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S- ` x7.` ` Pappas says its complaint is largely about KFWU's statutorily mandated right to be carried  xon its regular position on Channel 8 on all of these cable systems. Pappas notes that TCI of California  x=is currently carrying KFWU on cable systems serving eighteen of the thirty two identified communities,  xon various channel positions as Station KTNC, Concord, California, which retransmits KFWU's signal.  x<Pappas argues that since Station KTNC is retransmitting the signal of KFWU, KFWU as the parent station  xis entitled to its regular channel position on all of TCI of California's systems, an entitlement which is  S- xbeing ignored by TCI of California.f yO( - x#X\  P6G;IP#эA station's channel position has a substantial impact on viewership of a station, since lower channel positions generally lead to higher viewership. Pappas contends it is undisputed that KFWU is a full power  xLcommercial television station or that the station places a good quality signal over the headends of TCI of  Sp- xCalifornia's cable systems by means of retransmission of KFWU's signal by KTNC.+p f yO0 -  w#X\  P6G;IP#эPappas contends that the carriage of KFWU as KTNC removes any issue about the station meeting Commission signal strength requirements. TCI of California presented nothing to the contrary.+ Pappas claims that  xKFWU and the TCI of California's cable systems are all located in the San Francisco ADI, and KFWU  xis therefore entitled to carriage on those cable systems on its assigned Channel 8. Pappas argues that  xthe inclusion of statutory and regulatory provisions for complaints based solely on failure of cable  S - xoperators to meet their channel position obligations xf {O-#X\  P6G;IP#эSee 47 U.S.C.  534(d)(1) and 47 C.F.R.  76.61(a). demonstrates that its concern here about channel position is not a trivial matter.  SX- ` x8.` ` TCI of California in opposition disputes Pappas' assertion that KFWU is in the San  S0- x[Francisco ADI, asserting in essence that the listing in the 19911992 Television Market Guide of KFWU  S - xin the ChicoRedding ADI is controlling. TCI of California argues that the Commission, in Costa De Oro,  xconfirmed that a station may be physically located in one ADI but assigned to another, and that a station's  S- xmarket is determined for must carry purposes by the ADI to which it is assigned in the 19911992  S- xTelevision Market Guide. TCI of California argues that Pappas failed to distinguish Costa De Oro, noting  x\that KFWU, in addition to not placing a Grade B contour over either Redding or Chico, also does not  xzplace a Grade B contour over any of the named communities in the San Francisco ADI. It also argues  S -that Pappas failed to demonstrate that Costa De Oro was wrongly decided.  S- ` x9.` ` TCI of California also disputes as flawed Pappas' contention that the "home county"  x-exception has no application to this case. It contends that Pappas failed to prove that KFWU is listed out S- xofmarket, i.e., in the ChicoRedding ADI, only because of its former satellite status. TCI of California  x\argues that nothing in the Commission's rules excludes satellite stations from the exception. It argues  S4- xfurther that the 19911992 Television Market Guide's listing of KFWU in the ChicoRedding ADI instead  xyof the San Francisco ADI is not changed by the fact that Pappas now claims KFWU is located in the San  xkFrancisco ADI. If the failure of KFWU's Grade B contour to reach Chico or Redding establishes that  xKFWU is not in the ChicoRedding ADI as Pappas contends, then, TCI of California asserts, KFWU  xlikewise cannot be considered to be in the San Francisco ADI, because KFWU's Grade B contour falls  xeven further from the San Francisco Bay area. TCI of California also contends that must carry rights in  xthis case belong to KTNC, the station retransmitting KFWU's signal, and not to KFWU, and that KFWU"F  ,>(>(II "  S-cannot properly claim channel position rights on its cable systems that presently carry KTNC. f yOh- xw#X\  P6G;IP#эThe City of Belmont, California and the San Mateo County Telecommunications Authority submitted informal  xhopposition to the complaint in which they take the position that KFWU does not serve the San Francisco Bay area.  xOther than to note the distance between KFWU and the Bay area, neither informal opposition provided any empirical evidence in support of its position.  S- ` x10.` ` In reply, Pappas reasserts the arguments made in the complaint. It also provided  S- xstatements of two former Arbitron executives. \f yO- x#X\  P6G;IP#эOne former Arbitron executive developed the concept of ADI. The other former Arbitron executive was  {O - xresponsible for ratings research in Arbitron's Los Angeles office when the 19911992 Television Market Guide was  {Oj -published. See reply, declarations of Jon Currie and Roger Cooper. Pappas asserts that the statements of these former  S`- xArbitron executives establish that, under the concept of ADIs as implemented in the 19911992 Television  S:- x/Market Guide, ADIs consist of geographic areas (cities and counties) and not stations. Based on the  xgeographic methodology of the ADI concept, these former Arbitron executives stated that Arbitron  xLconsidered KFWU to be assigned to the San Francisco ADI. Pappas further asserts the former Arbitron  xexecutives' statements confirm also that, although the audience data of KFWU as a satellite of KRCRTV  x>was reported in conjunction with KRCRTV, that reporting process was considered irrelevant to the  xquestion of which ADI Arbitron considered KFWU to be in. In this connection, Pappas emphasizes that KFWU's city of license, Fort Bragg, is shown in the San Francisco ADI.  S$ -  S -DISCUSSION AND ANALYSIS ă   S - ` x11.` ` KFWU is a full power commercial television broadcast station licensed to Fort Bragg,  xCalifornia, which is located in Mendocino County, California. Mendocino County is located in the far  S\- x>northern portion of the San Francisco ADI, and adjacent to the ChicoRedding ADI. \f {O-#X\  P6G;IP#эSee 19911992 Television Market Guide, p. 1230. Despite being  S4- x[physically located in the San Francisco ADI, KFWU is listed in the 19911992 Television Market Guide  S- xas a station assigned to the ChicoRedding ADI. f f {O-#X\  P6G;IP#эSee 19911992 Television Market Guide, p. 280. Pursuant to 47 U.S.C.  534, a commercial television  xbroadcast station is entitled to assert mandatory carriage rights on cable systems located within the  xstation's market. As noted earlier, Section 76.55(e)(1) of the Commission's Rules defines a commercial  x?television station's market as its ADI, and the ADIs to be used for purposes of implementing the  Sn- xmandatory carriage rules are those published in Arbitron's 19911992 Television Market Guide. Since  SH- xthe 19911992 Television Market Guide lists KFWU as a station in the ChicoRedding ADI, we find that  xKFWU is in the ChicoRedding ADI for must carry purposes. As such, KFWU is not a "local commercial  x\television station" with respect to the cable systems located in the San Francisco ADI at issue in this  xjproceeding within the meaning of 47 U.S.C.  534(h)(1)(A). Therefore, KFWU is not entitled to carriage on TCI of California's cable systems serving the identified communities.  SZ- ` _x12.` ` The circumstances of this case are similar to that addressed in Costa De Oro. There, must  xcarry rights on cable systems located in the Los Angeles ADI were denied to KSTVTV, located in  S - xyVentura County, California, although Ventura County is in the Los Angeles ADI, because the 19911992  S- xTelevision Market Guide assigned the station to the adjacent Santa BarbaraSanta MariaSan Luis Obispo" ,>(>(II="  S- xADI. This case also parallels the case of KNTV, San Jose, noted in the Must Carry Order, where the  S- x19911992 Television Market Guide assigned KNTV to the SalinasMonterrey ADI, although KNTV's  S- xhome county of Santa Clara is physically within the geographic boundaries of the San Francisco ADI.uf {O-#X\  P6G;IP#эSee 8 FCC Rcd at 2975 at n. 108.u  S- xOur review of the 19911992 Television Market Guide shows that Arbitron assigned KFWU to the Chico xRedding ADI in the same fashion that KSTVTV was assigned to the Santa BarbaraSanta MariaSan Luis  S>- xyObispo ADI discussed in Costa De Oro and in the same fashion that KNTV was assigned to the Salinas S- xMonterrey ADI discussed in the Must Carry Order. Because we resolve this case based on the precedent cited, we need not reach other issues raised by the parties.  S- ` `x13.` ` As we stated in Costa De Oro, parties are entitled to rely on the 19911992 Television  S|- xMarket Guide for determining a station's market for signal carriage purposes. Section 614(h) of the  xCommunications Act contains a specific mechanism for revising Arbitron assignments where the propriety  S. - xof a station's television market is called into question.. Zf {O(-#X\  P6G;IP#эSee 47 U.S.C.  534(h)(1)(C). See also 47 C.F.R.  76.7 and 76.59. Because a specific mechanism for revising market  xassignments are available, it is inappropriate to address here the request made in the alternative by Pappas  xfor waiver of Section 76.55(c) of the rules to permit KFWU to obtain carriage rights on TCI of  S - xCalifornia's cable systems at issue. f yOB-#X\  P6G;IP#эCommunications Act of 1934, as amended, 614(h)(1)(C)(ii), 47 U.S.C. 534(h)(l)(C)(ii). We note in this connection that Pappas has not presented with its  xwaiver request the kinds of information that usually accompanies a petition for special relief seeking to  xinvoke the specific mechanisms for revising market assignments. We do not address here whether such a revision of KFWU's market would be appropriate.  S-1 ORDERING CLAUSES ă  S- ` Dx14.` ` For the foregoing reasons, IT IS ORDERED , pursuant to Section 614 of the  xyCommunications Act of 1934, as amended (47 U.S.C. 534), that the complaint of Pappas Telecasting of  SN-Concord, Inc. in File No. CSR4950M IS DENIED .  S- ` Bx15.` ` This action is taken pursuant to authority delegated under 0.321 of the Commission's Rules. x` `  hhFEDERAL COMMUNICATIONS COMMISSION x` `  hhGary M. Laden, Chief x` `  hhConsumer Protection and Competition Division x` `  hhCable Services Bureau