Articles Posted in FCC Enforcement

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October 2013

Pillsbury’s communications lawyers have published FCC Enforcement Monitor monthly since 1999 to inform our clients of notable FCC enforcement actions against FCC license holders and others. This month’s issue includes:

  • Online Public File Violations and Failure to Respond Result in $14,400 Fine
  • Unlicensed Broadcast Operation Draws $7,000 Fine
  • Fines Continue for Class A Children’s Television Violations

Licensee Fined for Public Inspection File Violations and Failure to Respond to FCC Inquiries
The FCC issued a Forfeiture Order in the amount of $14,400 to a California television licensee for failing to keep its online public inspection file up to date and for not responding to the FCC’s letters of inquiry.

Earlier this year, the FCC issued a Notice of Apparent Liability for Forfeiture (“NAL”) against the licensee, asserting that the station had failed to place required documentation in its online public inspection file and failed to respond to FCC letters of inquiry. The NAL concluded that the licensee should be assessed a $16,000 forfeiture for these violations, which was comprised of $10,000 for the public file violation and $6,000 for failure to respond to the FCC’s correspondence. Although the usual penalty for failure to respond is $4,000, the FCC imposed the higher penalty of $6,000 on this licensee because its “misconduct was egregious and repeated.”

The licensee timely responded to the NAL and argued against the imposition of a $16,000 fine. The FCC rejected all but the last of the station’s arguments. First, the FCC disagreed with the licensee’s argument that uploading documents into its online inspection file was unnecessary because of their availability at the station’s main studio, noting that “the online public file is a crucial source of information for the public.” Second, the FCC noted that providing the FCC with updated contact information is the responsibility of the licensee, and therefore rejected the licensee’s argument that the station’s failure to reply to FCC letters sent to an outdated address was unintentional. Third, the FCC ignored the licensee’s argument that paying a fine would impose a financial hardship, as the station declined to provide the required documentation of its financial status. Ultimately, however, the FCC agreed to reduce the fine from $16,000 to $14,400 in light of the station’s history of compliance with the FCC’s Rules.

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September 2013

Pillsbury’s communications lawyers have published FCC Enforcement Monitor monthly since 1999 to inform our clients of notable FCC enforcement actions against FCC license holders and others. This month’s issue includes:

  • FCC Assesses Substantial Fine for Antenna Lighting Outage
  • Big Fines for Children’s Television Violations

Failure to Monitor Antenna Lighting Costly

The FCC issued a Notice of Apparent Liability for Forfeiture (NAL) in the amount of $20,000 to an Alaskan telecommunications company for tower lighting violations.

The height of the antenna structure placed it within the jurisdiction of both the FAA and the FCC. FAA rules required the structure to have dual lighting: red lights at night and medium intensity flashing white lights during the daytime and at twilight.

The company’s troubles began when an agent from the FCC’s Anchorage Enforcement Bureau office observed that the tower was unlit during the daytime. The FCC agent contacted the FAA, which confirmed that no Notice to Airmen (NOTAM) had been issued for the lighting outage. Tower operators are required to notify the FAA immediately of any lighting outage lasting more than 30 minutes. The FCC agent also alerted the tower owner of the situation. According to the FCC, the owner did not appear to have a functioning monitoring system for the tower lighting.

The NAL cited the owner’s failure to visually monitor obstruction lighting on a daily basis or to maintain a functioning alarm system. In response, the owner acknowledged the violation and stated it had identified the source of the problem to be a failing capacitor on the system’s control board. It then replaced the failing component and installed a remote monitoring and alarm system for the antenna structure.

The base fine for failing to comply with tower lighting and monitoring requirements and for failing to provide notification of extinguished lights is $10,000. The NAL stated that the fine was increased to $20,000 as part of the FCC’s policy of fining “large” companies larger dollar amounts to ensure that the fine “is a deterrent and not simply a cost of doing business.”

FCC Actively Pursuing Kidvid Violations

This month, the FCC has once again been bringing enforcement actions against a number of Class A stations for failure to timely file Children’s Television Programming Reports on FCC Form 398. The Commission has issued at least ten NALs for Kidvid violations since the beginning of this month.

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August 2013

Pillsbury’s communications lawyers have published FCC Enforcement Monitor monthly since 1999 to inform our clients of notable FCC enforcement actions against FCC license holders and others. This month’s issue includes:

  • FCC Catches GPS Jammer at Airport
  • $75,000 Consent Decree Adopted for Class A TV Violations

Jamming Device in Truck Disrupts GPS Navigation at Newark Liberty International Airport

On August 1, 2013, the FCC issued a Notice of Apparent Liability for Forfeiture (NAL) in the amount of $31,875 to an individual in New Jersey for repeated use of a GPS jamming device. The individual had installed a signal jammer in his company-supplied truck, apparently to prevent his employer’s GPS tracking system from knowing his whereabouts.

While use of a signal jammer is itself illegal, the offender compounded his troubles when his GPS signal jammer interfered with the navigation signals at the Port Authority of New York and New Jersey. The FCC’s investigation into this matter arose when the FCC was contacted by the Federal Aviation Administration on behalf of the Port Authority. The FAA reported that the Port Authority had been experiencing interference in testing a ground-based aviation navigation system at Newark Liberty International Airport.

At that airport–one of the busiest in the nation, according to the FCC–an agent from the FCC’s New York Enforcement Bureau office determined that a red Ford pickup truck was emanating radio signals within the restricted 1559 to 1610 MHz band used by GPS satellites. The driver was stopped by Port Authority police at the airport gate. He then surrendered the jamming device to the FCC agent, and the interference with Newark’s navigation equipment ceased.

In determining the appropriate penalty, the FCC found three separate violations of its rules: (1) operating the transmission equipment without a license; (2) using unauthorized equipment; and (3) interfering with authorized communications, which was of particular concern in this case, with repeated and dangerous interference to critical air navigation equipment. That the signal jammer was truck-mounted also caused great concern, as its mobile nature made the interference widespread and its source difficult for authorities to locate and eliminate. Simply driving around the area could have had disastrous effects on GPS-based systems for aircraft.

In light of these concerns, the FCC issued a substantial upward adjustment to the normal base fine of $22,000, resulting in a total fine of $42,500. However, it then decided to lower the fine to $31,875 (a 25% reduction) because the individual voluntarily handed over the illegal device. The FCC indicated that it wanted to provide “incentives” for parties to do the same in the future.

Pittsburgh-Based Stations Pay Big for Kidvid and Other Violations

This week, the FCC pursued a Pittsburgh-area group of ten Class A television stations for failure to file, or to timely file, their children’s programming reports with the FCC, as well as for being silent without authorization. In addition to the kidvid violations, some of which had gone on for several years, the FCC states that the stations had, at various times, applied to go silent and proceeded to do so without first obtaining the necessary FCC authorization.

The matter was settled by consent decree, which included a voluntary contribution to the U.S. Treasury of $75,000. Not coincidentally, the licensee of the stations was in the process of selling them, and needed FCC approval to complete that transaction. The FCC granted the assignment application in the same order in which it adopted the consent decree.

This case is merely the latest in a continuing effort by the FCC to crack down on rule violations by Class A TV stations. In this case, by entry into the consent decree, the stations were able to avoid the imposition of fines and the risk of losing their Class A status. In addition to being subject to displacement by full-power TV stations, stations that lose their Class A status forfeit their eligibility to participate in the spectrum incentive auction (and to avoid being repacked out of existence subsequent to that auction).

Given this risk, Class A TV licensees should ensure they are in full compliance with the FCC’s rules to maintain their Class A eligibility. To be eligible for Class A status, the Community Broadcasters Protection Act of 1999 and the Commission’s rules implementing it require that Class A stations: (1) operate a minimum of 18 hours per day; (2) air an average of at least 3 hours per week of programming produced within the market area served by the station; and (3) comply with the Commission’s rules for full-power television stations.

A PDF version of this article can be found at FCC Enforcement Monitor.

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July 2013

Pillsbury’s communications lawyers have published FCC Enforcement Monitor monthly since 1999 to inform our clients of notable FCC enforcement actions against FCC license holders and others. This month’s issue includes:

  • FCC Issues “Lighting Fixture” Citation
  • Consent Decree Adopted for Sponsorship ID Violation

FCC Issues Citation to Credit Union for Operating Lighting Fixtures Causing Harmful Interference to Licensed Communications

On July 17, 2013, the FCC issued a citation to the Caribe Federal Credit Union (“CFCU”) in San Juan, Puerto Rico for operating incidental radiators and causing harmful interference to licensed communications in violation of the FCC’s rules. The FCC’s investigation into this matter arose after receiving complaints of interference from an FCC licensee.

On June 12, 2013, an agent of the FCC’s San Juan Office of the Enforcement Bureau used direction finding techniques to determine that the interference, which was transmitting on 712.5 MHz, originated from the CFCU building at 193-195 O’Neill Street, San Juan, Puerto Rico. After further testing, the FCC agent determined that the particular source of the transmission was the interior lighting on the highest ceiling in the building (fifteen light fixtures about 40 feet above the floor).

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June 2013

Pillsbury’s communications lawyers have published FCC Enforcement Monitor monthly since 1999 to inform our clients of notable FCC enforcement actions against FCC license holders and others. This month’s issue includes:

  • FCC Issues Heavy Fines for Late-Filed Children’s Television Programming Reports
  • Motel with Multichannel Video Programming Distribution System Is Cited for Excessive Cable Signal Leakage

FCC Fines Multiple Licensees for Failure to Timely File Children’s Television Programming Reports

As broadcasters have learned, the FCC takes licensees’ public inspection file and reporting obligations very seriously. This month, the FCC issued multiple Notices of Apparent Liability for Forfeiture (“NAL”) against licensees for failing to file Children’s Television Programming Reports on Form 398 in a timely manner. On June 18 and 21, the FCC issued a total of seven decisions proposing to fine stations between $3,000 and $18,000 for not filing their Form 398s on time.

Under the FCC’s rules, commercial television stations must report their children’s educational and informational broadcast programming efforts each quarter by electronically filing FCC Form 398, the Children’s Television Programming Report. Historically, the FCC has fined stations for failing to file their reports, and there would be nothing new about the FCC issuing an NAL for “failure to file”.

In these seven cases, however, the stations were not fined for a failure to file their reports, but for failing to file their reports on time. In the decisions, the FCC issued the following fines:

  • For a station that missed the filing deadline twenty-three times, the FCC issued an NAL in the amount of $18,000.
  • For a licensee that missed the filing deadline eleven times on one station and thirteen times on another, the FCC issued an NAL in the amount of $15,000.
  • For a station that missed the filing deadline fourteen times, the FCC issued an NAL in the amount of $9,000.
  • For a station that missed the filing deadline ten times, the FCC issued an NAL in the amount of $9,000 (eight reports were filed more than 30 days late).
  • For a station that missed the filing deadline three times, the FCC issued an NAL in the amount of $6,000 (three reports were filed more than 30 days late).
  • For a station that missed the deadline sixteen times, the FCC issued an NAL in the amount of $6,000.
  • For a station that missed the filing deadline eleven times, the FCC issued an NAL in the amount of $3,000.

The cases were all relatively similar. As an example, in the $15,000 NAL, the licensee filed license renewal applications for its two Class A TV stations. At the time of the applications, the licensee did not disclose that it had filed some of its Children’s Television Programming Reports late, and in fact, certified in its renewal applications that it had timely filed all relevant programming reports with the FCC. However, the Commission subsequently reviewed its records and found that the licensee failed to file programming reports on time for 11 quarters for one station and 13 quarters for another.

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We now know what the per-subscriber fee for cable systems lacking retransmission agreements with local broadcast stations is, and it isn’t “free”.

Section 76.64 of the FCC’s Rules requires cable systems to have a written retransmission agreement in place before retransmitting the signal of a station that elected retransmission consent status. Because the law is clear on this point (for a differing view, see Aereo), there have been few cases where the FCC has had to address complaints of illegal retransmission.

In the first of these cases, the FCC found the cable system violated its obligation to negotiate in good faith with the broadcaster and ordered retransmission to cease until an agreement was in place. Two later cases for a pair of 34-day violations against one cable system operator resulted in base fine calculations of $255,000 each, but the FCC reduced the fines to $15,000 each based upon the cable system operator’s inability to pay.

Today, the FCC upped the ante, proposing a fine of $2.25 million for TV Max, Inc. and related parties for retransmitting six local TV stations to 245 multiple dwelling unit buildings in Houston without a retransmission agreement. Despite having previously had retransmission agreements with all of the stations, the cable system operator claimed it now qualified for an exemption from the retransmission agreement requirement because it had installed a master antenna on each of the buildings, allowing residents to obtain the broadcast signals for free over-the-air. Each of the six stations filed a complaint with the FCC, noting that the respective retransmission agreements with the cable system operator had expired or been terminated for non-payment, but that retransmission was continuing.

On December 20, 2012, following an investigation, the FCC’s Media Bureau issued a letter to TV Max stating its “initial finding that TV Max had willfully and repeatedly violated, and continued to violate, the Commission’s retransmission consent rules, and stating that it planned to recommend that the Commission issue a Notice of Apparent Liability for Forfeiture for these violations.” The Media Bureau later followed up with a March 28, 2013 letter to all of the parties asking for the status of carriage and whether retransmission agreements were now in place. While the stations all responded that they were still being carried without their consent, TV Max indicated it had not retransmitted the stations over its fiber since June 7, 2012.

That led to today’s Notice of Apparent Liability for Forfeiture and Order. In its decision, the FCC found that some of the cable system operator’s statements to the FCC were “lacking in candor”. Specifically, the FCC concluded that the cable system had continued to retransmit the stations over its fiber and had not installed master antennas on all of its buildings by the time it claimed to have ceased fiber retransmission:

Based upon the evidence before us, and in view of the applicable law and Commission precedent, we conclude that TV Max has willfully and repeatedly violated Section 325 of the Act and Section 76.64 of the Commission’s rules, and persists in its violation of these provisions, by retransmitting the Stations’ signals without the express authority of the originating stations. As discussed below, the violations are based on (1) TV Max’s admitted carriage of the Stations from the time their retransmission consent agreements expired through at least July 25, 2012 without the Stations’ consent and without a master antenna television (MATV) system in place in all the buildings it serves; and (2) TV Max’s ongoing carriage of the Stations without their consent since July 26, 2012 because it was not exclusively using its MATV facilities to retransmit the broadcast signals to its subscribers.

While the precise length of time any particular station was carried without a retransmission agreement varied, the FCC noted in its decision that Section 503 of the Communications Act limits its ability to issue fines for cable violations occurring more than one year ago. As a result, the FCC based its proposed fine on 365 days worth of violations involving six stations. While the decision is a bit fuzzy on the precise math behind the final number (particularly given that the maximum fine is much higher than the fine proposed), a little reverse engineering provides some real-world context for a $2.25 million fine.

The FCC notes that the system has about 10,000 subscribers, that six stations were carried without a retransmission agreement, and that the fine reflected one year’s worth of violations. That works out to a monthly retransmission “fee” of $3.13 per subscriber for each station (apparently the federal government has less negotiating leverage than ESPN). Still, that is more than the cable system operator would have paid under an arms-length negotiated broadcast retransmission agreement. Unfortunately for the affected stations, however, payment of the fine goes to the U.S. Government rather than to the television stations.

On the other hand, retransmitting programs without consent is also a copyright violation, meaning that stations pursuing copyright claims against the cable system operator could add significantly to the operator’s financial pain. Such are the risks of reinterpreting the breadth of the Communications Act’s retransmission consent requirements (see Aereo?).

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May 2013

Pillsbury’s communications lawyers have published FCC Enforcement Monitor monthly since 1999 to inform our clients of notable FCC enforcement actions against FCC license holders and others. This month’s issue includes:

  • FCC Establishes New Enforcement Policy for Student-Run Noncommercial Radio Stations
  • CB Radio Owner Receives Fine for Harmful Interference and Lack of Responsiveness

Student-Run Noncommercial Radio Stations Will Face Lighter Sanctions on Some FCC Enforcement Actions

In a recent Policy Statement and Order, the FCC established a new policy for certain first-time violations of FCC documentation requirements committed by student-run noncommercial radio stations. The new policy allows such stations the option of entering into a Consent Decree with the FCC that includes a compliance plan and a “voluntary” contribution to the government that is smaller than the typical base fines for these violations.

In justifying its more lenient policy toward student-run stations, the FCC noted that such stations are staffed by a continually changing roster of young students lacking experience in regulatory compliance. In addition, such stations function without any professional oversight other than that provided by over-worked faculty advisors, and often operate with budgets so small that they are exceeded by even the base fine for a public inspection file violation. In the past, the FCC has issued numerous fines of $8,000-$10,000 to licensees of student-run stations, and with this new policy, the FCC recognizes that continuing to impose such fines could result in schools selling their stations altogether, as has indeed happened.

In the past, the FCC rejected arguments that fines on student-run stations should be reduced solely because the stations are run by students. The FCC has also typically rejected “inability to pay” arguments for these types of stations, and instead looked at the financial resources of the entire university or college, rather than the financial resources of the station, when assessing a fine. However, the FCC now concludes that allowing the cost of a first-time documentation violation to be reduced in exchange for a consent decree with a compliance plan will actually improve compliance with the FCC’s rules. Specifically, the FCC believes that such compliance plans will assist in the training of students while contributing to the educational function of these stations.

In its Policy Statement, the FCC emphasized that the policy will apply only to student-run noncommercial radio stations where the station is staffed completely by students. Stations that employ any professional staff, other than faculty advisors, do not qualify. The policy is also limited to violations where a student-run station has failed to (a) file required materials with the FCC (e.g., an Ownership Report), (b) place required materials in the public inspection file, or (c) publish a notice in a local newspaper or broadcast an announcement on the air. This new policy will not change the FCC’s forfeiture policies for any other type of violation or licensee.

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A few minutes ago, the FCC issued a Public Notice granting a thirty-day extension of the deadlines for submitting comments and reply comments in response to the FCC’s April 1, 2013 Public Notice seeking input on whether the Commission should make changes to its current broadcast indecency policies. Comments and reply comments were originally due on May 20 and June 18, 2013, respectively, but have now been extended to June 19, 2013 (comments) and July 18, 2013 (reply comments). The extension was granted in response to a Motion filed by the National Association of Broadcasters on April 26, 2013.

Scott Flick of our office posted a detailed analysis of the Public Notice early last month. To refresh your memory, the Public Notice (jointly released by the FCC’s Enforcement Bureau and General Counsel’s Office) was issued in response to FCC Chairman Genachowski’s request that FCC staff review the “Commission’s broadcast indecency policies and enforcement to ensure they are fully consistent with vital First Amendment principles.”

With respect to guidance for parties planning to file comments, the quoted language below from the Public Notice describes the matters on which the FCC is seeking comment:

  1. [W]hether the full Commission should … treat isolated expletives in a manner consistent with our decision in Pacifica Foundation, Inc., Memorandum Opinion and Order, 2 FCC Rcd 2698, 2699 (1987) (“If a complaint focuses solely on the use of expletives, we believe that . . . deliberate and repetitive use in a patently offensive manner is a requisite to a finding of indecency.”)?
  2. Should the Commission instead maintain the approach to isolated expletives set forth in its decision in Complaints Against Various Broadcast Licensees Regarding Their Airing of the “Golden Globe Awards” Program, Memorandum Opinion and Order, 19 FCC Rcd 4975 (2004)?
  3. As another example, should the Commission treat isolated (non-sexual) nudity the same as or differently than isolated expletives?

The Public Notice also states that parties are invited “to address these issues as well as any other aspect of the Commission’s substantive indecency policies.” As Scott pointed out in his analysis last month, this final question appears to open the door to a broader review of indecency doctrine than the FCC has engaged in for quite some time.

Given the controversy the FCC’s indecency policies have historically generated, you can expect to see plenty of comments filed on June 19 and reply comments on July 18 by parties on all sides of this issue. As the FCC moves toward new leadership with the departure of Chairman Genachowski, the FCC’s indecency enforcement policies could take some interesting turns.

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After nine months of rumors and uncertainty as to where the FCC is headed after last summer’s indecency decision by the Supreme Court in FCC v. Fox Television Stations, Inc. (which we discussed in this post), the FCC today released a very brief public notice that:

  1. Announces the FCC staff has disposed of over one million indecency complaints (which it states is over 70% of those that were pending at the FCC), “principally by closing pending complaints that were beyond the statute of limitations or too stale to pursue, that involved cases outside FCC jurisdiction, that contained insufficient information, or that were foreclosed by settled precedent.”
  2. Announces that the FCC will continue to actively investigate “egregious indecency cases.”
  3. Announces that it is opening up a new docket (GN Docket No. 13-86), and is seeking comments from the public in that docket as to whether the FCC should change its broadcast indecency policies, and if so, how. While not limiting the breadth of potential changes, the FCC specifically asks whether it is time to go back to the old policy of prosecuting on-air expletives only where there is “deliberate and repetitive use in a patently offensive manner,” or stick with the more recent policy of pouncing on a single fleeting expletive, the policy that led to the Supreme Court’s 2012 decision. The Public Notice also asks if the FCC should treat “isolated (non-sexual) nudity the same or different than isolated expletives?”
  4. Finally, emphasizing again the broad nature of the FCC’s proposed review, the Public Notice asks commenters “to address these issues as well as any other aspect of the Commission’s substantive indecency policies.”

The Public Notice indicates that comments will be due 30 days after the request for comments is published in the Federal Register, with reply comments being due 30 days after that.

While the timing of the Public Notice, just ahead of Chairman Genachowski’s (and Commissioner McDowell’s) announced departure from the FCC, is interesting, more interesting is the “spontaneous” look of the document. In an agency that can readily produce requests for comments that are hundreds of pages long, and on a subject that has produced reams of pleadings and precedent over several decades, the substantive portion of the Public Notice is but a few paragraphs long–a few paragraphs that open the door to a fundamental rethinking of the FCC’s approach to indecency.

The Public Notice therefore has the look of a document that was not long in the making, and which may have emerged as result of a departing Chairman beginning to move the ball forward for his successor. The process forward will likely be complex and arduous, and the ultimate result is anyone’s guess, but by at least launching the proceeding before his departure, Chairman Genachowski will absorb some of the political heat that could have otherwise fallen on his successor, while also challenging that successor to address an issue that has become a significant distraction and consumer of increasingly scarce FCC resources.

While also a result of its brevity, the lack of any “initial” or “tentative” conclusions by the FCC in the document gives the impression that the FCC may indeed be ready to commence a fundamental reexamination of indecency policy, and is not just going through the motions of collecting comments before proceeding on a largely predetermined route. It is not asking so much how it should proceed in light of the Supreme Court’s decision, but how it should proceed in general. For those who loudly proclaim that the FCC has failed in its duties as a “content cop”, as well as broadcasters struggling to figure out on a minute by minute basis what program content might cross the FCC’s invisible indecency line, a fresh look at the issue will be welcome. Whether this “reset” can resolve the many tough questions surrounding indecency enforcement is, however, another question entirely.

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March 2013

Pillsbury’s communications lawyers have published FCC Enforcement Monitor monthly since 1999 to inform our clients of notable FCC enforcement actions against FCC license holders and others. This month’s issue includes:

  • Delay in Providing Access to Public Inspection File Leads to Fine
  • FCC Fines Broadcaster for Antenna Tower Fencing, EAS and Public Inspection File Violations

Radio Station Fined $10,000 for Not Providing Immediate Access to Public File

This month, the Enforcement Bureau of the FCC issued a Notice of Apparent Liability for Forfeiture and Order (“NAL”) in the amount of $10,000 against a Texas noncommercial broadcaster for failing to promptly make its public inspection file available. For the delay of a few hours, the Commission proposed a fine of $10,000 and reminded the licensee that stations must make their public inspection file available for inspection at any time during regular business hours and that a simple request to review the public file is all it takes to mandate access.

According to the NAL, an individual from a competitor arrived at the station at approximately 10:45 a.m. and asked to review the station public inspection file. Station personnel informed the individual that the General Manager could give him access to the public files, but that the General Manager would not arrive at the station until “after noon.” The individual returned to the studio at 12:30 p.m.; however, the General Manager had still not arrived at the studio. According to the visiting individual, the receptionist repeatedly asked him if he “was with the FCC.” Ultimately, the receptionist was able to reach the General Manager by phone, and the parties do not dispute that at that time, the individual asked to see the public file. During that call, the General Manager told the receptionist to give the visitor access to the file. According to the visitor, when the General Manager finally arrived, he too asked if the individual was from the FCC, and then proceeded to monitor the individual’s review of the public file.

After the station visit, the competitor filed a Complaint with the FCC alleging that the station public files were incomplete and that the station improperly denied access to the public inspection files. The FCC then issued a Letter of Inquiry to the station, requesting that the station respond to the allegations and to provide additional information. The station denied that any items were missing from the public file and also denied that it failed to provide access to the files.

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