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Style 6Dutch Roman 14 Point$$N w [ PfQ   )a [ PfQO Style 10oInitial Codes for Advanced U )a [ PfQK  dddn  ##  [[ b, oT9 !b, oT9 !n )^ `> XifQ ` Advanced Legal WordPerfect Learning Guide   f )^ `> XifQ Advanced Legal WordPerfect Learning Guide   Q" )^ `> XifQ    Copyright  Portola Sys HeadlinenHeading for internal papersql + WITNESS.STYIN WITNESS WHEREOF*Cqw  ` IN WITNESS WHEREOF,2N K  K< K1H-ART.STYARTICLES IAD?qw )ARTICLE Iă  ` "i~'^09FSS999Sq+9+/SSSSSSSSSS99qqqSggnxggxx9In]nxgxgS]xgg]]?/?FS9SSISI/SS//I/xSSSS??/SInII?C/CZ9+ZF999+999999S9S/gSgSgSgSgSnnIgIgIgIgI9/9/9/9/nSxSxSxSxSxSxSxSxS]IgSxSxSxS]IxSgSgSgSgSnInInZnIxdgIgIgIgIxSxSxSxZxSxZxS9/9S999SSZZnI]/]<]9]5]/nSanSnSxSxSng?g?g?S?S?S?ZZ]<]/]FxSxSxSxSxSxSn]Z]?]?]?xS]9nSS?]9]Sd+SS8%8WuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuddddddddddddddddddddddddddddddddddddddddN%7777777777>>>0eOIIOD>OO%*ODaOO>OI>DOOgOOD%%37%07070%777V7777%*77O77055;%;3%%%%%%%%%7%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&&Bn77lBTn(nBB(AZZ>>n%07\n!"IIIITTenn7TnB@;7>lBBn7"i~'^5>I\\>>>\g0>03\\\\\\\\\\33gggQyyrg>Frgygrr>3>T\>Q\Q\Q>\\33\3\\\\>F3\\\\QX%Xc>0cT>>>0>>>>>>\>\3QQQQQwyQrQrQrQrQ>3>3>3>3\\\\\\\\\\Q\Z\\\g\QQQyQyQycyQtrQrQrQrQ\\\c\c\>3>\>>>\gcc\r3rIr>r>r3\l\\\\y>y>y>gFgFgFgcrMr3rT\\\\\\crQrQrQ\r>\gFr>\t0\\=!=WxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNBnnBT\>Q\\\\\3;\7;\7>>QQ\??n\\nBnnBmgg>Q\7"yyyy\njc\gnn\2 K KO`FZ"i~'^5>g\\>>>\g0>03\\\\\\\\\\>>ggg\yyrF\yrgyy>3>j\>\gQgQ>\g3>g3g\ggQF>g\\\QI(I_>0_j>>>0>>>>>>\>g3\\\\\QyQyQyQyQD3D3D3D3g\\\\gggg\\g\\\\pg\\\QQ_QyQyQyQyQ\\\_\gjF3FgF>Fgg__gy3ySy>yIy3ggg\\QQQgFgFgFg_y^y>yjgggggg_yQyQyQgy>ggFy>\0\\=2=WxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNBnnBa\>\\\\\\7>\7>\7>>\\\??n\\nBnnBsgg>\\7"yyyy\nlc\gnn\"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\\nBnnBb\\>g\7"yyyy\njc\}nn\<?xxx,x6X@`7X@y.X80,ɒX\  P6G;Py.\80,>\4  pG;7jC:,ynXj\  P6G;XP7nC:,7O0O0O0I0I0I;I0OED0D0D0D0O7O7O7O;O2, S- X   Oө S-#X\  P6G;ɒP#  #&a\  P6G; u&P#Federal Communications Commission`(#uDA 98779 ă  yxdddy O#n6X@`7 &@#VՊ# Xj\  P6G;ynXP##&a\  P6G; u&P#Pg Before the Federal Communications Commission  S-">Washington, D.C. 20554 ă  S- $PG pp  S`-In re Petition of hhCq) ` `  hhCq)  S- Paxson Phoenix License, Inc. hhCq) ` `  hhCq)  S-For Modification of Television Market of q)ppCSR 5188A  S-Station KWBF(TV), Flagstaff, Arizonaq) ` `  hhCq  S -   MEMORANDUM OPINION AND ORDER \  S -X` hp x (#%'0*,.8135@8:carriage in those communities. However, this right is subject to several conditions: 1) a cable system  d(#operator is generally required to devote no more than onethird of the system's activated channel capacity" |,p(p(88!"  S- d(#.to compliance with the mandatory signal carriage obligations,u {Oh-#X\  P6G;ɒP#эSee 47 U.S.C.  534(b)(1)(B).u 2) the station is responsible for delivering  S- d(#.a good quality signal to the principal headend of the system,z Z {O-#X\  P6G;ɒP#эSee 47 U.S.C.  534(h)(1)(B)(iii).z and 3) the system operator is not required  d(#jto carry the signal of any station whose signal substantially duplicates the signal of any other local signal  S- d(#carried, or the signals of more than one local station affiliated with a particular broadcast network.r  {O-#X\  P6G;ɒP#эSee 47 U.S.C.  534(b)(5).r If,  d(#pursuant to these requirements, a system operator elects to carry only one such duplicating signal, the  d(#\operator is obliged to carry the station from the ADI whose city of license is closest to the principal  S- d(#Lheadend of the cable system.a ~ yO. -#X\  P6G;ɒP#э8 FCC Rcd at 2981.a Accordingly, depending upon the circumstances involved, the addition of  S- d(#.communities to a station's market may have the following consequences. It may guarantee that station's  d(#carriage in the subject communities. Should there be more mustcarry stations than onethird of the  d(#ksystem's channel capacity, it would provide the system operator with an expanded list of mustcarry  d(#signals from which to choose. Should the station be a duplicating network station, it will determine which station has priority carriage in the subject communities added.  S -  MARKET FACTS AND ARGUMENT ă  S - 7.` ` Station KWBF is located in the Flagstaff, Arizona ADI. Paxson requests that the  d(#Commission modify the television market of KWBF by adding the Communities listed on Appendix A,  d(#which are located in Yavapai County and Navajo County, Arizona, in the Phoenix ADI, to the station's  d(#market. Paxson contends that KWBF provides local service to these Communities, and argues that the  d(#single county Flagstaff ADI does not reflect the full extent of KWBF's local market, a situation the  d(#Congress anticipated in adopting the market modification provisions of Section 614(h)(1)(C). Paxson  d(#asserts that KWBF is carried on cable systems serving a number of the Communities, covers almost all  d(#of the Communities with a Grade B signal, and provides locally oriented programming specifically  d(#targeted at viewers in the Communities. Paxson asserts further that Nielsen and other objective sources  d(#recognize a nexus between Coconino County, Arizona, the station's home county, and Navajo and Yavapai  d(#Counties, which together comprise an economically coherent "northern tier" of the Phoenix market that is distinguishable from the more densely populated urban portions of that market.  S- P8.` ` Paxson addresses the first statutory market modification factor by stating that KWBF has  d(#a history of carriage on the cable systems in Camp Verde, Cottonwood, Dewey/Humbolt, Keams Canyon,  d(#Lake Montezuma, Mayer, Sedona, Yavapai County, Oak Creek Village, and Verde Village, making KWBF  d(#available to 8,342 cable subscribers in Yavapai and Navajo Counties. Paxson contends that carriage in  d(#ythese communities supports inclusion of all of the Communities on Appendix A within KWBF's market,  d(#arguing that such wide spread carriage demonstrates that the cable operators in both counties consider  S- d(#KWBF to be a local station, citing Comcast of Central New Jersey, DA 971191 (Cable Serv. Bur.,  d(#released June 5, 1997). Paxson notes that Station KNAZTV, also licensed to Flagstaff, Arizona, is  d(#carried on many of the subject cable systems and argues that carriage of that station from the same  d(#community as KWBF establishes a nexus between the two stations' community of license and the cable  S -communities, citing TWI Cable, Inc., 12 FCC Rcd 13187 (CSB 1997)."  ,p(p(88!"Ԍ S-  2ԙ9.` ` With respect to the second statutory factor, Paxson states that all of the Communities are  S- d(#within or just beyond the fringes of KWBF's Grade B signal contour.c  yO@-#X\  P6G;ɒP#эPetition, Exhibit 2.c Paxson also states that the average  S- d(#ymean distance from the station to the subject Communities is only 47.8 miles.c X yO-#X\  P6G;ɒP#эPetition, Exhibit 1.c Paxson claims these two  d(#factors establish the station's local coverage of, and geographic proximity to, the relevant Communities  d(#zunder standards approved in other market modification decisions. Paxson also provides synopses of  d(#=topics covered in certain episodes of two of KWBF's half hour weekly programs "Community Coffee  d(#jBreak" and "Navajo Nation Update" as evidence that KWBF carries programming directed specifically  d(#^to the Communities and to the Native American population making up large portions of those  d(#Communities. Paxson asserts that Station KUSK, licensed to Prescott and the only station licensed to any  d(#of the Communities at issue, does not provide coverage of Native American issues and events as  d(#extensively as KWBF. Paxson also contends that KUSK does not provide Grade B coverage of Navajo  d(#County, and for that reason KUSK's limited amount of local programming cannot be deemed to address  d(#issues of local interest to Navajo county. Paxson argues that the failure of KUSK and other stations to  d(#Lprovide local service to the Communities may be considered an enhancement criterion in market addition  S - d(#cases.  {OX-#X\  P6G;ɒP#эCiting Smith Television of New York, Inc., 11 FCC Rcd 6025, 6032(CSB 1996). Paxson argues further that any local coverage provided by other stations should not be weighed against the market modification request, but would only render this factor inapplicable.  SX- 10.` ` Finally, Paxson argues that other factors weigh in favor of inclusion of the Communities  d(#in KWBF's market. First, Paxson notes that Nielsen Media Research includes both KWBF and the  d(#Communities in the Phoenix DMA. Paxson argues that although the Commission has retained for now  d(#yuse of Arbitron's ADIs as the presumed definitions of television markets, it has recognized that Nielsen's  d(#DMAs represent a more accurate current measure of television markets and indicated that Nielsen market  S- d(#=information may be considered when weighing a market modification request.z {O-#X\  P6G;ɒP#эCiting Market Determinations, 11 FCC Rcd at 6620. Paxson contends further  d(# that the ties between the station's home county and the Communities are reinforced by demographic  d(#similarities shared among them, including census figures, Native American populations, population densities, and per capita incomes.  S- 11.` ` Cable One, who operates cable systems serving sixteen of the Communities at issue,  d(#zcontends Paxson failed to establish that the statutory factors considered in connection with television  d(#.station market modification requests have been satisfied with respect to the Communities, and therefore  d(#failed to meet its burden of showing that the requested market modifications should be made. First, Cable  d(#One contends Paxson presented its case on a countywide basis rather than a communityspecific basis,  d(#=and asserts that the Commission has declined to make use of such countywide information in analyzing  d(#Mmarket modification petitions. In this connection Cable One points to Paxson's claim that carriage of  d(#KWBF on cable systems in some of the communities demonstrates that cable systems throughout both  d(#Yavapai and Navajo Counties consider KWBF to be a local station. It also points to Paxson's reliance  d(#on the average distance of the Communities from KWBF to establish proximity of the station to the  d(#Communities and to the emphasis Paxson places on the countywide focus of the weekly "Community"8 ,p(p(88 "  d(#Coffee Break" and "Navajo Nation Update" programs. Cable One notes that Section 614(h)(1)(C) focuses on "communities" in the listing of market adjustment factors that must be considered, and not on counties.  S-  12.` ` Next, Cable One attacks Paxson's claim that KWBF is local to the Communities first by  d(#stating that KWBF is not carried in the sixteen communities served by its cable systems and has no history  d(#kof carriage in those communities. Cable One argues this history of lack of carriage means that KWBF  d(#cannot satisfy this crucial factor with respect to communities served by Cable One. Cable One asserts that  d(#carriage of KWBF in some of the other communities began after enactment of the must carry provisions  d(#in 1992 and argues that such carriage history should not be given significant weight in the market  d(#modification process. Cable One further asserts that commencement of carriage would be disruptive to  d(#subscribers on its cable systems, because other programming would have to be displaced for carriage of  d(#KWBF. Cable One also discounts the significance of the carriage of KNAZ, Flagstaff, on the grounds  d(#that cable subscribers desire carriage of KNAZ as an alternative source of NBC Network programming  d(#/when the Phoenix NBC affiliate's signal is disrupted due to rain, fade, and other natural and technical transmission difficulties.  S -  13.` ` Cable One argues for a reduction of the weight given to KWBF's Grade B coverage of  d(#the Communities by noting that Paxson has claimed in other cases that Grade B coverage alone should  d(#not be considered determinative of the "local" status of a station for market modification purposes. Cable  d(#One also asserts that Holbrook, Arizona, served by one of its cable systems, is located well outside of  d(#yKWBF's Grade B coverage. Pointing out that Paxson's data shows distances from KWBF to some of the  d(#{cable communities ranging between 46 and 76 miles, Cable One argues that Paxson's reliance on an  d(#average distance to show station proximity to the communities is misleading. Cable One contends instead that the actual distances preclude any finding of ties between KWBF and the Communities.  S- 14.` ` Cable One contends that information submitted by Paxson shows that KWBF provides  d(#yonly a minimal amount of programming directed specifically to the Communities. Cable One asserts that  d(#the two weekly shows highlighted by Paxson represent only a very small percentage of KWBF's total  d(#broadcast schedule, and that the balance of KWBF's programming consists of infomercials and religious  d(#programming. Cable One claims an inspection of KWBF's program schedules show them to contain no  d(#listings for any news, sports or community interest programming. Cable One contends further that the  d(#weekly "Navajo Nation Update" program may be considered as local programming only with respect to the Navajo population of the Communities at issue.  S- `15.` ` Cable One contends the sixteen communities served by its cable systems are served by  d(#local television stations, licensed to Phoenix, as well as by KNAZ, licensed to Flagstaff, both through their  d(#/carriage on Cable One's cable systems and through the stations' offair Grade B coverage. Cable One  d(#claims the Phoenix stations' sports news programming and carriage of the Phoenix professional football,  d(#basketball and baseball games represent examples of programming of local interest to the Communities  d(#provided by those stations. Cable One also provided a copy of the television station programming  S!- d(#schedules from The Journal, a Camp Verde, Arizona newspaper, as evidence of the extent of local news  d(#provided by the Phoenix stations. Cable One argues that the coverage of local issues by these other  d(#station preclude giving any weight to KWBF's minimal local programming effort. Cable One also notes  d(#that the Communities are all located in the Phoenix ADI, and emphasizes that ADIs are the measure of local television service adopted by the Congress and the Commission. "%,p(p(88'"Ԍ S- n16.` ` Finally, Cable One points out that Paxson claimed no KWBF viewing in the Communities.  d(#To confirm that KWBF has no viewing, Cable One provided a Media Strategies, Inc. report, which states  S- d(#that "KWBFTV does not have any viewing in these counties."NX yO- d(##X\  P6G;ɒP#эThe Media Strategies, Inc. report purports to analyze KWBF's viewership in both cable and noncable  d(#households in Navajo and Yavapai Counties using Nielsen County Coverage Report for 1997. Opposition, at p. 27 & Exhibit J.N Cable One also provided a copy of the  S- d(#1997 Cable and Station Coverage Atlas to establish that KWBF is not significantly viewed in either  S`- d(#Navajo or Yavapai County.e` yO-#X\  P6G;ɒP#эOpposition, Exhibit K.e Cable One contrasts that with the Phoenix stations, some of which are listed  d(#jas significantly viewed in those counties. Cable One argues that the Commission has rejected claims that  d(#such viewing patterns are irrelevant in market modification cases where an addition of communities is at  S-issue.Nx {O - d(#x#X\  P6G;ɒP#эCiting Time Warner New York City Cable Group, 12 FCC Rcd 13094 (CSB 1996) recon. denied, 12 FCC Rcd  {O -12262 (1997), and KBL Cablesystems of the Southwest, Inc., 11 FCC Rcd 14524 (CSB 1996), at  20.N  S- 17.` ` In reply, Paxson reiterates the points presented in the petition, and contends further that  d(#KWBF's low viewership in communities served by Cable One is not dispositive of the scope of the  d(#station's market. In this regard, Paxson argues that the information provided with respect to other statutory factors amply demonstrates a nexus between KWBF and the Communities at issue.  S -( DISCUSSION AND ANALYSIS ă  S - 418.` ` As noted earlier, Station KWBF is located in the Flagstaff, Arizona, ADI. Paxson,  d(#licensee of KWBF, seeks to include the Communities, located within the Phoenix, Arizona, ADI, in  d(#KWBF's market. Cable One, which operates cable systems within sixteen of those Communities opposes  d(#.this market modification request. We resolve this matter by considering the information of record under  d(#the statutory factors set out in Section 614(h)(1)(C)(ii) and conclude that all of the Communities listed on Attachment A should be included in KWBF's market.  Sh- Historic Carriage of the Station and Other Stations ă  S- Q19.` ` KWBF is currently carried on cable systems serving ten of the Communities at issue.{X yO- d(#Z#X\  P6G;ɒP#эKWBF is carried on cable systems in Camp Verde, Cottonwood, Dewey/Humbolt, Lake Montezuma, Mayer,  d(#KVerde Village, Keams Canyon, Sedona, Yavapai County and Oak Creek, Arizona. The cable operators providing services in these communities have not opposed this petition. {  d(#{We find that such voluntary carriage of KWBF on Arizona Cablecomm's systems in Camp Verde,  d(#Cottonwood, Dewey/Humbolt, Lake Montezuma, Mayer, and Verde Village, on Indevideo Company,  d(#Inc.'s system in Keams Canyon, and on Cablevision of Sedonia's systems in Sedona, Yavapai County,  d(#^Oak Creek, and Verde Village demonstrates an interest in and connection with KWBF in these  SP-communities.P  {O%-#X\  P6G;ɒP#эSee Panhandle Telecasting Co., 12 FCC Rcd 884, 888 (CSB 1997), for example. "( ,p(p(88"Ԍ S-  ~ 20.` ` KWBF has no history of carriage in the other sixteen Communities served by the Cable  S- d(#/One's cable systems.o {O@-#X\  P6G;ɒP#эSee Opposition, Exhibit E.o However, under Section 614(h) we must consider not only whether the cable  d(#system carries the station subject to the modification petition, but also whether "other stations located in  S- d(#kthe same area historically have been carried on the cable system . . . ."|Z {O-#X\  P6G;ɒP#эSee 47 U.S.C.  534(h)(1)(C)(ii)(I).| The record shows carriage of  d(#zKNAZTV, Flagstaff, (also KWBF's community of license), on cable systems serving fourteen of the  S8- d(#[communities at issue served by Cable One's cable systems, which are not carrying KWBF.8 {O -#X\  P6G;ɒP#эSee Petition, p. 5 & N. 10. See also Reply, Revised Exhibit 1. The ability  d(#of the other Flagstaff station to reach cable viewers in communities where KWBF is not carried impacts  d(#on the ability of KWBF to compete with the other Flagstaff station. Such carriage of KNAZTV and the  d(#exclusion of KWBF impacts heavily on the ability of KWBF to reach viewers in the Communities at issue  S- d(#that KNAZTV is able to reach.~ {O-#X\  P6G;ɒP#эSee TWI Cable,Inc., 12 FCC Rcd 13187 (CSB 1997), at  17. We believe such carriage of KNAZTV is indicative of the interest in  d(#[the subject Communities in programming of Flagstaff stations and is evidence of a market nexus between  d(#Flagstaff and the cable communities. For these reasons, the carriage of KNAZTV, Flagstaff in  d(#communities within, near and just beyond KWBF's Grade B coverage adds substantial weight, along with  d(#that given other identified supporting factors, to our determination as to whether to include such  S - d(#communities within KWBF's market. Cable One has not demonstrated why KWBF should be treated  S -differently from KNAZTV.   SX-X Station Coverage and Local Service ă  S- P21. ` ` Paxson has presented evidence which shows that all of Communities except Holbrook and  S- d(#=Keams Canyon are within KWBF's Grade B coverage. yO- d(##X\  P6G;ɒP#эPetition, Exhibit 2. Holbrook and Keams Canyon appear to be at least ten miles beyond KWBF's Grade B signal contour. The Commission recognized in the Must Carry  S- d(#Order that "to show that the station provides coverage or other local service to the cable communities,  d(#{parties may demonstrate that the station places at least a Grade B contour coverage over the cable  Sl- d(#community or is located close to the community in terms of mileage."~lh  {Ot-#X\  P6G;ɒP#эMust Carry Order, 8 FCC Rcd at 2976-2977.~ This factor is particularly relevant  d(# in cases where a party asks that a community be deleted from a station's television market and other  d(#Mevidence on which a decision might be based is lacking. In cases of this type, while not to be used an  d(#=an absolute measure of the scope of a station's market, the existence of Grade B service is relevant under the station coverage and local service factor.  S-  S|- News Coverage and Coverage of Sporting Events of Local Interest  S,- 22.` ` We reject Cable One's contention that any weight given to KWBF's minimal local  d(#programming must be offset by the local programming of the Phoenix stations carried on cable systems  d(#=serving the Communities. In this connection, the record contains no description of the programming of" ,p(p(88["  d(#jthe Phoenix stations, other than that those stations carry sports news and games of Phoenix professional  S- d(# sport teams.c yO@-#X\  P6G;ɒP#эOpposition, p.2527.c Also, the record does not clearly establish that the Phoenix stations provide Grade B  S- d(#coverage of the Communities.^X {O- d(##X\  P6G;ɒP#эExhibit H attached to the Opposition, which consists of pages from the 1997 Edition of Television & Cable  {Or- d(#,Factbook, does not show the location of any of the Communities at issue in relation to the Phoenix stations' Grade  {O<-B signal contours. See also, Reply, Exhibit 2 (1997 Cable Station and Coverage Atlas, Map 9.  Consequently, offair service of the Communities by the Phoenix stations  d(#khas not been firmly established. Local service may be provided by the Phoenix stations through their  d(#carriage on cable systems in the Communities. As noted earlier, KWBF may also be credited with local  d(#yservice to those Communities located within its offair Grade B coverage. In any event, while an absence  d(#of other television station coverage may enhance a station's market inclusion request, other station  d(#coverage when present is inapplicable as a factor and does not weigh against a station seeking to add  S-communities to its market.[~ {O - d(##X\  P6G;ɒP#эSee Smith Television of New York, Inc., 11 FCC Rcd 6025, 6032 (CSB 1996); WTVT License, Inc., 11 FCC  {O-RCD 18020, 18025 (CSB 1996); Evergreen Broadcasting Corp. 11 FCC Rcd 19184, 19190 (CSB 1996).[  Sp- @ Station Viewing in the Communities ă  S -  23.` ` Cable One provided evidence tending to show that KWBF has little or no viewership in  d(#keither Navajo or Yavapai County. Paxson provided no credible evidence to the contrary. The weight  d(#given to KWBF with respect to this factor must be tempered by, and considered along with, any other  S - d(#nexus to the Communities at issue demonstrated on this record.  {O"- d(##X\  P6G;ɒP#эWe are under no obligation to give particular weight to any particular one of the several statutory factors. See  {O- d(#Time Warner Entertainment Co. v. FCC, 56 F.3d 151, 175 (D.C. Cir. 1995); Accord Omnipoint Corp. v. FCC, 78  d(#F.3d 620, 633634 (D.C. Cir. 1996) (When Congress directs an agency to consider certain factors, the agency simply  d(#"must reach an express and considered conclusion about the bearing of a factor, but is not required to give any specific weight to it.") We have indicated that communities  d(#may be added to a station's market even where a station has no measurable viewing audience in the  SX- d(#Ncommunities. See Channel 56 of Orlando, Inc., 12 FCC Rcd 4071 (CSB 1996). KWBF's lack of  d(#audience will be taken into account in determining whether the Communities at issue should be added to  S -the station's market.  ă  S-e SUMMARY ă  SB- #24.` ` Pursuant to the provisions of Section 614(h)(1)(C), we will modify the television market  d(#of KWBF to include the Communities listed on Attachment A as part of the market of Station KWBF,  d(#as well as within the Phoenix, Arizona ADI. The record establishes that KWBF provides Grade B  S- d(#coverage to all of the communities with the exception of Holbrook and Keems Canyon.  yO$-#X\  P6G;ɒP#эAs noted earlier, KWBF is nonetheless carried on Indevideo Company, Inc.'s system in Keems Canyon. This factor in  d(#conjunction with other evidence introduced in support of the requested modification persuades us that the relief requested in this instance should be granted "R ,p(p(88"Ԍ v 25. Carriage of KWBF on cable systems serving ten of these communities, including Keems  d(#Canyon, is also established. Additionally, Station KNAZTV, licensed to Flagstaff, the community of  d(#license of KWBF, is carried in fourteen of these communities, including Holbrook. KWBF's carriage in  d(#communities interspersed among the included Communities, and cable system carriage of another Flagstaff  d(#station in fourteen of these communities, provide strong evidence of an economic nexus between the  d(#[station and the included communities. These factors establish that the purposes of Section 614(h)(1)(C)  d(#would be better effectuated by including these communities in KWBF's market. Carriage of KWBF on  d(#cable systems in all communities within the station's Grade B coverage and in communities in which  d(#another Flagstaff station is carried will ensure that the station is carried in communities that form its  d(#economic market as well as enable KWBF to reach the same viewers that the other Flagstaff station is able to reach.  S - 26.` ` As Paxson points out, the Commission has concluded that Nielsen Media Research's DMA  d(#market assignments provide the most accurate method for determining areas served by local television  S - d(#stations.  {O8-#X\  P6G;ɒP#эSee Market Modifications, 11 FCC Rcd at 6620. Although the Commission retained the use of Arbitron's ADI as the definition of television  d(#station markets because of concerns about transition issues relating to use of DMAs, Nielsen's placement  d(#jof both KWBF and the Communities at issue in the Phoenix DMA serves to confirm our conclusion that  SX-the included communities should be considered part of KWBF's market.!XZ {OR-#X\  P6G;ɒP#эSee Panhandle Telecasting Co., 12 FCC Rcd 884 (CSB 1997), at  11, for example.  S-  27.` ` We reject Cable One's argument that any carriage of KWBF as a result of this market  d(#modification would be disruptive to subscribers through displacement of other programming. The  d(#statutory must carry provisions create a clear statutory right of carriage that applies notwithstanding prior  d(#arrangements of cable operators. The Commission has indicated that inconvenience, marketing problems,  d(#or the need to reconfigure the basic tier are not sufficient reasons for denying a channel positioning  S@- d(#Nrequest for a must carry signal.x"@ {O-#X\  P6G;ɒP#эSee Must Carry Order at  8991.x We reject also Cable One's argument that the petition should be  d(#dismissed because Paxson presented its case on a countywide basis. As our discussion above shows, we  d(#have been able to relate the information provided on this record to the Communities at issue in our  d(#consideration of the statutory factors applicable to this market modification case. Finally, because the  d(#zfacts and circumstances of each market modification case differ, it is immaterial that Paxson may have argued that Grade B coverage was not determinative of local service in another case.  S(-  28.` ` Based on a totality of the statutory factors, including carriage of the station in many  d(#communities within its grade B coverage area, Nielsen's placement of the station in the Phoenix DMA,  d(#carriage of another Flagstaff station in fourteen of the communities, and limited local programming, we conclude that the Communities listed on Appendix A should be added to KWBF's market.  $PG " ~",p(p(88"  S-1C ORDERING CLAUSES ă  S- 429.` ` For the foregoing reasons, IT IS ORDERED, pursuant to Section 614(h) of the  d(#Communications Act of 1934, as amended, 47 U.S.C. 534(h), and Section 76.59 of the Commission's  S`- d(#Rules, 47 C.F.R. 76.59, that the petition for special relief filed on beha lf of Paxson Phoenix License, Inc.  S8- d(#>in File No. CSR5188A IS GRANTED , and the television market of television station KWBF IS  S- d(#zMODIFIED to include the Arizona communities of Cottonwood (AZ0003, AZ0204 and AZ0124),  d(#[Clarkdale (AZ0029 and AZ0123), Holbrook (AZ0004), Navajo County (AZ0121 and AZ0122), Joseph  d(#KCity (AZ0217), Prescott (AZ0014), Prescott Valley, (AZ0145), Chino Valley (AZ0306), PrescottYavapai  d(#ZIndian Tribe (AZ0352), Yavapai County (AZ0146 and AZ0108), Winslow (AZ0009), Cornville (AZ0284),  d(#<Page Springs (AZ0285), Camp Verde (AZ0166), Dewey/Humbolt (AZ0185), Lake Montezuma (AZ0186),  d(#Mayer (AZ0184), Verde Village (AZ0167), Keams Canyon (AZ0058), Sedona (AZ0336), and Oak Creek Village (AZ0174).  v 30. This action is taken pursuant to authority delegated by 0.321 of the Commission's Rules, 47 C.F.R. 0.321. ` ` hhCFEDERAL COMMUNICATIONS COMMISSION ` `  hhCWilliam H. Johnson  S-` ` hhCDeputy Chief, Cable Services Bureau " ",p(p(88u"  S-` APPENDIX A Communities Affected by Petition  S-HFile No. CSR 5188A ă  X`-# Xj\  P6G;ynXP#  XI-Name of CommunityhhC Cuid No. pp Cable System Operatorq#I {O-#X\  P6G;ɒP#эSee Paxson Reply, Exhibit 1.q (All Arizona)  X-Cottonwood` `  hhCAZ0003ppCable One, Inc.  X-Clarkdale` `  hhCAZ0029ppCable One, Inc.  X-Clarkdale (uninc.) hhCAZ0123ppCable One, Inc.  X -Cottonwood (uninc.) hhCAZ0124ppCable One, Inc.  X -Holbrook` `  hhCAZ0004ppCable One, Inc.  X -Navajo County hhCAZ0121ppCable One, Inc.  Xz -Joseph City` `  hhCAZ0217ppCable One, Inc.  Xc -Prescott` `  hhCAZ0014ppCable One, Inc.  XL-Prescott Valley hhCAZ0145ppCable One, Inc.  X5-Chino Valley` `  hhCAZ0306ppCable One, Inc.  X-PrescottYavapai Indian TribehhCAZ0352ppCable One, Inc.  X-Yavapai County hhCAZ0146ppCable One, Inc.  X-Winslow` `  hhCAZ0009ppCable One, Inc.  X-Navajo County hhCAZ0122ppCable One, Inc.  X-Cornville` `  hhCAZ0284ppCable One, Inc.  X-Page Springs` `  hhCAZ0285ppCable One, Inc.  X}-Camp Verde` `  hhCAZ0166ppArizona CableComm  Xf-Cottonwood` `  hhCAZ0204ppArizona CableComm  XO-Dewey/Humbolt hhCAZ0185ppArizona CableComm  X8-Lake Montezuma hhCAZ0186ppArizona CableComm  X!-Mayer` `  hhCAZ0184ppArizona CableComm  X -Verde Village hhCAZ0167ppArizona CableComm  X-Keams Canyon hhCAZ0058ppIndevideo Company, Inc.  X-Sedona` `  hhCAZ0336ppCablevision of Sedona  X-Yavapai County hhCAZ0108ppCablevision of Sedona  X -Oak Creek Village hhCAZ0174ppCablevision of Sedona