DA 93-1554 Federal Communications Commission Record 9 FCC Red No. 2

its "area of dominant influence," or ADI, as defined by the Before the Arbitron audience research organization.4 An ADI is a Federal Communications Commission geographic market designation that defines each television Washington, D.C. 20554 market exclusive of others, based on measured viewing patterns. Essentially, each county in the United States is allocated to a market based on which home-market stations In re: receive a preponderance of total viewing hours in the county. For purposes of this calculation, both over-the-air LIMA COMMUNICATIONS CSR-3825-A and viewing are included.5 CORPORATION 3. This section of the 1992 Cable Act also provides that the Commission may: Lima,

For Modification of Station with respect to a particular television broadcast sta tion, include additional communities within its tele WLIO-TV©s ADI vision market or exclude communities from such station©s television market to better effectuate the purposes of this section. MEMORANDUM OPINION AND ORDER

Adopted: December 8, 1993; Released: January 18, 1994 In considering such requests, the 1992 Cable Act provides that: By the Chief, Mass Media Bureau: the Commission shall afford particular attention to the value of localism by taking into account such INTRODUCTION factors as- l..Lima Communications Corporation ("WLIO-TV"], li censee of Station WLIO-TV (NBC, Channel 35), Lima, (I) whether the station, or other stations located in Ohio, has filed the captioned petition for special relief the same area, have been historically carried on the seeking to include 98 communities in Auglaize, Hancock, cable system or systems within such community: Hardin, Mercer, Putnam, and Van Wert Counties, Ohio, (II) whether the provides coverage within the Lima, Ohio "area of dominant influence" for or other local service to such community: purposes of the cable television mandatory broadcast signal carriage rules. 1 WLIO-TV©s petition is opposed by Outlet (III) whether any other television station that is eli Broadcasting, Inc. ["WCMH-TV"]. licensee of Station gible to be carried by a cable system in such commu WCMH-TV (NBC, Channel 4), Columbus, Ohio, and by nity in fulfillment of the requirements of this section Findlay TV Corporation ["W47BD"|, licensee of Low Pow provides news coverage of issues of concern to such er Television Station W47BD (Channel 47), Findlay, Ohio. community or provides carriage or coverage of sport In addition, Corporation for General Trade |"WKJG-TV"|, ing and other events of interest to the community; licensee of Station WKJG-TV (NBC, Channel 33), Fort and Wayne, , has filed comments on WLIO-TV©s peti (IV) evidence of viewing patterns in cable and tion. WLIO-TV has replied. noncable households within the areas served by the cable system or systems in such community."

BACKGROUND 4. The legislative history of this provision indicates that: 2. Pursuant to §4 of the Cable Television Consumer Protection "and Competition Act of 1992 ["1992 Cable Act") 2 and implementing "rules adopted by the Commis where the presumption in favor of ADI carriage sion in its Report and Order in MM Docket No. 92-259.* a would result in cable subscribers losing access to commercial television broadcast station is entitled to assert local stations because they are outside the ADI in mandatory carriage rights on cable systems located within which a local cable system operates, the FCC may the station©s market. A station©s market for this purpose is make an adjustment to include or exclude particular

© WLIO-TV initially sought also to include a ninety-ninth used for purposes of the initial implementation of the man community Mt. Victory, Ohio--within the Lima, Ohio area of datory carriage rules are those published in Arbitron©s dominant influence. This portion of the petition has been with 1991-1992 Television Market Guide. drawn. A list of all 98 communities in which WLIO-TV seeks 5 Because of the topography involved, certain counties are mandatory carriage rights is contained in the Appendix. divided into more than one sampling unit. Also, in certain 2 Pub. L. No. 102-385, 106 Stat. 1460 (1992). circumstances, a station may have its home county assigned to 3 8 FCC Red 2965, 2976-2977 (1993). an ADI even though it receives less than a preponderance of the 4 Section 4 of the 1992 Cable Act specifies that a commercial audience in that county. For a more complete description of broadcasting station©s market shall be determined in the man how counties are allocated, see Arbitron©s Description of Meth ner provided in §73.3555(d)(3)(i) of the Commission©s Rules, as odology. in effect on May 1, 1991. This section of the rules, now s 47 U.S.C. §534(h)(l)(C)(ii). redesignated §73.3555(e)(3)(i), refers to Arbitron©s ADI for pur poses of the broadcast multiple ownership rules. Section 76.55(e) of the Commission©s Rules provides that the ADls to be

274 9 FCC Red No. 2 Federal Communications Commission Record DA 93-1554

communities from a television station©s market con to devote no more than one-third of the system©s activated sistent with Congress© objective to ensure that televi channel capacity to compliance with the mandatory signal sion stations be carried in the areas which they serve carriage obligations; 2) the station is responsible for and which form their economic market. delivering a good quality signal to the principal headend of the system; 3) indemnification may be required for any increase in copyright liability resulting from carriage; and 4) the system operator is not required to carry the signal of any station whose signal substantially duplicates the signal [This subsection] establishes certain criteria which the of any other local signal carried, or the signal of more than Commission shall consider in acting on requests to one local station affiliated with a particular broadcast net modify the geographic area in which stations have work. If, pursuant to these requirements, a system operator signal carriage rights. These factors are not intended elects to carry the signal of only one such duplicating to be exclusive, but may be used to demonstrate that signal, the operator is obliged to carry the station from the a community is part of a particular station©s market.© ADI whose is closest to the principal headend of the cable system. 10 Accordingly, based on the specific circumstances involved, the addition of commu 5. The Commission provided guidance in MM Docket nities to a station©s ADI may guarantee it cable carriage No. 92-259, supra, to aid decision making in these matters, and specific channel position rights, or may simply provide as follows: the system operator with an expanded list of must-carry signals from which to choose (i.e., when the system has For example, the historical carriage of the station used up its channel capacity mandated for broadcast signal could be illustrated by the submission of documents carriage, or determined which of duplicating network affili listing the cable system©s channel line-up (e.g., rate ated stations are entitled to carriage priority). cards) for a period of years. To show that the station provides coverage or other local service to the cable community (factor 2), parties may demonstrate that MARKET FACTS AND ARGUMENTS OF THE PARTIES the station places at least a Grade B coverage contour 8. The communities here in question are located in six over the cable community or is located close to the Ohio counties in four ADIs, The communities in Auglaize community in terms of mileage. Coverage of news or and Mercer Counties are located in the Dayton, Ohio ADI. other programming of interest to the community The communities in Hardin County are located in the could be demonstrated by program logs or other Columbus, Ohio ADI. The communities in Hancock and descriptions of local program offerings. The final fac Putnam Counties are located in the Toledo, Ohio ADI. tor concerns viewing patterns in the cable commu The communities in Van Wert County are located in the nity in cable and noncable homes. Audience data Fort Wayne, Indiana ADI. WLIO-TV©s Lima. Ohio ADI clearly provide appropriate evidence about this fac consists solely of Alien County, and the counties here in tor. In this regard, we note that surveys such as those question surround Alien County on all sides, largely within used to demonstrate significantly viewed status could WLIO-TV©s 35-mile zone and all within the station©s be useful. However, since this factor requires us to 55-mile zone. In addition, WLIO-TV©s predicted Grade B evaluate viewing on a community basis for cable and contour covers virtually all of the communities in ques noncable homes, and significantly viewed surveys tion. typically measure viewing only in noncable house 9. In support of its petition, WLIO-TV states that it has holds, such surveys may need to be supplemented been "carried on virtually all of the systems involved . . . with additional data concerning viewing in cable for a substantial period of time . . . ." WLIO-TV further homes. states that it provides a substantial amount of news and other programming that is responsive to local issues and Id. at 2977 (emphasis in original). concerns in the communities in question, and lists or 6. In adopting rules to implement this provision, the summarizes several examples of such programming since Commission indicated that changes requested should be 1991. and also submits a videotape. In addition. WLIO-TV considered on a community-by-community basis rather argues that there is a community of interest between its than on a county-by-county basis, and that they should be city of license and ADI and the communities WLIO-TV treated as specific to particular stations rather than ap seeks to add to its ADI. Auglaize. Hancock, and Hardin plicable in common to all stations in the market.8 The Counties, WLIO-TV notes, are in the same congressional rules further provide, in accordance with the requirements district as is Alien County. WLIO-TV also states that Mer of the 1992 Cable Act, that a station not be deleted from cer, Putnam, and Van Wert Counties are nearer to Lima carriage during the pendency of an ADI change request.9 than to any other Ohio station©s city of license, and that 7. Adding communities to a station©s ADI generally en the counties are not in the same congressional districts as titles that station to insist on cable carriage in those com the latter three communities. With respect to area viewing munities. However, this right is subject to several patterns, WLIO-TV states that it is significantly viewed in conditions: 1) a cable system operator is generally required Auglaize, Mercer. Putnam, and Van Wert Counties." and

7 H.R. Rep. 102-628, 102d Cong., 2d Sess. 97 (1992). Order, 36 FCC 2d 326, 435-437 app. B (1972). For a network 8 MM Docket No. 92-259, 8 FCC Red at 2977, 2977 n.139. station to be deemed to be significantly viewed in a community 9 47 C.F.R. §76.59. or a county, it must achieve in noncable homes a share of 10 MM Docket No. 92-259, 8 FCC Red at 2981. viewing hours of at least 3 percent (total week hours) and a net 11 See Reconsideration of the Cable Television Report and weekly circulation of at least 25 percent. 47 C.F.R. §76.5(i).

275 DA 93-1554 Federal Communications Commission Record 9 FCC Red No. 2 that 1992 Arbitron county coverage data for cable and county ADI cannot and does not accurately reflect the noncable homes combined in all six counties shows that station©s actual market and service area, and urges grant of the station currently meets or exceeds the significantly its petition. viewed criteria in these counties. This data, too. WLIO-TV 10. WCMH-TV, in opposition to WLIO-TV, argues that contends, shows that "WLIO-TV©s audiences are similar to WLIO-TV©s request "vastly exceeds the scope of relief per or greater than those of ADI NBC affiliates," as follows: missible by statute," seeking the addition of six entire counties to the station©s ADI, rather than specific commu Total Net Weekly nities. Although WLIO-TV©s petition is couched as involv County and Station Share Circulation ing communities, states WCMH-TV, most of the station©s Auglaize County supporting data is provided on a county-by-county basis, and what community-specific information is provided is WLIO-TV (NBC, Ch. 84 inadequate to justify relief. Focusing on Hardin County- 35), Lima OH WKEF (NBC, Ch. 22), 30 -the one county in question within WCMH-TV©s ADI- Dayton OH -WCMH-TV claims that WLIO-TV©s submissions show only WTVG (NBC, Ch. 13), 6 that it was carried on Hardin County cable systems in Toledo OH September 1989 and in March 1993, rather than dem onstrating continuous carriage between these dates, nor any Hancock County carriage from the time that WLIO-TV went on the air in 1953 until September 1989. Unlike other counties which WLIO-TV (NBC, Ch. 36 are encompassed by WLIO-TV©s Grade A contour, notes 35), Lima OH WTVG (NBC, Ch. 13), 21 87 WCMH-TV, Hardin County is only partially encompassed Toledo OH by the station©s Grade B contour. Nor, contends WCMH- TV, should Grade B coverage alone be determinative. With regard to specific programming, WCMH-TV notes that Hardin County WLIO-TV essentially only lists issues of concern to Hardin WLIO-TV (NBC, Ch. 10 46 County communities which the station claims to have ad 35), Lima OH dressed, rather than specific examples of programming ad WCMH-TV (NBC, Ch. 46 dressing those issues, with the exception of "Field Dog 4), Columbus OH WTVG (NBC. Ch. 13), 12 45 Trials" on certain days in 1992 and 1993. WCMH-TV states Toledo OH that WLIO-TV provides no evidence on the third statutory factor-the provision of local service by other stations en titled to carriage-which ignores WCMH-TV©s extensive Mercer County coverage of Hardin County news and events. Finally, WLIO-TV (NBC, Ch. 12 64 WCMH-TV notes that WLIO-TV provides only county 35), Lima OH viewership data rather than the requisite community-spe WKEF (NBC, Ch. 22), 1 22 cific data, which reveal low viewing shares for WLIO-TV in Dayton OH any event. WKJG-TV (NBC, Ch. 5 46 This is underscored, argues WCMH-TV. by the 33). Fort Wayne IN fact that of the responses WLIO-TV received to its cited baseball schedule promotion, only 3 percent came from Hardin County. Putnam County 11. W47BD. in opposition to WLIO-TV, argues that with WLIO-TV (NBC, Ch. 57 respect to Hancock County-the county within which 35), Lima OH W47BD©s city of license is located-WLIO-TV provides WTVG (NBC, Ch. 13), 70 Toledo OH "very little coverage of news or events . . . ." which are WKJG-TV (NBC, Ch. 13 more extensively covered by W47BD and by Toledo ADI 33), Fort Wayne IN stations. W47BD notes that it was chosen media pool co ordinator for President Bush©s visit to Hancock County in Van Wert County 1992, and not WLIO-TV, which also, according to W47BD, has not participated in covering other significant local WLIO-TV (NBC, Ch. 10 66 political events in the county. In fact, contends W47BD. 35), Lima OH the information submitted by WLIO-TV "mentioned only WKJG-TV (NBC, Ch. 12 72 33), Fort Wayne IN nine dates in the last two years when WLIO-TV broadcast news of Findlay or Hancock County, Ohio," let alone any other Hancock County communities. Nor does WLIO-TV WLIO-TV also notes that in a recent promotion in which indicate that it covers any local community sporting events it offered its viewers a schedule of the station©s Cincinnati in Hancock County, states W47BD. With regard to viewing Reds baseball broadcasts, it received "numerous" requests data, W47BD asserts that WLIO-TV©s own submissions from residents of the counties in question, and that re show that it garners little viewing in Hancock County, and quests from Auglaize, Hancock, Hardin, Mercer, and Van that the station©s own marketing materials which it submit Wert Counties constituted 54 percent of the requests re ted make no mention of Hancock County. Grant of WLIO- ceived by the station. 12 WLIO-TV contends that a single TV©s petition, W47BD contends, would diminish the

12 Specifically, WLIO-TV notes that 13 percent came from County; and 19 percent came from Van Wert County. WLIO- Auglaize County; 11 percent came from Hancock County; 3 TV also notes that it received requests from Putnam County, percent came from Hardin County; 8 percent came from Mercer but does not quantify this group of requests.

276 9 FCC Red No. 2 Federal Communications Commission Record DA 93-1554

number of available channels on Hancock County cable WLIO-TV©s petition, and agrees that it is possible for two systems that could otherwise carry W47BD, which provides affiliates of the same network to have mandatory carriage significant local news, sports, and other events coverage to rights in the same county. Findlay, Ohio and other Hancock County communities. 13 12. In commenting on WLIO-TV©s petition as it affects Van Wert County (in the Fort Wayne, Indiana ADI) and ANALYSIS AND DECISION Mercer County (in the Dayton, Ohio ADI), WKJG-TV 14. We shall grant WLIO-TV©s petition with respect to notes that it is licensed to Fort Wayne. Indiana, and is a Auglaize, Hardin, Mercer, Putnam. and Van Wert Coun local NEC station for Van Wert County. In addition, ties. We first note that WLIO-TV demonstrates a history of WKJG-TV states that it, too, is seeking to expand its own carriage on the cable systems serving the communities in carriage rights to Mercer County. However, states WKJG- question, WCMH-TV©s unsupported suggestions to the con TV, if the Commission is willing to grant both WKJG-TV trary notwithstanding. Second, WLIO-TV has shown that it and WLIO-TV mandatory carriage rights in a given county- provides coverage of and service to the communities in -that is, to consider a given county (or communities) to be question. The station©s predicted Grade B contour encom in more than one ADI for mandatory signal carriage pur passes all of the communities in question. We have pre poses, rather than transferring a county (or communities) viously stated that this is sufficient to satisfy this factor. 15 from one ADI to another then the Commission should Nevertheless, this may be challenged by a demonstration consider WLIO-TV©s petition. that a given station in fact does not provide actual pro 13. In reply, WLIO-TV states that it indeed seeks carriage gramming to a community or communities at issue, as in 98 specific communities, contrary to WCMH-TV©s asser both WCMH-TV and W47BD have attempted in the tion. As for WLIO-TV©s history of carriage, WLIO-TV notes present case, with respect to Hardin and Hancock Coun that WCMH-TV does not show that WLIO-TV has been ties, respectively. In response to WCMH-TV, however, dropped from any system between 1989 and 1992, and that WLIO-TV has submitted evidence of its programming spe in any event a review of the Television & Cable Factbook, cific to many of the communities in question in Hardin Cable and Services volumes for the past ten years confirms County, covering a wide variety of stories of interest and this, as well as WLIO-TV©s carriage since 1983. WLIO-TV concern to these communities. With respect to the fourth reiterates that its provision of Grade B service to the com factor, WLIO-TV has submitted evidence that it meets or munities in question, while not determinative, is a factor exceeds the significantly viewed criteria in the affected supporting its petition. WLIO-TV submits additional exhib communities, save for those located in Hancock County. its that indicate that since January 1992 the station has We recognize that these data are county-based, rather than aired 75 Hardin County ne^vs stories and 53 stories con community-specific. Absent evidence that such data are not cerning Hardin County sports events, in contrast to fairly reflective of viewing in the actual communities in WCMH-TV©s 5 news stories and 22 sports mentions. Turn question, we shall accept such data as probative, although ing to W47BD©s claims, 14 WLIO-TV states that it does not conclusive, in cases of this type. provide significant coverage of news, sports, and other 15. With respect to all but the communities located in events of concern to Findlay, Ohio, and other Hancock Hancock County , WLIO-TV satisfies the first, second, and County communities. Specifically, WLIO-TV submits a list fourth factors in the 1992 Cable Act. While WLIO-TV does of 42 news stories (nearly half concerning the 1992 presi not address the third factor, we nonetheless conclude that dential election) and 38 sports stories it has covered (focus WLIO-TV has justified its request to include the commu ing mostly on Findlay) since January 1992 as nities in question, save for those located in Hancock Coun demonstrating its Hancock County coverage. Moreover, ty, within its ADI. We do not believe that Congress WLIO-TV notes that it did provide extensive coverage of intended the third criterion to operate as a bar to a sta President Bush©s visit to Hancock County, albeit in a man tion©s ADI claim whenever other stations could also be ner different than that of W47BD. With regard to shown to serve the communities at issue. Rather, we be viewership data, WLIO-TV maintains that the county data lieve that this criterion was intended to enhance a station©s submitted sufficiently justifies grant of WLIO-TV©s petition. claim where it could be shown that other stations do not That other NBC stations may enjoy viewership similar to serve the communities at issue. Under such circumstances, or greater than that of WLIO-TV is irrelevant to the fact of a denial of carriage rights to the claiming station could the significant viewership that WLIO-TV does enjoy. Fi deprive cable viewers of anyH& broadcast signals that nally, WLIO-TV notes that WKJG-TV does not object to might provide programming geared to their communities. In this case, because other stations do appear to serve the communities named by WLIO-TV, this enhancement factor

13 Both §4 of the 1992 Cable Act and §76.55(d) of the Commis cannot file an opposition pursuant to §76.7(d) of the Commis sion©s Rules set forth the criteria for a low power television sion©s Rules. However, "(w|e have previously stated that ©we station to qualify for mandatory carriage rights. W47BD states intend to construe "interested person" ... as broadly as reason that it meets all but one of the criteria, which is that the 1990 ably possible.© Focus Cable of Oakland, Inc. (Oakland. Califor population of the station©s community of license not exceed nia), FCC 74-300, 46 FCC 2d 112 (1974)." Marsh Media. Ltd., 67 35,000. The 1990 population of Findlay, Ohio, states W47BD, FCC 2d 1516, 1522 (1978). We believe that, in the present case, was 35,703. it is reasonable to afford W47BD the opportunity to oppose 14 WLIO-TV argues that W47BD©s opposition should be dis WLIO-TV©s petition. missed for lack on standing on W47BD©s part. Since W47BD 15 MM Docket No. 92-259, 8 FCC Red at 2977. See also concedes that it lacks mandatory carriage rights, contends paragraph 5, supra. WLIO-TV, W47BD cannot be directly affected by grant of WLIO-TV©s petition, and is therefore not an interested person pursuant to §76.7(b) of the Commission©s Rules, and therefore

277 DA 93-1554 Federal Communications Commission Record 9 FCC Red No. 2

would not appear applicable. WLIO-TV©s showing on each to all generally applicable limitations on signal carriage of the other factors, however, is sufficient and, even absent rights, including copyright liability, signal quality, channel enhancement under the third criterion, warrants grant of capacity, and program duplication. See paragraph 7, supra. its request, except with regard to the communities located in Hancock County. 16. With respect to Hancock County, WLIO-TV has only ORDER demonstrated historic carriage, satisfying only the first cri 18. In view of the foregoing, we find that grant of terion. In response to W47BD©s challenge to WLIO-TV©s WLIO-TV©s petition, to the extent indicated above, is in the submissions, WLIO-TV fails to show that it serves Hancock public interest. County communities. Little coverage of news or events 19. Accordingly, IT IS ORDERED, pursuant to §614 of concerning Hancock County communities--with the excep the Communications Act of 1934, as amended (47 U.S.C. tion of Findlay-appears to be provided by WLIO-TV, and §534), and §76.59 of the Commission©s Rules (47 C.F.R. nearly half of WLIO-TV©s Hancock County news coverage §76.59), That the captioned petition for special relief filed focused on a single story, the 1992 presidential election. May 12, 1993 by Lima Communications Corporation IS Indeed, WLIO-TV©s marketing materials fail even to men GRANTED to the extent indicated at paragraph 17, supra, tion Hancock County. Accordingly, despite the presence of and in all other respects IS DENIED. This change shall be WLIO-TV©s predicted Grade B contour over part of Han effective in accordance with the following schedule: WLIO- cock County (five Hancock County communities-Arcadia, TV shall notify the cable systems in question in writing of Big Lick Township, Fostoria, Vanlue, and Washington its carriage and channel position elections (§§76.56, 76.57, Township-are located outside of WLIO-TV©s predicted and 76.64(f) of the Commission©s Rules) within 30 days of Grade B contour), we find that W47BD has sufficiently the release date of this Memorandum Opinion and Order. rebutted the presumption of local service created by this, The affected cable systems shall come into compliance with and WLIO-TV©s further submissions have not overcome the applicable rules within 45 days of the above notice. this rebuttal, except with respect to Findlay. As other sta 20. This action is taken by the Chief, Mass Media Bureau tions serve these communities, the enhancing third factor is pursuant to authority delegated by §0.283 of the Commis not applicable. With regard to the final factor, although the sion©s Rules. 16 viewership data submitted and available is county-based, we do note that in the six counties affected by this petition, WLIO-TV achieves its lowest viewing levels in Hancock FEDERAL COMMUNICATIONS COMMISSION County. We recognize that these viewership levels indicate that WLIO-TV exceeds the significantly viewed criteria in both cable and noncable homes in Hancock County. Nev ertheless, this is only county-wide data, and, in the face of W47BD©s submissions and the other factors noted above Roy J. Stewart which suggest that such data may not in fact be fairly Chief, Mass Media Bureau reflective of viewing in the actual communities in question, we cannot place probative value on this county-wide data for Hancock County. WLIO-TV, therefore, fails to satisfy this final factor, too, with respect to Hancock County. Therefore, WLIO-TV has satisfied only one of the four factors with respect to communities located within Han cock County, save for Findlay. With respect to Findlay, WLIO-TV satisfies both the first and second factors. In addition, as Findlay is the most populous community in Hancock County and is specifically programmed to by WLIO-TV, it is likely to be responsible for most of WLIO- TV©s viewership in the county. Accordingly, it appears that WLIO-TV satisfies the fourth factor as well with respect to Findlay, and WLIO-TV©s petition will be granted with re spect to Findlay as well. 17. Accordingly, for purposes of determining mandatory signal carriage obligations, we shall consider the commu nities listed in the Appendix in Auglaize, Hardin, Mercer, Putnam, and Van Wert Counties, and also the community of Findlay in Hancock County, to be part of the Lima, Ohio ADI with respect to WLIO-TV. as well as within the communities© current ADIs. This determination is subject

16 Pursuant to MM Docket No. 92-259, 8 FCC Red at 2978 n. 150, the Chief. Mass Media Bureau is authorized to act on requests for the inclusion or elimination of specific commu nities from local markets in accordance with the factors set forth in the 1992 Cable Act.

278 9 FCC Red No. 2 Federal Communications Commission Record DA 93-1554

APPENDIX

Communities Subject to WLIO-TV©s Petition

County (ADI) Communities

AUGLAIZE (Dayton OH) Buckland, Cridersville, Indian Lake, Long Island, Minster, Moulton, New Bremen, New Hampshire, New Knoxville, North Side, Northfork, Round head, St. Johns, St. Marys, Stokes Township, Uniopolis, Villa Nova, Wapakoneta, Waynesfield

HANCOCK (Toledo OH)* Alien Township, Alvada, Amanda Township, Arcadia, Arlington, Benton Ridge, Big Lick Township, Blanchard, Bluffton, Findlay, Fostoria, Jackson Township, Jenera, Li berty Township, Marion Township, McComb, Mt. Blanchard, Mt. Cory, Rawson, Union Township, Van Buren, Vanlue, Washington Township HARDIN (Columbus OH) Ada, Alger, Forest, Hale Township, Kenton, McGuffey, Patterson, Ridgeway, Victory

MERCER (Dayton OH) Butler Township, Celina, Chickasaw, Coldwater, Frank lin Township, Granville Township, Jefferson Township, Maria Stein, Mendon. Monte- zuma, Rockford, St. Henry, Southmoor Shores PUTNAM (Toledo OH) Blanchard Township, Cloverdale, Columbus Grove, Continental, Dupont, Fort Jennings, Gilboa, Glandorf, Greensburg Township, Jack son, Jackson Township, Jen nings, Kalida, Leipsic, Miller City, Monterey Township, Ot tawa, Ottawa Township, Ottoville, Pandora, Perry, Per ry Township, Pleasant Town ship, Union Township, West Leipsic VAN WERT (Fort Wayne IN) Delphos, Hoaglin Township, Jackson, Jackson Township, Middle Point, Ohio City, Van Wert, Willshire, Wren

* relief only granted with respect to Findlay in Hancock County

279