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InterMedia contends that Paxson stations utilize an infomercial format  xnationwide and this format has no specific nexus to the communities at issue. InterMedia also argues that  xWTLKTV's lack of nexus to the communities is further emphasized by the fact that the television  xlistings in the Athens daily newspaper, the Athens Daily News/Athens BannerHerald, do not include WTLKTV.  S- ` }x13.` ` InterMedia also notes that its cable systems carry a host of stations licensed in and around  S- xAtlanta, which provide extensive coverage of local news and sporting events. yOO%-ԍFor example, InterMedia states that its systems carry WSB(ABC), WGNX (CBS) and WXIA (NBC). InterMedia also states that  xjits systems carry channels such as the "Athens/Government Programming" channel, the "Clarke County  S- xSchool Channel," a University of Georgia (UGA Programming) channel and the "Community Channel""d ,`(`(88"  xwhich all focus on various communityoriented programming. Finally, InterMedia states that WTLKTV  x!has no significant viewership in the communities at issue. According to a marketing and research  xconsulting study cited by InterMedia, WTLKTV has no ratings whatsoever in either cable or noncable  S-households in either Clarke or Oconee County where the communities are located.{ yO-ԍInterMedia Petition, Exhibit 9 (Media Strategies letter dated October 15, 1997). {  S8- ` x14.` ` In opposition, Paxson argues that deletion of the communities from its television market  xwould place WTLKTV at a distinct disadvantage relative to the other stations in the Atlanta ADI.  xAccording to Paxson, Congress designed the must carry regime in order to ensure that smaller, less x1established stations, such as WTLKTV, would receive the cable carriage necessary to remain  xkeconomically viable, thereby promoting localism, diversity and competition in the video marketplace.  Sp- xMWTLKTV notes that the statutory rules were recently upheld by the Supreme Court in TBS, Inc. v.  SJ - xFCC,>J X yOB -ԍ117 S.Ct. 1174 (1997).> in which the Court stated that Congress properly designed the rules to "prevent any significant  S$ - xreduction in the multiplicity of broadcast programming sources available to noncable households.":$  {O-ԍId. at 1188.:  xOWTLKTV contends that its entitlement to carriage throughout its ADI is underscored by the  S - xCommission's determination  W$On9   W$On9 in the Report and Order in MM Docket 92259, supra, that Rome,  xGeorgia WTLKTV's city of license is an integral part of the Atlanta, Georgia market. In reaching  xthis determination, WTLKTV notes that the Commission found that all television stations licensed to  xAtlanta and Rome compete with each other, and that recognition of a hyphenated AtlantaRome, Georgia  S6- xmarket was warranted.6z yOP- xwԍ8 FCC Rcd at 2978. The Commission's list of major television markets in Section 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  S-based upon a mileagebased standard, and opted instead for an ADIbased test.j yO- xԍWTLKTV cites earlier drafts of the cable signal carriage legislation which proposed a mileagebased standard,  {OH- xe.g., S. 12, 102d Cong., 1st Sess 4(g) and 15 (1991); H.R. 1303, 102d Con., 1st Sess. 5(a) (1991), but which  {O- x;were subsequently amended to establish an ADI market standard. See 138 Cong. Rec. S609 (daily ed. Jan. 29, 1992)  x(amendment by Sen. Inouye); H.R. 4850, 102d Cong., 2d Sess. 6 (1992); H.R. Rep. 102628, 102d Cong., 2d Sess. 97 (1992).j  S- ` a x15.` ` Paxson further argues that InterMedia has failed to demonstrate that deletion of the  x>communities from WTLKTV's ADI would better effectuate the purposes of the must carry rules or  xMpromote the value of localism. Paxson maintains that InterMedia fails to support its arguments with  xparticularized evidence that the communities in question are not part of the station's ADI. Paxson  xycontends that the WTLKTV's lack of historic carriage should not be given great weight because the must  xcarry provisions were adopted, in large part, to cure past discriminatory signal carriage practices by cable  S- x.operators against broadcast stations.#  {O$- xԍPaxson cites Time Warner Cable, 10 FCC Rcd 936, 938 (1995); North Central Cable Communications, Inc.,  {O%-10 FCC Rcd 4381, 4383 (1995); and Kansas City Cable Partners, 10 FCC Rcd 3807, 3809 (1995).  # Paxson also argues that InterMedia's conclusion that WTLKTV  S- xldoes not provide local service to the cable communities is incorrect. According to Paxson, since it  xzacquired WTLKTV in July, 1994, the station has been airing a unique program format, developed by"~,`(`(88"  S- xkPaxson, that combines programlength presentations by local and national businesses and community  xorganizations with religious and local public affairs programming. WTLKTV states that its public affairs  xprogram "Daybreak" highlights topics of importance to residents of the cable communities and features  xlocallybased organizations which operate throughout the ADI. In addition, Paxson cites its airing of a  x=Japaneselanguage news program as well as locally produced cultural and information programs focusing  S8- x/on issues of concern to the Muslim community and to Americans of Asian and Pacific Islander, East  xjIndian, and Iranian descent. WTLKTV states that it is committed to both maintaining and expanding its  xlocal programming, and contends that a station's planned local programming is also to be weighed in  S-evaluating market modification petitions.v {O( -ԍPaxson cites Time Warner Cable, 10 FCC Rcd 962, 964 (1995). v  Sp- ` qx16.` ` Paxson also argues that in support of abrogating WTLKTV's must carry rights,  xInterMedia claims that it carries other stations that offer programming of interest to the communities; yet,  xjaccording to Paxson, InterMedia's rationale conflicts with one of the primary purposes of the must carry  xrules to enhance the diversity of programming and programming sources accessible to the public.  xPaxson also argues that if WTLKTV's carriage rights are eliminated, WTLKTV's ability to compete with other Atlanta ADI stations will be undermined.  S -  SX- ` x17.` ` Finally, with respect to viewing patterns in the cable communities, Paxson contends that  xthe Commission has previously found that specialty stations such as WTLKTV offer desirable  S- xprogramming diversity yet frequently attract limited audiences.Z {O- xKԍPaxson cites Nationwide Communications, Inc., 10 FCC Rcd at 13053 (1995) and Home Shopping Station  {O-Issues, 8 FCC Rcd at 5327 (1993), Moreover, Paxson argues that evidence  xregarding viewership "must be considered in light of the existing lack of carriage and the heavily cabled  S- xjnature" of the communities at issue. {O- xԍPaxson cites Complaint of Maranatha Broadcasting Company, Inc. against Garden State Cable TV, DA 97 {O-1167, CSR4882M,  22 (1997).   According to Paxson, Clarke County, the county in which Athens  S- x.and some of the cable communities are located, has a cable penetration rate of 89 percent, while Oconee  Sh- xCounty has a cable penetration rate of 80 percent.|h {O-ԍPaxson cites Nielsen Station Index, Viewers in Profile, October, 1997, at 1. | Paxson argues that the Commission has previously  xdetermined that if over 75 percent of potential viewers in the cable communities are cable subscribers,  x0overtheair ratings are considered to be of little relevance and should be discounted in the market  S- x[modification process.  {O4 -ԍPaxson cites The Chronicle Publishing Company, 10 FCC Rcd 9474, 948182 (1995). ć Thus, Paxson argues that WTLKTV's overtheair ratings in this case should be discounted.  Sx- ` x18.` ` In reply, InterMedia argues that Paxson fails to rebut InterMedia's showing that the  xcommunities in question are not truly part of WTLKTV's market. According to InterMedia, while  x]Paxson offers its own general interpretation of the Commission's must carry rules, Paxson fails to  xdemonstrate how the statutory fourpart test for market modification does not support InterMedia's request.  xInterMedia contends that while Paxson attempts to obfuscate the issue of historic carriage, the fact remains  S- xythat WTLKTV has never been carried on InterMedia's cable systems. InterMedia argues that while lack"6 ,`(`(88-"  xof carriage by itself may not be a controlling factor, it should weigh heavily in favor of deleting the  xcommunities at issue in this case, especially in light of the fact that Paxson fails to adequately rebut the  xother market modification criteria. Regarding local coverage, InterMedia argues that Paxson offers little  x[to show that WTLKTV's programming is "specifically tailored" to he communities at issue. In addition,  xyInterMedia argues that while Paxson claims that its programming is different from that aired on WNGM xTV, both stations appear to air an overlapping lineup of infomercials emanating from the same "entity" Paxson.  S- ` `x19.` ` With regard to carriage of other local stations, InterMedia argues that Paxson discounts  xthe fact that other stations licensed in the Atlanta area and carried by InterMedia's cable systems provide  xextensive local coverage. InterMedia also argues that, unlike WTLKTV, all of the commercial stations  xthat it carries that are licensed to Atlanta place at least a Grade B contour over the communities.  xInterMedia also reiterates its arguments regarding the lack of viewership of WTLKTV. InterMedia argues  xthat the suggestion that a station which offers primarily infomercials and some religious and foreign  xlanguage programming should get automatic carriage, even where it has no offair viewership, is unfounded.  SX-W ANALYSIS AND DECISION ă  S- ` x20.` ` We turn first to InterMedia's market modification petition, to determine whether Athens,  xjGeorgia and the surrounding communities served by InterMedia's cable systems should be removed from  xMWTLKTV's ADI. A resolution of this matter will determine whether WTLKTV is eligible to claim  x=carriage rights in these communities. Based on our analysis of the evidence relating to the four statutory and other relevant factors, InterMedia's petition will be granted.  S- ` x21.` ` Atlanta is the nation's tenth largest market in terms of population. It is approximately 170  xNmiles long and 150 miles wide, encompassing 52 counties in three states. Rome is 56 miles to the  xnorthwest of Atlanta. WTLKTV, licensed to Rome, Georgia, began operation in 1988 and broadcasts  xMon channel 14 from a transmitter close to Waleska, Georgia. Athens and the other cable communities  x\involved are located approximately 93 miles southeast of Rome and approximately 80 miles from the  xWTLKTV transmitter site. Rome is also more than 107 miles from InterMedia's headend sites in Athens  xand Oconee County. In addition to the Rome and Atlanta stations, the market is also served by WNGM S-TV, channel 34, Athens, Georgia, which InterMedia alleges duplicates the signal of WTLKTV.  S-x A. Historic Signal Carriage  S-  S`- ` x22.` ` Statutory factor one is "whether the station, or other stations located in the same area, have  xbeen historically carried on the cable system or systems within such community." WTLKTV has no  S - xhistory of carriage in the communities in question. WTLKTV began operation 10 years ago,M!  {Ox"-ԍSee supra  11 and note 20.M so this  xcarriage pattern is not a reflection of the recent origin of the station. Also, it appears that WTLKTV is  xnot carried on any of the cable systems serving communities located near the communities at issue here. InterMedia's cable systems also do not carry any other stations licensed to the Rome area.  SH$- ` x23.` ` Carriage on nearby cable systems is not a factor specified in the statute, but it does seem  S %- xlikely, depending on the specific circumstances involved, that carriage on nearby systems could serve as" % Z!,`(`(88&"  S- xjevidence to define the logical scope of a station's market.l" {Oh-ԍFouce Amusement Enterprises, Inc., 10 FCC Rcd 668, 671 (1995).l Such carriage serves to demonstrate the belief  x[of both the stations and systems involved that there is a market nexus between the broadcast station and  xMthe communities where the station is carried and thus provides evidence as to the scope of a station's market.  S8- B. Station Coverage of Communities  S-  Q24.` ` Statutory factor two is "whether the television station provides coverage or other local  S-  service to such community." With respect to coverage, the Commission stated in its Report and Order  S-  in MM Docket 92259, supra, that "to show that the station provides coverage or other local service to   the cable communities, parties may demonstrate that the station places at least a Grade B coverage contour  SL -  over the cable community or is located close to the community in terms of mileage."?#L Z yOF -ԍ8 FCC Rcd at 29762977.? InterMedia   =provides evidence that WTLKTV's Grade B contour falls short of the communities in question. In two  S -  previous Commission cases, Monroe and Covington,@$  {O-ԍSee supra note 14.@ the Commission issued orders modifying the   television market of WTLKTV in order to exclude communities that were located somewhat closer to  S -Rome, and were also located outside of WTLKTV's Grade B contour.%$ | {O- xԍIn Monroe, the cable communities involved were in Walton County, which is located to the southeast of  {O- x-Atlanta, some 94 miles from Rome and 65 miles from the WTLKTV transmitter site. In Covington, the cable  xicommunities involved were in Newton County, which is located to the southeast of Atlanta, some 86 miles from Rome and 67 miles from the WTLKTV transmitter site.   S^-  R25.` ` With respect to programming service, InterMedia alleges that there is no significant   Lamount of programming from WTLKTV that is specifically targeted to the cable communities involved.   Although Paxson contends that it has been airing a unique program format since 1994 that combines   infomercials with religious and local public affairs programming, that material does not appear to be 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.  SF-  C. Coverage of News, Sporting Events, or Other Events of Interest by Other Stations  S-Entitled to Carriage.  S-  }26.` ` Statutory factor three is "whether any other television station that is eligible to be carried  S-  zby a cable system in such community in fulfillment of the requirements of this section provides news  S~-  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, InterMedia alleges that its cable systems carry numerous stations licensed in and around Atlanta that provide local service to its subscribers.  S-  27.` ` Carriage of other local stations may be used as an enhancement factor to support a cable   operator's deletion request when there is other evidence in the record that the communities at issue are   outside of the station's market. While InterMedia suggests that WTLKTV's programming is not specific" h %,`(`(88"   yto the cable communities, it cites to equally nonspecific programming, such as local newscasts broadcast  S-  by local network affiliates, as evidence of the other stations' local service. InterMedia also notes that it   =carries several cable channels that it says feature community focused programming, yet InterMedia does not cite to any specific kind of programming carried by those channels.  S8- D. Station Audience in Communities Served by Cable System  S-   28.` ` 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." InterMedia states that   jWTLKTV has no ratings at all in either cable or noncable households in either Clarke or Oconee County   where the communities are located. This is confirmed by the most recent Nielsen viewership data, which  SH -records no viewing of WTLKTV in those counties.w&H  {O -ԍSee Nielsen County/Coverage Study 1997 (AlabamaIndiana Volume 1 of 4). w  S - E. Other Considerations  S -   29.` ` The factors specified in Section 614(h)(1)(C)(ii) of the Communications ActH' Z yO-ԍ47 U.S.C.  534(h)(1)(C)(ii).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  S0-  is the Commission's consideration of the scope of the AtlantaRome, Georgia market in the context of a  S-  jmarket hyphenation rulemaking proceeding.( {O-  ԍSee 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.   Market hyphenation proceedings, undertaken pursuant to  S-  Section 614(f) of the Communications Act,>)F yO-ԍ47 U.S.C.  534(f).> and ADI market modification proceedings, undertaken  S-  pursuant to Section 614(h)(1)(C)(ii) of the Act,H* yO.-ԍ47 U.S.C.  534(h)(1)(C)(ii).H although not identical in purpose nevertheless involve   some overlap of objectives and decisional criteria and the Commission's decision to join markets takes   yinto consideration the economic ties between the communities to be hyphenated and the subject stations.   The hyphenation of Atlanta and Rome reflects a 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 to significant  S-  overlapping portions of the same market area.d+f  {O!-ԍSee, e.g. Time Warner Cable, 11 FCC Rcd at 494. d However, the hyphenation is not controlling in 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 those   relating to `area of dominant influence' changes, to be addressed from the perspective of a properly  S(-  Ldefined market area."u,(  {O&-ԍReport and Order in MM Docket No. 93304, 10 FCC Rcd 9298, 9299 (1995).u Here, the issue is not whether stations in Rome and Atlanta are competitive, but"( ,,`(`(88"   whether the Rome station's market properly includes communities on the opposite side of Atlanta. Thus,   Kfor present purposes, the hyphenation decision appears to add little to the Section 614(h)(1)(C)(ii) decision  S-  making process.H- yO-ԍ47 U.S.C.  534(h)(1)(C)(ii).H Indeed the fact that Athens is not hyphenated with Rome (nor with Atlanta) would suggest that the market hyphenation argument weighs in favor rather than against the requested relief.  S8- F. Summary  S-  #30.` ` 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  Sp-  0market."Z.pX yOh -ԍH.R. Rep. 102628, 102d Cong., 2d Sess. 97 (1992).Z 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-ԍ47 U.S.C.  534(h).> In acting on such requests, the Commission was   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."Z0 x yO-ԍH.R. Rep. 102628, 102d Cong., 2d Sess. 97 (1992).Z The market   Lmodification provisions of Section 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  SX-  \station that it cannot be deemed part of the station's market."11X {O-ԍId.1 Based on the evidence presented, we   conclude that the requested exclusion of the subject cable communities from the market of WTLKTV will better effectuate the purposes of the must carry statutory provisions.  S-  31.` ` In reaching this conclusion, we have considered the statutory factors as well as other   relevant information. WTLKTV has never been carried in any of the communities in question (factor   I), provides no overtheair television broadcast service for the communities (factor II), and has no  S@-  measured audience in the communities.2@ {Oz-  ԍWe note that in the Monroe case cited previously, see supra note 14, WTLKTV was excluded from the   LGeorgia communities involved despite providing overtheair television broadcast service to a portion of the  {O -  communities and having some small measurable viewing audience. See Monroe  30. Also, in Covington, supra  yO -  note 14, WTLKTV was excluded from the market even though it provide overtheair television service to a portion   Jof the communities involved. In the instant case, WTLKTV is not carried overtheair to any of the communities in question and has no measured viewing audience.  Given the statutory directive, weight must be given to these   factors, but that must be done bearing in mind that the objective of the Section 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. Given the  SP-age of WTLKTV, however, that does not appear to be the circumstance here. "P 2,`(`(88"Ԍ S-  ԙ32.` ` 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-  Lalso on factors that are less influenced by the type of station involved or historical carriage.j3 {O-ԍSee Cablevision Systems Corp., 11 FCC Rcd 6453, 6474 (1996).j 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   znatural markets basic geographic, demographic, and political features that provide the best available   jevidence of the market boundaries of the stations involved. In this regard, the Commission has explicitly  S-  .noted the relevance of Grade B contours.r4Z yO -  ԍAs a general matter, Grade B coverage demonstrates service to cable communities and serves as a measure of  {OZ -  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, Melbourne, and Cocoa, Florida), 102 FCC 2d 1062, 1070 (1984) ("We believe   that television stations actually do or logically can rely on the area within their Grade B contours for economic  {O-support.").  r In the absence of other information, station service contours   provide at least one objective measure of the scope of a station's local market. Here we note that WTLK  TV does not provide Grade B service to any of the communities at issue. In addition, the communities   yare on the opposite side of the Atlanta urban area from WTLKTV and geographically separated from its city of license by 93 miles.  S -  333.` ` We have carefully considered each statutory and other relevant factor in the context of  S -  the circumstances presented here and, on balance, 5  {O0-  ԍWe are under no obligation to give particular weight to any one of the several factors. See Time Warner  {O-  ;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   Kexpress and considered conclusion about the bearing of a factor, but is not required to give any specific weight to   Kit."). Given the conclusions reached above we do not find it necessary to address InterMedia's argument that the Commission's signal duplication rule applies in this case.  we find that InterMedia has demonstrated that the   communities it serves lack a sufficient nexus with WTLKTV so as to warrant deletion of these communities from the station's ADI.  S-  34.` ` Turning to Paxson's signal carriage complaint, having found that grant of InterMedia's   mpetition for market modification is warranted, that complaint is now moot. Section 614 of the   Communications Act and the Commission's rules permit stations to assert mandatory carriage rights on   cable systems located within their market. The prerequisite for asserting must carry rights with respect   to a particular cable system, however, is that the operator serve communities in the station's ADI. These  S-  >communities have been deleted from WTLKTV's market by this Memorandum 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." 5,`(`(88"Ԍ S-8ř1' ORDERING CLAUSES ă  S-  35.` ` Accordingly, IT IS ORDERED , that the petition for special relief (CSR5131A) filed  S-  by Brenmor Cable Partners, L.P., d/b/a InterMedia IS GRANTED . Athens, Clarke County, Oconee   Co8unty, Winterville, Bogart, and Watkinsville, Georgia served by InterMedia's cable systems are no longer part of WTLKTV's market area for purposes of Section 614.  S-  36.` ` IT IS FURTHER ORDERED , that the Request for Mandatory Carriage Complaint (CSR S-  5129M) filed by Paxson Atlanta License, Inc. IS DISMISSED in accordance with Section 614(d)(3) of the Communications Act of 1934, as amended (47 U.S.C. 534) and 47 C.F.R. 76.56(b) ).  SH -  _37.` ` This action is taken pursuant to authority delegated by Section 0.321 of the Commission's Rules.   ` `  hh,VFEDERAL COMMUNICATIONS COMMISSION ` `  hh,VWilliam H. Johnson ` `  hh,VDeputy Chief, Cable Services Bureau