WPCG 2BVTZ 3|C)?xxx,/Xx6X@DQX@HP LaserJet IIISiroom 555A LPT2HPLAIISI.WRSx  @,,,?"LX@2@@P3 Z3|C"5@^*7DTT77T^*7*/TTTTTTTTTT//^^^Jxooxf\xx7Axfxx\xo\fxxxxf7/7NT7JTJTJ7TT//T/TTTT7A/TTxTTJP!PZ*7777BE7TTxJxJxJxJxJooJfJfJfJfJ7/7/7/7/xTxTxTxTxTxTxTxTxTxTxJxTxTxTxTxT\TxTxJxJoJoJoJfJfJfJxTxTxxTxTxTxTBT7T777TAxTf/fExTxTxTxo7oE\A\AN:*KT7JTTTTT.3}}T2T}277JJT77TT7J72t7[[[[^ee*B`^-wSTTn[Cfx`xWkRx[\[ceIfIs`Wx[rriwhe*7DTT77T^*7*/TTTTTTTTTT//^^^Jxooxf\xx7Axfxx\xo\fxxxxf7/7NT7JTJTJ7TT//T/TTTT7A/TTxTTJP!PZ7TJTT7\777JJ:T7A7xx*7TTTT!T7.T^7TB[227`K*723T}}}Jxxxxxxoffff7777xxxxxxx^xxxxxx\TJJJJJJoJJJJJ////TTTTTTT[TTTTTTTTimes New Roman (TT)Times New Roman (Bold) (TT)HP LaserJet IIISiroom 555A LPT2HPLAIISI.WRSC\  P6Q,,,?"LP2O@@) @i  I. A. 1. a.(1)(a) i) a) 1. 1. 1. a.(1)(a) i) a)"5@^2Boddȧ8BBdr2B28ddddddddddBBrrrdzNdzoȐB8BtdBdoYoYBdo8Bo8odooYNBodddYO,Oh2BB!BBPRBdodddddȐYYYYYN8N8N8N8oddddooooddoddddzodddYYYYYYddddooPoNoNBNodo8RoodȐYYoNoNNF2ldBddddddd<d<BBYYdBBddBYBdYzzzzBBBBqodYYYYYYYYYYY8888dddddddnddddddd"5@^*7\TT/77T_*7*/TTTTTTTTTT77___TxoxxofAToxfx\oxxxxo7/7aT7T\J\J7T\/7\/\T\\JA7\TxTTJB%BW*7777BE7T\xTxTxTxTxTxxJoJoJoJoJA/A/A/A/x\TTTTx\x\x\x\xTxTx\TTxTxTf\xTxTxTxJxJxJoJoJoJTTTT\\B\A\A7A\T\o/oEx\x\TxxJxJ\A\AN:*ZT7TTTTTT27}}T2}}T}277TTT77TT7T72t7[[[[_ee*B`_-wSTTn[Cfx`xWkRx[\[ceIfIs`Wx[rriwhe*7\TT/77T_*7*/TTTTTTTTTT77___TxoxxofAToxfx\oxxxxo7/7aT7T\J\J7T\/7\/\T\\JA7\TxTTJB%BW7TTTT7\777TT:T7A7xx*7TTTT%T7}2T_7}TB[227`Z*727T}}}TxxxxxxxooooAAAAxx_xxxxxf\TTTTTTxJJJJJ////T\TTTTT[T\\\\T\2Z@5^u@3y.C8*,/C\  P6QP.47UC2,XU4  pQX57PC2,CXP\  P6QXP.6y.G8*,`G4  pQ7RydK,'y\  P6QP8W!0(,߳h0\  P6QhPI(!,ϯ,(\  P6Q,P"5@^(1<reallotment request will not deprive the community of an "existing service", citing Midway,  X - xMPanacea and Quincy, Florida, 10 FCC Rcd 6112 (1995); Sanibel and San Carlos Park, Florida,  X- x10 FCC Rcd 7215 (1995); Pawley's Island and Atlantic Beach, South Carolina, 8 FCC Rcd 8657  x(1993). Rather, petitioner asserts, the two communities will continue to receive the same number  xxof aural broadcast services. Further, petitioner reports that as both communities presently receive  xat least two fulltime aural broadcast services, no white or gray areas exist. Petitioner concludes  xthat its proposal will serve the public interest by providing a first local broadcast outlet to Leupp to address the specific needs of a large Navajo population at that community.   ?x4. Pursuant to Commission policy, if a proponent intends to move its authorized facility  xto a community that is adjacent to an urbanized area and its intended operation would place a  xcity grade (70 dBu) signal over 50% or more of the urbanized area, the petitioner is required  xto demonstrate that the intended city of license is sufficiently independent of the central city to  X- x.justify a first local service preference. See Headland, Alabama and Chattahoochee, Florida, 10  x/FCC Rcd 10352 (1995). In this instance we note that Leupp is located adjacent to Flagstaff,  Xe- xArizona, an urbanized area.,Xe  yO6- x=ԍAccording to U.S. Census Bureau data, portions of Flagstaff, Arizona, became an urbanized area in 1996.  xLHowever, remote and thinly populated areas in Flagstaff were not encompassed within the boundaries of the urbanized area. , Further, our engineering analysis reveals that if Channel 255C is  xkallotted to Leupp, Station KBDT(FM) will provide a 70 dBu signal over 90% of the Flagstaff  xKurbanized area. Therefore, the petitioner's request to change its community of license is subject  X - x=to the provision of additional information responsive to a Tuck analysis to determine whether  xLeupp is sufficiently independent of Flagstaff to merit a first local service preference or whether" @,''""="  X- xit should be credited with all of the authorized services in the Flagstaff urbanized area.  yOy- xԍSee Huntington Broadcasting Co. v. FCC, 192 F.2d 33 (D.C. Cir. 1951), RKO General, Inc. ("KFRC"), 5 FCC  yOA- xRcd 3222 (1990), and Faye and Richard Tuck  ("Tuck"), 3 FCC Rcd 5374 (1988). In KFRC and Tuck, the  xCommission clarified the type of evidence to consider in determining whether a suburban community deserves a  xfirst local service preference by relying on three factors: (1) signal population coverage; (2) size and proximity of  xthe suburban community relative to the adjacent community; and (3) the interdependence of the suburban community with the central city.   xAdditionally, we request the petitioner to provide additional information regarding the public  xinterest benefits that would result from the reallotment of Channel 255C from Oraibi to Leupp,  x Arizona, since it proposes no reception change in the present technical facilities of Station  xKBDT(FM) to accommodate its proposal. In this regard we note that operation with existing  xjauthorized facilities from its present site would result in Station KBDT(FM) providing a 70 dBu  Xv-signal over the entire boundaries of Leupp.SXv@ yOg - xԍThe authorization issued to the petitioner for Station KBDT(FM) (BPH961113MB), describes its transmitter  xlocation as: "on a peak within the Newberry Mesa, on the Navajo Indian Reservation, 6.0 kilometers west of State Highway 99, Leupp, Navajo County, Arizona". S   {x5. In view of the above, we are unable to determine whether petitioner's proposal would  xzresult in a preferential arrangement of allotments. However, we do believe that the proposal  x=warrants consideration since the requested allotment of Channel 255C to Leupp could provide  xthat community with its first local aural transmission service, provided there is a satisfactory  xzdemonstration of its independence from the Flagstaff urbanized area. We also note that the  xpetitioner's proposal, if granted, would deprive Oraibi of its sole local authorization as  xyKBDT(FM) is the only station authorized to serve the community. While we carefully evaluate  xa proposal that would result in a loss of existing reception service, in this instance Station  xKBDT(FM) is not constructed. Therefore, we do not consider its removal from Oraibi to present  xthe parallel concerns with loss of service represented by the removal of an operating station, as  Xb- xit does not constitute a service the public has become reliant upon. See Sanibel and San Carlos  XK- xPark, Florida, supra; Pawley's Island and Atlantic Beach, South Carolina, supra; and Glencoe and  X4- x[LeSueur, Minnesota, 7 FCC Rcd 7651 (1992). Moreover, as the petitioner has stated it does not  xintend to relocate its transmitter site, Orabi would receive a 70 dBu signal from Station KBDT(FM) once it becomes operational.   x6. Channel 255C can be allotted to Leupp at the petitioner's current transmitter site  xylocated 42.2 kilometers (26.2 miles) north of the community at coordinates 352634 NL and 1105840 WL, consistent with the technical requirements of the Commission's Rules.   x7. Accordingly, we seek comments on the proposed amendment to the FM Table of  xAllotments, Section 73.202(b) of the Commission's Rules, with respect to the communities listed below, as follows: X` hp x (#%'0*,.8135@8: