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PDBM_WPshadowboxWPDPDBM_WPgroupboxWPApp2N@A@?E@HZK"5@^.=f\\3==\i.=.3\\\\\\\\\\==iii\zzpG\zpfzz=3=k\=\fRfR=\f3=f3f\ffRG=f\\\RH(H`.====IK=\f\\\\\RzRzRzRzRG3G3G3G3f\\\\ffff\\f\\\\pf\\\RRRzRzRzR\\\\ffIfGfG=Gf\fz3zKff\RRfGfGN@.c\=\\\\\\7<\7\7==\\\==\\=\=7t=ddddido.Iii3[\\xdCpi_w[dfdmoPpP~j_d~~tqo.=f\\3==\i.=.3\\\\\\\\\\==iii\zzpG\zpfzz=3=k\=\fRfR=\f3=f3f\ffRG=f\\\RH(H`=\\\\=f===\\@\=G=.=\\\\(\=7\i=\Id77=ic.=7<\\zzzzGGGGipf\\\\\\RRRRR3333\f\\\\\d\ffff\f"5@^2BRdd$BBdq2B28dddddddddd88qqqYzoBNzoozzB8B^dBYdYdYBdd88d8ddddBN8ddddY`(`l2BB!BBPRBddYYYYYYzYzYzYzYB8B8B8B8ddddddddddYdddddoddYYYYYzYzYzYddddddPdBdBBBdNdz8zRdddBRoNoNNF2ZdBYddddd7>d<d<BBYYdBBddBYBdYzzzzBBBBqodYYYYYYYYYYY8888dddddddnddddddd"5@^%-77\V%%7>%7777777777>>>1eOIIOC=OO%+OCbOO=OI=COOhOOC%%47%17171%777V7777%+77O77155<%%%%,-%77O1O1O1O1O1bII1C1C1C1C1%%%%O7O7O7O7O7O7O7O7O7O7O1O7O7O7O7O7=7O7O1O1I1I1I1C1C1C1O7O7OO7O7O7O7,7%7%%%7+O7CC-O7O7O7bOI%I-=+=+N&27%177777"SS7!TT7S!%%117n%%77ln%1n%!t%<<<<>l[O6Wls[77TTTH_%7777777777>>>1eOIIOC=OO%+OCbOO=OI=COOhOOC%%47%17171%777V7777%+77O77155%T7,OOOOOO=7111111I111117777777<7777777ny.C8*,gC\  P6QPo2J=.,/&J\  P6Q&P.p2N=.,&N4  pQ&q7PC2,W XP\  P6QXPrP,%,J,\  P6QJPsI(!,,(\  P6Q,P0J=.,3V^&J*f9 xQ&X2 X@KN@@Q@T"5@^!)22SN!!28!2222222222888-\HCCH=7HH!'H=YHH7HC7=HH^HH=!!/2!-2-2-!222N2222!'22H22-006!!!!()!22H-H-H-H-H-YCC-=-=-=-=-!!!!H2H2H2H2H2H2H2H2H2H2H-H2H2H2H2H272H2H-H-C-C-C-=-=-=-H2H2HH2H2H2H2(2!2!!!2'H2==)H2H2H2YHC!C)7'7'N#-2!-22222KK2LL2K!!--2d!!22bd!-d!t!77778c7States is allocated to a market based on which homemarket stations receive a preponderance of total  x>viewing hours in the County. For purposes of this calculation, both overtheair and cable television  S-viewing are included."[ yO - xKԍCertain counties are divided into more than one sampling unit because of the topography involved. 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. Refer to Arbitron's Description of Methodology handbook for a more complete description of how counties are allocated.  S8- ` ~x3.` ` 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:  ~Xxwith 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:  BXxthe Commission shall afford particular attention to the value of localism by taking into account such factors as   Xx(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;   Xx(II) whether the television station provides coverage or other local service to such community;   `Xx(III) whether any other television station that is eligible to be carried by a cable system  Cin 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   pXx(IV) evidence of viewing patterns in cable and noncable households within the areas served by the cable system or systems in such community.  "P ,`(`(88m"Ԍ S-x`4.` ` The legislative history of this provision indicates that:  Xxwhere the presumption in favor of ADI carriage would result in cable subscribers losing  Baccess 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  pfrom a television station's market consistent with Congress' objective to ensure that  #television stations be carried in the areas which they serve and which form their economic market.  * * * * *  Xx[This subsection] establishes certain criteria which the Commission shall consider in  acting on requests to modify the geographic area in which stations have signal carriage  Brights. These factors are not intended to be exclusive, but may be used to demonstrate  S -that a community is part of a particular station's market.^ [ yO` -ԍH.R. Rep. No. 102628, 102d Cong., 2d Sess. 97 (1992).^   S - ` x5.` ` The Commission provided guidance in its Report and Order in MM Docket No. 92259,  S -supra, to aid decision making in these matters, as follows:  ~XxFor example, the historical carriage of the station could be illustrated by the submission  S - Qof documents listing the cable system's channel lineup (e.g., rate cards) for a period of  years. To show that the station provides coverage or other local service to the cable  community (factor 2), parties may demonstrate that the station places at least a Grade B  coverage contour over the cable community or is located close to the community in terms  of mileage. Coverage of news or other programming of interest to the community could  obe demonstrated by program logs or other descriptions of local program offerings. The  S- pfinal factor concerns viewing patterns in the cable community in cable and noncable  homes. Audience data clearly provide appropriate evidence about this factor. In this  nregard, we note that surveys such as those used to demonstrate significantly viewed status  Dcould be useful. However, since this factor requires us to evaluate viewing on a  }community basis for cable and noncable homes, and significantly viewed surveys typically  nmeasure viewing only in noncable households, such surveys may need to be supplemented  S0-with additional data concerning viewing in cable homes.Q0X[ yO(-ԍ8 FCC Rcd at 2977 (emphasis in original).Q   S- ` x6.` ` In adopting rules to implement this provision, the Commission indicated that requested  xchanges should be considered on a communitybycommunity basis rather than on a countybycounty  x.basis, and that they should be treated as specific to particular stations rather than applicable in common",`(`(88"  S- x.to all stations in the market."[ yOh- x,ԍ8 FCC Rcd at 2977 n.139. Viewership information cited herein is county data, rather than communityspecific  xydata. However, absent evidence that such data is not fairly reflective of viewing in the actual communities in  {O- xxquestion, we accept such data as probative in cases of this type. See, e.g., RKZ Television, Inc., 8 FCC Rcd 8008, 8010 (1993). The rules further provide, in accordance with the requirements of the Act,  S-that a station not be deleted from carriage during the pendency of an ADI change request.<[ yO*-ԍ47 C.F.R. 76.59.<  S-p ARGUMENTS OF THE PARTIES ă 0%AM 7.0  S8- ` x7.` ` WGMETV is located within the PortlandPoland Spring, Maine ADI. The counties of Strafford and Rockingham, New Hampshire are located within the Boston, Massachusetts ADI.  S- ` x8.` ` In support of its request, WGMETV states that the must carry rules enacted by Congress  xin the 1992 Cable Act ensures the preservation of the "vital local service" provided by television  Sp- x broadcasting,X pB[ yOR-ԍS. Rep. No. 92, 102d Cong., 2nd Sess. 42 (1992).X and was intended "to ensure that television stations be carried in the areas which they  SH - xservice and which form their economic market."[ H [ yO-ԍH.R. Rep. No. 628, 102d Cong., 2nd Sess. 97 (1992).[ In this instance, WGMETV asserts that an analysis  x!of the statutory factors demonstrates that its market should be modified to include the requested communities.  S - ` x9. ` ` First, WGMETV states that it has established a history of carriage in the requested  xMcommunities. It indicates that it is currently carried in all of the requested communities. WGMETV  xargues that such voluntary carriage demonstrates that the cable operator considers it to be a local signal  xand provides convincing support for the instant request. WGMETV states that the Bureau has observed  xLthat historical carriage demonstrates that the cable operator and its subscribers "value the station and the  S- xservice it provides."h b [ {O-ԍChannel 17 Associates, Ltd., 11 FCC Rcd 4199, 4205 (1996).h Moreover, WGMETV points out that other Portland ADI stations have also been  S- xhistorically carried in the communities.  [ yOL- xhԍAccording to WGMETV, these stations include: WCSH WMTWTV WPXT WCBB WMEATV and WPMETV. WGMETV maintains that, since the Bureau has frequently  xcited the carriage of other stations from the same community as justification for rejecting an attempt to  Sh- xdelete a communities from a station's market,2 ZhL [ {OT"- xԍSee TWI Cable, Inc., 12 FCC Rcd 13187, 13193 (1997), in which the Bureau remarked upon the importance  xof ensuring that different television stations from the same community of license are treated similarly in carriage decisions.2 a similar principal should guide the Bureau's analysis of  xthe instant request as it represents compelling evidence of the required nexus between the requested communities and WGMETV's city of license. "n ,`(`(88C"Ԍ S- ` #x 10.` ` Second, WGMETV indicates that all of the instant communities are either located within  xWGMETV's Grade B contour or on the fringe. WGMETV points out that the Bureau has repeatedly  x]emphasized the importance of a station's Grade B coverage in demonstrating local service, even in  S- x<instances where a community is slightly beyond the contour's border.&[ {O- x,ԍSee Must Carry Order, 8 FCC Rcd 297677 (1993); Time Warner Cable, 11 FCC Rcd 8047, 8054 (1996); Time  {O-Warner Cable, 11 FCC Rcd 2902, 2905 (1996); and Time Warner Cable, 10 FCC Rcd 8040, 8044 (1995).& In addition, WGMETV states that  S`- xits city of license is geographically proximate to the communities at an average of 48.8 miles.g`$[ yO$-ԍAdjusted to reflect the lesser number of communities requested.g This  xdistance, WGMETV maintains, is well within the range of distances approved in prior ADI modification  S-decisions.M\[ {Od - xԍSee, e.g., Time Warner Cable, 11 FCC Rcd 8047, 8051 (1996); Time Warner Cable, 11 FCC Rcd 492, 493  {O. - x(1996); Busse Broadcasting Corp., 11 FCC Rcd 6408, 642225 (1996); and Pappas Telecasting, Inc., 11 FCC Rcd 6102, 6105 (1996).M  S- ` x 11.` ` Third, WGMETV states that it airs public affairs programming which is specifically  xtargeted to the communities. WGMETV indicates that, unlike other broadcast stations in the Boston and  xPortland markets, it maintains a fulltime presence in the "Seacoast Communities" that lie along the  xMsouthern Maine/northern New Hampshire border, an area which includes the requested communities.  xWGMETV states that it has a 56person news staff; it maintains its own satellite news bureau in Sanford,  S - xyMaine, which is less than 25 miles from the majority of the communities;5X [ yOp- xԍWGMETV states that this bureau is connected with its Portland facility via 24hour per day microwave links  xand regularly dispatches its remote news crews and two microwaveequipped trucks to covers news stories in the cable communities.5 and it staffs two fulltime on xair reporters, who reside in the area, and who research, produce and report on local news and events of  xinterest. WGMETV asserts that among the 27 hours of local news it broadcasts are stories produced by  S - xthe Seacoast Bureau as well as live broadcasts from its reporters. [ yO- xԍWGMETV states that such stories include breaking news events in the communities and informational programming targeted to the issues that are important to the residents. WGMETV points out that the Boston  xyADI network affiliates carried in the communities are more distant than is WGMETV's Seacoast Bureau  xand therefore less likely to cover local issues. In any event, WGMETV argues that, to the extent that  xother stations do provide local coverage to the communities, the Bureau has made clear that such coverage  S- x["does not act as a bar to a station's ADI claim."}^P [ {O- xyԍSee Smith Television of New York, Inc., 11 FCC Rcd 6025, 6032 (1996); WTVT License, Inc.,11 FCC Rcd  {O - x18020, 18025 (1996); Evergreen Broadcasting Corp., 11 FCC Rcd 19184, 19190 (1996); and Wabash Valley  {Od!-Broadcasting Corp., 11 FCC Rcd 19773, 19778 (1996). } Finally, WGMETV states that its commitment to the  S- xinstant communities is evidenced by its inclusion in the two Rockingham County newspapers, The  S- x/Portsmouth Herald and The Manchester Union Leader, as well as the New Hampshire edition of TV  Sl- xGuide, and its long advertising relationship with companies doing business in and around those communities.  S- `  %AM x 12. ` ` In its opposition, MediaOne argues that WGMETV's request should be denied because  xOthe station has failed to demonstrate that it adequately meets the criteria necessary for market"v,`(`(88"  xMmodification. MediaOne states that WGMETV fares poorly in its reliance on its Grade B coverage.  xMediaOne asserts that while the Commission has previously relied on a station's Grade B contour  xcoverage as a last resort to prevent the contraction of station's market, it does not typically rely solely on  xzthe Grade B to expand a market. Moreover, MediaOne states that recently performed signal strength  S`- xstudies`[ yO-ԍTests were performed at the system's Dover and Exeter headend locations at tower heights of 30 and 150 feet. indicate that WGMETV does not provide an offair signal of good quality to the system  xcommunities without reliance on the use of a highgain antenna at a height significantly greater than that  xjtypically available at individual homes in the cable communities. Further, MediaOne argues that, instead  x\of justifying modification, the average geographic distance relied on by WGMETV equals or exceeds  S-distances in previous Bureau decisions which justified exclusion of communities from a station's market.M\X[ {O - xԍSee, e.g., AR Services, Inc., 11 FCC Rcd 21080 (1996) 48 miles;  Time Warner Cable, 11 FCC Rcd 13149  {O - x(1996) 45 miles; and Cablevision of Cleveland and V Cable, d/b/a Cablevision of Ohio, 11 FCC Rcd 18034 (1996) 41 miles.M  Sp- ` ox 13.` ` MediaOne points out that WGMETV also does not provide evidence of programming  xspecifically tailored to the instant communities. MediaOne states that WGMETV is a CBS network  x|affiliate and thus broadcasts CBS programming which has no specific nexus or relevance to the  xcommunities herein. In any event, even if such programming did target the communities, MediaOne states  xthat it is already available from the Boston ADI's own CBS affiliate, WBZTV. Moreover, MediaOne  xMargues that the fact that WGMETV maintains a Seacoast Bureau does not in itself demonstrate local  xcoverage of the communities because only 2 of its 56 person news staff is dedicated to the Seacoast  xjBureau; only 15 miles of the Seacoast area is New Hampshire coastline, compared to 115 miles of Maine  xcoastline; and many of the New Hampshire stories included in WGMETV's exhibit appear to focus on  xissues of potential general appeal to New Hampshire and Maine residents and do not address news or  S- x/events specific to any of the instant communities.e|[ yO- x.ԍFor example: a) several of the 41 news stories over a period of approximately 100 days report on the  xwPowerball Jackpot; b) several others focus on northern New Hampshire communities already located in WGMETV's  xADI, or on Mainerelated stories; c) many of those listed by WGMETV appear to focus on stories involving New  xHampshire communities not at issue here; and d) the few remaining items listed do not provide enough detail to determine if they are indeed targeted to the requested communities.e The mere fact that WGMETV is listed in New  S- x.Hampshire papers and TV Guide, argues MediaOne, fails to establish the necessary local nexus with the communities as these publications also serve residents in the Portland ADI.  SB- ` x 14. ` ` MediaOne states further that WGMETV fails to provide any evidence to support its claim  x[that the instant communities are inadequately provided local coverage by their own market stations. For  xinstance, MediaOne points out that WGMETV completely ignores the fact that the cable communities  x.all receive WMURTV, a Grade A station licensed to Manchester, New Hampshire, WNDS, licensed to  xxDerry, New Hampshire, and WENH, licensed to Durham, New Hampshire. MediaOne states that WMUR x.TV provides extensive news and sports coverage from the cable communities as well as extensive public  SR- xaffairs and local entertainment programming;BR, [ yO%-ԍSee petition at Exhibit 6.B that WNDS reached an agreement on a formal "news  x[alliance" with the Boston ADI CBS affiliate, WBZTV, to air a nightly local newscast at 10:00 p.m.; and"* ,`(`(88{"  x^that WENH provides significant public affairs and news programming that targets the specific communities at issue.  S- ` %x15. ` ` Finally, MediaOne argues that WGMETV fails to provide any evidence regarding  xmaudience viewership of its stations in either the cable or noncable households in the requested  xcommunities. MediaOne maintains that this is hardly surprising since, in general, WGMETV does not  xMprovide an offair signal of good quality to the system communities. In a study conducted by Media  S- x=Strategies,9[ yOP-ԍId. at Exhibit 9.9 MediaOne states that no ratings were found for WGMETV in Rockingham County, where  xthe majority of the cable communities are located, and only minimal viewership in Strafford County which  xis easily eclipsed by that of the Boston CBS affiliate, WBZTV, which is also considered to be  xsignificantly viewed in both Rockingham and Strafford counties. Despite this, however, MediaOne states  xzthat due to the fact that Portland, WGMETV's city of license, is slightly closer to the cable system's  xprincipal headend than is Boston, carriage of WBZTV could be at risk should WGMETV's request be  xgranted since Commission rules require a cable operator to carry only the closest of two identical network  S - xaffiliates.F X[ yO-ԍ47 C.F.R. 76.56(b)(4)(ii).F MediaOne argues that such displacement of an inmarket station is not what Congress had in mind when it enacted the modification rules.  SX- ` 3x16.` ` In reply, WGMETV states that its petition decisively demonstrated that it meets the  x]statutory criteria for market modification. It argues that the arguments raised by MediaOne in its  xLopposition are factually inaccurate and fail to provide any basis upon which to deny the instant request.  xlWGMETV points out that MediaOne concedes that the station has been carried, voluntarily and  S- xcontinuously, in the requested communities. WGMETV argues that it is also relevant that MediaOne  S- xkcarries three other television stations licensed to the Portland ADI,B[ yO-ԍWCSH, WMTWTV and WMEATV.B since the Bureau has held that a  xkcable operator's decision to carry one station licensed to a community, but not another, can adversely  S@- xaffect the latter's ability to compete with the carried station.n@x[ {OX-ԍSee Paxson Phoenix License, Inc., 13 FCC Rcd 8555, 8562 (1998). n WGMETV maintains that such carriage  xrepresents convincing evidence of a nexus between these communities and Portland, and a grant of the  xcurrent request would ensure that WGMETV competes evenly with its Portland counterparts. In any  x=event, WGMETV states that MediaOne has provided no justification for treating its station differently from the other Portlandarea television stations.  SP- ` x17.` ` WGMETV argues further that MediaOne's contention that the Bureau does not rely on  xGrade B coverage to demonstrate local service is both unfounded and unsupported. WGMETV points  xout that the Bureau has issued a number of decisions in which it determined that Grade B coverage  S- x.supported the addition of communities to a television station's market.y^ [ {O$- xԍSee, e.g., Paxson San Jose License, Inc.,12 FCC Rcd 17520, 17525 (1997); Channel 56 of Orlando, Inc.,12  {OL%- xFCC Rcd 4071, 4080 (1996); and Market Modifications and New York Area of Dominant Influence ("New York ADI  {O&-Decision"), 12 FCC Rcd 12262, 12267 (1997). y Therefore, WGMETV argues  xthat MediaOne's attempt to diminish the importance of WGMETV's Grade B coverage is without any"0 ,`(`(88-"  xbasis. Moreover, WGMETV states that MediaOne's attempt to introduce the results of a purported field  xstrength study should be rejected because such measurements are not relevant to a market modification  S- xrequest and, in any event, MediaOne has conceded that its signal meets the threshold test.<[ yO-ԍSee opposition at 4.< Similarly,  xWGMETV maintains that, despite MediaOne's assertions, the Bureau has found that a distance of 56  S`- xmiles is not so great as to require rejection of a request to include communities in an ADI.&`X[ {OX- xhԍSee, e.g., Panhandle Telecasting Co., 12 FCC Rcd 884, 887(1998) where the communities were approximately  {O"- x108 miles from the station's community of license and outside the station's Grade B; and the New York ADI  {O- xDecision, 12 FCC Rcd 12262, 12271 (1997), which denied a cable operator's request to delete communities located on average 74 miles distant. With respect  xto the 9 served communities to which its request is now directed, however, WGMETV points out that the average distance is even closer at 49 miles.  S- ` x18. ` ` WGMETV asserts that MediaOne's attempts to dispute its local programming should also  xbe disregarded. WGMETV states that it is alone among the network affiliates licensed to either the  xBoston or Portland ADIs which provides a local news bureau designed to cover news and events occurring  x[in and around the served communities, a fact which MediaOne fails to rebut. WGMETV indicates that,  S - xaccording to its Executive Producer, Lois Czerniak,B F[ yO-ԍSee reply at Attachment C.B the New HampshireMaine border area, which  xincludes Portsmouth and the other served communities, forms an integral component of WGMETV's  xregular coverage area. WGMETV argues that its Seacoast Bureau is staffed fulltime by approximately  xonetenth of its news reporting and photography professionals which facilitates its ability to cover news,  S - xsports and community events in the served communities comprehensively and timely.1 [ {O-ԍId.1 In fact, WGME xTV states that it has aired at least 180 stories during the past eight months directed toward the served  x?communities and many other segments that, while not specifically directed at these communities,  S- x addressed statewide New Hampshire events of interest to the residents.!h [ yO-ԍWGMETV provides a videotape containing a representative sample of this targeted programming. Further, while MediaOne  xycontends that the third statutory factor regarding coverage of other local stations weigh[s] heavily against  xythe petition, WGMETV maintains that Commission precedent clearly authorizes a station to invoke the  xthird factor as an "enhancement criterion" in a market addition case, while expressly precluding its use  Sh-against such a station.~"h [ {O -ԍOpposition at 8. See also Paxson Phoenix License, 13 FCC Rcd 8555, 8562 (1998).~  S- ` Px19.` ` WGMETV points out that it is significant that a large number of businesses in the served  x=communities rely on WGMETV to reach their customers by purchasing advertising on the station. For  xjinstance, WGMETV states that contracts from businesses located in the New HampshireMaine border  xarea generate, on an annual basis, approximately $500,000, while advertisements with regional New  Sx- xHampshireMaine businesses exceed $2,500,000.O#x [ yO&-ԍSee Declaration of William S. Anderson.O In addition, WGMETV argues that its ratings also  xsupport this request as it is significantly viewed and has measurable ratings in Strafford County, in which"P#,`(`(88"  x4 of the 9 served communities are located. While WGMETV concedes that it does not enjoy the level  x.of ratings it would prefer in Rockingham County, it feels that its locallyfocused programming will soon  x.result in improved viewership. However, WGMETV argues that in light of the overwhelming evidence  xsatisfying the other statutory factors, its less significant ratings should not play a pivotal role in the  xBureau's analysis herein. Finally, WGMETV asserts that there is no merit in MediaOne's dire warning  xthat grant of the instant petition will jeopardize the carriage of WBZTV, Boston's CBS affiliate. WGME xTV points out that MediaOne has long provided the served communities with simultaneous carriage of  S- xthe network and local programming from both affiliates and there is every indication that the status quo will continue.  Sr-( DISCUSSION ă  S" - ` Rx20. ` ` The counties of Strafford and Rockingham, in which the communities requested for  xinclusion are located, are situated in the northeastern portion of the Boston ADI and are geographically  xproximate to the Portland ADI, to which WGMETV is licensed. In our review of the case herein, the  x[factors presented by WGMETV would argue for grant of its request. WGMETV has a long history of  xcarriage in the communities at issue (factor I); provides Grade B coverage and specificallydirected  xprogramming to the communities (factor II); and has reasonable viewership in Strafford County (factor  xIV). Other factors inherent in this situation, however, override the statutory factors and will support a denial of the requested modification.  S- ` x21.` ` In the present case, WGMETV, a CBS network affiliate, is seeking to modify its market  xto include 9 communities located in the Boston ADI. These communities are served by the Boston market  xCBS affiliate, WBZTV. In such circumstances, we are especially concerned that our decision not unduly  SB- xupset the economic marketplace expectations underlying the affiliation concept.h$B[ {O-ԍMohawk Valley Broadcasting, Inc., 11 FCC Rcd 12090 (1996).h Therefore, we must take into account the effect a grant of must carry status to WGMETV will have on WBZTV.  S- ` Px22. ` ` Our review of the case reveals several important factors. Both WGMETV and WBZTV  xprovide approximately equal Grade B coverage of the communities at issue. Geographically, however,  xthere is some disparity. According to the mostrecently available Commission records, the subject  xcommunities are served by two separate MediaOne systems one system serving the communities in  xStrafford County and the other the communities in Rockingham County. An analysis of the distances  xbetween the two stations' cities of license and the individual communities in the two systems reveals that  xall of the Strafford County communities are closer to Portland than to Boston while more than half of the  xRockingham communities are either closer to Portland or equidistant between Portland and Boston. A  xgrant of must carry status to WGMETV, therefore, particularly for the Strafford County system, would  xjeopardize WBZTV's must carry status within its own ADI market, a situation not intended or envisioned  S:-by the Cable Act.%:Z[ yO4#- xԍSee 47 C.F.R. 76.56(b)(5) which requires a cable operator obligated to carry duplicating network affiliate stations, to carry the station whose community of license is closest to the principal headend of the cable system.  S - ` Ax23. ` ` Viewership levels are also important in reaching our determination. WBZTV, the current  xNCBS affiliate serving the communities, achieves substantial viewership levels of 7/62 and 11/73 in  xjStrafford and Rockingham Counties, respectively, and is also considered to be significantly viewed in the"" %,`(`(88'$"  xtwo counties while, on the other hand, WGMETV achieves viewership levels of 5/41 in Strafford County,  S- xand no viewership recorded at all for Rockingham County. In neither county is WGMETV considered  xto be significantly viewed. These viewership levels show a preference for WBZTV in the subject  x=communities, especially in Rockingham County. Further, while WGMETV has shown that it provides  xlocallyfocused programming to the communities, it has not provided any information to conclude that  xWBZTV, or indeed any other Boston ADI station eligible to be carried, fails to provide adequate news coverage or other local programming. x  S- ` 3x24. ` ` Finally, we cannot overlook the importance of the local programming the communities  xreceive from their own market stations. We note MediaOne's apparent carriage of three other Portland  xmarket stations, WCSHTV, WMTWTV and WMEATV. Only one of these stations, WMEATV, a  xjnoncommercial television station, is carried pursuant to must carry requirements as the station's Grade B  xcontour encompasses the communities. The other two network stations, WCSHTV and WMTWTV, are  xapparently being carried voluntarily, as is WGMETV. As such, our action herein does not place WGMETV at an unfair disadvantage to the stations with which it competes.  S - ` x25. ` ` In light of WBZTV's current viewership in all of the communities, and the potential  xdanger to WBZTV's must carry status on the Strafford County system, we see no reason to interfere with  S0- xthe present affiliate relationship of the relevant ADIs or change the status quo of the stations involved,  xydespite the otherwise strong showing provided by WGMETV. WGMETV has long been carried in the  x.subject communities pursuant to retransmission consent agreements and there has been no indication by MediaOne that it intends to alter this arrangement. x  Sj-0 ORDERING CLAUSES ă  S- ` 1x26. ` ` Accordingly, IT IS ORDERED , pursuant to 614(h) of the Communications Act of 1934,  xas amended (47 U.S.C. 534(h) and 76.59 of the Commission's rules, 47 C.F.R. 76.59), that the petition  S-for special relief (CSR5289A), filed on behalf of Guy Gannett Communications, Inc., IS DENIED.  Sz- ` px27. ` ` This action is taken pursuant to authority delegated by 0.321 of the Commission's  SR-Rules.<&R[ yO-ԍ47 C.F.R. 0.321.< x` `  hh@FEDERAL COMMUNICATIONS COMMISSION x` `  hh@William H. Johnson, Deputy Chief x` ` hh@Cable Services Bureau