ORIGINAL Before the DOCKET FILE COpy ORIGINAL FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554
In the Matter of ) MM Docket No. 98-123 ) Amendment of Section 73.202(b), ) RM-9291 Table of Allotments, ) FM Broadcast Stations. ) RECEIVED (Marysville and Hilliard, Ohio) ) SEP 8 1998
JOINT COMMENTS IN OPPOSITION PIIIMM. CAMI"1lONI 0011111111 0fIIlCI OF 111! fIICfIEIMr
1. North American Broadcasting Co., Inc., licensee of
Stations WMNI(AM) and WBZX(FM), Columbus, Ohio, WCLT Radio
Incorporated, licensee of Stations WCLT(AM)-FM, Newark, Ohio,
Franklin Communications, Inc., licensee of Stations WVKO(AM) and
WSNY(FM), Columbus, Ohio, and Scantland Broadcasting, Ltd., licensee of Station WJZA(FM), Lancaster, Ohio and Station
WZJZ(FM), Richwood, Ohio (collectively, lithe Joint Commenters"), hereby submit their Joint Comments in Opposition to the proposal set forth in the Notice of Proposed Rule Making ("NPRM"), DA 98-
1373, released July 17, 1998, in the above-captioned proceeding.
As set forth in detail below, the proposed reallotment of
Channel 289A from Marysville, Ohio to Hilliard, Ohio would clearly and directly contravene both Section 307(b) of the
Communications Act and the Commission's own well-established
concern about preventing undue concentration of control of
broadcast ownership in particular markets.
2. The NPRM proposes the reallotment of Channel 289A from
Marysville to Hilliard. The proponent of this reallotment is
Citicasters Co., the licensee of Station WKFX(FM), which operates fGC'd_Q1'l i - 2 - on Channel 289A in Marysville.
3. Marysville is the county seat of Union County.
Hilliard is a suburb of Columbus. 1/ The overall Columbus market (including surrounding communities) has some 31 radio
stations licensed to it, according to BIA Research, Inc. See
Attachment B hereto. By contrast, Marysville has only one other
radio station -- a 500 watt AM station 1/ -- and, in addition to
that AM station in Marysville, there is but one other station
licensed to any community in all of Union County.
4. So the proposal would remove a 6 kW FM station from a
county seat and place it in a suburban community where it would
simply add one more voice to the already crowded Columbus market.
1/ Hilliard is approximately 10 miles from the center of downtown Columbus and is located in the same county as Columbus. Lest there be any doubt that Hilliard is viewed as a suburb of Columbus, the Joint Commenters note that at least two of the large companies which, according to Citicasters' petition for rule making, are located in Hilliard (as distinct from Columbus) apparently don't necessarily agree with that particular assessment. According to materials obtained from the internet web sites of CompuServe and GatesMcDonald, the former views itself to be "headquartered in Columbus, Ohio", while the latter views itself to be located in "the Columbus, Ohio, suburb of Hilliard." See Attachment A.
1/ It is possible that some Commission personnel may not have a practical grasp of just what it means to have facilities limited to 500 watts. Review of the 1998 Broadcasting Yearbook indicates that there are no stations licensed to Washington, D.C. or its surrounding suburbs which have less than 1 kW daytime power -- i.e., twice the power of the lone AM station in Marysville. Local D.C. stations which are limited to 1 kW (again, that's twice the power of the only station which would remain in Marysville if the NPRM proposal were to be adopted) include WOL(AM) (1459 kHz), WYCB(AM) (1340 kHz), and WINX(AM) (1600 kHz in Rockville, Maryland). To sample a SOO-watt nighttime signal, the Commission may wish to tune into WINX(AM) in the evening. - 3 -
And it would leave an entire county with only two local radio stations, one of which has, at best, limited AM facilities (and the other is a Class A FM station, far from a powerhouse in terms of signal reach). How could this possibly be viewed as a "fair and equitable distribution" of radio spectrum", as required by
Section 307(b) of the Communications Act? The public in
Marysville plainly has a legitimate expectation that existing
service will continue, and not be disrupted in order to afford
one more station to a larger metropolitan area already well
served by existing stations.
5. The Joint Commenters are well aware of the history and
purpose of the Commission's Table of FM Allotments. That Table
was adopted some 35 years ago largely to assure compliance with
the requirements of Section 307(b) See,~, Revision of FM
Broadcast Rules, 40 FCC 747 (1963) The Commission developed a
number of policies to discourage the reallotment of channels from
smaller rural communities to already well-served communities in
or adjacent to large metropolitan areas. ~,Berwick
Broadcasting Corp., 20 FCC2d 393 (1969). However, in 1983, those
policies were abandoned, see Suburban Community Policy, Berwick
Policy and De Facto Reallocation Policy, 93 FCC2d 436 (1983)
("Suburban Community Policy"), and the Commission substituted for
them the generic test articulated in the NPRM herein, see
93 FCC2d at 456.
6. But much has happened in the 15 years since Suburban
Community Policy which undermines the continued validity of that - 4 - decision and the analyses adopted therein. Most notably, in 1983 the Commission concluded that concern about the reallotment proponent's actual intentions vis-a-vis actual service to the proposed community of license was unnecessary because of the practical "risk of a renewal challenge". 93 FCC2d at 456; see also Roberts Communications. Inc., 11 FCC Red 1138, 1139 (1996)
That is, the Commission apparently felt that the incentives (or disincentives) imposed on reallotment proponents by the threat of a comparative renewal challenge could serve as an adequate safeguard against violations of Section 307(b). Accordingly, the
Commission eliminated its own regulatory policies (~, the
Berwick Policy) .
7. But wait a minute -- the protective device of renewal
challenges was eliminated more than two years ago by Congress in
the Telecommunications Act of 1996. And, to the best knowledge
of the Joint Commenters, no equivalent device has been imposed to
replace it. In other words, in 1983 the Commission observed that
its regulatory policies were an unnecessary belt in light of the
fact that the comparative renewal policy served effectively as
suspenders. Accordingly, the Commission removed its belt. But
now the suspenders are gone, too. That being the case, nothing
is presently supporting the Suburban Community Policy. The
Commission cannot blindly cite Suburban Community Policy and its
progeny without first addressing the fact that the Commission
currently lacks any apparent mechanism for assuring compliance
with Section 307(b). - 5 -
8. The Commission's policies have been similarly overtaken by other changes in the regulatory landscape which undermine the policy which it proposes to apply here. In abandoning its earlier regulatory policies, the Commission also cited its concern that those policies frustrated competition in metropolitan areas. 93 FCC2d at 445; see also Roberts
Communications, Inc., supra, 11 FCC Rcd at 1139. But that notion harkens back to a simpler time, when the Commission's rules limited local ownership to only one or two stations in a given service in a given market. Those were the good (or bad) old days. Again, the Telecommunications Act of 1996 changed all that by lifting the caps on local ownership to a degree not anticipated in 1983. The result is that, in a market such as
Columbus, a single licensee might own four, five or possibly even more stations (depending on a number of factors).
9. The opportunities presented by the increase in local ownership caps have largely undermined the fears expressed by the
Commission about use of its policies to prevent new licensees
from joining in in-market competition. Here, for example, the reallotment proponent is not seeking to become a new entrant in
the Columbus market. To the contrary, the proponent here already
owns, or has proposed to own, some nine stations in the Columbus
market. The move of the Marysville channel to Hilliard would
merely add to Citicasters's existing multiple ownership. if
if Indeed, if Citicasters is so convinced of Hilliard's need for its own local broadcast station, why doesn't Citicasters seek (continued... ) - 6 -
10. So the instant proposal effectively turns the Suburban
Community Policy on its head -- here, it is being invoked not to protect a new competitor's entry into the market, but rather in defense of a proposal which would aggravate a competitive imbalance which already exists in the market.
11. It is well established that an agency has an on-going obligation to assure that its policies continue to be valid in their application. Where, for example, intervening changes in related agency policies undermine the continued validity of other, unchanged, policies, the Commission must consider the
impact of the changes before continuing to apply the unchanged policies. See,~, Bechtel v. FCC, 10 F.3d 875 (D.C. Cir.
1993) .
12. The instant situation is a dramatically clear
illustration of this problem. In its 1983 abandonment of its
various Section 307(b) policies, the Commission may have been
correct in its conclusion that other factors notably, the
comparative renewal threat and the desire to encourage new
competition -- provided an adequate foundation to assure
protection of core Section 307(b) interests. But whether or not
that decision was correct, the fact is that that supposed
foundation has not just been eroded, it has been entirely
1/ ( •.. continued) the reallotment of one of its Columbus stations to Hilliard? Such an approach -- removing a station from an already well served community to a supposedly underserved community -- would make far more sense than taking away the only competitive station (and one of only three local county stations in toto) from a county seat. - 7 - removed! There is no comparative renewal threat anymore, and at least in this case -- the reallotment proponent is already a competitor (indeed, a dominant competitor) in the market. As a result, the Commission can no longer legitimately rely on its
Suburban Community Policy. Since the proposal in the NPRM is based exclusively on that policy, that proposal must be rejected unless and until the Commission is able to demonstrate that whatever policies it may seek to apply are consistent with the
Commission's statutory obligations, including those imposed by
Section 307(b) of the Act.
13. A further basis for rejection of the proposed reallotment exists. It is fundamental that a reallotment proponent must commit to filing for the subject channel if the channel is reallotted. But a substantial question exists here whether Citicasters would be able to make such a commitment. As noted above, Citicasters owns or has proposed to own some nine stations in the Columbus market. According to a "Radio Multiple
Ownership Analysis" submitted in February, 1998 by Citicasters in connection with its proposed (and since withdrawn) acquisition of two Chillicothe, Ohio radio stations, Citicasters owned or proposed to own or control (through common ownership or time brokerage) a total of 13 radio stations in the Columbus market.
See Attachment C.
14. But in August, 1998, the U.S. Department of Justice announced that it had reached an agreement with Citicasters' parent, Jacor Communications, Inc., pursuant to which - 8 -
Jacor/Citicasters would sell off, inter alia, five stations in
Columbus. See Attachment D. The result of this arrangement is to reduce Citicasters's ownership to four stations in Columbus.
But the proposed move of Station WKFX(FM) from Marysville to
Hilliard would increase that ownership to a fifth station in the
Columbus market, and thus would appear to run counter to the
recently announced settlement with the Department of Justice.
15. This in turn raises the question of whether, in light
of that settlement, Citicasters can legitimately commit to
applying to move Station WKFX(FM) to Hilliard. Absent some such
legitimate commitment, the proposal must be rejected. The Joint
Commenters suspect that, somewhere along the line, Citicasters
will offer up a boilerplate commitment to apply for and implement
the move to Hilliard. In view of the settlement between the
Department of Justice and Jacor, though, the Joint Commenters
submit that, in order to be valid and credible, any such
commitment must be accompanied by a specific written
confirmation, from an appropriate official of the Department of
Justice, expressly stating the Department's full familiarity, and
concurrence, with the proposed move of Station WKFX(FM) from
Marysville to Hilliard.
16. In summary, then, the Joint Commenters submit that it
would be inconsistent with Section 307(b) to remove
Station WKFX(FM) from Marysville and relocate it to the Columbus
suburb of Hilliard. Moreover, in assessing the Section 307(b)
considerations inherent in the Marysville-to-Hilliard proposal, - 9 - the Commission cannot fall back on the facile analysis suggested
in the NPRM, because that analysis was adopted on the basis of
factors which are no longer in place. Rather, the Commission must first develop a Section 307(b) policy based on the statutory
and regulatory situation as it exists today. Only after such a
policy, consonant with current and existing conditions, is
developed could Citicasters's proposal be properly considered at
all. As discussed above, the Joint Commenters do not believe
that any valid Section 307(b) analysis could support the
relocation of the channel from Marysville to Hilliard. Finally,
even if such relocation might ultimately be deemed, arguendo,
consistent with Section 307(b), the Joint Commenters submit that
Citicasters must be required to demonstrate that such relocation
has been specifically considered and approved by the Department
of Justice before the Commission can agree to it.
Respectfully submitted, An}A'~":="':Fa=-:=,/)=!-" Lsi An@~t _
Bechtel & Cole, Chartered 1901 L Street, N.W. Suite 250 Washington, D.C. 20036 (202) 833 -4190
Counsel for the Joint Commenters September 8, 1998 ATTACHMENT A CorrpuServe http://www.compuserve.com/content/cs_info.asp
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GatesMcDonald, a leading provider ofemployee benefit cost management, is headquartered in the Columbus, Ohio, suburb ofHilliard. ATTACHMENT B Marbt: Columbus, OH Competitive Overview Metro \ FM SUIIoM MIt , ...... _ ...... L '.1sI AV'I'" ___ ..... Mneer .... ~ LoaI , Fd I ...., Spr"'! CIVet fCC "- .,.. DIIIlI PItc...... RIIID .111 1117 1117 1117 , 1.M c.II ...... CIne FnlIt (IIWI HMT c ow.r SIll Itt:Jttd e-J Ie I'GrmII (IIIIDJIf con- •• . WCOl Cull. e 12.3 22.0 155 f JIlaar 41,nop aa ea.nJIy 1.'1 10.7 1.3 ... 10.0 '.7 e.o 1.0 I.' WCIO ....v... e 13.7 37.0 SI4 8 KNOX 51 ..AC 0.7 G.I 0.7 0.7 lUI 0.4 0-7 0.5 ~ -. WfMf B ...7 22.0 713 d .... 41 ." M,IGO NJ 11,C1llO 1.57 t.2 U 7.3 '.1 1.2 7.1 7.3 8.5 7.. , __ WHOK ...... B 15.5 21.0 ~ 3'- 0." .... 3.4 4.' 4.0 4.5 3.. 4.0 3.9 WL\IQ CoIIIlIIlIII B 15t , ...... eIIc", 1,CIllO 5.0 U 5.7 SA 5.2 e., 7.0 .3 '1.0 51_ 'AI u WINS CollI... B 0IIlIIa ~ OM UI U 5.5 5.2 4... 5.3 5.4 5.9 17.1 2G.1 '" b ~ BrOllllc:tllt • WNCI ".. ,o.J 10.1 1.0 11.3 7.7 CaIu.... B .7.t 111.0 ., , I' .710 p HoIAIC 1'_ 1.33 '.4 ... U WZAZ 505 , ... ,.....,.. U U Upper AIIngIon A ... 2.t 2,IlIlI O.ft :u 3.1 3.1 ... U 2.4 Ncdl~ .... 5.3 ,.9 WIZX CaU,'" e •.1 2.0.0 784. 12 .-oR U, U 5.4 U ...3 5.4 1.1 WlCl.T ~ B 110.3 so.o _. WCl.T ...... 47 c.., ''- U 2.2 2.AI U ZoO 1.1 1.' 1.9 wwco CJnNI CIIr A .OU 1.0 ...... Ino 80t11G 2,GOO M .- ••1.D7 2.7 1.1 1.1 2.2 2.2 3.1 2.5 3.0 2'- WIIlI(O ...... A '01.7 3.G _ c ...... ca. 72 0...-•• 4CIO ~ U U 0.1 0.. 0.7 0.7 0.4 0.5 WSME ...... , A , 1.1 -443 ...... 15.11 ''- UltlMAC lIOO 0..11 1.3 1A 1.0 t.~ 1,0 ~~-_. ~p .. 321' i Sf c' .0:' '." • WJZA···...... A 111B.S U id Ii t1QI', t • ...... 200 0.7 1.0 0-7 0.7 0.5 0." 0.5 0.5 WZ.R ~ A 10U 3.4 ... i t , ...... ',100 0.71 ... 1.A U ... 1. 1.5 1." '.7 WIICFX A tell.? 2.5 . • 1.31 I.G 0.7 0-4 0.9 OJS 1.7 2.2 2.1 512 r .... 10 flDt ee...... ',IICIO wac)( .....LeIldaR A IClU U 3ZI h _CIIIp ... UItlInNJ 0,32 2.7 3.. 2.1 1.' 2.2 1.4 2.0 1.4 WAZU _ r".. ... c--.. A 107-1 3.0 .170. ... AOR _"GO G.IO ,. 1.7 '.4 1.7 1.3 t.o 1.2 1.2 W.aA ~ A 107.1 ~ - Ulflln.NJ 0.35 • .0 3.8 5.0 5.0 5.4 U 8.1 5.1 1.' 413 .... .1711 .... ·.1,_- WLVR ~ tt_ A 107.' 2.'1:ft 505 ,"nnlllt.d ,'- LleRDcll 500 0.30 2.2 0.1 t.O 1.5 2.0 3.0 2.7 2..5 - _._~ ------_.------• PM""". 20 .c--.... 17 ....1OTALS 12.0 ..3 71.2 7U •.1 •.5 n.o 71.7 All 8tation.
/WI'" _-___~~cc._ AM .Jt-...._C..dgtIta) DIIft ..... L 1.'Est ,..., ..... LOQ/ ,.11 au.mer ..... WInW ,. su.rnet Spdng air" Pee ...... y_ ...... c... Qua ,... (IIWJ •A ...... ~ c.- 1111. til? , 1_ u.:... .. c owner lidze_1tCft. C., ...-0 •• . •• ..... W'NN CoIIInIua 110 5.0 e.aO f ..... ,1 NIWI1'ItIWIIIs 8J»D 1.25. .... 7.1 ... U 7.1 U .7.2 ·wtmf ...... • ••• .. 710 ,.0 D.cD • ""'kb" J cD.p 10 CalII*r 0-4 0.7 0..0 0.0 0.5 0.1 0.0 0.0 WfrD P$ 23 ' ; b. • 0. 000 4' Nell .....TIIIr o:a U 0.1 o:t ... 1.0 0.1 --wr VMtI Cc11ll111l. 1120 1.0 0.10 ...... -...-. II •• AlII... 1,2011 0.51 i.l 2.7 2.' 12 ,. '.1 U WPI • - ••• 0aIl • ftI 1Z1ll 1.0 t.ClO .C JII:Ior 22 mop Till 40Cl OAO 1.3 G.I 0.' U 1.3 '.3 t.3 1.5 WMIO .....v-on 13DO 0.4 0.. 8 tcNOX A v.IIIW 0.0 0.0 0..0 0.0 0.0 0.0 0.0 WLOH ...... • '3lZO '.0 0. WLOH • '712p 1110 AlII.... 0.1 o.e 0.0 0.0 D.I 0.0 0.0 0.0 wa.T ...... •.. 1430 0.5 OAII. WCLT ...... ,.."..,... 0.4 D.o 0.0 0.0 0.0 0.0 0.0 weNS llW ~. ... <:•• .. ,... s.o 1.GO b _.22,. s,.wrtll 0.12 U , 2A 1.7 U 1.5 2.7 1.2 U WDLR c.... IMO 0.5 om Eeq. 11 'Nlp 7'110 DIIIlM •• 0.0 0.0 0.0 0.0 0.0 0.0 0.0 WWO~ II• t$IO 1.0 G.21 d .. 51 .., Gel ••....,. 3lIO D.23 2.G 1.7 2.0 2.2 1.5 1.3 1.5 1.2 ./IM...... It lComboe· a ".TOTAUI 11.0 17.0 "'.7 15.4 1U ..., ..... 13.7
• IncIcIUe actwlge dIon 1/ See 1NnlduaIaI: rat .._peaklancf...... Metro Ra tr 7 7.'&_ 1...... c."...... eet __Rl:....Illc.M...... ~ .,...... RaMIo ...is cwre"'., ofi:J --,1,,"-,------11..--*.....------
ATTACHMENT C TECHNICAL STATEMENT RADIO MULTIPLE OWNERSHIP ANALYSIS CITICASTERS CO.
This statement and the attached figures were prepared on behalfofCiticasters Co., an indirect subsidiary ofJacor Communications, Inc. Citicasters Co. proposes the acquisition ofWBEX(AM) and WKKJ(FM), Chillicothe, Ohio. A multiple ownership analysis was prepared considering the following radio stations under present or proposed common ownership or time brokerage:
Can Sign City of License Facilities WBEX(AM) Chillicothe, OH 1490 kHz, 1 kW, U, NDI WKKJ(FM)l Chillicothe, OH Channe1227B, 50 kW, 106 m WTVN(AM) Columbus, OR 610 kHz, 5 kW, U, DAN WLW(AM) Cincinnati,OH 700 kHz, SO kW, D, ND-l WFII(AM) Columbus, OR 1230 kHz, 1 kW, D, ND-l WOFR(AM) Washington Court House, OR 1250 kHz, 0.5 kW, D, ND-l WCOL-FM Columbus, OH Channel 222B, 22 kW, 230 m WHOK(FM) Lancaster, OR Channel 238B, 21 kW, 232 m WLVQ(FM? Columbus, OH Channel 242B, 18 kW, 229 m WNCI(FM) Columbus, OH Channel 250B, 175 kW, 171 m WZAZ-FM Upper Arlington, OR Channel 255A, 2.6kW, 154 m WCHO-FM3 Washington Court House, OH Channel 288A, 3 kW, 91 m WAZU-FM CircleviHe, OR Channel 296A, 3 kW, 100 m
• Since certain ofthese stations have overlapping principal community contours (5 mV/m for AM stations, 3.16 mV/m for FM stations), an ownership study has been prepared in accordance with the Federal Communications Commission multiple ownership rules. 4
1 There is an application pending for WK.KJ(FM) to move the transmitter site (See FCC File No. BPH 900226IB). 2 There is an application pending for WLVQ(FM) to move the transmitter site and decrease ERP (See FCC File No. BMLH-940308KA). Since WTVN(AM) fully encompasses the licensed and the pending application principal community coverage contours, the pending application does not change the count of intersecting stations. 3 There is an application pending for WCHO-FM to move the transmitter site and to increase ERP (See FCC File No. 971126IC). Since WLW(AM) totally encompasses the licensed station and pending application, the "radio market" is not altered by this proposed change. 4 See Section 73.3555 of the FCC Rules. ATTACHMENT D 1869.hTM http://www.usdoj.gov/atr/public/pressJeleases/]998/1869.htm
Download the wp51 version here.
l'epartmtnt of Ju~ice
FOR IMMEDIATE RELEASE AT MONDAY, AUGUST 10, 1998 (202) 616-2771 TDD (202) 514-2888 JUSTICE DEPARIMENT REQUIRES JACOB TO SELL EIGHT RADIO STATIONS AS PART OF NATIONWIDE COMMUNICATIONS INC. ACQUISITION Radio Stations in San Diego, Cleveland and Columbus, Ohio Must be Sold to Alleviate Antitrust Concerns
WASHINGTON, D.C. -- The Department ofJustice reached a settlement today with Jacor Communications Inc. allowing the company to go forward with its $620 million acquisition ofNationwide Communications Inc. as long as Jacor sells offeight radio stations--two in San Diego, one in Cleveland, and five in Columbus, Ohio. The Department said that, without the divestitures, the acquisition would have significantly reduced competition in those cities. Ifthe deal were approved as originally proposed, Jacor would have had control of 12 stations in San Diego, accounting for 42 percentofthe radio advertising revenue. In Cleveland, Jacor would have owned six radio stations with 43 percent ofthe radio advertising revenue. In Columbus, with nine radio stations, Jacor would have had 58 percent ofthe radio advertising revenue. The Department's Antitrust Division and the Ohio Attorney General's Office conducted a joint investigation into Jacor's acquisition ofNationwide. "The divestitures will preserve the choices available to advertisers in the San Diego, Cleveland, and Columbus markets," said Joel 1. Klein, Assistant Attorney General in charge ofthe Department's Antitrust Division.
Jacor is addressing the Department's competitive concerns by selling or swapping radio stations with several different companies. Jacor is using a fix-it-first remedy, which means they will complete the sales before acquiring Nationwide. The two San Diego stations, KKLQ-FM and KJQY-FM, will be sold to Dallas based Heftel Broadcasting Corporation. Jacor will swap WKNR-AM in Cleveland for WTAE-AM in Pittsburgh, currently owned by Austin, Texas-based Capstar Broadcasting Partners. In Columbus, Jacor will sell WZAZ-FM to Cincinnati-based Blue Chip Broadcasting. Jacor has also agreed to sell their right to acquire WKKJ-FM ofChillicothe, Ohio, to Cincinnati-based Secret Communications LLC. Jacor will also swap three Columbus stations and two stations in Minneapolis-St. Paul with New York-based CBS Radio Station Group. In return, Jacor will receive two Baltimore stations, two S1. Louis stations, and two San Jose, California stations from CBS. Jacor's swap with CBS will give CBS WHOK-FM, WLVQ-FM, and WAZU-FM in Columbus and WMJZ-FM and KSGS-AM in Minneapolis-S1. Paul. Jacor will receive WOCT-FM and WCAO-AM in Baltimore, KSD-FM and KLOU-FM in St. Louis, and KOME-FM and KUFX-FM in San Jose.
O/ll/OR o.nA 11'- http://WWW.USdOj.gov/atr/PUblic/pressJeleaseS/1998/1869.htm
According to industry estimates, the divestitures will reduce Jacor's revenue share to approximately 39 percent in Cleveland, 36 percent in San Diego, and 38 percent in Columbus. Jacor, headquartered in Covington, Kentucky, currently owns and operates 197 million.radio stations in 55 markets in the U.S. In 1997, its revenues were approximately $600
Nationwide, headquartered in Columbus, Ohio, owns or operates 17 radio stations located in 11 metropolitan areas across the U.S. Nationwide's 1997 radio revenues were approximately $113 million.
98-362 ### CERTIFICATE OF SERVICE
I, Harry F. Cole, hereby certify that, on this 8th day of
September, 1998, I caused copies of the foregoing lIJoint Comments in Opposition" to be placed in the U.S. mail, first class postage prepaid, or hand-delivered (as indicated below), addressed to the following:
Marissa G. Repp, Esquire F. William LeBeau, Esquire Hogan & Hartson L.L.P. Columbia Square 555 Thirteenth Street, N.W. Washington, D.C. 20004 Counsel for Citicasters Co.
Leslie K. Shapiro Allocations Branch Policy and Rules Division Mass Media Bureau Federal Communications Commission 2000 M Street, N.W. - Room 564 Washington, D.C. 20554 (BY HAND) J-1':=SJ...I_...:.~~;f4~:------