Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554

In the Matter of ) ) Amendment of Section 73.3580 of the ) MB Docket No. 17-264 Commission’s Rules Regarding Public Notice of ) the Filing of Applications ) ) Modernization of Media Regulation Initiative ) MB Docket No. 17-105 ) Revision of the Public Notice Requirements of ) MB Docket No. 05-6 Section 73.3580 )

JOINT COMMENTS

I. INTRODUCTION AND SUMMARY

American General Media, Beasley Media Group Licenses, LLC, Connecticut Public,

Cumulus Media Inc., Entercom License, LLC, Galaxy Communications, LLC, Good Karma

Broadcasting, LLC, Good Karma Milwaukee, LLC, Meruelo Media, LLC, Sarkes Tarzian, Inc., and WNET, licensees of the 815 commercial and non-commercial broadcast stations identified on Attachment A hereto (“Joint Commenters”), by their attorneys hereby respond to the above- captioned Further Notice of Proposed Rulemaking (“FNPRM”)1 concerning the Commission’s proposals to amend Section 73.3580 of its rules governing public notice requirements for broadcast applications. Joint Commenters appreciate the Commission’s efforts to modernize its media rules, and especially its work in eliminating unnecessary and unduly burdensome regulations that no longer reflect the realities of today’s broadcast industry or the needs of broadcast consumers.

1 Amendment of Section 73.3580 of the Commission’s Rules Regarding Public Notice of the Filing of Applications, Further Notice of Proposed Rulemaking, FCC 19-97, MB Docket No. 17-264 (rel. Sept. 26, 2019).

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Rule 73.3580 requires broadcasters to notify the public when they file applications for new licenses, renewal, assignment and transfer of licenses, and certain modifications of licenses.2

Currently, for certain applications, stations must publish announcements in local newspapers, which is both costly and ineffective.3 The rule also requires stations to run lengthy on-air announcements4 that contain information that can be confusing to the public. It also contains complex requirements concerning the timing and content of the required notices, which can be confusing both to broadcasters and consumers.5

The FNPRM proposes to eliminate the current newspaper requirement and instead allow broadcasters to publish online notices on a station’s website that would link directly to the filed applications in the station’s online public inspection file.6 The Commission also proposes to shorten and standardize the required content of the on-air announcements and to allow stations to direct listeners and viewers to the online notice.7 Evidence in the record supports these proposals.8

Joint Commenters support the Commission’s proposal to make long-overdue changes to the newspaper publication requirements by allowing stations to instead post notices on their websites that link directly to the applications in an online public inspection file as well as the

Commission’s proposals to streamline online and on-air announcements and to simplify the timing of required announcements.

2 See generally 47 CFR § 73.3580. 3 47 CFR § 73.3580(c)(1). 4 47 CFR § 73.3580(d)(4)(i). 5 See e.g., 47 CFR § 73.3580(d)(4)(ii)(B). 6 FNPRM at 6, para. 10. 7 Id. at 15-16, para. 28-29. 8 See generally Reply Comments of National Association of Broadcasters, MB Docket No. 17-264 (filed. Jan. 16, 2018) (NAB Reply Comments).

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II. JOINT COMMENTERS SUPPORT THE COMMISSION’S PROPOSAL TO REPLACE THE NEWSPAPER PUBLICATION REQUIREMENT WITH AN ONLINE NOTICE REQUIREMENT

Eliminating the newspaper publication requirement and allowing stations to instead provide notice via their websites would reduce unnecessary and costly burdens on broadcasters and increase access to application information for consumers. This proposed change is consistent with other proceedings in which the Commission has found that the use of station websites to provide information to listeners and viewers is practical and cost effective and does not negatively impact consumers’ access to information about a broadcast station.9

The Commission has acknowledged that newspaper publication is costly. In fact, according to the Commission’s own calculations, the aggregate industry cost burden of the newspaper publication requirement is roughly $1.8 million per year.10 In the experience of Joint

Commenters, it can cost anywhere between hundreds to tens of thousands of dollars to publish a single notice containing abridged information about an application for four days depending on the number of stations and number of markets involved. In contrast, posting an announcement on a station’s website generally has little or no cost.11 Newspaper publication costs can fall disproportionately on smaller broadcasters for whom margins may already be thin.12 For large commercial broadcasters that own many stations and file assignment or transfer of control applications, the costs of publication in newspapers can reach tens of thousands of dollars. Most importantly, these costs do not result in greater access to the information for consumers.

9 See Amendment of Section 73.1216 of the Commission’s Rules Related to Broadcast Licensee-Conducted Contests, Report and Order, 30 FCC Rcd 10468 (2015) (“Contest Rules Order”) 10 FNPRM at 7 n.36. 11 Id. 12 See NAB Reply Comments at 6; Comments of Multicultural Media, Telecom, and Internet Council, MB Docket 17-264 (filed Dec. 29, 2017) at 1–2; see also Joint Comments of America’s Public Television Stations, Corporation for Public Broadcasting, and Public Broadcasting Service, MB Docket 17-264 (filed Dec. 29, 2017) at 4.

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The number of print newspapers in the United States is declining. In addition, the percentage of consumers who say they get their news from newspapers or subscribe to a newspaper is also declining significantly.13 Consequently, allowing broadcasters to post notices on a station’s website not only saves broadcasters money, it also increases the public’s access to information. Online notices are available any time a user wishes to access them. In addition, consumers can use online tracking and search tools to obtain information about applications they might have otherwise missed. The information posted to a website would be available within a few days after an application is filed, which means that consumers would have more time to review the information. Lastly, online postings can provide more information than a newspaper publication because online notices will link directly to full applications whereas newspaper notices only provide summaries of applications.14

Joint Commenters believe that allowing broadcasters to publish their online notices on a separate page or link that is easily accessible from the homepages of their websites is more practical than requiring the notices to be placed directly on homepages. The homepages of most stations’ websites contain a substantial amount of content including news and entertainment stories and information about programming and community events. The content often rotates quickly. An announcement about a pending application is likely to get lost in these content rich homepages. Including a conspicuous link on the homepage in the same section where stations already include links to the online public inspection file, EEO reports and contest rules makes more sense and will be easier for the public to navigate.

13 FNPRM at 8, para. 13; see Amy Mitchell, et al., How Americans Get their News, Pew Research Center (July 7, 2016), https://www.journalism.org/2016/07/07/pathways-to-news/ (showing that adults have a clear preference for getting news from digital sources and not print newspapers); Newspapers Fact Sheet, Pew Research Center, (July 9, 2019), https://www.journalism.org/fact-sheet/newspapers/ (showing a clear decline in newspaper subscriptions in recent years). 14 See FNPRM at 11, para. 20 (noting that shorter public notice messages, rather than detailed summaries and recitations of the parties, are justified by the fact that “the actual application is just a click away for the user.”).

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The Commission has reached this conclusion in similar contexts.15 For example, in the

Contest Rules Order, the Commission concluded that licensees should post their contest rules on a separate page and include a link to that page on the station’s homepage.16 The Commission recognized that consumers were already accustomed to navigating separate tabs or links and would have no additional difficulty finding the contest information simply because those rules were not posted to a station’s homepage.17 The same rationale applies here. Broadcasters already include links to a variety of FCC mandated information, so standardizing this method would not be additionally burdensome for stations. Finally, it is likely that consumers looking for FCC-related information on station websites are already familiar with links to public inspection files, EEO reports and contest rules.

III. JOINT COMMENTERS SUPPORT THE COMMISSION’S PROPOSALS TO STREAMLINE ONLINE AND ON-AIR ANNOUNCEMENTS

The current public notice requirements for on-air announcements are needlessly complex.

Depending on the type of station and/or application, there are different requirements for the content, schedule, and timing of the announcements.18 Joint Commenters strongly support streamlining and standardizing these announcements. Due to the length and content of current announcements, listeners and viewers may tune out the announcements, or even switch stations when the announcements air. Shorter, more pertinent announcements which direct listeners and viewers to the online announcements or public inspection files would be more effective.

15 See Contest Rules Order at 10471–72, paras. 7–8. 16 Id. at 10472, 75, paras. 8, 15. 17 Id. at 10475, para. 15. 18 See 47 CFR § 73.3580(d)(4)(1)(B); also 47 CFR § 73.3580(d)(4)(ii)(B); Jack N. Goodman, Five Rules Changes the FCC Should Consider, TVNewsCheck, (May 1, 2017), https://tvnewscheck.com/article/103674/five-rule- changes-the-fcc-should-consider/ (calling the local public notice rule “a morass of rules, exceptions to those rules and exceptions to the exceptions.” and noting that “Some FCC lawyers interpret the timing of required on-air announcement one way; others reading the same rules come up with a different schedule.”) (“Goodman Article”).

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Streamlining the announcements will reduce redundancy as well as the time and cost stations incur in producing and airing announcements. In addition, directing consumers to the website with a link to the online public file will provide them with direct access to the entire application.

One example of the complexity and impracticality of the current rule is the requirement to list all “parties” to the application, including all attributable shareholders and members in a licensee’s ownership chain, as well as all officers and directors.19 This requirement is particularly burdensome for non-commercial stations that have large boards of directors and commercial broadcasters that have complex ownership structures. These long announcements are clearly unappealing and often confusing to listeners. Additionally, the long list of “parties” drowns out the more important information in the announcements — that an FCC application has been filed and where consumers can obtain information about the application.20

IV. JOINT COMMENTERS SUPPORT THE PROPOSAL TO STANDARDIZE TIMING REQUIREMENTS OF THE REQUIRED ANNOUNCEMENTS

Joint Commenters also support the proposal to simplify the current timing requirements for on-air announcements.21 The proposed rule would require stations to air announcements a total of four times (once a week for four consecutive weeks).22 Currently, depending on the type of application filed, stations may have to air announcements during various specific time periods

— e.g. AM and PM drive time, or prime time.23 The FCC’s proposals to standardize the differing timing requirements and require all on-air announcement to be broadcast between 7

19 47 CFR § 73.3580(d)(3); see also Goodman Article (stating that “when stations change ownership, they must broadcast often endless lists of the officers and directors of each company involved.”). 20 Joint Commenters also support the proposal to continue allowing non-commercial stations to provide only on-air notices. See FNPRM at 12, para 22. As the Commission observes, imposing greater burdens on non-commercial stations is inconsistent with the goal of streamlining public notice obligations. 21 FNPRM at 15, para. 28. 22 Id. 23 See e.g., 47 CFR § 73.3580(d)(4)(1)(B).

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AM and 11 PM local time, Monday through Friday, makes sense.24 Giving stations more flexibility with on-air announcement schedules reduces the cost burdens on stations that might otherwise use that time for programming or other revenue generating content. Joint Commenters also support proposals to require on-air and online announcements to start within five days of the date that the FCC provides public notice that an application is accepted for filing and for online announcements to continue for 30 days.25 Standardizing the timing of on-air and online announcements is beneficial for broadcasters as well as listeners and viewers. Because access to these announcements will increase, the elimination of pre-filing announcements for renewal applications will not negatively impact the public.26

V. ADDITIONAL MATTERS

Joint Commenters urge the Commission not to adopt proposals that would require a television station to run “crawls” during their programming in addition to airing specific on-air announcements related to the applications. This requirement would be unnecessarily redundant and burdensome for stations as well as potentially confusing to viewers.

Although it is not specifically included in Rule 73.3580, the FCC has informally advised that if a renewal application for an FM translator station is filed on the same form as the renewal application for a full power station, a separate public notice announcement for the FM translator station is not required. Joint Commenters recommend that the Commission codify this guidance as part of the revised rule. Similarly, Joint Commenters recommend that revisions to the rule

24 FNPRM at 15, para. 28. 25 FNPRM at 12, para. 21. Because the generation of public notices of acceptance for filing for applications filed in the FCC Licensing Management System (LMS) is not standardized in the same manner as it is for applications filed in the Consolidated Database System (CDBS), the Commission could also consider requiring broadcast stations to begin announcements within a certain number of days after an application is filed. 26 Because the text of announcements will be standardized, Joint Commenters also recommend that the Commission eliminate the requirement that broadcasters include the text of renewal application public notice announcements with the certification that is uploaded to the online public file.

7 make clear that HD channels need to broadcast on-air public notice announcements only if the announcements are included in programming an HD channel is rebroadcasting. For example, if

Station WXYZ rebroadcasts Station WQQQ on WXYZ HD-2, it would not be required to insert public notice announcements relating to WXYZ on the HD-2 channel but would include announcements WQQQ is broadcasting.

VI. CONCLUSION

For the reasons set forth above, Joint Commenters support the Commission’s proposals to replace newspaper announcements with online announcements and to streamline the content and timing of on-air public notice announcements. The current rules are outdated and inconsistent with how listeners and viewers obtain information in today’s world. They also impose unnecessary regulatory burdens on broadcasters. The revisions proposed in the FNPRM will reduce the burdens on broadcasters and increase the likelihood that the public will promptly and effectively obtain important information about FCC applications.

Respectfully submitted,

JOINT COMMENTERS

By: /s/ Sally A. Buckman Jonathan Garvin Lerman Senter PLLC 2001 L Street, N.W., Suite 400 Washington, DC 20036

November 18, 2019 Their Attorneys

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ATTACHMENT A Attachment A

Broadcast Licensees

American General Media

KABG(FM), Los Alamos, NM KBOX(FM), Lompoc, CA KDGO(AM), Durango, CO KEBT(FM), Lost Hills, CA KENN(AM), Farmington, NM KERN(AM), Wasco-Greenacres, CA KFJA-FM, Pecos, NM KGEO(AM), Bakersfield, CA KGFM(FM), Bakersfield, CA KHFM(FM), Santa Fe, NM KIOT(FM), Los Lunas, NM KISV(FM), Bakersfield, CA KISZ-FM, Cortez, CO KJFA(AM), Belen, NM KKAL(FM), Paso Robles, CA KKDG(FM), Durango, CO KKJG(FM), San Luis Obispo, CA KKRG-FM, Santa Fe, NM KKSS(FM), Santa Fe, NM KKXX-FM, Shafter, CA KLVO(FM), Belen, NM KPAT(FM), Orcutt, CA KPRT-FM, Kirtland, NM KPTE(FM), Bayfield, CO KRQK(FM), Lompoc, CA KRTZ(FM), Cortez, CO KRWN(FM), Farmington, NM KSMA(AM), Santa Maria, CA KSNI-FM, Santa Maria, CA KSTT-FM, Atascadero, CA KVEC(AM), San Luis Obispo, CA KVFC(AM), Cortez, CO KZOZ(FM), San Luis Obispo, CA WISZ-FM, Cortez. CO WVFC(AM), Cortez, CO

Beasley Media Group Licenses, LLC

KCYE(FM), Boulder City, NV KDWN(AM), Las Vegas, NV KKLZ(FM), Las Vegas, NV KOAS(FM), Dolan Springs, AZ KVGS(FM), Meadview, AZ WAEC(AM), Atlanta, GA WAZZ(AM), Fayetteville, NC WBAV-FM, Gastonia, NC WBCN(AM), Charlotte, NC WBEN-FM, Philadelphia, PA WBOS(FM), Brookline, MA WBQT(FM), Boston, MA WBZ-FM, Boston, MA WCHZ-FM, Warrenton, GA WCSX(FM), Birmingham, MI WCTC(AM), New Brunswick, NJ WDHA-FM, Dover, NJ WDMK(FM), Detroit, MI WDRR(FM), Martinez, GA WFLB(FM), Laurinburg, NC WGAC(AM), Augusta, GA WGAC-FM, Harlem, GA WGUS-FM, New Ellenton, SC WHFS(AM), Seffner, FL WHHD(FM), Clearwater, SC WHSR(AM), Pompano Beach, FL WJBR-FM, Wilmington, DE WJBX(FM), North Fort Myers, FL WJPT(FM), Fort Myers, FL WJRZ-FM, Manahawkin, NJ WKLB-FM, Waltham, MA WKML(FM), Lumberton, NC WKQC(FM), Charlotte, NC WKXC-FM, Aiken, SC WLLD(FM), Lakeland, FL WMGC-FM, Detroit, MI WMGK(FM), Philadelphia, PA WMGQ(FM), New Brunswick, NJ WMMR(FM), Philadelphia, PA WMTR(AM), Morristown, NJ WNKS(FM), Charlotte, NC WPBB(FM), Holmes Beach, FL WPEG(FM), Concord, NC WPEN(FM), Burlington, NJ WQYK-FM, St. Petersburg, FL 2

WRAT(FM), Point Pleasant, NJ WRBQ-FM, Tampa, FL WRCA(AM), Watertown, MA WRDW(AM), Augusta, GA WRIF(FM), Detroit, MI WROR-FM, Framingham, MA WRXK-FM, Bonita Springs, FL WSBR(AM), Boca Raton, FL WSOC-FM, Charlotte, NC WTEL(AM), Philadelphia, PA WTMR(AM), Camden, NJ WUKS(FM), St. Pauls, NC WWCN(AM), Fort Myers Beach, FL WWDB(AM), Philadelphia, PA WWNN(AM), Pompano Beach, FL WWWE(AM), Hapeville, GA WXKB(FM), Cape Coral, FL WXTU(FM), Philadelphia, PA WYUU(FM), Safety Harbor, FL WZFX(FM), Whiteville, NC

Connecticut Public Broadcasting, Inc.

WEDH, Hartford, CT WEDN, Norwich, CT WEDW, Stamford, CT WEDW-FM, Stamford, CT WEDY, New Haven, CT WNPR(FM), Meriden, CT WPKT(FM), Norwich, CT WRLI-FM, Southampton, NY

Cumulus Media Inc.

KAAY(AM), Little Rock, AR KABC(AM), Los Angeles, CA KAMO-FM, Rogers, AR KAOK(AM), Lake Charles, LA KARN(AM), Little Rock, AR KARN-FM, Sheridan, AR KARX(FM), Canyon, TX KATC-FM, Colorado Springs, CO KATM(FM), Modesto, CA KATT-FM, Oklahoma City, OK KAYD-FM, Silsbee, TX KBBM(FM), Jefferson City, MO

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KBBQ-FM, Van Buren, AR KBBY-FM, Ventura, CA KBCY(FM), Tye, TX KBED(AM), Nederland, TX KBEE(FM), Salt Lake City, UT KBER(FM), Ogden, UT KBGG(AM), Des Moines, IA KBIU(FM), Lake Charles, LA KBOI(AM), Boise, ID KBUL-FM, Carson City, NV KBXR(FM), Columbia, MO KBZU(FM), Albuquerque, NM KCDD(FM), Hamlin, TX KCFX(FM), Harrisonville, MO KCHZ(FM), Ottawa, KS KCJK(FM), Garden City, MO KCMO(AM), Kansas City, MO KCMO-FM, Shawnee, KS KCSF(AM), Colorado Springs, CO KCUB(AM), Tucson, AZ KDJK(FM), Mariposa, CA KDRF(FM), Albuquerque, NM KDVB(FM), Effingham, KS KDVV(FM), Topeka, KS KEHK(FM), Brownsville, OR KENZ(FM), Provo, UT KESP(AM), Modesto, CA KFAY(AM), Farmington, AR KFFG(FM), Los Altos, CA KFOG(AM), Little Rock, AR KFRU(AM), Columbia, MO KGGO(FM), Des Moines, IA KGO(AM), San Francisco, CA KHAY(FM), Ventura, CA KHKI(FM), Des Moines, IA KHKK(FM), Modesto, CA KHOP(FM), Oakdale, CA KHTB(FM), Ogden, UT KHXS(FM), Merkel, TX KHYT(FM), Tucson, AZ KIIM-FM, Tucson, AZ KIKR(AM), Beaumont, TX KIPR(FM), Pine Bluff, AR KIZN(FM), Boise, ID KJJY(FM), West Des Moines, IA KJMO(FM), Linn, MO

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KJOY(FM), Stockton, CA KKAT(FM), Salt Lake City, UT KKEG(FM), Bentonville, AR KKFM(FM), Colorado Springs, CO KKGB(FM), Sulphur, LA KKGL(FM), Nampa, ID KKMG(FM), Pueblo, CO KKND(FM), Port Sulphur, LA KKOB(AM), Albuquerque, NM KKOH(AM), Reno, NV KKPK(FM), Colorado Springs, CO KKWD(FM), Bethany, OK KLAL(FM), Wrightsville, AR KLIF(AM), Dallas, TX KLIF-FM, Haltom City, TX KLIK(AM), Jefferson City, MO KLSZ-FM, Fort Smith, AR KLUR(FM), Wichita Falls, TX KMAJ(AM), Topeka, KS KMAJ-FM, Carbondale, KS KMCK-FM, Prairie Grove, AR KMEZ(FM), Belle Chasse, LA KMGA(FM), Albuquerque, NM KMGV(FM), Fresno, CA KMJ(AM), Fresno, CA KMJ-FM, Fresno, CA KMJJ-FM, Shreveport, LA KMJK(FM), North Kansas City, MO KNBR(AM), San Francisco, CA KNEK(AM), Washington, LA KNEK-FM, Washington, LA KNEV(FM), Reno, NV KNML(AM), Albuquerque, NM KNRQ(FM), Harrisburg, OR KNSH(AM), Canyon, TX KOBQ(FM), Albuquerque, NM KOLI(FM), Electra, TX KOMS(FM), Poteau, OK KOQL(FM), Ashland, MO KPLA(FM), Columbia, MO KPLX(FM), Fort Worth, TX KPUR(AM), Amarillo, TX KPUR-FM, Claude, TX KPZK(AM), Little Rock, AR KQFC(FM), Boise, ID KQHN(FM), Waskom, TX

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KQIZ-FM, Amarillo, TX KQLK(FM), De Ridder, LA KQRS-FM, Golden Valley, MN KQSM-FM, Fayetteville, AR KQXC-FM, Wichita Falls, TX KQXL-FM, New Roads, LA KQXY-FM, Beaumont, TX KRBE(FM), Houston, TX KRMD(AM), Shreveport, LA KRMD-FM, Oil City, LA KRMW(FM), Cedarville, AR KRRQ(FM), Lafayette, LA KRST(FM), Albuquerque, NM KRUZ(FM), Oak View, CA KSAN(FM), San Mateo, CA KSCR(AM), Eugene, OR KSCS(FM), Fort Worth, TX KSFO(AM), San Francisco, CA KSKS(FM), Fresno, CA KSMB(FM), Lafayette, LA KSZR(FM), Oro Valley, AZ KTBL(AM), Los Ranchos, NM KTCK(AM), Dallas, TX KTCK-FM, Flower Mound, TX KTCT(AM), San Mateo, CA KTCX(FM), Beaumont, TX KTIK(AM), Nampa, ID KTIK-FM, New Plymouth, ID KTLT(FM), Anson, TX KTOP(AM), Topeka, KS KTOP-FM, St. Mary’s, KS KTUC(AM), Tucson, AZ KUBL-FM, Salt Lake City, UT KUGN(AM), Eugene, OR KUJZ(FM), Creswell, OR KURB(FM), Little Rock, AR KVEN(AM), Ventura, CA KVMA-FM, Shreveport, LA KVOR(AM), Colorado Springs, CO KVYB(FM), Santa Barbara, CA KWIC(FM), Topeka, KS KWIN(FM), Lodi, CA KWNN(FM), Turlock, CA KWPN(AM), Moore, OK KWQW(FM), Boone, IA KWYE(FM), Fresno, CA

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KWYL(FM), South Lake Tahoe, CA KXKC(FM), New Iberia, LA KXXR(FM), Minneapolis, MN KXZZ(AM), Lake Charles, LA KYIS(FM), Oklahoma City, OK KYKZ(FM), Lake Charles, LA KYNG(AM), Springdale, AR KYYI(FM), Burkburnett, TX KZEL-FM, Eugene, OR KZRK-FM, Canyon, TX WAAV(AM), Leland, NC WABC(AM), New York, NY WABD(FM), Mobile, AL WALG(AM), Albany, GA WAOA-FM, Melbourne, FL WAPI(AM), Birmingham, AL WAQX-FM, Manlius, NY WARM(AM), Scranton, PA WARM-FM, York, PA WAYS(AM), Macon, GA WBAP(AM), Fort Worth, TX WBBF(AM), Buffalo, NY WBBL(AM), Whitehall, MI WBBW(AM), Youngstown, OH WBHD(FM), Olyphant, PA WBHT(FM), Mountain Top, PA WBLX-FM, Mobile, AL WBMQ(AM), Savannah, GA WBNQ(FM), Bloomington, IL WBSX(FM), Hazleton, PA WBWN(FM), Le Roy, IL WBZE(FM), Tallahassee, FL WBZF(FM), Hartsville, SC WCMG(FM), Latta, SC WCOA(AM), Pensacola, FL WCTO(FM), Easton, PA WCYN-FM, Cynthiana, KY WDAI(FM), Pawleys Island, SC WDEN-FM, Macon, GA WDLT-FM, Saraland, AL WDRQ(FM), Detroit, MI WDUZ(AM), Green Bay, WI WDUZ-FM, Brillion, WI WDVD(FM), Detroit, MI WDZZ-FM, Flint, MI WEAN-FM, Wakefield-Peacedale, RI

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WEAS-FM, Springfield, GA WEDG(FM), Buffalo, NY WEEX(AM), Easton, PA WEGC(FM), Sasser, GA WEMX(FM), Kentwood, LA WFAS(AM), White Plains, NY WFBE(FM), Flint, MI WFMS(FM), Fishers, IN WFNC(AM), Fayetteville, NC WFTK(FM), Lebanon, OH WFTW(AM), Ft. Walton Beach, FL WFYR(FM), Elmwood, IL WGFX(FM), Gallatin, TN WGKX(FM), Memphis, TN WGLD(AM), Manchester Township, PA WGLF(FM), Tallahassee, FL WGLO(FM), Pekin, IL WGNI(FM), Wilmington, NC WGOC(AM), Kingsport, TN WGOK(AM), Mobile, AL WGOW(AM), Chattanooga, TN WGOW-FM, Soddy-Daisy, TN WGRF(FM), Buffalo, NY WGRR(FM), Hamilton, OH WGVX(FM), Lakeville, MN WHBT(AM), Tallahassee, FL WHBX(FM), Tallahassee, FL WHGB(AM), Harrisburg, PA WHHY-FM, Montgomery, AL WHKR(FM), Rockledge, FL WHLD(AM), Niagara Falls, NY WHNN(FM), Bay City, MI WHOT-FM, Youngstown, OH WHRP(FM), Gurley, AL WHTS(FM), Coopersville, MI WHTT-FM, Buffalo, NY WIBR(AM), Baton Rouge, LA WILZ(FM), Saginaw, MI WIOG(FM), Bay City, MI WIOV(AM), Reading, PA WIOV-FM, Ephrata, PA WISW(AM), Columbia, SC WIVK-FM, Knoxville, TN WIWF(FM), Charleston, SC WIXO(FM), Peoria, IL WIXV(FM), Savannah, GA

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WJAD(FM), Leesburg, GA WJBC(AM), Bloomington, IL WJBC-FM, Pontiac, IL WJCL-FM, Savannah, GA WJCW(AM), Johnson City, TN WJEZ(FM), Dwight, IL WJJK(FM), Noblesville, IN WJLG(AM), Savannah, GA WJOX(AM), Birmingham, AL WJOX-FM, Birmingham, AL WJQX(FM), Helena, AL WJR(AM), Detroit, MI WJRW(AM), Grand Rapids, MI WJTQ(FM), Pensacola, FL WKAK(FM), Albany, GA WKDF(FM), Nashville, TN WKHX-FM, Marietta, GA WKIM(FM), Munford, TN WKKO(FM), Toledo, OH WKLQ(FM), Holland, MI WKOR-FM, Columbus, MS WKOS(FM), Kingsport, TN WKQX(FM), Chicago, IL WKQZ(FM), Midland, MI WKRU(FM), Allouez, WI WKSM(FM), Ft. Walton Beach, FL WKXS-FM, Leland, NC WKY(AM), Oklahoma City, OK WLAV-FM, Grand Rapids, MI WLAW(FM), Whitehall, MI WLBY(AM), Saline, MI WLCS(FM), North Muskegon, MI WLEV(FM), Allentown, PA WLFF(FM), Georgetown, SC WLLF(FM), Mercer, PA WLS(AM), Chicago, IL WLS-FM, Chicago, IL WLTI(AM), New Castle, IN WLTO(FM), Nicholasville, KY WLUP(FM), Cambridge, MN WLWI(AM), Montgomery, AL WLWI-FM, Montgomery, AL WLXC(FM), Columbia, SC WLXX(FM), Lexington, KY WLZN(FM), Macon, GA WLZR(AM), Melbourne, FL

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WMAC(AM), Macon, GA WMAL(AM), Washington, DC WMAL-FM, Woodbridge, VA WMDH-FM, New Castle, IN WMEZ(FM), Pensacola, FL WMGB(FM), Montezuma, GA WMGL(FM), Ravenel, SC WMGS(FM), Wilkes-Barre, PA WMGU(FM), Southern Pines, NC WMIM(FM), Luna Pier, MI WMNX(FM), Wilmington, NC WMOS(FM), Stonington, CT WMSP(AM), Montgomery, AL WMXS(FM), Montgomery, AL WMXT(FM), Pamplico, SC WMXU(FM), Starkville, MS WNAM(AM), Neenah-Menasha, WI WNBM(FM), Bronxville, NY WNCV(FM), Shalimar, FL WNDX(FM), Lawrence, IN WNKT(FM), Eastover, SC WNML(AM), Knoxville, TN WNML-FM, Friendsville, TN WNMQ(FM), Columbus, MS WNNF(FM), Cincinnati, OH WNNK-FM, Harrisburg, PA WNNX(FM), College Park, GA WNTQ(FM), Syracuse, NY WNTR(FM), Indianapolis, IN WODE-FM, Easton, PA WOFX-FM, Cincinnati, OH WOGB(FM), Reedsville, WI WOGT(FM), East Ridge, TN WOKI(FM), Oliver Springs, TN WOMG(FM), Lexington, SC WORC-FM, Webster, MA WOSH(AM), Oshkosh, WI WPEZ(FM), Jeffersonville, GA WPIC(AM), Sharon, PA WPKR(FM), Omro, WI WPLJ(FM), New York, NY WPRO(AM), Providence, RI WPRO-FM, Providence, RI WPRV(AM), Providence, RI WQGN-FM, Groton, CT WQHZ(FM), Erie, PA

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WQKL(FM), Ann Arbor, MI WQLH(FM), Green Bay, WI WQPD(FM), Marion, SC WQQK(FM), Goodlettsville, TN WQQO(FM), Sylvania, OH WQSM(FM), Fayetteville, NC WQUT(FM), Johnson City, TN WQVE(FM), Albany, GA WQXA-FM, York, PA WQXK(FM), Salem, OH WRBO(FM), Como, MS WRCQ(FM), Dunn, NC WRIE(AM), Erie, PA WRKN(FM), Picayune, MS WROK-FM, Sebastian, FL WRQN(FM), Bowling Green, OH WRQQ(FM), Hammond, LA WRQX(FM), Washington, DC WRRM(FM), Cincinnati, OH WRRX(FM), Gulf Breeze, FL WRWM(AM), Conway, SC WSBA(AM), York, PA WSEA(FM), Atlantic Beach, SC WSJR(FM), Dallas, PA WSKO(AM), Syracuse, NY WSKZ(FM), Chattanooga, TN WSM-FM, Nashville, TN WSMS(FM), Artesia, MS WSOM(AM), Salem, OH WSOX(FM), Red Lion, PA WSSO(AM), Starkville, MS WSSX-FM, Charleston, SC WSYN(FM), Surfside Beach, SC WTCB(FM), Orangeburg, SC WTKA(AM), Ann Arbor, MI WTKZ(AM), Allentown, PA WTMA(AM), Charleston, SC WTNR(FM), Greenville, MI WTRX(AM), Flint, MI WTYB(FM), Bluffton, SC WUHT(FM), Birmingham, AL WUMP(AM), Madison, AL WVBO(FM), Winneconne, WI WVEL(AM), Pekin, IL WVIB(FM), Holton, MI WVLK(AM), Lexington, KY

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WVLK-FM, Richmond, KY WVNN(AM), Athens, AL WVNN-FM, Trinity, AL WWCK(AM), Flint, MI WWCK-FM, Flint, MI WWFF-FM, New Market, AL WWFN-FM, Lake City, SC WWFX(FM), Southbridge, MA WWIZ(FM), West Middlesex, PA WWKI(FM), Kokomo, IN WWKL(FM), Hershey, PA WWKX(FM), Woonsocket, RI WWLD(FM), Cairo, GA WWLI(FM), Providence, RI WWLS-FM, The Village, OK WWQQ-FM, Wilmington, NC WWSN(FM), Newaygo, MI WWTN(FM), Hendersonville, TN WWWM-FM, Eden Prairie, MN WWWQ(FM), Atlanta, GA WWWW-FM, Ann Arbor, MI WWWX(FM), Oshkosh, WI WWWZ(FM), Summerville, SC WWYY(FM), Belvidere, NJ WXBM-FM, Milton, FL WXFX(FM), Prattville, AL WXKC(FM), Erie, PA WXKR(FM), Port Clinton, OH WXLM(AM), Groton, CT WXLO(FM), Fitchburg, MA WXMX(FM), Millington, TN WXNT(AM), Indianapolis, IN WXOK(AM), Port Allen, LA WXQW(AM), Fairhope, AL WXSM(AM), Blountville, TN WXTA(FM), Edinboro, PA WXTL(FM), Syracuse, NY WXZZ(FM), Georgetown, KY WYAY(FM), Gainesville, GA WYFM(FM), Sharon, PA WYMB(AM), Manning, SC WYNN(AM), Florence, SC WYNN-FM, Florence, SC WYZB(FM), Mary Esther, FL WZAT(FM), Tybee Island, GA WZCY-FM, Mechanicsburg, PA

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WZNS(FM), Ft. Walton Beach, FL WZPL(FM), Greenfield, IN WZPW(FM), Peoria, IL WZRH(FM), LaPlace, LA WZRR(FM), Birmingham, AL WZYP(FM), Athens, AL

Entercom License, LLC

KALC(FM), Denver, CO KALV-FM, Phoenix, AZ KAMP-FM, Los Angeles, CA KAMX(FM), Luling, TX KBZT(FM), San Diego, CA KCBS(AM), San Francisco, CA KCBS-FM, Los Angeles, CA KCSP(AM), Kansas City, MO KDGS(FM), Andover, KS KDKA(AM), Pittsburgh, PA KDKA-FM, Pittsburgh, PA KEYN-FM, Wichita, KS KEZK-FM, St. Louis, MO KEZW(AM), Aurora, CO KFBZ(FM), Haysville, KS KFH(AM), Wichita, KS KFRC-FM, San Francisco, CA KFRG(FM), San Bernardino, CA KFTK-FM, Florissant, MO KFXX(AM), Portland, OR KGMZ(AM), San Francisco, CA KGMZ-FM, San Francisco, CA KGON(FM), Portland, OR KHMX(FM), Houston, TX KHTP(FM), Tacoma, WA KIFM(AM), West Sacramento, CA KIKK(AM), Pasadena, TX KILT(AM), Houston, TX KILT-FM, Houston, TX KISW(FM), Seattle, WA KITS(FM), San Francisco, CA KJCE(AM), Rollingwood, TX KJKK(FM), Dallas, TX KKDO(FM), Fair Oaks, CA KKHH(FM), Houston, TX KKMJ-FM, Austin, TX KKWF(FM), Seattle, WA

13

KLLC(FM), San Francisco, CA KLOL(FM), Houston, TX KLUC-FM, Las Vegas, NV KLUV(FM), Dallas, TX KMBZ(AM), Kansas City, MO KMBZ-FM, Kansas City, MO KMLE(FM), Chandler, AZ KMNB(FM), Minneapolis, MN KMOX(AM), St. Louis, MO KMTT(AM), Vancouver, WA KMVK(FM), Fort Worth, TX KMXB(FM), Henderson, NV KNDD(FM), Seattle, WA KNOU(FM), St. Louis, MO KNRK(FM), Camas, WA KNSS(AM), Wichita, KS KNSS-FM, Clearwater, KS KNX(AM), Los Angeles, CA KOOL-FM, Phoenix, AZ KQKS(FM), Lakewood, CO KQMT(FM), Denver, CO KQPS(FM), Palm Desert, CA KQRC-FM, Leavenworth, KS KRBQ(FM), San Francisco, CA KRBZ(FM), Kansas City, MO KRLD(AM), Dallas, TX KRLD-FM, Fort Worth, TX KROQ-FM, Pasadena, CA KRSK(FM), Molalla, OR KRTH(FM), Los Angeles, CA KRXQ(FM), Sacramento, CA KSEG(FM), Sacramento, CA KSFM(FM), Woodland, CA KSON(FM), San Diego, CA KSWD(FM), Seatttle, WA KTWV(FM), Los Angeles, CA KUDL(FM), Sacramento, CA KVIL(FM), Highland Park-Dallas, TX KWFN(FM), San Diego, CA KWJJ-FM, Portland, OR KWOD(AM), Kansas City, KS KXFG(FM), Menifee, CA KXNT(AM), North Las Vegas, NV KXQQ-FM, Henderson, NV KXSN(FM), San Diego, CA KXST(AM), North Las Vegas, NV

14

KXTE(FM), Pahrump, NV KYCH-FM, Portland, OR KYKY(FM), St. Louis, MO KYW(AM), Philadelphia, PA KYXY(FM), San Diego, CA KYYS(AM), Kansas City, KS KZJK(FM), St. Louis Park, MN KZPT(FM), Kansas City, KS WAAF(FM), Westborough, MA WAOK(AM), Atlanta, GA WAXY(AM), South Miami, FL WBBM(AM), Chicago, IL WBBM-FM, Chicago, IL WBEB(FM), Philadelphia, PA WBEE-FM, Rochester, NY WBEN(AM), Buffalo, NY WBMX(FM), Chicago, IL WBT(AM), Charlotte, NC WBT-FM, Chester, SC WBTJ(FM), Richmond, VA WBZA(FM), Rochester, NY WBZU(AM), Scranton, PA WBZZ(FM), New Kensington, PA WCBS(AM), New York, NY WCBS-FM, New York, NY WCCO(AM), Minneapolis, MN WCFS-FM, Elmwood Park, IL WCMF-FM, Rochester, NY WDAF-FM, Liberty, MO WDCH-FM, Bowie, MD WDOK(FM), Cleveland, OH WDSY-FM, Pittsburgh, PA WDZH(FM), Detroit, MI WEAL(AM), Greensboro, NC WEEI(AM), Boston, MA WEEI-FM, Lawrence, MA WEZB(FM), New Orleans, LA WFAN(AM), New York, NY WFAN-FM, New York, NY WFBC-FM, Greenville, SC WFNZ(AM), Charlotte, NC WGGY(FM), Scranton, PA WGR(AM), Buffalo, NY WHLL(AM), Springfield, MA WIAD(FM), Bethesda. MD WILK(AM), Wilkes-Barre, PA

15

WILK-FM, Avoca, PA WINS(AM), New York, NY WIP-FM, Philadelphia, PA WJFK(AM), Morningside, MD WJFK-FM, Manassas, VA WJMH(FM), Reidsville, NC WJZ(AM), Baltimore, MD WJZ-FM, Catonsville, MD WKBU(FM), New Orleans, LA WKIS(FM), Boca Raton, FL WKRF(FM), Tobyhanna, PA WKRK-FM, Cleveland Heights, OH WKRZ(FM), Freeland, PA WKSE(FM), Niagara Falls, NY WKTK(FM), Crystal River, FL WKXJ(FM), Crystal River, FL WKZN(AM), West Hazleton, PA WLFP(FM), Germantown, TN WLIF(FM), Baltimore, MD WLKK(FM), Wethersfield Twnshp, NY WLMG(FM), New Orleans, LA WLND(FM), Signal Mountain, TN WLNK(FM), Charlotte, NC WLYF(FM), Miami, FL WLZL(FM), College Park, MD WMAS-FM, Enfield, CT WMC(AM), Memphis, TN WMC-FM, Memphis, TN WMFS(AM), Memphis, TN WMFS-FM, Bartlett, TN WMHX(FM), Waunakee, WI WMJX(FM), Boston, MA WMMM-FM, Verona, WI WMQX(FM), Pittston, PA WMXJ(FM), Pompano Beach, FL WMYX-FM, Milwaukee, WI WNCX(FM), Cleveland, OH WNEW-FM, New York, NY WNSH(FM), Newark, NJ WNVZ(FM), Norfolk, VA WNYL(FM), New York, NY WOCL(FM), Deland, FL WODS(FM), Boston, MA WOGL(FM), Philadelphia, PA WOLX-FM, Baraboo, WI WOMC(FM), Detroit, MI

16

WOMX-FM, Orlando, FL WORD(AM), Spartanburg, SC WPAW(FM), Winston Salem, NC WPET(AM), Greensboro, NC WPGC-FM, Morningside, MD WPHT(AM), Philadelphia, PA WPOW(FM), Miami, FL WPTE(FM), Virginia Beach, VA WPXY-FM, Rochester, NY WQAL(FM), Cleveland, OH WQAM(AM), Miami, FL WQMG-FM, Greensboro, NC WQMP(FM), Daytona Beach, FL WRCH(FM), New Britain, CT WRNL(AM), Richmond, VA WROC(AM), Rochester, NY WROQ(FM), Anderson, SC WRVA(AM), Richmond, VA WRVQ(FM), Richmond, VA WRVR(FM), Memphis, TN WRXL(FM), Richmond, VA WRXR-FM, Rossville, GA WSCR(AM), Chicago, IL WSFS(FM), Miramar, FL WSKY-FM, Micanopy, FL WSMW(FM), Greensboro, NC WSPA-FM, Spartanburg, SC WSSP(AM), Milwaukee, WI WSTR(FM), Smyrna, GA WTDY-FM, Philadelphia, PA WTIC(AM), Hartford, CT WTIC-FM, Hartford, CT WTPT(FM), Forest City, NC WTSS(FM), Buffalo, NY WTVR-FM, Richmond, VA WUSN(FM), Chicago, IL WUSY(FM), Cleveland, TN WVEE(FM), Atlanta, GA WVEI(AM), Worcester, MA WVEI-FM, Westerly, RI WVKL(FM), Norfolk, VA WWBX(FM), Boston, MA WWDE-FM, Hampton, VA WWEI(FM), Easthampton, MA WWJ(AM), Detroit, MI WWKB(AM), Buffalo, NY

17

WWL(AM), New Orleans, LA WWL-FM, Kenner, LA WWMX(FM), Baltimore. MD WWWL(AM), New Orleans, LA WWWS(AM), Buffalo, NY WXRT(FM), Chicago, IL WXSS(FM), Wauwatosa, WI WXYT(AM), Detroit, MI WXYT-FM, Detroit, MI WYCD(FM), Detroit, MI WYRD(AM), Greenville, SC WYRD-FM, Simpsonville, SC WZGC(FM), Atlanta, GA WZMX(FM), Hartford, CT

Galaxy Communications, LLC

WIXT(AM), Little Falls, NY WKLL(FM), Frankfort, NY WKRH(FM), Fair Haven, NY WKRL-FM, North Syracuse, NY WRNY(AM), Rome, NY WSGO(AM), Oswego, NY WTKV(FM), Minetto, NY WTKW(FM), Bridgeport, NY WTLA(AM), North Syracuse, NY WTLB(AM), Utica, NY WUMX(FM), Rome, NY WZUN(AM), Sandy Creek-Pulaski, NY WZUN-FM, Phoenix, NY

Good Karma Brands Milwaukee, LLC

WAUK(AM), Jackson, WI WKTI(FM), Milwaukee, WI WTMJ(AM), Milwaukee, WI

Good Karma Broadcasting, LLC

WBEV(AM), Beaver Dam, WI WEFL(AM), Tequesta, FL WKNR(AM), Cleveland, OH WTLX(FM), Monona, WI WTTN(AM), Columbus, WI

18

WUUB(FM), Jupiter, FL WWGK(AM), Cleveland, OH WXRO(FM), Beaver Dam, WI

KWHY-22 Broadcasting, LLC

KBEH(DT), Garden Grove, CA KPWR(FM), Los Angeles, CA KWHY-TV(DT), Los Angeles, CA

Meruelo Media, LLC

KDAY(FM), Redondo Beach, CA KDEY-FM, Ontario, CA KLOS(FM), Los Angeles, CA

Sarkes Tarzian, Inc.

KTVN(DT), Reno, NV WAJI(FM), Fort Wayne, IN WGBJ(FM), Auburn, IN WGCL(AM), Bloomington, IN WLDE(FM), Fort Wayne, IN WRCB(DT), Chattanooga, TN WTTS(FM), Trafalgar, IN

WNET

WLIW(DT), Garden City, NY WMBQ-CD, New York, NY WNDT-CD, Manhattan. NY WNET(DT), Newark, NJ

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