Federal Communications Commission FCC 08-80 
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Cumulus Licensing Corp.
Owner of Antenna Structures
#1052722 and #1052724
near Savannah, Georgia 
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File No. EB-03-AT-077
NAL/Acct. No. 200332480025
FRN: 0005-2603-77
MEMORANDUM OPINION AND ORDER
Adopted:  March 17, 2008 Released:  March 17, 2008
By the Commission:
I. INTRODUCTION
1. By this Memorandum Opinion and Order (“Order”), we deny an Application for Review 
filed on March 6, 2006, by Cumulus Licensing Corporation (“Cumulus”), owner of antenna structures, 
registration numbers 1052722 and 1052724, near Savannah, Georgia, of the Enforcement Bureau’s 
Memorandum Opinion and Order, released February 2, 2006.1 The MO&O denied Cumulus’ Petition for 
Reconsideration of an Enforcement Bureau Forfeiture Order,2 released December 28, 2004, which found 
Cumulus liable for a forfeiture in the amount of ten thousand dollars ($10,000) for willful and repeated 
violation of Section 17.50 of the Commission’s Rules (“Rules”).3 The noted violation involves the failure 
of Cumulus to clean and repaint its antenna structures to maintain good visibility.
II. BACKGROUND
2. On March 26, 1998, Cumulus acquired the subject antenna structures associated with AM 
radio station WBMQ, Savannah, Georgia.  Approximately three years and five months later, on August 
22, 2001, an agent from the Enforcement Bureau’s Atlanta, Georgia Field Office (“Atlanta Office”) 
inspected the subject antenna structures and found that the paint was badly faded and peeling, greatly 
reducing the structures’ visibility.  On September 19, 2001, the Atlanta Office issued a Notice of Violation 
(“NOV”) to Cumulus, noting, among other things, a violation of Section 17.50 of the Rules.  On October 
15, 2001, Cumulus responded that it was acquiring bids to repaint the structures and anticipated that the 
towers would be painted by December 31, 2001.
3. On October 18, 2001, the Atlanta Office issued a Continuation of Notice of Violation
requesting a status report on the antenna structure repainting.  In its response dated January 9, 2002, 
Cumulus replied that it would decide no later than January 31, 2002, whether to repaint or replace the 
towers.  On February 4, 2002, Cumulus submitted an additional reply to the Atlanta Office stating that it 
planned to replace the structures by June or July of 2002.  On July 31, 2002, Cumulus submitted another 
reply stating that it planned to relocate the transmitter site for WBMQ to another of its towers in 
Savannah, Georgia, after which it would dismantle the antenna structures.
  
1 Cumulus Licensing Corp., Memorandum Opinion and Order, 21 FCC Rcd 1032 (Enf. Bur. 2006) (“MO&O”).
2 Cumulus Licensing Corp., Forfeiture Order, 19 FCC Rcd 24815 (Enf. Bur. 2004) (“Forfeiture Order”).
3 47 C.F.R. § 17.50.  
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4. On March 18 and 19, 2003, approximately 18 months after issuing the NOV, an agent 
from the Atlanta Office re-inspected the antenna towers, and determined that the structures remained 
unpainted and that the orange and white aviation bands were not distinguishable at a distance of one-half 
mile.  On May 27, 2003, the Atlanta Office issued Cumulus a Notice of Apparent Liability for Forfeiture4
proposing a forfeiture in the amount of $10,000 for apparent willful5 and repeated6 violation of Section 
17.50 of the Rules.  In its August 1, 2003, Response to the NAL (“Response”), Cumulus did not contest 
the violation, but sought a downward adjustment of the forfeiture amount due to an overall history of 
compliance.7 Cumulus also sought a reduction of the proposed forfeiture amount based on its efforts to 
solve the problem once it received notice of the violation from the Atlanta Office.8 Cumulus described 
the remedial steps it had taken to date to cure the violation and the difficulties posed by the towers being 
located in protected wetlands.  Cumulus stated that it solicited bids from three tower companies, but each 
determined that the towers were unsafe to climb and further, one company reported that the towers should 
be condemned.9 Cumulus also explained that the Army Corps of Engineers, which is responsible for 
protecting the wetlands, was concerned that scrapings of the lead paint would fall into the wetlands and 
could harm its inhabitants.  Cumulus claimed that it then decided to dismantle the towers and replace 
them, but the “considerable cost” of erecting new towers in the place of the dismantled towers was 
“prohibitive.”10 Finally, Cumulus stated that it planned to move the transmitter site of WBMQ to its 
nearby station.  
5. On December 28, 2004, the Enforcement Bureau released a Forfeiture Order finding 
Cumulus liable for a monetary forfeiture in the amount of $10,000 for willful and repeated violation of 
Section 17.50 of the Rules.  The Enforcement Bureau determined that Cumulus’ efforts to cure the 
violation were remedial as they were initiated in response to Commission notification, and concluded, that 
consistent with precedent that the remedial or corrective action did not mitigate the forfeiture at issue.11  
  
4 Cumulus Licensing Corp., Notice of Apparent Liability for Forfeiture, NAL/Acct. No. 200332480025 (Enf. Bur., 
Atlanta Office, released May 27, 2003) (“NAL”).  
5 Section 312(f)(1) of the Communications Act of 1934, as amended (“Act”), 47 U.S.C. § 312(f)(1), which applies to 
violations for which forfeitures are assessed under Section 503(b) of the Act, provides that “[t]he term ‘willful,’ . . . 
means the conscious and deliberate commission or omission of such act, irrespective of any intent to violate any 
provision of this Act or any rule or regulation of the Commission authorized by this Act . . . .”  The Conference 
Report for Section 312(f)(1) of the Act indicates that Congress intended to apply this definition to Section 503 of the 
Act as well as Section 312 of the Act.  See H.R. Rep. 97th Cong. 2d Sess. 51 (1982); see Southern California 
Broadcasting Co., Memorandum Opinion and Order, 6 FCC Rcd 4387, 4388 (1991), recon. denied, Memorandum 
Opinion and Order, 7 FCC Rcd. 3454 (1992) (“Southern California Broadcasting”) and Western Wireless 
Corporation, Notice of Apparent Liability for Forfeiture, 18 FCC Rcd 10319, 10326 n.56 (2003) (“Western 
Wireless”). 
6 Section 312(f)(2) of the Act, 47 U.S.C. § 312(f)(2), which applies to violations for which forfeitures are assessed 
under Section 503(b) of the Act, provides that a violation is “repeated” if it continues for more than one day.  The 
Conference Report for Section 312(f)(2) of the Act indicates that Congress intended to apply this definition to 
Section 503 of the Act as well as Section 312 of the Act.  See H.R. Rep. 97th Cong. 2d Sess. 51 (1982).  See 
Southern California Broadcasting, 6 FCC Rcd at 4388 and Western Wireless, 18 FCC Rcd at 10326 n.56.
7 Response at 5.
8 Id. at 4.
9 Id. at 2.  
10 Id. at 3.
11 Forfeiture Order, 19 FCC Rcd at 24818 citing AT&T Wireless Services, Inc., Forfeiture Order, 17 FCC Rcd 
21866, 21871 (2002) (“AT&T Wireless”) (remedial action to correct tower painting violation was not a mitigating 
factor warranting reduction of forfeiture); Seawest Yacht Brokers, Forfeiture Order, 9 FCC Rcd 6099 (1994) 
(“Seawest”) (corrective action taken to comply with the Rules is expected, and does not mitigate any prior 
(continued....)
Federal Communications Commission FCC 08-80
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Moreover, the Enforcement Bureau denied Cumulus’ claim of a history of overall compliance based on 
evidence of numerous violations connected with the operation and maintenance of its other stations.12
6. On January 27, 2005, Cumulus filed a Petition for Reconsideration of the Forfeiture 
Order.  Again, not disputing the violation, Cumulus asserted that it was “still not legally able to dismantle 
the towers,” explaining that doing so would lead to severe monetary penalties from other government 
agencies,13 and sought a reduction in the forfeiture amount due to the “exceptional circumstances” it 
continued to encounter in attempting to comply with the Rules.  Cumulus stated that although it was 
making “every effort to comply” with the Rules, it had experienced setbacks and delays due to approvals 
needed from a variety of governmental agencies before dismantling the towers.  For example, Cumulus 
explained that the absence of a central authority to specify the requirements for dismantling the towers 
had resulted in a series of delays.  Cumulus argued that often, once it met the specific requirements of one 
agency, “another agency impose[d] different and sometimes conflicting requirements.”14 Cumulus also 
discussed some of the “substantial progress” it had made toward dismantling the towers:  (1) consulting 
with the relevant governmental agencies and obtaining some of the required regulatory approvals, (2) 
hiring consultants to evaluate environmental and safety issues and recommend the best approach to 
dismantling the towers and (3) contracting a construction company to oversee the demolition.15 Cumulus 
explained that it had obtained certain environmental agency approvals concerning protected species,16
filed applications for approvals to dismantle the towers and would continue to update the Commission on 
its progress in curing the violation.  On August 3, 2005, Cumulus informed the Enforcement Bureau that 
it had completed demolition of the subject towers on July 22, 200517 — over seven years after acquiring 
the towers, and almost four years after receiving the NOV.
7. On February 2, 2006, the Enforcement Bureau issued an MO&O denying Cumulus’ 
Petition for Reconsideration.  The Enforcement Bureau determined, as it had in the Forfeiture Order, that 
Cumulus delayed taking any steps to comply with the rules until it received notice of the violation from 
the Atlanta Office on September 19, 2001,18 approximately three years and six months after acquiring the 
antenna structures.  In the MO&O, the Enforcement Bureau reiterated the determination of the Forfeiture 
Order — that the Commission has consistently found that “corrective action taken to come into 
  
(...continued from previous page)
forfeitures or violations).  See TCI Cablevision of Maryland, Memorandum Opinion and Order, 7 FCC Rcd 6013, 
6014 (1992) (basing mitigation of a forfeiture upon corrective action taken subsequent to the misconduct upon 
which liability is based would tend to encourage remedial rather than preventive action); KGVL, Inc., Memorandum 
Opinion and Order, 42 FCC 2d 258, 259 (1973) (licensees not excused for past violations by reason of subsequent 
corrective action).
12 Forfeiture Order, 19 FCC Rcd at 24818.
13 Petition for Reconsideration at 3.  Cumulus stated that it was required to obtain authorization from the Army 
Corps of Engineers prior to dismantling the towers, and that to do so without such approval could potentially subject 
Cumulus to a liability of over $100,000.  
14 Id. at 4.
15 Id. at 3.  Cumulus asserted that this process involved, among other things, measuring the lead in the top soil to 
determine the extent of the lead clean up once the towers were dismantled.  
16 Petition for Reconsideration at 3.  Cumulus submitted a partial list of the governmental agencies involved in the 
antenna tower demolition approval process:  the Environmental Protection Agency, Federal Aviation 
Administration, U.S. Fish and Wildlife Service, U.S. Army Corps of Engineers, Georgia Department of Natural 
Resources and the Chatham County Department of Building Safety & Regulatory Services.  
17 Cumulus Licensing Corp., Final Progress Report at 1 (Aug. 3, 2005).
18 MO&O, 21 FCC Rcd at 1035 citing Forfeiture Order, 19 FCC Rcd 24817.
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compliance with Commission rules or policy is expected, and does not nullify or mitigate any prior 
forfeitures or violations."19 The Enforcement Bureau stated that Cumulus could not carve out an 
exception to the Commission’s long-held determination that remedial measures do not mitigate a Rule 
violation, even when the cure is complicated, takes time and great expense.20 The Enforcement Bureau 
determined, as it did in its previous orders, that “Cumulus should have known of, and acted on, the lack 
of paint on the towers prior to or immediately upon the March 26, 1998, purchase of the station and 
associated towers.”21
8. In its Application for Review, Cumulus again does not dispute the Enforcement Bureau’s 
findings that its towers were in violation of the tower painting rules.22 However, Cumulus reiterates that 
the Enforcement Bureau has not given “adequate consideration” to the “exceptional circumstances” it
faced to “cure this violation,”23 and argues that these circumstances warrant a reduction in the forfeiture 
amount “for such matters as justice may require.”24 In addition, Cumulus again seeks a downward 
adjustment of the forfeiture amount for overall compliance with the rules, a request which was previously 
denied.25 Cumulus argues that as an owner of more than 260 stations, its “numerous” violations relative 
to its size, are very small, and that “it is unfair to portray Cumulus as an entity that does not respect 
Commission rules.”26  
9. The forfeiture amount in this case was assessed in accordance with Section 503(b) of the 
Act, Section 1.80 of the Rules, and The Commission’s Forfeiture Policy Statement and Amendment of 
Section 1.80 of the Rules to Incorporate the Forfeiture Guidelines.27 In examining Cumulus’ Application 
for Review, Section 503(b) of the Act requires that the Commission take into account 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 any other “such matters as justice may 
require.”28
III. DISCUSSION
A. Tower Painting Violation
10. Background. Section 303(q) of the Act grants the Commission authority to oversee 
antenna structure painting requirements.29 Section 303(q) of the Act is codified in Part 17 of the Rules.  
  
19 MO&O, 21 FCC Rcd at 1035 citing Forfeiture Order, 19 FCC Rcd at 24818 citing AT&T Wireless, 17 FCC Rcd 
at 21871; Seawest, 9 FCC Rcd at 6099.
20 MO&O, 21 FCC Rcd at 1035.
21 Id. citing Forfeiture Order, 19 FCC Rcd at 24817-18.
22 Application for Review at 6.
23 Id. at 2.
24 Id. at 8 citing 47 U.S.C. §503(b)(2)(E).
25 Forfeiture Order, 19 FCC Rcd at 24818.
26 Application for Review at 7.
27 The Commission’s Forfeiture Policy Statement and Amendment of Section 1.80 of the Rules to Incorporate the 
Forfeiture Guidelines, Report and Order, 12 FCC Rcd 17087 (1997), recon. denied, Memorandum Opinion and 
Order, 15 FCC Rcd 303 (1999) (“Forfeiture Policy Statement ”).
28 47 U.S.C. § 503(b)(2)(E).
29 47 U.S.C. § 303(q).
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Section 17.50 of the Rules states that antenna structures requiring painting must be cleaned or repainted 
as often as necessary to maintain good visibility.  The Commission has consistently stressed the 
importance of compliance with antenna structure rules because of the potential danger to air navigation.30  
The Commission has established a $10,000 base forfeiture for violations of its antenna structure painting 
and lighting requirements.
11. Discussion. For the reasons provided below, we conclude that Cumulus’ remedial efforts 
to bring the tower into compliance do not mitigate its forfeiture for willful and repeated violation of 
Section 17.50.  As an initial matter, the record shows that Cumulus has never disputed the Commission’s 
finding that the antenna structures violated Section 17.50 of the Rules.  On the one hand, Cumulus states 
that it “is not trying to avoid paying a $10,000 fine.”31 On the other hand, paradoxically, Cumulus seeks a 
downward adjustment of the forfeiture amount on the basis of “such other matters as justice may 
require,”32 claiming that the Enforcement Bureau did not “adequately recognize the elaborate remedial 
efforts performed by Cumulus” to bring the towers into compliance with the rules. 33 We disagree.  
Throughout this proceeding, we have acknowledged Cumulus’ remedial efforts.  Simply stated, however, 
Cumulus did not initiate a cure for the violation or condition of the tower until after it was put on notice 
by the Commission.  It is well established that “corrective action taken to come into compliance with 
Commission rules or policy is expected, and does not nullify or mitigate any prior forfeitures or 
violations.”34 Thus, Cumulus is not entitled to a downward adjustment for these efforts.
12. Cumulus, which purchased the station and towers on March 26, 1998, admits that it knew 
that the towers were in bad repair, but claims that it did not know at that time that the towers could not be 
brought into compliance with the tower painting rules. 35 The point is unavailing.  Cumulus did not do 
anything before the inspection, to determine whether the towers could be brought into compliance -
through repainting or otherwise.  Had Cumulus done so, it would have learned, as it did following the 
inspection, that the towers could not be painted.  Cumulus approached three tower painting companies.  
Each determined that the towers were unsafe to climb -- one company reported that the towers should be 
condemned.36 Had Cumulus attempted to address the condition of the towers prior to receiving 
Commission notice through the issuance of the NOV, a justification to downwardly adjust the forfeiture 
amount may arguably have been presented.37 An after-the-fact determination by Cumulus that it could 
not have cured the violation through repainting, either before or after issuance of the NOV, is not a 
  
30 See SpectraSite Communications, Notice of Apparent Liability for Forfeiture, 18 FCC Rcd 22799 (2002) 
(stressing the importance of compliance with antenna structure rules in light of air safety considerations); see AT&T 
Wireless, 17 FCC Rcd at 21870 (stressing the importance of compliance with antenna structure rules in light of air 
safety considerations).
31 Application for Review at 7.
32 Id. At 8.
33 Id. at 6.
34 MO&O, 21 FCC Rcd at 1035 citing Forfeiture Order, 19 FCC Rcd at 24818 citing AT&T Wireless, 17 FCC Rcd 
at 21871; Seawest, 9 FCC Rcd at 6099.
35 Application for Review at 7.
36 Response at 2.  
37 See A-O Broadcasting Corporation, Memorandum Opinion and Order, 20 FCC Rcd 756, 761 (2005) (“A-O 
Broadcasting”) (because licensee showed good faith by obtaining EAS equipment and starting constructing a main 
studio before the inspection, the forfeiture was reduced); Radio One Licenses, Inc., Memorandum Opinion and 
Order, 18 FCC Rcd 15964, 15965 ¶ 4 (2003), recon. denied, Memorandum Opinion and Order, 18 FCC Rcd 25481 
(2003) (reducing a forfeiture from $9,200 to $8,000 for EAS violations because the licensee had identified the 
problems and had ordered replacement equipment prior to the Field Office’s on-site inspection).
Federal Communications Commission FCC 08-80
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mitigating factor to support a reduction of the forfeiture amount.38 There is no record of any efforts by 
Cumulus to address the towers’ condition prior to notification of the violation.  Absent such showing, we 
concur with the Enforcement Bureau’s determination that Cumulus should have known of, and acted on, 
the tower violation prior to or immediately upon its purchase of the station and associated towers.39  
13. Cumulus also argues that the tower painting violation could not be cured by painting the 
towers, but rather required dismantling.  To the extent that Cumulus attempts to argue for mitigation 
because it could not cure the tower violation by painting the towers, it is misguided.  What Cumulus fails 
to acknowledge is that the remedy for violating the Commission’s tower painting rules is to bring the 
towers into compliance with those rules, by whatever means necessary.  The remedy for the tower 
painting violation in this instance was to dismantle them.  Cumulus deserves no credit for ultimately 
doing that which had to be done.40
14. Cumulus next claims that the time it takes to cure a violation should be a deciding factor 
in determining what constitutes exceptional circumstances.  Cumulus argues that in Tower Properties of 
Florida, Inc. (“Tower”),41 the Enforcement Bureau did not find that a delay of a few weeks constituted 
exceptional circumstances warranting a downward adjustment of the forfeiture amount, but that a delay of 
four years should.42 Cumulus misses the point.  In Tower, the Enforcement Bureau flatly rejected any 
notion of time as a mitigating factor in post-notice efforts to cure a tower painting violation, stating that 
time had “no bearing on the subject forfeiture.”43 In Tower, the cure took approximately three months.  In 
the instant case, the cure took over four years.  Tower Properties and Cumulus both initiated curative 
measures after being notified by the Commission of a tower painting violation.  As previously explained,  
in Tower as here, unforeseen and unavoidable circumstances resulting in a delay of any duration 
encountered after Commission notification of a violation are not deemed mitigating factors warranting a 
downward adjustment of the forfeiture amount.44
  
38 Post-notification remedial efforts cannot mitigate the effects of a violation that results in the issuance of forfeiture.  
See Sutro Broadcasting Corporation, 19 FCC Rcd 15274, 15277 (2004) (stating that the Commission will generally 
reduce the assessed forfeiture amount “based on the good faith corrective efforts of a violator when those actions 
were taken prior to Commission notification of the violation”) (emphasis added); CB Radio, Inc., Memorandum 
Opinion and Order, 22 FCC Rcd 8836, 8839-40 (2007) (noting that “it is well established that post-investigational 
efforts to correct a violation do not mitigate the forfeiture or warrant a reduction in the assessed forfeiture amount”), 
recon pending.  However, post-notification remedial efforts may be relevant in determining the ultimate severity of 
any further or future enforcement action.  Thus, for instance, a licensee that takes minimal steps to remedy a 
violation post-notification could receive an NAL that is significantly higher (by way of an upward adjustment) than 
a licensee that takes substantial steps to come into compliance as quickly as possible -- although neither licensee can 
reduce its forfeiture liability for its pre-notification violation.   
39 MO&O, 21 FCC Rcd at 1035 citing Forfeiture Order, 19 FCC Rcd at 24816. 
40 Cumulus seems to ignore that the condition of its towers represented a significant potential hazard to air 
navigation.  We note that if the Commission were to take no action after observing the non-compliant condition of 
the towers, the Commission would be failing to meet its responsibilities for assisting in air navigation safety.
41 Tower Properties of Florida, Inc., Forfeiture Order, 18 FCC Rcd 26094, 26096 (Enf. Bur. 2003) (“Tower”) (once 
notified by the Commission of a tower painting violation, subsequent unforeseen and unavoidable circumstances 
which allegedly caused a delay in remedial efforts to comply with the rules were not deemed mitigating factors and 
had no bearing on the subject forfeiture).  
42 Application for Review at 8.
43 Tower, 18 FCC Rcd at 26096.
44 MO&O, 21 FCC Rcd at 1035 citing Tower, 18 FCC Rcd at 26096.  
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B. History of Compliance
15. Background. Section 1.80 of the Rules contains criteria for downwardly adjusting 
forfeiture amounts that are determined in accordance with Section 503 of the Act.  One such criterion is a 
history of overall compliance with the Commission’s Rules.  Forfeiture amounts have been downwardly 
adjusted in cases where Commission licensees or regulatees claim, and agency records (including 
Commission, Bureau and Field Office decisions) confirm, a history of overall compliance with the 
requirements of the Act and the Rules.
16. Discussion. We conclude that the record does not support a downward adjustment of the 
forfeiture based on a history of overall compliance with the Commission’s Rules.  In the Application for 
Review, Cumulus again seeks a downward adjustment of the forfeiture amount due to a history of 
compliance.45 Cumulus argues that although it owns more than 260 stations and has “numerous 
violations,” the number of violations is comparatively very small.46 Our records for Cumulus provide that 
a number of the Enforcement actions noted in its enforcement history are for violations of the 
Commission’s tower painting rules.  Accordingly, based on these noted previous tower violations by 
Cumulus, we do not believe that a history of compliance reduction would be appropriate.  Cumulus also 
argues that “it is unfair to portray it as an entity that does not respect the Commission’s rules.”47 Cumulus 
mischaracterizes the Commission’s decision not to downwardly adjust the forfeiture amount on the basis 
of a history of compliance with the rules.  Cumulus is not being punished for these other rule violations; 
rather, the Commission simply finds that these violations preclude mitigation of the forfeiture amount on 
the basis of a history of overall compliance.  
C. Conclusion
17. We have examined Cumulus’ Application for Review pursuant to the statutory factors 
above and in conjunction with the Forfeiture Policy Statement as well.  As a result of our review, we 
affirm the MO&O’s conclusion that Cumulus willfully and repeatedly violated Section 17.50 of the Rules 
and that it is not entitled to a reduction in the assessed forfeiture amount.
IV. ORDERING CLAUSES
18. ACCORDINGLY, IT IS ORDERED that, pursuant to Section 1.115 of the Rules,48 the 
Application for Review filed by filed by Cumulus Licensing Corporation of the Enforcement Bureau’s 
Memorandum Opinion and Order IS DENIED.
19. IT IS ALSO ORDERED THAT, pursuant to Section 503(b) of the Act and Section 
1.80(f)(4) of the Rules,49 Cumulus Licensing Corporation IS LIABLE FOR A MONETARY 
FORFEITURE in the amount of ten thousand dollars ($10,000) for willful and repeated violation of 
Section 17.50 of the Rules.
  
45 Cumulus first sought a downward adjustment of the forfeiture amount on the basis of a history of compliance in 
its Response to the NAL.  The Bureau Forfeiture Order denied the request for the downward adjustment based on 
evidence of numerous violations by Cumulus connected with the operation and maintenance of its other stations.  
See Forfeiture Order, 19 FCC Rcd at 24818.  Cumulus did not request a history of compliance reduction in its 
Petition for Reconsideration of the Forfeiture Order.
46 Application for Review at 7.
47 Id.
48 47 CFR § 1.115.
49 47 C.F.R. § 1.80(f)(4).
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20. Payment of the forfeiture must be made by check or similar instrument, payable to the 
order of the Federal Communications Commission.  The payment must include the NAL/Account 
Number and FRN Number referenced above.  Payment by check or money order may be mailed to 
Federal Communications Commission, P.O. Box 979088, St. Louis, MO 63197-9000.  Payment by 
overnight mail may be sent to U.S. Bank – Government Lockbox #979088, SL-MO-C2-GL, 1005 
Convention Plaza, St. Louis, MO 63101.  Payment by wire transfer may be made to ABA Number 
021030004, receiving bank TREAS/NYC, and account number 27000001.  For payment by credit card, 
an FCC Form 159 (Remittance Advice) must be submitted.  When completing the FCC Form 159, enter 
the NAL/Account number in block number 23A (call sign/other ID), and enter the letters “FORF” in 
block number 24A (payment type code).  Requests for full payment under an installment plan should be 
sent to:  Chief Financial Officer -- Financial Operations, 445 12th Street, S.W., Room 1-A625, 
Washington, D.C.  20554.  Please contact the Financial Operations Group Help Desk at 1-877-480-3201 
or Email: ARINQUIRIES@fcc.gov with any questions regarding payment procedures.  
21. IT IS FURTHER ORDERED THAT a copy of this Order shall be sent by first class 
mail and certified mail, return receipt requested, to Cumulus Media Inc., 111 East Kilbourn Avenue, Suite 
2700, Milwaukee, Wisconsin, 53202, and its Counsel, Mark N. Lipp, Wiley Rein LLP, 1776 K Street 
NW, Washington, DC 20006.
FEDERAL COMMUNICATIONS COMMISSION
 Marlene H. Dortch
 Secretary