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If you need the complete document, download the WordPerfect version or Adobe Acrobat version, if available. ***************************************************************** Before the Federal Communications Commission Washington, D.C. 20554 In re: ) ) Complaint of Maranatha Broadcasting CSR-4882-M) Company, Inc. against Garden State) Cable TV ) ) Request for Carriage ) ) ) Garden State Cablevision, L.P. CSR-4932-A) ) For Modification of the ADI of ) Station WFMZ-TV ) MEMORANDUM OPINION AND ORDER Adopted: May 30, 1997 Released: June 5, 1997 By the Deputy Chief, Cable Services Bureau: INTRODUCTION 1. Maranatha Broadcasting Company, Inc. ("Maranatha"), licensee of Station WFMZ- TV (Ind., Channel 69), Allentown, Pennsylvania, has filed the above-captioned signal carriage complaint (CSR-4882-M) against Garden State Cable TV ("Garden State"), operator of a cable television system serving 58 communities in New Jersey. These communities, as is Allentown, are located in the Philadelphia area of dominant influence ("ADI"). Garden State has opposed Maranatha's must-carry complaint, and Maranatha has replied. In addition, Garden State has filed the above-captioned petition (CSR-4932-A) to modify WFMZ-TV's ADI, so as to remove the communities Garden State serves from the station's market. Maranatha has opposed Garden State's petition, and Garden State has replied. We are consolidating these cases for processing to determine the signal carriage rights of WFMZ-TV in the communities Garden State serves. BACKGROUND 2. Pursuant to 614 of the Communications Act and implementing rules adopted by the Commission in its Report and Order in MM Docket No. 92-259, commercial television broadcast stations are entitled to assert mandatory carriage rights on cable systems located within the station's market. A station's market for this purpose is its "area of dominant influence," or ADI, as defined by the Arbitron audience research organization. An ADI is a geographic market designation that defines each television market exclusive of others, based on measured viewing patterns. Essentially, each county in the United States is allocated to a market based on which home-market stations receive a preponderance of total viewing hours in the county. For purposes of this calculation, both over-the-air and cable television viewing are included. 3. Under the Act, however, the Commission is also directed to consider changes in market areas. Section 614(h)(l)(C) provides that the Commission may: with respect to a particular television broadcast station, include additional communities within its television market or exclude communities from such station's television market to better effectuate the purposes of this section. In considering such requests, the 1992 Cable Act provides that: the Commission shall afford particular attention to the value of localism by taking into account such factors as - (I) whether the station, or other stations located in the same area, have been historically carried on the cable system or systems within such community; (II) whether the television station provides coverage or other local service to such community; (III) whether any other television station that is eligible to be carried by a cable system in such community in fulfillment of the requirements of this section provides new coverage of issues of concern to such community or provides carriage or coverage of sporting and other events of interest to the community; and (IV) evidence of viewing patterns in cable and noncable households within the areas served by the cable system or systems in such community. 4. The legislative history of this provision indicates that: where the presumption in favor of ADI carriage would result in cable subscribers losing access to local stations because they are outside the ADI in which a local cable system operates, the FCC may make an adjustment to include or exclude particular communities from a television station's market consistent with Congress' objective to ensure that television stations be carried in the areas in which they serve and which form their economic market. * * * * [This subsection] establishes certain criteria which the Commission shall consider in acting on requests to modify the geographic area in which stations have signal carriage rights. These factors are not intended to be exclusive, but may be used to demonstrate that a community is part of a particular station's market. 5. The Commission provided guidance in its Report and Order in MM Docket No. 92- 259, supra, to aid decision making in these matters, as follows: For example, the historical carriage of the station could be illustrated by the submission of documents listing the cable system's channel line-up (e.g., rate cards) for a period of years. To show that the station provides coverage or other local service to the cable community (factor 2), parties may demonstrate that the station places at least a Grade B coverage contour over the cable community or is located close to the community in terms of mileage. Coverage of news or other programming of interest to the community could be demon- strated by program logs or other descriptions of local program offerings. The final factor concerns viewing patterns in the cable community in cable and noncable homes. Audience data clearly provide appropriate evidence about this factor. In this regard, we note that surveys such as those used to demonstrate significantly viewed status could be useful. However, since this factor requires us to evaluate viewing on a community basis for cable and noncable homes, and significantly viewed surveys typically measure viewing only in noncable households, such surveys may need to be supplemented with additional data concerning viewing in cable homes. 6. As for deletions of communities from a station's market, the legislative history of this provision indicates that: The provisions of [this subsection] reflect a recognition that the Commission may conclude that a community within a station's ADI may be so far removed from the station that it cannot be deemed part of the station's market. It is not the Committee's intention that these provisions be used by cable systems to manipulate their carriage obligations to avoid compliance with the objectives of this section. Further, this section is not intended to permit a cable system to discriminate among several stations licensed to the same community. Unless a cable system can point to particularized evidence that its community is not part of one station's market, it should not be permitted to single out individual stations serving the same area and request that the cable system's community be deleted from the station's television market. 7. In adopting rules to implement this provision, the Commission indicated that requested changes should be considered on a community-by-community basis rather than on a county-by-county basis, and that they should be treated as specific to particular stations rather than applicable in common to all stations in the market. The rules further provide, in accordance with the requirements of the 1992 Cable Act, that a station not be deleted from carriage during the pendency of an ADI change request. ARGUMENTS OF THE PARTIES 8. Signal Carriage Complaint (CSR-4882-M). Maranatha argues in support of its complaint that it qualifies for mandatory carriage on Garden State's system, and that the system is not carrying its full complement of must-carry signals. Maranatha states that it requested carriage on the system on September 30, 1996. Maranatha further states that on October 30, 1996, Garden State rejected Maranatha's request, claiming that WFMZ-TV did not provide a good quality signal to Garden State's principal headend. Maranatha argues that Garden State's signal test data are insufficient to demonstrate that WFMZ-TV's signal is inadequate. Maranatha states that Garden State's measurements were made with an antenna only 30 feet above ground level, while Garden State's actual signal receiving antennae at its headend are located on a 250-foot tower. Maranatha also notes that Garden State's measurements were made using a zero-gain antenna, and it is not likely that Garden State uses zero-gain antennae to receive other UHF signals. In any event, Maranatha states that it has promised to supply to Garden State, at Maranatha's expense, all equipment necessary to deliver a good quality signal to the system's principal headend. Accordingly, Maranatha requests that the Commission order Garden State to commence carriage of WFMZ-TV. 9. Garden State concedes that Maranatha recently demonstrated, using a more specialized antenna, that WFMZ-TV can provide an adequate signal to Garden State's principal headend. Nevertheless, Garden State argues in opposition that it will seek to modify WFMZ-TV's ADI to remove Garden State's communities from the station's ADI. Garden State asserts that it cannot be compelled to carry WFMZ-TV until Garden State's ADI modification petition is resolved. 10. Maranatha argues in reply that Garden State's concession regarding WFMZ-TV's signal quality settles the case, and that Garden State should be ordered promptly to commence carriage of WFMZ-TV upon denial of Garden State's market modification petition. 11. Market Modification Petition (CSR-4932-A). Garden State argues that the communities it serves lack any significant nexus with WFMZ-TV, and that the communities should be removed from the station's ADI. Garden State notes that it has never carried WFMZ-TV since the station began operations in 1976. Garden State argues that the communities it serves are located from about 47 to 75 miles from Allentown, Pennsylvania, WFMZ-TV's city of license, and are separated from Allentown by Philadelphia and the Delaware River. Garden State notes that WFMZ- TV's predicted Grade B contour falls short of the communities, and even if the station should upgrade its facilities as planned, its Grade B contour will still fall short of Garden State communities. Garden State describes WFMZ-TV's programming as primarily syndicated comedy and drama programs, religious programming, and paid programming, and notes that WFMZ-TV's news programming consists of CNN Headline News and news local to the Lehigh Valley around Allentown, not to Garden State's New Jersey communities. Garden State argues that its system carries numerous stations licensed in New Jersey and to Philadelphia which provide local service to Garden State's subscribers. Garden State further notes that it carries local access and local origination channels which contain local news and sports coverage, and also The New Jersey Channel and The Cable Television Network of New Jersey. Finally, Garden State contends that WFMZ-TV has no measurable viewing in the communities in question. Accordingly, Garden State urges that WFMZ-TV's ADI be modified to exclude the communities Garden State serves. 12. Maranatha argues in opposition that it has no history of carriage on Garden State's systems because until recently, following improvements in WFMZ-TV's facilities in 1993 and passage of the Satellite Home Viewing Act in 1994, WFMZ-TV had no right to mandatory carriage on these systems. Maranatha notes that within the past year WFMZ-TV has gained access to more than 500,000 cable homes, including the Trenton, New Jersey system and all three cable systems serving Philadelphia itself, immediately across the Delaware River from Garden State's system. Maranatha further notes that the Philadelphia metropolitan edition of TV Guide now lists WFMZ-TV in the channel reference pages, and expects its programming to be listed in that edition commencing in June. Maranatha contends that Garden State's description of the geography of the ADI is misleading, and states that Garden State's system is located close to the Philadelphia ADI's geographic center, in the market's core. Maranatha further contends that were the Delaware River -- which is the entire Pennsylvania-New Jersey border -- to be treated as a market boundary, no Philadelphia or other Pennsylvania station (or any Delaware station) would have carriage rights anywhere in New Jersey, including on Garden State's system. Maranatha states that WFMZ-TV provides five live daily newscasts Monday through Friday totalling two hours and forty-five minutes (as well as a half-hour tape rebroadcast at 1:00 am), and also a half-hour local newscast at 5:00 pm Saturday and Sunday, each of which include substantial news coverage of issues of direct concern to New Jersey residents in general, and to residents of Burlington, Camden, and Gloucester Counties in particular, where Garden State operates. Maranatha notes that in a fourteen-month period WFMZ- TV news programs reported on over 350 stories affecting Burlington, Camden, and Gloucester Counties -- including in particular the communities of Camden, Cherry Hill, and Collingswood -- and submits sample scripts from 51 stories. In addition to this local news coverage, Maranatha states that WFMZ-TV broadcasts a rotation of public affairs programs Monday through Friday at 8:00 pm, including "Law Journal" which is hosted by New Jersey attorney Christopher Naughton. "Law Journal" has included attorneys from Burlington, Camden, and Gloucester Counties on 65 occasions since 1995. This program is carried by the Cable Television Network on Garden State's cable system, and is advertised in the Courier-Post, a local newspaper of general circulation in the area Garden State serves. 13. Maranatha argues that while Garden State claims that it carries numerous New Jersey and Philadelphia stations, Garden State has not shown that any of these stations actually provide news or other coverage of specific concern or interest to Garden State's communities. Maranatha notes that three of the stations Garden State carries -- Television Broadcast Stations WGTW (Ind., Channel 48), Burlington, New Jersey; WGBS-TV (Ind., Channel 57), Philadelphia, Pennsylvania, and WTGI-TV (Ind., Channel 61), Wilmington, Delaware -- provide no news programming, and Station WPHL-TV (Ind., Channel 17), Philadelphia, Pennsylvania, offers only a single nightly newscast at 10:00 pm. Maranatha contends that Garden State's viewership analysis is simply a two- page letter from a consultant with no specific information concerning what viewing data the consultant reviewed. Nor is it surprising that the consultant found no viewing of WFMZ-TV on Garden State's system, Maranatha argues, because Garden State does not carry the station. Maranatha states that it commissioned a special Nielsen study in January 1997 which shows, based on diaries in nearly 1300 households across the Philadelphia ADI, that WFMZ-TV reaches 120,000 households Noon to Midnight Monday through Friday, compared with 178,000 homes for WGTW; 51,000 homes for WYBE; and 12,000 homes each for WTGI-TV and WHSP, all of which Garden State carries. In addition, the study recorded no viewing for WWAC (Ind., Channel 53), Atlantic City, New Jersey, which Garden State carries on its system. Maranatha states that 83 percent of potential viewers in Gloucester County, 79 percent in Camden County, and 82 percent in Burlington County are cable viewers, and argues that in such a case the viewership factor is virtually indistinguishable in analysis from the historic carriage factor. 14. Garden State contends in reply that the question of historic carriage of WFMZ-TV is relevant and should be considered, and that the station could have sought carriage as early as 1992. Garden State reiterates that WFMZ-TV's Grade B contour covers none of Garden States' communities, and maintains that while the communities in question may be centrally located within the Philadelphia ADI, it is WFMZ-TV's distance from the communities that is more relevant. Garden State further contends that geographic features are legitimate boundary considerations in determining a station's market. Garden State questions WFMZ-TV's length of commitment to local programming, and describes one program cited by WFMZ-TV as simply a report of Hurricane Bertha's effect on New Jersey beaches. Finally, Garden State submits an April 1, 1997 letter from Media Strategies, a marketing and research consulting firm, which Garden State argues shows that WFMZ-TV has the lowest circulation in the Philadelphia DMA Monday-Sunday, 7 a.m. to 1 a.m. DISCUSSION AND ANALYSIS 15. We turn first to Garden State's market modification petition, to determine whether the communities served by Garden State should be removed from WFMZ-TV's ADI. A resolution of this matter will determine whether WFMZ-TV is eligible to claim carriage rights in these communities. 16. Based on our analysis of the evidence relating to the four statutory and other relevant factors, Garden State's petition will be denied. Philadelphia is the fourth nation's largest populous television market in terms of population. It is a large market in terms of geographic area, stretching from Northampton County in the north to Atlantic City and into Delaware in the South. Allentown is some 45 miles to the north of Philadelphia, the core city of the market. The cable communities involved are in the New Jersey counties of Burlington, Camden, Gloucester, and Salem. Cherry Hill, the community with which the system principally identifies itself, is located immediately across the Delaware River from the City of Philadelphia. WFMZ-TV, licensed to Allentown, Pennsylvania began operation in 1976 and broadcasts on channel 69 from a transmitter located in Allentown. The cable communities are approximately 47 to 75 miles from the station. A. Historic Signal Carriage 17. Statutory factor one is "whether the station, or other stations located in the same area, have been historically carried on the cable system or systems within such community." WFMZ-TV has no history of carriage in the cable communities in question. Nor are other stations carried from the same general area (Allentown) to which this station is licensed. WFMZ-TV is not a station of recent origin, having commenced operations more than 20 years ago. 18. Carriage on nearby cable systems is not a factor specified in the statute, but it does seem likely, depending on the specific circumstances involved, that carriage on nearby systems could serve as evidence to define the logical scope of a station's market. Such carriage could serve to demonstrate the belief of both the stations and systems involved that there is a market nexus between the broadcast station and the communities where the station is carried and thus provide evidence as to the scope of a station's market. The signal of WFMZ-TV is carried in the City of Philadelphia and in Trenton. Cherry Hill and the surrounding cable communities are immediately adjacent to Philadelphia. B. Station Coverage of Communities 19. Statutory factor two is "whether the television station provides coverage or other local service to such community." This factor incorporates both technical service and programming service. With respect to technical service coverage, the Commission has stated in its Report and Order in MM Docket No. 92-259 that "to show that the station provides coverage or other local service to the cable communities, parties may demonstrate that the station places at least a Grade B coverage contour over the cable community or is located close to the community in terms of mileage." WFMZ-TV does not provide Grade B service to the cable communities. An application is pending, however, that will extend the station's Grade B service area so that portions of Burlington and Camden Counties in which the system operates will be within or on the fringe of the contour. 20. With respect to programming service, Garden State alleges that there is no significant amount of programming from the station that is specifically targeted to the cable communities involved. There is evidence from the station, however, that its broadcasts material directed toward New Jersey viewers, including stories specific to Burlington, Camden and Gloucester Counties. C. Coverage of News, Sporting Events, or Other Events of Interest by Other Stations Entitled to Carriage 21. Statutory factor three is "whether any other television station that is eligible to be carried by a cable system in such community in fulfillment of the requirements of this section provides news coverage of issues of concern to such community or provides carriage or coverage of sporting and other events of interest to the community." In this instance Garden State alleges that it provides carriage to numerous Pennsylvania and New Jersey stations that provide local service to its subscribers. These include KYW-TV, WPVI-TV, WCAU-TV, WPHL-TV, WTXF-TV, WYBE, and WGBS-TV from Philadelphia; WGTW from Burlington; WHSP from Vineland; and WNJS from Camden. Maranatha argues that some of these stations carry no news at all and disputes the significance of the coverage by the other stations. D. Station Audience in Communities Served by Cable System 22. Statutory factor four is "evidence of viewing patterns in cable and noncable households within the areas served by the cable system or systems in such community." Although Maranatha challenges the quality of the evidence provided by Garden State as to the viewing it receives in the cable communities, there does not appear to be any serious dispute that the station has no significant audience in the cable communities, either in cable or in noncable households. Nielsen data for the counties reflect no viewing of WFMZ-TV which is entirely consistent with the lack of Grade B service to the communities. We note, however, that this evidence must be considered in light of the existing lack of carriage and the heavily cabled nature of the communities (80 to 90 percent). E. Other Considerations 23. The factors specified in 614(h) do not purport to be exclusive and thus other evidence may be considered that is helpful in defining the scope of the markets of the stations involved. One such additional factor involves whether local newspaper or other listings of station programming that have circulation in the cable communities include the programming of the stations in question. WFMZ-TV is said to be now listed in the channel reference pages of the Philadelphia metropolitan edition of TV Guide with a full program listing scheduled to commence in June of 1997. F. Summary 24. The cable television mandatory broadcast signal carriage rules were adopted as part of the 1992 Cable Act. According to the legislative history of that Act, the use of ADI market areas is intended "to ensure that television stations be carried in the areas which they serve and which form their economic market." The Act specifically provided that the Commission was to consider adding additional communities or excluding communities from the markets of television stations "to better effectuate the purposes" of the mandatory carriage requirements. In acting on such requests the Commission was instructed to "afford particular attention to the value of localism, taking into account four specified statutory factors." These factors, however, were "not intended to be exclusive." The market modification provisions of 614(h) are said, in the legislative history, to "reflect a recognition that the Commission may conclude that a community within a station's ADI may be so far removed from the station that it cannot be deemed part of the station's market." We do not believe that the requested exclusion of the communities served by Garden State's cable systems from the markets of WFMZ-TV will better effectuate the purposes of the must-carry statutory provisions. 25. In reaching this conclusion, we have considered the statutory factors as well as other relevant information. WFMZ-TV has never been carried in the communities in question (factor I), provides no over-the-air television broadcast service to the communities (factor II), and has no measured audience in the communities (factor IV). Other stations that are entitled to carriage do provide news and other information regarding issues of concern to the communities (factor III). Given the statutory directive, weight must be given to these factors, but that must be done bearing in mind that the objective of the 614(h) process is to "better effectuate the purposes" of the broadcast signal carriage scheme. Thus, with respect to the question of historical carriage patterns, attention must be paid to the circumstances from which such patterns developed. Some stations have not had the opportunity to build a record of historical carriage for specific reasons that do not necessarily reflect a judgment as to the geography of the market involved. Thus, these factors -- to the extent they are reflective of circumstances outside of the shape of the market -- are not by themselves controlling in circumstances where such an implementation of the 1992 Cable Act would, in effect, prevent weaker stations like WFMZ-TV, that cable systems had previously declined to carry, from ever obtaining carriage rights. 26. Another factor to consider is the availability of other broadcasters in the market that are eligible for carriage and provide coverage of news, sporting events, or other events of interest to the communities at issue. We have stated, however, that where a cable operator is seeking to delete a station's mandatory carriage rights in certain communities within its ADI and it is clear that the station is not providing local service to those communities, the issue of local coverage by other stations becomes a factor to which we will give greater weight than in cases where a party is seeking to add communities. Carriage of other local stations may be used as an enhancement factor to support a cable operator's deletion request when there is other evidence in the record that the communities at issue are outside of the station's market. In the present case, Garden State carries numerous other stations licensed to communities in the Philadelphia ADI that are closer to the cable communities and provide coverage of local news and events. There is, however, also evidence of WFMZ-TV's service to the cable communities. 27. Given the difficulties of relying exclusively and explicitly on the statutory factors of historical carriage and viewing patterns, which could severely narrow the carriage rights of stations even within what is undeniably their local market area, we have found it necessary to focus more heavily on factors that are not influenced by the type or age of the stations involved or historical carriage. The scope of a local station's market may be measured through geographic means by examining the distance between the station and the cable community subject to the deletion request and by taking into account natural phenomena such as waterways, mountains, and valleys that may tend to separate communities and define natural markets -- basic geographic, demographic, and political features that provide the best available alternative evidence of the market boundaries of the stations involved. In this regard the Commission has explicitly noted the relevance of Grade B contours. In the absence of other information, station service contours provide at least one objective measure of the scope of a stations local market. Here we note that WFMZ-TV does not presently provide Grade B service to the cable communities but is in the process of improving its facilities so that they will be on the edge of or somewhat beyond its service area. The station is also geographically separated from Burlington and Gloucester Counties in terms of mileage by approximately 47 to 75 miles, is on the far side of the Delaware River from the cable communities, and is in a different state. 28. Weighing against the grant of the petition is evidence relating to cable carriage in other adjoining communities and the fact that station has demonstrated some efforts to provide programming targeted to New Jersey, including Burlington, Camden, and Gloucester. These two factors are of significant importance in our analysis of this petition and persuade us, along with the other facts as to the station's broadcast service area and the distances and geography involved that exclusion of these communities from the market of WFMZ-TV is not warranted. We recognize that a number of the other factors weigh in Garden State's favor, including in particular the absence of any historical carriage in the areas in question after many years of operation. The station's facilities were improved in 1993 and a further improvement has been applied for, so that the lack of historical carriage is based circumstances that no longer exist. The listing of the station and its schedule in TV listings relevant to these communities also provides some evidence that the market regards this area to be within the economic market and service area of the station. The distances and geography involved are not so extreme in terms of the core area of the cable system as to suggest no market nexus with the communities exists. Most of the communities in question are clustered together just across the Delaware River from Philadelphia, and along the river to the northeast. While some of the cable communities are considerably more distant, the information provided by Garden State is not adequate to permit distinctions to be made among the 58 individual communities involved. 29. We have carefully considered each statutory and other relevant factors in the context of the circumstances presented here and, on balance, we find that Garden State has not demonstrated that the communities it serves lack a sufficient nexus with WFMZ-TV to warrant deletion of these communities from the station's ADI. 30. Turning to Maranatha's signal carriage complaint, having found that grant of Garden State's petition for market modification is not warranted, we find no issue remaining. Garden State has conceded that WFMZ-TV's signal is of sufficient strength if the proper receiving antenna is used, and Maranatha has committed to supplying at its own expense the necessary equipment to deliver a good quality signal to Garden State's principal headend. We find, therefore, that WFMZ-TV is a qualified UHF station entitled to carriage on Garden State's systems serving the communities in question. ORDERING CLAUSES 31. Accordingly, IT IS ORDERED, that the petition for special relief (CSR-4932-A) filed January 16, 1997 by Garden State Cablevision, L.P. IS DENIED. 32. IT IS FURTHER ORDERED, that the "Complaint" (CSR-4882-M) filed November 27, 1996 by Maranatha Broadcasting Company, Inc., IS GRANTED, in accordance with 614(d)(3) of the Communications Act of 1934, as amended (47 U.S.C. 534) and 47 C.F.R. 76.56(b). 33. IT IS FURTHER ORDERED, that the affected cable systems shall commence carriage of WFMZ-TV sixty (60) days from the date that WFMZ-TV provides the necessary specialized equipment to receive a good quality signal at the principal headend of Garden State Cablevision, L.P. 34. This action is taken pursuant to authority delegated by 0.321 of the Commission's Rules. FEDERAL COMMUNICATIONS COMMISSION William H. Johnson Deputy Chief, Cable Services Bureau APPENDIX County Communities Burlington Chesterfield Township, Eastampton Township, Evesham Township, Fieldsboro Borough, Florence Township, Fort Dix, Hainesport Borough, Lumberton Borough, Mansfield Township, McGuire Air Force Base, Medford Lakes Borough, Medford Township, Moorestown Township, Mount Holly Township, Mount Laurel Township, New Hanover Township, North Hanover Township, Pemberton Borough, Pemberton Township, Shamong Township, Southampton Township, Springfield Township, Tabernacle Township, Westampton Township, Woodland Township, Wrightstown Borough Ca mden Audubon Borough, Audubon Park Borough, Barrington Borough, Bellmawr Borough, Berlin Borough, Berlin T ownship, Camden City, Cherry Hill Township, Cl ementon Borough, Collingswood Borough, Gibbsbor o Borough, Gloucester Township, Haddon Township, Haddonfield Borough, Haddon Heights Borough, Hi-Nella Borough, Laurel Springs Borough, Lawnside Borough, Lindenwold Borough, Magnolia Borough, Merchantville Borough, Oaklyn Borough, Pennsauken Township, Pine Hill Borough, Runnemede Borough, Somerdale Borough, Startford Borough, Voorhees Township, Woodlynne Borough Gloucester Pitman Borough Ocean Plumsted Township Salem Carneys Point Township