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Grade B Coverage  S' ( 15. ` ` All of the parties contest WRNNTV's assertion that it provides Grade B coverage to a  S' !gmajority of the subject communities. Harron states that WRNNTV generalizes the extent of its Grade  !tB coverage and Century/TCI argues that WRNNTV's Grade B contour does not accurately reflect the  Sv' !cstation's local signal quality, which is far from ideal." vX yOn ' !^ РCentury/TCI opposition at Exhibit 4. Century/TCI states that it conducted signal strength studies at TCI's  ! headend facility and a representative sample of communities. It states that these studies reveal that it is highly  ! unlikely that WRNNTV provides an overtheair signal of good quality to individual homes. Moreover, the signal was not detectable in Stockbridge and very poor in the communities of Lenox and Lee. Harron and Century/TCI states that all of the  !communities they serve are outside of WRNNTV's predicted Grade B contour. Time Warner, Adelphia  !kand HearstArgyle argue that although some of the communities they serve fall within WRNNTV's Grade  S ' !B contour, this factor alone is insufficient grounds to grant WRNNTV's request.#^ @ {O' !@ РTime Warner opposition citing Agape Church, Inc., 1999 FCC Lexis at 30; Adelphia opposition citing  {O' !p Channel 33, Inc., 11 FCC Rcd 3579 (citing at 4, H.R. Rep. No. 628, 102d Cong., 2d Sess. 97 (1992)("House  {Or'Report"); HearstArgyle citing Mohawk Valley Broadcasting, Inc., 11 FCC Rcd 12090, 12095 (1996).  Indeed, Adelphia states  !that legislative history governing the modification process shows that ADI boundaries, and not Grade B  S ' !contours, define markets.Y$Z f  {O' ! РSee House Report at 66 ("The Committee believes that ADI lines are the most widely accepted definition  ! of a television market and more accurately delineate the area in which a station provides local service than any arbitrary mileagebased definition.")Y Young points out that approximately 61 percent of the requested communities  !/are not within WRNNTV's Grade B contour. Young maintains that absence of Grade B coverage  S^'militates against grant of WRNNTV's request.%^  {O' !Z РSee, e.g., Channel 17 Associates, Ltd., 11 FCC Rcd 4199, 4207 (1996); and Burnham Broadcasting Co.,  yOP'10 FCC Rcd 7177, 7120 (1995).  S' ( 16. ` ` A majority of the parties raise geographic distance factors in support of their oppositions.  !WRGB states that over 130 of the requested communities are between 45165 miles distant from Kingston,  !WRNNTV's city of license, and that these distances were sufficient for the Commission to deny other  S' !similar requests.$&( {O#' ! РSee e.g., Time Warner Entertainment Co., L.P., DA 97526 (released March 14, 1997)(4668 miles);  {O#' ! Armstrong Utilities, Inc., 12 FCC Rcd 2498 (1997)(3955 miles); Comcast Cablevision of Danbury, Inc., DA 97234  {O$' !M (released February 12, 1997)(42 miles); AR Cable Services, Inc., 11 FCC Rcd 21080 (1996)(48 miles); and Time  {Ov%'Warner Cable, 11 FCC Rcd 13149 (1996)(45 miles). $ Young states that at least 116 of the communities are located farther than 50 miles"&,&&77."  S' !from Kingston.T' yOh'РYoung opposition at Exhibit 2.T Harron, Adelphia, Century/TCI and Time Warner all cite geographic distances as a  S'major factor in WRNNTV's failure to have a nexus with their system communities.(X yO' !M РCentury/TCI opposition at Exhibit 5. Harron opposition at Exhibit 1. Adelphia opposition at Exhibit C. Time Warner opposition at Attachment 2.  S' ( 17. ` ` One party, WNYT, argues that WRNNTV's predicted service area using the LongleyRice  S`' !method is substantially less than the station's calculated Grade B contour.Q)` yO 'РOpposition at Attachment A.Q WNYT asserts that hilly  S8' !topography precludes offair reception of WRNNTV in much of the area in which it seeks carriage.  !Indeed, WNYT maintains that the Albany region's topography prevents WRNNTV from being received  S' !Dat least 99 percent of the communities.G*@ yO 'РOpposition at 10.G WNYT states that in Costa de Oro, Inc., the Commission based  !its partial denial of the requested modification on the fact that opponents to the petition had provided  S'evidence that there was no viewable overtheair signal within the applicant's predicted Grade B contour.S+ yO 'Р13 FCC Rcd 4360, 4374 (1998).S  SJ ' D. Local Programming  S ' ( 18. ` ` At least half of the parties state that WRNNTV provides no evidence of relevant local  !programming, while the remainder state that any programming that WRNNTV does provide is minimal  !at best, and in general, of more widespread than specific interest. For instance, Century/TCI states that  !the two news items WRNNTV attributes to Scotia, New York, do not target specific TCI communities.  SZ' !Harron states that WRNNTV lists only one news story involving only one out of 28 Harron system  !*communities. Adelphia points out that WRNNTV's own exhibit reveals that in over 3 years, WRNNTV  S ' !hhas carried only one story about Adelphia communities.L, `  yO 'РPetition at Exhibit 4.L Adelphia states that in Home Link  S' !Communications of Princeton, the Commission concluded that WRNNTV's claim to "seven to eight  !Isubstantial news stories per day" was insufficient to prevent it from being excluded from the cable  S' !7communities that were within its ADI.S-  yO&'Р13 FCC Rcd 1578, 1584 (1997).S HearstArgyle states that there are only 3 news stories cited that  !"even remotely relate to its system communities. WNYT states that the bulk of the program listing  !tprovided by WRNNTV is targeted to the Catskill area, which includes the areas closest to WRNNTV  S' !xand where it is already carried.G.  yO>#'РOpposition at 11.G WRGB points out that half of the 87 news reports claimed to be Albany !based are issues of statewide interest involving state politics or professional sports while the remaining" .,&&77"  S' !79, for areas outside Greene and Columbia counties, relate to only 16 of the total communities.F/ yOh'РOpposition at 9.F Young  !xconcludes that the programming information provided by WRNNTV has gaping holes in its asserted local  !Mcoverage and many of the core market communities, such as Schenectady and Troy, have never been provided any local coverage.  S8' E. Coverage by Other Local Stations  S' ( 19. ` ` Many of the parties argue that the instant communities already receive ample local  !gprogramming from the stations they currently receive. Adelphia states that it carries seven must carry  !stations, all licensed to communities closer than Kingston, which provide its subscribers with more focused  Sp' !local programming.G0pX yOh 'РOpposition at 12.G Harron states that it carries 13 stations licensed to communities closer than  SH ' !Kingston, seven of which provide daily local coverage.N1H  yO'РOpposition at Exhibit 2.N WRGB states that not only is WRNNTV's  !absence of local programming in stark contrast to the presentation made by other stations, but it makes  S ' !7no claim that other stations fail to provide local programming.G2 x yO'РOpposition at 11.G WNYT argues that WRNNTV is wrong  !Din its assertion that programming by other stations is irrelevant. WNYT states that while the Commission  !has interpreted this provision as an "enhancement factor," petitioners still bear the burden of persuasion  S ' !tin demonstrating why the Commission should redraw established boundaries.o3  {O('РSee Channel 33, Inc., 11 FCC Rcd 3579, 3582 (1996).o WNYT concludes that WRNNTV's failure to do so demonstrates that it has not met its burden of persuasion.  S' F. Other Arguments  S' ( 20. ` ` Several of the parties object to WRNNTV's request because, if granted, WRNNTV will  !be carried in the core of the Albany market. This they maintain would eliminate the existence of two  !different markets rather than represent a modification as contemplated by the rules. Time Warner states  !that WRNNTV seeks to invade the heart and fringes of the adjacent Albany ADI. Indeed, Time Warner  !points out, WRNNTV's request encompasses all 14 counties comprising the Albany market. WRGB  !@asserts that there is no basis for granting WRNNTV such broad must carry rights outside its market,  !psimply because it has lost ground in its market, particularly when it has made no effort to serve the  !requested area. Adelphia maintains that, in essence, WRNNTV is asking the Commission to extend its  !_market beyond the over 2 million households it is currently eligible to serve because its Grade B  !encompasses some of the subject communities. However, Adelphia argues that a grant of WRNNTV's  !request would be tantamount to a complete redrawing of the New York and Albany ADI boundaries,"( 3,&&77"  S' !something the Commission has made clear is well beyond its intended bounds.4 {Oh' !8 РSee e.g., Agape Church, Inc., DA 99276 (released February 3, 1999), 30 ("[T]he importance of  {O2' !k maintaining the integrity of the basic structure of an ADI market is also a prime concern."); Channel 33, Inc., DA  !7 98317 (released February 20, 1998), 22, ("In granting the Commission authority to modify market areas to better  ! effectuate the purposes of Section 614, the Congress manifested no intent for us to alter the basic structure of an ADI  {O'market by including its core another ADI market."); and WTVT License, Inc., 11 FCC Rcd 18020, 15 (1996). Adelphia points out  !further that WRNNTV's claim of losing 70 percent of its market to adverse decisions obscures the fact  S' !*that in a market such as New York, with 6,749,500 TV households, a 70% reduction still leaves WRNN S' !TV with 2,024,850 households.D5~ yO 'РPetition at 4.D Adelphia argues that, with the exception of 4 ADIs, a market of over 2 million homes is larger than nearly every other ADI in the country.  S' ( 21. ` ` Harron argues that it is ironic that WRNNTV relies on previous Commission decisions  !ywhich imply that the station may "more aptly serve Albany and its environs" when it has always  S' !uvehemently opposed any suggestion of doing so.D6 yOn'РPetition at 3.D Indeed, Harron points out, in Home Link  S' !Communications of Princeton, L.P. and ComVideo Systems, Inc., WRNNTV argued the opposite when  !Dit "urge[d] that this . . . statement was incorrect and that the Commission wrongly stated that Nielsen has  SL ' !3assigned WRNN to the Albany DMA."S7L  yO'Р13 FCC Rcd 1578, 1590 (1997).S In any event, WRGB argues that the quote WRNNTV relies  !@on herein about serving the Albany market was taken out of context and is misleading. WRGB states  !that in the case from which it was cited, WRNNTV lost "must carry" rights in New Jersey cable  S ' !communities served by Comcast Cablevision.8 .  {O'РSee Comcast Cablevision of Monmouth County et al., 11 FCC Rcd 6440, 6450 (1996). WRGB indicates that the basis for comparison appears  !to have been Comcast's pleading, in which it claimed that WRNNTV "provides coverage of importance  !to its local viewers in the upstate New York counties of Ulster and Dutchess, instead of providing local  S\'service and coverage of the New York City area."?9\  {O'РId.?  S ' ( 22. ` ` A majority of the parties point out that the advertising revenue information provided by  !WRNNTV is inadequate to measure the station's importance in the Albany market. Time Warner states  !that WRNNTV does not indicate the relative importance of the advertising revenue it receives from the  !Albany market in relation to its overall advertising sales. WRGB argues, therefore, that there is no basis  !*for comparison with the advertising revenues from WRNNTV's home market. Moreover, Time Warner  !Qargues that all or a substantial percentage of the Albany market revenue of WRNNTV could be attributed  !solely to advertisers located in Greene and Columbia counties. Century/TCI, WRGB, and Harron argue  !Dthat WRNNTV fails to break down the advertising revenue by community or county and it is too general  !to demonstrate any nexus to the communities. WNYT states that the revenue data reveals nothing about  !tWRNNTV's audience and that it reflects the fact that some businesses in the Albany market also have  !kbusinesses in the Kingston area. Finally, both Time Warner and WNYT point out that the total advertising"| R 9,&&77"  !<revenues reported by WRNNTV dropped significantly from 1997 to 1998, suggesting a decline in  S'WRNNTV's status.S: yO@'РPetition at Exhibits 5 and 6.S  S' ( 23. ` ` Finally, Adelphia argues that since all of its affected cable systems are channellocked,  !&grant of WRNNTV's petition would result in the deletion of popular cable programming valued by its  !subscribers. Since its subscribers already receive Albany must carry stations and a New York City station  !Mvia retransmission consent, Adelphia maintains that a grant of the instant request would undermine the Commission's longstanding policy of increasing program diversity.  S' ( ~24. ` ` In a consolidated reply, WRNNTV maintains that it meets the four statutory factors and  !that grant of its petition is warranted. WRNNTV states that not only is it historically carried on several  !cable systems serving communities in Albany, Columbia, Greene and Schoharie counties, but several  S ' !Albany ADI stations are carried on cable systems near Kingston and other communities in the New York  S ' !market.I; X yO'РReply at Exhibit B.I Indeed, WRNNTV points out that the Grade B coverage contours of Albany stations WTEN,  !WRGB, WNYT and WMHT reach well into the New York ADI from their respective communities of  S ' !*license.G<  yO0'РUp to 81.8 miles.G Therefore, WRNNTV argues, these stations are direct competitors who have the advantage in  !Zthat they qualify for carriage throughout the Albany ADI. Since the arguments of WTEN, WRGB and  !DWNYT directly contradict their current carriage outside the Albany market, WRNNTV asserts that these  !targuments should be disregarded. Further, while Adelphia and WRGB criticize WRNNTV for its lack  !of widespread cable carriage in the Albany market, despite being licensed since 1985, WRNNTV points  !Zout that it only acquired its current owners in December 1994 and its current format in October 1995.  ! WRNNTV maintains that its voluntary carriage on several Albanybased cable system is "convincing  S'evidence that the [S]tation's programming is of particular interest to viewers in the area."=x {O'РReply at 6. See DP Media License of Battle Creek, Inc., 13 FCC Rcd 7122, 7127 (1998).  S@' (  25. ` ` WRNNTV argues that it has satisfied the second statutory factor because many of the  S' !requested communities are located within the station's City Grade, Grade A and Grade B contours.I>  yO'РReply at Exhibit D.I  !Moreover, WRNNTV states that the Commission has also concluded that cable communities that lie on  !the fringe of the Grade B contour of a given station or close to the station in terms of mileage may be  S' !^appropriately included within a station's local market.? {O!' ! РSee Bay Television, Inc., 13 FCC Rcd 7209, 7215 (1998); DP Media of Martinsburg, Inc., 13 FCC Rcd 2123, 2131 (1998). WRNNTV states that several of the communities  !are located on the fringe or in close proximity to the Grade B contour in terms of mileage, including  !tSchenectady, which is within a mile of the Grade B and Bennington which is partially within the Grade  !B. In addition, despite the assertions of several parties, WRNNTV states that recently performed signal"( ?,&&77~"  !strength tests indicate that a good quality signal is delivered to test points in Albany, Troy, Schenectady,  S' !Rensselaer, Bennington, Pittsfield, Lee, and the Fly Summit Mountain, New York area.I@ yO@'РReply at Exhibit E.I WRNNTV  !maintains that there are no natural barriers to prevent it from providing coverage to the subject  !communities. Indeed, it asserts that the Hudson Valley, which runs northsouth within its coverage area  !Vfrom Kingston to Albany and beyond, provides a natural geographic tie between the station and the communities.  S' ( 26. ` ` In addition to the programming examples it submitted in its petition, WRNNTV states  !3that it includes Albany traffic and weather reports, which are updated every ten minutes, in each daily  S' !newscast. WRNNTV states that it also has Albany news listed on its website.DAX yO 'Рwww.rnntv.com.D While WRNNTV  !gadmits that for any station located near a state capital it is to be expected that many of the stories aired  !^will be of interest to residents throughout the state, it disputes the contention raised in the oppositions that  !"its programming is more general in nature and not communityspecific. WRNNTV states that its  !commitment to providing local service to the Albany market is shown by the establishment of a separate  !8news bureau to serve that area. WRNNTV states that it is also arranging to provide live news  !programming for carriage on the New York Network/State University of New York's ("NYN") "Capital  !Network." It points out that no other Albany television station's news is carried on NYN or provides the amount of regional news, public affairs or community interest programming that WRNNTV provides.  S' ( #27. ` ` WRNNTV reargues that the third statutory factor regarding coverage by other stations  !is inapplicable to this proceeding and it urges that the relevant arguments raised by the opposing parties  !should be disregarded. Further, despite the claims of the opposing parties, WRNNTV asserts that it has  S' !measurable viewer ratings in the Albany market, as evidenced by the February 1999 Nielsen report.IB yO'РReply at Exhibit I.I  !WRNNTV states that, assuming that the 7.4% cume rating attributed by Young's opposition to WRNN !TV in Columbia is correct, it is interesting to note that comparable ratings for CNN, MSNBC and FOX  S' !News for the same period are significantly lower.Cx yO0' !M РWRNNTV states that CNN's rating is listed as 5.86 percent, MSNBC's as 0.71 percent, and FOX News as 5.4%. WRNNTV continues that since nearly three quarters,  !*or 74 percent, of the Albany market households subscribe to cable, they cannot for all practical purposes  !receive its signal overtheair. Therefore, WRNNTV argues, unless it receives cable carriage, the vast  !majority of viewers in the Albany ADI are not able to watch its station even if they would like to do so.  !Indeed, WRNNTV states that in situations where a station has gained cable carriage in a heavilycabled  !market, it has generated measurable ratings. For this reason, WRNNTV states that the Commission should not penalize it for lower ratings in the heavilycabled Albany market.  S' ( 28. ` ` While WRGB denounces the 1989 finding of WRNNTV as significantly viewed in  !Columbia and Greene counties as outdated and irrelevant, WRNNTV maintains that the information  !Qremains accurate and an important consideration in the modification proceeding. If nothing else, WRNN" C,&&77"ԫ !TV argues that WRNNTV's significantly viewed status in Greene and Columbia counties favors the  !addition of at least the communities within those counties. Further, WRNNTV states that it is not only  S' !*listed in the "On TV" guide provided by the Times Union, but also the Albany edition of TV Guide, which  !is available in the Albany market for all viewers. WRNNTV argues that these listings indicate that  !Albany area viewers value its presence in their market. With regard to advertising revenues, WRNNTV  !Qstates that because several oppositions criticized it failure to break down the businesses that advertised on  S'its station, it has provided a list herein that does so.ID yOz'РReply at Exhibit K.I  S' ( ~29. ` ` Finally, WRNNTV states that WNYT's cite to Channel 39, Inc., urging the Commission  !to deny the instant request because it encroaches on the core of the Albany market is misplaced and out  St' !of context.SEtX yOl 'Р13 FCC Rcd 3108, 3117 (1998).S WRNNTV states that a review of the Channel 39 decision indicates that if the Commission  !had granted Miami station WBZL's request to expand into the West Palm Beach ADI, it would have had  !to grant the inevitable requests filed by the seven other Miami stations broadcasting from the same antenna  !farm north of Miami. Such a result would have altered the West Palm Beach ADI by essentially merging  S ' !tit with the Miami ADI, an outcome not intended by Congress. In contrast, WRNNTV argues that the  !7addition of one independent station, isolated from the core of its own ADI, to the core of the Albany ADI  !will hardly impact, much less alter the basic structure of that market. WRNNTV contends that, despite  !cits inclusion in the New York ADI, it is tied to the Albany market in several important ways: a) the  !7Hudson River creates a natural valley which connects Kingston with Albany; b) commuters and residents  !routinely travel between the two areas via Interstate 87 and the Taconic State Parkway; c) businesses in  !gthe Hudson Valley area near Kingston routinely advertise through Albanymarket media and vice versa;  !and d) Albany market stations are carried on several cable systems located near Kingston. Given these facts, WRNNTV concludes that the Commission should grant its request.  SF' IV. DISCUSSION  S' ( 30. ` ` WRNNTV is seeking to add 219 communities located in 14 counties in New York,  !Massachusetts and Vermont to its New York ADI. WRNNTV argues that it sufficiently meets the criteria  !with regard to local service and local programming to be considered a local station for the communities  !gin question. The opposing parties deny this. Based on our analysis of the evidence relating to the four statutory and other relevant factors, WRNNTV's petition will be granted in part and denied in part.  S' ( 31. ` ` New York is the nation's most populous television market. Geographically, the market  S' !encompasses some 29 counties in four states.F yOf!' !t РThe following counties are located in the New York ADI: (1) Pike County, PA; (2) Fairfield County, CT;  !D (3) Ocean County, NJ; (4) Monmouth County, NJ; (5) Middlesex County, NJ; (6) Somerset County, NJ; (7) Union  ! County, NJ; (8) Hudson County, NJ; (9) Essex County, NJ; (10) Hunterdon County, NJ; (11) Warren County, NJ  ! (12) Sussex County, NJ; (13) Morris County, NJ; (14) Passaic County, NJ; (15) Bergen County, NJ; (16) Suffolk  !g County, NY; (17) Nassau County, NY; (18) Westchester County, NY; (19) Rockland County, NY; (20) Putnam  ! County, NY; (21) Dutchess County, NY; (22) Orange County, NY; (23) Ulster County, NY; (24) Sullivan County,"N%E,&&O%"  ! NY; (25) Queens County, NY; (26) Kings County, NY; (27) Richmond County, NY; (28) New York County, NY; and (29) The Bronx, NY. It is roughly 170 miles long and 150 miles wide," F,&&77"  !pstretching north into Ulster County and the Catskill Mountains and down to the New Jersey coastal  !counties of Monmouth and Ocean in the south; Pike County, Pennsylvania is at the westernmost edge of  S' !3the market which then extends eastward to include Fairfield County, CT and all of Long Island, NY.G   yOp' ! РThe AlbanySchenectadyTroy ADI abuts the New York ADI to the north; the HartfordNew Haven ADI  !k abuts the New York ADI to the east; the Philadelphia ADI abuts the New York ADI to the southwest; the Wilkes  ! BarreScranton ADI abuts the New York ADI to the west; and the Binghamton ADI abuts the New York ADI to the northwest.  !WRNNTV, licensed to Kingston, New York, signed ontheair in 1985 as WTZA, and broadcasts on  S`' !Mchannel 62 from a transmitter located on Overlook Mountain in Woodstock, New York.bH` yO 'РWoodstock is 10 miles northwest of Kingston.b Albany, the  !kmarket in which all of the requested communities are located, is, in terms of population and size, less than  !khalf that of New York, encompassing only 14 counties in three states. The requested communities range,  !on average, anywhere from 14 to 129 miles away from Kingston, WRNNTV's city of license. The  !relationship of many of the requested communities is affected by such natural barriers as the Catskill Mountains.  SH ' (  32. ` ` Historic Carriage. While WRNNTV does have a history of carriage on five cable  !gsystems serving communities located in Columbia, Greene, Albany and Schoharie counties, there is no  S ' !evidence that it is carried on nearby cable systems serving the remainder of the requested communities.I   yO0' !t РPetition at Exhibit 2. The majority of communities served are located in Greene and Columbia Counties.  ! Four communities at the southern end of Albany County are served by a system which also serves communities in  ! Greene and Columbia Counties (MidHudson Cablevision) and three communities in Schoharie County are served by Milestone Communications.   !&While carriage on nearby cable systems is not a factor specified in the statute, such carriage has been  !considered as demonstrating that the station at issue has a nexus with other nearby communities. In this  !instance, nearby carriage has not been demonstrated. It should also be noted that WRNNTV appears to  !}be listed only in general distribution newspapers serving Greene and Columbia Counties, the Albany  S0'edition of TV Guide and the "On TV" guide provided by Albany's Time Union newspaper.  S' ( 33. ` ` Viewership. WRNNTV has been operating as a fullpower television station since 1985.  !It was able to achieve significantly viewed status in Columbia and Greene counties based on viewership  S' !levels it achieved within its first three years of operation.J  yO ' !D Р1997 A.C. Nielsen information indicates no viewership for WRNNTV in Greene County, and that reported for Columbia County, falls below the significantly viewed threshold. WRNNTV is not considered to be  !*significantly viewed in any of the other instant counties nor, except for Columbia County, does it achieve"jJ,&&77"  S' !any ratings in the subject counties.K yOh' !M РNielsen's 1997 County/Coverage Study indicates that WRNNTV achieves viewership levels of 1/10 in Columbia County. We note that, due to its allnews format, WRNNTV may have less opportunity to attract viewership than a typical commercial station.  S' ( 34. ` ` Local Programming. WRNNTV contends that its all news program format provides  !Mvaluable programming services to the instant communities. However, we are not convinced that such  !^programming, while of potential general interest, is the kind that suggests that the requested communities,  !in total, are a particular focus of the station or are in any sense served in a manner that establishes a specific market connection.  S' ( 35. ` ` Coverage by Other Stations. In general, in instances where other stations eligible to be  !carried serve the communities in question, we do not believe that Congress intended this criterion to  !/operate as a bar to a station's ADI claim whenever other stations could also be shown to serve the  !communities at issue. Rather, we believe that this criterion was intended to enhance a station's claim where it could be shown that other stations do not serve the communities at issue.  S ' ( 36. ` ` Station Coverage of Communities. With respect to coverage, the Commission stated in  S ' !*its Must Carry Order, supra, that "to show that the station provides coverage or other local service to the  SZ' !cable communities, parties may demonstrate that the station places at least a Grade B coverage contour  S2' !over the cable communities or is located close to the community in terms of mileage."ML2  yO'Р8 FCC Rcd at 29762977.M WRNNTV  !claims that its predicted Grade B contour encompasses the majority of the requested communities. Our  !Zreview, however, indicates that less than half of the subject communities either lie within or are on the  !fringe of WRNNTV's Grade B contour. Moreover, we note that a LongleyRice propagation study  !"submitted by WNYT indicates that even within its predicted Grade B contour, WRNNTV's signal  !Zprovides spotty coverage in some areas and virtually no signal is provided in areas outside the station's Grade B contour.  S' V. CONCLUSION   S' ( 37. ` ` In reaching our conclusion, we have considered the statutory factors as well as other  !relevant information. WRNNTV has limited historic carriage in 36 of the 219 communities in question  !(factor I), provides little specificallydirected local programming to the communities (factor II), and has  !Dmeasured audience in only one of the counties in which the communities are located. Given the statutory  !directive, weight must be given to these factors, but that must be done bearing in mind that the objective  !of the Section 614(h) process is to "better effectuate the purposes" of the broadcast signal carriage scheme.  !Thus, with respect to the question of historical carriage patterns, attention must be paid to the  S' !Dcircumstances from which such patterns developed. Some stations have not had the opportunity to build  ! a record of historical carriage for specific reasons that do not necessarily reflect a judgment as to the  !geography of the market involved. Given the age of WRNNTV and the terrain involved, however, that does not appear to be the circumstance here. " L,&&77"Ԍ S' ( 38. ` ` Given the difficulties of relying exclusively and explicitly on the statutory factors of  !historical carriage and viewing patterns, which in certain circumstances could severely narrow the carriage  !^rights of stations even within what is undeniably their local market area, we have found it helpful to focus  !also on factors that are less influenced by the type of station involved or historical carriage, especially in  S`' !instances such as here when the station had a specialty format.xM` {O'РSee Cablevision Systems Corp., 11 FCC Rcd 6453, 6474 (1996).x The scope of a local station's market may  !be measured through geographic means by examining the distance between the station and the cable  !Zcommunities subject to the request and by taking into account natural phenomena such as waterways,  !mountains, and valleys that may tend to separate communities and define natural markets basic  !geographic, demographic and political features that provide the best available evidence of the market  !Mboundaries of the stations involved. In the absence of other information, station service contours also  Sp' !provide at least one objective measure of the scope of a station's local market.]NpZ yOj ' ! РAs a general matter, Grade B coverage demonstrates service to cable communities and serves as a measure  {O2 ' !* of a station's natural economic market. See MM Docket No. 92259, 8 FCC Rcd at 2977. See also Amendment of  {O ' !D Section 76.51 (OrlandoDaytona, Melbourne, and Cocoa, Florida), 102 FCC 2d 1062, 1070 (1984) ("We believe  ! that television stations actually do or logically can rely on the area their Grade B contours for economic support.")] In the case herein, we  !&find that, in view of the natural barriers inherent in the region in which the requested communities are  !located, WRNNTV's predicted Grade B contour alone cannot be relied on as an accurate representation  !kof the station's actual overtheair coverage or the scope of its market. LongleyRice propagation studies,  !&however, take such factors as terrain into account and can be of help in determining a station's actual  !^service area. Moreover, since such studies have been used in a variery of contexts, including both analog  !&and digital television, and are generally useful in demonstrating the effects of irregular terrain, we find  !their use of probative value in modification cases. We therefore accept WNYT's LongleyRice submission as supporting evidence in this case.  S' ( 39. ` ` Upon review, we do not agree with WRNNTV that it provides a Grade B or better signal  ! to a majority of the communities. Relying solely on WRNNTV's Grade B coverage, it is evident that  !only five of the 14 counties are encompassed by the station's Grade B contour, either wholly or in major  Sh' !Qpart.Oh yO'РGreene, Columbia, Albany, and Rensselaer, New York, and Berkshire, Massachusetts. In addition, small portions of two other counties lie just within the Grade B contour.cPh yO'РSchoharie, New York, and Bennington, Vermont.c That leaves  !7 counties, and the majority of two others, completely outside WRNNTV's Grade B contour. If one looks  !kat the LongleyRice propagation study presented, WRNNTV's coverage shrinks even further. Outside of  !Columbia County and portions of Greene and Rensselaer County, WRNNTV's coverage appears spotty  !at best, while the majority of counties appear to receive no Grade B service at all. Such spotty coverage  !Vis a clear indication that the natural barriers found in a majority of the region precludes overtheair  ! reception of WRNNTV's signal in all but a few instances. Adding this factor to WRNNTV's lack of  !historic carriage in a majority of the communities, and its general lack of specific programming and  !viewership, we conclude that it cannot be used to justify grant of WRNNTV's request for communities  !located in the counties of Rennselaer, Saratoga, Schoharie, Albany, Montgomery, Fulton, Schenectady,". P,&&77'"  S' !Washington, Hamilton, and Warren, New York; Berkshire, Massachusetts; and Bennington, Vermont. For  !*communities in the counties of Greene and Columbia, New York, however, the factors weigh in favor of  !a grant, particulary given the close geographic distance and historic carriage. Moreover, WRNNTV  !appears to provide a consistent overtheair signal to this region. In addition, while we decline to grant  !cWRNNTV its request relative to all of the requested communities in the counties of Schoharie and  !}Albany, New York, we grant WRNNTV's request with regard to the six communities in these two  !7counties in which it is historically carried. Those communities are Bethlehem, Coeymans, Ravena Village  !Dand Westerlo in Albany County, and Summit and Jefferson in Schoharie County. In general, we find that  !the areas we grant today, where WRNNTV is historically carried, defines the limit of their market to the  !southernmost portion of the Albany ADI. Because the counties of Greene and Columbia and the six  !specified communities cannot be said to constitute the core of the Albany market, there is little danger that  !7the limited grant of must carry rights to WRNNTV will pose serious harm to the structure of the Albany market as a whole.  S ' VI. ORDERING CLAUSES  S ' ( 40. ` ` Accordingly, IT IS ORDERED , pursuant to 614(h) of the Communications Act of 1934,  !as amended, 47 U.S.C. 534(h) and 76.59 of the Commission's Rules, 47 C.F.R. 76.59, that the petition  S0' !for special relief (CSR5392A) filed on behalf of WRNNTV Associates Limited Partnership IS  S' !pGRANTED IN PART with respect to the communities of Bethlehem, Coeymans, Ravena Village  !7Westerlo, Summit, Jefferson, Durham, Athens Village, Athens, Cairo, Catskill Village, Catskill, Coxsackie  !VVillage, Coxsackie, Greenville, New Baltimore, Tannersville Village, Hunter, Hunter Village, Jewett,  !tLexington, Claverack, Gallatin, Greenport, Hudson, Livingston, Philmont Village, Stockport, Clermont,  !3Germantown, Ancram, Chatham Village, Chatham, Austerlitz, Canaan, Hillsdale, Ghent, Copake, New  S@' !Lebanon, Kinderhook Village, Stuyvesant Village, Valatie Village, and Kinderhook, New York, and IS  S'OTHERWISE DENIED.  S' ( 41. ` ` This action is taken pursuant to authority delegated by Section 0.321 of the Commission's  S'Rules.JQ yO'Р47 C.F.R. 0.321.J ` `  ,hh]FEDERAL COMMUNICATIONS COMMISSION ` `  ,hh]William H. Johnson ` `  ,hh]Deputy Chief, Cable Services Bureau ` `  ,hh] h S'X` hp x (#%'0*,.8135@8: