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A. a.(1)(a) i) a)DocumentgPleadingHeader for Numbered Pleading PaperE!n    X X` hp x (#%'0*,.8135@8:8HH"&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""/>/>/>/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+SS8-8WuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxN%7777777777>>>0eOIIOD>OO%*ODaOO>OI>DOOgOOD%%37%07070%777V7777%*77O77055;%;3%%%%%%%%%%%7O0O0O0O0O0aHI0D0D0D0D0%%%%O7O7O7O7O7O7O7O7O7O7O0O7O6O7O7O7>7O0O0O0I0I0I;I0OED0D0D0D0O7O7O7O;O7O;O7%%7%%%7M>;;O7DD,D%D%DO7AO7O7O7O7aOI%I%I%>*>*>*>;D.DD3O7O7O7O7O7O7gOO;D0D0D0O7D%O7>*D%O7E77%%WMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxN(BB(37%07777j7#TT7!#TT7T!%%007n&&Bn77lCTn(nBB(A\\>>n%07\n!"IIIITTenn7TnB@;7>lBBn7 H5!,,5\  P6G;,P\{,W80,%W*f9 xr G;Xy.\80, {\4  pG;"i~'^5>M\\>>>\}0>03\\\\\\\\\\>>}}}\rryrr>Qygyrr\grrggF3FM\>\\Q\Q3\\33Q3\\\\FF3\QyQQFI3Ic>0cM>>>0>>>>>>\>\3r\r\r\r\r\yyQrQrQrQrQ>3>3>3>3y\\\\\\\\\gQr\\\\gQ\r\r\r\r\yQyQycyQnrQrQrQrQ\\\c\c\>3>\>>>\\ccyQg3gBg>g;g3y\jy\y\\\yrFrFrF\F\F\FccgBg3gM\\\\\\ygcgFgFgF\g>y\\Fg>g\n0\\=(=WddddddddddddddddddddddddddddddddddddddddNBnnB_\F\\\\\\3;\7;\7>>gg\??n\\pBnnBb\\>g\7"yyyy\njc\}nn\y.X80,IX\  P6G;P 2a=5,0&a\  P6G;&P 2e=5,D&e4  pG;& 7jC:,+Xj\  P6G;XP 7nC:,Xn4  pG;X\ 5hC:,%Xh*f9 xr G;XX W!@(#,9h@\  P6G;hP H5!,,5\  P6G;,P\{,W80,%W*f9 xr G;Xy.\80, {\4  pG;\0_=5,% &_*f9 xr G;&XP:% ,1J:\  P6G;JP  JGNg `  Arial2@ X- X   S S-  Federal Communications Commission`}(#<DA 971856 ă  yxdddy #Xj\  P6G;+XP#vK #X\  P6G;IP#Before the Federal Communications Commission  yO}"Washington, D.C. 20554 #Xj\  P6G;+XP#у  Sb-#&a\  P6G;0&P#In re:j) j)  S-Amzak Cable Midwest, Inc.j)ppCSR4996A dba Paragon Cablej) j) For Modification of the ADI of Televisionj) Broadcast Station KXLI, St. Cloud,j) Minnesotaj)  S -  MEMORANDUM OPINION AND ORDER lU  S -X` hp x (#%'0*,.8135@8:States is allocated to a market based on which homemarket stations receive a preponderance of total   viewing hours in the county. For purposes of this calculation, both overtheair and cable television  S -viewing are included.'Z Q- yO>'- xԍ Because of the topography involved, certain counties are divided into more than one sampling unit. Also, in  xcertain circumstances, a station may have its home county assigned to an ADI even though it receives less than a  {O(- xpreponderance of the audience in that county. For a more complete description of how counties are allocated, see"(,**("  {O-Arbitron's Description of Methodology.'" Z,**88)""Ԍ S-  ~ԙ3.` ` Under the Act, however, the Commission is also directed to consider changes in market areas. Section 614(h)(1)(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 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  S-areas served by the cable system or systems in such community.Z} yO-ԍ Communications Act of 1934, as amended, 614(h)(1)(C)(ii), 47 U.S.C. 534(h)(1)(C)(ii).  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 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.  S8-X` hp x (#%'0*,.8135@8: X} yO-ԍ 47 C.F.R. 76.59.>  S-  S-  MODIFICATION ARGUMENTS ă  S8-  8.` ` The communities here in question are located in Brown and Watonwan Counties,   Minnesota and are considered to be part of the Minneapolis, Minnesota ADI. St. Cloud, Minnesota, the   Lcity of license of KXLI, is also part of the same ADI. KXLI is located approximately 85 miles from the nearest of the communities served by Paragon.  Sp-  9.` ` In support of its request, Paragon argues that KXLI should be excluded from carriage on   its systems because its fails to meet any of the criteria for market stations. First, Paragon states that there   is no history of carriage of KXLI on either of its systems even though the station has been in operation   since 1982. Secondly, Paragon points out that not only does KXLI's Grade B contour not encompass  S -  =either of the communities at issue,L X } yOX-  iԍ Paragon points out that KXLI operates from a transmitter site near Big Lake, Minnesota, which is located   approximately 25 miles southeast of St. Cloud. It states that KXLI's Grade B contour falls 35 miles short of New Ulm and over 45 miles short of Madelia.L but the station is geographically remote as well. Paragon states that   the closest community, New Ulm, is approximately 85 miles from St. Cloud, while the farthest, Madelia,   is more than 100 miles away. It maintains that these distances are even farther away than those cited in   .previous modification requests where the Commission granted requests to exclude stations from system  S0-  Lcommunities. ^0} {O-  ,ԍ See TKR Cable Company, DA 96189, TCI of Indiana, Inc., DA 962144 (released December 20, 1996), AR  {O-  Cable Services, Inc., DA 962015 (released December 5, 1996), TCI of Northern New Jersey, Inc., DA 97112  {Ol-(released January 22, 1997), and Armstrong Utilities, Inc., DA 97458 (released March 4, 1997).. Third, Paragon indicates that KXLI provides no programming covering issues of specific   >concern to its subscribers. Indeed, Paragon stresses that a good portion of its programming seems to   include programlength "infomercials" by national businesses and organizations. Moreover, Paragon states   that the absence of any nexus between its systems and KXLI is buttressed by the fact that it is not listed  S-  /in the Journal, New Ulm's daily newspaper nor in the MinneapolisSt. Paul edition of TV Guide. In   addition, Paragon argues that issues of concern to its subscribers are more than adequately covered by the  SB-  \local stations it currently carries on its systems.y XB. } yO -  ԍ Paragon states that its carries the following stations on both systems: KEYCTV (CBS), WCCOTV (CBS),   KMSPTV (ABC), KARE (CBS), WFTC (Ind.), KSTPTV (NBC), and WTBS (Ind.). In addition, on the New Ulm system it carries KTCA (PBS) and on the Madelia system it carries KLGTTV (Ind.) and WGNTV (Ind.).y Finally, Paragon states that KXLI has no reported viewership in either Brown or Watonwan Counties, where the communities are located.  S-  Q10.` ` In its opposition, KXLI argues that Paragon has failed to demonstrate how granting its   exclusion request would promote local broadcast service and foster the goals of diversity and competition   mandated by Congress. KXLI states that it is undisputed that both KXLI and Paragon's communities are   all located within the Minneapolis ADI. Therefore, KXLI maintains that it is entitled to carriage on   jParagon's systems. KXLI argues that the factors which Paragon relies upon for its exclusion request (i.e."*N ,`(`(88"   .distance and Grade B coverage) were expressly rejected by Congress as dispositive of must carry rights.   Instead, KXLI points out that Congress stated that "ADI lines are the most widely accepted definition of  S-  a television market and more accurately delineate the area in which a station provides local service than  S-  \any arbitrary mileagebased definition." (emphasis supplied in filing). } yO-  xԍ House Committee on Energy and Commerce, Cable Television Consumer Protection and Competition Act of 1992, H.R. Rep. No. 102628, at 97 (1992). Therefore, granting Paragon's   krequest to exclude based on the lack of a Grade B contour, maintains KXLI, effectively eliminates the   LADIwide carriage contemplated by Congress. Moreover, KXLI states that Paragon has not shown that   .grant of its request would allow it to "better effectuate" the purposes of the must carry rules by alleging   that carriage of its station would preclude the systems from carrying a more local broadcast station. KXLI   argues further that it is an independent commercial station airing a unique program format combining   programlength presentations by local and national businesses and community organizations with religious  Sp-  and local public affairs programming.~Xp } yO0 -  ԍ In addition, KXLI states that each week it presents three hours of children's programming, two and onehalf   hours of locally originated news programming in the evenings, two and onehalf hours of agricultural programming in the mornings and three hours of outdoororiented programming on Saturday afternoons.~ It states that it airs local news and programming designed to   ]address the needs and interests of residents throughout the Minneapolis ADI, including Paragon's   jsubscribers. In addition, KXLI points out that the Commission has previously stated in exclusion cases  S -  that lack of historical carriage "should not be given great weight."b @} {O-ԍ See Time Warner Cable, 10 FCC Rcd 936, 938 (1995).b At the same time, KXLI states that   it is immaterial that Paragon carried other local stations which provide local programming to its   subscribers. It indicates that the Commission has previously held that "[We] do not believe Congress   intended the third criterion to operate as a bar to a station's ADI claim whenever other stations could also   be shown to serve the communities at issue, but rather that this criterion was intended to enhance a  S0-  station's claim where it could be shown that other stations do not serve the community at issue."0} {O-  ԍ See Kansas City Cable Partners, 10 FCC Rcd at 3809 n. 14, North Central Cable Communications, Inc., 10  {Ol-FCC Rcd at 4383, and Time Warner Cable, 10 FCC Rcd 8050, 8053 n. 15 (1995).   Finally, KXLI argues that the Commission has previously rejected arguments regarding lack of local   jaudience shares, finding instead that specialty stations, such as KXLI "are capable of 'offer[ing] desirable  S-diversity of programming. . .' yet typically attract limited audiences."R\. } {O-  ԍ See Nationwide Communications, Inc., 10 FCC Rcd 13050, 13053, First Report and Order in Docket 20553,  {OP-  53 FCC 2d 442, 452 (1976), recon. denied, 60 FCC 2d 661 (1976), and Home Shopping Station Issues, 8 FCC Rcd 5321, 5327 (1993).R  Sh-  11.` ` In its reply, Paragon reiterates the factors addressed in its petition for exclusion and   maintains that they fully support grant of request. It also argues that KXLI offers in opposition its now  standard analysis of the must carry requirements and the related modification provisions which have been  S-  repeatedly rejected by the Commission in previous decisions.nR } {O$-ԍ See TCI of Illinois, Inc., DA 971002 (released May 12, 1997).n Moreover, Paragon points out that KXLI   essentially ignores the distance between it and the cable systems and the failure of its Grade B contour   to encompass the communities. In addition, Paragon argues that while KXLI maintains that it provides   programming focused on newsworthy events outside the MinneapolisSt. Paul metro area, it fails to"x,`(`(88"   provide any examples of coverage of news events involving either New Ulm or Madelia specifically, or Brown and Watonwan Counties generally.  S-@ DISCUSSION ă  S8-  12.` ` Based on the four statutory and other relevant factors, Paragon's petition will be granted.   As an initial matter, we note that, according to the legislative history of the 1992 Cable Act, the use of   yADI market areas is intended "to ensure that television stations be carried in the areas which they service   \and which form their economic market." Changes may be sought and granted by the Commission "to   ybetter effectuate the purposes" of the mandatory carriage requirements. The ADI market change process   incorporated into the Communications Act, however, is not intended to be a process whereby cable   operators may seek relief from the mandatory signal carriage obligations apart from the question of   whether a change in the market area involved is warranted. When viewed against this backdrop, and   yconsidering all of the relevant factual circumstances in the record, the operator's deletion petition appears   to be a legitimate request to redraw ADI boundaries to make them congruous with market realities.   Paragon's actions do not reflect an intention to skirt its signal carriage responsibilities under the   Communications Act and the Commission's Rules nor do they evidence a pattern of discriminatory   kconduct against the station subject to deletion. Based on the geography and the statutory factors, we   believe that the communities in question are sufficiently removed from KXLI that they ought not be   deemed part of the station's market for mandatory carriage purposes. Congress enacted Section 614(h)   with a deletion provision so that market anomalies such as this one could be properly rectified through the special relief process.  Sh-  13.` ` At the outset, the evidence suggests that KXLI does not provide local service to the   communities in question. KXLI does not place either a Grade A or Grade B contour over the cable  S-  communities.} yO-  ԍ We have held that the local service requirement is satisfied if the station's Grade B contour covers the  {OH-community. See 8 FCC Rcd at 2981. In addition, we do not believe that it has been shown that KXLI carries programming of   specific local interest or import for cable viewers in the instant communities. The KXLI programming   information provided to us indicates programming of potential general interest but without specific ties   to the communities at issue in this matter. We also believe that Paragon's carriage of other local   jtelevision stations provides support for the requested action. Where a cable operator is seeking to delete   ja station's mandatory carriage rights in certain communities within its ADI, and it is clear that the station   jis not providing local service to those communities, the issue of local coverage by other stations becomes   /a factor which we will give greater weight than in cases where a party is seeking to add communities.   In this case, there are several television stations carried by Paragon which have a closer nexus to the system communities herein.  S`-  `14.` ` Paragon also demonstrates that KXLI has no historical carriage on the cable systems in   question, despite 15 years of operation, and has no reported audience in either Brown or Watonwan   County, where the cable systems are located. We note that these facts are not determinative, in and of   themselves, of the relationship between the cable communities and the market of the television station,   nor should their absence permit a cable operator to undermine the objectives of the mandatory carriage   requirement. However, we also note in this instance, that St. Cloud, Minnesota, KXLI's city of license,   jis located from 85 to 100 miles from Paragon's headends. The distances involved in this situation further   attenuates the local ties that the station might have to the cable communities and helps explain why the"H$",`(`(88%"   .station's viewership is too low to be reported. Thus, we conclude that the lack of historical carriage and   /the dearth of audience is of evidentiary significance when linked with other information regarding the   market and the particular distances involved, particularly where a station has been broadcasting since 1983   and has no reportable audience share in the relevant community. This is not a situation where the carriage   pattern suggests that a station is logically part of the market for carriage purposes, but has not been carried   for competitive reasons. Nor do we believe that the operator has impermissibly singled out KXLI from among other similarly situated stations as the sole station it has declined to carry.  S-  Q15.` ` KXLI argues that there is a strong presumption of carriage throughout a station's ADI.   And KXLI takes the position that the presumption should be given full effect in this case. This argument   disregards the information provided for the record as well as the four statutory factors set forth in the   ymarket modification provisions. For instance, as noted above, KXLI claims the availability of other local   [stations in the market should not be considered in this case. In addition, KXLI discounts as insignificant   to our decision the station's lack of historical carriage, the station's lack of technical coverage of the   communities, and the station's lack of viewership, as well as the distance of the station from the   communities. Section 614(h)(1)(C), however, specifically and unambiguously directs the Commission,   .in considering requests for market modification, to afford particular attention to the value of localism by   taking each of these factors into account. We have previously observed that the must carry rules "were   not intended to transform an otherwise local station into a regional `super station' that must be  S-  automatically carried in every single community in an ADI. . . ."} {Op-ԍ See Time Warner EntertainmentAdvance Newhouse Partnership, 11 FCC Rcd 6541 (1996) at 25. KXLI contends the only circumstance   in which deletion of a local station would enhance localism is where a cable system is unable, in the   absence of deletion, to carry the signal of another station that is outside of the ADI market and that   kprovides demonstrably more local service. We find these interpretations of Section 614(h) and of the   0Commission's implementing regulations too restrictive and without a sufficient basis in either the   legislative history or the wording of the statute. The statute, on its face, does not limit market deletion   requests only to those situations where an outofthemarket station is more deserving of carriage than an   inmarket station. There is also no language in the legislative history of Section 614(h) directly supporting   KXLI's viewpoint, nor is there any in the Commission's Rules. To the contrary, KXLI ignores Congress'   directive allowing either broadcasters or cable operators to ask for market modifications so that a station's  Sx-  ADI could better reflect the economic market at hand.bxZ} yOr-ԍ H.R. Rep. No. 628, 102d Cong., 2d Sess. 66 at 97 (1992).b In summary, we reject KXLI's arguments that   amount to a wholesale attack on the statutory market modification provisions of Section 614 of the Communications Act. ",`(`(88>"Ԍ S- 1' ORDERING CLAUSES  S-  S-  116.` ` Accordingly, IT IS ORDERED , pursuant to 614(h) of the Communications Act of 1934,   as amended, 47 U.S.C. 534, and 76.59 of the Commission's Rules, 47 C.F.R. 76.59, that the petition  S`-  for special relief, filed April 15, 1997, on behalf of Amzak Cable Midwest, Inc. dba Paragon Cable IS  S8-GRANTED .  S-17.` ` 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   X -#Xj\  P6G;+XP#  X$-l #&a\  P6G;0&P#у