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.

BTCCDT - 20140624ABP
Section I - General Information
1. Legal Name of the Licensee/Permittee
WTAT LICENSEE, LLC
Mailing Address
2000 W. 41ST STREET

City
BALTIMORE
State or Country (if foreign address)
MD
Zip Code
21211 -
Telephone Number (include area code)
4106629688
E-Mail Address (if available)
FCC Registration Number:
0007282957
Call Sign
WTAT-TV
Facility ID Number
416
2. Contact Representative (if other than licensee/permittee)
MILES S. MASON, ESQ.
Firm or Company Name
PILLSBURY WINTHROP SHAW PITTMAN LLP
Mailing Address
2300 N STREET, NW

City
WASHINGTON
State or Country (if foreign address)
DC
ZIP Code
20037 - 1128
Telephone Number (include area code)
2026638000

E-Mail Address (if available)
MILES.MASON@PILLSBURYLAW.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
FEDDORA, INC.
Mailing Address
2000 W. 41ST STREET

City
BALTIMORE
State or Country (if foreign address)
MD
Zip Code
21211 -
Telephone Number (include area code)
4106629688
E-Mail Address (if available)

4.
Contact Representative (if other than Assignor/Transferor)
MILES S. MASON, ESQ.
Firm or Company Name
PILLSBURY WINTHROP SHAW PITTMAN LLP
Mailing Address
2300 N STREET, NW

City
WASHINGTON
State or Country (if foreign address)
DC
Zip Code
20037 -
Telephone Number (include area code)
2026638195

E-Mail Address (if available)
MILES.MASON@PILLSBURYLAW.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
416 WTAT-TV - CHARLESTON SC


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
MICHAEL ANDERSON
Typed or Printed Title of Person Signing
PRESIDENT
Signature
Date
06/24/2014
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).



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
CHARLESTON (WTAT-TV), LLC
Mailing Address
2000 W. 41ST STREET

City
BALTIMORE
State or Country (if foreign address)
MD
Zip Code
21211 -
Telephone Number (include area code)
4106629688
E-Mail Address (if available)

3.
Contact Representative (if other than Assignee/Transferee)
MILES S. MASON, ESQ.
Firm or Company Name
PILLSBURY WINTHROP SHAW PITTMAN LLP
Mailing Address
2300 N STREET, NW

City
WASHINGTON
State or Country (if foreign address)
DC
Zip Code
20037 -
Telephone Number (include area code)
2026638195

E-Mail Address (if available)
MILES.MASON@PILLSBURYLAW.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)

FEDDORA, INC., 2000 W. 41ST. STREET, BALTIMORE, MD 21211 DE 100 100 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)

CHARLESTON (WTAT-TV), LLC, 2000 W. 41ST. STREET, BALTIMORE, MD 21211 MD 0 0 100 100

(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)

CUNNINGHAM BROADCASTING CORPORATION ('CBC'), 2000 W. 41ST. STREET, BALTIMORE, MD 21211 MD 100 100 100 100


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
MICHAEL ANDERSON
Typed or Printed Title of Person Signing
PRESIDENT OF SOLE MEMBER
Signature
Date
06/24/2014
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).



Exhibits
Exhibit 2
Description:
EXHIBIT 2

THE INSTANT PRO FORMA TRANSFER OF CONTROL IS BEING FILED IN ASSOCIATION WITH AN INTERNAL RESTRUCTURING. THE MEMBERSHIP INTERESTS IN THE LICENSEE ARE BEING TRANSFERRED FROM FEDDORA, INC., A WHOLLY OWNED SUBSIDIARY OF CUNNINGHAM BROADCASTING CORPORATION ('CBC'), TO CHARLESTON (WTAT-TV), LLC, ALSO WHOLLY OWNED BY CBC. AS A RESULT, THERE WILL NOT BE A SUBSTANTIAL CHANGE IN THE OVERALL OWNERSHIP STRUCTURE OF THE LICENSEE.   ACCORDINGLY, THE USE OF THE FCC FORM 316 IS APPROPRIATE SINCE THE PROPOSED TRANSFER OF CONTROL IS FROM ONE WHOLLY OWED SUBSIDIARY TO ANOTHER.

Attachment 2
Description
Ownership Chart


Exhibit 5
Description:
EXHIBIT 5

THE INSTANT TRANSACTION IS BEING UNDERTAKEN AS AN INTERNAL REORGANIZATION AND IS NOT BEING REDUCED TO WRITING. A COPY OF THIS APPLICATION, AND ANY ASSOCIATED CORRESPONDENCE, WILL BE INCLUDED IN THE STATION'S ONLINE PUBLIC FILE.

Attachment 5


Exhibit 7
Description:
EXHIBIT 7

WHILE WE DO NOT BELIEVE THE ISSUES RAISED IN THE FOLLOWING PENDING PROCEEDINGS CONSTITUTE 'CHARACTER ISSUES,' THEY ARE BEING DISCLOSED IN AN ABUNDANCE OF CAUTION:

IN 2002 AND 2003, APPLICATIONS WERE FILED TO TRANSFER WNUV(TV), BALTIMORE, MARYLAND, WTTE(TV), COLUMBUS, OHIO, WRGT-TV, DAYTON, OHIO, WTAT-TV, CHARLESTON, SOUTH CAROLINA, AND WVAH-TV, CHARLESTON, WEST VIRGINIA, FROM SUBSIDIARIES OF CUNNINGHAM BROADCASTING CORPORATION ('CBC') TO VARIOUS SUBSIDIARIES OF SINCLAIR BROADCAST GROUP, INC. SEE FCC FILE NOS. BTCCT-20020718ABB, ABJ, BALCT-20020718ABH, ABM, ABO; BTCCT-20031107AAF, AAP, BALCT-20031107AAU, ABB, ABM. THE RAINBOW/PUSH COALITION FILED PETITIONS TO DENY THE APPLICATIONS. THE APPLICATIONS WERE DISMISSED AND RAINBOW'S PETITIONS WERE DISMISSED AS MOOT. ACCORDINGLY, NONE OF THE APPLICATIONS ARE CURRENTLY PENDING BEFORE THE COMMISSION. MOREOVER, THE MEDIA BUREAU DENIED RAINBOW'S ALLEGATIONS ON THE MERITS. SEE LETTER TO KATHRYN R. SCHMELTZER (DA 04-570), DATED FEBRUARY 27, 2004. RAINBOW HAS FILED A PETITION FOR RECONSIDERATION OF THIS DECISION, WHICH REMAINS PENDING.

ON SEPTEMBER 7, 2004, RAINBOW FILED A LETTER REFERENCING CBC'S PENDING LICENSE RENEWAL APPLICATIONS FOR WNUV(TV), WVAH-TV, AND WTAT-TV AND THE THEN-ANTICIPATED RENEWAL FILINGS FOR WTTE(TV) AND WRGT-TV AND NOTIFYING THE COMMISSION OF THE ALLEGATIONS IT HAD RAISED AGAINST CBC IN THE CONTEXT OF THE DISMISSED TRANSFER APPLICATIONS. THE MATTER REMAINS PENDING.

ON NOVEMBER 1, 2004, FREE PRESS, AN ORGANIZATION BASED IN NORTHAMPTON, MASSACHUSETTS, FILED A PETITION TO DENY AND FOR OTHER RELIEF CHALLENGING THE LICENSE RENEWAL APPLICATIONS FOR WTAT-TV, CHARLESTON, SOUTH CAROLINA, AND WMYA-TV, ANDERSON, SOUTH CAROLINA, BOTH LICENSED TO CBC SUBSIDIARIES, BASED ON THE SAME ALLEGATIONS RAISED BY RAINBOW. THE MATTER REMAINS PENDING.

ON OCTOBER 24, 2004, THE SINCLAIR MEDIA WATCH, A PROJECT OF THE ASHEVILLE, NORTH CAROLINA-BASED NONPROFIT ORGANIZATION CITIZENS FOR MEDIA LITERACY, FILED AN INFORMAL OBJECTION CHALLENGING THE LICENSE RENEWAL APPLICATION FOR WMYA-TV, ANDERSON, SOUTH CAROLINA. THE MATTER REMAINS PENDING.



Attachment 7


Exhibit 11
Description:
EXHIBIT 11

SEE EXHIBIT 5.

Attachment 11


Exhibit 14
Description:
EXHIBIT 14

THE PROPOSED TRANSFEREE'S PARENT ENTITY, CUNNINGHAM BROADCASTING CORPORATION, HAS ATTRIBUTABLE INTERESTS IN THE FOLLOWING LICENSEES AND STATIONS:

ANDERSON (WFBC-TV) LICENSEE, INC., LICENSEE OF WMYA-TV, ANDERSON, SOUTH CAROLINA (FAC. ID #56548);

BALTIMORE (WNUV-TV) LICENSEE, INC., LICENSEE OF WNUV(TV), BALTIMORE, MARYLAND (FAC. ID #7933);

COLUMBUS (WTTE-TV) LICENSEE, INC., LICENSEE OF WTTE(TV), COLUMBUS, OHIO (FAC. ID #74137);

WRGT LICENSEE, LLC, LICENSEE OF WRGT-TV, DAYTON, OHIO (FAC. ID #411);

WTAT LICENSEE, LLC, LICENSEE OF WTAT-TV, CHARLESTON, SOUTH CAROLINA (FAC. ID #416);

WVAH LICENSEE, LLC, LICENSEE OF WVAH-TV, CHARLESTON, WEST VIRGINIA (FAC. ID #417);

WDBB-TV, INC., LICENSEE OF WDBB(DT), BESSEMER, ALABAMA (FAC. ID# 71325);

PEORIA (WYZZ-TV) LICENSEE, INC., LICENSEE OF WYZZ-TV, BLOOMINGTON, ILLINOIS (FAC ID# 5875);

FLINT (WBSF-TV) LICENSEE, INC., LICENSEE OF WBSF(TV), BAY CITY, MICHIGAN (FAC ID# 82627); AND

TRAVERSE CITY (WGTU-TV) LICENSEE, INC., LICENSEE OF WGTQ(TV), SAULT STE MARIE, MI (FAC ID# 59279) AND WGTU(TV), TRAVERSE CITY, MI (FAC ID# 59280).



Attachment 14


Exhibit 15
Description:
EXHIBIT 15

SEE FCC FILE NO. BALCDT-20130315ACP - GRANTED NOVEMBER 18, 2013 AND CONSUMMATED NOVEMBER 22, 2013.

Attachment 15


Exhibit 16
Description:
EXHIBIT 16

WHILE WE DO NOT BELIEVE THE ISSUES RAISED IN THE FOLLOWING PENDING PROCEEDINGS CONSTITUTE 'CHARACTER ISSUES,' THEY ARE BEING DISCLOSED IN AN ABUNDANCE OF CAUTION:

IN 2002 AND 2003, APPLICATIONS WERE FILED TO TRANSFER WNUV(TV), BALTIMORE, MARYLAND, WTTE(TV), COLUMBUS, OHIO, WRGT-TV, DAYTON, OHIO, WTAT-TV, CHARLESTON, SOUTH CAROLINA, AND WVAH-TV, CHARLESTON, WEST VIRGINIA, FROM SUBSIDIARIES OF CUNNINGHAM BROADCASTING CORPORATION ('CBC') TO VARIOUS SUBSIDIARIES OF SINCLAIR BROADCAST GROUP, INC. SEE FCC FILE NOS. BTCCT-20020718ABB, ABJ, BALCT-20020718ABH, ABM, ABO; BTCCT-20031107AAF, AAP, BALCT-20031107AAU, ABB, ABM. THE RAINBOW/PUSH COALITION FILED PETITIONS TO DENY THE APPLICATIONS. THE APPLICATIONS WERE DISMISSED AND RAINBOW'S PETITIONS WERE DISMISSED AS MOOT. ACCORDINGLY, NONE OF THE APPLICATIONS ARE CURRENTLY PENDING BEFORE THE COMMISSION. MOREOVER, THE MEDIA BUREAU DENIED RAINBOW'S ALLEGATIONS ON THE MERITS. SEE LETTER TO KATHRYN R. SCHMELTZER (DA 04-570), DATED FEBRUARY 27, 2004. RAINBOW HAS FILED A PETITION FOR RECONSIDERATION OF THIS DECISION, WHICH REMAINS PENDING.

ON SEPTEMBER 7, 2004, RAINBOW FILED A LETTER REFERENCING CBC'S PENDING LICENSE RENEWAL APPLICATIONS FOR WNUV(TV), WVAH-TV, AND WTAT-TV AND THE THEN-ANTICIPATED RENEWAL FILINGS FOR WTTE(TV) AND WRGT-TV AND NOTIFYING THE COMMISSION OF THE ALLEGATIONS IT HAD RAISED AGAINST CBC IN THE CONTEXT OF THE DISMISSED TRANSFER APPLICATIONS. THE MATTER REMAINS PENDING.

ON NOVEMBER 1, 2004, FREE PRESS, AN ORGANIZATION BASED IN NORTHAMPTON, MASSACHUSETTS, FILED A PETITION TO DENY AND FOR OTHER RELIEF CHALLENGING THE LICENSE RENEWAL APPLICATIONS FOR WTAT-TV, CHARLESTON, SOUTH CAROLINA, AND WMYA-TV, ANDERSON, SOUTH CAROLINA, BOTH LICENSED TO CBC SUBSIDIARIES, BASED ON THE SAME ALLEGATIONS RAISED BY RAINBOW. THE MATTER REMAINS PENDING.

ON OCTOBER 24, 2004, THE SINCLAIR MEDIA WATCH, A PROJECT OF THE ASHEVILLE, NORTH CAROLINA-BASED NONPROFIT ORGANIZATION CITIZENS FOR MEDIA LITERACY, FILED AN INFORMAL OBJECTION CHALLENGING THE LICENSE RENEWAL APPLICATION FOR WMYA-TV, ANDERSON, SOUTH CAROLINA. THE MATTER REMAINS PENDING.



Attachment 16