Federal Communications Commission
Washington, D.C. 20554
Approved by OMB
3060-0110
(March 2011)
FCC 303-S
FOR FCC USE ONLY
 
APPLICATION FOR RENEWAL OF BROADCAST STATION LICENSE

Read INSTRUCTIONS Before Filling Out Form

FOR COMMISSION USE ONLY
FILE NO.

BRH - 20140331AOW
Section I - General Information- TO BE COMPLETED BY ALL APPLICANTS
1. Legal Name of the Licensee
CBS RADIO STATIONS INC.
Mailing Address
1800 K STREET NW
SUITE 920

City
WASHINGTON
State or Country (if foreign address)
DC
ZIP Code
20006 -
Telephone Number (include area code)
2024574518
E-Mail Address (if available) 
RCBENEDICT@CBS.COM
FCC Registration Number:
0003616588
Facility ID Number
20350
Call Sign 
KDKA-FM
2. Contact Representative
REBECCA NEUMANN
Firm or Company Name
LERMAN SENTER PLLC
Mailing Address
2000 K STREET NW
SUITE 600
City
WASHINGTON
State or Country (if foreign address)
DC
Zip Code
20006 -
Telephone Number (include area code)
2024298970
E-Mail Address (if available)
RNEUMANN@LERMANSENTER.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 Other
N/A (Fee Required)
4.
Purpose of Application

Renewal of license
Amendment to pending renewal application

If an amendment, submit as an exhibit a listing by Section and Item Number the portions of the pending application that are being revised. [Exhibit 1]
5. Facility Information: Commercial Noncommercial Educational
6. Service and Community of License
a. AM    FM    FM Translator    LPFM
TV Translator    Low Power TV   Class A TV
Digital TV    Digital Translator or Digital LPTV   Digital Class A TV
Community of License /Area to be Served
City: PITTSBURGH State : PA
b.
Does this application include one or more FM translator station(s), or TV translator station(s), LPTV station(s), in addition to the station listed in Section I question 1? (The callsign(s) of any associated FM translators, TV translators or LPTV stations will be requested in Section V).

Yes No

7.

Other Authorizations. List call signs, facility identifiers and location(s) of any FM booster or TV booster station(s) for which renewal of license is also requested.

[Exhibit 2] N/A



NOTE: In addition to the information called for in Sections II, III, IV and V, an explanatory exhibit providing full particulars must be submitted for each item for which a "No" response is provided.

Section II - Legal - TO BE COMPLETED BY ALL APPLICANTS

1. Certification.  Licensee certifies that it has answered each question in this application based on its review of the application instructions and worksheets. Licensee 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. Character Issues. Licensee certifies that the neither the licensee 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 party to the application; or
Yes No
See Explanation in
[Exhibit 3]
b. any pending broadcast application in which character issues have been raised. Yes No
See Explanation in
[Exhibit 4]
3. Adverse Findings. Licensee certifies that, with respect to the licensee 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 provisons of any laws related to 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 5]

4. FCC Violations during the Preceding License Term. Licensee certifies that, with respect to the station(s) for which renewal is requested, there have been no violations by the licensee of the Communications Act of 1934, as amended, or the rules or regulations of the Commission during the preceding license term. If No, the licensee must submit an explanatory exhibit providing complete descriptions of all violations. Yes No

See Explanation in
[Exhibit 6]

5. Alien Ownership and Control. Licensee 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 7]

6. Anti-Drug Abuse Act Certification. Licensee certifies that neither licensee 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
7. Non-Discriminatory Advertising Sales Agreements. Commercial licensee certifies that its advertising sales agreements do not discriminate on the basis of race or ethnicity and that all such agreements held by the licensee contain nondiscrimination clauses. Noncommercial licensees should select “not applicable.”

Yes No
N/A

See Explanation in
[Exhibit 8]

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
JO ANN HALLER
Typed or Printed Title of Person Signing
SVP, GENERAL COUNSEL, AND ASSISTANT SECRETARY
Signature
Date
03/31/2014
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).



Section III - TO BE COMPLETED BY AM and FM LICENSEES ONLY

1. Biennial Ownership Report: Licensee certifies that the station's Biennial Ownership Report (FCC Form 323 or 323-E) has been filed with the Commission as required by 47 C.F.R. Section 73.3615. Yes No

See Explanation in
[Exhibit 9]

2. EEO Program: Licensee certifies that:
a. The station's Broadcast EEO Program Report (FCC Form 396) has been filed with the Commission, as required by 47 C.F.R. Section 73.2080(f)(1).

Specify FCC Form 396 File Number : B396 - 20140331ALB

Yes No

See Explanation in
[Exhibit 10]

b. The station has posted its most recent Broadcast EEO Public File Report on the station's website, as required by 47 C.F.R. Section 73.2080(c)(6).
Yes No
N/A

See Explanation in
[Exhibit 11]

3. Local Public File. Licensee certifies that the documentation, required by 47 C.F.R. Section 73.3526 or 73.3527, as applicable, has been placed in the station's public inspection file at the appropriate times. Yes No

See Explanation in
[Exhibit 12]

4. Adherence to Minimum Operating Schedule. Licensee certifies that, during the preceding license term, the station has not been silent (or operating for less than its prescribed minimum operating hours) for any period of more than 30 days.

If No, submit an Exhibit specifying the exact dates in the preceding license term on which the station was silent or operating for less than its prescribed minimum hours.

Yes No

See Explanation in
[Exhibit 13]

5. Discontinued Operations. Licensee certifies that during the preceding license term, the station has not been silent for any consecutive 12-month period. Yes No

See Explanation in
[Exhibit 14]

6. Silent Station Licensee certifies that the station is currently on the air broadcasting programming intended to be received by the public.
Yes No
7. Environmental Effects. Licensee certifies that the specified facility complies with the maximum permissible radio frequency electromagnetic exposure limits for controlled and uncontrolled environments.

By checking "Yes" above, the licensee also certifies that it, in coordination with other users of the site, will reduce power or cease operation as necessary to protect persons having access to the site, tower, or antenna from radio frequency electromagnetic exposure in excess of FCC guidelines.

Yes No

See Explanation in
[Exhibit 15]

8.

Radio/Newspaper Cross-Ownership. Licensee certifies that neither the applicant nor any party to this application has an attributable interest in a newspaper which: (1) is published four or more days per week, (2) is in the dominant language in the market, and (3) is published in a community entirely encompassed by:

 
a.

the 1 mV/m contour of one of the FM station(s)?

Yes No N/A
b. the 2 mV/m contour of one of the AM station(s)?
Yes No N/A

If No to either Question 8.a or 8.b, has the Commission made a finding pursuant to Section 310(d) of the Communications Act that the newspaper/broadcast combination is in the public interest?

Yes No

See Explanation in
[Exhibit 16]



Exhibits
Exhibit 3
Description:
CHARACTER-RELATED ALLEGATIONS

IN ANSWERING THIS CERTIFICATION QUESTION, THE APPLICANT HAS RELIED ON A REVIEW OF ITS FILES AND RECORDS, AND HAS EXAMINED THE PUBLIC RECORDS OF THE COMMISSION AVAILABLE AS OF MARCH 25, 2014. AS USED IN THIS CERTIFICATION, THE PHRASE 'TO APPLICANT'S KNOWLEDGE' MEANS TO APPLICANT'S ACTUAL KNOWLEDGE, DURING THE PERIOD THAT THE LICENSEE HAS OWNED THE STATION, WITHOUT FURTHER INVESTIGATION OTHER THAN AS DESCRIBED IN THIS EXHIBIT.

BASED UPON AND SUBJECT TO THE QUALIFICATIONS IN THE PRECEDING PARAGRAPH, TO APPLICANT'S KNOWLEDGE, NO CHARACTER ISSUES WERE RESOLVED ADVERSELY OR HAVE BEEN LEFT UNRESOLVED AGAINST THE APPLICANT OR A PARTY TO THE APPLICATION.

Attachment 3


Exhibit 4
Description:
CHARACTER-RELATED ALLEGATIONS

IN ANSWERING THIS CERTIFICATION QUESTION, THE APPLICANT HAS RELIED ON A REVIEW OF ITS FILES AND RECORDS, AND HAS EXAMINED THE PUBLIC RECORDS OF THE COMMISSION AVAILABLE AS OF MARCH 25, 2014. AS USED IN THIS CERTIFICATION, THE PHRASE 'TO APPLICANT'S KNOWLEDGE' MEANS TO APPLICANT'S ACTUAL KNOWLEDGE, DURING THE PERIOD THAT THE LICENSEE HAS OWNED THE STATION, WITHOUT FURTHER INVESTIGATION OTHER THAN AS DESCRIBED IN THIS EXHIBIT.

BASED UPON AND SUBJECT TO THE QUALIFICATIONS IN THE PRECEDING PARAGRAPH, TO APPLICANT'S KNOWLEDGE, AND WITHOUT CONCEDING THE VALIDITY OF ANY MATTER DISCLOSED IN THIS EXHIBIT, THE FOLLOWING CHARACTER-RELATED ALLEGATIONS HAVE BEEN RAISED IN CONNECTION WITH PENDING BROADCAST APPLICATIONS:

CHARACTER-RELATED ALLEGATIONS WERE RAISED (I) IN A PETITION TO DENY ('WXYT PETITION TO DENY') FILED ON SEPTEMBER 1, 2004 BY RIGHT TO DECENCY, INC. ('RTD') AND AMERICAN DECENCY ASSOCIATION ('ADA') AGAINST THE APPLICATION FOR RENEWAL OF LICENSE FOR STATION WXYT-FM (FORMERLY WKRK-FM), DETROIT, MICHIGAN, FCC FILE NO. BRH-20040601BHZ AND (II) IN AN INFORMAL OBJECTION ('WNOW INFORMAL OBJECTION') FILED ON MAY 24, 2006 ALSO BY RTD AND ADA AGAINST THE APPLICATION FOR RENEWAL OF LICENSE FOR STATION WNOW-FM (FORMERLY WXRK(FM) AND WFNY-FM), NEW YORK, NY, FCC FILE NO. BRH-20060201BAP. THE LICENSEE OF WXYT-FM AND WNOW-FM (CBS RADIO EAST INC.) AND THE LICENSEE OF THE APPLICANT ARE COMMONLY OWNED. IN THE WXYT PETITION TO DENY, THE PETITIONERS SUGGESTED THAT THE LICENSEE OF WXYT-FM LACKED THE BASIC CHARACTER QUALIFICATIONS TO BE A COMMISSION LICENSEE BECAUSE OF ALLEGED VIOLATIONS OF THE COMMISSION'S RULE ON THE BROADCAST OF INDECENT MATERIAL. IN THE WNOW INFORMAL OBJECTION, RTD AND ADA INCORPORATED BY REFERENCE THE WXYT PETITION TO DENY, REFERENCED THE PROGRAMMING AT ISSUE IN INFINITY BROADCASTING OPERATIONS, INC., NOTICE OF APPARENT LIABILITY FOR FORFEITURE, 18 FCC RCD 19954 (2003) ('OPIE AND ANTHONY NAL'), AND SUGGESTED THAT THE LICENSEE OF WXRK(FM) LACKED THE BASIC CHARACTER QUALIFICATIONS TO BE A COMMISSION LICENSEE BECAUSE OF ALLEGED VIOLATIONS OF THE COMMISSION'S RULE ON THE BROADCAST OF INDECENT MATERIAL.

ON NOVEMBER 23, 2004, THE FCC APPROVED A CONSENT DECREE ('2004 CONSENT DECREE') ENTERED BY VIACOM INC. (NOW KNOWN AS CBS CORPORATION), WHICH RESOLVED ALL ALLEGATIONS THAT VIACOM INC. AND ITS LICENSEE SUBSIDIARIES HAD VIOLATED THE BROADCAST INDECENCY LAWS WITH RESPECT TO ANY MATERIAL BROADCAST BEFORE THAT DATE, WITH THE EXCEPTION OF THE CBS TELEVISION NETWORK'S COVERAGE OF THE SUPER BOWL HALFTIME SHOW ON FEBRUARY 1, 2004. IN ITS ORDER APPROVING THE 2004 CONSENT DECREE, THE COMMISSION STATED THAT 'THERE ARE NO SUBSTANTIAL AND MATERIAL QUESTIONS OF FACT IN REGARD TO THESE MATTERS AS TO WHETHER VIACOM POSSESSES THE BASIC QUALIFICATIONS, INCLUDING ITS CHARACTER QUALIFICATIONS, TO HOLD OR OBTAIN ANY FCC LICENSES OR AUTHORIZATIONS.' IN THE MATTER OF VIACOM INC., ET AL., 19 FCC RCD 23100 (REL. NOV. 23, 2004), RECON. DENIED 21 FCC RCD 12223 (REL. OCT. 17, 2006) ('2006 ORDER ON RECONSIDERATION'). ALTHOUGH THE WNOW INFORMAL OBJECTION WAS FILED AFTER THE 2004 CONSENT DECREE, THE ALLEGATIONS SET FORTH IN THE WNOW INFORMAL OBJECTION WERE VAGUE AND GENERALLY RELATED TO ALLEGED VIOLATIONS OF THE COMMISSION'S RULE ON THE BROADCAST OF INDECENT MATERIAL (A) THAT AROSE PRIOR TO THE EFFECTIVE DATE OF THE 2004 CONSENT DECREE (NOV. 23, 2004) AND (B) THAT WERE GOVERNED BY THE 2004 CONSENT DECREE AND 2006 ORDER ON RECONSIDERATION (ISSUED AFTER THE WNOW INFORMAL OBJECTION WAS FILED). SEE 2006 ORDER ON RECONSIDERATION, 21 FCC RCD AT 12225-26 ('THE COMMISSION... AGREED NOT TO USE THE FACTS OF THE [2004] CONSENT DECREE, THE FORFEITURE ORDERS, THE PENDING INQUIRIES OR COMPLAINTS, 'OR ANY SIMILAR COMPLAINTS' REGARDING PROGRAMMING AIRED BEFORE THE [2004] CONSENT DECREE'S EFFECTIVE DATE [(NOV. 23, 2004)] FOR ANY PURPOSE RELATING TO VIACOM OR ITS STATIONS, AND TO TREAT ALL SUCH MATTERS AS NULL AND VOID.'). ISSUES RELATING TO THE 2004 SUPER BOWL HALFTIME SHOW HAVE NOW BEEN RESOLVED WITHOUT ADVERSE CONSEQUENCE TO CBS-OWNED STATIONS. SEE CBS CORP. V FCC, 663 F. 3D 122 (3D CIR. 2011), CERT. DENIED, FCC V. CBS CORP., 132 S. CT. 2677 (2012).

Attachment 4


Exhibit 6
Description:
FCC VIOLATIONS

IN ANSWERING THIS CERTIFICATION QUESTION, THE APPLICANT HAS RELIED ON A REVIEW OF ITS FILES AND RECORDS, AND HAS EXAMINED THE PUBLIC RECORDS OF THE COMMISSION AVAILABLE AS OF MARCH 25, 2014. AS USED IN THIS EXHIBIT, THE PHRASE 'TO APPLICANT'S KNOWLEDGE' MEANS TO APPLICANT'S ACTUAL KNOWLEDGE WITHOUT FURTHER INVESTIGATION OTHER THAN AS DESCRIBED IN THIS EXHIBIT.

LICENSEE SUBMITS THE FOLLOWING INFORMATION, WHICH IS TO APPLICANT'S KNOWLEDGE, CONCERNING THE PRECEDING LICENSE TERM:

1. ON OCTOBER 2, 2003, THE COMMISSION ISSUED A NOTICE OF APPARENT LIABILITY FOR FORFEITURE RELATING TO ALL RADIO AFFILIATES OWNED BY CBS RADIO INC. (FORMERLY KNOWN AS INFINITY BROADCASTING CORPORATION, WITH VARIOUS INFINITY SUBSIDIARIES DIRECTLY AND INDIRECTLY CONTROLLED BY CBS CORPORATION, FORMERLY KNOWN AS VIACOM INC.) OF 'THE OPIE AND ANTHONY SHOW' FOR ALLEGED VIOLATION OF 18 U.S.C. 1464 AND SECTION 73.3999 OF THE COMMISSION'S RULES DUE TO THE BROADCAST OF ALLEGEDLY INDECENT MATERIAL ('2004 NAL'). THE 2004 NAL AND OTHER NALS, FORFEITURE ORDERS, LETTERS OF INQUIRY, AND UNRESOLVED COMPLAINTS BY THIRD PARTIES RELEVANT TO OTHER INFINITY STATIONS WERE RESOLVED BY A CONSENT DECREE RELEASED ON NOVEMBER 23, 2004 (FCC 04-268) ('2004 CONSENT DECREE'), WHICH BECAME A FINAL ORDER ON DECEMBER 18, 2006.

PARAGRAPH 7 OF THE 2004 CONSENT DECREE STATED THAT 'SOLELY FOR THE PURPOSE OF THIS CONSENT DECREE AND IN EXPRESS RELIANCE ON FULFILLMENT OF THE FCC'S COMMITMENTS HEREUNDER, VIACOM ADMITS THAT...CERTAIN OF THE BROADCAST MATERIAL AT ISSUE IN THE ALLEGED VIOLATIONS IS INDECENT IN VIOLATION OF 47 C.F.R. 73.3999....'   PARAGRAPH 10 THEREOF PROVIDED, AMONG OTHER THINGS, THAT 'THE COMMISSION SHALL RESCIND, VACATE AND CANCEL THE...NALS...' AND THAT FROM THE EFFECTIVE DATE IT 'SHALL NOT, EITHER ON ITS OWN MOTION OR IN RESPONSE TO ANY PETITION TO DENY OR OTHER THIRD-PARTY OBJECTION, INITIATE ANY INQUIRIES, INVESTIGATIONS, FORFEITURE PROCEEDINGS, HEARINGS, OR OTHER SANCTIONS OR ACTIONS AGAINST ANY AFFECTED LICENSEE, OR ANY PENDING OR FUTURE APPLICATION TO WHICH AN AFFECTED LICENSEE IS A PARTY (INCLUDING...ANY APPLICATION...FOR RENEWAL OF LICENSE...) BASED IN WHOLE OR IN PART ON [ ] THE NALS....'

PARAGRAPH 10 OF THE 2004 CONSENT DECREE ALSO PROVIDED THAT THE FCC 'SHALL NOT USE THE FACTS OF THIS CONSENT DECREE OR...THE NALS...OR THE UNDERLYING FACTS, BEHAVIOR, OR BROADCASTS THAT RELATE TO ANY OF THE FOREGOING, FOR ANY PURPOSE RELATING TO ANY AFFECTED LICENSEE, AND SHALL TREAT ALL SUCH MATTERS AS NULL AND VOID FOR ALL PURPOSES.'

2. ON MARCH 15, 2006, THE COMMISSION ISSUED A NOTICE OF APPARENT LIABILITY ('2006 NAL') FOR FORFEITURE AGAINST CERTAIN CBS BROADCASTING OWNED-AND-OPERATED AND AFFILIATED TELEVISION STATIONS THAT AIRED THE PROGRAM 'WITHOUT A TRACE' ON DECEMBER 31, 2004. CBS'S ALLEGED FAILURE, AS PART OF THE 2006 NAL, TO COMPLY WITH CERTAIN ASPECTS OF THE 2004 CONSENT DECREE WAS RESOLVED BY A CONSENT DECREE WHICH WAS RELEASED ON NOVEMBER 21, 2007 (DA 07-4692) ('2006 CONSENT DECREE').

PARAGRAPH 11 OF THE 2006 CONSENT DECREE STATED THAT 'SOLELY FOR THE PURPOSE OF THIS CONSENT DECREE AND IN RELIANCE ON FULFILLMENT OF THE BUREAU'S COMMITMENTS HEREUNDER, CBS ACKNOWLEDGES THAT IT INADVERTENTLY FAILED TO COMPLY WITH THE REMEDIAL STEPS SPECIFIED IN SECTION IV, PARAGRAPH 8, SUBSECTION (F) OF THE 2004 CONSENT DECREE AS CONTEMPLATED BY THE COMMISSION FOLLOWING ISSUANCE OF THE WITHOUT A TRACE NAL, UNDERSTANDS THE 2004 CONSENT DECREE'S TERMS, AND HAS TAKEN STEPS TO ENSURE THAT ADDITIONAL SUCH OVERSIGHTS DO NOT RECUR IN THE FUTURE.'

PARAGRAPH 14 OF THE 2006 CONSENT DECREE PROVIDED, AMONG OTHER THINGS, THAT THE BUREAU WOULD 'NOT USE...THE EXISTENCE OF THIS CONSENT DECREE TO INSTITUTE...ANY NEW PROCEEDING, FORMAL OR INFORMAL, OR TAKE ANY ACTION...AGAINST CBS CONCERNING THE MATTERS THAT WERE THE SUBJECT OF THE INVESTIGATION.' PARAGRAPH 14 FURTHER PROVIDED THAT THE BUREAU WOULD 'NOT USE... THE EXISTENCE OF THIS CONSENT DECREE TO INSTITUTE...ANY PROCEEDING...OR TAKE ANY ACTION...AGAINST CBS WITH RESPECT TO BASIC QUALIFICATIONS, INCLUDING ITS CHARACTER QUALIFICATIONS, TO BE A COMMISSION LICENSEE.' THE 2006 CONSENT DECREE AMENDED THE 2004 CONSENT DECREE TO EXTEND THE TERM OF CBS'S COMPLIANCE PLAN BY THREE YEARS, UNTIL NOVEMBER 23, 2010. BOTH THE 2004 AND 2006 CONSENT DECREES HAVE NOW EXPIRED BY THEIR TERMS.

3. THE LICENSEE ALSO DISCLOSES THAT ON APRIL 19, 2006, THE COMMISSION ISSUED A LETTER OF INQUIRY REQUESTING INFORMATION REGARDING CBS RADIO INC.'S ('CBS RADIO') COMPLIANCE WITH SECTIONS 317 AND 507 OF THE COMMUNICATIONS ACT AND SECTION 73.1212 OF THE COMMISSION'S RULES. CBS RADIO AND THE COMMISSION SUBSEQUENTLY ENTERED INTO A CONSENT DECREE (FCC 07-27) EFFECTIVE AS OF APRIL 12, 2007 ('2007 CONSENT DECREE').

IN PARAGRAPH 12 OF THE 2007 CONSENT DECREE, CBS RADIO ADMITTED 'SOLELY FOR THE PURPOSE OF THE CONSENT DECREE AND FOR FCC CIVIL ENFORCEMENT PURPOSES, AND IN EXPRESS RELIANCE ON THE PROVISIONS IN PARAGRAPH 8 HEREOF, AND FOR NO OTHER PURPOSE OR TO OTHER EFFECT' THAT IT HAD 'CONDUCTED AN INTERNAL INVESTIGATION WITH RESPECT TO THE MATTERS SUBJECT TO THE INVESTIGATIONS AND COMPLAINTS, AND COMPANY'S POLICIES AND PROCEDURES WITH RESPECT TO THE SPONSORSHIP IDENTIFICATION LAWS CAN BE IMPROVED SO AS TO FURTHER ENHANCE THE PROSPECTS FOR COMPANY-WIDE COMPLIANCE.' PARAGRAPH 12 FURTHER STATES THAT 'BY ENTERING INTO THIS CONSENT DECREE, COMPANY MAKES NO ADMISSION OF LIABILITY OR VIOLATION OF ANY LAW, REGULATION OR POLICY.'

AS REFERENCED ABOVE, THE LIMITED ADMISSION WAS MADE IN EXPRESS RELIANCE ON PARAGRAPH 8 OF THE 2007 CONSENT DECREE, WHICH STATES AS FOLLOWS: 'AS PART OF THE ADOPTING ORDER, THE COMMISSION SHALL TERMINATE ALL INVESTIGATIONS AND SHALL DISMISS THE COMPLAINTS WITH PREJUDICE. FROM AND AFTER THE EFFECTIVE DATE, THE COMMISSION SHALL NOT...INITIATE ANY INQUIRES, INVESTIGATIONS, FORFEITURE PROCEEDINGS, HEARINGS OR OTHER SANCTIONS OR ACTIONS AGAINST COMPANY OR ANY COMPANY STATION WITH RESPECT TO ANY PENDING OR FUTURE APPLICATION TO WHICH COMPANY IS A PARTY (INCLUDING WITHOUT LIMITATION, ANY APPLICATION FOR A NEW STATION, FOR RENEWAL OF LICENSE, FOR ASSIGNMENT OF LICENSE, OR FOR TRANSFER OF CONTROL)... BASED IN WHOLE OR IN PART ON (I) THE INVESTIGATIONS; (II) THE COMPLAINTS; (III) ANY OTHER SIMILAR INVESTIGATIONS OR COMPLAINTS ALLEGING A VIOLATION BY COMPANY, ANY COMPANY STATION, OR ANY CURRENT OR FORMER COMPANY EMPLOYEE OF THE SPONSORSHIP IDENTIFICATION LAWS PRIOR TO THE EFFECTIVE DATE; (IV) THE ALLEGATIONS CONTAINED IN ANY OF THE FOREGOING; (V) THE UNDERLYING FACTS OR CONDUCT THAT RELATE TO ANY OF THE FOREGOING....'

PARAGRAPH 8 OF THE 2007 CONSENT DECREE FURTHER STATES THAT WITHOUT LIMITATION TO THE FOREGOING, 'THE FCC SHALL NOT (A) USE THE FACTS OF THIS CONSENT DECREE, THE INVESTIGATIONS, THE COMPLAINTS OR OTHER SIMILAR COMPLAINTS...OR THE UNDERLYING FACTS, BEHAVIOR OR BROADCASTS THAT RELATE TO ANY OF THE FOREGOING, FOR ANY PURPOSE RELATED TO COMPANY, ANY COMPANY STATION OR ANY COMPANY EMPLOYEE...AND (C) SHALL TREAT ALL SUCH MATTERS AS NULL AND VOID FOR ALL PURPOSES.' THE OBLIGATIONS AGREED TO IN THE 2007 CONSENT DECREE HAVE EXPIRED.

TO THE EXTENT THAT ANY NALS, NOVS, FORFEITURE ORDERS OR OTHER ITEMS OTHERWISE DISCLOSABLE UNDER THIS QUESTION 4 PREDATED ANY OF THE ABOVE REFERENCED CONSENT DECREES AND WERE RESOLVED AS PART OF SUCH CONSENT DECREES, LICENSEE HAS NOT SPECIFICALLY LISTED THEM HEREIN. LICENSEE WILL PROVIDE A LIST OF ANY SUCH ITEMS TO THE COMMISSION UPON REQUEST.

Attachment 6


Exhibit 8
Description:
NON-DISCRIMINATION CERTIFICATION

LICENSEE CERTIFIES THAT SINCE MARCH 14, 2011, LICENSEE'S STANDARD BROADCAST TERMS AND CONDITIONS HAVE PROHIBITED DISCRIMINATION ON THE BASIS OF RACE OR ETHNICITY. SINCE MARCH 14, 2011, THE LICENSEE HAS ENDEAVORED TO ENSURE THAT ALL WRITTEN ADVERTISING SALES AGREEMENTS ENTERED INTO BY THE LICENSEE HAVE EITHER INCORPORATED BY REFERENCE THE LICENSEE'S STANDARD BROADCAST TERMS AND CONDITIONS OR HAVE CONTAINED NONDISCRIMINATION CLAUSES.

Attachment 8


Exhibit 12
Description:
LOCAL PUBLIC FILE CERTIFICATION

IN ANSWERING THIS CERTIFICATION QUESTION, THE APPLICANT REVIEWED ITS PUBLIC INSPECTION FILE AND INQUIRED OF CURRENT EMPLOYEES WHO ARE KNOWLEDGEABLE OF THE CONTENTS AND MAINTENANCE OF THE APPLICANT'S PUBLIC INSPECTION FILE. AS USED IN THIS CERTIFICATION, THE PHRASE 'TO APPLICANT'S KNOWLEDGE' MEANS TO APPLICANT'S ACTUAL KNOWLEDGE, DURING THE PERIOD THAT THE LICENSEE HAS OWNED THE STATION, WITHOUT FURTHER INVESTIGATION OTHER THAN AS DESCRIBED IN THIS EXHIBIT.

BASED UPON AND SUBJECT TO THE QUALIFICATIONS IN THE PRECEDING PARAGRAPH, TO APPLICANT'S KNOWLEDGE, ALL DOCUMENTS REQUIRED BY 47 C.F.R. 73.3526 HAVE BEEN PLACED IN THE APPLICANT'S PUBLIC INSPECTION FILE IN A MANNER THAT COMPLIES WITH COMMISSION REQUIREMENTS AS TO TIMING IN ALL MATERIAL RESPECTS.

Attachment 12