**Before the**

**Federal Communications Commission**

Washington, D.C. 20554

+----------------------------------+----+------------------------------+
| In the Matter of                 | *  | NAL/Acct. No.                |
|                                  | *) | MB-200841410041              |
| # Cumulus Licensing LLC          | ** |                              |
|                                  |    | FRN: 0002834810              |
| Licensee of Stations             | *  |                              |
|                                  | *) | Facility I.D. No. 52551      |
| WPEZ(FM), Jeffersonville,        | ** |                              |
| Georgia                          |    | Facility I.D. No. 68679      |
|                                  | *  |                              |
| WIFN(FM) (Formerly WAYS(FM)),    | *) | Facility I.D. No. 52546      |
|                                  | ** |                              |
| Macon, Georgia                   |    | Facility I.D. No. 68678      |
|                                  | *  |                              |
| WDDO(AM), Macon, Georgia         | *) | Facility I.D. No. 46996      |
|                                  | ** |                              |
| WAYS(AM) (Formerly WWFN(AM)),    |    | Facility I.D. No. 46998      |
|                                  | *  |                              |
| Macon, Georgia                   | *) | Facility I.D. No. 88541      |
|                                  | ** |                              |
| WDEN-FM, Macon, Georgia          |    | Facility I.D. No. 54672      |
|                                  | *  |                              |
| WMAC(AM), Macon, Georgia         | *) |                              |
|                                  | ** |                              |
| WMGB(FM), Montezuma, Georgia     |    |                              |
|                                  | *  |                              |
| WLZN(FM) (Formerly WMKS (FM)),   | *) |                              |
|                                  | ** |                              |
| Macon, Georgia                   |    |                              |
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+----------------------------------+----+------------------------------+

**NOTICE OF Apparent Liability for Forfeiture**

**Adopted: September 17, 2008 Released: December 30, 2008**

By the Commission: Commissioners Copps and Adelstein issuing a joint
statement.

**I. INTRODUCTION**

1\. In this *Notice of Apparent Liability for Forfeiture ("NAL")* issued
pursuant to Section 503(b) of the Communications Act of 1934, as amended
(the "Act"), and Section 1.80 of the Commission's Rules (the
"Rules"),[^1] we find that Cumulus Licensing LLC (the "Licensee"),
licensee of Stations WPEZ(FM), Jeffersonville, Georgia; WIFN(FM)
(formerly WAYS (FM)), Macon, Georgia; WDDO(AM), Macon, Georgia; WAYS(AM)
(formerly WWFN(AM)), Macon, Georgia; WDEN-FM, Macon, Georgia; WMAC(AM),
Macon, Georgia; WMGB(FM), Montezuma, Georgia; and WLZN(FM) (formerly
WMKS(FM)), Macon, Georgia (collectively, the "Stations" and each a
"Station"), apparently willfully and repeatedly violated Sections
73.2080(c)(2), 73.2080(c)(3), 73.2080(c)(5), 73.2080(c)(6)(iii),
73.2080(c)(6)(iv), and 73.3526(e)(7) of the Commission's Rules[^2] by
failing to comply with the Commission's Equal Employment Opportunity
("EEO") record-keeping, recruitment source information, interviewee
information, EEO initiative, self-assessment, and public file
requirements. Based upon our review of the facts and circumstances
before us, we conclude that the Licensee is apparently liable for a
monetary forfeiture in the amount of fourteen thousand dollars
(\$14,000). We also impose reporting conditions on the Licensee and any
successor Licensee of any of the Stations that are or may be included in
the employment unit, to prevent future violations of these requirements.

**II. BACKGROUND**

2\. Section 73.2080(c)(1) of the Rules requires that a broadcast
licensee recruit for every full-time job vacancy in its employment unit
operation. In this regard, the Rules impose, *inter alia*, the following
respective obligations on such licensees:

-   Section 73.2080(c)(2): complete two recruitment initiatives (if in a
    small market) over two years;

-   Section 73.2080(c)(3): analyze the recruitment program for the
    licensee's unit on an ongoing basis to ensure that it is effective
    in achieving broad outreach to potential applicants, and address any
    problems found as a result of its analysis;

-   Section 73.2080(c)(5): retain records of its EEO efforts;

-   Section 73.2080(c)(6)(iii): maintain recruitment source data; and

-   Section 73.2080(c)(6)(iv): maintain interviewee data.

In addition, Section 73.3526(e)(7) requires commercial licensees to
include certain EEO-related materials in their station public files,
including that noted above.

3\. *EEO Review.* By letter dated June 7, 2006, the Media Bureau ("the
Bureau") notified the Licensee that it had been randomly selected for an
audit of its EEO program.[^3] The Commission has before it the
Licensee's response to the audit.[^4] The Licensee reports that its
record-keeping in the Macon, Georgia, market was unsatisfactory in 2004
and 2005.[^5] The Licensee states that poor record-keeping during those
two years made it difficult, if not impossible, for it to accurately
report on its EEO public file reports the number of individuals
interviewed for full-time openings in 2004 and 2005 and how those that
filled full-time positions in 2004 learned about the openings.[^6] Our
review of the Licensee's public file reports during the periods at issue
(December 1, 2003, through November 30, 2004, and December 1, 2004,
through November 30, 2005) ("2004 report" and "2005 report,"
respectively), reveals that the Licensee did not retain adequate EEO
records of interviewees and referrals, as required by Section
73.2080(c)(5), and did not produce documentation of the recruitment
initiatives it was required to complete, as required by Section
73.2080(c)(2). The 2004 report also fails to list any information
regarding the total number of interviewees and the recruitment source
for interviewees for each of the vacancies filled, in violation of
Section 73.2080(c)(6)(iv). The report shows eight vacancies filled in
this time period but other records produced by the Licensee in its audit
response indicate that two additional hires took place, so the correct
total of hires for the 2004 report appears to be 10. The 2005 report
lists the recruitment source for all 11 hirees in the reporting period,
but does not include any information regarding the total number of
interviewees and the interviewee referral sources for the positions
filled, as required by Sections 73.2080(c)(6)(iv) and
73.2080(c)(6)(iii). In addition, for its hires during both reporting
periods, the Licensee produced some of the job notices it sent to
sources, but almost none of the notices indicated which source received
the notices, thus indicating that the Licensee did not have complete
copies of all job notices, as required by Section 73.2080(c)(5)(iii).
The Licensee was able to provide documentation showing completion of one
recruitment initiative in the 2004-2005 year but submitted no
information regarding any other recruitment initiatives during the
2003-2005 period, in violation of Section 73.2080(c)(2). Also, the
Licensee's deficiencies in retaining records relating to its EEO
requirements reveal an apparent lack of self-assessment for EEO
compliance during the 2004 and 2005 periods, in violation of Section
73.2080(c)(3). Finally, because of the Licensee's incomplete records, it
was not able to include all required information in the public
inspection files of each station, in violation of Sections 73.3526(e)(7)
and 73.2080(c)(6).

**III. DISCUSSION**

4\. We conclude that the Licensee failed to maintain adequate
recruitment records for all of its vacancies for its 2003-2004 and
2004-2005 reporting periods, as required by Section 73.2080(c)(5). The
Licensee filled ten vacancies in its 2003-2004 reporting period, and 11
vacancies in the 2004-2005 reporting period. The Licensee reported that
it had no interviewee or referral information for seven of the eight
vacancies reported in the 2004 reporting period, and the record further
fails to include any interviewee or referral information for two hires
that were not listed on the 2004 report but were indicated elsewhere in
the Licensee's audit response.[^7] In the 2005 public file report, the
Licensee provided the recruitment referral source for its 11 hirees but
was unable to provide information regarding the total number of job
applicants interviewed and the recruitment referral source for the
interviewees for those positions. Also in the 2005 report, the licensee
provided information for only one recruitment initiative of the two it
was required to complete in the 2003-2005 period in accordance with
Section 73.2080(c)(2). The Licensee admits in its response that it is
unable to document all of its supplemental recruitment initiatives for
the reporting periods at issue.[^8] Furthermore, the Licensee's records
for the majority of its job notices were incomplete, failing to indicate
the sources to which they were sent, as required by Section
73.2080(c)(5)(iii).

5\. We find that the Licensee's 2004 and 2005 public file reports and
audit response indicate that it did not retain adequate records of
interviewees and referrals or job notices, as required by Section
73.2080(c)(5). We also find that the Licensee did not produce
documentation of one of the two recruitment initiatives it was required
to complete, as required by Section73.2080(c)(5). Because of the
Licensee's lack of records of interviewees, referrals, and job notices,
and its failure to document completion of one of its two required
recruitment initiatives, we find that it was not possible for it to have
adequately analyzed its recruitment program to ensure that it was
effective in achieving broad outreach, in violation of Section
73.2080(c)(3). Finally, we find that it failed to place all of the
required information in the public inspection files of the stations, as
required by Sections 73.3526(e)(7) and 73.2080(c)(6).

6\. The Licensee reports that it revised its EEO program "toward the end
of 2005" and now follows an EEO program that includes advertising each
full-time position over the air on all eight Cumulus stations in the
Macon, Georgia, market, advertising each opening on its six websites,
advertising each opening in the local Macon newspaper and mailing or
e-mailing information about each full-time position to every entity
listed on its recruitment source list.[^9] While these changes should
result in a much improved EEO program for the Licensee's Stations, we
find that the Licensee's repeated violations of our EEO rule, as noted
above during the public file reporting periods of 2003-2004 and
2004-2005, warrant the assessment of a monetary forfeiture in the amount
of fourteen thousand dollars (\$14,000).

7\. This *NAL* is issued pursuant to Section 503(b)(1)(B) of the Act.
Under that provision, any person who is determined by the Commission to
have willfully or repeatedly failed to comply with any provision of the
Act or any rule, regulation, or order issued by the Commission shall be
liable to the United States for a forfeiture penalty.[^10] Section
312(f)(1) of the Act defines willful as "the conscious and deliberate
commission or omission of \[any\] act, irrespective of any intent to
violate" the law.[^11] The legislative history of Section 312(f)(1) of
the Act clarifies that this definition of willful applies to both
Sections 312 and 503(b) of the Act,[^12] and the Commission has so
interpreted the term in the Section 503(b) context.[^13] Section
312(f)(2) of the Act provides that "\[t\]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."[^14]

8\. The Commission's *Forfeiture Policy Statement* and Section
1.80(b)(4) of the Rules do not establish base forfeiture amounts for
specific EEO rule violations, such as a failure to recruit widely for
vacancies or to self-assess EEO performance. However, they do establish
a base forfeiture amount of \$10,000 for violation of the Commission´s
public file rules, of \$3,000 for failure to file required information,
and of \$1,000 for failure to maintain required records.[^15] In
determining the appropriate forfeiture amount, we may adjust the base
amount upward or downward by considering the factors enumerated in
Section 503(b)(2)(D) of the Act, including "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 such other matters as justice may require."[^16]

9\. As discussed *supra*, the Licensee failed to list recruitment source
data on its 2003-2004 EEO public file report; list interviewee data on
its 2004 and 2005 EEO public file reports; list the total number of
interviewees for any of the Stations' 10 full-time vacancies on its 2004
EEO public file report and 11 full-time hires on its 2005 report; list
two of its hires on its 2004 report; list all required information on
its job notices; self-assess its EEO program; and place required
information in the public inspection files of the Stations. Accordingly,
based upon the facts before us, the factors noted above, and pertinent
precedent,[^17] we find that the Licensee is apparently liable for the
following forfeiture amounts for its willful and repeated violations of
these Rules: \$4,000 for its violation of Section 73.2080(c)(2); \$2,000
for its violation of Section 73.2080(c)(3); \$4,000 for its violation of
Section 73.2080(c)(5); \$1,000 for its violation of Section
73.2080(c)(6)(iii); \$2,000 for its violation of Section
73.2080(c)(6)(iv), and \$1,000 for its violation of Section
73.3526(e)(7), for a total proposed forfeiture in the amount of
\$14,000.[^18] We will also impose reporting conditions as set forth
below, to ensure that the Licensee and any successor licensee of any of
the above-captioned Stations maintains an adequate EEO program in
compliance with the Rules. The reporting conditions will apply to the
above-captioned Stations, and to all other stations that are part of
their employment unit.

**IV. ORDERING CLAUSES**

10\. Accordingly, IT IS ORDERED, pursuant to Section 503(b) of the
Communications Act of 1934, as amended, and Section 1.80 of the
Commission's Rules, that Cumulus Licensing LLC is hereby NOTIFIED of its
APPARENT LIABILITY FOR FORFEITURE in the amount of fourteen thousand
dollars (\$14,000) for its apparent willful and repeated violation of
Sections 73.2080(c)(2), 73.2080(c)(3), 73.2080(c)(5),
73.2080(c)(6)(iii), 73.2080(c)(6)(iv), and 73.3526(e)(7) of the
Commission's Rules.

11\. IT IS FURTHER ORDERED, pursuant to Section 1.80 of the Commission's
Rules, that, within thirty (30) days of the release of this *NAL*,
Cumulus Licensing LLC SHALL PAY the full amount of the proposed
forfeiture or SHALL FILE a written statement seeking reduction or
cancellation of the proposed forfeiture.

12\. 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.

13\. The response, if any, must be mailed to Office of the Secretary,
Federal Communications Commission, 445 12^th^ Street, S.W., Washington
D.C. 20554, ATTN: Lewis Pulley, Assistant Chief, Policy Division, Media
Bureau, and MUST INCLUDE the NAL/Acct. No. referenced above.

14\. The Commission will not consider reducing or canceling a forfeiture
in response to a claim of inability to pay unless the respondent
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 respondent'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.

15\. Requests for full payment of the forfeiture proposed in this *NAL*
under the installment plan should be sent to: Associate Managing
Director- Financial Operations, 445 12th Street, SW, Room 1-A625,
Washington D.C. 20554.[^19]

16\. IT IS FURTHER ORDERED that Cumulus Licensing LLC and any successor
licensee for any or all of Stations WPEZ(FM), WIFN(FM) (formerly WAYS
(FM)), WDDO(AM), WAYS(AM) (formerly WWFN(AM)), WDEN-FM, WMAC(AM),
WMGB(FM), and WLZN(FM) (formerly WMKS(FM))[^20] shall submit to the
Federal Communications Commission, Media Bureau, EEO Staff, an original
and one copy of the following information on January 4, 2010; January 3,
2011; and January 3, 2012, with respect to those and all other stations
that may be in its employment unit:

\(a\) the unit's most recent EEO public file report;

\(b\) dated copies of all advertisements, bulletins, letters, faxes,
e-mails, or other communications announcing each full-time vacancy for
the preceding reporting year;

\(c\) the recruitment source that referred the hiree for each full-time
vacancy; and

\(d\) the total number of interviewees for each full-time vacancy for
the preceding reporting year and the referral source for each
interviewee.

17\. IT IS FURTHER ORDERED that, pursuant to Section 73.3526(e)(10) of
the Commission's Rules, Cumulus Licensing LLC shall place a copy of this
*NAL* in the public inspection files of Stations WPEZ(FM), WIFN(FM),
WDDO(AM), WAYS(AM), WDEN-FM, WMAC(AM), WMGB(FM), and WLZN(FM).

18\. IT IS FURTHER ORDERED that copies of this *NAL* shall be sent, by
First Class and Certified Mail, Return Receipt Requested, to Cumulus
Licensing LLC, c/o Richard S. Denning, Vice President, Secretary and
General Counsel, 3535 Piedmont Road, Building 14, Suite 1400, Atlanta,
Georgia 30305.

FEDERAL COMMUNICATIONS COMMISSION

Marlene H. Dortch

Secretary

**JOINT STATEMENT OF**

**COMMISSIONER MICHAEL J. COPPS**

**AND**

**COMMISSIONER JONATHAN S. ADELSTEIN**

 

Re:       *Dickey Broadcasting Company, Notice of Apparent Liability for
Forfeiture; Urban Radio I, LLC, Memorandum Opinion and Order and Notice
of Apparent Liability for Forfeiture; Puerto Rico Public Broadcasting
Corporation, Memorandum Opinion and Order and Notice of Apparent
Liability for Forfeiture; W.S. Communications, L.L.C., Memorandum
Opinion and Order and Notice of Apparent Liability for Forfeiture;
Cumulus Licensing L.L.C., Notice of Apparent Liability for Forfeiture;
Fox Television Stations, Inc., Notice of Apparent Liability for
Forfeiture*

The Commission's enforcement of Equal Employment Opportunity ("EEO")
rules related to self-assessment, recordkeeping, recruitment source
information, interviewee information, and public file requirements is
one of the principal ways we strive to promote employment diversity and
opportunities in the communications industry. While this is
unquestionably the right thing to do, Sections 334 and 634 of the
Communications Act specifically authorize the Commission to take steps
to promote equality of employment opportunities for women and members of
racial and ethnic minority groups. Our EEO rules, for example, require
wide dissemination of job vacancies in order to attract all qualified
employees. According to reports, from 1971 to 1997, employment of people
of color in broadcasting increased from 5 to 19 percent, and from 12 to
43 percent for women during the same period.

In recent years, however, Commission enforcement of EEO rules has been
inconsistent and, as one consequence, employment in broadcasting does
not reflect America. As the Minority Media and Telecommunications
Council has found, while the average forfeiture amount for EEO
violations has increased, the Commission's EEO docket has decreased by
96 percent. Between 1994 and 1997, the Commission decided 251 cases,
resulting in 86 forfeitures. Between 2004 and 2007, however, the
Commission decided only 10 cases, resulting in 8 forfeitures.

Lax EEO enforcement has yielded less diversity in employment. The most
recent report on employment trends in broadcasting by the Radio and
Television News Directors Association/Hofstra University found that,
while the minority population in the United States has risen 8.1 percent
in the past 18 years, minority workforce in TV news is up 5.8 percent,
and the minority workforce in radio is up by just 1 percent.

So it is clear that the Commission's recent efforts to promote
employment diversity have been woefully inadequate. If we are truly
committed to employment diversity, as required by law, we must get
serious about restoring an effective and rational EEO enforcement
program. This level of commitment is currently lacking at the FCC.

There are other, more pro-active, steps we should consider. At a
minimum, we should make our process more transparent by compiling and
releasing FCC Form 395 data, as well as developing annual and
longitudinal employment reports. As we work with industry and advocacy
groups in a cooperative manner, these initial steps should help us
better understand employment trends in the communications industry and
permit us to better craft more effective oversight.

Having a communications industry that reflects our nation's diversity
would best serve a wide range of consumer and societal interests. It is
not only a legal obligation, it is also the right thing to do.

[^1]: 47 U.S.C. § 503(b); 47 C.F.R. § 1.80.

[^2]: *See* 47 C.F.R. §§ 73.2080(c)(2), 73.2080(c)(3), 73.2080(c)(5),
    73.2080(c)(6)(iii), 73.2080(c)(6)(iv), and 73.3526(e)(7).

[^3]: Letter from Lewis Pulley, Assistant Chief, Policy Division, Media
    Bureau, to Cumulus Licensing, LLC (Jun. 7, 2006).

[^4]: Letter and documentation from Richard S. Denning, Vice President,
    Secretary and General Counsel of Cumulus Licensing LLC, to EEO
    Staff, Policy Division, Media Bureau (Jul. 21,2006).

[^5]: *Id.*

[^6]: *Id.*

[^7]: Letter and documentation from Richard S. Denning, Vice President,
    Secretary and General Counsel of Cumulus Licensing LLC, to EEO
    Staff, Policy Division, Media Bureau (Jul. 21, 2006), Response to
    Question 3(a).

[^8]: *Id*.

[^9]: *Id.*

[^10]: 47 U.S.C. § 503(b)(1)(B). *See also* 47 C.F.R. § 1.80(a)(1).

[^11]: 47 U.S.C. § 312(f)(1).

[^12]: *See* H.R. Rep. No. 97-765, 97^th^ Cong. 2d Sess. 51 (1982).

[^13]: *See Southern California Broadcasting Co.*, Memorandum Opinion
    and Order, 6 FCC Rcd 4387, 4388 (1991).

[^14]: 47 U.S.C. § 312(f)(2).

[^15]: *See Forfeiture Policy Statement and Amendment of Section 1.80(b)
    of the Rules to Incorporate the Forfeiture Guidelines*, Report and
    Order, 12 FCC Rcd 17087, 17113-15 (1997) *("Forfeiture Policy
    Statement"),* *recon. denied*, 15 FCC Rcd 303 (1999); 47 C.F.R. §
    1.80(b)(4), note to paragraph (b)(4), Section I.

[^16]: 47 U.S.C. § 503(b)(2)(D); *see also Forfeiture Policy Statement,*
    12 FCC Rcd at 17100-01, ¶27; 47 C.F.R. § 1.80(b)(4); 47 C.F.R. §
    1.80(b)(4), note to paragraph (b)(4), Section II.

[^17]: In *Waitt Omaha, LLC*, we proposed an \$8,000 forfeiture for a
    licensee's violations of various EEO rules, specifically Sections
    73.2080(c)(3), 73.2080(c)(5), 73.2080(c)(6)(iii), 73.2080(c)(6)(iv),
    and 73.3526(e)(7). The licensee had failed to maintain required EEO
    records, list the recruitment source of hirees, provide data on the
    numbers of persons interviewed and referred from each recruitment
    source, self-assess adequately, and place required EEO information
    in its public inspection file. *Waitt Omaha, LLC*, Notice of
    Apparent Liability for Forfeiture, 22 FCC Rcd 2661 (2007) (response
    pending). In the instant case, Cumulus Licensing, LLC, in addition
    to violating the rules violated in *Waitt Omaha, LLC,* also failed
    to list two hires on its 2004 public file report and failed to
    maintain complete records of job notices sent to sources. In *Viper
    Communications*, we proposed an \$8,000 forfeiture for a licensee's
    violation of Sections 73.2080(c)(2) and (c)(3). The licensee had
    failed to complete its one required initiative during the 18-month
    period of our review of its EEO record, or to self-assess
    adequately. *Viper Communications*, Notice of Apparent Liability for
    Forfeiture, 20 FCC Rcd 20254 (2005) (forfeiture paid). In the
    instant case, Cumulus Licensing LLC also failed to perform one of
    its two required initiatives, but its violation of Section
    73.2080(c)(2) is not as severe because it did perform one
    initiative.

[^18]: In assessing the forfeiture amounts for the Licensee's various
    violations, the Commission did not consider any violations that
    occurred before March 26, 2004, because the Stations' renewal
    applications were granted on that date.  *See* File Nos.
    BRH-20031208BTC, BRH-20031208BUZ, BR-20031208BVV, BR-20031208BUG,
    BRH-20031208BUI, BR-20031208BVT, BRH-20031208BVE, and
    BRH-20031208BVN; *see also* 47 U.S.C.

    § 503(b)(6)(A) (Commission is barred from issuing an NAL to
    broadcast licensees in this circumstance.)  47 C.F.R. §
    73.3526(e)(7) requires EEO information to be kept in a station's
    public inspection file until final action has been taken on the
    station's next license renewal application.  The renewal grant
    becomes final 40 days after public notice of the grant of the
    renewal application, unless a petition for reconsideration or
    application for review is timely filed or the Commission otherwise
    sets aside the grant.  *See* 47 C.F.R. §§ 1.106, 1.115, 1.117. 

[^19]: *See* 47 C.F.R. § 1.1914.

[^20]: In the event of an assignment of any of the Stations, this
    continuing obligation will run to the assignee with regard to each
    Station assigned.