Some NALs (Notices of Apparent Liability), Forfeiture Orders, Notices of Violation (NOVs), and Consent Decrees issued by the MB (Media Bureau) or the EB (Enforcement Bureau) are worth taking a look.
Note: Clicking on the NAL amount takes you to the FCC Notice.
Clicking on the cited rule number will take you to the text of the rule.
12/14/12 – Steckline Communications was another company which seems to have been found, upon inspection, to have more than a few “problems. NOVs were issued to KQAM and KGSO, Wichita, KS, and KGYN, Guymon, OK. Steckline’s operations were tagged for:
12/13/12 – NOVs were issued to the former licensee of two Nevada stations, KWNA and KWNA-FM, Winnemucca NV, for a raft of violations. Given all the publicity this year on Public File and EAS issues, it will be interesting to see how this one shakes down as the NAL is issued:
Ely Radio, LLC was asked to respond.
12/4/12 – 73.3526 – Radio stations are back on the EB’s firing line again. Hayco Broadcasting’s two stations in Celina, OH, WCSM and WCSM-FM self reported on their Renewal that they had not placed all the required documentation in the Public File – at least nine Issues & Programs lists were missing in 2004 and 2006. The NAL for $20K was issued, $10k for each station.
12/4/12 – 73.1350, 73.1740, 73.1015 – Failure to respond promptly to the FCC, operating from an unauthorized site, and being silent without authorization brought a Forfeiture Order for $18k to the now deleted DWVUV, Leone, American Samoa. The Commission rejected various arguments and, for the second time, affirmed the fine.
11/21/12 – Apparently vacation time at the EB is over! An NAL for $13k. And the winner is: W40CN-D Waubonsee Community College’s station in Sugar Grove, IL did not file with the Commission nor place their Children’s Television Programming report in the Public File during a conversion from LPTV to a Class A station. The Commission did not accept the explanation that the station did not think they had to file the forms.
Another … and there seems to be a large string of these fines for this issue. For examle, W33BY in Detroit, MI got another of the $13k NALs. There are more, but the basic story is the same: electronic filings were not made and the paper reports are missing. “Willful and repeated” replies the FCC.
10/16/12 – It may be hard to believe, but the FCC Daily Digest has not reported any real broadcast-based fines so far this month. There was a big blast this week about companies selling cell phone jammers on Craig’s List, etc, but either the EB was on vacation or stations have suddenly become “perfect” in compliance. The best guess: this lull is almost over.
9/28/12 – 73.3526 – The failure to maintain a Public File properly was the cause of an NAL for $15k to KESQ in Indio, CA. Gulf-California Broadcasting had no Issues & Programs lists since 2005. Excuses that a company with a Time Brokerage Arrangement was responsible did not gain any favor; indeed, the fine was upped by $5k.
9/28/12 – 303(q), 17.47, 17.51 – Another tower lighting issue: Cox Communications received an NAL for $20k for not having had proper lighting on their 300-foot tower at Portsmouth, VA. The fine was doubled when Cox admitted they had not done the quarterly lighting system inspections and did not know the system was not alarming.
9/27/12 – 17.50 – And now, three: James Cable, LLC was handed a Forfeiture Order for $10k for failing to repaint/repair its tower in Durant, OK. Although the company said it had been talking about replacing the tower, the FCC essentially said “talk is not enough.”
9/26/12 – 303(q), 17.50 – Two of them this week. Another failure to keep tower paint properly maintained. Allegiance Communications in McAlester, OK, received their NAL for $10k after an inspection. Again, an agent reported he could not distinguish the bands of color at 1/4 mile. This is an easy test any station could – and should – make regularly.
9/20/12 – 303(q), 17.47, 17.51 – KAGM-FM, Strasburg, CO, received an NAL for $15k after the FCC noted their tower lights were inoperative – and the station had not been doing a daily check. In fact, the lights had been out for four months, for non-payment of the electric bill! The fine was increased 50% for the length of violation and failing to act until after the FCC notified the station.
9/8/12 – 11.35 – This one is not strictly radio and TV related, but the cable system on St, George Island, FL received an NAL for … ready? … $236,500, for EAS violations and TV signal leakage. Part of it was they had an EAS box, but never installed it. But after they added the leakage fine, the failure to respond (and shut down) fines, etc., the FCC is demanding a quarter of a million dollars. Again, not necessarily broadcast, but an indication of how serious they take some of these issues.
8/31/12 – 73.3598 – How likely is the FCC to waive a fine if you file a 302 about four years late? (See 8/1/11 below) Somewhere between not a chance and who are you kidding? WKLC, St. Albans, WV just got a Forfeiture Order, indicating the FCC is not interested in any more excuses or adjustments. The fine of $7k stands.
8/22/12 – 73.1206 – Someone at Spanish Broadcasting Company will likely be paying attention, as the FCC confirmed their policy on recording phone calls without permission with a Forfeiture Order for $25k. The incidents go back to 2006 at WZNT, San Juan,PR.
8/21/12 – 73.3526, 17.57 – It was another Public File Violation that will cost J&J Broadcasting’s WJMS and WIMI(FM) $13k, according to the NAL from the FCC. It was a failure to maintain and make available the Issues and Programs lists – five of them since the stations were purchased, plus not notifying the FCC of change of ownership of the radio tower.
8/13/12 – 73.3539 – The FCC tagged WDSR, Lake City, FL. for failing to turn in the renewal in 2004 on time. Largely on the failure to have an STA and renewing it, the Forfeiture Order for $3.2k represented a slight reduction as the FCC was barred from fining the station for operation between 2004 and 2006.
8/1/12 – 11.35, 73.1745 – The former owner of WLTM-FM and WNIX-AM in Greenville, MS was given an NAL for $15k. When a field agent inspected the stations, Debut Broadcasting Mississippi had been operating with non-directional day power at night, and an EAS receiver was out of service for an undetermined time period.
7/31/12 – 301 – An NAL for $10k was issued to WSJU-TV in San Juan, PR for using an STL frequency without a license.
7/27/12 – 73.3526 – Another Self-reported violation is affirmed for WWNQ, Forest ACres, SC. The NAL was for $10k (see 4/10/12 below) Public File violations. The FCC again rejected arguments as to the amount of the fine and the issue of “willful,” but also noted that “recreated” Issues & Programs lists do not obviate the violation.
7/27/12 – 73.3527 – The FCC affirmed the NAL for $10k to WTXR, Toccoa Falls College in Georgia (see 5/12/12 below). The Forfeiture Order clearly rejects one by one all of the common excuses for Public File violations: “it wasn’t willfiul,” “we are an NCE station,” “we self-reported and told the truth,” “it wasn’t so bad,” “the fine is too high,” etc.
7/26/12 – 301 – NALs for $68k went to Mt. Rushmore Broadcasting’s stations in Casper, WY for operating STLs without licenses or, in one case, being 0.3 miles from the authorized location. In each case, the fine was doubled because of the long period of violation – in two cases it was over 15 years – and that the stations had no documentation permitting their operation. The stations involved were KASS(FM), KQLT(FM), KHOC(FM), and KMLD(FM)/WLP722.
7/26/12 – 73.1125 – WJDZ, Pastillo, PR was tagged with an NAL for $7k for not having anyone at their Main Studio when inspected during Business Hours. Apparently, it did not impress the station, as the field agent came four more times in the next two weeks, only to find the station locked and empty.
7/18/12 – 73.49 – The FCC expects tower bases to be secure. Two NALs were issued today assessing $17k. An NAL for $10k went to WCMC, Wildwood, NJ and WPWC in Dumfries, VA got an NAL for $7k for not having a secure, locked fence. Why was the fine for WCMC higher? The station was told by the field agent to secure the fence – and they did not do so. Plus the station owner had a similar previous violation.
7/13/12 – 303(q), 17.48, 17.50, 17.51, 17.57 – Two NALs went out this week for tower violations. James A. Davis’s Hearne, TX antenna brought an NAL for $13k for several violations relating to failure to keep the lights operating properly and not notifying the FCC of the change in ownership of the tower.
An NAL for $3k was issued to the current owners of the antenna used by KMRI for not updating the FCC’s ASL when the station sold the tower.
7/9/12 – 11.35 – A second NAL for $8k in four days was issued for an inoperative EAS receiver. This time is was at WMAF in Madison, FL. Agents responding to a complaint that the unit was not operative found it disconnected for some six months. According to what logs existed, no EAS test reception had ever been logged.
7/6/12 – 11.35 -Lack of attention to the EAS receivers was the reason for an NAL for $8k issued to KDDD AM&FM in Dumas, TX. In this case, the EAS receiver could send tests, but could not receive tests – it had been nearly three years since the station logged a received test. The logs had no explanation of why the tests were not received. Ka-ching.
6/27/12 – A bureaucracy needs all its forms on time, and the FCC is no exception. Joseph Tesiero received an NAL for $3k because, although he won the Aucion 91 for Speculator, NY, he missed the deadline to file the required 301 form. The Commission noted they could have defaulted Tesiero and dismissed his grant, but settled for the fine.
6/15/12 – Do what you say you will do. That is the idea behind the Forfeiture Order for $25k issued to A Radio’s WEGA, Vega Baja, PR for not paying, as agreed $8k on a prior issue.
6/15/12 – 73.3526, 1.17 – The FCC issues a lot of fines for missing Issues & Programs lists. WBPO, Port Neches, TX received an NAL for $15k – it was augmented because two inspections within a year uncovered the same violation. But the other shoe dropped – and in a big way: An NAL for $25k was issued for providing incorrect factual information to the Commission, when the station certified the file was in order and up to day. As has been stated before, you must be careful with anything submitted to the FCC.
6/14/12 – 73.1745 – Birach Broadcasting got its second NAL in two weeks. This time its WOAP in Owasso, MI was issued an NAL for $4k for operating a daytime station at night. The station argued it was operating under a PSSA (which was withdrawn in 2007) or a Construction Permit (which was never built).
6/13/12 – The FCC cancelled the licenses of five stations and translators, with effective dates as far back as 2001. According to the FCC’s letter, most of the facilities had never operated as authorized. Some were dark for over a year. The Commission deleted all the licenses and denied the attempted transfer of one of the stations.
6/13/12 – 17.47, 17.51, 73.1745 – Debut Broadcasting’s WNLA-AM received an NAL for $14k for over power operation and tower lighting violations. The field agents had responded to a complaint that the station was operating with day power at night – and discovered the tower lights were out. Although the station knew it, they did not notify the FAA, even after the agents visit.
5/29/12 – 73.3526, 17.57 – Issues & Programs and tower registration were at the core of an NAL for $13k issued to Quinn Broadcasting, owner of WSNJ and WMVB in NJ. Seven I&P issues were missing, and the station failed to change the ASR records when they bought WSNJ. Because they operated for eight years without the notification, the fine was increased by $3k.
5/23/12 – 73.49 – A broken hasp cost a York, PA station $7k. WOYK was issued an NAL for $7k after an inspection by field agents determined the gate was not secured (and would not close). Although the station repaired the gate immediately after being informed by the field agents, the FCC determined the $7k fine was warranted – the station should have known and fixed it itself.
5/18/12 – 73.1206 – Improperly recording a telephone call, even though it was not broadcast netted a $2k NAL to WWEG, Myersville, MD. The call was reported to the FCC by the recipient. Largely because the station immediately stopped the recording and did not air it, the fine was reduced from $4k to $2k. But the FCC emphasized that notification by broadcasters must occur before any recording or airing is done – with the exception of those phone lines where the caller specifically calls in to go on the air.
5/18/12 – 399, 73.503 – Another case of repeated violations led to a Forfeiture Order for $12,500 to KUFW in Woodlake, CA. This case, which dates back to incidents in 2005 and 2006, deals with over 2000 prohibited advertisements on a non-comm station. Proper and improper language are discussed in the FO.
5/18/12 – 73.1125, 73.1225, 73.1350 – An NAL for $21,500 was the result of several visits by a FCC Field Agent to KZMX AM/FM in Hot Springs, SD, only to find the main studio locked and unable to get any phone number answered. Without access to the station for inspection, and visually noting the repeated use of an unlicensed FM antenna, the fine was increased to $21.5k.
5/15/12 – 303(q), 17.48, 17.50, 17.51, 17.57 – The FCC has issued another NAL, for $13k, to a tower owner, even though the tower is not used for broadcast. The key points: when the tower was sold from Clear Channel the new owner did not register in the ASR database, with poor paint, no lights, with no NOTAM the tower was a hazard, and the new owner did not respond to an FCC letter.
The regulatory issue is in Section 303(q), where it says: “In the event that the tower ceases to be licensed by the Commission for the transmission of radio energy, the owner of the tower shall maintain the prescribed painting and/or illumination of such tower until it is dismantled, and the Commission may require the owner to dismantle and remove the tower when the Administrator of the Federal Aviation Agency determines that there is a reasonable possibility that it may constitute a menace to air
5/15/12 – 73.3527 – WKCR-FM, Columbia University, New York City drew an NAL for $10k for self-reporting the lack of Issues & Programs lists during their operations from the last renewal period. The FCC said it would have given a short term renewal but since the station must renew in 2014, it decided to let that stand.
5/14/12 – 73.3526, 73.3527 – Three stations checked the box indicated they had not properly filed everything in the Public Information File during the last license period. What makes things a bit different for Yeary Broadcasts’ WXLZ AM and FM and University of Maryland, Eastern Shore’s WESM is that is past eight years, 32 of the quarterly reports were missed. The FCC issued NALs for $10k each – PLUS a short term renewal of only fours years.
5/2/12 – Another station checked “no” on the renewal form regarding the Public File contents. And, as a reward, Toccoa Falls College station WTXR. Toccoa Falls, GA received an NAL for $10k. The FCC is not showing any sympathy to stations that fail to put the Issues & Programs lists in the files – on time – and maintain the Public File.
5/1/12 – The FCC warned the “owner” of four towers, left over from a silent AM directional station, that they faced sanction and fines if they did not immediately report the actual ownership of the towers, get them lit, and possibly painted – or drop them. Fines of $16k a day, $112.5k for a single act … and worse … were mentioned.
4/27/12 – 73.3539, 73.1740 – WVBC, Bethany, WV received an NAL for $6.5k because of a late renewal filing and for being silent over 30 days without authorization. The Bethany College station appears to have closed for the summer, but missed a couple of very important tasks – a timely warning as this school year comes to a close.
4/26/12 – 73.3526 – The operator of four stations in Florida, Opus Broadcasting received four NALF’s, each for $4k, this week for its WANK, WHTF, WWOF, and WQTL. Station owners admitted on the Renewal Form that they had not kept the Public File properly, specifically the Issues & Programs lists. The NALFs came back accordingly.
4/24/12 – 73.3526 – Two more stations have self-reported themselves into an NAL for a $10k fine for Public File violations. WHLG(FM), Port St. Lucie, FL and WSBH(FM), Satellite Beach, FL, both owned by Horton Broadcasting, checked the “no” box on the License Renewal Form asking if the required items were placed in the Public File at the appropriate times. Noting that the violations were “extensive,” running the entire time the stations were owned (as long as five years), the FCC was ready, willing, and able to asses the fines.
4/18/12 – A California station, KXDZ in Templeton, is the latest to get a Public File NAL for $10k for having missing Issues and Programs lists. Among the excuses, part of the violation was from before they bought the station. That did not fly.
4/10/12 – 73.3526, 73.3527 – Self-reporting on their Renewal Applications that they violated the Public File rules cost a pair of stations NALs for $10K each. WWNQ(FM), Forest Acres, SC and WBMQ(FM), Monroe, LA both answered “no” to the question certifying all proper Public File items were properly filed on time. A discussion on the how to prevent this problem is located here.
4/6/12 – 73.1745 – Sometimes, an NAL comes out the shute fast: after all, it only takes two events to be “willful and repeated.” ERJ Media’s WOIR, Miami FL was observed not reducing power from 5 kW to 500 Watts two nights in a row (the field strength was “approximately the same value…”), and had no explanation during an inspection the next day. The NAL cash register total: $4k
4/5/12 – 17.47, 17.51, 17.56 – The EB issued two separate NALs totalling $32k to Telava for violations in Kentucky and Georgia of various tower light issues, including failure to be lit as authorized, not visually inspecting the tower lights each day and improper reporting of outages. One site was said to have had no power at all since April 2010; the other site apparently had power, but no lights, and despite FCC contact, the lights were still not repaired over a year later. The NALs do not mention specific stations, but emphasize that monitoring tower lights is not a trivial matter.
4/2/12 – 73.1125, 73.3526 – A reduction from $25k to $500 might seem like a victory, but Vision Latina’s KBPO, Port Neches, TX, there is a double-edged sword there. KBPO received their Forfeiture Order based on ability to pay, which typically means the $500 represents a little less than 8% of the station’s gross income. Furthermore, although the station has certified they are now in compliance, the FCC is now aware of KBPO, and likely will check again – but likely without allowing another reduction in fine if the same violations are found.
3/26/12 – There are too many items to list on this one, so we will invite you to read the story of how and why DWHNY, McComb, MS lost its license – and why the FCC declined to make any accomodation to the owner, Charles Holt. Be sure to note the contents of footnotes 5, 13, and 25 for additional background.
But it gets better (worse?). Get yourself a large cup of coffee (a BDR Mug would be helpful) and get ready to be surprised at how this case meandered for well over a decade: The FCC issued a notice about DWLMA, Greenwood, SC. This former station, which has trying to sell itself for $75,000, has not had a valid authorization for as long as 15 years. It moved without authorization and … well …according to Powell Way, this station is “still on the air as if nothing happened.”
3/19/12 – 76.64 – Two NALs for $15k were assessed to one cable company, Bailey’s Cable TV in Louisiana, for carrying two TV stations without re-transmission permission. The fine, reduced from $310k total, due to Bailey’s financial condition, was accompanied by a stern warning that this provided no precedent for future reductions.
3/9/12 – 73.3526, 73.49, 11.35 – WNFO, Sun City Hilton Head, SC racked up a pretty sizeable NAL for $25k after the FCC field agents responded to a complaint and visited in July 2011. A broken tower fence, no EAS connected, and no Public File were cited.
The owner apparently refused to meet with the field agents on two separate days, nor would he send a representative. His claim was that an LMA company failed to keep the Public File available and vandals had caused the other problems, breaking into the transmitter building and fence, leaving some gear, but taking the EAS logs, and then locking the building back with its padlock was just not entirely credible.
3/7/12 – The FCC released a special Public Notice today that informs potential users of jamming devices on GPS or cell frequencies, for example, that fines of $100,000 will be part of the FCC’s “aggressive action.” The FCC says that jammers can potentially prevent emergency or public safety communications “with tragic consequences.”
3/7/12 – 73.3526(e)(11)(iii) – Four NAL’s for $13k went out to TV stations for failure to file required materials on Children’s Programming. This comes on the heels of actions last week to downgrade a number of stations for similar violations. BELO’s WBXN-CA got one. As did the Glen Iris Baptist School (twice!). And WOIL-LP.
2/28/12 – 73.1350 – Failure to change power and pattern bought a $4k NAL to WIPC, Lake Wales, FL. The 1kW day/540 W (DA) Ni7ght station was found not to change power on several occasions. The station claimed the control system had just recently malfunctioned, and the station owner had forgotten to change the power and antenna on the night the Field Agent was checking.
2/27/12 – 17.57 – The importance of making sure all the paperwork is done on a station transfer of control is the underlying meaning of the $4.5k NAL issued to Hacienda San Eladio, PR’s WRRE. The station was purchased in 2003, however they never filed the required FCC Form 854 to notify the FCC about the changed owner of the tower structure. Due to the long delay, the $3k fine was raised 50% to $4.5k.
2/24/12 – 73.3526 – Self-reporting a violation was again the catalyst for a $10k fine for WTSM(FM) in Woodville, FL. On their renewal form 303-S, the station checked “no” in response to the requirement to certify that the proper documentation was placed in the Public File. Citing the station’s self-reported admission, the EB issued an NAL for $10k, saying that it was evident the station’s actions were “willful and repeated.” (Similar to the WODR case on 2/3/12 below.)
2/15/12 – 73.3539 – WSBU, St Bonaventure University’s student run station in NY received an NAL for $7k for their late renewal (the 2006 renewal was finally filed in 2010, after the FCC initially deleted the station). The FCC did not accept a change in the staff advisor nor the non-comm status as mitigating factors.
2/14/12 – 73.1125 – Failure to have the Main Studio open and staffed during business hours netted WJTB, Elyria, OH an NAL – and an enhanced fine. Several aspects of this are instructive. While the Field Agents were standing outside a locked door, someone drove up, apparently with the same last name as the individual in charge. When told the FCC Field Agents were there to inspect, she told them to call someone else, who did not answer the calls.
It gets better (worse?). Despite the agents explaining there needed to be staff, and despite a letter to the station, the agents returned five and a half months later to … a locked door. A letter from the station during the interim included a couple of odd excuses. The FCC, after considering matters, increased the $7k fine and issued an NAL for $10k.
2/13/12 – 76.1700 – While not strictly broadcast, perhaps some broadcasters will get a tiny modicum of comfort to know the Public File requirements affect cable systems, too. An NAL for $10k was issued to Allen’s TV Cable System in Morgan City, LA for not allowing immediate access to the Public File during business hours.
2/7/12 – 73.3526, 73.1560, 11.35, 17.51 – One might suppose it was a bargain when the FCC reduced the $42k fine racked up by KQMG AM/FM in Independence, IA. and issued an NAL for $10k. The violations read like a laundry list – and were tripped by a complaint the tower lights were not working and no NOTAM had been sought: only a single non-flashing center beacon was on. By the time the Field Agents arrived 10 days later, no lights were on at all. Worse yet (if that is possible), the operator on duty admitted the lights had been out for over three months
But, there is more. A single Public File (not correct) had no Issues & Programs list since 2001. The operator could not trigger an EAS test. There was no EAS log, but the operator said there were no EAS receptions in at least three months. There was no station log either, nor remote control for the two stations (the phone line had been disconnected) – and one was found to be running 108% of licensed power. The agents could not determine the power level of the other, as the antenna current meter was broken.
2/7/12 – 73.3526 – You might be surprised at the continuing list of stations that get cited for Public File violations. While it may be a pain to maintain, it is pretty straightfoward. But when a station is on the air over 30 years and yet the FCC comments “there was no evidence the station had ever maintained” its Public File, you know what is next: the FCC issued an NAL for $10k to KPIR, Granbury, TX.
2/6/12 – 73.1212 – In perhaps the largest specific broadcast fine in a while, the Sponsorship ID Rule was involved in the NAL for $44k issued to WLS, Chicago and its licensee “Radio License Holding XI, LLC,” (which most folks might not recognize as Citadel – pre-Cumulus). At issue was an ad, run 11 times, which was related to a state legislative issue. The Commission held that in the form broadcast (see the NAL) they were designed to sound like a news story. Given the content and manner of broadcast, the Commission decided to issue a fine for each of the 11 ads. It might also be a warning to all stations for this election year.
2/1/12 – Section 301 – While we know the FCC has been hitting pirates for $10k fines, two from Florida this week indicate that Field Agents are losing patience with some offenders. One, who pleaded poverty to reduce a previous fine of $20k to $500, was back on the air again. So, the EB figures that to send a message, an NAL for $25k was appropriate. A different pirate was found interfering with FAA transmissions. An NAL for $20k was issued.
1/24/12 – 1.903 – A somewhat strange Forfeiture Order for $3.2k was issued to Gila Electronics for running an STL for station KUKY, Welton, AZ on 956.65 MHz – at an unlicensed location, 15 miles from designated for WNTB570. While Gila attempted to defend its operation under Part 101, the FCC noted that does not apply to the final RF link in a broadcast chain. The $4k fine was reduced as Gila had no other violations in over 20 years of operation.
1/23/12 – The EB may be looking more closely at your NRSC measurement reports. An NOV was receently issued to KRDM, Redmond, OR for not having an NRSC report for over two years when inspected in October 2011.
1/20/12 – 73.1216 – A 2008 contest run by Clear Channel’s LA Cluster brought an NAL for $22k for violating the Contest Rules – and a warning. The NAL says posting contest rules on a website does not exempt a station from 73.1216. There also were conflicting dates for the contest and the judging. Significantly, the NAL ends by increasing the base fine of $4k to $22k stating, “in light of Clear Channels’ prior history of non-compliance, we caution that the imposition of even higher forfeitures may result in the future if such mis-conduct persists.” (Several previous contest violations were noted in the footnotes.)
1/19/12 – 73.3526, 73.1745 – It took a decade for the FCC to discover that WPLY in Mount Pocono, PA had no Public File and was operating at only 250 W Non-D (instead of a 4-tower DA). The fine of $14k was increased to an NAL of $17k due to the ten year failure to observe the FCC’s Rules and Regulations.
1/5/12 – 73.3526 – The FCC affirmed an $8k Forfeiture Order against Lazer Licenses in Santa Maria, CA for failure to have Issues & Programs lists available for its three stations, KSBQ, KLMM-FM, and KLUN-FM. The Order notes that although the station said the files were in the station, it apparently took three months – and an NAL – before the station actually put things right.