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A. a.(1)(a) i) a)DocumentgPleadingHeader for Numbered Pleading PaperE!n    X X` hp x (#%'0*,.8135@8:/>/>/>/x]SSSSx]x]x]x]xSxSx]SSxSxSf]xSxSxSxIxIxWxIx{nInInInISSSWS]a?/?]?9?]]WW]n/nKn9nCn/x]xx]x]SSxxIxIxI]?]?]?]WnUn9nax]x]x]x]x]x]xxWnInInIx]n9x]]?n9xSz+SS8-8WuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxN8HH"&H>XHH8HB8>HH^HH>"".2",2,2,"222N2222"&22H22,006"6."""""""""""2H,H,H,H,H,XAB,>,>,>,>,""""H2H2H2H2H2H2H2H2H2H2H,H2H1H2H2H282H,H,H,B,B,B6B,H?>,>,>,>,H2H2H2H6H2H6H2""2"""2F866H2>>(>">">H2;H2H2H2H2XHB"B"B"8&8&8&86>*>>.H2H2H2H2H2H2^HH6>,>,>,H2>"H28&>"H2?22!!WFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxN$<<$.2",2222`2 LL2 LL2L"",,2d"" x18 yO/-ԍ 47 C.F.R. 76.59.>  X-  ARGUMENTS OF THE PARTIES lU  X-  8.` ` Signal Carriage Complaint (CSR4881M). Maranatha argues in support of its   complaint that it qualifies for mandatory carriage on Comcast's systems, and that each system is   xnot carrying its full complement of mustcarry signals. Maranatha states that it requested carriage   on these systems on September 30, 1996. Maranatha further states that on October 18, 1996,   Comcast rejected Maranatha's request, asserting without documentation that WFMZTV did not   provide a good quality signal to Comcast's principal headends. Maranatha contends that   Comcast's bare assertions are insufficient to demonstrate that WFMZTV's signal is inadequate.   Maranatha notes that it has promised to supply to Comcast, at Maranatha's expense, all equipment   necessary to deliver a good quality signal to the systems' principal headends. Accordingly, Maranatha requests that the Commission order Comcast to commence carriage of WFMZTV." ,N(N(ZZ;"Ԍ X-  ԙ9.` ` Comcast argues in opposition that upon receipt of Maranatha's carriage request,   KComcast engineers tested WFMZTV's signal and found it to be inadequate. Comcast states that   it retested WFMZTV's signal in January 1997, and again found the signal to be inadequate.   LComcast submits test reports with its opposition, and notes that it will seek to modify WFMZ  \TV's ADI to remove Comcast's communities from the station's ADI. Comcast asserts that it cannot be compelled to carry WFMZTV until Comcast's ADI modification petition is resolved.  X_-  10` ` Maranatha argues in reply that Comcast's submission of its test data is untimely,   and that the test data do not comport with Commission requirements, as only a consumergrade   antenna was used, and at heights of 30 and 40 feet above the ground, even though Comcast's antenna tower is 250 feet high.  X -  ^11. ` ` Market Modification Petition (CSR4928A). Comcast argues that the communities   iit serves lack any significant nexus with WFMZTV, and that the communities should be removed   from the station's ADI. Comcast states that neither of its systems have ever carried WFMZTV   =since the station began operations in 1976. Comcast argues that the communities it serves are   on average about 51 miles from Allentown, Pennsylvania, WFMZTV's city of license, and some   are as distant as 68 miles. In addition, Comcast states that its communities are separated from   yAllentown by Philadelphia and the Delaware River. Comcast notes that WFMZTV's predicted   Grade B contour falls short of the communities, and even if the station should upgrade its   jfacilities as planned, perhaps four or five of the communities in question would be at the fringe   of the station's expanded Grade B contour. Comcast describes WFMZTV's programming as   primarily syndicated comedy and drama programs, religious programming, and paid   jprogramming, and notes that WFMZTV's news programming consists of CNN Headline News   @and news local to the Lehigh Valley around Allentown, not to Comcast's New Jersey   communities. Comcast states that its systems carry numerous stations licensed in New Jersey and  X-  =in Philadelphia which provide local service to Comcast's subscribers. @18 yO%-  Kԍ Comcast states that its systems carry Stations KYWTV (NBC, Channel 3), WPVITV (ABC, Channel 6),   WCAUTV (CBS, Channel 10), WPHLTV (Ind., Channel 17), WTXFTV (Ind., Channel 29), WYBE (Ind., Channel   Z35), and WGBSTV (Ind., Channel 57), all Philadelphia, Pennsylvania; WHYYTV (ETV, Channel 12), WGTW   (Ind., Channel 48), Burlington, New Jersey; and WHSP (Ind., Channel 65), Vineland, New Jersey. In addition,   Comcast states that its Gloucester County system carries Stations WTGITV (Ind., Channel 61), Wilmington,   JDelaware and WNJS (ETV, Channel 23), Camden, New Jersey, and that Comcast's Burlington County system carries   Stations WNJNTV (ETV, Channel 50), Montclair, New Jersey and WWAC (Ind., Channel 53), Atlantic City, New Jersey. Comcast further states   that its systems carry The Comcast Network, which features area college and high school sports   coverage and Delaware valley news and information programs, and that each system has a local   Lorigination/local access/community bulletin board channel as well. Finally, Comcast contends   Kthat WFMZTV has no measurable viewing in Burlington and Gloucester Counties. Accordingly, Comcast urges that WFMZTV's ADI be modified to exclude the communities Comcast serves.  X -  ~12.` ` Maranatha argues in opposition that it has no history of carriage on Comcast's   systems because until recently, following improvements in WFMZTV's facilities in 1993 and" ,N(N(ZZ"   passage of the Satellite Home Viewing Act in 1994, WFMZTV had no right to mandatory   icarriage on Comcast's systems. Maranatha notes that within the past year WFMZTV has gained   access to more than 500,000 cable homes, including Comcast's Trenton, New Jersey system (just   to the north of Burlington County) and all three cable systems serving Philadelphia itself   (immediately to the north of Gloucester County), including one owned and operated by Comcast.  X-  ZMaranatha 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 Comcast's description of the geography of the   ADI is misleading, and states that Comcast's systems in question are located close to the ADI's   geographic center, in the market's core. Maranatha further contends that were the Delaware   River which is the entire PennsylvaniaNew Jersey border to be treated as a market   jboundary, no Philadelphia or other Pennsylvania station (or any Delaware station) would have   carriage rights anywhere in New Jersey, including on Comcast's systems. Maranatha states that   jWFMZTV provides five live daily newscasts Monday through Friday totalling two hours and   fortyfive minutes (as well as a halfhour tape rebroadcast at 1:00 am), and also a halfhour 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 Gloucester and   yBurlington Counties in particular. Maranatha notes that in a fourteenmonth period WFMZTV   ynews programs reported on over 350 stories affecting Gloucester and Burlington Counties, and   <submits sample scripts from 47 stories. In addition to this local news coverage, Maranatha states   that WFMZTV 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 and Gloucester Counties on 34 occasions   since 1995. This program is carried by the Cable Television Network on Comcast's Burlington County system.  X-  #13.` ` Maranatha argues that while Comcast claims that it carries numerous New Jersey   and Philadelphia stations, Comcast has not shown that any of these stations actually provide news   xor other coverage of specific concern or interest to Comcast's communities. Maranatha notes that   Lthree of the stations Comcast carries WGTW, WGBSTV, and WTGITV provide no news   Mprogramming, and WPHLTV offers only a single nightly newscast at 10:00 pm. Maranatha   ycontends that Comcast's viewership analysis is simply a twopage letter from a consultant with   Mno specific information concerning what viewing data the consultant reviewed. Maranatha   {contends that it is not surprising that the consultant found no viewing of WFMZTV on   Comcast's systems, because Comcast does not carry the station. Maranatha states that it   jcommissioned a special Nielsen study in January 1997 which shows, based on diaries in nearly   K1300 households across the Philadelphia ADI, that WFMZTV 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 WTGITV and WHSP, all of which Comcast carries.   In addition, the study recorded no viewing for WWAC, which Comcast's Burlington County   system carries. Maranatha states that 83 percent of potential viewers in Gloucester 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. "%' ,N(N(ZZ%"Ԍ X-  14.` ` Comcast contends in reply that the question of historic carriage of WFMZTV is   [relevant and should be considered, and that the station could have sought carriage as early as   =1992. Comcast notes that even communities at the edge of a station's Grade B contour may be  X-  [deleted from a station's ADI, 18 {O4-ԍ Comcast cites Comcast Cablevision of Danbury, Inc., CSR4826A, DA 97234 (released February 12, 1997). and reiterates that WFMZTV's Grade B contour covers none of   Comcast's communities. While the communities in question may be centrally located within the   LPhiladelphia ADI, Comcast argues that it is WFMZTV's distance from the communities that is   xmore relevant, and that geographic features are legitimate boundary considerations in determining   a station's market. Comcast questions WFMZTV's length of commitment to local programming,   .and describes one program cited by WFMZTV as simply a report of Hurricane Bertha's effect   on New Jersey beaches. Finally, Comcast submits an April 1, 1997 letter from Media Strategies,   La marketing and research consulting firm, which Comcast states shows that WFMZTV has he lowest circulation in the Philadelphia DMA MondaySunday, 7 a.m. to 1 a.m.  X - w DISCUSSION AND ANALYSIS ă  X -  15.` ` We turn first to Comcast's market modification petition, to determine whether the   communities served by Comcast should be removed from WFMZTV's ADI. A resolution of this   matter will determine whether WFMZTV is eligible to claim carriage rights in these communities.  X4-  16.` ` Based on our analysis of the evidence relating to the four statutory and other   relevant factors, Comcast'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 and Gloucester, located   immediately across the Delaware River from the City of Philadelphia. WFMZTV, 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 68 miles from the station.  X7- A. Historic Signal Carriage  X -  X -  217. ` ` 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."   WFMZTV 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 stations is licensed.   .WFMZTV is not a station of recent origin, having commenced operations more than 20 years ago. "#Z ,N(N(ZZe""Ԍ X-  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  X-  jcould serve as evidence to define the logical scope of a station's market.r 18 {OK-ԍ Fouce Amusement Enterprises, Inc., 10 FCC Rcd 668, 671 (CAB, 1995)r 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 WFMZTV is carried in the City of Philadelphia and in Trenton, which are both close to the cable communities.  XH- B. Station Coverage of Communities  X1-  X -  _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  X -  iits Report and Order in MM Docket No. 92259 that "to show that the station provides coverage   yor 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  X-  community in terms of mileage."h Z18 yO-#X\  P6G;P#э 8 FCC Rcd at 29762977.h WFMZTV does not currently 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 a number but not all of the communities involved will be on the fringe of the contour.  X-  A20. ` ` With respect to programming service, Comcast alleges that there is no significant  X-  amount of programming from the station that is specifically targeted to the cable communities   Zinvolved. There is evidence from the station, however, that it broadcasts material directed toward New Jersey viewers, including stories specific to Burlington and Gloucester Counties.  X- M C. Coverage of News, Sporting Events, or Other Events of Interest by Other  X-Stations Entitled to Carriage  Xg-  n21. ` ` 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 Comcast alleges that   Kit provides carriage to numerous Pennsylvania and New Jersey stations that provide local service   /to its subscribers. These include KYWTV, WPVITV, WCAUTV, WPHLTV, WTXFTV,   NWYBE, and WGBSTV from Philadelphia; WHYYTV and WGTW from Burlington; and   WHSP from Vineland. In addition, the Gloucester system carries WTGITV, Wilmington,   Delaware and WNJS, Camden, New Jersey, and the Burlington system carries WNJNTV,"! ,N(N(ZZ "   Montclair and WWAC, Atlantic City. Maranatha notes, however, that at least three of these stations carry no news at all and disputes the significance of the coverage by the other stations.  X- D. Station Audience in Communities Served by Cable System  X-  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 Comcast as to the   Kviewing 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 WFMZTV which is entirely  X -  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 (83 percent in Gloucester County and 82 percent in Burlington  X -County). 18 {O7-  Zԍ See The Chronicle Publishing Company d/b/a Ventura County Cablevision, 10 FCC Rcd 9474, 94819482 (1995).  X- E. Other Considerations  Xb-  $23.` ` The factors specified in 614(h) do not purport to be exclusive and thus other   Levidence may be considered that is helpful in defining the scope of the markets of the stations   involved. One such additional factor involves whether local newspaper or other listings of station   kprogramming that have circulation in the cable communities include the programming of the   =stations in question. WFMZTV is said to be now listed in the channel reference pages of the  X-  Philadelphia metropolitan edition of TV Guide with a full program listing scheduled to commence in June of 1997.  X- F. Summary  X~-  "24.` ` The cable television mandatory broadcast signal carriage rules were adopted as part  Xg-  of the 1992 Cable Act. According to the legislative history of that Act, the use of ADI market   areas is intended "to ensure that television stations be carried in the areas which they serve and  X9-  which form their economic market."\9"18 yO !-ԍ H.R. Rep. 102628, 102d Cong., 2d Sess. 97 (1992).\ The Act specifically provided that the Commission was  X"-  {to consider adding additional communities or excluding communities from the markets of  X -  television stations "to better effectuate the purposes" of the mandatory carriage requirements.? 18 yOn$-ԍ 47 U.S.C. 534(h).?   In acting on such requests the Commission was instructed to "afford particular attention to the  X-  value of localism, taking into account four specified statutory factors." These factors, however," B,N(N(ZZ"  X-  .were "not intended to be exclusive."\18 yOy-ԍ H.R. Rep. 102628, 102d Cong., 2d Sess. 97 (1992).\ 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  X-  deemed part of the station's market."3X18 {O-ԍ Id.3 We do not believe that the requested exclusion of the   /communities served by Comcast's cable systems from the markets of WFMZTV will better effectuate the purposes of the mustcarry statutory provisions.  X_-  25.` ` In reaching this conclusion, we have considered the statutory factors as well as   other relevant information. WFMZTV has never been carried in the communities in question   <(factor I), provides no overtheair television broadcast service to the communities (factor II), and   zhas 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   Lreasons that do not necessarily reflect a judgment as to the geography of the market involved.   LThus, these factors to the extent they are reflective of circumstances outside of the shape of   ythe market are not by themselves controlling in circumstances where such an implementation   of the 1992 Cable Act would, in effect, prevent weaker stations like WFMZTV, that cable systems had previously declined to carry, from ever obtaining carriage rights.  X-  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   jcoverage by other stations becomes a factor to which we will give greater weight than in cases  Xe-  ywhere a party is seeking to add communities.ue18 {O -ԍ Nationwide Communications, Inc., 10 FCC Rcd 13050, 13053 n.22 (1995).u 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  X7-  Lin the record that the communities at issue are outside of the station's market.7|18 {Od#-ԍ TCI of Illinois, DA 971002, para. 26, 1997 WL 241995 (F.C.C.) (CSB released May 12, 1997). In the present   case, Comcast 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 WFMZTV service to the cable communities. " ,N(N(ZZ;"Ԍ X-  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  X-  or historical carriage.l18 {O-ԍ See Cablevision Systems Corp., 11 FCC Rcd 6453, 6474 (1996).l 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,  X_-  <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   jof the market boundaries of the stations involved. In this regard the Commission has explicitly  X -  noted the relevance of Grade B contours.W Z18 yO% -  -ԍ As a general matter, Grade B coverage demonstrates service to cable communities and serves as a measure  {O -  of a station's natural economic market. See MM Docket No. 92259, 8 FCC Rcd at 2977. See also Amendment of  {O-  Section 76.51 (OrlandoDaytona Beach, Melbourne, and Cocoa, Florida), 102 FCC 2d 1062, 1070 (1984)("We   Lbelieve that television stations actually do or logically can rely on the area within their Grade B contours for economic support.").W 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   Lnote that WFMZTV 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 its service area.   The communities are also geographically separated from WFMZTV's city of license in terms   ]of mileage by approximately 47 to 68 miles, are on the far side of the Delaware River from Allentown, and are in a different state.  Xb-  _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 and Gloucester Counties. 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 WFMZTV is not warranted. We   recognize that a number of the other factors weigh in Comcast'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 upon circumstances that no longer exist. The listing of   the station and its schedule in TV listings relevant to these communities also provides some   jevidence 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 as to suggest no market   /nexus with the communities exists. Virtually all of the communities in question are situated   along the Delaware River, clustered together just across from Philadelphia. While certain of the   cable communities in Gloucester County are considerably more distant, the information provided   >by Comcast is not adequate to permit distinctions to be made among each of the individual communities involved." ,N(N(ZZ"Ԍ X-  ԙ29.` ` We have carefully considered each statutory and other relevant factor in the  X-  context of the circumstances presented here and, on balance,c18 yOb-  Zԍ We are under no obligation to give particular weight to any particular one of the several statutory factors.  {O*-  See Time Warner Entertainment Co. v. FCC, 56 F.3d 151, 175 (D.C. Cir. 1995); accord, Omnipoint Corp. v. FCC,   78 F.3d 620, 633634 (D.C. Cir. 1996) (When Congress directs an agency to consider certain factors, the agency   isimply "must reach an express and considered conclusion about the bearing of a factor, but is not required to give any specific weight to it.").c we find that Comcast has not   [demonstrated that the communities it serves lack a sufficient nexus with WFMZTV to warrant deletion of these communities from the station's ADI.  X-  30.` ` Turning to Maranatha's signal carriage complaint, having found that grant of   Comcast's petition for market modification is not warranted, the only remaining issue with   =respect to Maranatha's complaint is WFMZTV's signal strength. Comcast has submitted test   results which demonstrate that WFMZTV's signal is weaker than the requisite signal level of 45   LdBm to qualify for mandatory carriage. These test results, however, do not include the date of   zlast calibration of the equipment used. Of controlling significance, however, is Maranatha's   commitment to provide at its own expense the equipment necessary to deliver a good quality   [signal to Comcast's principal headends. We find, therefore, that WFMZTV is a qualified UHF station entitled to carriage on Comcast's systems serving the communities in question.  X -% ORDERING CLAUSES lU  Xy-  231.` ` Accordingly, IT IS ORDERED , that the petition for special relief (CSR4928A)   filed January 9, 1997 by Comcast Cablevision of Burlington County, Inc. and Comcast  XK-Cablevision of Gloucester County, Inc. IS DENIED .  X-  32.` ` IT IS FURTHER ORDERED , that the "Complaint" (CSR4881M) filed  X-  [December 16, 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).   X-  #33.` ` IT IS FURTHER ORDERED , that the affected cable systems shall commence   zcarriage of WFMZTV sixty (60) days from the date that WFMZTV provides the necessary   specialized equipment to receive a good quality signal at the principal headends of Comcast Cablevision of Burlington County, Inc. and of Comcast Cablevision of Gloucester County, Inc.  X7-  34.` ` This action is taken pursuant to authority delegated by 0.321 of the Commission's Rules. ` `  hh,VFEDERAL COMMUNICATIONS COMMISSION ` `  hh,VWilliam H. Johnson ` `  hh,VDeputy Chief, Cable Services Bureau