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For purposes of this calculation, both overtheair and cable television  S`-viewing are included.$`" yO"-  ԍ Because of the topography involved, certain counties are divided into more than one sampling unit. Also, in   certain circumstances, a station may have its home county assigned to an ADI even though it receives less than a  {O -  preponderance of the audience in that county. For a more complete description of how counties are allocated, see  {O| -Arbitron's Description of Methodology.  S-  ~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 news 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.  S-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" ,_(_(II!"Ԍparticular 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.  S`-X` hp x (#%'0*,.8135@8: yO -ԍ 47 C.F.R. 76.59.>  SH -q ARGUMENTS OF THE PARTIES ĐlU  S -  8.` ` Signal Carriage Complaint (CSR4970M). WTLKTV states that its city of license and   Lthe communities the Monroe Commission serves are all located in the Atlanta ADI, and that WTLKTV   is thus entitled to carriage on the Monroe Commission's cable system. WTLKTV further states that it   has promised to pay for any equipment necessary for the Monroe Commission to receive a good signal   from WTLKTV at the system's principal headend, but that the Monroe Commission has not responded.   Accordingly, WTLKTV requests that the Commission now order the Monroe Commission to commence carriage of WTLKTV's signal.  S-  `9.` ` In response to WTLKTV, the Monroe Commission states that it is filing a petition to   Mmodify the ADI of WTLKTV to delete the communities the system serves from WTLKTV's ADI.   Accordingly, states the Monroe Commission, it need not carry the signal of WTLKTV pending resolution  SB-of this ADI market modification petition.i ^Bx {OZ-  <ԍ The Monroe Commission cites Cablevision Systems Corp., et al., 11 FCC Rcd 12669, 12673 (1996); Time  {O$-  wWarner New York City Cable Group, 11 FCC Rcd 6514, 65266527 (1996); and the Report and Order in MM Docket  {O-No. 92259, 8 FCC Rcd at 2977.i  S-  o 10.` ` WTLKTV contends in reply that allowing the Monroe Commission to ignore WTLK  TV's requests for carriage and then to allow the system to continue to avoid carriage of WTLKTV by   filing a market modification petition in response to the station's mustcarry complaint is an abuse of the Commission's procedures and contrary to the intent of Congress.  S*-   11.` ` Market Modification Petition (CSR4991A). The Monroe Commission states that it has   never carried WTLKTV, even though the station began operation in 1988. The Monroe Commission   contends that WTLKTV fails to place a Grade B contour over either of the communities the cable system  S-  serves. In addition, the Monroe Commission notes that WTLKTV's city of license is located 93.78 miles   zfrom the cable system's headend, and that the station's transmitter site is 65.02 miles distant from the   headend. The Monroe Commission also suggests that the Atlanta metropolitan area separates WTLKTV"d ,_(_(II"   from the communities in question and defines the southern boundary of the station's market. The Monroe   Commission contends that these geographic facts demonstrate that WTLKTV is not a local signal for  S-  Nthese communities.  {O-  <ԍ The Monroe Commission cites Time Warner Cable, 11 FCC Rcd 13149 (1996); Cablevision of Cleveland,  {O-  L.P. and V Cable, Inc. d/b/a Cablevision of Ohio, 11 FCC Rcd 18034 (1996); Time Warner Entertainment {O-  JAdvance/Newhouse Partnership, 11 FCC Rcd 6541, 6555 (1996); Continental Cablevision of Western New England,  {Ov-  ;Inc., 11 FCC Rcd 6488 (1996); Cablevision Systems Corporation, 11 FCC Rcd 6453 (1996); Frederick Cablevision,  {O@-  <Inc. and C/R TV Cable, Inc., 11 FCC Rcd 4242 (1996); and Greater Philadelphia Cablevision, Inc., 10 FCC Rcd 8788 (1995). The Monroe Commission argues that most of WTLKTV's programming is  S-  infomercials, with some religious programming that shows no nexus to the communities the Monroe   =Commission serves. The Monroe Commission notes that its system carries eleven other local broadcast  S8-  =stations, 8J yO" -  ԍ These are Stations WSBTV (ABC, Channel 2), WAGATV (Fox, Channel 5), WXIATV (NBC, Channel   11), WTBS (Ind., Channel 17), WPBA (PBS, Channel 30), WATL (Ind., Channel 36), WGNX (CBS, Channel 46),   and WUPA (Ind., Channel 69), Atlanta, Georgia; WGTV (PBS, Channel 8) and WNGMTV (Ind., Channel 34), Athens, Georgia; and WHSG (Ind., Channel 63), Monroe, Georgia. all of which are licensed to cities closer to the communities in question than is Rome, Georgia,   <WTLKTV's city of license. The Monroe Commission states that these stations carry local news and other  S-  programming of interest, including Atlanta Braves baseball games, Atlanta Hawks basketball games,   ."Georgia Gang," "Georgia Week in Review," and "Atlanta This Week." These eleven stations also place   Grade B contours over the system's communities. In addition, the Monroe Commission states that one   .of these stations, WNGMTV, airs paid programming identical or similar to that which WTLKTV airs.   [Finally, the Monroe Commission suggests that it is unlikely that WTLKTV garners measurable viewing in the communities the system serves.  S -  P 12.` ` WTLKTV argues in opposition that the mustcarry portions of the Communications Act   are designed to protect local stations such as WTLKTV by ensuring their carriage rights throughout their  S -  jADI. WTLKTV notes that the statutory rules were recently upheld by the Supreme Court in TBS, Inc.  SZ-  v. FCC,@ Z2  yO,-ԍ 117 S.Ct. 1174 (1997).@ in which the Court stated that Congress properly designed the rules to "prevent any significant  S4-  reduction in the multiplicity of broadcast programming sources available to noncable households."< 4  {O-ԍ Id. at 1188.<   >WTLKTV contends that its entitlement to carriage throughout its ADI is underscored by the FCC's  S-  Ldetermination in the Report and Order in MM Docket No. 92259, supra, that Rome, Georgia WTLK  TV's city of license is an integral part of the Atlanta, Georgia market. In reaching this determination,   WTLKTV notes that the FCC found that all television stations licensed to Atlanta and Rome compete  Sn-  with each other, and that recognition of a hyphenated AtlantaRome, Georgia market was warranted.nT  yOb"-  ԍ 8 FCC Rcd at 2978. The Commission's list of major television markets in 76.51 of the rules, 47 C.F.R. 76.51, has implications for the cable television program exclusivity rules.   WTLKTV notes as well that Congress rejected a definition of a station's market based upon a mileage"F,_(_(IIc"ԫ S-based standard, and opted instead for an ADIbased test.l yOh-  ԍ WTLKTV cites earlier drafts of the cable signal carriage legislation which proposed a mileagebased  {O0-  standard, e.g., S. 12, 102d Cong., 1st Sess 4(g) and 15 (1991); H.R. 1303, 102d Con., 1st Sess. 5(a) (1991), but  {O-  which were subsequently amended to establish an ADI market standard. See 138 Cong. Rec. S609 (daily ed. Jan.   29, 1992) (amendment by Sen. Inouye); H.R. 4850, 102d Cong., 2d Sess. 6 (1992); H.R. Rep. 102628, 102d Cong., 2d Sess. 97 (1992).l  S-  B 13.` ` WTLKTV further argues that the Monroe Commission has failed to demonstrate that  S-  Zdeletion of the communities the system serves from WTLKTV's ADI would better effectuate the purposes   !of the mustcarry rules or promote the value of localism. WTLKTV maintains that the Monroe   yCommission fails to support its arguments with particularized evidence that the communities in question   are not part of the station's ADI. WTLKTV contends that the station's lack of historic carriage should   not be counted against it, particularly given WTLKTV's status as a small station with a specialized  S-  programming format. (| {O -  ԍ WTLKTV cites Time Warner Cable, 10 FCC Rcd 8045, 8048 (1995); Time Warner Cable, 10 FCC Rcd  {O-  6663, 6667 (1995); North Central Cable Communications, Inc. dba Meredith Cable, 10 FCC Rcd 4381, 4383 (1995);  {Op-  Kansas City Cable Partners d/b/a American Cablevision of Kansas City, 10 FCC Rcd 3807, 3809 (1995); and Time  {O:-Warner Cable, 10 FCC Rcd 936, 938 (1995).  WTLKTV argues that, contrary to the Monroe Commission's claims, WTLKTV   =provides local coverage to the cable communities. WTLKTV notes that its programming format, which   -combines programlength presentations by local and national businesses and community organizations with   yreligious and public affairs programming, is a valuable outlet and conduit for local advertisers, businesses,   community, and minority organizations. WTLKTV states that its public affairs program "Daybreak"   [provides information on educational, political, societal, and public affairs issues, and has featured several   Atlantaarea guests discussing local issues. WTLKTV further states that its weekly "Georgia Farm  S -  Monitor" features news and information for local farmers. In addition, WTLKTV cites its airing of   Japaneselanguage newscasts as well as locally produced cultural and information programs focusing on   /issues of concern to Americans of Asian and Pacific Islander descent and to the Muslim community.   WTLKTV states that it is committed to maintaining and strengthening its local programming, and   Ocontends that a station's planned local programming is also to be weighed in evaluating market  S-modification petitions.ll  {O-ԍ WTLKTV cites Time Warner Cable, 10 FCC Rcd 962, 964 (1995).l  S-   14.` ` WTLKTV reiterates that, despite the Monroe Commission's reliance on the distance   between its communities and WTLKTV's city of license and transmitter site, the FCC has previously   {found that Rome and Atlanta form a unified market. WTLKTV states that its ability to compete   throughout this market should not be limited. WTLKTV argues that the fact that the Monroe   Commission's system carries eleven other stations licensed to communities in the Atlanta ADI is not a  S-  reason to abrogate WTLKTV's carriage rights within the market. WTLKTV contends that this is   |particularly so in a case such as this one in which the Monroe Commission is seeking to delete  Sx-  communities from WTLKTV's market.^x  {O%-  ԍ WTLKTV cites Nationwide Communications, Inc. d/b/a EagleVision, 10 FCC Rcd 13050, 13053 n. 22  {O%-  (1995); Time Warner Cable, 10 FCC Rcd at 8048 n. 19; North Central Cable Communications, 10 FCC Rcd at 4383;  {O&-and Kansas City Cable Partners, 10 FCC Rcd at 3809 n. 14. In addition, WTLKTV argues that the fact that WNGMTV   zmay air programming that is similar to or at times identical to that aired by WTLKTV has no bearing"P$,_(_(II"   on whether the communities in question are part of WTLKTV's ADI. Finally, with respect to viewing   patterns in the cable communities, WTLKTV contends that the FCC has previously found that specialty   stations such as WTLKTV offer desirable programming diversity yet frequently attract limited  S-  Laudiences. {O-  <ԍ WTLKTV cites the Report and Order in MM Docket No. 938, 8 FCC Rcd 5321, 5322, 5327 (1993) and  {O-Nationwide Communications, Inc. d/b/a EagleVision, 10 FCC Rcd at 13053. WTLKTV argues that limited viewership should not be counted against a specialty station  S`-in the context of a market modification petition, citing Greater Worcester Cablevision.I`$ yO$-ԍ 10 FCC Rcd 12569, 12572 (1995).I  S-  }15.` ` In reply, the Monroe Commission maintains that WTLKTV has not rebutted the Monroe   .Commission's showing that the communities in question are not truly part of WTLKTV's market. The   Monroe Commission argues that it is the central purpose of the mustcarry rules to preserve the diversity  S-  of local voices. {O -  ԍ The Monroe Commission cites TBS, Inc. v. FCC, supra, and 2(b)(1) of the Cable Television Consumer Protection and Competition Act of 1992, Public Law 102385, 106 Stat. 1460 (1992). The Monroe Commission states that the Time Brokerage Agreement entered into   jbetween WTLKTV and WNGMTV shows that WTLKTV will supply up to 96.4% of WNGMTV's   weekly programming. The Monroe Commission additionally notes that an examination of the two   stations' program schedules for the week of May 11, 1997May 17, 1997 shows that 104 of WTLKTV's   234 listed programs are also aired during that week on WNGMTV, with 56 of these programs being aired   at the same time. This duplicating programming includes WTLKTV's "Daybreak" and "Georgia Farm   Monitor," as well as the station's children's programming. The Monroe Commission also notes that   WTLKTV and WNGMTV have entered into an "Option Agreement" granting WTLKTV the exclusive   option to purchase WNGMTV. The Monroe Commission asserts that failure to remove the communities   in question from WTLKTV's ADI will maintain a duplicative voice rather than a diverse voice in these   communities. The Monroe Commission argues that WTLKTV should not be allowed to use the must S-carry rules to expand its reach beyond its natural market bounds. {O-  xԍ The Monroe Commission cites Time Warner Entertainment Advance/Newhouse Partnership, 11 FCC Rcd  {OZ-at 65536554, and Cablevision Systems Corporation, 11 FCC Rcd at 6474.  S-  #16.` ` The Monroe Commission asserts that it has demonstrated through an analysis of the four   statutory factors that modifying WTLKTV's ADI will better effectuate the purpose of the mustcarry   rules. The Monroe Commission contends that the FCC's hyphenation of the AtlantaRome, Georgia major   .television market does not warrant finding that the cable communities here in question are naturally part   {of WTLKTV's ADI. The Monroe Commission maintains that this hyphenation was based upon   competition among Atlanta and Rome stations in their areas of service overlap, and not throughout the  S-  entirety of the geographic extent of the Atlanta and Rome markets.j  {O"-  ԍ The Monroe Commission cites the Notice of Proposed Rule Making in MM Docket No. 92295, 7 FCC Rcd  {Ov#-8591, 8592 (1993), and Time Warner Cable, 11 FCC Rcd 492 (1996). The Monroe Commission argues   therefore that because WTLKTV does not place a Grade B contour over the cable communities, WTLK  yTV does not compete with Atlanta licensees in these communities. The Monroe Commission states that  S*-  the present case is similar to that of The World Company, d/b/a Columbine CableVision,A*  yO'-ԍ 11 FCC Rcd 5662 (1996).A in which"*V ,_(_(II"  S-  jcommunities were deleted from a station's ADI despite being part of a hyphenated market. The Monroe  S-  Commission further states that the Atlanta edition of TV Guide does not list WTLKTV. The Monroe   yCommission argues that it is reasonable to evaluate local service based upon Grade B contours, which are   ma commonly used Commission standard. In addition, with respect to WTLKTV's analysis of   Congressional intent, the Monroe Commission contends that Congress' rejection of a fixed 50mile   Lstandard to determine a station's mustcarry rights does not negate the fact that WTLKTV is far distant from the particular cable communities in question.  S-  }17.` ` The Monroe Commission further disputes WTLKTV's commitment to serve the interests   of Monroe and Walton County subscribers. The Monroe Commission argues that the programming   WTLKTV cites as being of local interest has no nexus to Monroe or Walton County, but is of merely   general statewide or area interest. The Monroe Commission asserts that, in any event, the amount of local  S" -  programming WTLKTV provides is de minimis, constituting only one and onehalf hours per week. "  {O -  Yԍ The Monroe Commission cites Clear Cablevision, Inc. and Manchester Cablevision Inc., both d/b/a Adelphia  {OT -Cable Communications, CSR4669A, et al., DA 96812, at n. 14 and 24 (released May 22, 1996).    Nor, states the Monroe Commission, does WTLKTV show how its Asian and Pacific Islander  S -  [programming has any nexus to Monroe or to Walton County.bX $ yO-  ԍ The Monroe Commission cites 1990 U.S. Census data to show that Walton County has an Asian or Pacific   Islander population of 0.19%. In contrast, the Monroe Commission notes that 63% of Georgia's Asian or Pacific islander population reside in the five counties surrounding Atlanta.b The Monroe Commission contends that   WTLKTV's proposed future programming is not relevant to whether the station currently provides local   coverage or service, which is the statutory standard. The Monroe Commission states that the cases   WTLKTV cites to argue that little weight should be given the station's lack of historic carriage are   distinguishable, as those cases involved stations that placed Grade B contours over the communities, as  S -  =well as having other indicia of local service. The Monroe Commission further states that the Report and  S-  Order in MM Docket No. 938, supra, merely addressed the question of home shopping stations' carriage   ]rights in general, and did not address the scope of any such station's market. Finally, the Monroe   /Commission argues that its carriage of other ADI stations with a closer nexus to its communities is a   factor to be weighed in favor of granting the instant market modification petition, particularly given  SH-WTLKTV's lack of Grade B or other local service to Monroe and Walton County.HD {O,-  xԍ The Monroe Commission cites Time Warner Entertainment Advance/Newhouse Partnership, 11 FCC Rcd at 6554.  S-W ANALYSIS AND DECISION lU  S-  18.` ` We turn first to the Monroe Commission's market modification petition, to determine   <whether Monroe and the Walton County areas served by the Monroe Commission should be removed from   MWTLKTV's ADI. A resolution of this matter will determine whether WTLKTV is eligible to claim   carriage rights in these communities. We note initially, as a procedural matter, that we disagree with   WTLKTV's claim that the Monroe Commission is abusing the Commission's processes by filing this   petition. The Communications Act explicitly contemplates market modification petitions and our rules  S-set forth the process which the Monroe Commission has followed. {O&-ԍ See, e.g., 47 U.S.C. 534(h)(1)(C); 47 C.F.R. 76.59; 8 FCC Rcd at 29762977."0 ,_(_(II"Ԍ S-  ԙ19.` ` Based on our analysis of the evidence relating to the four statutory and other relevant   factors, the Monroe Commission's petition will be granted. Atlanta is the nation's tenth largest market   in terms of population. It is approximately 170 miles long and 150 miles wide, encompassing 52 counties   in three states. Rome is some 56 miles to the northwest of Atlanta. WTLKTV, licensed to Rome,   Georgia, began operation in 1988 and broadcasts on channel 14 from a transmitter close to Waleska,   MGeorgia. The cable communities involved are in Walton County, which is located to the southeast of   LAtlanta, some 94 miles from Rome and 65 miles from the WTLKTV transmitter site. In addition to the   Rome and Atlanta stations, the market is also served by WNGMTV, channel 56, Athens, Georgia. Athens is approximately 25 miles from the cable communities.  Sp- A. Historic Signal Carriage  S -  20.` ` 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." WTLKTV has no   =history of carriage in the cable communities in question. WTLKTV operations more than 10 years ago,   so that this carriage pattern is not a reflection of the recent origin of the station. Nor are there stations carried from the same area (Rome) to which this station is licensed.  S0-  21.` ` 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  S-  jevidence to define the logical scope of a station's market.n {OH-ԍ Fouce Amusement Enterprises, Inc., 10 FCC Rcd 668, 671 (1995).n Such carriage serves 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   ymarket. The signal of WTLKTV is carried in Atlanta and a number of the surrounding counties between Monroe and Rome but is not carried in the general vicinity of Monroe.  S-  S- B. Station Coverage of Communities  S-  Q22.` ` Statutory factor two is "whether the television station provides coverage or other local  Sx-  service to such community." With respect to coverage, the Commission has stated in its Report and Order  SR-  =in MM Docket No. 92259, supra, that "to show that the station provides coverage or other local service  S,-  kto the cable communities, parties may demonstrate that the station places at least a Grade B coverage  S-  contour over the cable community or is located close to the community in terms of mileage."AZ yO-ԍ 8 FCC Rcd at 29762977.A The   Monroe Commission provides evidence that WTLKTV's Grade B contour falls short of the communities in question.  Sd-  $23.` ` With respect to programming service, the Monroe Commission alleges that there is no   [significant amount of programming from the station that is specifically targeted to the cable communities   =involved. Although the station contends that it broadcasts material of interest to these communities and   the Atlanta market more generally, that material does not appear to be of the kind that suggests that these   communities are a particular focus of the station or are in any sense served in a manner that establishes a specific market connection.  St#-"t# ,_(_(II%"Ԍ S-  C. Coverage of News, Sporting Events, or Other Events of Interest by Other Stations  S-Entitled to Carriage  S-  24.` ` Statutory factor three is "whether any other television station that is eligible to be carried   zby 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  S-  events of interest to the community." In this instance, the Monroe Commission alleges that it provides  S-  jcarriage to numerous Atlanta stations that provide local service to its subscribers.M {OP-ԍ See footnote 11, supra.M WTLKTV disputes the significance of the coverage by the other stations.  Sp-  25.` ` Carriage of other local stations may be used as an enhancement factor to support a cable  SH -  operator's deletion request when there is other evidence in the record that the communities at issue are   [outside of the station's market. While the Monroe Commission suggests that WTLKTV's programming   is not specific to the cable communities, it cites equally nonspecific programming as evidence of the other   stations' local service. The Monroe Commission offers no explanation of why the programming from the other Atlanta ADI stations is any more locally oriented than is WTLKTV's programming.  SX- D. Station Audience in Communities Served by Cable System  S-  o26.` ` 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." The Monroe Commission   indicates, without specific evidence, that WTLKTV lacks viewing in Monroe and Walton County,  S-  Georgia. There is, however, some evidence of WTLKTV viewing in Walton County, where available   \Nielsen viewership data indicate that WTLKTV achieves a share of viewing of under 0.5, and a total  S@-weekly cume of 2.r @Z {O:-ԍ These figures are taken from Nielsen's 1995 County/Coverage Study.r  S- E. Other Considerations  S-  o27.` ` 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. Another   consideration argued to be relevant to this proceeding is the Commission's consideration of the scope of  S(-  the AtlantaRome, Georgia market in the context of a market hyphenation rulemaking proceeding.!( {O-  ,ԍ See Report and Order in MM Docket No. 92259, 8 FCC Rcd at 29772978; Notice of Proposed Rule Making  {O~ -in MM Docket No. 92295, supra.   LMarket hyphenation proceedings, undertaken pursuant to 614(f) of the Communications Act, and ADI   market modification proceedings, undertaken pursuant to 614(h) of the Act, although not identical in   purpose nevertheless involve some overlap of objectives and decisional criteria and the FCC's decision   to join markets takes into consideration the economic ties between the communities to be hyphenated and   the subject stations. The hyphenation of Atlanta and Rome reflects as judgment that stations in Rome and   Atlanta are competitive. The hyphenation decision is thus suggestive evidence of the belief,   =notwithstanding the distances between Atlanta and Rome, that stations from both communities are local" H!,_(_(II!"  S-  to significant overlapping portions of the same market area.`" {Oh-ԍ See, e.g., Time Warner Cable, 11 FCC Rcd at 494.` However, the hyphenation is not controlling   zin every circumstance. The "[r]edesignation of the market reflects in the rules the general competitive   .situation that in fact exists in the local area, allowing the application of the more specific rules, including   jthose relating to `area of dominant influence' changes, to be addressed from the perspective of a properly  S`-  defined market area."w#`Z {OZ-ԍ Report and Order in MM Docket No. 93304, 10 FCC Rcd 9298, 9299 (1995).w Here, the issue is not whether stations in Rome and Atlanta are competitive but   <whether the Rome's station's market properly includes communities on the opposite side of Atlanta. Thus, for present purposes the hyphenation decision appears to add little to the 614(h) decision making process.  S-  R28.` ` The Monroe Commission also argues that the duplication of programming between   WTLKTV and WNGMTV weighs in favor of its petition. The fact that WNGMTV, which is   significantly closer to the cable communities than WTLKTV, broadcasts programming duplicative of that   which WTLKTV presents is suggestive of a belief among the market participants that WTLKTV's reach   jinto the WNGMTV side of the Atlanta market is limited. Generally, in the broadcast industry, stations with duplicative programming do not operate in identical market areas.  S - F. Summary  S -  SX-  #29.` ` 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   y"to ensure that television stations be carried in the areas which they serve and which form their economic  S-  0market."\$ yOl-ԍ H.R. Rep. 102628, 102d Cong., 2d Sess. 97 (1992).\ 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  S-  \purposes" of the mandatory carriage requirements.?%| yO-ԍ 47 U.S.C. 534(h).? In acting on such requests the Commission was  Sh-  instructed to "afford particular attention to the value of localism, taking into account four specified  S@-  statutory factors." These factors, however, were "not intended to be exclusive."\&@  yO-ԍ H.R. Rep. 102628, 102d Cong., 2d Sess. 97 (1992).\ The market  S-  kmodification provisions of 614(h) are said, in the legislative history, to "reflect a recognition that the   MCommission may conclude that a community within a station's ADI may be so far removed from the  S-  \station that it cannot be deemed part of the station's market."3' {O!-ԍ Id.3 Based on the evidence presented, we   <conclude that the requested exclusion of the communities served by the Monroe Commission cable systems from the market of WTLKTV will better effectuate the purposes of the mustcarry statutory provisions.  S(-  30.` ` In reaching this conclusion, we have considered the statutory factors as well as other  S-  relevant information. WTLKTV has never been carried in any of the communities in question (factor   I), provides no overtheair television broadcast service for a portion of the communities (factor II), and   has little measured audience in the communities (factor IV). Given the statutory directive, weight must" . ',_(_(II<"   Lbe 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   ԩ are not by themselves controlling in circumstances where such an implementation of the 1992 Cable Act   .would, in effect, prevent weaker stations that cable systems had previously declined to carry, from ever obtaining carriage rights.  Sp-  31. ` ` Given the difficulties of relying exclusively and explicitly on the statutory factors of   historical carriage and viewing patterns, which in certain circumstances could severely narrow the carriage   rights of stations even within what is undeniably their local market area, we have found it helpful to focus  S -  also on factors that are not influenced by the type or age of the stations involved or historical carriage.l(  {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, 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  S-  [regard, the Commission has explicitly noted the relevance of Grade B contours.X)Z 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.").X In the absence of other   information, station service contours provide at least one objective measure of the scope of a station's   Nlocal market. Here we note that WTLKTV does not provide Grade B service to any of the cable   communities. In addition, the Monroe communities are on the opposite side of the Atlanta urban area   from WTLKTV and geographically separated from its city of license by approximately 93 miles and from its transmitter location by 65 miles.  S-  232.` ` An additional point weighing in favor of a conclusion that Monroe is sufficiently separate   [from WTLKTV to warrant exclusion is the existence of station WNGMTV which is already carried by   ythe cable systems and which carries much of the same programming as does WTLKTV which has a time   brokerage agreement with WNGMTV and provides much of its programming. Based on general patterns   yin the television broadcast industry, where two stations are broadcasting much of the same programming,   such an arrangement suggests that the area closer to the brokered station is not served by the brokering  S-  station. While that may not always be the case, in the present circumstances it provides reinforcing   evidence that the Monroe communities are logically excluded from the WTLKTV mandatory carriage area.  S-  S`-  3 33.` ` We have carefully considered each statutory and other relevant factor in the context of"` ),_(_(II"  S-  <the circumstances presented here and, on balance,V* {Oh-  iԍ We are under no obligation to give particular weight to any one of the several statutory factors. See Time  {O2-  Warner Entertainment Co. v. FCC, 56 F. 3d 151, 175 (D.C. Cir. 1995); accord, Omnipoint Corp. v. FCC, 78 F. 3d   633634 (D.C. Cir. 1996) (When Congress directs an agency to consider certain factors, the agency simply "must   reach an express and considered conclusion about the bearing of a factor, but is not required to give any specific weight to it.").V we find that the Monroe Commission has demonstrated   that Monroe and the Walton County communities served by the Monroe Commission lack a sufficient nexus with WTLKTV to warrant deletion of these communities from the station's ADI.  S`-  !34.` ` Turning to WTLKTV's signal carriage complaint, having found that grant of the Monroe   yCommission's petition for market modification is warranted, that complaint is now moot. Section 614 of   the Communications Act and the Commission's implementing rules permit stations to assert mandatory   carriage rights on cable systems located within their market. The prerequisite for asserting mustcarry  S-  rights with respect to a particular cable system, however, is that the operator serve communities in the  S-  station's ADI. These communities have been deleted from WTLKTV's market by this Memorandum  Sr-  Opinion and Order. Because we have granted the petition to delete these communities from WTLKTV's   market, the associated complaint filed for mandatory carriage of its signal in these communities is rendered moot.  S -'1 ORDERING CLAUSES lU  S -  "35.` ` Accordingly, IT IS ORDERED , that the petition for special relief (CSR4991A) filed  S\-  /April 3, 1997 by the Monroe Water, Light and Gas Commission IS GRANTED . Monroe and the   =surrounding unincorporated areas of Walton County, Georgia served by the Monroe Commission are no longer part of WTLKTV's market area for purposes of 614.  S-  36.` ` IT IS FURTHER ORDERED , that the "MustCarry Complaint" (CSR4970M) filed  S-  March 11, 1997 by Paxson Atlanta License, Inc., IS DISMISSED , 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)).  S-37.` ` 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