OIb SEP 2

A 0: S

Sc1IARRIN0 & SHUBERT, PLLC
BROADCAST &MEDIA LEGAL SERVICES

Dawn M. Sciarrino4

Lee W. Shubert *°

christine McLaughlin*t

Katherine Tranchemontagne*t

dawn@sciarrinolaw.com
(202) 256-9551

1ce@sciarrinoIaw.com
(410) 935-1440

christine@sciarrinolaw.com

ksuh@seiarrino]aw.corn

(202) 375-9166

(202) 905-8291

September 28, 2016

Accoptod / Fd
Via Hand Delivery

SEP 22O16

Marlene H. Dortch, Secretary
Federal Communications Commission
Washington, DC 20554
Re:

Federal Communications

Conmjssjon

Office of the Secretarj

Red Desert Communications, LLC
Application for Transfer o(ontrol of Station KREO(FM,),
James Town, Wyoming (FIN. 190387)
File No. BTCH-20160824ABJ

Dear Ms. Dortch:
Transmitted herewith, on behalf of Wagonwheel Communications Corporation, please
find the original and filing copies of its Petition to Deny the above-referenced application.
Enclosed please also find an additional copy of this filing; please date-stamp that copy
and return it to our courier, who is waiting.
Should you have any questions concerning this matter, kindly contact the undersigned.

cc:

Service List

4601 N. FAIRFAX DR. SUiTE 1200 ARLINGTON, VA 22203
703.991.7120 (FAX)
Athnitted in the District of Columbia, New York and Virginia * Of Counsel t Admitted in District of Columbia

Retired

	

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC 20554

In Fe: Application of
RED DESERT COMMUNICATIONS, LLC

File No. BTCH-20160824ABJ

For Transfer of Control of Station KREO(FM),
James Town, Wyoming (FIN: 190387)

To:

The Secretary, Federal Communications Commission
Chief, Audio Services Division, Media Bureau

PETITION TO DENY
Wagonwheel Communications Corporation ("Wagonwheel"), by its attorneys and
pursuant to Section 3 09(d) of the Communications Act of 1934, as amended (the "Act"), 47
U.S.C. § 309(d) and Section 73.3584 of the Commission's Rules, 47 C.F.R. § 73.3584, hereby
requests that the Commission dismiss or deny the above-captioned application of Red Desert
Communications, LLC ("Red Desert") for the transfer of control of Station KREO(FM) (the
"Application") from Clifton Topp to Robert K. Cornman In support hereof, the following is
respectfully shown:
I.

Wagonwheel has Standing to Protest the Application.

Wagonwheel is the licensee of a number of radio stations in the State of Wyoming,
including KYCS(FM) (FIN: 20482), licensed to Rock Springs, in Sweetwater County, Wyoming.
James Town, the community of license of KREO(FM), is likewise in Sweetwater County.
Wagonwheel's station and the subject station serve the same market, a predominantly rural area

Application was accepted for filing by Public Notice released on August 29, 2016. See
Report No. 28808. This Petition, filed within thirty days thereafter, is timely.

	

with limited advertising revenue to support the stations operating there. Thus, Wagonwhee! is a
competitor with standing to file this Petition.
II.

KREO Violated the Express Condition of its License and
the License Should Therefore Be Cancelled.

It is axiomatic that in order for a licensee to assign or transfer control of a license, it must
have a valid license to convey. In the instant case, KREO(FM) violated an express condition of
its license; the license should therefore be void and the subject Application dismissed.
In the fall of 2015, Red Desert applied for a license for KREO under file number BLH20150914AFR, which CDBS shows was granted on October 1, 2015. That license, a copy of
which is attached hereto as Exhibit One, contained "Special operating conditions or restrictions"
including the following:
3. Grant of this license application is conditioned on the continuous operation of
the licensed facility for the twelve-month period following grant. The failure of
the facility to so operate will result in the rescission of this grant, dismissal of the
license application and the forfeiture of the associated construction permit
pursuant to 47 C.F.R. § 73 .3598(c) unless the licensee rebuts the presumption
that the authorized facilities were temporarily constructed.
As indicated in the attached Declaration of Alan Harris, attached hereto as Exhibit Two,
KREO did not operate continuously from and after October 1, 2015. Indeed, as Mr. Harris
attests, KREO did not broadcast any programming until, at the earliest, July 2016, some nine
months after receiving a license that required "continuous operation" of KREO. See Exhibit
Two. Mr. Harris was not alone in his observations; attached hereto as Exhibit Three is the
Declaration of Bruce Pivic, principal of another licensee in the subject Sweetwater County,
Wyoming area, and a copy of an email Mr. Pivic submitted to the Commission complaining of
KREO's failure to conform to the requirements of its license.

2

Both Mr. Harris and Mr. Pivic first heard broadcast programming on KREO in or around
July 2016; prior to that date, despite regular listening, neither observed anything on KREO's
authorized frequency other than an unmodulated carrier. See Exhibits Two and Three. Members
of the public encountered the same unmodulated carrier. See Exhibit Two. Starting July of
2016, it appears that KREO was testing, carrying intermittent programming from a station based
some 100 miles away from the community of license. Id. KREO did not begin continuous
programming until sometime in August 2016 - nearly one year after its application for license
was filed. Id. Even now, it appears that they are broadcasting an Internet radio station from
Rock Springs, WY, and it is unclear where the KREO main studio and public file might be
located. Id.
Moreover, Red Desert had even more explicit notice that the Commission expected
station KREO to provide continuous operations than the face of its license. Not long after the
grant of its license application, Red Desert filed an STA request to remain silent. See BLSTA20151119AZY. The Commission responded with a letter dated March 15, 2016, attached hereto
as Exhibit Four, specifically inquiring as to the construction status of KREO. CDBS does not
reflect what response, if any, Red Desert provided to the Commission's inquiry, but KREO
failed to operate until July of 2016, some four months thereafter. See Exhibits Two and Three.
Especially in light of the March 15, 2016 letter, no reasonable licensee could have mistaken the
seriousness with which the Commission intended the condition of twelve months' continuous
operation.
In short, two nearby licensees attest that for the better part of a year after obtaining a
license requiring continuous operations, for approximately four months after the Commission
questioned KREO's operational status, and up until approximately the month before filing the

3

instant Application for transfer of control, Red Desert occasionally transmitted no more than an
umodulated carrier over the facilities of KREO. See Exhibits Two and Three. That is wholly
insufficient to constitute the "operations" the Commission requires of broadcast licensees; it is
well settled that broadcast licensees must actually provide some form of programming to the
public. See, e.g., Mr. David Jackson, DA 16-74 1 (rd. June 30, 2016) ("A station must
disseminate radio communications intended to be received by the public in order to be
considered to have resumed operations"); ETC Communications, Inc., 24 FCC Rcd. 3021, 3022
(2009) ("The Communications Act defines 'broadcasting' as 'the dissemination of radio
communications intended to be received by the public,' and it is well settled that conducting
equipment tests or transmitting an equipment test pattern does not prevent the automatic
expiration of a license pursuant to Section 312(g)."). The attached Declarations demonstrate that
KREO failed to comply with an express condition of its license, even following a rather pointed
reminder from the Commission, until the eve of filing a transfer of control application. For that
reason alone, the FCC should cancel the license for KRBO and dismiss the subject Application.
III.

Other Questions Surrounding KRFO's Belated Operations
Warrant Further Commission Inquiry

In addition to Red Desert's utter failure to comply with conditions the Commission
imposed upon the KREO license, its behavior since belatedly instituting operations raises more
questions than it answers. As stated in the attached Declarations, it is unclear whether KREO
has a main studio or is maintaining an accessible public file. See Exhibit Two. Those failures,
standing alone, would constitute significant rule violations. Additionally, a Red Desert
announcer has made statements on air indicating an imminent increase in power, and the use of
translators to broadcast from Sweetwater County to Evanston, WY, some 100 miles away. Id.
CDBS contains no indication of any applications for Red Desert to implement those plans;
4

nonetheless, the long delays in providing any service at all to the KREO community of license
coupled with plans to serve a far more extensive area, appear to support the Commission's
concern that the KREO facilities for which Red Desert sought a license in September 2015 were
merely "temporarily constructed." At a minimum, the Commission should not grant the subject
Application without further inquiry into whether Red Desert has violated other Commission rules
in addition to the conditions of the KREO license, and whether the representations in Red
Desert's license application for the current KREO facilities were truthful and accurate.2 At the
outset it appears that Red Desert willfully and intentionally misrepresented fact to the
Commission in both its 2015 license application and in the instant application for transfer of
control.

2 CDBS shows no response by Red Desert to the Commission's March 15, 2016 letter requesting
data supporting the construction status of KREO. Unless any such response admitted that the
station was at most transmitting an unmodulated carrier, however, the representations in any
such response would likewise raise questions as to their truthfulness.
5

Conclusion.
FOr all the foregoing reasons, Basin respectfully requests that the subject Application be
dismissed or denied and that the KREO license be revoked.

Respectfully submitted,
WAGONWHEEL COMMUNICATIONS CORPORATION

By:
Dawn M. Scianino
Christine McLaughlin
Its Attorneys
SCIARRINO & SHUBERT, PLLC
4601 N. Fairfax Drive, Suite 1200
Arlington, VA 22203
Tel.: (202) 375-9166
DATE: September 28, 2016

6

EXHIBIT ONE

	

United States of America

FEDERAL COMMUNICATIONS COMMISSION
FM BROADCAST STATION LICENSE

Authorizing Official:
Official Mailing Address:
RED DESERT COMMUNICATIONS, LLC

Rodolfo F. Bonacci

5920 SUN RIDGE DRIVE

Assistant Chief

ROCK SPRINGS WY 82901

Audio Division
Media Bureau

Facility Id: 190387
Call Sign:

EO

Grant Date: October 01, 2015
This license expires 3:00 a.m.
local time, October 01, 2021.

License File Number: BLH2O15O914AFR
This license covers permit no.: BNPH-20120529ALM,
as modified by permit no.: BMPH-2O15O831ADK
Subject to the provisions of the Communications Act of 1934, subsequent
acts and treaties, and all regulations heretofore or hereafter made by
this Commission, and further subject to the conditions set forth in this
license, the licensee is hereby authorized to use and operate the radio
transmitting apparatus herein described.
This license is issued on the licensees representation that the
statements contained in licenseeTs application are true and that the
undertakings therein contained so far as they are consistent herewith,
will be carried out in good faith. The licensee shall, during the term of
this license, render such broadcasting service as will serve the public
interest, convenience, or necessity to the full extent of the privileges
herein conferred.

This license shall not vest in the licensee any right to operate the
station nor any right in the use of the frequency designated in the
license beyond the term hereof, nor in any other manner than authorized
herein. Neither the license nor the right granted hereunder shall be
assigned or otherwise transferred in violation of the Communications Act
of 1934. This license is subject to the right of use or control by the
Government of the United States conferred by Section 606 of the
Communications Act of 1934.

FCC Form 351B October21, 1985

Page 1 of 3

Callsign: KREO

License No.: BLH-20150914AFR

Name of Licensee: RED DESERT COMMUNICATIONS, LLC
Station Location: WY-JAMES TOWN
Frequency (MHz): 93.5
Channel: 228
Class: C3
Hours of Operation:Unlimited
Transmitter: Type Accepted. See Sections 73.1660, 73.1665 and 73.1670 of
the Commission's Rules.
Transmitter output power: .85 kW
Antenna type: Non-Directional
Description:NCM

BKG77/4L, four sections, 0.9 wavelength spaced

Antenna Coordinates: North Latitude:

4ldeg 29min

50 sec

West Longitude:

l09deg 2Omin

36 sec
Horizontally
Polarized
Antenna

Vertically
Polarized
Antenna

1.60

1.60

12

12

Height of radiation center above mean sea level (Meters) :

2341

2341

Height of radiation center above average terrain (Meters):

323

323

Effective radiated power in the Horizontal Plane (kW):
Height of radiation center above ground (Meters) :

Antenna structure registration number: Not Required
Overall height of antenna structure above ground:

18 Meters

Obstruction marking and lighting specifications for antenna structure:
It is to be expressly understood that the issuance of these specifications
is in no way to be considered as precluding additional or modified marking
or lighting as may hereafter be required under the provisions of Section
303(q) of the Communications Act of 1934, as amended.
None Required

Special operating conditions or restrictions:
The permittee/licensee in coordination with other users of the site
must reduce power or cease operation as necessary to protect persons
having access to the site, tower or antenna from radiofrequency
electromagnetic fields in excess of FCC guidelines.

FCC Form 351B October 21, 1985

Page 2 of 3

	

Cailsign: KREO

License No.: BLH2O15O914AFR

Special operating conditions or restrictions:
2

The licensee has demonstrated compliance with the FCC radiofrequency
electromagnetic field exposure guidelines based upon the usage of the
antenna specified herein.
If the licensee makes any changes in
facilities via modification of license application in accordance with
47 CFR section 73.1690(c), the subsequent Form 302-FM, application
for license, must include a revised RF field showing to demonstrate
continued compliance with the FCC guidelines.

3

Grant of this license application is conditioned on the continuous
operation of the licensed facility for the twelve-month period
following grant.
The failure of the facility to so operate will result
in the rescission of this grant, dismissal of the license application
and the forfeiture of the associated construction permit pursuant to 47
C.F.R. § 73.3598(c) unless the licensee rebuts the presumption that the
authorized facilities were temporarily constructed.
'*

FCC Form 351 B October21, 1985

END OF AUTHORIZATION

***

Page 3 of 3

EXHIBIT TWO

DECLARATION OF ALAN W. HARRIS
I, Alan W. Harris, declare under penalty of perjury as follows:
1. I am over the age of 18 and competent to be a witness.
2. I am the President of Wagonwheel Communications Corporation ("Wagonwheel"), licensee of a
number of radio stations in Wyoming, including KYCS(FM), Rock Springs, in Sweetwater
County, Wyoming.
3. I have observed strange operations on 93.5 MHz in Sweetwater County. More particularly, for
some time, a transmitter has been transmitting on that frequency, but with no programming.
Based upon a review of the Commission's records, 93.5 MHz in this area is licensed as station
KREO(FM), Jamestown, WY (FiN: 190387), to Red Desert Communications, LLC ("Red
Desert"). Jamestown is also in Sweetwater County, WY, approximately 20 miles west of Rock
Springs.
4. I tune to 93.5 MHz, and other channels in the area, approximately once a month to keep
apprised of what is happening in the markets I serve. Until recently, no programming was
received over 93.5MHz, only a silent carrier.
5. I was not alone in my observation of a station operating on 93.5MHz with no programming, no
station identification, etc. People would call our station and ask what 93.5 was, saying that their
radios would stop there on scan but then never heard anything. These reports confirmed my
experience. Other than fielding occasional calls from confused members of the public, however,
these transmissions caused no harm to my station, nor did they compete for any of the limited
advertising dollars in Sweetwater County.
6. To my knowledge, these carrier-only transmissions continued into July of2016. I observed this
mode of operation as recently as on or about July 29, 2016. However, at other points in July
2016, specifically July 31, 2016, 93.5 MHz sometimes appeared to be simulcasting a station in
Evanston, WY, approximately 100 miles to the west. The transmissions I heard identified the
station as KDAQ and the frequency as 98.5 MHz. The transmissions were sporadic, several
hours in duration, and appeared to be in the nature of program testing.
7. On or about August 19, 2016, I observed that what appears to be full-time broadcasting on 93.5
MHz had commenced, and continues. I recognized the programming being broadcast as that of
an internet station based in Rock Springs. Upon information and belief, that internet station is
run from a residence in Rock Springs. The broadcasts identified the station as KREO, Rock
Springs (not Jamestown), WY.
8. My observations are confirmed by Mr. Bruce Pivic of Big Thicket Broadcasting of Wyoming,
Inc., licensee of stations including KQSW(FM) in Rock Springs. As indicated in Exhibit Three
to the Petition, Mr. Pivic has filed a complaint against KREO, which to the best of my
knowledge and belief remains pending before the Commission, based upon KREO's long
history of silence, followed by its August 2016 commencement of full time operations.

9. I have been unable to locate a main studio for KREO. The addre
ss listed on the license for
KREO is, to the best of my information and belief, the reside
nce of the licensee. There is no
equipment visible to indicate that they are broadcasting
from that location I do not know
whether KREO's public file is located there, I have found
no information to indicate whether
that is the public file location or if it is elsewhere (for exam
ple, in a eommercial or public
building in the Jamestown area)
10. 1 have also observed conflicting information
about KREO's power. The authorization I
reviewed in CDBS, File No BLH-29150914AFR, autho
rizes an output power of 1 6 KW I
have heard their announcer, John King, say on the air they
were installing a larger transmitter in
September to improve their signal and that they would soon
have translators "from here to
Evanston".

have reviewed the foregoing Petition to Deny, and all statem
ents of fact therein and in the Declaration
are true and correct to the best of my knowledge, inform
ation and belief.

DATE: September27, 2016

EXHIBIT THREE

	

DECLARATION OF Bruce W. Pivic
I, Bruce w Pivic, declare under penalty of perjury as follows:
L

I am over the age of 18 and competent to be a witness.

2.

1 am the President of Big Thicket Broadcasting, licensee of a number of radio stations in

Wyoming, including KQSW (96.5 FM) Rock Springs, in Sweetwater County. Wyoming.

3.

I too have observed strange operations on 93.5 MHz in Sweetwater County. More

particularly, for some time, a transmitter has been transmitting on that frequency, but with no
programming. I have submitted complaints #1115325 and 1115393 on the operation of this
frequency the 6 months up to August when the station went live simulcasting an internet radio
station. Based upon a review of the Commission's records, 93.5 MHz in this area is licensed as
station KREO (FM), James Town, WY (FIN: 190387), to Red Desert Communications, LLC
("Red Desert"). James Town is also in Sweetwater County, WY, approximately 20 miles west of
Rock Springs.

4.

1 also wrote a letter (see attached) to Victoria M. McCauley on August 17, 2016 on the

disturbing intrusion of the radio station at frequency 93.5 in Rock Springs area

5.

I too on or about August 19, 2016, observed that what appears to be full-time

broadcasting on 93.5 MHz had commenced, and continues. I also recognized the programming
being broadcast as that of an internet station based in Rock Springs. I belief that the internet
station is run from a residence in Rock Springs. The broadcasts identify the station as KREO,
Rock Springs (not James Town), WY.

	

6.

1 too have heard conflicting information about KREO's power. The authorization I

reviewed in CDBS, File No. BLH-20150914AFR, authorizes and output power of.85 KW. The
announcer (John King) has indicated that they are broadcasting at 1.6kw and are installing a new
transmitter (all on the radio on or around August 22, 2016) that will be increasing their signal
strength within a few weeks. Also stating that they are installing translators to get their signal all
the. way from Rock Springs to Evanston Wyoming. This announcement was confirmed by a
listener, Terry Nations at the Rock Springs Urban renewal agency, and quizzed my sales
manager, Michael Berry, on August 241h during a remote radio broadcast

7.

On August 22, 2016 I was approached by Robert Cornman of Communications Technology

LLC about a lease our radio station had for tower space on one of his towers on Aspen
Mountain. During the conversation he revealed to me that he has been funding K,REO and was
filing for a transfer of license to him from Red Desert Communications. He also indicated that
they were going to purchase a new transmitter. I have no knowledge that this occurred though. It
was a conversation to inform me of his attempt to purchase the frequency and license.

8.
AU statements of fact therein and in this Declaration are true and correct to the best of my
knowledge, informatIon and belief,

Bruce Pivic
From:
Sent:
To:
Subject:

Victoria McCauley 
Monday, August 22, 2016 11:31 AM
Bruce Pivic
RE: KREO frequency in Wyoming

Mr. PivicPlease send me documentation of you
r complaints with exact dates of no serv
ice and file it through the FCC's Offic
the Secretary. If you can get pictures
e of
of the facility, or whatever is at the stat
ion's location, that would also support
complaint. I will follow up once I hav
your
e your documentation, Thanks.
Victoria M. McCauley
Attorney/Advisor
Audio Division
Media Bureau
202 418 2136
Victoria.McCau1eyçgçv

***For FCC Official Use OnIy***

From: Bruce Pivic [mailto:bpivic@wyom
ing.com ]
Sent: Wednesday, August 17, 2016 3:20
PM
To: Victoria McCauley 
Subject: KREO frequency in Wyomin
g
Dear Ms. McCauley
I am concerned over the radio frequen
cy 93.5 FM in Sweetwater county (KR
EO). This station has had a carrier freq
for the past 3-4 months with no aud
uency
io, no station identification or any sub
seq
uent audio except for a couple of hou
about two weeks where they were simu
rs
lcasting a station out of Evanston Wyo
ming. I am concerned that this frequen
is intercepting listeners who maybe
cy
trying to scan the dial, but also that
this is against the rules of the FCC.
to see some sort of auction so this stat
I would like
ion is turned off.
Not to be a pest, but there are over
10 radio stations in Sweetwatercoun
tythat struggle as it is, and none of them
this annoyance.
need
Bruce W. Pivic
1701 Decora Dr.
Rock Springs WY, 82901
307-389-6661

1

EXHIBIT FOUR

Federal Communications Commission
Washington, D.C. 20554
MAR 1 5 2016
In Reply Refer to: 1800B3-VM

CERTIFIED MAIL - RETURN RECEIPT REOUESTED
Mr. Cliff Topp
Red Desert Communications, LLC
5920 Sun Ridge Drive
Rock Springs, WY 82901
In re:

KREOFM), James Town, WY
Facility ID No. 190387
File No. BLSTA-20 15111 9AZY
Status Inquiry

Dear Mr. Topp:
This letter concerns the status of Station KREO(FM), Jamestown, Wyoming (Station),
licensed to Red Desert Communications, LLC (RDC). Pursuant to Section 73.1015 of the
Commission's Rules,' you are required to clarii,' this matter in writing within thirty days of the
date of this letter.
Our records show that the Station was granted its initial license on October 1, 2015,
with the following condition:
Grant of this license application is conditioned on the continuous operation of the
licensed facility for the twelve-month period following grant, The failure of the facility
to so operate will result in the rescission of this grant, dismissal of the license
application and the forfeiture of the associated construction permit pursuant to
47C.F.R. § 73.3598(c) unless the licensee rebuts the presumption that the authorized
facilities were temporarily constructed.2
According to a request for Special Temporary Authority to Remain Silent (STA) filed
on November 19, 2015, the Station is silent and has been silent from its initial licensing date,
October 1, 2015. RDC's &hibit 1 to the STA request states:
FM radio broadcast station KREO was fully constructed in September of this year with
the facilities authorized in the Station's construction permit. The covering license
application and program test authority were granted in October, Ordinarily, the Station
would have gone on the air shortly thereafter. However, in this case the Licensee plans
to relocate this Station in order to facilitate achievement of the public interest goals
determined by the Commission in MM Docket 05-243 (Meeteetso, Wyoming, Fruita,
Colorado, Naples, Utah, Diamondville, Wyoming, Etc.). Red Desert Communications
does not wish the public in James Town (2015 Census estimated population 556) to
become accustomed to service from KREO lest the Station's relocations [sic] cause
'47CFR73,1015.
2File No. BLH-20150914AFR.

unnecessary disruption. Therefore, the Licensee seeks authority to keep KREO silent
pending effectuation of the Station relocation.3
Based on the above, further inquiry is required regarding the Station's construction.
Please provide evidence documenting proof of completion of the Station's consti uction,
including an affidavit or unsworn declaration under penalty of perjury4 executed by an officer
or director of RDC stating (I) the date on which the Station's construction was completed, (ii)
the names, addresses and telephone numbers of all persons who participated in the Station's
construction, (iii) the transmitter site's address and coordinates, and (iv) the transmitter make
and model number and supplier, the antenna's make and model number and supplier, and the
antenna height above ground level. This documentation must also include vendor receipts,
tower lease, studio lease, occupancy certificate, lease payments, invoices, bills, checks written
or received, credit card charges, wire transfers or deposits of funds relating to the Station's
construction. Please include photographs of the Station's transmission facilities.
Fai lure to respond to this letter within the specified time will result in adverse actions
jeopardizing both the station's license and call letters. If you have any questions concerning the
content of this letter, please contact Victoria Mccauley, Attorney, by phone (202-418-2136), or
e-mail (Victoria.McCauleyfcc.gov ).
Sincerely,

LeffiA
Peter H. Doyle
Chief, Audio Division
Media Bureau
cc: Barry D. Wood, Esq.

No. BLSTA-20 15111 9AZY, Exhibit 1.
4See47CFR. 1.16.

2

CERTIFICATE OF SERVICE
The undersigned hereby certifies that a copy of the foregoing Petition to Deny was sent the
following on the 28th day of September 2016 by first class U.S. mail, postage prepaid:

Ms. Annette Smith*
Audio Division, Media Bureau
Federal Communications Commission
445 Twelfth Street, S.W.
Washington, DC 20554
Ms. Victoria McCauley*
Audio Division, Media Bureau
Federal Communications Commission
445 Twelfth Street, S.W..
Washington, DC 20554
Jeffrey L. Timmons, Esq.
974 Branford Lane NW
Lilburn, GA 30047 - 2680

Christine McLaughlin

* denotes delivery by email.