Table of Contents The Joint Statement on Micro Radio
Annotated Web Links
Micro Radio Art Gallery Chapter 1: Introduction |
Sailing the Spectrum from Pirates to Micro Broadcasters:
CHAPTER 4Findings, Discussion, and InterpretationsAll interviews referred to in this thesis were conducted by this researcher during the winter and spring of 1995. For further information on these interviews, including locations, see Appendix A. This study focused on the main thrust of the micro broadcasting movement as it developed in the San Francisco Bay Area and thus it may appear that this is where the movement originated. However, all participants interviewed in this study, as well as all data collected from the press and other sources, pointed to Mbanna Kantako, a blind African-American micro broadcaster in Illinois, as the originator of the modern micro broadcasting movement. (See Chapter 3 for more detailed information on Kantako and Black Liberation Radio.) San Francisco Bay Area micro broadcasters looked to his experiences before embarking on their own paths of electronic civil disobedience. Kantako's case is currently on hold because the FCC did not pursue it. According to Allan Corn, a member of the National Lawyers Guild, the Committee for Democratic Communication (CDC) is using the case of United States v. Dunifer (No. C 94-03542 CW) to push for regulatory acceptance of micro broadcasting, utilizing many of the same arguments employed in the Kantako brief. Louis Hiken, Stephen Dunifer's attorney, stated that Kantako was originally approached concerning making this challenge, but he declined to participate (observations of National Lawyers Guild forum on micro radio, September 22, 1995, Berkeley, CA). Lawrence Clance, Assistant Bureau Chief for Law, Compliance and Information Bureau, Federal Communications Commission, said that while the FCC was still interested in pursuing the Kantako case, the local U.S. Attorney's Office viewed the case as a low priority for prosecution proceedings (Appendix A, personal interview, January 10, 1995). Thus, no further action has been taken, although the case remains open. U.S. v. Dunifer (No. C 94-03542 CW) is on-going as of this writing. While initial hearings have impacted the micro radio movement (Ewell, 1995), conclusions concerning the ultimate outcome of this case must be tentative. In fact, Hiken of the CDC stated that the real trial had not begun (Appendix A, personal interview, February 15, 1995). Hiken believed the two sides were still arguing the administrative aspects of the case which he viewed as precursors to the case's primary issues. He further stated that the substantive issues associated with the case concerning access and Constitutional considerations had not yet been addressed in court. However, FCC officials disagreed with Hiken's assessment, taking the position that the Dunifer case was wholly an administrative matter concerning an unlicensed broadcast and the subsequent fine (Akizuki, 1995; FCC, 1995b).
The Origins of the San Francisco Bay Area Micro Radio Movement In the late 1980s and early 1990s, a conflict arose concerning amplified music at People's Park. Tom Schreiner of Free Radio Santa Cruz said that the City of Berkeley set up an apparently confusing permit procedure that resulted in the Berkeley police confiscating amplification equipment from several concerts at the park (Appendix A, personal interview, May 31, 1995). Since most of this equipment was rented, this resulted in unexpected expenses for the organizers and for a while stymied efforts to produce live music at the park. According to Schreiner, who was living in Berkeley at the time, someone had the idea of installing a half-watt FM transmitter on stage. The audience could then bring portable radios that would be tuned to the half-watt transmitter that would, in turn, broadcast the music on stage. A half-watt transmitter is legal under Part 15 of the Communications Act. This would make the regulated amplification equipment unnecessary and bypass the city ordinance. The concept worked and successfully circumvented the ordinance. Schreiner attributed the use of the transmitter to Dunifer of Free Radio Berkeley (Appendix A, May 31, 1995). Dunifer said that his initial motivation for starting the process that resulted in Free Radio Berkeley, the Free Communications Coalition, and the San Francisco Micro Radio Movement, was the Gulf War in 1990 (Appendix A, personal interview, March 1, 1995). Dunifer stated that his "total and absolute disgust" with what happened during the war spurred him to action. He further argued that "the media essentially moved into a spare office in the Pentagon and tried to make it some national celebration that we murdered several hundred thousand people in that part of the world." It was Dunifer's perception that the media were coopted by the Pentagon and became a propaganda tool for American foreign policy (Appendix A, March 1, 1995). Dunifer stated he was a veteran of the numerous social causes since the 1970s (Appendix A, March 1, 1995). He also described himself a full-time community activist. However, he stated that his experience in communications predated his role as activist. His first job, at age 17, was as a broadcast engineer at a television station in the Los Angeles area. At that time he received his First Class Radio and Telephone License. Dunifer described himself as a self-taught engineer and technician who has spent most of his life being self employed in those trades. As with many of the people who have gotten involved in unlicensed broadcasting, his fascination with communication and community broadcasting has been a life-long one. Therefore, it is not surprising that this would eventually merge with his activist inclinations and lead to an electronic media-based incarnation. As noted in the Ewell (1995) article, although the movement is essentially non-hierarchical, Dunifer is conceptual leader of, and a primary player in, the day-to-day operations of Free Radio Berkeley and the Free Communications Coalition.
The Micro Radio Movement Forms The micro radio movement in the Bay Area was mostly contained under an umbrella organization called the Free Communications Coalition, the "People's FCC" as its proponents called it. The Coalition included many parts, the most visible of which were the micro radio stations that fell under its banner. Dunifer said these stations were not controlled, as in a network environment, but usually shared information and technical support as well as a basic philosophy concerning media access (Appendix A, March 1, 1995). From Dunifer's perspective, placement of a station under the Coalition banner had no requirements other than a passion for free speech and an abhorrence of censorship. The Free Communications Coalition was also seen as a possible mediator of disputes between micro radio stations, thus eliminating much of the need for intervention by the FCC (Appendix A, March 1, 1995). Another aspect of this organization has been the design, assembly, shipping, and marketing of micro radio transmitter kits and related equipment. Schreiner observed that a majority of micro radio stations in California have used Free Radio Berkeley kits, although similar kits have been available from other sources (Appendix A, May 31, 1995). Schreiner added that these kits are constantly being updated and improved, as illustrated by the fact that of the five micro transmitters purchased in the Santa Cruz, CA area over the course of six months, all were of different design generations. Dunifer also has offered workshops and videos on the assembly and operation of these transmitters. The size of a shoe box and getting smaller all the time, these transmitters have become more transportable and efficient with each new generation. The FRB operation has supplied transmitters to the United Nations for developing nations, primarily the Philippines, and the Chiapas Movement in Mexico. According to Dunifer, the Free Communications Coalition operation had shipped in excess of 400 transmitter kits domestically as of March 1995 (Appendix A, March 1, 1995). The third aspect of the coalition has been the activist/outreach program. According to Dunifer, this was the most influential aspect of the movement. This has involved media outreach, public education, demonstrations, and the general goal of spreading the word of micro radio to the nation and the world. The activist/outreach program has included a newsletter, Reclaiming the Airwaves, with a circulation of 10,000 world wide; an Internet site; and a communications network that has reached activists involved in all areas (Appendix A, March 1, 1995).
Testing the Spectrum Dunifer also stated that Free Radio Berkeley had been selling transmitter kits since the late 1980s (Appendix A, March 1, 1995). Since the micro radio stations were so small, broadcasts were carried out from various locations in the Berkeley Hills and from Dunifer's 1964 Volvo station wagon. Broadcasting from different locations further served the purpose of making the station's signal more difficult to trace (Fine, 1994). Eventually, Dunifer moved the operation to his home and workshop on Allstone Way in Berkeley. Dunifer did not provide an explicit rationale for moving the operation to his home in his interview or press documents (Appendix A, March 1, 1995). However, this researcher would speculate that Dunifer decided to broadcast from a fixed location in order to facilitate FCC detection and subsequent action. According to four Declarations filed by FCC engineers on October 6, 1994, the local field office became aware of Free Radio Berkeley on the evening of April 25, 1993. On May 2, 1993, FCC field agents again monitored Dunifer's signal and tracked it to his home on Allstone Way. The FCC engineers reported in the Declarations that the occupants of the house denied the existence of the station. On June 1, 1993, the San Francisco Office of the FCC issued a Notice of Apparent Liability (NAL) to Dunifer for violation of Section 301 of the Communications Act, broadcasting without a license. The NAL carried a fine of $20,000, an excessive amount when compared to other NALs issued by the FCC for similar violations (FCC, 1989, 1990a-e, 1991a-c). As mentioned in Chapter 2, most fines have ranged from $750 to $1,000.
Challenging the FCC Dunifer said that he was a great believer in direct action and civil disobedience (Appendix A, March 1, 1995). Therefore, he saw his decision to move directly to electronic civil disobedience and an open challenge to the FCC as a logical one. It was Dunifer's stated intention to draw the attention of the FCC and force a court hearing on the legitimacy of the current regulatory scheme, a plan that had been fermenting since 1990. Statements made by Dunifer and Hiken confirmed this and suggested that CDC involvement occurred just prior to the broadcasts that led to the FCC issuing the NAL (Appendix A, March 1, 1995; February 15, 1995, respectively).
Committee for Democratic Communication (CDC) Dunifer's decision to make his station fixed instead of mobile occurred after an initial meeting with lawyers from the CDC including Hiken and Peter Francks. This change allowed the FCC to locate the station more easily and thereby draw the FCC into court. Dunifer's knowledge of electronic communication would seem to discount the idea that he did not expect the FCC to be able to find him. According to Schreiner of Free Radio Santa Cruz (FRSC), finding an FM transmitter is relatively easy (Appendix A, May 31, 1995). He illustrated this by referring to the media's success in finding the FRSC transmitter site with equipment that he stated could be purchased for a few dollars at Radio Shack. Dunifer and Hiken believed that their three-part strategy was well-planned and executed. First, Dunifer's acts of electronic civil disobedience drew the FCC into court. Second, Dunifer and Hiken stated that there was an effort to get other activists across the country to also engage in acts of electronic civil disobedience. Third, they reasoned that these acts of electronic civil disobedience would force the FCC to justify its regulatory scheme in open court in a timely fashion (Appendix A, March 1, 1995; February 15, 1995).
Micro Radio Spreads Across the Bay
Legal Maneuvering Both Hiken, Dunifer's attorney, and Clance, FCC official, discussed the forfeiture process which began after the FCC issued Dunifer the Notice of Apparent Liability (NAL) (Appendix A, February 15, 1995; January 10, 1995, respectively). The forfeiture process consisted of the steps taken by the FCC to recoup the fine it levied in the NAL. In the Dunifer case, forfeiture referred to a monetary forfeiture, or fine, as opposed to the seizing of equipment. Hiken said that the CDC attacked the basic forfeiture scheme, the financial criteria of what the forfeiture should be, and the Constitutionality of the entire licensing process itself as it applied to micro radio (Appendix A, February 15, 1995). However, the arguments raised concerning the forfeiture scheme and its application were moot, when the Court of Appeals for the Federal District Court of Washington, DC vacated the FCC Table of Fines (USTA v. FCC, 28 F.3d 1232, 1994). The FCC sustained the CDC's opposition to Dunifer's Notice of Apparent Liability. Under the operating rules of the FCC, there was no hearing, no investigation, or opportunity for argument. The local FCC office then issued a Notice of Forfeiture (NOF), confirming its assertion of liability. The CDC challenged the Notice of Forfeiture. The agency reiterated the propriety of the Notice, and informed Dunifer and his counsel that they could file an application for review, which was a petition to review that decision. That was in December 1993. The FCC took no further action until December 1994, 18 months after the initial NAL. Hiken stated that at this point, and without further contacting the CDC or Dunifer, the FCC filed for a Preliminary Injunction and Declaritory Relief with the Federal District Court for the Northern District of California to enjoin further broadcasts by Dunifer (Appendix A, February 15, 1995). Clance confirmed that this action was consistent with FCC actions in the past concerning unlicensed broadcasting (Appendix A, January 10, 1995). If the court enjoined Dunifer from broadcasting, and he ignored the injunction and continued to broadcast, he would be in contempt of court. This would then case leave the case to the U.S. Attorney's office to prosecute (Bender, 1988; Boyd, 1983; Kuipers, 1989).
United States v. Dunifer
An Analogy
At Issue
The FCC Position Silberman, as the attorney for the FCC, stated that this was a simple case of someone (Dunifer) who wished to broadcast without obtaining a license. Silberman noted that all cases brought before a judge concerning the FCC's right to regulate the airwaves in a manner determined by the agency, have been decided in the favor of the FCC (Appendix A, January 10, 1995). All precedents in federal court and the U.S. Supreme Court support this contention. Further, all major issues concerning the right of the FCC to regulate as it saw fit, barring an act of Congress, have been argued and fallen in the FCC's favor as detailed in Chapter 2 of this thesis. Therefore, from the FCC's perspective, there were no grounds for an argument; Dunifer simply broke the law and end of case (Appendix A, Silberman, Clance, January 10, 1995). Silberman did state that if Dunifer wanted to be able to obtain a permit to broadcast below the 100-watt minimum, he could have taken one of the two paths made available to the public to challenge FCC regulations. These paths were a request for a waiver or a petition for a rule making. A rule making is a request by petition for a change in a particular regulatory structure (FCC, 1993a). These options would involve a review by the Commission itself as to the merits of the request brought through official channels. Dunifer did not attempt these officially-sanctioned avenues to alter the regulation scheme to allow him to broadcast legally. Dunifer's stated motivation for violating Section 301, to challenge the regulatory scheme, had no merit in Silberman's view since an administrative solution was possible (Appendix A, January 10, 1995; observations of U.S. v. Dunifer hearing, January 20, 1995). The FCC also took the position that the court needed to file a preliminary injunction against Dunifer to enjoin him from broadcasting because of irreparable harm caused by his illegal transmissions. The FCC supported its claim of irreparable harm in two ways. First, the FCC accused Dunifer of interference with licensed broadcasters. However, these allegations were not substantiated in court (observations of U.S. v. Dunifer hearing, January 20, 1995). Second, the FCC argued that Dunifer's actions harmed the regulatory scheme itself (FCC, 1995b). According to Silberman, unchecked violation of the law would cause an increase in violations and lead to "chaos" on the airwaves similar to what occurred in the late 1920s (Appendix A, January 10, 1995; see also Chapter 2). If the court were to issue such an injunction, any future broadcast would leave Dunifer in contempt of court. This would necessitate prosecution by the U.S. Attorney, thus removing the FCC from the legal process. As explained in Chapter 2, the FCC would cease to be involved because the issue would no longer be illegal broadcasting, but contempt of court, a criminal offense. During the hearing, Silberman strenuously argued these facts, and cited multiple precedents of what he considered similar cases. Silberman implied that Judge Wilken's decision had been dictated in advance by other courts' actions. Silberman further reiterated the dire consequences of the judge not finding in his favor. His actions seemed to aggravate Wilken. This was particularly evident when Silberman made a reference to the relative ages of Wilken and himself, Silberman being the older of the two. Silberman stated that the judge was not yet born when the Constitutionality of section 301 was established in the 1943 NBC case (319 US 190, 227, 1943). Citing the nature of the Dunifer case, Judge Wilken questioned her own jurisdiction, as well as the case's Constitutional considerations. Silberman responded that she did have jurisdiction, that there were no Constitutional considerations, and that she virtually had to find in the FCC's favor. Silberman talked over the judge and Hiken six or seven times to reiterate the FCC's position (observations of U.S. v. Dunifer hearing, January 20, 1995).
Dunifer's Position Hiken, in arguing Dunifer's case, contended in the January 20, 1995 court hearing that the Commission's rules, which did not provide for licensing of a stand-alone transmitter under 100 watts, were overly restrictive and constituted a total ban against micro broadcasting (National Lawyers Guild, 1992; observations of U.S. v. Dunifer hearing, January 20, 1995). Therefore, Hiken said the rules violated Dunifer's First Amendment right to free speech. A stand-alone transmitter sends primary signals, as opposed to an FM translator, which simple boosts a signal to increase range. FM translators are legal and in wide use (FCC, 1995b). Thus, the Commission's failure to establish regulations for a micro power radio service violated its mandate to create a regulatory scheme that was the least restrictive in terms of state interest (National Lawyers Guild, 1992). Moreover, Hiken argued in the court hearing that because the FCC had refused to issue low-power radio licenses, a large percentage of individuals could not afford to participate in this medium. The cost of establishing a 100-watt radio station is easily in excess of $100,000, much of it in legal, licensing, and engineering fees. This leaves only the wealthy in control of the airwaves (National Lawyers Guild, 1992). Dunifer said that he believed that most of these costs were artificial and were designed to restrict access, violating his interpretation of the FCC's mandate to provide for "the public interest, convenience, and necessity" (Appendix A, March 1, 1995). In the court brief, Dunifer's attorneys argued that such a financial qualification did not serve the public interest, and violated the equal protection clause of the Constitution (National Lawyers Guild, 1992). Additionally, Hiken argued in the court hearing that the Commission's rules violated international treaties such as the U.N. Declaration of Human Rights, the International Covenant of Civil and Political Rights, and the American Convention on Human Rights. Since the United States is a signatory of these treaties, these treaties became U.S. law. The central theme of these treaties, as applied to this case, was that of a person's right to communicate freely with others (FCC, 1995b; National Lawyers Guild, 1992). Hiken's arguments were primarily in response to Silberman's statements. On multiple occasions, Hiken had to plead to the court when Silberman interrupted him. Hiken contended that the precedents stated by Silberman had no bearing on Dunifer's case because they did not deal with micro radio and the challenging of regulatory schemes. Further, those cases dealt with the right of the FCC to regulate the airwaves or selectively issue licenses as it saw fit. Hiken stated that he was not arguing these points (observations of U.S. v. Dunifer hearing, January 20, 1995). Hiken responded to the FCC's assertion that Dunifer had administrative alternatives to breaking the law in three ways. First, Hiken stated that such alternatives were not real alternatives because of the cost and time involved. Second, he argued that Dunifer's individual's Constitutional rights were violated because he did not have the opportunity to apply for a broadcasting license. Third, Hiken stated that the FCC rule-making and waiver process, which allowed the Commission itself to rule without review until an appeal to the courts, was an excessively lengthy process (Appendix A, February 15, 1995; observations of U.S. v. Dunifer hearing, January 20, 1995).
Judge Wilken's Decision Concerning United States v. Dunifer
Micro-proliferation: A Can of Worms From the period starting in February 1995 and ending in August 1995, the number of micro radio stations in the Greater Bay Area and Northern California increased markedly. The original three were Free Radio Berkeley, San Francisco Liberation Radio, and Radio Libre (located in the Mission District in San Francisco). The Free Communications Coalition and Free Radio Santa Cruz (FRSC) reported additional micro radio sources, including stations in Saulsalito, Hunters Point in San Francisco, San José, and Mendicino County, as well as other parts of rural Northern California (Ewell, 1995; "On the Air," 1995). A major area of proliferation was in Santa Cruz County. In addition to Free Radio Santa Cruz, located in the city of Santa Cruz, there were two stations in Watsonville, one of which was a 40-watt transmitter, another in Salinas operating on the same frequency with different programming, and a back-up transmitter for Free Radio Santa Cruz for servicing or other eventualities. According to Schreiner of Free Radio Santa Cruz, there were at least two other transmitters on-line and technically ready to go. He put the total number of micro stations in California at 20 or more (Appendix A, May 31, 1995). The Salinas and Watsonville stations were operated by Latinos and broadcast in Spanish, with some English programming. These stations were operated, at least in part, as organizing tools for labor. The micro radio movement in Santa Cruz and Northern Monterey was a significant off-shoot of the San Francisco Movement and warranted further attention (Appendix A, May 31, 1995).
Parallel Developments
Free Radio Santa Cruz Schreiner, like so many people involved with micro radio, described himself in the interview as a long-time activist. As mentioned earlier, his roots go back to the Free Speech Movement in Berkeley in the 1960s. Schreiner stated that he has been a "perpetrator" in micro broadcasting. Unlike Dunifer, he was not an engineer or technician, he has been an organizer. A high school dropout and professional carpenter, Schreiner has been working on a degree in anthropology at the University of California, Berkeley. He saw early on the possibilities in micro broadcasting, especially in organizing the new "dispossessed" class he observed emerging in America. The first station he helped set up was the first one in the Monterey Bay Area. A Spanish station located in the city of Salinas, it predated Free Radio Santa Cruz by several months (Appendix A, May 31, 1995). Free Radio Santa Cruz was almost an accident. There was some interest by local activists, and initial encouragement by Tom Revielle of Radio Free Venice in Southern California. Revielle was shut down by the FCC in June 1991 and fined $1,000 (FCC, 1991a). He relocated to Santa Cruz and attempted to take part in the organization of Free Radio Santa Cruz. However, personality conflicts developed between Revielle and other staff members and he left to start his own station. Revielle had a complete studio and transmitter ready for operation, but had not gone beyond the testing stage (observations of Free Radio Santa Cruz staff meeting, May 13, 1995). Although there was noticeable tension between the two stations, Free Radio Santa Cruz has given full technical support to Revielle. The principles of access and abhorrence of censorship, evident in Bay Area stations, were seen again here. Schreiner described Free Radio Santa Cruz as an egalitarian coalition which began meeting in March 1995 and went on the air a month later. The first broadcast was a reading of the Bill of Rights and the International Workers of the World (IWW) preamble (Appendix A, May 31, 1995). Considering the experience level of the staff, it was not surprising that there were some technical difficulties at first. Soon after the first broadcast, FRSC slipped frequencies down from 89.3 to 88.9, which is KUSP, a public radio station in Santa Cruz (Davidson, 1995). Unfortunately, this happened during a KUSP pledge drive. The interference was discovered almost immediately by FRSC staff members who were monitoring the signal and the transmitter was shut down. Frequency stability was established soon after and FRSC was back on the air (Appendix A, May 31, 1995). The station has been broadcasting nearly 24 hours a day ever since and was still on the air as of November 1995. The location of FRSC was always fixed, as opposed to mobile, although the studio itself has changed locations several times. Schreiner stated that Free Radio Santa Cruz is not a Free Communications Coalition station. However, Schreiner did add that FRSC is in contact with other stations in California as well as with the Committee for Democratic Communication. The FCC has visited the studio in Santa Cruz twice as of November 1995. Staff members denied the FCC access to the transmitter both times. So far FCC actions have resulted in a temporary disruption of mail service and the questioning of people whose names appeared on the phone service for the station. On several occasions, on-air announcers have called the FCC in Hayward, and put the agents on the air, live (Appendix A, May 31, 1995). The last report from FRSC was that it had changed frequencies to 96.3 FM, changed studio location, and increased power to 40 watts (personal communication via e-mail with Schreiner, September 15, 1995). The frequency change was in response to information that an FM translator was going on-line on 89.3 as well as to lessen the chance of interference with KUSP at 88.9. According to Schreiner, this had an added bonus of decreasing tension between those who supported the public radio station and those who operated the micro operation (personal communication via e-mail with Schreiner, September 15, 1995). Although FRSC followed the aggressive civil disobedience of Free Radio Berkeley, Free Radio Santa Cruz differed from Dunifer's station in one important area. Where FRB generally followed FCC content regulations, FRSC openly violated obscenity regulations as interpreted by the FCC. FRSC's argument was that it was following local "community standards" in terms of obscenity; that Santa Cruz is used to the rawer side of discourse. However, the CDC communicated to FRSC that, although it would help if it could, the content violations made a defense difficult. This had not dissuaded these broadcasters, most of whom had no broadcasting experience and shared only a vision of what they perceive as free speech (Appendix A, May 31, 1995).
United States v. Dunifer Continues
The FCC Responds In response to Dunifer's allegations that the current regulatory scheme violated his First Amendment right of free speech, the FCC cited 60 years of statutory procedure in establishing its rules and regulations, as well as the requirement by Congress that an individual file a written application for a license. Further, the FCC argued that Congress gave the FCC the power to design a regulatory scheme as the FCC saw fit. The purpose of a license was to prevent interference by reserving spectrum space for that signal. If no license were required, conflict and interference could not be prevented, only dealt with after the fact. This situation would be "costly, disruptive, inefficient, and directly contrary to the expressed will of Congress" (FCC, 1995b, p. 3). The statement concerning the possibilities for conflict and interference in an unlicensed spectrum are accurate. However, Daniel S. Emrick, Chief of Investigations Branch, Enforcement Division, Information and Compliance Bureau, said that conflict and signal interference regularly occur between licensed commercial broadcasters (Appendix A, personal interview, January 10, 1995). Thus, licensing does not prevent interference. Rather, station licensing provides a mechanism for resolving disputes concerning interference and other issues. Moreover, Hiken was not arguing that Dunifer was exempt from needing a license to broadcast. He argued that Dunifer had not been given the opportunity to obtain a license because the FCC did not license low-power broadcasting (Appendix A, February 15, 1995; observations of U.S. v. Dunifer hearing, January 20, 1995). Several court cases have established the lack of any constitutional right to use radio facilities (Red Lion Broadcasting Co. v. FCC [395 U.S. 367, 390, 1969], National Broadcasting Co. v. US. [319 U.S. 190, 227, 1943], and Turner Broadcasting System v. FCC [114 S. Ct. 2445, 2456-57, 1994]). Since there is limited spectrum space, the government has an interest in regulating it. Because there is not enough space for everyone, some people will not be able to obtain a license. These cases were standard fare in previous unlicensed broadcasting cases (see Chapter 2). The concept that individuals need a license to broadcast was widely accepted by the courts and most broadcasters. However, many unlicensed broadcasters have rejected the government's jurisdiction over the airwaves (e.g., Shields & Ogles, 1992). Dunifer did not argue this. As discussed later in this chapter, he did mention that his station's lack of proven interference brings into question the FCC's action against him in terms of the Commerce Clause of the Constitution. However, it was only a small part of the overall argument. Dunifer wanted the ability to apply for a micro power broadcasting license. This is prohibited by the FCC; therefore, he could not apply for a license. The court cases cited above were primarily concerned with licenses that were denied. In contrast, Dunifer could not even apply for a license. The FCC contended that Dunifer did not follow agency procedures to attempt to change the rules concerning low-power broadcasting. The FCC Memorandum and Order (FCC, 1995b) discussed the opportunity for appeals during the waiver or rule-making petition process. The FCC provided an example in which the agency lost a decision concerning its stand on a rule-making petition on appeal. This was to illustrate that there was a fair process for individuals to challenge and change FCC regulations, even if the FCC did not agree with those changes. From the FCC's perspective there were administrative remedies available rather than breaking the law (FCC, 1995b). Silberman, an FCC attorney, expressed his objections to Dunifer's disregard for established rules and procedures (Appendix A, January 10, 1995). However, seeking a more immediate remedy to what was perceived as a Constitutional violation would seem to be justified. Civil disobedience has a long and generally accepted history in the United States, especially if it is non-violent. In addition, the cost and time of such a rule-making or waiver campaign makes that strategy unavailable to most people. Such an endeavor could literally take years and cost hundreds of thousands of dollars, much of the cost in attorney fees. However, the CDC's assistance in this case was pro bono for two reasons. First, the CDC has a commitment to free communication (observations from National Lawyers Guild forum on micro radio, September 22, 1995, Berkeley, CA). Second, CDC lawyers had prepared a brief for the Mbanna Kantako case concerning micro broadcasting (National Lawyers Guild, 1992). It was also doubtful that the CDC could commit to the high costs and time involved in a rule-making effort. According to Hiken, media law is a very exclusive club usually involving millions of dollars in lawyers' fees. Thus, Hiken's position was that pursuing administrative avenues to operate a low-power radio station presented a financial burden most people could not afford (Appendix A, February 15, 1995). Dunifer and the CDC also argued against a rule-making or waiver request because they believed micro broadcasters should not have to ask permission for what should be a fundamental right (Ewell, 1995; observations from National Lawyers Guild forum on micro radio, September 22, 1995, Berkeley, CA). Further, the fact that the FCC had been aware of Kantako's operation since 1989 and had taken no further action, led the CDC to contend in its court brief that the FCC itself should have taken steps to allow for this new technology to enter the regulatory scheme (National Lawyers Guild, 1992). The remedy of a waiver would also allow only Dunifer to broadcast, rather than allow the broader use of this technology. As Hiken, Dunifer's CDC lawyer, stated "The principle is that micro stations have the right to broadcast, and that's what this thing's about." He went on to say, "look at their Act [the Communications Act]. It obligates upon them [the FCC] the mandate that they assist the American people in incorporating new technologies, in initiating on their own rule-making procedure...for ensuring the broadest use of the airwaves" (Appendix A, February 15, 1995). Thus, the CDC's position was that the FCC had its chance to recognize and address this issue in 1989 and when the FCC failed to act, the CDC challenged the FCC's policies and procedures. In the FCC's Memorandum Opinion and Order, the agency found Dunifer's claim that the lack of a low-power radio service violated his right to free speech under the First Amendment was unavailing in several ways (FCC, 1995b). First, the FCC argued that these technical specifications were not based on the content of speech, and, therefore, were not speech related. Second, there need only be reasonable means of promoting the statute's public interest standard to survive a First Amendment challenge. Third, FCC regulations meet the terms of the Intermediate Scrutiny Test, the statutory objective of ensuring "fair, efficient, and equitable distribution of radio service." Further, "The Commission's rules pertaining to low power broadcasting services are reasonably related to this permissible statutory objective and are designed to allow the most efficient use of the spectrum" (FCC, 1995b, pp. 4-5). The FCC then devoted a section of its Memorandum Opinion and Order (FCC, 1995b) to the process involved in the establishment of regulations for low-power FM translators and rejected a request to allow them to have original programming. That would have permitted a defacto low-power service. The Commission went on to state that public hearings were held in the process of deciding to raise the minimum broadcasting power to 100 watts. After the public hearings were completed, the Commission decided that it was a more efficient use of the spectrum, would provide more diverse programming to rural areas, and reduce interference with bigger stations and especially channel 6 television if low-power radio were eliminated. "The Commission's public interest determination to provide for increased power to these facilities [upgrade low watt to high watt] was based on its goal of providing, on a nation-wide basis, a stable, efficient, and diverse radio communication service" (FCC, 1995b, p. 5). The FCC further noted Dunifer had a chance to participate in these hearings and did not. While the FCC's arguments addressed the issues raised by Dunifer, several weaknesses can be identified in those arguments. First, the right of free speech addresses access as well as context. Thus, the First Amendment is concerned with both the ability to speak in a public place and the content of that speech. Dunifer and his attorneys argued that the FCC violated his First Amendment rights by denying him the ability to speak (Davidson, 1995). Similarly, the premise of a free press is historically based on the right to own and operate a literal "press," in the mechanical sense, as a person sees fit (Altschull, 1990). In the case of FRB, Dunifer was arguing that he should be able to use his "printing press," a micro radio transmitter. Second, the argument dealing with the review of the low-power translator service was not examined in light of the Constitutional or access questions raised by the Dunifer case. Also, if low-power radio stations cause interference, it would seem translator stations would cause interference as well. They operate with the same relative power and differ only in that they re-broadcast other signals instead of originating programming. Third, limiting the number of radio stations would seem to hinder rather than facilitate diversity. Random House defines diversity as variety (Flexner, 1987, p. 574). Higher station wattage leads to a larger broadcast area resulting in fewer stations and less variety for a particular region of the country. Fourth, the FCC statement that Dunifer did not participate in the 1978 decision to establish a limit on minimum broadcasting power (69 FCC 2d 240), 15 years before the NAL was issued, was accurate, although irrelevant. Kahane (1995) defined irrelevant reasons as "reasons or premises that are irrelevant to a conclusion. . . . In typical cases of irrelevant reason, the attempt is made to make the listener or reader believe that the issue has been addressed, and, indeed, addressed satisfactorily, when in fact it hasn't" (pp. 69-70). In addition, the United States system of government has always been open to constant revision, and is revised on a regular basis. Even the Constitution has been amended, and has had amendments repealed numerous times. Thus, while Dunifer did not participate in the 1978 hearings, this would not preclude him from seeking changes in 1995 FCC practices and policies. The FCC also reiterated its stand on the efficient use of the spectrum as it has since the 1930s. In its Memorandum Opinion and Order (FCC, 1995b), the FCC argued that high-power stations typically have better quality equipment, bigger and better signal strength, and take up bigger and better-defined areas. Therefore, such stations are easier to track and regulate. In contrast, smaller stations, operating on the fringe of a larger station's contour, or official area of operation, can cause interference, which is harder to find and correct because of the weaker signal strength. Further, the low-power transmitters "typically used by unlicensed radio operators" do not meet technical standards concerning signal drift and stability which will inevitably led to interference (FCC, 1995b, p. 7). Thus, rules and regulations are needed to keep the spectrum clear. In addition, the FCC argued that low-power FM cannot adequately service communities and mobile audiences and could interfere with larger stations. The FCC noted that super high-power stations are also not permitted. Apparently the middle ground as defined by the FCC will give the American public the maximum number of stations with the maximum reach, thus ensuring the FCC's definition of diversity. A smaller station within the contour of a larger station will cause interference, but only if the two stations were on, or near, the same frequency. As Emrick, an FCC official, noted, prevention of interference is the primary reason for licensing radio stations (Appendix A, January 10, 1995). Therefore, this interference problem would be less likely to exist if the FCC licensed micro radio stations as the agency has done with larger stations. That is, if micro radio stations were licensed, they would have their own frequency assignment. Thus, they would be no more likely to cause interference than higher-wattage stations. It would be possible for unlicensed radio operators to have substandard equipment and cause interference with other stations. However, this problem would be eliminated by FCC licensing and the technical frequency stability standards that would come with licensing. In fact, 10-watt Class D FM stations were licensed prior to 1978. According to FCC documentation, the decision to no longer license such stations was not based on interference or frequency instability (69 FCC 2d 240, 1978). As it has in the past (69 FCC 2d 240, 1978; McChesney, 1993), the Commission repeatedly returned to the bigger is better (up to a point) technical perspective (FCC, 1995b). However, another issue was raised in Memorandum and Opinion Order (FCC, 1995b): Maximum wattage stations are more economically feasible and a micro station cannot cover enough area to make a profit. However, micro radio stations generally incur minimal costs and have a non-commercial orientation (Ewell, 1995; Fine, 1994). Thus, although the FCC's concerns are applicable to higher-wattage stations, this particular economic argument does not seem to fit the case of the typical micro broadcasting operation. Dunifer used the Canadian system of regulating micro radio as a model for such a system in the United States (FCC, 1995b; National Lawyers Guild, 1992). The FCC responded in its Memorandum and Opinion Order (FCC, 1995b) that even Canada has made an individual obtain a license first. This is an easy task since the Canadians license micro radio, thus making it unnecessary to broadcast illegally. The main thrust of the Commission's argument was centered around the different population and broadcast operation densities. There are obviously more people and more radio stations in the United States. While this is true, it may not, as the FCC stated, preclude such a system here. There can only be as many stations are there are frequencies. If micro radio were licensed, the number of low-power stations could be regulated. However, such licensing might reduce the number of large contour stations (high-wattage stations that occupy a specific frequency over a large geographical area) because of the presence of small operations. Dunifer also argued that since his transmissions did not interfere with a licensed operation or cross state lines, he was protected from prosecution under the Commerce Clause of the Constitution (FCC, 1995b; National Lawyers Guild, 1992). Although this argument has been used previously by unlicensed broadcasters, it has been repeatedly rejected by courts in the past (Phipps, 1991). Hiken stated that the rationale underlying this argument was that none of the applicable cases involved micro radio and most of the stations in past cases did cause interference (Appendix A, February 15, 1995). The FCC also mentioned in this section of its Memorandum Opinion and Order that if micro radio were unregulated under the Commerce Clause, then the proliferation of stations would lead to interference (FCC, 1995b). However, according to Hiken, such interference, if it involved a licensed broadcast station, would fall under the Commerce Clause and could be regulated (Appendix A, February 15, 1995). The FCC also stated in its Memorandum and Opinion Order (FCC, 1995b) that Congress gave the FCC the mandate to operate in "the public interest, convenience, and necessity" (p. 10). Defining what this mandate constituted was left to the discretion of the FCC. Dunifer argued that the current regulatory scheme disallows micro broadcasting, denies access to poor and minorities, and therefore violates the Equal Protection Clause of the Constitution. The Commission reserved the right to define what was in the public interest, and did not see a micro broadcast service as being in the definition of the public interest, despite the increased access to the poor and minorities (National Lawyers Guild, 1992). Although the technology is available for these people to broadcast, the artificial requirements of minimum power, legal, and licensing fees makes it inaccessible. Dunifer's attorneys listed a number of international treaties, mentioned previously in this chapter, in relation to the right to communicate with others (National Lawyers Guild, 1992). In its Memorandum and Opinion Order (FCC, 1995b), the Commission dismissed this argument, having examined these treaties and finding no specific mention of micro broadcasting. The FCC did not comment on the concepts of communication discussed. The agency added that there was nothing contained within those treaties that would give someone a right to broadcast without a license or without the permission of the FCC. However, Dunifer did not request the right to broadcast without a license. Rather, he broadcast without a license as a protest against not having a micro broadcasting license available. The remainder of the FCC's arguments in its Memorandum and Opinion Order (FCC, 1995b) was directed towards the forfeiture and NAL process itself. Dunifer contended that he should have been warned before he was fined, based on the notion that the fining system was set up for licensees. Dunifer stated because he was not a licensed broadcaster took him out of the information loop regarding penalties and therefore entitled him to a warning first (FCC, 1995b). The Commission rejected this, reasoning that since Dunifer chose to broadcast as if he were a licensed station, but without obtaining a license first, he should be subject to the same penalties. Further, the FCC noted there is nothing in FCC rules and regulations that required it to issue warnings. Any warnings issued in the past were a judgment call by the particular field office. Clance stated this type of flexibility in procedure and fining as initiated by individual field offices could cause confusion, but was consistent with earlier actions (Appendix A, January 10, 1995). Dunifer also brought up the issue of legal representation which had caused Mbanna Kantako to walk out of court (see Chapter 2). The FCC position was that in a civil action, as opposed to a criminal action, the right to counsel does not exist. While this is true before the forfeiture appeal stage, once the forfeiture is appealed, an individual is entitled to counsel. The Commission added that Dunifer had been able to retain counsel. This made invalid the argument that his lack of funds and state-appointed counsel violated his rights (FCC, 1995b; Shields & Ogles, 1992). The argument that Dunifer's fine was excessive was addressed in part in the FCC's Memorandum Opinion and Order. The FCC did reduce his fine to $10,000 from $20,000. Although the $10,000 fine was in excess of the standard fine (Davidson, 1995), FCC regulations allow for a maximum fine of $10,000 per day for parties other than those who have sought Commission authorization. Again, the flexibility of enforcement procedures applies to the levying of fines and was codified by the FCC. "[T]he nature, circumstances, extent, and gravity of the violation and, with respect to the violator, the degree of culpability, any history of prior offense, ability to pay, and such other matters as justice may require" can be taken into consideration when assessing fines (FCC, 1995b, p. 13). The NAL only cited one violation, therefore the maximum fine for one violation was issued (FCC, 1995b). This flexibility has been given to allow for a different penalty for the high school student playing disc jockey in his or her garage, and an adult who intentionally and publicly operates in violation of the law. In its Memorandum Opinion and Order (FCC, 1995b), the FCC pointed out one of Dunifer's numerous press interviews as an example of his intransigence. Thus, the FCC argued Dunifer willfully violated the law rather than violating the law out of ignorance. Finally, Dunifer stated that he could not afford to pay such a fine (FCC, 1995b). Financial ability to pay fines has been a major mediating force in forfeiture procedures. Examination of FCC printouts concerning fines and violations (FCC, 1995a) indicated that the FCC routinely took ability to pay into account when deciding on the final amount of a forfeiture order. However, Dunifer had not filed any financial statements with the FCC concerning the ability to pay. Therefore, the amount of the fine stood at $10,000. Considering Commission history concerning these matters, any compelling financial information provided by Dunifer in the future would likely result in the lowering of the fine (FCC, 1995a). The Commission response ended simply with the statement that Dunifer's arguments were denied and a fine was issued, with instructions on how to pay.
The Next Phase The Commission response gave only short service to the primary issues involved in the Dunifer challenge to the regulatory scheme. The FCC concentrated on the actual violation that formed the protest and gave Dunifer the legal standing to enter court and challenge the regulatory scheme. The agency's position was that Congress gave the FCC the right to make and interpret the rules, Dunifer broke those rules, and therefore, he must pay the penalty. " [T]heir [the FCC's] decision provides remarkable insight into the government's complete lack of understanding of the reasons for the communication revolution represented by micro radio." (Allan Hopper, CDC Attorney, "FCC rejects low power," 1995).
FCC Enforcement Difficulties Funding and personnel were spread over 35 field offices with 307 employees, and the main offices in Washington, DC, which had 67 employees. As of 1993, California had the largest number of field offices with four. Additional field offices were located in 23 other states and Puerto Rico. Although the FCC had listening sites around the country, these sites could only give the appropriate field offices a general area to search. Locations of unlicensed broadcasters were often discovered through investigations of complaints and the monitoring of press. The primary mode of tracking these broadcasters was with radio detection finding (RDF) vehicles. Emrick, an engineer with the FCC, stated the FCC had approximately 75 such vehicles in operation spread out over the different field offices and the research facility that the FCC operated in Powder Springs, GA (Appendix A, January 10, 1995). Some offices had only one vehicle, while other offices had upwards to three. These vehicles were all custom fit with RDF equipment at the Powder Springs facility, at a combined cost of vehicle and electronics equipment approaching $80,000 each, not including labor. The FCC must monitor and regulate 6,900 conventional FM stations (FCC, 1995b) in addition to all AM stations, transmission towers, television, cable service, and a host of other electronics technology and manufacturing. Nearly all these regulatory and enforcement functions were handled by the field offices (FCC, 1993b). Thus, the agency was spread fairly thinly. The prospect of attempting to track down over 400 unlicensed broadcasters, and process them through the NAL and forfeiture procedure could prove to be problematic. The portability of a micro station, which would easily fit in a large backpack, including power source, further added to the tracking difficulties. Even if the number of unlicensed stations were exaggerated, half that projected number would be difficult to interdict ("forbid" or "prohibit" [Flexner, 1987, p. 993]). Moreover, although he did not provide specific numbers, Dunifer stated that the number of kits ordered each year from FRB has been increasing steadily. Combined with the ability of others to construct such units, an end result is an ever-increasing, difficult-to-track, number of transmitters (Appendix A, March 1, 1995). Added to the difficulty of locating such stations and the processing of Notices of Apparent Liability (NAL) and Notices of Forfeiture (NOF) has been taking action against broadcasters who have refused to pay fines or stop broadcasting. Even in the current climate where Kantako refused to pay his fine or stop broadcasting since 1989 with no further FCC action, enforcement had been difficult. When violators have refused to acknowledge Notices of Apparent Liability (NAL) and Notices of Forfeiture, the FCC has had to go to the local U.S. Attorney to obtain assistance in prosecution, search warrants, and equipment seizure orders. According to Clance, an armed officer must serve a search warrant (Appendix A, January 10, 1995). This usually has been a Federal Marshal, and rarely, local police. FCC field agents do not carried firearms. Both Clance and Emrick stated that any move to arm FCC agents would be strenuously opposed internally (Appendix A, Clance, Emrick, January 10, 1995). FCC agents only carried firearms during World War II, when the agents played a counter-espionage role. Clance further stated that obtaining cooperation from some U.S. Attorneys, who regularly deal with drug trafficking and organized crime cases, ranged from difficult to impossible. He noted the problems associated with convincing a U.S. Attorney that someone operating a 10-watt radio station without a license deserves the attorney's time and energy (Appendix A, January 10, 1995). It would be easy to see how local police would not go out of their way for the same reasons, especially since it would be a federal action outside their jurisdiction. Moreover, court action involving micro broadcasting station would present further difficulties. In the past, pirate radio stations usually consisted of one to several people, or were managed or coordinated by an individual. As with commercial stations, the pirate operations tended to be hierarchical in nature. All the micro broadcasting organizations in the San Francisco Greater Bay Area known to this researcher are not structured hierarchically. It might seem to the casual observer that Dunifer and Free Radio Berkeley are one and the same entity. However, Ewell's (1995) article on Free Radio Berkeley and Dunifer's statements indicate that this is not the case. As Dunifer stated, he just elected to take the heat to bring the case into court (Appendix A, March 1, 1995). These stations were primarily coalitions with several key people, and no one clearly in authority. This was true of FRB by Dunifer's admission, and was also true of Free Radio Santa Cruz. FRSC was very adamant in its rejection of traditional hierarchy (Davidson, 1995). The influence of Food Not Bombs, the IWW, and the Green Party in many of these stations has served to reinforce this tendency. With no leader, it has been difficult for the FCC to find an individual to prosecute. Further, the FCC has had to convince a judge that the individual identified was the responsible party (Kuipers, 1989). This would probably be the unfortunate person who happened to be on the air when the authorities showed up, as in the RNI case (Kuipers, 1989), or perhaps the individual(s) who rented the space where the transmitter was located. Issuing a preliminary injunction against an individual to stop broadcasting would only stop that individual, no one else. The FCC would have to get action taken against a whole staff to make such a legal remedy work in a non-hierarchical environment. Providing individuals could be proven to be responsible, the penalties for such individuals would produce even more difficulties. Besides the possibility of going to jail for contempt of court in the case of a violation of a preliminary injunction, the only other penalties involved are monetary forfeiture and the seizure of equipment. As stated above, enjoining a few people may not be enough to stop others from broadcasting. The concept of a fine as a penalty was based on deterring a money generating broadcast or manufacturing facility from breaking the rules. If individuals were primarily trying to make money, a fine could prove to be a deterrent. Even an individual with real property or assets could be dissuaded from acting in a manner that would cause her or him to be fined. However, a individual with no assets, either in cash or property, would not have been deterred. According to FCC records (FCC, 1995a), fines were regularly reduced or eliminated when the person fined produced proof that she or he did not have the money to pay. A majority, if not all of those involved in the movement, were poor. As Schreiner of Free Radio Santa Cruz explained, this was a movement of the dispossessed and their supporters (Appendix A, May 31, 1995). These people had no property, investments, or savings. Many of them did not even own cars or have bank accounts. With no money to lose, the prospect of a fine was meaningless. The FCC would have to move to incarceration as a remedy, and considering the backlog in the American court system at both the federal and state levels, such an option did not seem viable. The seizure of equipment could be a major setback to a small poor radio station, but the replacement cost for such equipment was relatively minimal and getting less expensive all the time. A group of people could easily contribute $10 each, or hold a benefit to pay for the replacement of such equipment. To raise $500 would not be a lot of money for a group of dedicated activists and their supporters. Since many of the people involved were veterans of grassroots social activism, they were well schooled in fund-raising methods. Finally, the FCC seemed to underestimate the micro broadcasting movement. As illustrated by the FCC response to Judge Wilken's request, the FCC dealt with the Dunifer case as just another individual who wanted to broadcast without a license. This can be seen from the citations and language used, as well as the fixation on issues covered in past unlicensed broadcasting cases. Based on this researcher's inquiries, the only indication of FCC acknowledgment of a fundamental difference between micro broadcasters and traditional radio pirates came from Emrick. He assigned the title "pirate" primarily to short-wave operators, while acknowledging that there was a "distinction" between micro broadcasters and other unlicensed FM broadcasters. "I generally try not to use the term [pirate]," when describing FM activity (Appendix A, January 10, 1995). The Free Communications Coalition in conjunction with the Committee for Democratic Communication in this researcher's estimation were two very organized and experienced organizations. The Free Communications Coalition strength was contained in its associations with other well-established activist organizations with which it shared members and common cause, as well as a non-hierarchical system of organization. Schreiner stated that the movement welcomed all viewpoints, as long as they supported the concepts of free speech and communication (Appendix A, May 31, 1995). Currently, most stations could be classified as "left wing" in their political orientation. However, this would be an oversimplification of staff composition. Most announcers appeared apolitical, with ages ranging from 8 to 80. On March 2, 1995, the day after Dunifer was interviewed, he had meetings to set up shows for the Gray Panthers, a senior citizen activist group, and a group from Berkeley High School. Free Radio Santa Cruz had several shows where elementary school students had total control (Appendix A, May 31, 1995; Davidson, 1995). The decision of what goes on the air depended on what the announcer wanted to do; all an individual had to do to get on the air was show up to be trained and arrive for his or her shifts. With such a broad base of support, these stations might be harder to undermine than the FCC realizes.
Summary As explicitly stated in the title of the case, U.S. v. Dunifer, the Commission seemed determined to treat this issue as it concerned the individual, and not the movement. Dunifer's decision to be the test case for access to radio broadcasting by the larger population seemingly has been ignored by the FCC, which has continued to focus on Dunifer himself and two violations of Section 301 of the Communications Act. The larger implications and consequences of micro radio proliferation, its proponents, and support base, will continue to create problems for the FCC regardless of the outcome of this individual case. Operations such as Free Radio Santa Cruz (FRSC) and the Latino broadcast stations to the south indicated the spread of the concept of micro radio as well as varying degrees of application, content, and mission. As Schreiner of FRSC said, while the Hispanic stations were more conservative, FRSC leaned the other way (Appendix A, May 31, 1995). This variety was seen in other Bay Area micro broadcasters as well. They embraced the idea, seized the space, and are unlikely to give it up without a fight. The FCC's apparent underestimation of micro radio's potential impact was further seen when the availability of agency resources were combined with seemingly limited enforcement capacities as it interacted with a spreading micro broadcasting movement. Taking into consideration the chain of events that led to this case, the state of technology in use, and the attitudes of the participants, a simple solution seems unlikely. This and other implications of the present study will be discussed further in Chapter 5.
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