Federal Communications Commission
Washington, D.C. 20554
Approved by OMB
3060-0009 (June 2010)
FCC 316
FOR FCC USE ONLY
 
APPLICATION FOR CONSENT TO ASSIGN BROADCAST STATION CONSTRUCTION PERMIT OR LICENSE OR TO TRANSFER CONTROL OF ENTITY HOLDING BROADCAST STATION CONSTRUCTION PERMIT OR LICENSE

Read INSTRUCTIONS Before Filling Out Form

FOR COMMISSION USE ONLY
FILE NO.

BTCH - 20061018ACO
Section I - General Information
1. Legal Name of the Licensee/Permittee
BROWN BROADCASTING SERVICE, INC.
Mailing Address
88 BENEVOLENT ST.

City
PROVIDENCE
State or Country (if foreign address)
RI
Zip Code
02906 - 2046
Telephone Number (include area code)
4012729550
E-Mail Address (if available)
GM@WBRU.COM
FCC Registration Number:
0003764453
Call Sign
WBRU
Facility ID Number
7313
2. Contact Representative (if other than licensee/permittee)
PETER TANNENWALD
Firm or Company Name
IRWIN, CAMPBELL & TANNENWALD, P.C.
Mailing Address
1730 RHODE ISLAND AVE., N.W.
SUITE 200

City
WASHINGTON
State or Country (if foreign address)
DC
ZIP Code
20036 - 3120
Telephone Number (include area code)
2027280400

E-Mail Address (if available)
PTANNENWALD@ICTPC.COM
3. If this application has been submitted without a fee, indicate reason for fee exemption (see 47 C.F.R. Section 1.1114):
Governmental Entity Noncommercial Educational Licensee/Permittee Other
N/A (Fee Required)
4.
a.  Voluntary Assignment or Transfer of Control  Involuntary Assignment or Transfer of Control
Amendment to pending application
File number of pending application: -

If an amendment, submit as an Exhibit a listing, by Section and Question Number, of the portions of the pending application that are being revised.

[Exhibit 1]

b.

Applicant certifies that the use of FCC Form 316 is appropriate for this transaction.

 

Yes No
See Explanation in
[Exhibit 2]
5.

Were any of the authorizations that are the subject of this application obtained through the Commission's competitive bidding procedures (see 47 C.F.R. Sections 1.2111(a) and 73.5000)?

If yes, list pertinent authorizations in an Exhibit.

Yes No

[Exhibit 3]



NOTE: In addition to the information called for in this section, an explanatory exhibit providing full particulars must be submitted for each question for which a "No" response is provided.

Section II - Assignor/Transferor

1. Certification.   Assignor/Transferor certifies that it has answered each question in this application based on its review of the application instructions and worksheets. Assignor/Transferor further certifies that where it has made an affirmative certification below, this certification constitutes its representation that the application satisfies each of the pertinent standards and criteria set forth in the application instructions and worksheets. Yes No
2.
Application for (check one): Consent to Assign Construction Permit Consent to Transfer Control of Permittee
Consent to Assign License Consent to Transfer Control of Licensee
Amendment to pending application
3.
Legal Name of the Assignor/Transferor
OLD BOARD OF DIRECTORS
Mailing Address
BROWN BROADCASTING SERVICE, INC.
88 BENEVOLENT ST.,

City
PROVIDENCE
State or Country (if foreign address)
RI
Zip Code
02906 - 2046
Telephone Number (include area code)
4012729550
E-Mail Address (if available)

GM@WBRU.COM
4.
Contact Representative (if other than Assignor/Transferor)
PETER TANNENWALD
Firm or Company Name
IRWIN, CAMPBELL & TANNENWALD, P.C.
Mailing Address
1730 RHODE ISLAND AVE., N.W.
SUITE 200

City
WASHINGTON
State or Country (if foreign address)
DC
Zip Code
20036 - 3120
Telephone Number (include area code)
2027280400

E-Mail Address (if available)
PTANNENWALD@ICTPC.COM
 
If more than one Transferor, submit the information requested in Questions 3 and 4 for each transferor.
[Exhibit 4]
5. Authorizations to be Assigned/Transferred. List the authorized stations and construction permits to be assigned/transferred. Provide the Facility Identification Number and the Call Sign, or the Facility Identification Number and the File Number of the Construction Permit, and the location, for each station to be assigned/transferred. Include main stations, FM and/or TV translator stations, LPTV stations, FM and/or TV booster stations.

[Enter Station Information]


List the authorized stations and construction permits to be assigned/transferred. Provide the Facility Identification Number and the Call Sign, or the Facility Identification Number and the File Number of the Construction Permit, and the location, for each station to be assigned/transferred. Include main stations, FM and/or TV translator stations, LPTV stations,, FM and/or TV booster stations.

Facility ID Number
Call Sign or Construction Permit File Number
City
State
7313 WBRU - PROVIDENCE RI


6.
Agreements for Sale/Transfer of Station.
a. If the transaction is voluntary, Assignor/Transferor certifies that:
  i. it has placed in licensee's/permittee's public inspection file(s) and submitted as an exhibit to this item copies of all agreements for the assignment/transfer of the station(s);
  ii. these documents embody the complete and final understanding between assignor/transferor and assignee/transferee; and
  iii. these agreements comply fully with the Commission's rules and policies.
b. If the transaction is involuntary, the Assignor/Transferor certifies that court orders or other authorizing documents have been issued and that it has placed in the licensee's/permittee's public inspecition file(s) and submitted to the Commission copies of such court orders or other authorizing documents.
Exhibit Required
Yes No
N/A

[Exhibit 5]


Yes No
N/A

[Exhibit 6]

7.
Character Issues. Assignor/Transferor certifies that neither licensee/permittee nor any party to the application has or has had any interest in, or connection with:
a. any broadcast application in any proceeding where character issues were left unresolved or were resolved adversely against the applicant or any party to the application; or
b. any pending broadcast application in which character issues have been raised.
Yes No

See Explanation in
[Exhibit 7]

8.
Adverse Findings. Assignor/Transferor certifies that, with respect to the assignor/transferor and each party to the application, no adverse finding has been made, nor has an adverse final action been taken by any court or administrative body in a civil or criminal proceeding brought under the provisions of any law related to any of the following: any felony; mass media-related antitrust or unfair competition; fraudulent statements to another governmental unit; or discrimination.
Yes No
See Explanation in
[Exhibit 8]
9. Auction Authorization. Assignor/transferor certifies that more than five years have passed since the issuance of the construction permit for the station being assigned, where that permit was acquired in an auction through the use of a bidding credit or other special measure. Yes No
N/A


See Explanation in
[Exhibit 9]
10. Anti-Drug Abuse Act Certification. Assignor/Transferor certifies that neither licensee/permittee nor any party to the application is subject to denial of federal benefits pursuant to Section 5301 of the Anti-Drug Abuse Act of 1988, 21 U.S.C. Section 862. Yes No

I certify that the statements in this application are true, complete, and correct to the best of my knowledge and belief, and are made in good faith. I acknowledge that all certifications and attached Exhibits are considered material representations.

Typed or Printed Name of Person Signing
MONICA BRADY-MYEROV
Typed or Printed Title of Person Signing
PRESIDENT
Signature
Date
10/18/2006
WILLFUL FALSE STATEMENTS ON THIS FORM ARE PUNISHABLE BY FINE AND/OR IMPRISONMENT (U.S. CODE, TITLE 18, SECTION 1001), AND/OR REVOCATION OF ANY STATION LICENSE OR CONSTRUCTION PERMIT (U.S. CODE, TITLE 47, SECTION 312(a)(1)), AND/OR FORFEITURE (U.S. CODE, TITLE 47, SECTION 503).



NOTE: In addition to the information called for in this section, an explanatory exhibit providing full particulars must be submitted for each question for which a "No" response is provided.

Section III - Assignee/Transferee

1. Certification.   Assignee/Transferee certifies that it has answered each question in this application based on its review of the application instructions and worksheets. Assignee/Transferee further certifies that where it has made an affirmative certification below, this certification constitutes its representation that the application satisfies each of the pertinent standards and criteria set forth in the application instructions and worksheets. Yes No
2.
Legal Name of the Assignee/Transferee
NEW BOARD OF DIRECTORS
Mailing Address
BROWN BROADCASTING SERVICE, INC.
88 BENEVOLENT ST.

City
PROVIDENCE
State or Country (if foreign address)
RI
Zip Code
02906 - 2046
Telephone Number (include area code)
4012729550
E-Mail Address (if available)

GM@WBRU.COM
3.
Contact Representative (if other than Assignee/Transferee)
PETER TANNENWALD
Firm or Company Name
IRWIN, CAMPBELL & TANNENWALD, P.C.
Mailing Address
1730 RHODE ISLAND AVE., N.W.
SUITE 200

City
WASHINGTON
State or Country (if foreign address)
DC
Zip Code
20036 - 3120
Telephone Number (include area code)
2027280400

E-Mail Address (if available)
PTANNENWALD@ICTPC.COM
 
If more than one Transferee, submit the information requested in Questions 2 and 3 for each transferee.
[Exhibit 10]
4.
Agreements for Sale/Transfer of Station. Assignee/Transferee certifies that:
a. the written agreements in the licensee/permittee's public inspection file embody the complete and final agreement for the sale or transfer of the station(s); and
b. these agreements comply fully with the Commission's rules and policies.
Yes No
[Exhibit 11]
5. Changes in interests as a result of assignment/transfer.
a. [Enter Changes in Interests Information]

Changes in Interests as a Result of Assignment/Transfer

(A) NAMES AND ADDRESSES OF ANY PARTY TO APPLICATION HOLDING AN ATTRIBUTABLE INTEREST
(B)
CITIZENSHIP
INTEREST HELD
(C) BEFORE TRANSFER OR ASSIGNMENT
(D) AFTER TRANSFER OR ASSIGNMENT
(1) Percentage Vote
(2) PercentageTotal Assets

(Equity plus Debt)

(1) Percentage Votes
(2) PercentageTotal Assets

(Equity plus Debt)

ERIC B. SCHULTZ, 47B SHEFFIELD RD., BOXFORD, MA 01921 US 12.5 0 11.1 0

(A) NAMES AND ADDRESSES OF ANY PARTY TO APPLICATION HOLDING AN ATTRIBUTABLE INTEREST
(B)
CITIZENSHIP
INTEREST HELD
(C) BEFORE TRANSFER OR ASSIGNMENT
(D) AFTER TRANSFER OR ASSIGNMENT
(1) Percentage Vote
(2) PercentageTotal Assets

(Equity plus Debt)

(1) Percentage Votes
(2) PercentageTotal Assets

(Equity plus Debt)

PETER TANNENWALD, 3910 GARRISON ST., N..W., WASHINGTON, DC 20016 US 12.5 0 11.1 0

(A) NAMES AND ADDRESSES OF ANY PARTY TO APPLICATION HOLDING AN ATTRIBUTABLE INTEREST
(B)
CITIZENSHIP
INTEREST HELD
(C) BEFORE TRANSFER OR ASSIGNMENT
(D) AFTER TRANSFER OR ASSIGNMENT
(1) Percentage Vote
(2) PercentageTotal Assets

(Equity plus Debt)

(1) Percentage Votes
(2) PercentageTotal Assets

(Equity plus Debt)

SUSAN HOWITT, 29 GARLAND RD., NEWTON, MA 02469 US 12.5 0 11.1 0

(A) NAMES AND ADDRESSES OF ANY PARTY TO APPLICATION HOLDING AN ATTRIBUTABLE INTEREST
(B)
CITIZENSHIP
INTEREST HELD
(C) BEFORE TRANSFER OR ASSIGNMENT
(D) AFTER TRANSFER OR ASSIGNMENT
(1) Percentage Vote
(2) PercentageTotal Assets

(Equity plus Debt)

(1) Percentage Votes
(2) PercentageTotal Assets

(Equity plus Debt)

DAVID H. FERRARA, 170 BEECHWOOD DRIVE, CRANSTON, RI 02921 US 12.5 0 0 0

(A) NAMES AND ADDRESSES OF ANY PARTY TO APPLICATION HOLDING AN ATTRIBUTABLE INTEREST
(B)
CITIZENSHIP
INTEREST HELD
(C) BEFORE TRANSFER OR ASSIGNMENT
(D) AFTER TRANSFER OR ASSIGNMENT
(1) Percentage Vote
(2) PercentageTotal Assets

(Equity plus Debt)

(1) Percentage Votes
(2) PercentageTotal Assets

(Equity plus Debt)

RICHARD CHASE, 12 WOODBURY RD., SOUTHBOROUGH, MA 01772 US 12.5 0 0 0

(A) NAMES AND ADDRESSES OF ANY PARTY TO APPLICATION HOLDING AN ATTRIBUTABLE INTEREST
(B)
CITIZENSHIP
INTEREST HELD
(C) BEFORE TRANSFER OR ASSIGNMENT
(D) AFTER TRANSFER OR ASSIGNMENT
(1) Percentage Vote
(2) PercentageTotal Assets

(Equity plus Debt)

(1) Percentage Votes
(2) PercentageTotal Assets

(Equity plus Debt)

MONICA BRADY-MYEROV, CAMBRIDGE, MA US 12.5 0 11.1 0

(A) NAMES AND ADDRESSES OF ANY PARTY TO APPLICATION HOLDING AN ATTRIBUTABLE INTEREST
(B)
CITIZENSHIP
INTEREST HELD
(C) BEFORE TRANSFER OR ASSIGNMENT
(D) AFTER TRANSFER OR ASSIGNMENT
(1) Percentage Vote
(2) PercentageTotal Assets

(Equity plus Debt)

(1) Percentage Votes
(2) PercentageTotal Assets

(Equity plus Debt)

STEPHEN G. HILL, 100 W. 57TH ST., NEW YORK, NY 10019 US 12.5 0 11.1 0

(A) NAMES AND ADDRESSES OF ANY PARTY TO APPLICATION HOLDING AN ATTRIBUTABLE INTEREST
(B)
CITIZENSHIP
INTEREST HELD
(C) BEFORE TRANSFER OR ASSIGNMENT
(D) AFTER TRANSFER OR ASSIGNMENT
(1) Percentage Vote
(2) PercentageTotal Assets

(Equity plus Debt)

(1) Percentage Votes
(2) PercentageTotal Assets

(Equity plus Debt)

JEREMIAH S. HUBENY, 205 LAZELL ST., HINGHAM, MA 02043 US 0 0 11.1 0

(A) NAMES AND ADDRESSES OF ANY PARTY TO APPLICATION HOLDING AN ATTRIBUTABLE INTEREST
(B)
CITIZENSHIP
INTEREST HELD
(C) BEFORE TRANSFER OR ASSIGNMENT
(D) AFTER TRANSFER OR ASSIGNMENT
(1) Percentage Vote
(2) PercentageTotal Assets

(Equity plus Debt)

(1) Percentage Votes
(2) PercentageTotal Assets

(Equity plus Debt)

RITA CIDRE, 88 BENEVOLENT ST., PROVIDENCE, RI 02906 US 12.5 0 11.1 0

(A) NAMES AND ADDRESSES OF ANY PARTY TO APPLICATION HOLDING AN ATTRIBUTABLE INTEREST
(B)
CITIZENSHIP
INTEREST HELD
(C) BEFORE TRANSFER OR ASSIGNMENT
(D) AFTER TRANSFER OR ASSIGNMENT
(1) Percentage Vote
(2) PercentageTotal Assets

(Equity plus Debt)

(1) Percentage Votes
(2) PercentageTotal Assets

(Equity plus Debt)

JEAN HARRINGTON, ONE TURKS HEAD PLACE, SUITE 1200, PROVIDENCE, RI 02903 US 0 0 11.1 0

(A) NAMES AND ADDRESSES OF ANY PARTY TO APPLICATION HOLDING AN ATTRIBUTABLE INTEREST
(B)
CITIZENSHIP
INTEREST HELD
(C) BEFORE TRANSFER OR ASSIGNMENT
(D) AFTER TRANSFER OR ASSIGNMENT
(1) Percentage Vote
(2) PercentageTotal Assets

(Equity plus Debt)

(1) Percentage Votes
(2) PercentageTotal Assets

(Equity plus Debt)

TRACEY CUGNO, 23 PERKINS AVE., NARRAGANSETT, RI 02882 US 0 0 11.1 0


or [Exhibit 12]
 
 
b. Applicant certifies that equity interests not set forth above are non-attributable.
Yes No

N/A

[Exhibit 13]

6. Other Authorizations. List call signs, locations, and facility identifiers of all other broadcast stations in which assignee/transferee or any party to the application has an attributable interest. N/A

[Exhibit 14]

7. Acquisition of Control. List the file number and date of grant of FCC Form 301, 314, or 315 application by which the Commission approved the qualifications of the individual or entity with a pre-existing interest in the licensee/permittee that is now acquiring control of the licensee/permittee as a result of the grant of this application. N/A

[Exhibit 15]

8.
Character Issues. Assignee/Transferee certifies that neither assignee/transferee nor any party to the application has or has had any interest in, or connection with:
a. any broadcast application in any proceeding where character issues were left unresolved or were resolved adversely against the applicant or any party to the application; or
b. any pending broadcast application in which character issues have been raised.
Yes No

See Explanation in
[Exhibit 16]

9.
Adverse Findings. Assignee/Transferee certifies that, with respect to the assignee/transferee and each party to the application, no adverse finding has been made, nor has an adverse final action been taken by any court or administrative body in a civil or criminal proceeding brought under the provisions of any law related to any of the following: any felony; mass media-related antitrust or unfair competition; fraudulent statements to another governmental unit; or discrimination.
Yes No

See Explanation in
[Exhibit 17]

10. Alien Ownership and Control. Assignee/Transferee certifies that it complies with the provisions of Section 310 of the Communications Act of 1934, as amended, relating to interests of aliens and foreign governments. Yes No

See Explanation in
[Exhibit 18]

11. Auction Authorization. Assignee/transferee certifies that where less than five years have passed since the issuance of the construction permit and the permit had been acquired in an auction through the use of a bidding credit or other special measure, it would qualify for such credit or other special measure. Yes No
N/A


See Explanation in
[Exhibit 19]
12. Anti-Drug Abuse Act Certification. Assignee/transferee certifies that neither licensee/permittee nor any party to the application is subject to denial of federal benefits pursuant to Section 5301 of the Anti-Drug Abuse Act of 1988, 21 U.S.C. Section 862. Yes No

I certify that the statements in this application are true, complete, and correct to the best of my knowledge and belief, and are made in good faith. I acknowledge that all certifications and attached Exhibits are considered material representations. I hereby waive any claim to the use of any particular frequency as against the regulatory power of the United States because of the previous use of the same, whether by license or otherwise, and request an authorization in accordance with this application. (See Section 304 of the Communications Act of 1934, as amended.)

Typed or Printed Name of Person Signing
MONICA BRADY-MYEROV
Typed or Printed Title of Person Signing
PRESIDENT
Signature
Date
10/18/2006
WILLFUL FALSE STATEMENTS ON THIS FORM ARE PUNISHABLE BY FINE AND/OR IMPRISONMENT (U.S. CODE, TITLE 18, SECTION 1001), AND/OR REVOCATION OF ANY STATION LICENSE OR CONSTRUCTION PERMIT (U.S. CODE, TITLE 47, SECTION 312(a)(1)), AND/OR FORFEITURE (U.S. CODE, TITLE 47, SECTION 503).



Exhibits
Exhibit 2
Description:
USE OF FORM 316

ALTHOUGH WBRU IS LICENSED AS A COMMERCIAL BROADCAST STATION, THE LICENSEE, BROWN BROADCASTING SERVICE, INC. ('BBS'), IS A NON-PROFIT CORPORATION WITH AN IRS TAX EXEMPTION UNDER SECTION 501(C)(3) OF THE INTERNAL REVENUE CODE. IT HAS NO STOCKHOLDERS.

THE CIRCUMSTANCE OF A NONPROFIT CORPORATION OPERATING A COMMERCIAL STATION ARISES FROM THE FACT THAT THE PRIMARY OBJECTIVE OF BBS IS TO OPERATE WBRU AS AN EDUCATIONAL WORKSHOP TO TRAIN STUDENTS ENROLLED AT BROWN UNIVERSITY IN RADIO BROADCASTING AND RELATED AREAS. THE STATION IS STAFFED AND MANAGED PRIMARY BY VOLUNTEER BROWN STUDENTS. BBS OPERATES A COMMERCIAL, RATHER THAN A NONCOMMERCIAL, STATION BECAUSE IT BELIEVES THAT LEARNING TO MANAGE A SELF-SUPPORTING BUSINESS, INCLUDING THE SALE OF ADVERTISING, IS AN INTEGRAL PART OF ITS TRAINING MISSION.
NO PARTICIPANT AT THE STATION RECEIVES ANY COMPENSATION OTHER THAN TRADITIONAL ADVERTISING SALES COMMISSIONS, SALARIES FOR A SMALL FULL-TIME PROFESSIONAL STAFF TO SUPPORT STUDENT MANAGERS WHOSE TIME IS LIMITED BECAUSE OF ACADEMIC OBLIGATIONS, AND MODEST STIPENDS TO HELP STUDENTS WHO REMAIN ON CAMPUS TO WORK AT THE STATION WHEN SCHOOL IS NOT IN SESSION MEET THEIR LIVING EXPENSES.

IN LIEU OF STOCKHOLDERS, THE CORPORATION HAS TWO CLASSES OF 'MEMBERS,' ONE MADE UP OF BROWN UNIVERSITY STUDENTS AND THE SECOND MADE UP OF CORPORATE DIRECTORS. THE CORPORATE BY-LAWS PROVIDE THAT THE 'BUSINESS AND PROPERTY OF THE CORPORATION SHALL BE MANAGED AND CONTROLLED BY A BOARD OF DIRECTORS,' EXCEPT AS OTHERWISE PROVIDED. THE EXISTING BOARD MEMBERS ELECT THEIR OWN SUCCESSORS, SUBJECT TO VETO BY THE STUDENT MEMBERS. THE ESTABLISHMENT OF A SELF-PERPETUATING BOARD OF DIRECTORS WHO (EXCEPT FOR ONE) ARE NOT STUDENTS WAS INTENDED TO GIVE CONTINUITY OF DIRECTION TO THE CORPORATION. IN LIGHT OF THE FACT THAT THE STUDENT MEMBERS CHANGE FREQUENTLY, THE CORPORATION HAS CONSISTENTLY TAKEN THE POSITION WITH THE COMMISSION, IN BOTH OWNERSHIP REPORTS AND TRANSFER APPLICATIONS, THAT LOCUS OF 'CONTROL' IS THE BOARD OF DIRECTORS.

THE BOARD OF DIRECTORS IS MADE UP OF ONE STUDENT AND ALUMNI/AE AND OTHER INTERESTED PARTIES WHO ARE WILLING TO VOLUNTEEER THEIR TIME TO LEND THEIR EXPERTISE TO THE STUDENTS MANAGING THE STATION. THE DIRECTORS CHANGE FROM TIME TO TIME, AS INDIVIDUAL BOARD MEMBERS WITHDRAW, AND THE STUDENTS SEARCH OUT AND FIND REPLACEMENTS. THE STUDENT DIRECTOR IS THE GENERAL MANAGER OF THE RADIO STATION, AND THE OCCUPANT OF THAT SEAT CHANGES ONCE A YEAR.

THE LICENSEE DOES NOT BELIEVE THAT TRUE 'CONTROL' OF BBS EVER CHANGES, BECAUSE BBS HAS ALWAYS MAINTAINED ITS CENTRAL PURPOSE OF TRAINING BROWN STUDENTS. HOWEVER, THE COMMISSION HAS DETERMINED THAT A GRADUAL CHANGE IN THE BOARD OF DIRECTORS OF A NON-PROFIT ENTITY SUCH BBS IS DEEMED A TRANSFER REQUIRING APPROVAL.

IN LIGHT OF BBS' NON-PROFIT NATURE AND LACK OF STOCKHOLDERS, GRADUAL CHANGES IN THE BBS BOARD HAVE PREVIOUSLY BEEN APPROVED ON FORM 316, IN BTCH-19860530GE AND BTCH-19931014GN. OF NINE DIRECTORS WHO HELD OFFICE IN 1993, FOUR REMAIN AFTER CHANGES OVER THE YEARS. THE MOST RECENTLY ELECTED DIRECTOR HAS AGREED NOT TO CAST ANY VOTES UNTIL THIS APPLICATION IS APPROVED. TWO ADDITIONAL REPLACEMENTS ARE ANTICIPATED TO BE ELECTED IN DECEMBER, 2006, AND ONE OF THOSE WHO IS RETIRING WAS ON THE BOARD IN 1993, WITH THE RESULT THAT ONLY THREE OF THE NINE DIRECTORS IN 1993 WILL REMAIN. THIS APPLICATION REQUESTS APPROVAL OF THE CHANGES OVER THE PAST 13 YEARS, INCLUDING THE NEWEST DIRECTOR WHO IS REFRAINING FROM VOTING AND THE TWO DIRECTORS TO BE ELECTED IN DECEMBER OF THIS YEAR.


Attachment 2


Exhibit 5
Description:
AGREEMENT FOR TRANSFER

THIS QUESTION IS ANSWERED 'YES' BECAUSE CDBS WILL NOT VALIDATE THE APPLICATION WITHOUT A 'YES' ANSWER TO EITHER QUESTION 6A OR 6B. HOWEVER, BECAUSE THIS APPLICATION INVOLVES A GRADUAL TUROVER IN THE BOARD OF DIRECTORS OF A NON-PROFIT ENTITY WITH NO STOCKHOLDERS, THERE IS NO CONTRACT OR OTHER FORMAL AGREEMENT BETWEEN THE TRANSFEROR AND TRANSFEREE. THE ONLY DOCUMENTATION OF THE CHANGE IS MINUTES OF THE VARIOUS BOARD MEETINGS WHERE VOTES WERE TAKEN TO ELECT NEW DIRECTORS, AND THOSE MINUTES ARE INTERNAL CORPORATE DOCUMENTS THAT ARE NOT IN THE PUBLIC FILE.

Attachment 5


Exhibit 11
Description:
AGREEMENTS

SEE EXHIBIT 4 FOR EXPLANATION.

Attachment 11


Exhibit 13
Description:
NON-ATTRIBUTABLE INTERESTS

THERE ARE NO NON-ATTRIBUTABLE INTERESTS IN THE LICENSEE.

Attachment 13


Exhibit 14
Description:
OTHER INTERESTS

BROWN BROADCASTING SERVICE, INC. HAS NO OTHER MEDIA INTERESTS.

MONICA BRADY-MYEROV IS EMPLOYED AS A NEWS REPORTER FOR WBUR(FM), BOSTON, MA.

TRACEY CUGNO IS EMPLOYED AS DIRECTOR OF DEVELOPMENT FOR WSBE-TV, PROVIDENCE, RI.

BOTH WBUR AND WSBE-TV ARE NONCOMMERCIAL EDUCATIONAL STATIONS, SO THEY ARE NOT ATTRIBUTABLE INTERESTS FOR PURPOSES OF SECTION 73.3555(A) OF THE COMMISSION'S RULES. IN ANY EVENT, MS. BRADY-MYEROV AND MS. CUGNO ARE ONLY EMPLOYEES OF THOSE STATIONS AND DO NOT SERVE ON THE BOARD OF DIRECTORS OR HAVE ANY OWNERSHIP INTEREST IN THE LICENSEES.

STEPHEN G. HILL IS AM EMPLOYEE OF BLACK ENTERTAINMENT TELEVISION ('BET'), WHICH SUPPLIES PROGRAMMING TO MULTI-CHANNEL VIDEO PROGRAM DISTRIBUTORS BUT IS NOT ITSELF A BROADCAST STATION OWNER. HE IS NOT A CORPORATE OFFICER OR DIRECTOR, NOR DOES HE HAVE AN ATTRIBUTABLE STOCK OWNERSHIP INTEREST IN BET.

Attachment 14


Exhibit 15
Description:
LONG FORM APPROVAL

BBS ACQUIRED WBRU ON A LONG FORM APPLICATION IN 1965. IT WAS THE SAME NON-PROFIT, NON-STOCK CORPORATION THEN, WITH THE SAME PURPOSE OF TRAINING STUDENTS, THAT IT IS TODAY. PERSONS NOW AFFILIATED WITH THE STATION DO NOT KNOW THE FILE NUMBER OF THE 1965 LONG FORM, AND IT IS NOT RETRIEVABLE FROM BAPS, BECAUSE THE BAPS ARCHIVE STARTS IN 1980. COPIES OF THE 1986 AND 1993 SHORT-FORM TRANSFER APPLICATIONS ARE AVAILABLE, BUT THOSE FORMS DID NOT ASK FOR THE 1965 FILE NUMBER.

Attachment 15