Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554
In the Matter of ) ) WRNN License Company, LLC ) MB Docket No. 12-1 ) CSR-______Petition for Special Relief for ) Modification of the Television Market of ) Station WRNN-TV ) ) To: Chief, Media Bureau )
PETITION FOR SPECIAL RELIEF
I. INTRODUCTION AND SUMMARY
WRNN License Company, LLC (“WRNN License Co.”), licensee of television station
WRNN-TV, New Rochelle, New York (Fac. ID No. 74156) (“WRNN” or the “Station”), by its
attorneys and pursuant to Section 614 of the Communications Act of 1934, as amended, and
Section 76.7(a) of the Commission’s Rules, hereby submits this Petition for Special Relief
(“Petition”) to modify the television market of WRNN to include all of the communities served
by Altice’s1 systems in the following counties: Suffolk (NY), Essex (NJ), Hudson (NJ),
Monmouth (NJ), Ocean (NJ), and Union (NJ).2
1 According to the FCC’s COALs database, Altice N.V. does business in the communities at issue herein as CSC Holdings LLC, Cablevision Systems East Hampton Corp., CSC Holdings, Inc., CSC Acquisition-NY Inc., Cablevision of Newark, Cablevision of Monmouth LLC, Cablevision of Hudson County LLC, Cablevision of New Jersey LLC, and CSC TKR LLC. For ease of reference, “Altice” is used herein. 2 Each county is located in the New York Designated Market Area (“DMA”) and is not currently part of WRNN’s market. Specifically, WRNN is seeking to add the communities identified on Exhibit A and any additional communities in the same counties or served by the same systems and not presently included in WRNN’s television market (the “Communities”). As described more fully herein, WRNN recently relocated within the New York DMA to
implement its channel sharing agreement, resulting in a material change to the service it provides to the Communities. Through this change, WRNN now satisfies the statutory test for market modification proceedings: (i) Altice historically has carried WRNN’s channel share partner,
WWOR-TV, and the stations co-located with RNN at One World Trade Center in all of the
Communities; (ii) WRNN places a noise-limited service contour over most of the Communities, is geographically proximate to all of them, and is connected to them by shopping and labor patterns; (iii) WRNN is located in the same state as many of the Communities; and (iv) programming aired by WRNN is of interest to residents of the Communities. WRNN License
Co. respectfully requests that the Commission modify WRNN’s local television market without delay.
II. BACKGROUND
WRNN is an independent television station that has served the New York DMA for
decades.3 WRNN formerly was licensed to Kingston, New York, and broadcast from a
transmitter site located in Woodstock, New York, ten miles northwest of Kingston. WRNN has
invested significantly over the years to improve its coverage within the New York DMA, which
has been the subject of a number of regulatory proceedings.
In 1996, the Cable Services Bureau granted in part and denied in part a petition filed by
Cablevision Systems Corporation (“CSC”), Altice’s predecessor company, seeking to remove the
Communities served by its New Jersey systems, its Long Island systems, its Bronx and Brooklyn
systems, its Portchester and Westchester systems, and its systems in Fairfield County,
3 WRNN signed on-air as WTZA in 1985.
-2- Connecticut from WRNN’s market.4 In granting the petition as to the Long Island systems, the
majority of the New Jersey systems, and the New York City systems, the Bureau focused on
WRNN’s geographic distance from several of the Communities and its then-failure to place a
Grade B contour over them, finding that “because of its location and Grade B contour, [WRNN] more aptly serves Albany and its environs, rather than New York City and the cable communities
on the far side of it.”5 Specifically, the Bureau noted that all of the communities at issue were
outside WRNN’s Grade B contour and located between 83 and 130 miles from the station.6
Indeed, the Bureau noted that “the majority of the New York ADI stations have transmitters located atop of the World Trade Center in lower Manhattan and provide a Grade B contour covering almost every County in the New York market involved in this proceeding.”7 At the
same time, the Bureau denied CSC’s petition with regard to its Westchester (Yonkers),
Portchester, Fairfield County (Norwalk and Bridgeport) and Bergen systems “because the
communities are either inside the station’s Grade B contour or are not far outside the contour on
the northern part of the market and there is some evidence of a local programming connection.”8
In 2006, the Media Bureau granted in part and denied in part WRNN License Co.’s
petition to restore the Communities in Nassau and Suffolk Counties to WRNN’s market.9
4 Petition of Cablevision Systems Corp. for Modification of the ADI of Television Stations WTBY, WRNN, WMBC-TV, and WHAI-TV, Memorandum Opinion and Order, 11 FCC Rcd. 6543 (Cable Services Bureau 1996). 5 Id. at 6480, para. 66. 6 Id. at 6480, para. 67. 7 Id. at 6475, para. 49. 8 Id. at 6481, para. 68. 9 Petition of WRNN License Company, LLC for Modification of Television Market of Television Station WRNN-DT, Kingston, New York, Memorandum Opinion and Order, 21 FCC Rcd. 5952 (MB 2006) (“2006 Cablevision Order”), aff’d 22 FCC Rcd. 21054 (MB 2007).
-3- Although the Bureau dismissed WRNN’s petition with regard to Suffolk County on procedural grounds, it granted the petition as to the communities in Nassau County, finding that: (1) WRNN provided evidence of carriage on cable systems adjacent or sufficiently near to the Nassau
County communities;10 and (2) RNN provided a 41 dBu signal over all of Nassau County.11
In 2001, the Cable Services Bureau granted a separate petition filed by CSC seeking to remove the Communities served by its Elizabeth and Hamilton, New Jersey systems from
WRNN’s market.12 The Bureau again focused on WRNN’s geographic distance from several of the Communities and its then-failure to place a Grade B contour over them, finding that
“WRNN-TV’s failure to be carried for over 15 years reflects the lack of geographic proximity to the subject communities.”13 The Bureau went on to note: “Not only does WRNN-TV’s predicted
Grade B contour fail to encompass any of the subject communities, but WRNN-TV’s city of license is geographically remote from Cablevision’s Elizabeth and Hamilton systems at a minimum of 100 miles distance.”14
Now, the factors that previously caused the Commission to delete the Communities from
WRNN’s market no longer apply. Not only are the Communities either within the Station’s recently-modified noise-limited service contour or not far outside the contour, but the Station is also geographically proximate to them. WRNN’s dramatic change in circumstance is the result of its successful bid to relinquish spectrum in the broadcast Incentive Auction and a channel sharing
10 2006 Cablevision Order, 21 FCC Rcd. at 5958, para. 12. 11 Id. at 5959, para. 14. 12 Petition of CSC TKR, Inc. For Modification of the New York, New York DMA, Memorandum Opinion and Order, 16 FCC Rcd. 12577 (Cable Services Bureau 2001). 13 Id. at 12583, para. 14. 14 Id. at 12854, para. 15.
-4- arrangement with WWOR-TV, Secaucus, New Jersey (Fac. ID No. 74197) (“WWOR”) pursuant
to which WRNN is the channel “sharee.”15 As a result of that arrangement, WRNN broadcasts
from an antenna that sits atop One World Trade Center in lower Manhattan and has changed its
community of license to New Rochelle, New York. WRNN’s signal now covers all or parts of
the counties of Suffolk (NY), Essex (NJ), Hudson (NJ), Monmouth (NJ), Ocean (NJ), and Union
(NJ), and WRNN’s community of license is considerably closer to the Communities.
Accordingly, the Communities are now properly within the Station’s market and the market
should be modified accordingly.
III. LEGAL STANDARD
a. Market Modification Procedures
Pursuant to Section 614(h) of the Communications Act, the Commission considers the
following factors when evaluating market modification petitions:
(I) Whether the station, or other stations located in the same area, have been historically carried on the cable system(s) within the community;
(II) Whether the television station provides coverage or other local service to the community;
(III) Whether modifying the market of the television station would promote consumers’ access to television broadcast station signals that originate in their State of residence;
(IV) Whether any other television station that is eligible to be carried by a cable system in the community in fulfillment of the requirements of Section 614(h) provides news coverage of issues of concern to the community or provides carriage or coverage of sporting and other events of interest to the community; and
(V) Evidence of viewing patterns in cable and noncable households within the areas served by the cable system(s) in such community.16
15 See LMS File No. 0000042455. 16 47 U.S.C. § 534(h)(l)(C)(ii)(I)-(V). See also Second Report and Order Definition of Markets for Purposes of the Cable Television Broadcast Signal Carriage Rules, Order on
-5-
To establish a station’s relationship to the communities at issue, the Commission requires petitioners to support their requests for market modification with the following evidence:
(1) A map or maps illustrating the relevant community locations and geographic features, station transmitter sites, cable system headend locations, terrain features that would affect station reception, mileage between the community and the television station transmitter site, transportation routes and any other evidence contributing to the scope of the market;
(2) Noise-limited service contour maps (for full-power digital stations) or protected contour maps (for Class A and low power television stations) delineating the station’s technical service area and showing the location of the cable system headends or satellite carrier local receive facilities and communities in relation to the service areas.
(3) Available data on shopping and labor patterns in the local market;
(4) Television station programming information derived from station logs or the local edition of the television guide;
(5) Cable system channel line-up cards or other exhibits establishing historic carriage, such as television guide listings; and
(6) Published audience data for the relevant station showing its average all day audience (i.e., the reported audience averaged over Sunday-Saturday, 7 a.m.-1 a.m., or an equivalent time period) for both cable and noncable households or other specific audience indicia, such as station advertising and sales data or viewer contribution records.
(7) If applicable, a statement that the station is licensed to a community within the same state as the relevant community.17
Reconsideration and Second Report and Order, 14 FCC Rcd. 8366, 8369-8370 (1999); The STELA Reauthorization Act of 2014, Pub. L. No. 113-200, 128 Stat. 2059 (2014) (adding new statutory factor, denominated as factor (III) above); Amendment to the Commission’s Rules Concerning Mkt. Modification, Implementation of Section 102 of the STELA Reauthorization Act of 2014, Report and Order, 30 FCC Rcd. 10406 (MB 2015). 17 47 CFR § 76.59(b).
-6- The Bureau may waive the requirement to submit certain evidence for good cause shown,
particularly if it is in a position to resolve the petition without such evidence.18
b. Relevant Precedent
When instituting the current channel sharing regime pursuant to the broadcast Incentive
Auction, the Commission recognized that “relocations made to implement a channel sharing
arrangement may [impact] a station’s MVPD carriage rights.”19 It noted that the carriage rights of a station moving within its DMA would not be “expanded or diminished” automatically
through the relocation process, but that a channel sharee able to reach additional communities
from its new location could seek to add those communities to its market.20
In 2018, the Media Bureau considered two petitions for market modification filed by
Entravision Holdings, LLC (“Entravision”) seeking to add certain communities to television station WJAL’s market.21 Like WRNN, WJAL was a successful bidder in the Incentive Auction
and entered into a channel sharing arrangement as a sharee that resulted in a transmitter site re-
location and community of license change. Based on WJAL’s new transmitter site and community of license, Entravision sought to add certain communities in the Washington, DC
DMA served by Comcast and CoxCom to WJAL’s market.22 Many of these communities had
previously been deleted from the station’s market.
18 Tobacco Valley Communications, Memorandum Opinion and Order, 31 FCC Rcd. 8972, 8976 n. 22 (MB 2016) (“Tobacco Valley Communications”); 47 CFR § 1.3. 19 Expanding the Economic and Innovation Opportunities of Spectrum Through Incentive Auctions, Report and Order, 29 FCC Rcd. 6567, 6857, para. 708 (2014). 20 Id. at 6857, para. 709. 21 Entravision Holdings, LLC for Modification of the Television Market for Station WJAL(TV), Silver Spring, Maryland, Memorandum Opinion and Order, 33 FCC Rcd. 2215 (MB 2018) (“Entravision Order”). 22 See Entravision Holdings LLC for Modification of the Television Market for Station WJAL(TV), Silver Spring, Maryland, Facility ID 10259, Petition for Special Relief, MB Docket
-7- The Media Bureau granted Entravision’s petition. In so doing, the Bureau found that
historic carriage of WJAL’s channel sharing partner weighed in favor of Entravision’s requested
market modification and that WJAL’s signal coverage and geographic proximity to the
communities at issue, as well as shopping and labor patterns, “strongly weigh[ed] in favor of a
grant.”23 Although the Bureau noted that it would evaluate subsequent requests by channel
sharing stations “on the specific facts and circumstances presented in those proceedings,”24 as
discussed herein, the same factors weigh heavily in favor of granting the instant Petition.
Recently, the Bureau had the opportunity to apply these same principals in response to a
petition by WRNN License Co. to add communities served by Spectrum’s Bergen County, New
Jersey cable system to WRNN’s market.25 Although the Bureau reiterated that every market
modification must be based on the specific facts of that proceeding, it nevertheless recognized
that it should not “discount the relevance of the Entravision Order.”26 In granting WRNN’s
petition, the Bureau focused on Spectrum’s carriage of WRNN’s channel sharing partner in the
subject communities along with Spectrum’s carriage of other co-located and nearby stations.27
The Bureau also found “substantial evidence regarding WRNN’s signal coverage, geographic proximity, and shopping and labor patterns in relation to the Communities that overcomes the
No. 17-306 (filed Nov. 7, 2017) (Comcast Petition); Entravision Holdings LLC for Modification of the Television Market for Station WJAL(TV), Silver Spring, Maryland, Facility ID 10259, Petition for Special Relief, MB Docket No. 17-307 (filed Nov. 7, 2017) (Cox Petition). 23 Entravision Order at 2231, para. 28. The Commission afforded little or no weight to other statutory factors discussed in Entravision’s petition. 24 Id. 25 See Petition of WRNN License Company, LLC for Modification of the Television Market of Station WRNN-TV, New Rochelle, New York, Memorandum Opinion and Order, MB Docket No. 19-95, DA 19-734 (MB rel. Aug. 1, 2019) (“WRNN-Spectrum Order”). 26 Id. at para. 9. 27 Id. at para. 12.
-8- absence of local programming in WRNN’s channel lineup.”28 Ultimately, the Bureau found that
the first and second statutory factors weighed in favor of the market modification request, the third and fourth factors were not provided any weight, and while the fifth factor did not support a grant, there were “mitigating circumstances related to this finding.”29
On August 11, 2019, WRNN License Co. filed a petition seeking to expand the local
television market of WRNN in communities served by Altice.30 On January 14, 2020, the Media
Bureau issued an order dismissing the August Petition without prejudice and inviting WRNN
License Co. to refile its petition.31
IV. THE FIVE MARKET MODIFICATION FACTORS ENUMERATED IN THE COMMUNICATIONS ACT SUPPORT ADDITION OF THE COMMUNITIES TO WRNN’S MARKET
Application of the five market modification factors to WRNN supports grant of the instant
Petition.
a. Historic Carriage
The first statutory factor the Commission must consider is “whether the station, or other stations located in the same area, have been historically carried on the cable system or systems within such community.”32 This factor can demonstrate the presence of a “‘market nexus’
28 Id. at para. 13. 29 Id. at para. 24. 30 WRNN License Company, LLC for Modification of the Television Market for Station WRNN- TV, New Rochelle, New York, Facility ID 74156, Petition for Special Relief, MB Docket No. 19- 271 (filed Aug. 11, 2019) (the “August Petition”). The August Petition sought to expand WRNN’s local television market in all of the Communities included in the instant petition except for Bayonne, New Jersey, which is specifically identified in the instant petition. 31 WRNN License Company, LLC for Modification of the Television Market for Station WRNN- TV, New Rochelle, New York, Facility ID 74156, Order, MB Docket No. 19-271, DA-20-61 (rel. Jan. 14, 2020) (the “January WRNN Order”). 32 47 U.S.C. § 534(h)(l)(C)(ii)(I).
-9- between the broadcast station and the communities where the station is carried and thus provide
evidence as to the scope of a station’s market.”33
Although Altice has not carried WRNN on Altice’s systems serving the Communities, as
the Media Bureau recognized in the WRNN-Spectrum Order, “carriage of co-located stations in a
particular community also is relevant in the context of a market modification request.”34 The
Bureau explained that “such carriage is evidence of a petitioner station’s nexus with a community” and that “‘[e]ven when a station has no history of carriage in a community, the
Commission [gives] weight to this factor when another station based in the same area has been carried in the community.’”35 Accordingly, the Bureau found that the historic carriage factor
weighted in favor of WRNN’s prior requested market modification even though WRNN had no
history of carriage in the communities by Spectrum because WRNN relocated its transmission facilities to WWOR’s transmitter site, and Spectrum carried WWOR. The Bureau further explained that “since Spectrum also carries other co-located and nearby stations, we believe that
WRNN would be at a competitive disadvantage if Spectrum did not also carry WRNN in the
Communities.”36
33 Tennessee Broadcasting Partners, Memorandum Opinion and Order, 23 FCC Rcd. 3928, 3932, para. 5 (MB 2008) (“Tennessee Broadcasting Partners”); see also Entravision Order at 2223, para. 11. 34 WRNN-Spectrum Order, para. 10. 35 Id. at para. 12 (quoting Woods Communications Corporation, Memorandum Opinion and Order, 32 FCC Rcd. 6597, 6600, para. 6 (MB 2017) (citing Tennessee Broadcasting Partners, 23 FCC Rcd. at 3934, para. 10 (finding that carriage of a competing station in the same community provides evidence to support market modification)). 36 Id.
-10- As demonstrated by Exhibit B, Altice carries WWOR on its all of its systems serving the
Communities.37 Altice also carries a number of other stations co-located with WRNN and
WWOR at One World Trade Center.38 Thus, for Altice to refuse to carry WRNN in the
Communities would make WRNN an outlier amongst its peers and place the Station at a severe
competitive disadvantage.39
Also relevant to the Commission’s consideration of the historic carriage factor is whether
the station requesting market modification is carried by competitors in the relevant
communities.40 As evidenced by the local channel lineup cards in Exhibit C, WRNN is currently
carried in the Communities by Verizon FiOS, DISH, DIRECTV, and others.41 Furthermore, as
demonstrated by Exhibit D, Altice itself carries WRNN on cable systems immediately adjacent
to and/or surrounding the cable systems serving the Communities.42 Thus, the historic carriage
factor clearly weighs in favor of WRNN’s requested market modification.43
b. Local Coverage and Service
37 Exhibit B (Altice Cable Lineup Card). 38 For example, Altice carries WABC(DT), WCBS-TV, WNBC(DT), WNET(DT), and WPXN- TV, all of which broadcast from One World Trade Center. Id. 39 Entravision Order at 2225, para. 15. 40 See, e.g., Petition for Modification of Philadelphia, PA Designated Market Area with Regard to Station WACP, Atlantic City, NJ, Memorandum Opinion and Order, 29 FCC Rcd. 1835, 1845, para. 19, n. 77 (MB 2014). 41 Exhibit C (Comcast, Verizon FiOS, DISH and DIRECTV Channel Lineup Cards). 42 Exhibit D (Altice Carriage of WRNN-TV). 43 Although the Media Bureau determined in the WRNN-Spectrum Order that it need not accord WRNN new station status to properly analyze its market modification petitions, it nevertheless “consider[ed] the Station’s dramatic change in circumstances due to its change in community of license and transmitter site relocation as mitigating circumstances with respect to the Station’s lack of historic carriage.” WRNN-Spectrum Order, para. 12.
-11- Under the second statutory factor, the Commission considers “whether the television station provides coverage or other local service” to the community at issue.44 To establish that a
station provides coverage or other local service, “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.”45 The Commission has consistently recognized that signal
coverage46 and geographic proximity47 are solid measures of the scope of a station’s market and
help establish the relevant nexus between the station and the market. The Commission also looks
to shopping and labor patterns to help assess the connection between a station and the
communities at issue as well as any locally-focused programming broadcast by the station.48 The
Commission affords less significance to locally-focused programming where signal coverage,
44 47 U.S.C. § 534(h)(1)(C)(ii)(II). 45 Tennessee Broadcasting Partners, 23 FCC Rcd. at 3934, para. 11. The service area of an analog station was defined by the station’s Grade B contour. A digital television station’s service area is defined as the area within its noise-limited contour where its signal strength is predicted to exceed the noise-limited contour service level, which for channels 14-69 is 41 dBu. See 47 CFR § 73.622(e). The Commission treats a digital station’s noise-limited contour as the functional equivalent of an analog station’s Grade B contour. See Report to Congress: The Satellite Home Viewer Extension and Reauthorization Act of 2004, Study of Digital Television Field Strength Standards and Testing Procedures, 20 FCC Rcd. 19504, 19507, para. 3 (2005). 46 CoxCom, LLC, Memorandum Opinion and Order, 30 FCC Rcd. 10978, 10985, para. 11 (MB 2015) (“the Commission has long recognized that Grade B contour coverage, in the absence of other determinative facts, is an efficient tool to adjust market boundaries because it is a count indicator of the economic reach of a particular television station’s signal.”). 47 Comcast Cable Communities, Inc., Memorandum Opinio and Order, 19 FCC Rcd. 5245, 5252, para. 17 (MB 2005) (“Given the station’s closer geographic proximity, it appears that it is [the station’s] intent to serve these communities. As such, carriage of the station’s signal is reasonable and appropriate under the [Communications Act] and the Commission’s rules.”). 48 Tennessee Broadcasting Partners, 23 FCC Rcd. at 3937, para. 22.
-12- geographic proximity, and shopping and labor patterns evidence a sufficient nexus to the
community.49
i. Contour and Signal Strength
Pursuant to its channel sharing arrangement, WRNN broadcasts from a transmitter
located atop One World Trade Center. From that location, the Station’s 41 dBu noise-limited
service contour clearly encompasses nearly all of the Communities. Exhibit E provides a map
showing WRNN’s current signal contour in relation to the Communities and the relevant Altice
headends.50 WRNN’s signal contour covers all or part of each of the relevant cable systems.
Indeed, as demonstrated by Exhibit F, WRNN’s coverage of the Communities is nearly identical
49 WRNN-Spectrum Order, para. 18 (“[W]e find substantial evidence regarding WRNN’s signal coverage, geographic proximity, and shopping and labor patterns in relation to the Communities that overcomes the absence of local programming in WRNN’s channel lineup.”); Entravision Order at 2229, para. 23 (“[W]e find that the ample evidence regarding WJAL’s signal coverage, geographic proximity, and shopping and labor patterns in relation to the Communities overcomes the absence of local programming in WJAL’s channel lineup and that the second statutory factor weighs strongly in favor of WJAL’s Petition.”). 50 Exhibit E (Contour Map - WRNN). See 47 C.F.R. § 76.59(b)(2) (noting that “[s]ervice area maps using Longley-Rice (version 1.2.2) propagation curves may also be included to support a technical service exhibit”); see also WRNN-Spectrum Order, para. 4 n. 10; Entravision Order at 2219, para. 4 n. 17. The locations of cable headends are no longer available via cable operators’ public inspection files. Thus, WRNN License Co.’s engineer called his counterpart at Altice to determine the location of the headends for the systems serving the Communities. The engineer was told that Altice operates three master headends where signals are ingested and encoded before they are distributed to the hub-sites for the Communities. The locations of Altice’s master headends are plotted on the Contour Map in Exhibit D. Given the number of Communities at issue, including all of the Communities on a single map would have rendered the map illegible. Accordingly, WRNN License Co. has provided an overview map (WRNN-DT Overview Map) identifying all of the counties and systems in which the Communities are located and more detailed maps reflecting the location of each of the Communities. See 47 C.F.R. § 76.59(b)(1) (specifying that the required evidence be provided on “[a] map or maps”); January WRNN Order ¶ 7 (“If it chooses to refile, we expect WRNN to provide a map or maps responsive to the requirements of section 76.59(b)(1) of the Commission’s rules, or a detailed explanation of its efforts to do so and why they were unsuccessful.”). WRNN License Co. has also provided in Exhibit G calculations reflecting the distance between each of the Communities and both WRNN’s transmitter site and community of license.
-13- to the other major stations co-located on One World Trade Center—all of which are deemed
local to the Communities even though none has a contour that encompasses all of the
Communities.51 WRNN’s contour and signal strength, therefore, support inclusion of the
Communities in the Station’s market.52
ii. Geographic Proximity
Pursuant to its analysis of the second statutory factor, the Commission will examine a
station’s proximity to the subject communities in terms of mileage. In so doing, the Commission
considers both the distance between a station’s transmitter site and the relevant communities, and
the distance between a station’s community of license and the relevant communities.53 As
demonstrated by Exhibit E and discussed in further detail below, the Station is geographically
proximate to the Communities.
The table below reflects the direct distances from WRNN’s transmitter and community of
license to the closest and farthest Communities in each of the Altice systems at issue:
DISTANCES TO TRANSMITTER (ONE WORLD TRADE) System Closest Farthest Average Community Community Community Bayonne 6.0 miles 6.0 miles 6.0 miles Brookhaven/Suffolk 47.9 miles 61.7 miles 55.3 miles Elizabeth 9.0 miles 9.0 miles 9.0 miles Hauppauge/Islip 39.3 miles 70.4 miles 48.7 miles Hudson/Riverview 2.7 miles 13.3 miles 6.3 miles Monmouth East 31.9 miles 41.7 miles 36.4 miles Monmouth West 30.1 miles 48.3 miles 37.9 miles
51 Exhibit F (Contour Map of Stations Located at One World Trade Center). 52 See Entravision Order at 2229, para. 23 (finding that WJAL’s contour encompassing the communities at issue supported the station’s requested market modification); 2006 Cablevision Order at 19, para. 71 (explaining inclusion of additional communities in the market that did not meet all criteria but were “an integrated part of” and “in close proximity to” a covered system). 53 See, e.g., WRNN License Company, Memorandum Report and Order, 20 FCC Rcd. 7904, 7909, para. 10 (MB 2005); Time Warner Entertainment-Advance/Newhouse Partnership, Memorandum Report and Order, 22 FCC Rcd. 13642, 13646, para. 9 (MB 2007).
-14- DISTANCES TO TRANSMITTER (ONE WORLD TRADE) System Closest Farthest Average Community Community Community Newark 8.6 miles 13.1 miles 10.9 miles Riverhead/East 73.2 miles 99.7 miles 85.6 miles Hampton/Shelter Island Seaside 31.8 miles 66.1 miles 51.2 miles
DISTANCES TO COMMUNITY OF LICENSE (NEW ROCHELLE) System Closest Farthest Average Community Community Community Bayonne 25.8 miles 25.8 miles 25.8 miles Brookhaven/Suffolk 34.8 miles 50.5 miles 43.3 miles Elizabeth 26.6 miles 26.6 miles 26.6 miles Hauppauge/Islip 23.9 miles 49.0 miles 35.8 miles Hudson/Riverview 14.8 miles 29.6 miles 18.6 miles Monmouth East 48.2 miles 57.9 miles 52.6 miles Monmouth West 47.9 miles 67.0 miles 56.0 miles Newark 28.3 miles 32.5 miles 25.6 miles Riverhead/East 59.5 miles 85.4 miles 71.9 miles Hampton/Shelter Island Seaside 39.6 miles 82.1 miles 65.6 miles
A table reflecting the distances both “as the crow flies” and driving from WRNN’s community
of license and transmitter site to each of the Communities is attached hereto as Exhibit G, and
terrain maps showing the distances to a sample Community in each Altice system are attached
hereto as Exhibit H. This data demonstrates WRNN’s proximity to the Communities. The closest
Community on each system is less than 60 miles from New Rochelle, which is comparable to
distances that the Commission previously has found geographically proximate to the station at
issue.54
54 See, e.g., In re KJLA, LLC for Modification of the Television Market for Station KJLA-DT, Ventura, California, Memorandum Opinion and Order, 26 FCC Rcd. 12652, para. 11 (MB 2011) (modifying KJLA’s market to include communities located between 64 and 108 miles from the station’s community of license); KNTV License, Inc., 16 FCC Rcd. 6785 (2001) (adding communities that were 35-55 miles away); Paxson Atlanta License, Inc., 13 FCC Rcd. 20087 (1998) (adding communities that were 50 miles away); Burnham Broadcasting, Inc., 10 FCC Rcd. 7117 (1997) (adding a community that was 48 miles away); Time Warner Cable, 11 FCC
-15- While some of the Communities in the Riverhead/East Hampton/Shelter Island and
Seaside systems are farther from WRNN’s community of license and transmitter site, this is due to the unique geographies of Long Island and the Barnegat Peninsula, each of which includes several Communities located proximate to WRNN and within WRNN’s 41 dBu service area.
These landforms both extend over water away from not only WRNN but the other stations co- located at One World Trade Center.55 Indeed, WRNN’s community of license, New Rochelle, is
actually closer to eastern Long Island than New York, which is the community of license of each
of the other stations co-located at One World Trade Center and carried in the Communities.56
And while the driving distance from WRNN’s current community of license, New Rochelle, to
East Hampton (the farthest community) is 101.7 miles, this is closer than the driving distance from WRNN’s prior community of license, Kingston, to the closest community in Nassau
County – which the Bureau previously determined was part of WRNN’s market.57
Consistent with relevant precedent, the Commission should find that the distance of
WRNN’s transmitter and community of license from the Communities weighs in favor of
WRNN License Co.’s requested market modification.
iii. Shopping and Labor Patterns
The Commission also considers shopping and labor patterns when analyzing whether a
nexus exists between a station and the communities it seeks to add to its market. As
Rcd. 8047 (1996) (refusing to delete communities that were 60 miles away); Cablevision Systems Corporation, 11 FCC Rcd. 6453 (1996) (refusing to delete communities that were 48-55 miles away); Time Warner Cable, 11 FCC Rcd. 3510 (1996) (refusing to delete communities that were 45 miles away). 55 See Exhibit F (Contour Map of Stations Located at One World Trade Center). 56 Exhibit H (Terrain Maps). 57 See 2006 Cablevision Order at 5958, para. 13 (explaining that “the driving distance from the closest Community to WRNN-DT’s community of license is 111 miles”).
-16- demonstrated herein, WRNN’s community of license—New Rochelle, New York—shares strong
economic connections with the Communities.
New Rochelle, New York and the Communities are part of the larger New York/New
Jersey Metropolitan Area and are therefore connected by a multitude of interstate and state highways as well as public transportation. New Rochelle is easily accessible by car from any of the Communities.58 The Communities are also all part of New York/New Jersey’s interconnected
public transportation system, which connects New Rochelle and all of the Communities through
Penn Station – the busiest train station in the country serving approximately 650,000 passengers
each day.59 Passengers can access New Rochelle from Penn Station via Amtrak in just 26
minutes.60
New Rochelle boasts many businesses, entertainment and sports venues, and shopping
outlets that attract residents from all over the New York/New Jersey Metropolitan Area,
including the Communities.61 New Rochelle is also home to Iona College, which is one of nine colleges that participates in Suffolk County Community College’s New York State Presidential
Transfer Scholarship program that awards scholarships to top transfer students from Suffolk
58 Exhibit I (Driving and Public Transportation Routes). New York is currently considering a proposal to build a tunnel from Westchester County to Long Island that will further reduce travel times between New Rochelle and the Suffolk County communities. See Jordan Fenster, Westchester to Long Island Tunnel Plan Get 6 Developers’ Thumbs-up As Feasible, Desirable, USA Today: lohud (Apr. 27, 2018), https://www.lohud.com/story/news/local/2018/04/27/westchester-long-island-tunnel-plan- developers/558943002/. 59 John Schettino, The New York Penn Station Atlas (2015), http://pennstationatlas.com/book/. 60 Exhibit J (Amtrak Route From New Rochelle to Penn Station). 61 Exhibit K (New Rochelle Chamber of Commerce Business Directory). Similarly, many residents of New Rochelle are likely to be quite familiar with the Communities.
-17- County Community College.62 The Urban League of Westchester County (where New Rochelle
is located), meanwhile, administers a Senior Community Service Employment workforce
development program for residents of Suffolk County.63
In addition, U.S. Census Data shows that New Rochelle and the Communities share many common characteristics.64 For example, the average commuting time in New Rochelle and
communities in each of the relevant systems is around 30 minutes, reflecting the interconnected and interdependent nature of the New York/New Jersey Metropolitan Area:
Commuting Time [minutes] New Rochelle 30.5 Altice System Community (sample)
Bayonne Bayonne 34.6 Hauppauge/Islip Islip 32.8 Brookhaven/Suffolk Brookhaven 33 Riverhead/East Riverhead 27.6 Hampton/Shelter Island Newark Newark 34.7 Monmouth East Wall 26.6 Monmouth West Lakewood 20.2 Hudson/Riverview North Bergen 33.2 Elizabeth Elizabeth 23.8 Seaside Berkeley 32.2
62 Exhibit L (Suffolk County Community College, New York State Presidential Transfer Scholarship). 63 See Senior Community Service Employment Program (SCSEP), Urban League of Westchester County, Inc., https://www.ulwc.org/seniors-in-community-service-employ (last visited Sept. 4. 2019). 64 See Data USA, http://datausa.io/ (last visited Sept. 4, 2019).
-18- Health Care and Social Assistance is also among the top three industries in nearly all of the
communities identified above.65
The Communities on Long Island and the Barnegat Peninsula are also popular vacation
destinations for residents in the New York City area, including Westchester County. USA Today
has described Long Island as “an ideal location for a weekend getaway,” directing city dwellers to “[s]imply grab the Long Island Rail Road and end at Greensboro, where you can grab the ferry to Shelter Island.”66 The website Mommy Poppins, which is dedicated to “get[ing] more out of
Westchester with kids” has featured “Kid-Friendly Wineries on Long Island’s East End” and “LI
Day Trip: Fun Things to Do With Kids on Shelter Island.”67 Time Out New York, meanwhile,
identifies Seaside Heights as one of “the best family beach vacations from NYC.”68 And the Real
Estate Hudson Valley blog identifies Great Adventure amusement park in Jackson, New Jersey
(Ocean County) as “a terrific choice” for a day trip or an overnight trip.69 New Jersey Transit
specifically advertises vacation routes to Monmouth and Ocean Counties from New York.70
65 Id. 66 See Beau Prichard, Weekend Vacations in Long Island, USA Today (Mar. 15, 2018), https://traveltips.usatoday.com/weekend-vacations-long-island-11091.html. 67 Lisa Mancuso, Kid-Friendly Wineries on Long Island’s East End, MommyPoppins (Aug. 8, 2018), https://mommypoppins.com/kids/the-top-5-kid-friendly-wineries-on-the-north-fork; Jaime Sumersille, LI Day Trip: Fun Things to Do With Kids on Shelter Island, MommyPoppins (July 26, 2018), https://mommypoppins.com/kids/long-island-day-trip-6-fun-things-to-do-on-shelter- island. 68 Dorkys Ramos, et al., The Best Family Beach Vacations From NYC, TimeOut (May 22, 2018), https://www.timeout.com/new-york-kids/things-to-do/the-best-family-beach-vacations-near-nyc. 69 Amusement Parks Around Westchester and Hudson Valley, Real Estate Hudson Valley (July 9, 2015), https://www.realestatehudsonvalleyny.com/blog/amusement-parks-around-westchester- and-hudson-valley/. 70 See Next Stop Summer, NJTransit, https://www.njtransit.com/summer/Summer_Shore.html (last visited Sept. 4, 2019).
-19- Further demonstrating the interconnected nature of the New York/New Jersey
Metropolitan Area, the counties of Nassau, Suffolk and Westchester (home to New Rochelle) are
working together on an initiative to cooperatively purchase over 200 police vehicles for the
counties themselves as well as towns and villages within their boundaries.71
Thus, as demonstrated herein, the interconnection between New Rochelle and the
Communities supports weighing the second statutory factor in favor of WRNN License Co.’s
requested market modification.
iv. Local Programming
Finally, when analyzing the second statutory factor the Commission will consider local
programming. The absence of such programming, however, will not tip the scale against a
petitioner where historical carriage, geographic proximity, and shopping and labor patterns
support weighing the second statutory factor in favor of petitioner.72
WRNN airs regional and international news, paid programming, and syndicated programming.73 This programming is of general interest to viewers in the Communities.
Furthermore, each night, WRNN broadcasts Richard French Live, an Emmy-award winning
news talk show that covers issues of importance throughout the region and, specifically, in the
Communities. Recent episodes of Richard French Live have included numerous stories about the
Suffolk County communities, including coverage of a severe weather event that included an
interview with Suffolk County Executive Steve Bellone, increased gang activity, the reduction in
71 Thomas P. DiNapoli, Long Island Regional Economic Snapshot (May 2019), Office of the New York State Comptroller, https://www.osc.state.ny.us/localgov/pubs/economicprofile/long- island-region.pdf. 72 See Entravision Order at 2229, para. 23. 73 Program lineups for WRNN and its multicast channels from TitanTV are attached hereto as Exhibit M.
-20- rush hour service on the Long Island Railroad, and school safety. Mr. French has also interviewed Congressman Peter King, who represents New York’s 2nd Congressional District,
which includes several of the Suffolk County communities.74 Richard French Live has also covered a number of stories about the New Jersey communities, including concerns about lead levels in Essex County, transportation options for residents of Hudson County amidst service changes at Hoboken Terminal, proposals to legalize recreational marijuana and sports betting in
New Jersey, and the controversy surrounding the alleged employment of undocumented workers at President Trump’s golf club in Colt’s Neck (Monmouth County). In October 2018, Mr. French moderated a live debate on the Station between the candidates in New Jersey’s 7th Congressional
District, which includes parts of Essex and Union counties. Mr. French has also interviewed
Congressman Donald Payne, who represents New Jersey’s 10th Congressional District, which
includes portions of Essex, Hudson, and Union Counties.75
Thus, as demonstrated herein, WRNN provides programming of interest to the
Communities, further supporting weighing the second statutory factor in its favor.
c. Consumer’s Access to In-State Broadcast Signals
The third statutory factor asks “whether modifying the market of the television station
would promote consumers’ access to television broadcast station signals that originate in their
State of residence.”76 This factor is intended to ensure that cable and other multichannel video
programming distributor subscribers are “receiving news, politics, sports, emergency
information, and other television programing relevant to their home state” and “relevant to their
74 See Exhibit N (Excerpts from Richard French Live). 75 See id. 76 47 U.S.C. § 534(h)(1)(C)(ii)(III).
-21- everyday lives.”77 Nonetheless, the Commission has explicitly stated that, to the extent a petition
does not involve an “in-state” station, the “in-state factor would be inapplicable and the
modification request would be evaluated based on the other statutory factors.”78
WRNN is licensed to New Rochelle, New York, and broadcasts from a transmitter
located atop One World Trade Center in lower Manhattan. The Suffolk County communities are located in New York and, therefore, this factor weighs in favor of the market modification with regard to those communities. The remaining communities are located in New Jersey, and thus the Commission should assign no weight to this factor with regard to those communities.
d. Carriage of Other Eligible Stations
Next, under the fourth statutory factor, the Commission will consider “whether any other television station that is eligible to be carried by a cable system in 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.”79 This factor is generally interpreted as enhancing a station’s market modification
petition if other stations do not sufficiently serve the communities at issue; however, other
stations’ service to the communities rarely has counted against a petition.80 Upon information
and belief, Altice’s systems serving each of the Communities carry other television stations that
77 Amendment to the Commission’s Rules Concerning Mkt. Modification, Implementation of Section 102 of the STELA Reauthorization Act of 2014, Report and Order, 30 FCC Rcd. 10406, 10420, para. 18 (MB 2015) (“STELAR Market Mod. Order”). 78 Entravision Order at 2230, para. 25 (citing STELAR Market Mod. Order, 30 FCC Rcd. at 10420, para. 19). The Commission also affirmed in the Entravision Order that “[t]he inability to satisfy one factor does not serve to increase scrutiny under any of the other four factors, any more than satisfaction of one factor would diminish scrutiny under the others.” Id. (emphasis in original). 79 47 U.S.C. § 534(h)(1)(C)(ii)(IV). 80 Entravision Order at 2230, para. 26.
-22- provide coverage of news, sports, and other issues of interest to the Communities. Consistent
with well-established precedent, the Commission should assign no weight to this factor in its
evaluation of the Petition.
e. Viewing Patterns
The fifth statutory factor focuses on “evidence of viewing patterns” in cable and noncable
households located within the area served by the cable system at issue.81 In the WRNN-Spectrum
Order, the Bureau determined that even if it considered WRNN’s viewership to be low or non-
existent in the communities at issue:
WRNN’s recent changed circumstances regarding its community of license and transmitter site relocation and improved signal coverage are mitigating circumstances with respect to a lack of viewership in the Communities. Any lack of WRNN viewership would not be surprising given that its market was modified to exclude the Communities over two decades ago.82
So too here. WRNN still does not subscribe to Nielsen or any other ratings service and has
requested, but did not receive, permission to utilize published audience data relevant to this
factor.83 Furthermore, while WRNN maintains advertising and sales data for the market
generally, it does not have any specific sales in the Communities (and, as a commercial
81 47 U.S.C. § 534(h)(1)(C)(ii)(V). 82 WRNN-Spectrum Order, para. 23. 83 To the extent necessary, WRNN requests a waiver of the requirement of 47 CFR § 76.59(b)(6) to provide published audience data for the relevant station. Although the Commission recently directed the Media Bureau to “dismiss without prejudice at the outset of the proceeding petitions that fail to either include all required supporting evidence, or reflect at least an effort to obtain that evidence,” N.B., Colorado Petitions for Modification of the Satellite Television Markets of KDVR-TV, KCNC-TV, KMGH-TV, and KUSA-TV, Denver, Colorado, MB Docket Nos. 16-366, 16-367, 16-368, and 16-369, Memorandum Opinion and Order, 34 FCC Rcd. 5030, para. 16 (2019), it concurrently noted that “the Media Bureau may waive the requirement to submit certain evidence for good cause, particularly if the Bureau is in a position to resolve the petition without such evidence,” id. at para. 5 (citing Tobacco Valley Communications, 31 FCC Rcd. at 8976 n. 22). As the Bureau determined in the WRNN-Spectrum Order, it can weigh the missing evidence against WRNN and still resolve the petition in WRNN’s favor.
-23- television station, it does not have viewer contribution records). WRNN’s direct response media
provider does maintain logs of orders received in response to programming broadcast on WRNN,
which, thus far in 2019, have included numerous orders from the Communities—evidencing
WRNN’s viewership in those communities.84
As explained above, WRNN’s market was modified in 1996 to exclude the Communities.
Thus, to the extent the Commission considers the Station’s viewership to be “low” or
“nonexistent,” it should similarly consider that level of viewership to be “unsurprising” and
afford this factor limited weight.85 Furthermore, the Commission should consider the Station’s
recent modifications to its community of license, transmitter site relocation, and signal coverage
improvement as mitigating circumstances with respect to any lack of viewership in the
Communities.86 The Commission should either weigh this factor in favor of WRNN, or afford it
limited weight.
V. Conclusion
As shown herein, application of the statutory factors to WRNN License Co.’s requested
market modification support adding the Communities to WRNN’s market.
84 See Exhibit O (WRNN Direct Response Order Logs). The Media Bureau recently determined that the information provided in this exhibit reflects “a substantial and good-faith effort” by WRNN License Co. “to obtain ‘specific audience information’ responsive to the requirements of section 76.59(b)(6) . . . in a genuine attempt to demonstrate specific engagement by viewers in the Communities it hopes to more fully serve.” WRNN Dismissal Order ¶ 7. The Bureau further stated that “[i]n light of this demonstrated effort, we anticipate that a waiver of the requirements of section 76.59(b)(6) to the extent necessary would be appropriate, and will not expect WRNN to provide new or additional evidence responsive to this section if it chooses to refile.” Id. 85 Entravision Order at 2231, para. 27; WRNN-Spectrum Order, para. 23. 86 Id.
-24- Respectfully Submitted,
WRNN License Company, LLC
By: s/Ari Meltzer p Ari Meltzer Kathryne Dickerson Wiley Rein LLP 1776 K Street, NW Washington, DC 20006 (202) 719-7000
Its Attorneys
Date: January 28, 2020
-25- DECLARATION OF CHRISTIAN FRENCH
I, Christian French, hereby declare under penalty of perjury that I have reviewed the foregoing Petition for Special Relief and that, to the best of my knowledge, information, and belief formed after reasonable inquiry, it is well grounded in fact and is warranted by existing law and is not interposed for any improper purpose.
s/Christian French p Christian French Chief Operating Officer
Dated: January 28, 2020
CERTIFICATE OF SERVICE
I, Ari Meltzer, hereby certify that, on January 28, 2020, I directed a copy of the foregoing Petition for Special Relief to be sent to the following entities via first-class mail, postage pre- paid:
CSC Holdings LLC Cablevision Systems East Hampton Corp. CSC Holdings, Inc. CSC Acquisition-NY Inc. Cablevision of Newark Cablevision of Monmouth LLC Cablevision of Hudson County LLC Cablevision of New Jersey LLC CSC TKR LLC 1111 Stewart Avenue Bethpage, NY 11714
American Broadcasting Companies, Inc. 77 West 66th Street, 16th Flr Attn: John W. Zucker, Esq. New York, NY 10023-6298
CBS Broadcasting Inc. CBS LITV LLC 1725 Desales St., NW Suite 501 Washington, DC 20036
Connecticut Public Broadcasting, Inc. 1049 Asylum Avenue Hartford, CT 06105
WNET 825 Eighth Avenue Attn: General Counsel New York, NY 10019
NBC Telemundo License LLC 300 New Jersey Ave, N.W. Suite 700 Washington, DC 20001
New Jersey Public Broadcasting Authority PO Box 777 Trenton, NJ 08625 0777
Univision New York LLC 5999 Center Drive Suite 4083 Los Angeles, CA 90045
PMCM TV, LLC 1329 Campus Parkway Neptune, NJ 07754
Mountain Broadcasting Corporation 99 Clinton Road West Caldwell, NJ 07006
New York City Dept. of Info Technology & Telecommunications NYC Media Attn: Janet Choi, GM 1 Centre Street, 27th Floor New York, NY 10007
Fox Television Stations, LLC 400 N. Capitol Street, NW Suite 890 Washington, DC 20001
WPIX, LLC 220 East 42nd Street New York, NY 10017
ION Media License Company, LLC 601 Clearwater Park Road West Palm Beach, FL 33401
Trinity Broadcasting of New York, Inc. 111 E. 15th Street New York, NY 10003 2101
WXTV License Partnership, G.P. 5999 Center Drive Suite 4083 Los Angeles, CA 90045
NRJ TV NY License Co., LLC 722 S. Denton Tap Road, Suite 130 Coppell, TX 75019
-28- New York State Public Service Commission Empire State Plaza Agency Building 3 Albany, NY 12223-1350
State of New Jersey Board of Public Utilities Office of Cable Television 44 South Clinton Avenue Post Office Box 350 Trenton, New Jersey 08625-0350
Suffolk County Matthew G. Kiernan Public Administrator 300 Center Dr, Riverhead, NY 11901
Administrator Town of Belle Terre 1 Cliff Road Belle Terre NY 11777
Administrator Village of Brightwaters 40 Seneca Drive Brightwaters, NY 11718
Administrator Town of Brookhaven 1 Independence Hill Farmingville, NY 11738
Village Administrator/Clerk - Margaret O’Keefe Head of the Harbor Village Hall 500 North Country Rd. St. James NY, 11780
Administrator Town of Islandia 1100 Old Nichols Road Islandia, N.Y. 11749
Administrator Town of Islip 655 Main Street Islip, NY 11751
-29-
Administrator Village of Nissequogue 631 Moriches Road St. James, New York 11780
Administrator Town of Old Field Old Field Lighthouse 207 Old Field Road Setauket, NY 11733
Administrator Village of Port Jefferson 121 West Broadway Port Jefferson, New York 11777
Administrator Incorporated Village of Shoreham 80 Woodville Rd. (north end of Woodville Rd.) Shoreham New York 11786-0389
Administrator Town of Smithtown 99 W. Main St. Smithtown, NY 11787
Administrator Village of Branch PO Box 725 Smithtown, NY 11787
Administrator Town of Bellport 29 Bellport Lane Bellport, NY 11713
Administrator Incorporated Village of Lake Glove 980 Hawkins Avenue Lake Grove, NY 11755
Administrator Village of Patchogue 14 Baker St. Patchogue, NY 11772
-30- Administrator Village of Poquott E. Setauket, NY 11733
Administrator Village of Mastic Beach 427 Neighborhood Road Mastic Beach, NY 11951
Administrator Village of Dering Harbor PO Box K Shelter Island, NY 11965
Administrator Village of East Hampton 27 Main Street East Hampton, NY 11937
Administrator Village of Greenport 236 Third Street Greenport, NY 11944
Administrator Village of North Haven 335 Ferry Road Sag Harbor, NY 11963
Administrator Village of Quogue Jessup Avenue Quogue, NY 11959
Administrator Riverhead 210 Howell Avenue Riverhead, NY 11901
Administrator Village of Sag Harbor Main St., P.O. Box 660 Sag Harbor, NY 11963
-31- Administrator Village of Sagaponack PO Box 600 3175 Montauk Highway Sagaponack, NY 11962
Administrator Town of Shelter Island 38 North Ferry Road Shelter Island, NY 11964-0970
Administrator Village of Southampton 23 Main Street Southampton, NY 11968
Administrator Town of Southold 53095 Route 25 Southold, NY 11971
Administrator Village of West Hampton Dunes PO Box 728 4 Arthur Street West Hampton Beach, NY 11978
Administrator Village of Westhampton Beach Sunset Avenue Westhampton Beach, NY
Administrator Essex County 465 Martin Luther King Jr Blvd Newark, NJ 07102
Administrator Monmouth County One East Main Street P.O. Box 1255 Freehold, NJ 07728
-32- Administrator Ocean County Carl W. Block, Administrator Michael J. fiure, Assistant Administrator 101 Hooper Ave Toms River, NJ 08754-2191
Administrator Union County 10 Elizabethtown Plaza Elizabeth, NJ 07207
Administrator Hudson County 595 Newark Avenue Jersey City, NJ 07306
Administrator City of Newark 920 Broad St Newark, NJ 07102
Administrator Village of South Orange 76 South Orange Avenue South Orange, NJ 07079
Administrator City of Asbury Park One Municipal Plaza Asbury Park, NJ 07712
Administrator Borough of Avon by the Sea 301 Main Street Avon-by-the-Sea, NJ 07717
Administrator Borough of Belmar 601 Main Street Belmar, NJ 07719
Administrator Borough of Bradley Beach 701 Main Street Bradley Beach, NJ
-33- Administrator Borough of Brielle 601 Union Lane Brielle, NJ 08730
Administrator Borough of Farmingdale 11 Asbury Avenue Farmingdale NJ 07727
Administrator Borough of Interlaken Address: 100 Grasmere Avenue Interlaken, NJ 07712
Administrator Borough of Manasquan 201 East Main Street Manasquan, NJ 08736
Administrator Neptune Township 25 Neptune Blvd Neptune, NJ 07753
Administrator 106 West Sylvania Avenue Neptune City, New Jersey 07753
Administrator Ocean Township 399 Monmouth Rd Oakhurst, NJ 07755
Administrator Borough of Sea Grit 321 Baltimore Boulevard Sea Girt, NJ 08750
Administrator South Belmar 1740 Main Street Lake Como, NJ 07719
-34- Administrator Township of Wall 2700 Allaire Road Wall, NJ 07719
Administrator Borough of Spring Lake 423 Warren Avenue PO Box 638 Spring Lake, NJ 07762
Administrator Borough of Spring Lake Heights 555 Brighton Avenue Spring Lake Heights, NJ 07762
Administrator Township of Colts Neck 124 Cedar Drive Colts Neck, New Jersey 07722
Administrator EARL Naval Weapon Station 201 NJ-34 Colts Neck, NJ 07722
Administrator Borough of Englishtown 5 Main Street Englishtown, NJ 07726
Administrator Freehold Township 1 Municipal Plaza Freehold, NJ 07728
Administrator Howell Township 4567 Route 9 North Howell, NJ 07731
Administrator Jackson Township 95 W. Veterans Hwy Jackson, NJ 08527
-35- Administrator Lakewood Township 231 Third Street Lakewood, NJ 08701
Administrator Manalapan Township 120 County Rd 522 Manalapan, NJ 07726
Administrator Marlboro Township 1979 Township Drive Marlboro, NJ 07746
Administrator Millstone Township 470 Stage Coach Road Millstone Township, NJ 08510
Administrator Upper Freehold Township 314 Route 539 Cream Ridge, NJ 08514
Administrator Berkeley Township 627 Pinewald-Keswick Road Bayville NJ 08721
Administrator Township of Toms River 33 Washington Street Toms River, NJ 08753
Administrator Borough of Lavallette 1306 Grand Central Ave Lavallette NJ 08735
Administrator Borough of Seaside Heights 901 Boulevard Seaside Heights, NJ 08751
-36- Administrator Borough of Seaside Park 1701 North Ocean Ave Seaside Park, NJ 08752
Administrator The Township of North Bergen 4233 Kennedy Boulevard North Bergen, NJ, 07047
Administrator City of Hoboken 94 Washington St Hoboken, NJ 07030
Administrator Township of Weehawken 400 Park Ave Weehawken, NJ 07086
Administrator Town of West New York 428 60th St West New York, NJ 07093
Administrator Union Township 1976 Morris Ave Union, NJ 07083
Administrator City of Elizabeth 50 Winfield Scott Plaza Elizabeth, NJ 07201
By: s/ p Ari Meltzer
-37-