EB Field Office NAL - HBC License Corporation, KHOT-FM (Paradise Valley, AZ) and KHOV-FM (Wickenburg, AZ),

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


In the Matter of 
HBC License Corporation File No. EB-02-SD-157 


Licensee of Station KHOT-FM 
Paradise Valley, Arizona 


and 


File No. EB-02-SD-158 
Licensee of Station KHOV-FM 
Wickenburg, Arizona NAL/Acct. No.: 200332940001 


FRN: 000-494-6141 


XX xr A OA AAA 


NOTICE OF APPARENT LIABILITY FOR FORFEITURE 
Released: November 29, 2002 
By the District Director, San Diego Office, Enforcement Bureau: 


I. INTRODUCTION 


1. In this Notice of Apparent Liability for Forfeiture ("NAL"), we find that HBC License 
Corporation (“HBC”), licensee of FM Broadcast stations KHOT-FM, Paradise Valley, Arizona and 
KHOV-FM, Wickenburg, Arizona, has apparently willfully and repeatedly violated Sections 11.35(a), 
11.35(c) and 11.61 of the Commission's Rules by failing to maintain operational Emergency Alert 
System ("EAS") encoder and decoder equipment and by failing to conduct and log required EAS tests. 
We conclude, pursuant to Section 503(b) of the Communications Act of 1934, as amended (“Act”), 
that HBC is apparently liable for a forfeiture in the amount of eight thousand dollars ($8,000). 


Il. BACKGROUND 


2. On May 6, 2002, an Agent from the FCC’s San Diego Office inspected stations KHOT-FM 
and KHOV-FM at the shared main studio facility located at 4745 N. qe St., #140, Phoenix, Arizona. The 
inspection revealed that KHOT-FM and KHOV-FM share common EAS equipment, which at the time of 
inspection, appeared to be operational. The Agent noted that HBC maintained a single, continuous 


147 C.F.R. $$ 11.35(a), 11.35(c) and 11.61. 


? 47 U.S.C. $ 503(b). 


Federal Communications Commission 


printout of the log for the EAS equipment for both KHOT-FM and KHOV-FM. This printout indicated 
that no EAS tests (sent or received) were conducted during the period from September 14, 2001 through 
April 9, 2002. Further, the printout indicated that the EAS unit was not operational from September 17, 
2001 through April 8, 2002. There was no written explanation of why the EAS tests were omitted or any 
indication that the stations’ chief operator or other personnel attempted to identify the source of any 
problem with the EAS equipment. 


3. On May 28, 2002, an official Notice of Violation was issued to HBC for failing to maintain 
operational EAS equipment, for failing to receive and transmit tests, and for failing to conduct weekly 
checks of the station’s records by the designated chief operator from September 14, 2001 though April 9, 
2002.* 


4. On June 27, 2002, the FCC’s San Diego office received a reply letter dated June 26, 2002, 
from HBC. The letter included a statement from HBC’s designated chief operator dated June 24, 2002. 
In that statement the chief operator acknowledged the violations and delineated steps taken to prevent 
future EAS rule violations. 


II. DISCUSSION 


5. Section 503(b) of the Act provides that any person who willfully or repeatedly fails to 
comply substantially with the terms and conditions of any license, or willfully or repeatedly fails to 
comply with any of the provisions of the Act or of any rule, regulation or order issued by the 
Commission thereunder, shall be liable for a forfeiture penalty.* The term “willful” as used in Section 
503(b) has been interpreted to mean simply that the acts or omissions are committed knowingly, and 
“repeated” means the commission or omission of the act more than once or for more than one day.” 


6. The Rules provide that every FM Broadcast station is part of the nationwide EAS network 
and is categorized as a participating national EAS source unless the station affirmatively requests 
authority to not participate. The EAS provides the President and state and local governments with 
the capability to provide immediate and emergency communications and information to the general 


3 47 CFR. $8 11.35, 11.61(a)(1) & 73.1870(c)(3). 
* 47 U.S.C. $ 503(b). 


> Section 312(f)(1) of the 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’, 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 or any rule or regulation of the Commission authorized by this Act....” See Southern California Broadcasting Co., 
6 FCC Red 4387 (1991). Section 312(f)(1), 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.” 


647 CFR. §§ 11.11 & 11.41. 


Federal Communications Commission 


public.’ State and local area EAS plans identify sources responsible for coordinating carriage of 
common emergency messages from agencies such as the National Weather Service or local 
emergency management officials.* 


7. The Rules require FM Broadcast stations to ensure that EAS equipment, such as encoders, 
decoders, attention signal generators and receivers, is installed so that the monitoring and transmitting 
functions are available during the times whenever the station is in operation.” The Rules also require 
FM Broadcast stations to: (a) receive monthly EAS tests from designated EAS sources and retransmit 
the monthly test within 60 minutes of its receipt and (b) conduct tests of the EAS header and EOM 
codes at least once a week at random days and times. ° 


8. As required by Section 11.61 of the Rules, monthly EAS tests must be retransmitted within 
60 minutes of receipt, weekly EAS tests be conducted at least once a week at random times and all 
EAS tests received and transmitted must be logged in the station’s records. Section 73.1820(a) of the 
Rules provides, in part, that entries must be made in the station log either manually by a person 
designated by the licensee who is in actual charge of the transmitting apparatus or by automatic 
devices.'' This rule section further provides that all stations must enter each test and activation of the 
EAS pursuant to the requirements of Part 11 of the Rules and the EAS Operating Handbook.’ 
Stations may keep EAS data in a special EAS log maintained at a convenient location; however, this 
log is considered a part of the station log. 


9. The shared EAS log for KHOT-FM and KHOV-FM indicated that the EAS equipment was 
not operational for over 6 months, and that personnel for both stations failed to conduct or log a single 
transmitted or received test (monthly or weekly) from any source from September 14, 2001 through 
April 9, 2002. The log also revealed that the designated chief operator did not conduct the weekly 
review of the station’s log. 


747C.F.R.$ 11.1 & 11.21. 


$ 47 C.F.R. § 11.18. State EAS plans contain guidelines that must be followed by broadcast and cable personnel, emergency 
officials and National Weather Service personnel to activate the EAS for state and local emergency alerts. The state plans 
include the EAS header codes and messages to be transmitted by the primary state, local and relay EAS sources. 


247 C.F.R. $ 11.35. 

10 47 C.F.R. $ 11.61(a)(1)(v). At the time of the violations, the Rules required monthly EAS tests to be retransmitted within 
15 minutes of receipt of the required test message. Effective May 16, 2002, the Rules were modified to require monthly EAS 
tests to be retransmitted within 60 minutes of receipt of the required monthly test message. Amendment of Part 11 of' the 
Commission's Rules Regarding the Emergency Alert System, EB Docket No. 01-66, Report and Order, FCC 02-64 (Feb. 26, 
2002); 67 Fed Reg 18502 (April 16, 2002). 

' 47 C.F.R. $ 73.1820(a). 


2 47 C.F.R. Part 11. 


Federal Communications Commission 


10. Based on the evidence, we find that HBC willfully and repeatedly violated Sections 11.35 
and 11.61 of the Rules by failing to maintain operational EAS equipment and failing to comply with 
EAS testing and logging requirements. The base forfeiture amount set by The Commission 's 
Forfeiture Policy Statement and Amendment of Section 1.80 of the Rules to Incorporate the Forfeiture 
Guidelines, (“Forfeiture Policy Statement”),' and Section 1.80 of the Rules, for EAS equipment not 
installed or operational is $8,000. 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 Act, which include the nature, 
circumstances, extent, and gravity of the violation(s), and with respect to the violator, the degree of 
culpability, and 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, an $8,000 
forfeiture is warranted. 


IV. ORDERING CLAUSES 


11. Accordingly, IT IS ORDERED THAT, pursuant to Section 503(b) of the Communications 
Act of 1934, as amended,’ and Sections 0.111, 0.311 and 1.80 of the Commission's Rules, HBC is 
hereby NOTIFIED of an APPARENT LIABILITY FOR A FORFEITURE in the amount of eight 
thousand dollars ($8000) for violations of Sections 11.35(a), 11.35(c) and 11.61 of the Rules.'* 


12. IT IS FURTHER ORDERED THAT, pursuant to Section 1.80 of the Commission's Rules, 
within thirty days of the release date of this NOTICE OF APPARENT LIABILITY, HBC 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 must include the FCC Registration Number (FRN) and the NAL/Acct. No. 
referenced in the caption. 


14. The response, if any, must be mailed to Federal Communications Commission, Enforcement 
Bureau, Technical and Public Safety Division, 445 12° Street, SW, Washington, D.C. 20554 and must 
include the NAL/Acct. No. referenced in the caption. 


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 


3? 12 FCC Red 17087 (1997), recon denied, 15 FCC Red 303 (1999). 
* 47 C.F.R. $ 1.80. 


547 U.S.C. $ 503(b). 


647 C.F.R. $$ 0.111, 0.311, 1.80, 11.35(a), 11.35(c) and 11.61. 


Federal Communications Commission 


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 Receivables Operations Group, 445 12th 
Street, SW, Washington, D.C. 20554." 


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, 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, Technical & Public Safety 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 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 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 HBC License Corporation, 3102 Oak 
Lawn Ave., Suite 215, Dallas, Texas 75219. 


FEDERAL COMMUNICATIONS COMMISSION 


William R. Zears Jr. 
District Director, San Diego Office 


Enc: FCC List of Small Entities 


17 See 47 C.F.R. $ 1.1914. 


Attachment A 


FCC List of Small Entities 


As described below, a “small entity” may be a small organization, 
a small governmental jurisdiction, or a small business. 


October 2002 


(1) Small Organization 


Any not-for-profit enterprise that is independently owned and operated and 
is not dominant in its field. 


(2) Small Governmental Jurisdiction 


Governments of cities, counties, towns, townships, villages, school districts, or 
special districts, with a population of less than fifty thousand. 


(3) Small Business 


Any business concern that is independently owned and operated and 
is not dominant in its field, and meets the pertinent size criterion described below. 


Industry Type Description of Small Business Size Standards 


Cable Services or Systems 


Special Size Standard — 
Cable Systems Small Cable Company has 400,000 Subscribers Nationwide 
or Fewer 


Cable and Other Program Distribution 


Open Video Systems $12.5 Million in Annual Receipts or Less 


Common Carrier Services and Related Entities 


Wireline Carriers and Service providers 


Local Exchange Carriers, Competitive Access 
Providers, Interexchange Carriers, Operator 1,500 Employees or Fewer 
Service Providers, Payphone Providers, and 
Resellers 


Note: With the exception of Cable Systems, all size standards are expressed in either millions of dollars or 
number of employees and are generally the average annual receipts or the average employment of a firm. 
Directions for calculating average annual receipts and average employment of a firm can be found in 

13 C.F.R. §121.104 and 13 C.F.R. $ 121.106, respectively. 


International Services 


International Broadcast Stations 


International Public Fixed Radio (Public and 
Control Stations) $12.5 Million in Annual Receipts or Less 


Fixed Satellite Transmit/Receive Earth Stations 


Fixed Satellite Very Small Aperture Terminal 
Systems 


Mobile Satellite Earth Stations 


Radio Determination Satellite Earth Stations 


Geostationary Space Stations 


Non-Geostationary Space Stations 


Direct Broadcast Satellites 


Home Satellite Dish Service 


Mass Media Services 


Television Services 


Low Power Television Services and Television 
Translator Stations 


TV Auxiliary, Special Broadcast and Other 
Program Distribution Services 


$12 Million in Annual Receipts or Less 


Radio Services 


Radio Auxiliary, Special Broadcast and Other 
Program Distribution Services 


$6 Million in Annual Receipts or Less 


Multipoint Distribution Service 


Auction Special Size Standard — 
Small Business is less than $40M in annual gross revenues 
for three preceding years 


Wireless and Commercial Mobile Services 


Cellular Licensees 


220 MHz Radio Service — Phase I Licensees 


1,500 Employees or Fewer 


220 MHz Radio Service — Phase II Licensees 


700 MHZ Guard Band Licensees 


Private and Common Carrier Paging 


Auction special size standard - 

Small Business is average gross revenues of $15M or less for 
the preceding three years (includes affiliates and controlling 
principals) 

Very Small Business is average gross revenues of $3M or 
less for the preceding three years (includes affiliates and 
controlling principals) 


Broadband Personal Communications Services 
(Blocks A, B, D, and E) 


1,500 Employees or Fewer 


Broadband Personal Communications Services 
(Block C) 


Broadband Personal Communications Services 
(Block F) 


Narrowband Personal Communications Services 


Auction special size standard - 

Small Business is $40M or less in annual gross revenues for 
three previous calendar years 

Very Small Business is average gross revenues of $15M or 
less for the preceding three calendar years (includes affiliates 
and persons or entities that hold interest in such entity and 
their affiliates) 


Rural Radiotelephone Service 


Air-Ground Radiotelephone Service 


1,500 Employees or Fewer 


800 MHz Specialized Mobile Radio 


900 MHz Specialized Mobile Radio 


Auction special size standard - 
Small Business is $15M or less average annual gross 
revenues for three preceding calendar years 


Private Land Mobile Radio 


1,500 Employees or Fewer 


Amateur Radio Service 


N/A 


Aviation and Marine Radio Service 


Fixed Microwave Services 


1,500 Employees or Fewer 


Public Safety Radio Services 


Small Business is 1,500 employees or less 
Small Government Entities has population of less than 
50,000 persons 


Wireless Telephony and Paging and Messaging 


1,500 Employees or Fewer 


Personal Radio Services 


N/A 


Offshore Radiotelephone Service 


1,500 Employees or Fewer 


Wireless Communications Services 


39 GHz Service 


Small Business is $40M or less average annual gross 
revenues for three preceding years 

Very Small Business is average gross revenues of $15M or 
less for the preceding three years 


Multipoint Distribution Service 


Auction special size standard (1996) — 

Small Business is $40M or less average annual gross 
revenues for three preceding calendar years 

Prior to Auction — 

Small Business has annual revenue of $12.5M or less 


Multichannel Multipoint Distribution Service 


Instructional Television Fixed Service 


$12.5 Million in Annual Receipts or Less 


Local Multipoint Distribution Service 


Auction special size standard (1998) — 

Small Business is $40M or less average annual gross 
revenues for three preceding years 

Very Small Business is average gross revenues of $15M or 
less for the preceding three years 


218-219 MHZ Service 


First Auction special size standard (1994) — 

Small Business is an entity that, together with its affiliates, 
has no more than a $6M net worth and, after federal income 
taxes (excluding carryover losses) has no more than $2M in 
annual profits each year for the previous two years 

New Standard — 

Small Business is average gross revenues of $15M or less for 
the preceding three years (includes affiliates and persons or 
entities that hold interest in such entity and their affiliates) 
Very Small Business is average gross revenues of $3M or 
less for the preceding three years (includes affiliates and 
persons or entities that hold interest in such entity and their 
affiliates) 


Satellite Master Antenna Television Systems 


$12.5 Million in Annual Receipts or Less 


24 GHz — Incumbent Licensees 


1,500 Employees or Fewer 


24 GHz — Future Licensees 


Small Business is average gross revenues of $15M or less for 
the preceding three years (includes affiliates and persons or 
entities that hold interest in such entity and their affiliates) 
Very Small Business is average gross revenues of $3M or 
less for the preceding three years (includes affiliates and 
persons or entities that hold interest in such entity and their 
affiliates) 


Miscellaneous 


On-Line Information Services 


$18 Million in Annual Receipts or Less 


Radio and Television Broadcasting and Wireless 
Communications Equipment Manufacturers 


Audio and Video Equipment Manufacturers 


750 Employees or Fewer 


Telephone Apparatus Manufacturers (Except 
Cellular) 


1,000 Employees or Fewer 


Medical Implant Device Manufacturers 


500 Employees or Fewer 


Hospitals 


$29 Million in Annual Receipts or Less 


Nursing Homes 


$11.5 Million in Annual Receipts or Less 


Hotels and Motels 


$6 Million in Annual Receipts or Less 


Tower Owners 


(See Lessee’s Type of Business)