Federal Communications Commission DA 10-784
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
World Media Broadcast Company
Licensee of Station WCLM (AM)
Highland Springs, Virginia
Facility ID # 73728
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File Number: EB-10-NF-0003
NAL/Acct. No.: 201032640002
FRN: 5016308
NOTICE OF APPARENT LIABILITY FOR FORFEITURE
Adopted:  May 6, 2010 Released:  May 10, 2010
By the Resident Agent, Norfolk Office, South Central Region, Enforcement Bureau:
I. INTRODUCTION
1. In this Notice of Apparent Liability for Forfeiture (“NAL”), we find that World Media 
Broadcast Company, (“World Media”), licensee of station WCLM(AM), in Highland Springs, Virginia, 
apparently willfully and repeatedly violated Sections 11.35(a), 73.1400(a)(1)(ii) and 73.3526 of the 
Commission’s Rules (“Rules”)1 by failing to maintain functioning Emergency Alert System (“EAS”) 
equipment, failing to provide functioning transmission system remote control equipment, and failing to 
maintain and make available a public inspection file.  We conclude, pursuant to Section 503(b) of the 
Communications Act of 1934, as amended (“Act”),2 that World Media is apparently liable for a forfeiture in 
the amount of twenty-one thousand dollars ($21,000).
II. BACKGROUND
2. On January 26, 2010, in response to a complaint, an agent of the Commission’s Norfolk 
Office of the Enforcement Bureau (“Norfolk Office”) inspected the main studio for station WCLM in 
Richmond, Virginia.  The agent observed that the station was without a functioning EAS system.  WCLM’s 
station manager and the station’s “technical representative” stated that they believed the EAS 
encoder/decoder unit had been removed for repairs, but there were no logs to confirm the equipment 
removal.  The agent observed, however, that the EAS unit was actually installed at the main studio but was 
not connected to the transmission system.  Neither the station manager nor the “technical representative” 
was able to send an EAS test over the air, or knew when the EAS was last operational, or when the last EAS 
test was sent.  There were no station logs at the main studio or records of any kind that showed that any 
required weekly or monthly EAS tests had ever been sent or received.  Additionally, in response to the 
agent’s request for inspection during normal business hours, World Media was unable to produce its public 
inspection file or any of the required contents of the file.  WCLM’s station manager stated that the public 
inspection file was kept at World Media’s headquarters in Washington, DC. 
  
1 47 C.F.R. §§ 11.35(a), 73.1400(a)(1)(ii) and 73.3526.
2 47 U.S.C. § 503(b).  
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3. Also on January 26, 2010, during the inspection of the station’s transmitter site, the agent 
observed that the transmitter’s DC plate meter was apparently defective, as it read zero when the antenna 
base current meter indicated 3.8 amps at the base of the antenna. The agent also observed that World 
Media was unable to control the remote transmitter operation from the main studio because of an 
inoperative remote control system.  World Media’s “technical representative” stated that he was aware that 
the remote control unit was inoperative as a result of being struck by lightning sometime in November 2009.  
The “technical representative” stated that he was unable to repair the remote control equipment and planned 
to suggest that World Media purchase a new unit.
III. DISCUSSION
4. 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) of the Act has been 
interpreted to mean simply that the acts or omissions are committed knowingly.3 The term “repeated” means
the commission or omission of such act more than once or for more than one day.4
5. Every 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 refrain from 
participation, and that request is approved by the Commission.5 The EAS enables the President and state 
and local governments to provide immediate and emergency communications and information to the 
general public.6 State and local area plans identify local primary sources responsible for coordinating 
carriage of common emergency messages from sources such as the National Weather Service or local 
emergency management officials.7 Required monthly and weekly tests originate from EAS Local or State 
Primary sources and must be retransmitted by the participating station.  As the nation’s emergency 
warning system, the Emergency Alert System is critical to public safety, and we recognize the vital role 
that broadcasters play in ensuring its success.  The Commission takes seriously any violations of the 
Rules implementing the EAS and expects full compliance from its licensees.
6. Section 11.35(a) of the Rules requires all broadcast stations to ensure that EAS encoders, 
EAS decoders, and attention signal generating and receiving equipment are installed and operational so that 
the monitoring and transmitting functions are available during the times the station is in operation.8   During 
the January 26, 2010 inspection, the agent observed that the WCLM(AM) EAS encoder/decoder unit was, in 
fact, installed at the main studio but was not operational.  Both the station manager and the “technical 
  
3 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 Rcd 4387 (1991).
4 Section 312(f)(2) of the Act, 47 U.S.C. § 312(f)(2), which also applies to violations for which forfeitures are 
assessed under Section 503(b) 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.” 
5 47 C.F.R. §§ 11.11, 11.41.
6 47 C.F.R. §§ 11.1, 11.21.
7 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.
8 47 C.F.R. § 11.35(a).
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representative” admitted that neither of them knew that an EAS Encoder/Decoder unit was installed at the 
main studio or when the last EAS test was sent.  In addition, World Media was unable to produce any 
evidence that required EAS weekly or monthly tests had ever been sent or received.  Therefore, we find that 
World Media apparently willfully and repeatedly violated Section 11.35(a) of the Rules by failing to ensure 
that EAS equipment was installed and operational when the station was in operation.
7. Section 73.1400(a)(1)(ii) of the Rules states that if a remote control system of the 
transmission system is used, the “remote control system must provide sufficient transmission system 
monitoring and control capability so as to ensure compliance with §73.1350.”9 On January 26, 2010, the 
installed transmitter dial-up remote control system at the WCLM transmitter site was inoperative. 
According to the station manager and “technical representative”, the transmitter remote control unit was 
“hit by lightning” sometime in November 2009 and had not subsequently been repaired or replaced.  
Therefore, we find that World Media apparently willfully and repeatedly violated Section 
73.1400(a)(1)(ii) of the Rules by operating a remote transmitter from the main studio without functional 
remote control equipment. 
8. Section 73.3526(a)(2) of the Rules states that “[e]very permittee or licensee of an AM, 
FM, TV or a Class A station in the commercial broadcast services shall maintain a public inspection file 
containing the material” set forth in this section.10 The public inspection file must be maintained at the 
main studio of the station,11 and must be available for public inspection at any time during regular business 
hours.12  An agent from the Norfolk Office requested to inspect station WCLM’s public inspection file 
during regular business hours on January 26, 2010.  The station manager was unable to make its public 
inspection file or any of the required contents of the file available for inspection.  He stated that WCLM’s 
public inspection file is maintained at World Media’s headquarters in Washington, DC. Based on the 
evidence before us, we find that World Media apparently willfully and repeatedly violated Section 73.3526 
of the Rules by failing to maintain a public inspection file.  We also find that World Media apparently 
willfully violated Section 73.3526 of the Rules by failing to make available a public inspection file.  
 
9. Pursuant to 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, the base forfeiture amounts for not having operational EAS equipment installed, violation of 
transmitter control and metering requirements, and violation of public file rules are, respectively, $8,000, 
$3,000 and $10,000.13 In assessing the monetary forfeiture amount, we must also take into account the 
statutory factors set forth in Section 503(b)(2)(E) of the Act, which include the nature, circumstances, 
extent, and gravity of the violations, 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.14 Applying the Forfeiture 
Policy Statement, Section 1.80 of the Rules, and the statutory factors to the instant case, we conclude that 
World Media is apparently liable for $21,000 forfeiture.
 
IV. ORDERING CLAUSES
10. Accordingly, IT IS ORDERED that, pursuant to Section 503(b) of the Communications 
Act of 1934, as amended, and Sections 0.111, 0.311, 0.314 and 1.80 of the Commission's Rules, World 
Media Broadcast Company is hereby NOTIFIED of this APPARENT LIABILITY FOR A 
  
9 47 C.F.R. § 73.1400(a)(1)(ii).
10 47 C.F.R. § 73.3526(a)(2).
11 47 C.F.R. § 73.3526(b).
12 47 C.F.R. § 73.3526(c).
13 12 FCC Rcd 17087 (1997), recon. denied, 15 FCC Rcd 303 (1999); 47 C.F.R. § 1.80.
14 47 U.S.C. § 503(b)(2)(E).
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FORFEITURE in the amount of twenty-one thousand dollars ($21,000) for violations of Sections 
11.35(a), 73.1400(a)(1)(ii) and 73.3526 of the Rules.15
11. 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 for Forfeiture, World Media 
Broadcast Company, 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 credit card, check or similar instrument, 
payable to the order of the Federal Communications Commission.  The payment must include the 
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 Federal Reserve Bank of New York, 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. 20554.16  If you have questions, please contact the Financial 
Operations Group Help Desk at 1-877-480-3201 or Email: ARINQUIRIES@fcc.gov.  If payment is 
made, World Media Broadcast Company will send electronic notification on the date said payment is 
made to SCR-Response@fcc.gov.
13. The response, if any, must be mailed to Federal Communications Commission, 
Enforcement Bureau, South Central Region, Norfolk Office 1457 Mount Pleasant Rd, Suite 113, 
Chesapeake, Virginia 23322 and must include the NAL/Acct. No. referenced in the caption.  
14. 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 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.  
  
15 47 U.S.C. § 503(b); 47 C.F.R. §§ 0.111, 0.311, 0.314, 1.80, 11.35(a), 73.1400(a)(1)(ii), 73.3526.
16 See 47 C.F.R. § 1.1914
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15. IT IS FURTHER ORDERED that a copy of this Notice of Apparent Liability for 
Forfeiture shall be sent by Certified Mail, Return Receipt Requested, and regular mail, to World Media 
Broadcast Company, at its address of record.  
FEDERAL COMMUNICATIONS COMMISSION
Luther Bolden
Resident Agent
Norfolk Office
South Central Region
Enforcement Bureau