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Under the casebycase standard, the Commission makes a public interest determination  xby weighing five factors: (1) the potential public benefits of joint operation of the facilities, such  xas economies of scale, cost savings, and programming and service benefits; (2) the types of  x-facilities involved; (3) the number of media outlets owned by the applicant in the relevant market;  xy(4) the financial difficulties of the stations involved; and (5) the nature of the relevant market in  X- xlight of the level of competition and diversity after the joint operation is implemented. See  X-Second Report and Order, 4 FCC Rcd at 1753.  X-  x5. Benefits of Joint Operation. Raycom contends that continued joint operation of  xWMCAM, WMCFM and WMCTV (collectively, "the WMC stations") will continue to produce  xLsubstantial economic efficiencies, including cost savings of $220,000 per year based on studio  xoperation, engineering, business and management costs. Raycom also claims that operating  xWMCTV independently of WMC(AM/FM) would involve a onetime cost of $200,000 to"7 ,-(-(ZZ"  xrelocate and separate the transmitter sites and studio operations. These efficiencies, Raycom  xasserts, were a major factor in the Commission's decision to grant a waiver of the onetoa X- xmarket rule in ScrippsHoward. Raycom further contends that, since its acquisition of the WMC  xLstations from ScrippsHoward, ElcomMemphis has realized savings of approximately $200,000  xLper year in newsgathering costs. Raycom also maintains that the joint operation of the WMC  xzstations would continue to produce significant public service benefits, and that without the  xstability and operating efficiencies that joint ownership provides, the WMC stations "could not  xcontinue to produce the abundance of locallyoriginated programming that they currently  XH- xbroadcast," such as: (1) Memphis in the Morning, a news and information program aired  X1- xweekdays on WMCAM; (2) callin talk shows like the Mike Fleming Show, the Gil Gross Show  X - xand the Reanetta Hunt Show, which focus on topical issues on the day and are aired weekdays  X - xon WMCAM; (3) Memphis News Magazine, a news magazine aired Sundays on WMCFM; (4)  xKlocal news, traffic and weather reports that run throughout the day on WMCFM; and (5) various  X - xnews segments, including Hometown Hero, Unsolved Murders, Food for Thought, Family  X -Healthcast, Pet of the Week, produced by WMCTV and aired during local newscasts.  X-  mx6. Other Media Outlets/Types of Facilities. Raycom states that it has no other media  xinterests in the Memphis market. Our engineering records show that WMCTV is a VHF station  xoperating with 100 kW effective radiated visual power ("ERP") from an antenna height at 308  xmeters above average terrain ("HAAT"), WMCAM is a fulltime Class B AM station operating  xon 790 kHz at 5 kW day and night (with a directional pattern at night), and WMCFM is a Class  xC FM station operating on 99.7 MHz at 290 kW ERP from an antenna at 277 meters HAAT.  xAccording to Raycom, none of the WMC stations is dominant in the market based on the types  x-of facilities involved and the level of diversity and competition in Memphis. Raycom asserts that  x=none of the facilities has been modified and that the WMC stations' Arbitron audience ratings  X- xMin the Memphis market are comparable to what they were at the time of the ScrippsHoward  xdecision, namely WMCTV ranked number 2 of 6 television stations, and WMCAM and WMCFM ranked 10 and 5, respectively, out of 22 radio stations in the Memphis market.  Xe-  x7. Competition and Diversity in the Market. The final factor Raycom addresses concerns  XN- xthe nature of the relevant market visavis the Commission's concerns about diversity and  X7- x0competition. Raycom refers to our findings in US Radio Stations, L.P., 11 FCC Rcd 5772  x(1996), where we recently considered the transfer of control of US Radio, Inc. ("US Radio") to  xClear Channel Communications of Memphis, Inc. ("Clear Channel"), and a request for permanent  xjwaiver of the onetoamarket rule to allow Clear Channel, the licensee of WPTYTV, Memphis,  xto acquire WDIA(AM) and WHRKFM, Memphis. In evaluating Clear Channel's waiver request,  X - xwe found, in May of this year, that Memphis is a top 50 market with 30 separatelyowned and  xNoperated broadcast "voices" in the market. We also found that Memphis has nine daily  xnewspapers, 27 weekly publications and 34 cable operators with a cable penetration of 58.1%.  xWe concluded that the public benefits of common ownership of the Memphis stations involved  x[in the US Radio/Clear Channel transaction outweighed any negative effect on competition and  xdiversity in the market, and granted a waiver of the onetoamarket rule. Accordingly, Raycom  xLstates that grant of the instant waiver will have no adverse affect on competition and diversity in the Memphis market."#',-(-(ZZ%"Ԍ/DISCUSSION   x8. In analyzing a casebycase request for waiver of the onetoamarket rule, the  xCommission's "goal in all situations is to permit the public to benefit from such efficiencies of  xoperation as may be achieved through the use of common facilities and staff, consistent with the  X- x[maintenance of diversity and vigorous competition within the market areas involved." Second  Xv- xReport and Order Recon., 4 FCC Rcd at 6491. We conclude that, on balance, Raycom's showing  x.in support of its request for waiver of the onetoamarket rule meets our casebycase criteria,  xand that a waiver in this instance would not adversely affect competition and diversity in the Memphis market.   kx9. As discussed above, Raycom has shown economic benefits and cost savings, in excess  xof $400,000 per year, which will be derived from the continued joint operation of the WMC  xstations. According to Raycom, continued joint operation will ensure the continuation of the  xnews and informational program offerings of these stations. The Commission has noted that  xsignificant cost savings and economies of scale are "precisely the type of public interest benefit  xfrom common station ownership which [it] envisioned as warranting a waiver of the onetoa Xy-market rules. . . ." Great American Television and Radio Co., 4 FCC Rcd 6347, 6349 (1989).   x10. As to the types of facilities involved, the Commission endeavors to predict and avoid  X4- xyany significant adverse effect on diversity or competition from too powerful a combination. Id.  xat 6349. Here, while the technical facilities of the WMC stations are significant, we find that,  xgiven the substantial competition in the Memphis market, continuation of the AM/FM/TV  xcombination does not present issues of market dominance inconsistent with the public interest.  xjAlthough none of the WMC stations are experiencing financial difficulties, we note that not all  X- xLof the casebycase factors are relevant in every case. See Second Report and Order Recon., 4 FCC Rcd at 6491.   1x11. Finally, we find that the continued joint ownership of the WMC stations will not  xdiminish diversity in Memphis, the 42nd television market. Our analysis indicates that, upon  x/grant of these applications, Memphis will continue to be served by 18 AM stations, 18 FM  X7- xstations, 4 VHF television stations and 5 UHF television stations.7e yO- xԍ We note that Raycom has submitted its analysis of the Memphis market, concluding that there are 52 broadcast  xxstations with a total of 35 broadcast voices upon consummation of the US Radio/Clear Channel transaction. Our  xyevaluation of Raycom's showing indicates that it is overinclusive, having considered radio stations outside the  yO!- xMemphis television metropolitan market. However, we agree with Raycom to the extent that Memphis is served by  yO!-at least 30 separatelyowned and operated media voices.#x6X@`7iX@#ѱ Of these 45 broadcast stations,  X - xwe find, as we recently did in US Radio Stations, that Memphis is served by at least 30  xseparatelyowned and operated broadcast "voices," as well as nine daily newspapers, 27 weekly  xkpublications and 34 cable operators with a 58.1% cable penetration. Because grant of these  x applications will continue an existing combination, there will be no decrease in this level of  xdiversity and competition. For the foregoing reasons, we are persuaded that the public interest  x.benefit of continued common ownership of WMCAM, WMCFM and WMCTV in Memphis"!x,-(-(ZZ " warrants a waiver of the onetoamarket rule. CONTINUED SATELLITE STATUS   x12. Note 5 to Section 73.3555 of the Commission's rules exempts from application of  xthe multiple ownership rules those television stations that are "satellite" operations. Raycom  xseeks to acquire from Kelso Partners three satellite stations which are licensed to whollyowned  x/subsidiaries of Elcom. They are: WHLT(TV), Hattiesburg Mississippi, which operates as a  x>satellite of WJTV(TV), Jackson, Mississippi; and KABYTV, Aberdeen, South Dakota, and  x>KPRYTV, Pierre, South Dakota, which operate as satellites of KSFYTV, Sioux Falls, South Dakota.  X -  x13. In Television Satellite Stations, 6 FCC Rcd 4212, 4215 (1991), the Commission  xestablished the requirement that all applicants seeking to transfer or assign satellite stations justify  xcontinued satellite status by demonstrating compliance with a threepart "presumptive" satellite  xexemption standard applicable to new satellite stations. Alternatively, applicants may demonstrate  xthat there exist "other compelling circumstances" to warrant continued satellite authorization. The  xjpresumptive satellite exemption is met if the following three public interest criteria are satisfied:  x(1) there is no City Grade overlap between the parent and the satellite; (2) the proposed satellite  xwould provide service to an underserved area; and (3) no alternative operator is ready and able  X- x<to construct or to purchase and operate the satellite as a fullservice station. Id. at 4212. Raycom  xrequests continued satellite exemption status for the three stations, asserting that they presumptively qualify under the Commission's threepart standard.   x14. Regarding the first criterion, a review of the authorized facilities of the stations  x-demonstrates that the City Grade contour of WHLT(TV) does not overlap the City Grade contour  x/of WJTV(TV), nor do the City Grade contours of KABYTV and KPRYTV overlap the City  x]Grade contour of KSFYTV. As to the second criterion, an applicant can use one of two  x\different tests to demonstrate that an area is underserved. Under the "transmission test," a  xproposed satellite community of license is considered underserved if there are two or fewer full X7- xLservice stations already licensed to it. Id. at 4215. Upon review, our records show that KTSD xTV, Channel 10, is the only other station licensed to Aberdeen, South Dakota, and KDSDTV  x is the only other station licensed to Pierre, South Dakota. Similarly, WHLT(TV) is the only station licensed to Hattiesburg, Mississippi. Therefore, the areas are underserved.   x15. With respect to the third criterion, an applicant must show that no alternative operator  xis ready and able to construct, or to purchase and operate, the proposed satellite as a fullservice  xstation. In support of the instant satellite request, Raycom submits a statement from Brian E.  xiCobb, an experienced broadcast broker. Mr. Cobb states that he has reviewed the relevant market  x[information, and has concluded that the satellites are not in large enough communities to have  xsufficient economic viability to survive as standalones. He additionally asserts that his firsthand  xknowledge of operating stations and personal experience brokering numerous sales of television  xstations lead him to conclude that a viable buyer for any of the current satellites does not exist. "#',-(-(ZZ%"  x-In fact, Mr. Cobb declined the opportunity to take a listing on the satellites. Based on the above,  xcontinued operation of WHLT(TV) as a satellite of WJTV(TV), and KABYTV and KPRYTV as satellites of KSFYTV is justified.  X-   OTHER MATTERS   Ox16. A license renewal application for KAMETV, Reno, is pending. Generally, where  xboth a transfer of control application and a renewal application involving the same broadcast  x.station are pending, the Commission refrains from acting on the transfer of control application  xystarting on the date the station's renewal application must be filed until after it has taken action  x.on the renewal. Where the pendency of a transfer application overlaps with the renewal cycle  xof a station involved in a multiplestation transfer, however, the Commission has allowed the  xtransfer if there are no basic qualifications issues pending against the transferor and transferee,  xzand if both the transferor and transferee indicate a willingness to assume the consequences  xzassociated with the transferee succeeding to the place of the current licensee in the renewal  X - xapplication. See Stockholders of CBS Inc., 11 FCC Rcd 3733, 3750 (1995); see also Capital  X-Cities/ABC, Inc., 11 FCC Rcd 5841, 59005901 (1996); US Radio Stations, 11 FCC Rcd at 5775.   x17. Here, the transfer of control applications are unopposed and there are no outstanding  xbasic qualifications issues against the applicants. Raycom has demonstrated that it is otherwise  xqualified to acquire the stations, and that the transfer of control would serve the public interest.  x\Moreover, KAMETV, the station with a pending license renewal application, is part of this  xmultiplestation transfer, and Kelso Partners and Raycom have stated their willingness "to abide  xKby the consequences of Raycom's succeeding Kelso as the party controlling the Elcom stations."  x-Thus, we find that the pending license renewal application is not an impediment to approving the  x/transfer of control, and that the public interest is served by facilitating this multiplestation transfer without detriment to the public's ability to comment on this pending application. T h,CONCLUSION   lx18. Having determined that the applicants are qualified in all respects, we find that grant  xjof the transfer of control of the licenses held by Elcom, through its whollyowned subsidiaries, to Raycom will serve the public interest.   x19. Accordingly, IT IS ORDERED, That the abovecaptioned applications for transfer  x/of control of Ellis Communications, Inc. from Kelso Partners IV, L.P. to Raycom Media, Inc. ARE GRANTED.   }x20. IT IS FURTHER ORDERED, That the request for a waiver of the Commission's  xonetoamarket rule, 47 C.F.R.  73.3555(c), to allow Raycom's common ownership and operation of WMCAM, WMCFM and WMCTV, Memphis, Tennessee, IS GRANTED. "Q%,-(-(ZZ $"   x21. IT IS FURTHER ORDERED, That the requests of Raycom Media, Inc. for operation  xof WHLT(TV), Hattiesburg Mississippi, KABYTV, Aberdeen, South Dakota, and KPRYTV,  xPierre, South Dakota, pursuant to the satellite exemption of Note 5 to 47 C.F.R.  73.3555, ARE GRANTED. TFEDERAL COMMUNICATIONS COMMISSION X(#P x` `  hh@ Roy J. Stewart  X -x ` `  hh@ Chief, Mass Media Bureau