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


 In  the  Matter  of  )  )  File  No.  EB-  03-  NY-  364 
 Jarad  Broadcasting  Company  of  Westhampton,  Inc.  )  WBON-  FM,  formerly  WDRE  )  NAL/  Acct.  No.  200432380012 
 Garden  City,  New  York  )  )  FRN:  0004  9288  34 


 NOTICE  OF  APPARENT  LIABILITY  FOR  FORFEITURE 
 Released:  May  20,  2004 
 By  the  District  Director,  New  York  Office,  Northeast  Region,  Enforcement  Bureau: 
 I.  INTRODUCTION 
 1.  In  this  Notice  of  Apparent  Liability  for  Forfeiture  (“  NAL”),  we  find  that  Jarad  Broadcasting  Company  of  Westhampton,  Inc.  (“  Jarad”),  the  licensee  of  radio  station  WBON-  FM,  has  apparently  violated 
 Section  73.1350(  a)  of  the  Commission’s  Rules  (the  “Rules”),  1  by  operating  with  an  excessive  antenna  height.  This  section  requires  that  a  licensee  operate  its  broadcast  station  in  accordance  with  the  terms  of  the 
 station  authorization.  We  conclude  that  Jarad  is  apparently  liable  for  a  forfeiture  in  the  amount  of  five  thousand  dollars  ($  5,000). 


 II.  BACKGROUND 
 2.  On  September  26,  2003,  the  FCC  New  York  Office  received  a  complaint,  which  alleged  that  Jarad  was  operating  with  an  excessive  antenna  height. 


 3.  On  October  15,  2003,  Commission  agents  from  the  New  York  Office  inspected  Jarad’s  transmitting  facilities,  located  in  Manorville,  New  York.  The  inspection  was  conducted  with  Jarad’s 
 president,  John  Caracciolo,  and  chief  engineer,  Ron  Reeve.  During  the  inspection,  the  agents  observed  that  Jarad’s  transmitting  antenna  was  mounted  at  a  height  of  approximately  114  meters  above  ground  level.  The 
 station’s  license  (File  No.  BLH-  20030115AAA)  authorizes  Jarad  to  operate  with  an  antenna  height  of  40  meters. 


 4.  On  October  29,  2003,  the  New  York  Office  issued  a  Notice  of  Violation  (No.  V20043238001)  to  Jarad  for  operating  with  an  antenna  height  in  excess  of  its  authorized  height,  in  violation 
 of  Section  73.  1350(  a)  of  the  Rules. 


 1  47  C.  F.  R.  §  73.1350(  a). 
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 5.  On  November  18,  2003,  the  New  York  Office  received  a  reply  to  the  Notice  of  Violation,  in  which  Jarad  acknowledged  the  violation  and  stated  that  they  raised  the  antenna  height,  without  Commission 
 authorization,  in  response  to  residents’  complaints  of  interference  to  consumer  electronic  equipment  in  the  vicinity  of  the  transmitting  tower.  The  response  stated  that  on  October  9,  2003,  Jarad  requested  Special 
 Temporary  Authority  (“  STA”)  from  the  FCC’s  Audio  Division  to  reduce  power  and  increase  antenna  height,  in  order  to  eliminate  the  interference  to  nearby  homes.  The  response  also  stated  that  on  October  29,  2003,  the 
 antenna  was  returned  to  its  authorized  height  of  40  meters  above  ground.  A  review  of  the  Commission’s  records  showed  no  evidence  that  the  FCC  had  granted  Jarad  a  STA  or  any  other  authorization  to  operate  with 
 an  antenna  height  other  than  that  stated  on  the  station  license. 
 6.  On  December  4,  2003,  the  New  York  office  obtained  copies  of  Jarad’s  Antenna  Site  Agreement  and  Tenant  Installation  Notice  for  the  tower  they  rent,  showing  that  they  installed  the  antenna  at  a 
 height  of  107  meters  above  ground  level  on  December  22,  2002. 
 7.  Jarad’s  call  sign  was  WDRE  for  facility  ID  57672  at  the  time  of  complaint  and  the  subsequent  FCC  inspection  conducted  on  October  15,  2003.  A  review  of  the  Commission’s  records 
 showed  that  Jarad’s  call  sign  was  changed  from  WDRE  to  WBON-  FM  on  January  12,  2004. 
 III.  DISCUSSION 
 8.  Section  73.  1350(  a)  of  the  Rules  states  that  each  licensee  is  responsible  for  maintaining  and  operating  its  broadcast  station  in  a  manner  which  complies  with  the  technical  rules  set  forth  elsewhere  in  this 
 part  and  in  accordance  with  the  terms  of  the  station  authorization.  On  October  15,  2003,  agents  observed  that  Jarad  operated  with  an  antenna  height  of  approximately  114  meters,  exceeding  its  authorized  antenna  height 
 of  40  meters,  in  violation  of  Section  73.  1350(  a)  of  the  Rules.  Information  obtained  subsequent  to  the  inspection  shows  that  they  had  operated  in  violation  since  antenna  installation  on  December  22,  2002. 


 9.  Based  on  the  evidence  before  us,  we  find  that  Jarad  willfully  2  and  repeatedly  3  violated  Section  73.1350(  a)  of  the  Rules  by  operating  with  an  excessive  antenna  height,  thereby  failing  to  operate  its 
 broadcast  station  in  accordance  with  the  terms  of  the  station  authorization. 
 10.  The  Commission’s  Forfeiture  Policy  Statement  and  Amendment  of  Section  1.80  of  the  Rules  to  Incorporate  the  Forfeiture  Guidelines,  12  FCC  Rcd  17087,  17113  (1997),  recon.  denied,  15  FCC  Rcd 
 303(  1999)  (“  Forfeiture  Policy  Statement”),  4  sets  the  base  forfeiture  amount  for  exceeding  the  authorized  antenna  height  at  $5,000.  In  assessing  the  monetary  forfeiture  amount,  we  must  take  into  account  the 
 statutory  factors  set  forth  in  Section  503(  b)(  2)(  D)  of  the  Communications  Act  of  1934,  as  amended,  5  (“  Act”) 
 2  Section  312(  f)(  1)  of  the  Act,  47  U.  S.  C.  312(  f)(  1),  which  applies  to  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  Section  312(  f)(  2),  which  also  applies  to  Section  503(  b),  provides:  [t]  he  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. 


 4  47  C.  F.  R.  §  1.80. 
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 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.  Applying  the  Forfeiture  Policy  Statement  and  the  statutory  factors  to  the  instant  case  and  applying  the  inflation  adjustments,  we  believe  that  a  five  thousand  dollar  ($  5,000)  monetary  forfeiture  is  warranted. 


 IV.  ORDERING  CLAUSES 
 11.  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  ,  Jarad  is  hereby  NOTIFIED  of  its  APPARENT  LIABILITY  FOR  A 
 FORFEITURE  in  the  amount  of  five  thousand  dollars  ($  5,000)  for  willful  and  repeated  violation  of  Section  73.1350(  a)  of  the  Commission’s  Rules. 


 12.  IT  IS  FURTHER  ORDERED  THAT,  pursuant  to  Section  1.80  of  the  Rules,  within  thirty  days  of  the  release  date  of  this  NOTICE  OF  APPARENT  LIABILITY,  Jarad  SHALL  PAY  the  full  amount  of  the 
 proposed  forfeiture  or  SHALL  FILE  a  written  statement  seeking  reduction  or  cancellation  of  the  proposed  forfeiture. 


 13.  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.  200432380012  and  FRN:  0004  9288  34. 


 14.  Any  response  to  this  NAL  must  be  mailed  to  Federal  Communications  Commission,  New  York  Office,  201  Varick  Street,  New  York,  NY  10014,  and  MUST  INCLUDE  THE  NAL/  Acct.  No. 
 200432380012. 
 15.  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. 


 16.  Requests  for  payment  of  the  full  amount  of  this  Notice  of  Apparent  Liability  under  an  installment  plan  should  be  sent  to:  Chief,  Revenue  and  Receivable  Operations  Group,  445  12th  Street,  S.  W., 
 Washington,  D.  C.  20554.  8 
 17.  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, 
 5  47  U.  S.  C.  §  503(  b)(  2)(  D). 


 6  47  U.  S.  C.  §  503(  b) 
 7  47  C.  F.  R.  §§  0.  111,  and  0.311. 
 8  See  47  C.  F.  R.  §  1.1914. 
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 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  Federal  Communications  Commission,  Enforcement  Bureau,  Spectrum  Enforcement 
 Division,  445  12  th  Street,  S.  W.,  Washington,  D.  C.  20554.  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  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. 
 18.  IT  IS  FURTHER  ORDERED  THAT  a  copy  of  this  NOTICE  OF  APPARENT  LIABILITY  shall  be  sent  by  Certified  Mail  Return  Receipt  Requested  to  Jarad  Broadcasting  Company  of  Westhampton, 
 Inc.,  1103  Stewart  Avenue,  Garden  City,  NY  11530. 
 FEDERAL  COMMUNICATIONS  COMMISSION 


 Daniel  W.  Noel  District  Director 
 New  York  Office 


 Attachment  A  –  FCC  List  of  Small  Entities,  October  2002 
4