WPCyT 2BJZ Courier3|j':Wx6X@`7X@HP LaserJet 5SiT1:ional)RM 700HPLAS5SI.PRSx  @\,$:`X@26 ZFK3|j'HP LaserJet 5SiT1:ional)RM 700HPLAS5SI.PRSXj\  P6G;\,$:`XP"i~'^:DPddDDDdp4D48dddddddddd88pppX|pDL|pp||D8D\dDXdXdXDdd88d8ddddDL8ddddX`(`lD4l\DDD4DDDDDDdDd8XXXXXX|X|X|X|XD8D8D8D8ddddddddddXdbdddpdXXXXXlX~|X|X|X|XdddldldD8DdDDDdplld|8|P|D|D|8dvddddDDDpLpLpLpl|T|8|\ddddddl|X|X|Xd|DdpL|Dd~4ddC$CWxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNHxxH\dDXddddd8@d<@d<DDXXdDDxddxHxxHvppDXd<"dxtldpxxd X- I. A. 1. a.(1)(a) i) a) 1. 1. 1. a.(1)(a) i) a)#X\  P6G;ɒP#X01Í ÍX01Í Í#Xj\  P6G;ynXP#2yvp3kka8DocumentgDocument Style StyleXX` `  ` a4DocumentgDocument Style Style . a6DocumentgDocument Style Style GX  a5DocumentgDocument Style Style }X(# 2 vPt: a2DocumentgDocument Style Style<o   ?  A.  a7DocumentgDocument Style StyleyXX` ` (#` BibliogrphyBibliography:X (# a1Right ParRight-Aligned Paragraph Numbers:`S@ I.  X(# 2   P  a2Right ParRight-Aligned Paragraph Numbers C @` A. ` ` (#` a3DocumentgDocument Style Style B b  ?  1.  a3Right ParRight-Aligned Paragraph Numbers L! ` ` @P 1. ` `  (# a4Right ParRight-Aligned Paragraph Numbers Uj` `  @ a. ` (# 2   j:a5Right ParRight-Aligned Paragraph Numbers _o` `  @h(1)  hh#(#h a6Right ParRight-Aligned Paragraph Numbersh` `  hh#@$(a) hh#((# a7Right ParRight-Aligned Paragraph NumberspfJ` `  hh#(@*i) (h-(# a8Right ParRight-Aligned Paragraph NumbersyW"3!` `  hh#(-@p/a) -pp2(#p 2#EETech InitInitialize Technical Style. k I. A. 1. a.(1)(a) i) a) 1 .1 .1 .1 .1 .1 .1 .1 Technicala1DocumentgDocument Style Style\s0  zN8F I. ׃  a5TechnicalTechnical Document Style)WD (1) . a6TechnicalTechnical Document Style)D (a) . 2UPa2TechnicalTechnical Document Style<6  ?  A.   a3TechnicalTechnical Document Style9Wg  2  1.   a4TechnicalTechnical Document Style8bv{ 2  a.   a1TechnicalTechnical Document StyleF!<  ?  I.   2D3Pa7TechnicalTechnical Document Style(@D i) . a8TechnicalTechnical Document Style(D a) . Doc InitInitialize Document Stylez   0*0*0*  I. A. 1. a.(1)(a) i) a) I. 1. A. a.(1)(a) i) a)DocumentgPleadingHeader for Numbered Pleading PaperE!n    X X` hp x (#%'0*,.8135@8:8HH"&H>XHH8HB8>HH^HH>"".2",2,2,"222N2222"&22H22,006"6."""""""""2"2H,H,H,H,H,XAB,>,>,>,>,""""H2H2H2H2H2H2H2H2H2H2H,H2H1H2H2H282H,H,H,B,B,B6B,H?>,>,>,>,H2H2H2H6H2H6H2""2"""2F866H2>>(>">">H2;H2H2H2H2XHB"B"B"8&8&8&86>*>>.H2H2H2H2H2H2^HH6>,>,>,H2>"H28&>"H2?22!!WFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxN$<<$.2",2222`2 LL2 LL2L"",,2d""><q*"xxxxWWxxxWWkkxxx"  Y- d(#WPTZ(TV) in accordance with the satellite exception to the duopoly prohibition.\d yOy- d(#ԍ WNNETV had operated as a satellite of WPTZ(TV) pursuant to Note 5 to Section 73.3555 which exempts  {OA- d(#yfrom application of the multiple ownership rules those television stations that are "satellite" operations. Taft  {O -Broadcasting Company, 5 FCC Rcd 6988, 6991 (1990), recon. denied, 6 FCC Rcd 3744 (1991).  Mt.  d(#KMansfield had opposed the request, arguing that: (1) the Trustee failed to meet its burden of  d(#Ysatisfying the Commission's threeprong publicinterest test for the presumption that a station  d(#xmay continue to operate as a satellite; (2) the Trustee should be required to demonstrate that,  d(#absent the basis for a presumption, compelling circumstances existed which warranted a waiver;  d(#Yand (3) any grant of a satellite waiver for WNNETV should be conditioned on the outcome of  d(#the Commission's review of its television broadcast ownership policies and regulations. In  d(#addition, Mt. Mansfield claimed that Heritage Media's time brokerage agreement with the  d(#permittee of WFFF, Channel 44, Burlington, Vermont, would give it control of three out of the  d(#five commercial television stations in the "relatively small" Burlington, VermontPlattsburgh,  d(#-New York market, and that Heritage Media should be required to demonstrate the extent to  d(#which the informational programming commitments made in its 1990 satellite request, "which  Y - d(#formed a basis for the Commission's public interest finding, remain applicable today." Informal  Y -Objection (July 24, 1997) at 4.  v ?3. In responding to Mt. Mansfield's informal objection to the transfer application,  Y- d(#Heritage Media substituted for its satellite request a claim, inter alia, that the small degree of  Y- d(#Grade B overlap between WNNETV and WPTZ(TV) qualified the stations for a de minimis  d(#waiver of the duopoly rule. According to Heritage Media, terrain features limit the Grade B  d(#contours of WNNETV and WPTZ(TV), and thus account for only a small overlap between the  d(#Ktwo stations. In support, Heritage Media submitted a Supplementary Engineering Statement  d(#containing population counts of the terrainlimited Grade B coverage of WNNETV and  d(#WPTZ(TV) as determined by using the LongleyRice Irregular Terrain Model, Version 1.2.2  Y- d(#Land 1990 U.S. Census data. Mt. Mansfield challenged Heritage Media's duopoly waiver  Y- d(#request, contending that it failed because the Commission has neither found an overlap de  Y- d(#minimis on the basis of population estimates alone, without considering the extent of the overlap  Y-area, nor relied on a terrainlimited analysis to conclude that an overlap is de minimis.  Y- v 4. Upon review of the record and its own independent technical analysis,XXd yO'- d(#ԍ Based upon the engineering data submitted, the staff was able to conduct its own analysis and determine that  d(#,the terrainlimited Grade B contour overlap area represented less than one percent of the areas encompassed by the stations' predicted Grade B signal contours. X the staff  d(#confirmed Heritage Media's terrainlimited analysis that the overlap between WNNETV and  Y\- d(#WPTZ(TV) is de minimis. The staff granted a waiver of the duopoly rule on that basis,  YG- d(#,concluding that it would serve the public interest, convenience and necessity, and dismissed as  d(#moot Mt. Mansfield's informal objection as it related to the initial continued satellite request.  d(#In addition, the staff stated that Mt. Mansfield presented no evidence that the time brokerage  d(#agreement between WFFF's permittee and Heritage Media failed to comply with the  d(#Commission's rules and policies, or that WFFF's permittee had surrendered control of its station" ,-(-(ZZ "  d(#to Heritage Media. The staff further noted that time brokerage agreements are nonattributable  d(#interests for the purposes of the television multiple ownership rules. Lastly, after reciting the  d(#improvements made to WNNETV's technical facilities and the overall increase in local news  d(#hprogramming, the staff concluded that Heritage Media had made good faith efforts to carry out its earlier proposals regarding WNNETV's local news and public affairs programming.  v 5. In the Pleadings under consideration here, Mt. Mansfield reiterates the issues raised  Y_- d(#win the WNNETV transfer of control proceeding, see supra 2 and 3 and challenges the staff's  YJ- d(#grant of the de minimis duopoly waiver request as contrary to Commission precedent and policy.  d(#Specifically, Mt. Mansfield contends that in granting the original satellite waiver for WNNETV  Y - d(#iin 1990, the full Commission rejected Heritage Corp.'s terrainbased calculation showing de  Y - d(#minimis overlap. Thus, Mt. Mansfield argues, the staff's decision "to bypass" the Commission's  d(#threeprong presumptive waiver test, and characterize the overlap between WNNETV and  Y - d(#WPTZ(TV) as de minimis based on a terrainlimited analysis, is inconsistent with the 1990  d(#ruling. Also inconsistent, Mt. Mansfield claims, are the results of Heritage Media's terrain  d(#limited analysis with those of the staff's analysis. Mt. Mansfield further criticizes the staff's  d(#-decision as having been based entirely on the staff's own terrain analysis, and for failing to  d(#wprovide an explanation of the methods and data used in that terrain analysis. The staff's failure  d(#to give the parties an opportunity to review and comment on its analysis, Mt. Mansfield maintains, also raises due process concerns.  Y>- aDISCUSSION  Y- v z 6. Having reviewed the staff's decision, we find that the staff thoroughly considered  d(#.all relevant information and that its decision is adequately supported and consistent with  d(#\Commission precedent and policy. As for the allegations relating to the programming  d(#commitments made by Heritage Media in 1990, and the potential of the Trustee or Sinclair to  d(#;control or influence a third station in the market by means of a time brokerage agreement with  Y- d(#WFFF,d {O- d(#ԍ According to the Asset Purchase Agreement, supra n.2, Sinclair will acquire Rollins Telecasting's rights under the time brokerage agreement with WFFF's licensee. Mt. Mansfield has presented no new facts or arguments that would cause us to alter the  d(#wstaff's conclusions on these issues. We take this opportunity to emphasize that, contrary to Mt.  d(#iMansfield's assertion, our grant of the satellite request in 1990 was not based on the alleged  d(#,programming commitments made by Heritage Media. Rather, we considered Heritage Media's  Y*- d(#programming proposals as factors reinforcing the appropriateness of that grant. Taft, 5 FCC Rcd  Y- d(#,at 6991. We believe, moreover, that Mt. Mansfield's concerns regarding the number of media  d(#interests held by a licensee in a smaller market are more appropriate for consideration in a  d(#rulemaking proceeding, such as those underway which deal with various relationships by  Y - d(#,broadcasters in the same market, including television time brokerage agreements. See Priscilla  Y!- d(#A. Schwier, et al., FCC 97313 (released September 22, 1997); see also Further Notice of  Y"- d(#Proposed Rulemaking, MM Docket No. 94150, et al., 11 FCC Rcd 19895 (1996); Second  Y#- d(#Further Notice of Proposed Rulemaking, MM Docket Nos. 91222 and 877, FCC 96438"#",-(-(ZZ$"  Y- d(#(released November 7, 1996) (Television Ownership Second Further Notice). We note, here,  Y- d(#our statement in the Television Ownership Second Further Notice, that we would "reserve the  d(#right . . . to invalidate an otherwise grandfathered LMA [local marketing agreement] in  d(#,circumstances that raise particular competition and diversity concerns, such as those that might  Y-be presented in very small markets." Id. at 88.  v 7. In addition, we affirm the staff's decision granting a duopoly waiver based on a  d(# terrainlimited analysis which demonstrates that the overlap between WNNETV and WPTZ(TV)  YN- d(#;is de minimis, i.e., the overlap represents less than one percent of both the area and population  Y9- d(#of the Grade B contour of each station. See Hubbard Broadcasting, Inc., 2 FCC Rcd 7374  Y$ - d(#(1987). As a preliminary matter, we are not swayed by Mt. Mansfield's argument that the  Y - d(#YDivision Letter is inconsistent with our 1990 decision granting the original satellite request for  d(#hWNNETV. According to Mt. Mansfield, the inconsistency lies in the staff's reliance upon the  d(#xterrainlimited analysis to grant the duopoly waiver request at issue here, when, in our 1990  d(#decision, we "specifically rejected" such an analysis, and instead relied on the standard  d(#prediction method and "applied the full waiver analysis." We disagree. Mt. Mansfield's  d(#reliance upon language from our 1990 decision, which it characterizes as a specific rejection of the terrainlimited analysis, is misplaced. In that decision, we said: While [sic] it appears that the terrain between WNNE(TV) and WPTZ(TV) is such that the actual overlap area may be less than that shown utilizing the standard prediction method of Section 73.684 of our Rules, we cannot state that the overlap area will be as small as that shown by the applicants' alternative method.  Y- d(#Taft Broadcasting, 5 FCC Rcd at 6992 n.9. This language merely expressed our deference to  d(#the standard prediction method in light of the particular terrainlimited analysis before us at that  Y- d(#wtime. It had neither the intent, nor effect, of foreclosing our future consideration of alternative  d(#Jmethodology, such as subsequent terrainlimited analyses, to evaluate the overlap area between  d(#WNNETV and WPTZ(TV), or any other two television stations. In this regard, the staff acted  Y^- d(#: appropriately and in a manner consistent with our 1990 decision by reviewing a different terrain d(#limited analysis than the one which we considered in 1990. Here, Heritage Media presented  d(#wthe staff with a terrainlimited analysis which reflected updated population data, refinements in  d(#xLongleyRice terrainsensitive methodology and improvements in computer technology, and,  Y- d(#significantly, the Commission's own terrainlimited analysis confirmed the de minimis nature of  d(#the overlap area. For these reasons, we state now what we could not in 1990, that the overlap  Y - d(#area between WNNETV and WPTZ(TV) is de minimis.  Specifically, the WNNETV predicted  d(#Grade B contour encompasses an area of 26,280 square kilometers, and the WPTZ(TV)  d(#zpredicted Grade B contour encompasses an area of 43,180 square kilometers. The staff  d(#Ydetermined that the Grade B overlap between WNNETV and WPTZ(TV) comprises an area of  d(#218 square kilometers, which is 0.83 percent of the area within the WNNETV predicted Grade  d(#,B signal contour, and 0.50 percent of the area within the WPTZ(TV) predicted Grade B signal  d(#xcontour. In addition, based on 1990 U.S. Census data, the populations within the predicted  d(#Grade B contours of WNNETV and WPTZ(TV) are 639,921 and 568,402, respectively. The"9',-(-(ZZP("  Y- d(#staff's analysis confirmed that the population in the overlap area is also de minimis, finding that  d(#the overlap area contains approximately 1,500 people which represents 0.23 percent of the  d(#Jpopulation within WNNETV's predicted Grade B contour, and 0.26 percent of the population within WPTZ(TV)'s predicted Grade B contour.  Y- v 8. We also find that, having confirmed the de minimis nature of the overlap area, the  d(#Jstaff acted in accordance with Commission precedent and policy by granting a duopoly waiver  d(#hon that basis. Section 73.684(f) of our rules permits the filing of terrainlimited analyses under  YL- d(#certain circumstances, such as those presented in this case.  Ld yO - d(#Zԍ Section 73.684(f) of the Commission's Rules, 47 C.F.R.  73.684(f), allows an applicant to supplement the  d(#required prediction model calculations with an alternative method, such as the terrainlimited analysis at issue here,  d(#in cases where the terrain in the general direction from the antenna site "departs widely from the average elevation of the 3.2 to 16.1 kilometers (2 to 10 mile) sector" used in the prediction method.  In fact, "under Section 73.684(f),  d(#an applicant may make a supplemental terrainlimited contour showing to demonstrate that the  Y - d(#duopoly restriction of Section 73.3555 is inapplicable." Mad River Broadcasting Company, 4  Y - d(#FCC Rcd 6456, 6458 n.3 (1989); see also Kathleen Bailey d/b/a Capital Foothill Broadcasters,  d(#4 FCC Rcd 1429, 1430 n.3 (1989). The Commission has previously used terrainlimited  Y - d(#wanalyses to conclude that no actual overlap exists. See, e.g., John H. Phipps, Inc., 11 FCC Rcd  d(#,13053, 13054 n.1 (1996) (Commission's engineering analysis confirms that, due to intervening  d(#terrain, no actual overlap exists). We believe it would be counterintuitive to interpret Section  d(#73.684(f) as permitting the submission of a terrainlimited analysis to show that the duopoly rule  Y- d(#is inapplicable, i.e., that no actual overlap exists, but not to show that an overlap is de minimis.  Y@- v 9. Once a de minimis overlap has been demonstrated, a duopoly waiver may be granted  Y+- d(#Zon that ground. To this end, we see no reason to treat a de minimis duopoly waiver request  d(#based on a terrainlimited analysis differently from one based on the standard prediction method.  d(#Furthermore, Mt. Mansfield cites no evidence in support of its proposition that the Commission  Y- d(#must conduct an additional public interest analysis in cases where a de minimis overlap has been  d(#,demonstrated by means of a terrainlimited showing. We presume that, when the overlap area  Y- d(#between two television stations is de minimis, the common ownership of the stations will not  d(#result in their serving common areas and populations to any significant degree and, therefore,  d(# that such common ownership will not undermine the concerns that form the basis of our duopoly  Yy- d(#policy. See, e.g., Hubbard Broadcasting, Inc., 2 FCC Rcd 7374. In addition, Mt. Mansfield  d(#fails to persuade us that previous cases in which a terrainlimited analysis showed a greater than  YM- d(#-de minimis overlap, and thus required additional analysis, control here, where a de minimis  Y8- d(#overlap has been demonstrated.  See, e.g., Sunshine Television, Inc., 8 FCC Rcd 4428 (1993).  d(#Rather, those cases support the staff's position that the Commission has previously considered  d(#terrainlimited analyses to determine the overlap area in evaluating duopoly waiver requests.  d(#YFor these reasons, we conclude that the staff properly considered the terrainlimited analysis in  Y - d(#granting the de minimis duopoly waiver request. Accordingly, the demonstration of a de  Y!- d(#minimis overlap between WNNETV and WPTZ(TV) mooted the applicants' initial continued"!,-(-(ZZ""  d(#satellite request for those stations. Likewise, it moots Sinclair's similar request, and, based upon  Y- d(#-the the de minimis nature of the overlap area between the stations, we will grant a duopoly waiver to Sinclair.  v .10. With respect to the discrepancy between the numerical results of the staff's analysis  d(# and those reached in the analysis submitted by Heritage Media, we disagree with Mt.  Yx- d(#Mansfield's conclusion that this deems the analyses inconsistent. Both analyses yield a de  Yc- d(#minimis overlap, the preeminent consistency for our purposes in reviewing the staff's grant of  YN- d(#;a de minimis duopoly waiver. In addition, we are satisfied with the staff's judgment, as stated  Y9- d(#in the Division Letter, that Heritage Media provided sufficient engineering data for the  d(#hCommission to conduct its own study of the overlap area. We therefore reject Mt. Mansfield's assertion that the staff gave no explanation of the data used in its analysis.  Y -  Y - v y11. Mt. Mansfield likewise fails to persuade us that the Division Letter is flawed for not  d(# having explained the methods used in the staff's analysis when, as the expert agency in broadcast  d(#television regulation, the Commission employs sound engineering principles in conducting its  d(#analyses of all technical matters. As the staff correctly noted, moreover, the Commission has  d(#routinely conducted its own technical analyses, at times involving use of the Irregular Terrain  Yn- d(#.Model (ITM), to evaluate de minimis duopoly waiver requests. Here, the staff's analysis  YY- d(#confirmed the de minimis overlap. Mt. Mansfield's dissatisfaction with this result gives us  d(#neither pause nor reason to revise the staff's findings and reach a different conclusion.  Y-- d(#Furthermore, Mt. Mansfield's failure to submit its own technical analysis disputing the de  Y-minimis overlap strengthens our resolve on this matter.  Y- v 12. Finally, our decision to affirm the Division Letter remains unchanged by Mt.  d(#Mansfield's contention that the staff's reliance on its independent terrain analysis, without  d(#providing an opportunity for adversarial review and comment, raises due process concerns. We  Y- d(#recently rejected a similar challenge made by the petitioners in Radio Ingstad Minnesota, Inc.,  Y- d(#KFCC 97199 (released June 17, 1997) (Radio Ingstad) (Commission did not act arbitrarily by  d(#relying on its independent terrain analysis, corroborating existing record evidence, without  d(#wincorporating it into the record and allowing for adversarial comment), and we see no basis for  YQ- d(#Yaccording Mt. Mansfield different treatment in this case. Like the petitioners in Radio Ingstad,  Y<- d(#Mt. Mansfield cites "no authority for the proposition that the Commission cannot resort to its  d(#own expertise under the circumstances presented here without providing for comment . . . ."  Y- d(#/Id. at 8. However, in the interest of providing Mt. Mansfield with a more complete  d(#[understanding of the basis for the staff's conclusions, we have appended to this Order an  Y -explanation of how the staff conducted its independent analysis.  v 13. Upon review of the staff's action, we find that the matters raised by Mt. Mansfield  d(#were fairly, fully and correctly treated. In addition, having determined WNNETV, Inc.,  d(#Rollins Telecasting, Inc. and Tuscaloosa Broadcasting Licensee, Inc. qualified in all respects,  d(#we conclude that grant of the abovecaptioned assignment applications would serve the public interest. "A',-(-(ZZP("Ԍ v 14. Accordingly, IT IS ORDERED, That the application for review and informal  d(#objection filed by Mt. Mansfield Television, Inc. against File Nos. BTCCT970519ZF and BALCT970805KK, respectively, ARE DENIED.  v 15. IT IS FURTHER ORDERED, That a permanent waiver of the television duopoly  d(#rule, 47 C.F.R. Section 73.3555(b), to allow the common ownership by Sinclair Broadcast  d(#Group, Inc. of television stations WNNETV, Hartford, Vermont, and WPTZ(TV), North Pole, New York, IS GRANTED.  v 16. IT IS FURTHER ORDERED, That the application for consent to the assignment of  d(#license of station WNNETV from WNNETV, Inc. to WNNE Licensee, Inc., File No.  d(#;BALCT970805KK, and the application for consent to the assignment of license of WPTZ(TV)  d(#from Rollins Telecasting, Inc. to WPTZ Licensee, Inc., File No. BALCT970805KH, ARE GRANTED.  h qFEDERAL COMMUNICATIONS COMMISSION q qMagalie Roman Salas  Y-qSecretary(#(#  h ",-(-(ZZ"  Y-fAPPENDIXă L Determining Grade B Service Contour Overlap (WNNETV, Hartford, VT and WPTZTV, North Pole, NY)  d(#YThe following analysis concerns an engineering exhibit in the supplemental showing submitted  d(#by HMI Broadcasting Corporation, licensee of WNNETV, Hartford, Vermont. The purpose  d(#is to determine the actual size of the area overlap by the Grade B service contours of WNNETV and coowned WPTZTV.  d(#WNNETV is located 148 kilometers southeast of WPTZTV in the 145-N azimuth. As  d(#Jdetermined by the standard prediction method, the area overlap by the Grade B contours of the TV stations is about 2,400 square kilometers.  d(# We have examined the terrain profiles along seven evenly spaced radials (300-N to 360-N) from  d(#KWNNETV to a distance of 100 km and eight evenly spaced radials (100-N to 170-N) from  d(#WPTZTV to a distance of 100 km using a 3arcsecond terrain database. From observations  d(#of the terrain profiles, there are large mountain ridges in the area between WNNETV and  d(#hWPTZTV. Because a major obstacle is usually the limit of a contour, standard area prediction  d(#<procedures are inaccurate and inappropriate where, as here, the terrain departs widely from average elevations (average terrain conditions).  d(#hFrom pointtopoint field strength calculations based on the path clearance, the Grade B service  d(#contours in the area of interest are limited by the obstructing ridges. When both Grade B  d(#contours stop at the same mountain ridge, there is some minimal overlap area at the top of the  d(#Lridge. It is reasonable to assume that very few TV viewers, if any, are located at rugged mountain peaks.  Y|-Conclusion  d(#The WNNETV predicted Grade B contour encompasses an area of 26,280 square kilometers,  d(# and the WPTZ(TV) predicted Grade B contour encompasses an area of 43,180 square  d(#kilometers. Based on our calculations, the Grade B contours of WNNETV and WPTZTV are  d(#as indicated by the dashed line and dotted line on the attached map respectively. The area  d(#overlap by the predicted Grade B contours is about 218 square kilometers, which is 0.83 percent  d(#of the area within the WNNETV predicted Grade B signal contour, and 0.50 percent of the area within the WPTZ(TV) predicted Grade B signal contour.  d(#YAccording to 1990 U.S. Census data, the populations within the predicted Grade B contours of  d(#WNNETV and WPTZ(TV) are 639,921 and 568,402, respectively. We have determined that  d(#the overlap area consists of two population centers, Granville and Braintree, Vermont.  d(#Granville's population of 309 and Braintree's population of 1,174 yields a total of 1,483 people  d(#in the overlap area, which we have rounded to 1,500. The overlap area population of 1,500  d(#[represents 0.23 percent and 0.26 percent of the population within the predicted Grade B contours of WNNETV and WPTZ(TV), respectively.