DA 96-185 Federal Communications Commission Record 11 FCC Red No. 5

BACKGROUND 2. Pursuant to §614 of the Communications Act and Before the implementing rules adopted by the Commission in its Re­ Federal Communications Commission port and Order in MM Docket 92-259,5 commercial televi­ Washington, D.C. 20554 sion broadcast stations are entitled to assert mandatory carriage rights on cable systems located within the station's market. A station's market for this purpose is its "area of In re: dominant influence" or ADI as defined by the Arbitron audience research organization.6 An ADI is a geographic WNNE-TV, Inc. CSR-4001-A market designation that defines each television market ex­ Hartford, CSR-4002-A clusive of others, based on measured viewing patterns. CSR-4004-A Essentially, each county in the United States is allocated to a market based on which home-market stations receive a preponderance of total viewing hours in the county. For For Modification of Station purposes of this calculation, both over-the-air and cable WNNE-TV's ADI television viewing are included.7 3. Under the Act, however, the Commission is also di­ rected to consider changes in ADI areas. Section MEMORANDUM OPINION AND ORDER 61,4(h)(l)(C) provides that the Commission may: Adopted: February 13, 1996; Released: February 2l, 1996 with respect to a particular television broadcast sta­ By the Cable Services Bureau: tion, include additional communities within its tele­ vision market or exclude communities from such station's television market to better effectuate the INTRODUCTION purposes of this section. 1. WNNE-TV, Inc. ("WNNE-TV"), licensee of commer­ cial WNNE-TV (NBC, Channel 31), Hart­ In considering such r~quests, the Act provides that: ford, Vermont, filed the captioned petitions seeking to include communities in Sullivan County, New the Commission shall afford particular attention to Hampshire;1 Cheshire County, ;2 and the value of localism by taking into account such Windham County, Vermont3 (collectively known as "the factors as -- Communities") within the Burlington, Vermont­ (I) whether the station, or other stations located in Plattsburgh, "area of dominant influence" (ADI) the same area, have been historically carried on the for the limited purpose of the mandatory cable system or systems within such community; broadcast signal carriage rules. On September 8, 1993, Group W Television, Inc. ("Group W"), licensee of Station (II) whether the television station provides coverage WBZ-TV ' (NBC, Channel 4), , Massachusetts or other local service to such community; ("WBZ-TV") filed an opposition to the petitions for special (III) whether any other television station that is eli­ 4 relief. On October 7, 1993, WNNE-TV filed a reply to the gible to be carried by a cable system in such commu­ Group W Opposition. nity in fulfillment of the requirements of this section provides news coverage of. issues of concern to such community or provides carriage or coverage of sport­ ing and other events of interest to the community; and

1 These communities are Charlestown, Claremont, Cornish. Newfane, Stratton, Stratton Mountain. Stratton Ski, Stratton Cornish (town), George Mills, Grantham, Guild, Langdon. West, West Dover, Whitingham, Williamsville, Wilmington. and Meriden, Newport, Plainfield, South Charlestown, Springfield, surrounding areas in Windham County. Sunapee, Wendell, and surrounding areas in Sullivan County. 4 On September 23, 1993, WNNE-TV filed a Consent Motion 2 These communities are Alstead, Alstead Center, Ashuelot, for an Extension to file a reply. Chesterfield, Drewsville, East Alstead, East Swanzey, 5 8 FCC Red 2965, 2976-2977 (1993). Fitzwilliam, Gilsum, Harrisville, Hinsdale, Jaffrey, Keene, 6 Section 76.55(e) of the Commission's Rules provides that the Keene Ramada-5636, Marlborough, Marlow, Nelson, North ADls to be used for purposes of the initial implementation of Swanzey, North Walpole, Richmond, Rindge, Rindge-Franklin the mandatory carriage rules are those published in Arbitron's Pierce College, Roxbury, Spofford, Surry, Swanzey, Troy, Wal­ 19

2384 11 FCC Red No. 5 Federal Communications Commission Record DA 96-185

(IV) evidence of viewing patterns in cable and 6. In adopting rules. to implement this prov1s1on, the noncable households within the areas served by the Commission indicated that changes requested should be cable system or systems in such community.8 considered on a community-by-community basis rather than on a county-by-county basis and that they should be 4. The legislative history of this provision indicates that: treated as specific to particular stations rather than ap­ 11 plicable in common to all stations in the market. . The rules further provide, in accordance with the requirements where the presumption in favor of ADI carriage of the Act, that a station not be deleted from carriage would result in cable subscribers losing access to during the pendency of an market area change request.12 local stations because they are outside the ADI in which a local cable system operates, the FCC may 7. Adding communities to a station's market area gen­ make an adjustment to include or exclude particular erally entitles that station to insist on cable carriage in communities from a television station's market con­ those communities. However, this right is subject to several sistent with Congress' objective to ensure that televi­ conditions: 1) a cable system operator is generally required sion stations be carried in the areas which they serve to devote no more than one-third of its activated channel and which form their economic market. capacity to compliance with the mandatory signal carriage obligations, 2) the station is responsible for 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 sys­ tem operator is not required to carry the signal of any [This subsection] establishes certain criteria which the station whose signal substantially duplicates the signal of Commission shall consider in acting on requests to any other local signal carried or the signals of more than modify the geographic area in which stations have one local station affiliated with a particular broadcast net­ signal carriage rights. These factors are not intended work. If, pursuant to these requirements, a system operator to be exclusive, but may be used to demonstrate that elects to carry the signal of only a single affiliate of a 9 a community is part of a particular station's market. broadcast network, it is obliged to carry the affiliate _from within the market whose is closest to the 5. The Commission provided guidance in its Report and principal headend of the cable system.° Accordingly, based Order in MM Docket 92-259, supra, to aid decision making on the specific circumstances involved, the addition of in these matters, as follows: communities to a station's market area may guarantee it cable carriage and specific channel position rights; simply For example, the historical carriage of the station provide the system operator with an expanded list of must­ could be illustrated by the submission of documents carry signals from which to choose, i.e., when it has used listing the cable system's channel line-up (e.g., rate up its channel capacity mandated for broadcast signals cards) for a period of years. To show that the station carriage, or determined which of duplicating network affili­ provides coverage or other local service to the cable. ated stations are entitled to carriage priority. community (factor 2), parties may demonstrate that the station places at least a Grade.B coverage contour over the cable community or is located close to the MARKET FACTS AND ARGUMENTS OF THE PARTIES community in terms of mileage. Coverage of news or 8. Windham County, Vermont and Sullivan County, other programming of interest to the community New Hampshire are contiguous to Windsor County, . could be demonstrated by program logs or other WNNE-TV's home county. To the south of Sullivan Coun­ descriptions of local program offerings. The final fac­ ty and across the border from Windham County is Chesh­ tor concerns viewing patterns in the cable commu­ ire County, New Hampshire. The borders of Cheshire and nity in cable and noncable homes. Audience data Windsor Counties are five miles apart: WNNE-TV's main clearly provide appropriate evidence about this fac­ transmitter in Windsor, Vermont is adjacent to Sullivan tor. In this regard, we note that surveys such as those County, is 15 miles from Windham County, and is ap­ used to demonstrate significantly viewed status could proximately 20 miles from Cheshire County. Boston is be useful. However, since this factor requires us to approximately 72 miles from Keene, Cheshire County's evaluate viewing on a community basis for cable and largest community; 80 miles from Brattleboro, Windham noncable homes, and significantly viewed surveys County's largest community; and 90 miles from Claremont, typically measure viewing only in noncable house­ Sullivan County's largest community. holds, such surveys may need to be supplemented 9. WNNE-TV requests modification of its market to in­ with additional data concerning viewing in cable clude the Communities, which are located in Sullivan and homes. 10 Cheshire Counties, New Hampshire, and Windham Coun­ ty, Vermont. WNNE-TV argues that physically, economically, and in terms of coverage and programming,

8 Communications Act of 193-l, as amended. §61-l(h)(l)(C)(ii). absent evidence that such data is not fairly reflective of viewing 47 u.s.c. §534(h)(l)(C)(ii). in the actual communities in question, we accept such data as 9 H.R. Rep. No. 628. 102d Cong., 2d Sess. 97 ( 1992). probative in cases of this type. 10 8 FCC Red at 2977 (emphasis in original). 2 47 C.F.R. §76.59. 11 8 FCC Red at 2977 n.139. Viewership data cited herein is 13 8 FCC Red at 2981. county data, rather than community-specific data. However,

2385 DA 96·185 Federal CommuniC~tions Commis~ion Record 11 FCC Red No. 5 the relationship and nexus between a station and commu­ claims that it provides in-depth local news, weather, sports nities - which WNNE-TV argues is central to a satisfactory and election coverage to viewers in the Communities. showing for modification to add to a television station's WNNE-TV states that the three counties are composed of . market -- could not be closer than between WNNE-TV and small villages, and that WNNE-TV monitors newsworthy the Communities. Windham County, Sullivan County, and events throughout the counties and broadcasts on a timely Cheshire County are all within the Boston, Massachusetts basis. WNNE-TV notes that it is aided in doing so by a ADI. WNNE-TV is located in Hartford, Vermont in Wind­ transportable satellite uplink station (Station E874053). sor County, which is assigned to the Burlington-Plattsburgh WNNE-TV lists several news stories it broadcast relating to ADI. WNNE-TV states that because the counties are rural issues of interest to the Communities throughout the three and mountainous many viewers in the Communities rely counties. In addition, WNNE-TV serves the community on cable television to receive local broadcast signals. through off-air activities such as co-sponsoring charitable 10. In support of its petitions, WNNE-TV notes that has events, organizing school tours of its facilities, and provid· been carried on all but one cable system in Sullivan Coun­ ing speakers for career days at area schools. ty since the early 1980s, 14 and on virtually all cable systems 12. In addressing the third statutory factor, WNNE-TV in Windham County since at least 1987 .15 In Cheshire believes that because of its location as the closest commer­ County, WNNE-TV has been carried on most of Cheshire's cial television station to the Counties and its familiarity twelve cable systems since at least 1987 and on one system and involvement in the community, it provides more news since 1990. 16 WNNE-TV maintains that carriage is due to and programming covering the Community than au: other the fact that it considers the Communities an integral part stations in the Boston ADI combined. The Boston stations of its principle service area and is considered by local are not located close to the communities and must of businesses as a local station over which they can reach necessity direct their programming to the stations' own city consumers in the Communities. Over a dozen different of license, Boston. businesses from each county chose to advertise on WNNE­ 13. In its opposition, Group W asserts that WNNE-TV TV in 1992. WNNE-TV argues that this demonstrates the has failed to meet the four statutory criteria. Group W importance of WNNE-TV as an advertising medium for argues that WNNE-TV "merely serves as a s_atellite" of local business that cannot afford the higher rates of Boston Television Broadcast Station (WPTZ (NBC, Channel S), or Portland, Maine stations and who need WNNE-TV to North Pole, New York, and simply rebroadcasts WPTZ reach their large market area. WNNE-TV states that it programming. Group W states that its licensee WBZ-TV places a predicted Grade A contour over all of Sullivan has a long history of carriage on cable systems in contrast County, more than half of Cheshire County and 80 percent to WNNE-TV. With respect to WNNE-TV's local news and of Windham County, and places a predicted Grade B con­ public affairs programming, Group W argues that WNNE­ tour over the remaining parts of the counties. According to TV's local news is limited to one hour a day during WNNE-TV, only one other television station, WMUR-TV weekdays and none on weekends and no public affairs (ABC, Channel 9), Manchester, New Hampshire, places a programming. Group W claims that much of WNNE-TV's predicted Grade A contour over Sullivan or Cheshire programming and news service is generated from WPTZ, Counties, and no other station places a predicted Grade A more than 120 miles away. In contrast, Group W states, contour over Windham County. WMUR-TV places a pre­ WBZ-TV broadcasts five hours of local news a day during dicted Grade B contour over 50 percent of Windham weekdays and three hours on weekends. WBZ-TV tradi­ County, and both Television Broadcast Stations WRGB tionally considers the counties an integral part of its (NBC, Channel 6) and WNYT (CBS, Channel 13), both viewership and provides news and local information for Albany-Schenectady, New York place a Grade B contour these counties. Group W states that over the past six years over 60 percent of Windham County. There are three other WBZ-TV news programming has co'v'.ered approximately stations that provide Grade B service to 25 percent of 100 stories about or of interest to the counties. Group W Sullivan County. argues that WNNE-TV cannot match WBZ-TV's news ser". 11. WNNE-TV presents data to suggest that it achieves vice in substance, quality and level. Moreover, it states that substantial viewership in both cable and noncable homes WBZ-TV provides public affairs programming that smaller in Sullivan, Cheshire, and Winc,lham Counties. 17 Signifi­ markets cannot. In addition, Group W states that Arbitron cantly, WNNE-TV points out that A.C. Nielsen in 1992 data for each county reveals that WBZ-TV is significantly 18 reassigned Sullivan County from the Boston to the viewed in the counties. · Burlington-Plattsburgh DMA. Moreover, WNNE-TV asserts 14. In reply, WNNE-TV argues that Group W's opposi­ that it provides more news coverage of the Communities tion is misleading and devoid of merit as it downplays the than any other commercial television station. WNNE-TV fact that WNNE-TV places Grade A and B contours over

14 WNNE-TV is not currently carried on Community Cable Highland Communications serving Harrisville (town) and Nel­ One CATV in Springfield, New Hampshire. son (town); on Community Cable One CA TV serving Marlow; 15 First Carolina Cable's Manchester system, which provides and on Comsat Video Enterprises. serving Keene-Ramada 5636. service to small portions of Windham County, does not carry 17 Based on A.C. Nielsen data, WNNE-TV states that its view­ WNNE-TV. In addition to systems on which the station has ing in Sullivan County was a 16% share in total viewing (27% historically been carried, WNNE-TV notes that it is currently in non-cable households), and that its average weekly cume was carried in Jacksonville, West Dover, Whitingham, and Wilming­ 59%. In Cheshire County the station's viewing was 5% (7% in ton. With respect to this latter community. the Television and non-cable households), with an average weekly cume of 36%. In Cable Factbook indicates that WNNE-TV has been carried since Windham County WNNE-TV had a 13% share ( 32% in non­ 1992. cable households), and had an average weekly cume of 62%. t6 WNNE-TV gained carriage on Warner Cable's Hinsdale A.C. Nielsen County Report 1992, County Summaries for system only in 1990. WNNE-TV is not carried on Lamont WNNE-TV Trading Area: Household Shares. · Television Systems serving Rindge-Franklin Pierce College; on 18 A network station deemed to be significantly viewed in a

2386 11 FCC Red No. 5 Federal Communications Commission Record DA 96-185 the Communities, and mm1m1zes the amount of WNNE­ and the station has only shown itself to be carried cur­ TV's local programming while inflating WBZ-TV's own rently in Jacksonville, West Dover, and Whitingham. How­ contribution to local programming. WNNE-TV states that. ever, WNNE-TV has demonstrated historic carriage with it does not rebroadcast the local news carried on WPTZ, respect to all other cable communities. but rather the station originates local news broadcasts in its 17. WNNE-TV has shown that it meets the second statu­ fully staffed Hartford studio with stories directed toward tory factor by providing coverage or other local service to the needs of Communities. WNNE-TV asserts that it only the Communities. WNNE-TV's predicted Grade A contour rebroadcasts WPTZ's NBC network and syndicated pro­ covers all of Sullivan County; 80% of Windham County gramming. WNNE-TV disputes Group W's contention that and more than half of Cheshire County and WNNE-TV WBZ-TV has been carried on some cable systems since places a Grade B over the remaining areas of Windham 1955 whereas WNNE-TV has only been carried since 1979 and Cheshire Counties.21 With respect to the communities or 1980 as legally insignificant. Group W, according to in Cheshire County on which WNNE-TV has not achieved WNNE-TV, ignores the fact that WNNE-TV began service historic carriage, we note that Nelson, Marlow, and in 1978, in contrast to WBZ-TV which .began service in Harrisville are within WNNE-TV's Grade A service con­ 1948. WNNE-TV notes that the two stations have had tour, while Rindge is at the fringe of the station's Grade B similar continuous carriage patterns, with WNNE-TV ap­ contour. The fact that WNNE-TV places a Grade A or pearing on more systems. Grade B signal over these communities in Cheshire County 15. WNNE-TV argues that Group W's characterization of is persuasive evidence that WNNE-TV provides service. to WBZ-TV's programming is misleading because the portion these communities. Moreover, WNNE-TV's showing is fur­ directed to the Communities is insignificant compared to ther supported by its coverage of news events and provision coverage of interest to its Boston viewers. WNNE-TV as­ of other local service specific to many of the Communities. serts that its coverage of the Communities far exceeds that WNNE-TV has demonstrated that the Communities are of WBZ-TV. WNNE-TV states that the bulk of WBZ-TV's close in proximity to WNNE-TV's community of license programming, unlike WNNE-TV's newscasts, is focused not and the site of its transmitter. We have previously stated on residents of Communities but on Boston, which is 70 to that the second statutory criterion may be satisfied with a 90 miles away from the Communities. WNNE-TV claims showing that the station places at least predicted Grade B that events around Boston are of no interest to residents of contour or is located close to the community in terms of the Communities. In response to Group W's claims to have mileage.22 Clearly, WNNE-TV satisfies this criterion in Sul­ broadcast 100 stories over six years (e.g., one and a half livan, Cheshire, and Windham Counties, based on the cov­ stories per month), WNNE-TV argues that this hardly evi­ erage of the station's service contours and its ·close dences a devotion or focus on needs of Communities. In proximity to the Communities. Though Group W attempts contrast, according to WNNE-TV, its full-time news staff of to rebut this by arguing that WNNE-TV provides no public eight people broadcast 200 stories concerning Communities affairs programming and limited local news for the Com­ over the past 2 years and more than 400 stories over the munities, the petitions provide numerous examples of pro­ past six years, four times WBZ-TV's local coverage. gramming directed toward the needs and interests of the WNNE-TV contends that Group W's viewership data is Communities. misleading because both stations have significant viewing 18. Group W also challenges WNNE-TV's petition under and during the time periods that include local newscasts the third criterion, arguing that its Boston licensee, WBZ­ 19 WNNE-TV achieves greater viewership. TV, is entitled to carriage on cable systems in the Commu­ nities in the three counties and provides more and better news and programming coverage of interests to the Com­ ANALYSIS AND DECISION munities. We believe that Congress did not intend the third 16. We shall grant WNNE-TV's petitions. With respect to criterion to be a bar to a station's ADI modification claim the first statutory factor, we note that WNNE-TV has dem­ whenever other stations could also be shown to serve the onstrated a history of carriage on most of the cable systems communities at issue. Rather, we believe that this criterion serving the Communities. We note that the one cable was intended to. enhance a station's claim where it could be system in Sullivan County on which WNNE-TV is not shown that other stations do not serve the communities at carried---serving the communitJ of Springfield---has only issue. Under such circumstances, a denial of carriage rights been in operation since 1990.z In Cheshire County, the to the claiming station could deprive cable viewers of any cable systems in the communities of Nelson, Marlow. and broadcast signals that might provide programming geared Harrisville and some portions of Keene and Rindge do not to their communities. Because WBZ-TV, along with other carry WNNE-TV. In Windham County, the cable system stations, does appear to serve the Communities, this en­ serving the communities of Stratton. Stratton Mountain, hancement factor would not appear applicable. Stratton Ski, and Stratton West does not carry WNNE-TV,

community or a county is one that achieves in noncable homes TV's 1-t share. Arbitron, Television County Coverage: Vermont a share of viewing hours of at least 3 percent (total week hours) (Cable Controlled Counties) 1993; Television County Coverage: and net weekly circulation of at least 25 percent. H C.F.R. New Hampshire (Cable Controlled Counties) 1993. §76.5(i). . !O Television and Cable Factbook at D-!065 (199.t). 19 During the daypart which includes WNNE-TV's 6:00 p.m. 21 We note in contrast that WBZ-TV's Grade B contour only local newscasts, WNNE-TV has a 15 share in Windham County, extends as far as the southeastern portion of Cheshire Cou.nty, compared with WBZ-TV's 5 share, and an 8 share in Sullivan New Hampshire. the area in question nearest to Boston. County, compared with WBZ-TV's 6 share. In Cheshire Coun­ 22 E.g., WNNE-TV, Inc., 9 FCC Red 270, 272 (1994); MM ty, during the daypart which includes WNNE-TV's 11:00 p.m. Docket 92-259, 8 FCC Red at 2977. local newscast, WNNE-TV has a IO share, compared with WBZ-

2387 DA 96-185 Federal Communications Commission Record 11 FCC Red No. 5

19. With respect to the fourth criterion, we find that of the Burlington, Vermont-Plattsburgh, New York ADI WNNE-TV has presented evidence of viewing patterns for with respect to WNNE-TV; as well as within the Boston, cable and noncable households to demonstrate substantial Massachusetts ADI. This determination is subject to all viewership of the in the communities located within Sulli­ generally applicable limitations on signal carriage rights, van and Windham Counties. A review of Arbitron data for including copyright liability, signal quality, channel capac­ these counties confirms that WNNE-TV achieves a high ity, and program duplication. See paragraph 7, supra. share of viewership, indeed the highest share relative to. the Boston stations.23 We note that both Nielsen and Arbitron data are county-wide, rather than community-specific. Ab­ ORDERING CLAUSES sent evidence that such data are not fairly reflective of 22. Accordingly, IT IS ORDERED, pursuant to §614 of viewing in the actual communities in question, we shall the Communications Act of 1934, as amended (47 U.S.C. accept such data as probative, although not conclusive, in §534), and §76.59 of the Commission's Rules (47 C.F.R. cases of this type. In addition to the four statutory factors, §76.59), that the captioned petitions for special relief (CSR- we believe that the fact that local businesses in the counties 4004-A, CSR-4001-A, and CSR-4002-A) filed by WNNE­ use WNNE-TV as an advertising medium further supports TV, Inc. ARE GRANTED. This change shall be effective in 24 a grant of the petitions. With respect to the communities accordance with the following schedule: WNNE-TV, Inc. located in Sullivan and Windham Counties, WNNE-TV shall notify the cable systems in question in writing of its clearly satisfies the first; second and fourth factors, and, carriage and channel position election (§§76.56, 76.57, and even absent enhancement under the third criterion, has 76.64(f) of the Commis$ion's Rules) within 30 days of the justified grant of its requests. release date of this Memorandum Opinion and Order. The 20. With respect to Cheshire County, for certain commu­ affected cable systems shall come into compliance with the nities WNNE-TV has not demonstrated historic carriage. applicable rules within 60 days of the above notice. However, the location of these communities within 23. This action is taken pursuant to authority delegated WNNE-TV's Grade A service contour outweighs the lack by §0.321 of the Commission's Rules. of historic carriage.2s As other stations serve Cheshire County the third factor is not applicable. With respect to FEDERAL COMMUNICATIONS COMMISSION the fourth factor, WNNE-TV's showing is not as conclusive as it is for Sullivan and Windham Counties. In Cheshire County, Arbitron data reveal that WNNE-TV has only a two total share and 27 percent of net weekly circulation. In contrast, three Boston stations [WBZ-TV, WCVB-TV (ABC, Channel 5), and WHDH-TV (CBS, Channel 7)] and one William H. Johnson Manchester station (WMUR-TV) have total shares over 12 Deputy Chief, Cable Services Bureau and net weekly circulation over 60 percent. WNNE's view­ ing pattern between cable and non-cable homes is similar: non-cable share of one and nine percent of net weekly circulation; cable share of two and 33 percent of net week­ ly circulation.26 However, WNNE-TV has shown that its viewership is most significant during the times when it broadcasts its local news,27 and has presented Nielsen view­ ing data on viewership that supports its petition.28 More­ over, the use of WNNE-TV as an advertising medium by local business in Cheshire County further supports includ­ ing these communities in WNNE-TV's market. Weighing the totality of circumstances presented to us with respect to the communities located in Cheshire County, we believe a grant of WNNE-TV's request is warranted. 21. Accordingly, for the purposes of determining man­ datory signal carriage obligations. we shall consider the communities in Sullivan County and Cheshire County, New Hampshire and Windham County, Vermont, listed respectively in notes one, two, and three, supra, to be part

23 In Windham County, Vermont, WNNE-TV holds a 12 share below WNNE-TV's numbers. Arbitron, Television County Cov­ of the total market and has a 61 percent net weekly circulation. erage: Vermont (Standard/Fringe) 19lJ3; Arbitron, Television Only the Boston station WBZ-TV holds a larger share of 15, but County Coverage: New Hampshire (Standard/Fringe) 1993. at 56 percent WBZ-TV does not exceed WNNE-TV's net weekly 24 See, e.g., WNNE-TV, Inc., 10 FCC Red 4993, 4lJ95 (1995). . circulation. The data for all other Boston ADI stations fall is We note that WNNE-TV has no record of historic carriage below WNNE-TV's numbers. In Sullivan County, New Hamp­ in the community of Rindge-Franklin Rierce College, which is shire, WNNE-TV has a lJ share of the total market and a 74 within the station's Grade B contour. However, in the neigh­ percent of net weekly circulation, whereas only the Manchester boring community of Rindge, WNNE-TV has been carried for station WMUR-TV holds a larger share of 15. However, at 62 ov.er a decade. percent WMUR-TV does noi exceed WNNE-TV's net weekly 26 Arbitron, Television County c;overage: New Hampshire (Ca­ circulation. The data for all other Boston ADI stations fall far ble Controlled Counties) 1993. 27 See note 20, supra. 28 See note 18, supra.

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