  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 
 2  47  C.  F.  R.  §  73.3526(  a)(  2). 
 3  47  C.  F.  R.  §  73.3526(  b). 
 4  47  C.  F.  R.  §  1.80(  b)(  4). 
 5  47  U.  S.  C.  §  503(  b)(  2)(  D). 
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 warrants  an  $18,000  forfeiture. 
 IV.  ORDERING  CLAUSES 
 9.  Accordingly,  IT  IS  ORDERED  THAT,  pursuant  to  Section  503(  b)  of  the  Act,  6  and  Sections  0.111,  0.311  and  1.80  of  the  Rules,  7  Rama  Communications,  Inc.  is  hereby  NOTIFIED  of  this  APPARENT 
 LIABILITY  FOR  A  FORFEITURE  in  the  amount  of  eighteen  thousand  dollars  ($  18,000)  for  failure  to  have  the  EAS  transmitting  functions  available  during  times  the  station  is  in  operation,  and  failure  to  make 
 available  for  inspection  the  complete  public  inspection  file. 
 10.  IT  IS  FURTHER  ORDERED  THAT,  pursuant  to  Section  1.80  of  the  Rules,  within  thirty  days  of  the  release  date  of  this  NAL,  Rama  Communications,  Inc.  SHALL  PAY  the  full  amount  of  the  proposed 
 forfeiture  or  SHALL  FILE  a  written  statement  seeking  reduction  or  cancellation  of  the  proposed  forfeiture. 
 11.  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.  Requests  for  payment  of  the  full  amount  of  this  NAL 
 under  an  installment  plan  should  be  sent  to:  Chief,  Revenue  and  Receivables  Operations  Group,  445  12th  Street,  S.  W.,  Washington,  D.  C.  20554.  8 


 12.  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-  Spectrum  Enforcement 
 Division  and  MUST  INCLUDE  THE  NAL/  Acct.  No.  referenced  above. 
 13.  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. 


 14.  Under  the  Small  Business  Paperwork  Relief  Act  of  2002,  Pub  L.  No.  107-  198,  116  Stat.  729  (June  28,  2002),  the  FCC  is  engaged  in  a  two-  year  tracking  process  regarding  the  size  of  entities  involved  in 
 forfeitures.  If  you  qualify  as  a  small  entity  and  if  you  wish  to  be  treated  as  a  small  entity  for  tracking  purposes,  please  so  certify  to  us  within  thirty  (30)  days  of  this  NAL,  either  in  your  response  to  the  NAL  or  in 
 a  separate  filing  to  be  sent  to  the  Spectrum  Enforcement  Division.  Your  certification  should  indicate  whether  you,  including  your  parent  entity  and  its  subsidiaries,  meet  one  of  the  definitions  set  forth  in  the  list 
 provided  by  the  FCC’s  Office  of  Communications  Business  Opportunities  (OCBO)  set  forth  in  Attachment 
 6  47  U.  S.  C.  §  503(  b). 
 7  47  C.  F.  R.  §§  0.111,  0.311,  1.80. 
 8  See  47  C.  F.  R.  §  1.1914. 
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 A  of  this  Notice  of  Apparent  Liability.  This  information  will  be  used  for  tracking  purposes  only.  Your  response  or  failure  to  respond  to  this  question  will  have  no  effect  on  your  rights  and  responsibilities  pursuant 
 to  Section  503(  b)  of  the  Communications  Act.  If  you  have  questions  regarding  any  of  the  information  contained  in  Attachment  A,  please  contact  OCBO  at  (202)  418-  0990. 


 15.  IT  IS  FURTHER  ORDERED  THAT  a  copy  of  this  NAL  shall  be  sent  by  regular  mail  and  Certified  Mail  Return  Receipt  Requested  to  Rama  Communications,  Inc.,  PO  Box  680889,  Orlando,  FL 
 32868. 


 FEDERAL  COMMUNICATIONS  COMMISSION 


 Ralph  M.  Barlow  Tampa  Office,  Enforcement  Bureau 
 Attachment 
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