City of license
In American, Canadian and Philippine broadcasting, a city of license or community of license is the community that a radio station or television station is officially licensed to serve by that country's broadcast regulator.
In North American broadcast law, the concept of community of license dates to the early days of AM radio broadcasting. The requirement that a broadcasting station operate a main studio within a prescribed distance of the community which the station is licensed to serve appears in U.S. law as early as 1939.
Various specific obligations have been applied to broadcasters by governments to fulfill public policy objectives of broadcast localism, both in radio and later also in television, based on the legislative presumption that a broadcaster fills a similar role to that held by community newspaper publishers.
In the United States, the Communications Act of 1934 requires that "the Commission shall make such distribution of licenses, frequencies, hours of operation, and of ower among the several States and communities as to provide a fair, efficient, and equitable distribution of radio service to each of the same." The Federal Communications Commission interprets this as requiring that every broadcast station "be licensed to the principal community or other political subdivision which it primarily serves." For each broadcast service, the FCC defines a standard for what it means to serve a community; for example, commercial FM radio stations are required to provide a field strength of at least 3.16 millivolts per meter (mV/m) over the entire land area of the community, whereas non-commercial educational FM stations need only provide a field strength of 1 mV/m over 50% of the community's population. This electric field contour is called the "principal community contour".
The Federal Communications Commission (FCC) makes other requirements on stations relative to their communities of license; these requirements have varied over time. One example is the requirement for stations to identify themselves, by call sign and community, at sign-on, sign-off, and at the top of every hour of operation. Other current requirements include providing a local telephone number in the community's calling area (or else a toll-free number) and (in most cases) maintaining an official main studio within 25 miles of the community's geographic center.
Policy and regulatory issuesEdit
Nominal main studio requirementsEdit
The requirement that a station maintain a main studio within a station's primary coverage area or within a maximum distance of the community of license originated in an era in which stations were legally required to generate local content and the majority of a station's local, non-network programming was expected to originate in one central studio location. In this context, the view of broadcast regulators held that an expedient way to ensure that content broadcast reflected the needs of a local community was to allocate local broadcast stations and studios to each individual city.
The nominal main studio requirement has become less relevant with the introduction of videotape recorders in 1956 (which allowed local content to be easily generated off-site and transported to stations), the growing portability of broadcast-quality production equipment due to transistorization and the elimination of requirements (in 1987 for most classes of US broadcast stations) that broadcasters originate any minimum amount of local content.
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While the main studio concept nominally remains in US broadcast regulations, and certain administrative requirements (such as the local employment of a manager and the equivalent of at least one other full-time staff member, as well as the maintenance of a public inspection file) are still applied, removal of the requirement that stations originate local content greatly weakens the significance of maintaining a local main studio. A facility capable of originating programming and feeding it to a transmitter must still exist, but under normal conditions there most often is no requirement that these local studio actually be in active use to originate any specific local programming.
Exceptions to these rules have been made by regulators, primarily on a case-by-case basis, to deal with "satellite stations": transmitters which are licensed to comply with the technical requirements of full service broadcast facilities and have their own independent call signs and communities of license but are used simply as full-power broadcast translators to rebroadcast another station. These are most often non-commercial educational stations or stations serving thinly populated areas which otherwise would be too small to support an independent local full-service broadcaster.
The requirement that a full-service station maintain local presence in its community of license has been used by proponents of localism and community broadcasting as a means to oppose the construction and use of local stations as mere rebroadcasters or satellite-fed translators of distant stations. Without specific requirements for service to the local community of license, stations could be constructed in large number by out-of-region broadcasters who feed transmitters via satellite and offer no local content.
There also has been a de facto preference by regulators to encourage the assignment of broadcast licenses to smaller cities which otherwise would have no local voice, instead of allowing all broadcast activity to be concentrated in large metropolitan areas already served by many existing broadcasters.
When dealing with multiple competing US radio station applications, current FM allotment priorities are: (1) first full-time aural service; (2) second full-time aural service; (3) first local aural transmission service; and (4) Other public interest matters.
Similar criteria were extended to competing applicants for non-commercial stations by US legislation passed in 2000.
Suburban community problemEdit
Any policy favoring applicants for communities not already served by an existing station has had the unintended effect of encouraging applicants to merely list a small suburb of a large city, claiming to be the "first station in the community" even though the larger city is well served by many existing stations. "The Suburban Community Problem" was recognized in FCC policy as early as 1965. "Stations in metropolitan areas often tend to seek out national and regional advertisers and to identify themselves with the entire metropolitan area rather than with the particular needs of their specified communities," according to an FCC policy statement of the era. In order "to discourage applicants for smaller communities who would be merely substandard stations for neighboring, larger communities," the FCC established the so-called "Suburban Community presumption" which required applicants for AM stations in such markets to demonstrate that they had ascertained the unmet programming needs of the specific communities and were prepared to satisfy those needs.
By 1969, the same issues had spread to FM licensing; instead of building transmitters in the community to nominally be served, applicants would often seek to locate the tower site at least halfway to the next major city. In one such precedent case (the Berwick Doctrine), the FCC required a hearing before Berwick, a prospective broadcaster, could locate transmitters midway between Pittston, Pennsylvania (the city of license) and a larger audience in Wilkes-Barre.
A related problem was that of 'move-in'. Outlying communities would find their small-town local stations sold to outsiders, who would then attempt to change the community of license to a suburb of the nearest major city, move transmitter locations or remove existing local content from broadcasts in an attempt to move into the larger city.
The small town of Anniston, Alabama, due to its location 90 miles west of Atlanta and 65 miles east of Birmingham, has lost local content from both TV and FM stations which were re-targeted at one of the two larger urban centers or moved outright. (WHMA-FM Anniston is now licensed as WNNX College Park, Georgia - an Atlanta suburb - after a failed attempt to relicense it to Sandy Springs, Georgia - another Atlanta suburb. Transmitters are now in downtown Atlanta.) The same is true for WJSU, which served East Alabama with local news until the station was merged into a triplex to form ABC 33/40 which focuses its coverage on the central part of the state.
A 1988 precedent case (Faye and Richard Tuck, 3 FCC Rcd 5374, 1988) created the "Tuck Analysis" as a standard which attempts to address the Suburban Community Problem on a case-by-case basis by examining:
- the station's proposed signal coverage over the urbanized area (the "Coverage Factor");
- the relative population size and distance between the suburban community and the urban market (the "Relative Size and Distance Factor"); and
- the independence of the suburban community, based on various factors that would indicate self-sufficiency (the "Independence Factor").
Despite the best intentions of regulators, the system remains prone to manipulation.
This has almost become a parlor game. The goal of the game—whether you're applying for a new station or a station currently licensed to a rural area—is to move as close to a big market as possible. The closer you get to a big market, the more potential listeners you can reach and hence the more advertising dollars you can attract. But there's a catch—at least there's supposed to be. The Commission is required by Section 307(b) of the Communications Act "to provide a fair, efficient, and equitable distribution of radio service" to "the several States and communities." The FCC cannot simply permit radio stations to relocate from rural areas to well-served urban markets without violating that mandate. That's when the game gets interesting. Under our FM allotment rules, the Commission will give a preference to any applicant that proposes to serve a community with no current licensees—i.e., not that the community doesn't receive radio service (it could receive service from dozens of stations) but that no station lists that particular community as its "community of license." That's where a good atlas comes in handy. The next step is to scour the maps to find a community near an urban area that doesn't yet have any stations licensed to it. You win the game if you get the FCC to grant you a preference for providing "first service" to a close-in suburban community while being able to cover the larger market.— Commissioners Copps & Adelstein, Federal Communications Commission, 2008
Licensing and on-air identityEdit
While becoming less meaningful over the decades, stations are still required to post a public file somewhere within 25 miles of the city, and to cover the entire city with a local signal. In the United States, a station's transmitter must be located so that it can provide a strong signal over nearly all of its "principal community" (5 mV/m or stronger at night for AM stations, 70 dbuV for FM, 35 dbu for DTV channels 2-6, 43 dbu for channels 7-13 and 48 dbu for channels 14+), even if it primarily serves another city. For example, American television station WTTV primarily serves Indianapolis; however, the transmitter is located farther south than the other stations in that city because it is licensed to Bloomington, 50 miles south of Indianapolis (it maintains a satellite station, WTTK, licensed to Kokomo, Indiana, but in the digital age, WTTK is for all intents and purposes the station's main signal, transmitting from the traditional Indianapolis transmitter site). In some cases, such as Jeannette, Pennsylvania-licensed WPCW 19, the FCC has waived this requirement; the station claimed that retaining an existing transmitter site 25.6 miles southeast of its new community of license of Jeannette would be in compliance with the Commission's minimum distance separation requirements (avoiding interference to co-channel WOIO 19 Shaker Heights). Another extreme example of a station's transmitter located far from the city of license is the FM station KPNT, formerly licensed to Ste. Genevieve, Missouri and transmitting from Hillsboro, but serving the St. Louis and Metro East market to the north. In 2015, the station was allowed by the FCC to move their city of license to Collinsville, Illinois and have a transmitter in St. Louis proper with a power decrease.
FCC regulations also require stations at least once an hour to state the station's call letters, followed by the city of license. However, the FCC has no restrictions on additional names after the city of license, so many stations afterwards add the nearest large city. For example, CBS affiliate WOIO is licensed to Shaker Heights, a suburb of Cleveland, and thus identifies as "WOIO Shaker Heights-Cleveland." Similarly, northern New York's WWNY-TV (also a CBS affiliate) identifies as "WWNY-TV 7 Carthage-Watertown" as a historical artifact; the original broadcasts originated from Champion Hill in 1954 so the license still reflects this tiny location.
If the station is licensed in the primary city served, on occasion the station will list a second city next to it. For example, the Tampa Bay region's Fox owned-and-operated station WTVT is licensed to Tampa, Florida, its primary city, but identifies on-air as "WTVT Tampa/St. Petersburg", as St. Petersburg is another major city in the market.
There is no longer a requirement to carry programs relevant to the particular community, or even necessarily to operate or transmit from that community. Accordingly, stations licensed to smaller communities in major metropolitan markets often target programming toward the entire market rather than the official home community, and often move their studio facilities to the larger urban centre as well. For instance, the Canadian radio station CFNY-FM is officially licensed to Brampton, Ontario, although its studio and transmitter facilities are located in downtown Toronto.
This may, at times, lead to confusion — while media directories normally list broadcast stations by their legal community of license, audiences often disregard (or may even be entirely unaware of) the distinction. For instance, for a short time while resolving a license conflict and ownership transaction in 1989, the current day KCAL-TV in Los Angeles was licensed to the little-known southeast suburb of Norwalk, California, with the station's identifications at the time only vocally mentioning the temporary city of license in a rushed form, with Norwalk barely receiving any visual mention on the station; at no time were any station assets actually based in Norwalk, nor was public affairs or news programming adjusted to become Norwalk-centric over that of Los Angeles and Southern California. The station returned to its Los Angeles city of license after the transaction was complete.
Table of allotmentsEdit
In the United States, the Federal Communications Commission maintains a Table of Allotments, which assigns individual channel frequencies to individual cities or communities for both TV and FM radio.
A corresponding Table of Allotments for digital television was created in 1997. To operate a licensed station, a broadcaster must first obtain allocation of the desired frequencies in the FCC's Table of Allotments for the intended city of license. This process is subject to various political and bureaucratic restrictions, based on considerations including the number of existing stations in the area.
The term "city" has in some cases been relaxed to mean "community", often including the unincorporated areas around the city that share a mailing address. This sometimes leads to inconsistencies, such as the licensing of one metro Atlanta station to the unincorporated Cobb County community of Mableton, but the refusal to license another to Sandy Springs, which is one of the largest cities in the state, and was at the time an unincorporated part of Fulton County only for political reasons in the Georgia General Assembly.
The definition of a "community" also comes into play when a broadcaster wants to take a station away from a tiny hamlet like North Pole, New York whose population is in decline. In general, regulators are loath to allow a community's only licence to be moved away - especially to a city which already has a station (a rare few exceptions were made to accommodate the then-fledgling third-rank American Broadcasting Company in the 1950s). A broadcaster may make the case that the "community" functionally no longer exists in order to be released from its local obligations.
Often, the city of license does not correspond to the location of the station itself, of the primary audience or of the communities identified in the station's branding and advertising.
Some of the more common reasons for a community of license to be listed as a point far from the actual audience include:
- The "compromise" location
- A broadcaster may wish to serve two different communities, both in the same region but far enough from each other that a transmitter in one market would provide poor service to the other. While a transmitter in each community served would be preferable, occasionally a station licensed to a small town between the two larger centres will be used.
|Broadcaster||City||Community of license||Comments|
|CBK (AM) 540||Regina||Watrous||The original historic AM transmitter was built in Watrous in 1939 to serve both Regina and Saskatoon from studios in Regina. Both cities are now served by local FM repeaters of CBK, yet the original clear-channel AM 540 and the community of license remain with tiny Watrous.|
|CHWI-TV 16 / 60 A-Channel||Windsor||Wheatley||Founded 1993 as an independent local television station, licensed to Wheatley in an attempt to serve both Chatham and Windsor, Ontario. The UHF 16 Wheatley transmitter proved inadequate to cover Windsor so, in 1995, a Windsor repeater was deployed on channel 60. Newsrooms are in Windsor.|
- The suburban station
- In FM radio broadcasting, small local stations were sometimes built to serve suburban or outlying areas in an era where AM radio stations held the largest audiences and much of the FM spectrum lay vacant. In the era of vacuum tubes, the five-tube AM radio with no FM tuning capability and limited audio quality was common; later advances in receiver design were to make good-quality FM commonplace (even though most AM/FM stereo receivers still have severely limited AM frequency response and no AM stereo decoders). Eventually FM spectrum became a very scarce commodity in many markets as AM stations moved to the FM dial, relegating AM largely to talk radio. As cities expanded, former small-town FM stations found themselves not only in what were now becoming rapidly expanding suburbs but also on what was becoming some of the most valuable spectrum in broadcast radio. The once-tiny FM stations would often then be sold, increased (where possible) to much-higher power and used to serve a huge mainstream audience in the larger metropolitan area.
|Broadcaster||City||Community of license||Comments|
|CFNY-FM 102.1||Toronto||Brampton, Ontario||Originally a secondary signal for a tiny local station, CHIC AM Brampton, the station originally operated with a mere 857 watts, first rebroadcasting existing AM programming, then adopting an alternative-rock format in which entire albums were broadcast nonstop with just a break for the AM operator to flip the LP over. The station has since changed hands various times in the 1980s and now broadcasts from Toronto's CN Tower with a modern rock format. Effectively now a Toronto station, the city of license still indicates Brampton.|
|KROQ-FM 106.7||Burbank - Los Angeles||Pasadena, California||Originally owned by the Pasadena Presbyterian Church and, until 1969, broadcast from a studio in the basement of the church. Multiple changes of ownership, location, format and callsign (the station went bankrupt more than once) ended with Infinity Broadcasting (now CBS) buying the station in 1986 and moving the studios to Burbank the following year. The city of license still indicates Pasadena.|
- The short-spaced station
- To avoid co-channel interference, a minimum distance is maintained between stations operating on the same frequency in different markets. On VHF, full-power stations are typically 175 miles or more apart before the same channel is used again. An otherwise-desirable channel may therefore be unavailable to a community unless either it is operated at greatly reduced-power, forced onto a strongly directional antenna pattern to protect the distant co-channel station or relocated to some other, more distant location in the region to maintain proper spacing. The choice of another community as home for a station can be one possible means to avoid short-spacing, effectively shifting the entire station's coverage area to maintain the required distances between transmitters.
|Broadcaster||City||Community of license||Comments|
|CJOH-TV-6 CTV||Kingston||Deseronto, Ontario||Transmitter primarily serves Kingston, but its construction at full-power in Kingston itself would have resulted in interference to a small part of the CBMT (CBC 6 Montreal) coverage area. The station was therefore built further west, on Mount Carmel in Deseronto, to cover Kingston and Belleville. Co-channel CIII-TV 6 (Global) would in turn be pushed westward to Paris, Ontario when it signed on a few years later, causing it to need a powerful UHF rebroadcaster to adequately cover the Toronto area.|
|WITI 6 Fox; CBS at the time||Milwaukee||Whitefish Bay, Wisconsin||WITI originally signed on in 1956 with the North Shore suburb of Whitefish Bay as nominal community of license operating from a transmission site far north of Milwaukee in the then-rural Ozaukee County town of Mequon (which has since been incorporated as the City of Mequon) as the allocation of VHF 6 to Milwaukee itself at the time would have left the station short-spaced to WOC-TV in Davenport, Iowa. By 1962, transmitters and community of license had both moved to Milwaukee as the FCC learned how to better finesse distancing requirements and allow some exceptions depending on area geography.|
|WETP 2 PBS||Knoxville
|Sneedville, Tennessee||East Tennessee Public Television was founded in 1967 with a transmitter atop Short Mountain in tiny Sneedville (pop. 1000) as the only location which could reach both Knoxville and Johnson City, Tennessee on this frequency without being short-spaced to co-channel stations in Nashville to the west, Atlanta to the south and Greensboro to the east. A local signal was extended into Knoxville itself in 1990 using WKOP, a UHF station.|
- The distant mountaintop antenna
- In hilly or mountainous regions, a city would often be built in a waterfront or lakeside location (such as Plattsburgh-Burlington, both on Lake Champlain) - lower ground which in turn would be surrounded by tall mountain peaks. The only reliable means to get the VHF television or radio signals over the mountains was to build a station atop one of the mountain peaks. This occasionally left stations with a distant mountaintop (or its nearest small crossroads) as the historical city of license, even though the audience was elsewhere.
|Broadcaster||City||Community of license||Comments|
|WPTZ 5 NBC||Plattsburgh||North Pole||WPTZ was originally licensed in 1954 to North Pole, New York, the closest tiny crossroads to its mountaintop transmitter site near Lake Placid/Adirondack State Park. Station has used "North Pole - Plattsburgh - Burlington" or even "Montreal" as part of its on-air identity but the community of license, once chosen, is not easily modified. It took until January 2011 to finally transfer the COL from North Pole to Plattsburgh.|
- The relocation of an existing station
- Often, a license for a new station will not be available in a community, either because a regulatory agency was only willing to accept new applications within specified narrow timeframes or because there are no suitable vacant channels. A prospective broadcaster must therefore buy an existing station as the only way to readily enter the market, in some cases being left with a station in a suburban, outlying or adjacent-market area if that were the only facility available for sale.
|Broadcaster||City||Community of license||Comments|
|CHRO-TV||Ottawa||Pembroke||Launched in the small city of Pembroke in 1961, the station struggled for financial viability until gaining carriage on cable systems in Ottawa and adding a news bureau there — but because it was affiliated with television networks that already had other affiliates in Ottawa proper, it was restricted to cable distribution. It was eventually acquired by CHUM Limited in 1997, and added an over-the-air transmitter in Ottawa after joining CHUM's NewNet system. CHUM subsequently centralized the station's operations and studios in Ottawa — legally, however, the Pembroke transmitter is still the primary station.|
|CHSC||Toronto||St. Catharines||After going into bankruptcy in 2002, the station was acquired by Pellpropco, a company which repurposed the station as a multilingual station aimed at the sizable Italian Canadian community in Toronto. After numerous additional license violations over the next number of years, the CRTC revoked the station's license in 2010.|
|CBAT-DT||Fredericton||Saint John||Originally a private CBC Television affiliate with the call sign CHSJ-TV, the station became the CBC affiliate for the entire province after CKCW-TV in Moncton, the province's only other television station at the time, switched to CTV in 1969. Although CHSJ remained licensed to Saint John, some of the station's programming was produced in Fredericton due to that city's status as the provincial capital. The station was fully relocated to Fredericton in 1994 after becoming a fully owned-and-operated station of the network.|
|KNTV 11 NBC||San Francisco||San José, California||NBC programming traditionally had been carried by KRON-TV 4, a San Francisco affiliate which NBC had unsuccessfully attempted to purchase outright for $750 million in 1999. Outbid by an outside buyer, NBC attempted to force the new owners to rebrand the station as "NBC 4" and greatly restrict the station's ability to schedule its programming differently from the main network. The new owners refused. NBC purchased the San José station for $230 million in 2001, moving their network programming on January 1, 2002 and relocating KNTV's transmitters to San Bruno Mountain on September 12, 2005 over KRON's objections. The station's license and newly built studios remain in San José and the station has well-lapped KRON-TV, which is now affiliated with MyNetworkTV and shares a building with ABC's KGO-TV.|
|WPCW 19 The CW||Pittsburgh||Jeannette, Pennsylvania||Originally a Johnstown station, one of the rare instances in which the community of license for an existing channel has successfully been changed. WPCW (then WTWB) managed to circumvent an FCC moratorium on new channel allocations in Pittsburgh by listing Jeannette, a small community of 11,000 people technically in the Pittsburgh market area, as the new city of license for an existing station. Effectively a flag of convenience, this maneuver portrays the station's owners as moving it from a community that had at least two other broadcasters (Johnstown) to one that had none (Jeannette) - easier to justify for regulatory purposes. The actual intended target market, Pittsburgh, already has many local stations. While the transmitter remains in Jennerstown (a small borough near Johnstown) and is inadequate to properly cover Pittsburgh over-the-air, this nominal community of license in the Pittsburgh market confers "must-carry" status for Pittsburgh's cable TV systems. Studios are at KDKA-TV Pittsburgh and city-grade coverage for Pittsburgh itself is supplied by a UHF repeater. The main transmitters never were moved, and soon after taking a license to serve Jeannette the station applied for must-carry on cable in Johnstown, its former community of license. No physical connection of this station with the small community of Jeannette has ever existed except as a very clever legal fiction. The station's new WPCW callsign is marketed using the slogan "Pittsburgh's CW", and has filed two construction permit applications to base a future digital transmitter within Allegheny County that would still give Jeannette a decent signal.|
|WPWR-TV 50 The CW||Chicago||Gary, Indiana||WPWR operates from Chicago studios, transmitting from the Willis Tower (formerly known as the Sears Tower), but is licensed out-of-state. Its owners obtained this channel allocation by first buying an existing construction permit for a Gary, Indiana station which had been licensed as Channel 56 but never built, then swapping its channel allocations with WYIN - a PBS member station also licensed to Gary, Indiana. WYIN had been refused a Sears Tower transmitter location as Chicago had two locally licensed PBS member stations before 2017.|
|WPXE 55 ION||Milwaukee||Kenosha, Wisconsin||A station which came on the air in 1988 as an affiliate of the religious LeSEA network with low penetration into the general Milwaukee area and some local programming for Kenosha mixed within the general LeSEA schedule, WHKE (as it was known at the time) was purchased in 1995 by Paxson Communications to become the eventual Milwaukee station for the PAX network due to that network's strategy of buying low-rated outlying stations to quickly launch their network, and since then the station has drifted continuously north of their city of license. The station's analog tower was actually located in north-central Racine County, just close enough to serve the northern reaches of the Milwaukee area and still provide a city grade signal to Kenosha. The station has no Kenosha facilities and has their offices in the northern Milwaukee suburb of Glendale, while the station's digital transmitter is within the traditional tower site of all Milwaukee television stations on Milwaukee's northwest side, thus WPXE is a station based in Milwaukee which nominally serves a city thirty miles away from their station facilities. The only mentions of Kenosha at all beyond identification come during their two locally produced programs, which air usually early in the morning.|
|WTVE 51 Ind/Rel||Philadelphia||Reading, Pennsylvania||An outlying UHF station which barely reaches Philadelphia despite applying for ever-increasing amounts of power, WTVE was near-bankrupt. Instead of building one main digital transmitter, WTVE is instead constructing a distributed transmission system composed nominally of eight co-channel transmitters in Reading, Bethlehem, North East MD, Quarryville, Myerstown, Lambertville, Philadelphia and Brockton for a combined total of 136.67kW of digital TV. As the bulk of this power (126 kW) is assigned to the Philadelphia transmitter site alone, effectively this configuration is a full-power Philadelphia station with a series of small low-power on-channel boosters covering the original service area and city of license. (Reading itself will get 760 watts.)|
|WVEA-TV 62 Univisión||Tampa||Venice, Florida||A Spanish-language station licensed to Venice, a community nearly 60 miles away from its Tampa studios and nearly 55 miles away from its Riverview transmitter site, in a Tampa suburb. WVEA originally was an unprofitable English-language independent WBSV, which served the Sarasota / Bradenton / Venice area. In 2000, Entravision acquired WBSV and in 2001 moved the transmitter from Venice to Riverview, increasing transmitter power and adopting its current Spanish-language « ¡vea! » identity (meaning "I see"). Prior to the move, WVEA's programming was seen on a low-powered channel in Tampa.|
|WWOR-TV 9 MyNetworkTV||New York City||Secaucus, New Jersey||New York City's Channel 9, then having the call sign WOR-TV in 1983, was at that time owned by RKO General. Due to misconduct in its operations, RKO General was threatened with loss of its license to operate many of its broadcast stations, including WOR. RKO convinced New Jersey Senator Bill Bradley to introduce a bill in Congress guaranteeing an automatic renewal of a station's license if it moved to a state that did not have a VHF commercial television station under a claim of 'underservement'. Under that very specific criteria, only New Jersey and Delaware met those requirements (both states being dually served by stations from New York or Philadelphia). With the bill passed and signed by Ronald Reagan, WOR relocated the station's operations to a business park in their new city of license, Secaucus (located directly across the Hudson River from Manhattan), and obtained an automatic license renewal, though their transmission facilities remained atop the World Trade Center in Manhattan and requirements for the station to properly serve New Jersey, an issue that has continued to affect WWOR's operations to the present day (their last license renewal was delayed by several years due to FCC claims it did not fulfill this directive).|
|WYCN-CD 15 NBC||Boston||Nashua, New Hampshire||The newest example in this list, this was a result of the FCC's 2016 spectrum auction to reallocate television spectrum for the use of wireless devices. WYCN was previously a low-power community station serving Nashua carrying low-interest networks out of primetime, but was purchased by OTA Broadcasting in 2013, a company that mainly purchased stations to profit from their spectrum rather than a genuine interest in broadcasting. OTA won $80.4 million from the FCC for returning its spectrum, but also decided to retain the station's license for a channel sharing arrangement with another station, of which it had perfect timing; NBCUniversal was looking for both a full-market station and a way to broadcast their "NBC Boston" service (originating on equally low-power WBTS-LD) after their 2017 disaffiliation from WHDH. OTA, NBC, and the WGBH Educational Foundation then made an arrangement where WYCN would be purchased from OTA by NBC's O&O group, and WGBH would arrange to share their spectrum on secondary PBS member station WGBX-TV, allowing NBC a full-market and central home for their NBC and Cozi TV programming in Boston on their signal, using the license of what is in technicality a low-power station. The station thus moved on January 18, 2018 from transmitting a low-power signal only serving Nashua, to a full-power signal transmitting 32 miles (51 km) away in Needham, Massachusetts, with NBC programming, sports and Boston news replacing the repeat-heavy Heroes & Icons network (though WBTS-LD remains the originating station for NBC Boston).|
- The border blaster
- Occasionally, a community on an international border is served using a station licensed to another country. This may provide access to less restrictive broadcast regulation or represent a means to use local marketing agreements or adjacent-market licences to circumvent limits on the number of stations under common ownership.
|Broadcaster||City||Community of license||Comments|
|WTOR AM 770||Toronto||Youngstown, New York||WTOR airs a multicultural format aimed primarily at listeners in the Greater Toronto Area in Canada, rather than in its home state of New York. The station uses a highly directional transmitter array, aimed so strongly at Toronto that parts of Michigan can receive the station even though it's barely audible in Buffalo, just 20 miles south of its transmitter.|
|KVRI AM 1600||Vancouver||Blaine, Washington||A Punjabi language radio station licensed to the border town of Blaine, Washington. Owned by Multicultural Broadcasting, the station has a local marketing agreement with Radio India. Studios are located in Surrey, British Columbia.|
|WLYK FM 102.7||Kingston||Cape Vincent, New York||A south-of-the-border station licensed to a tiny border village of 760 people. Owned by US-based Border International Broadcasting, but operated through a local marketing agreement from the Kingston (Williamsville) studios of CIKR-FM (K-Rock 105.7). Primary audience is Kingston, Ontario, population 117,000.|
|XETV-TDT 6 Canal 5||San Diego||Tijuana, Baja California||Mexican-owned station, fed from a San Diego-based studio. San Diego (channels 8 and 10), Los Angeles (channels 2, 4, 5, 7, 9, 11, and 13) and Santa Barbara (channel 3) had already been allocated as early as 1952, with the remaining pair of VHF channels (6 and 12) allocated to Tijuana by Mexican authorities. The only means to add a third VHF TV broadcaster to San Diego without unacceptable interference was therefore to enter a local marketing agreement with Mexican-owned Televisa. The station was a charter Fox affiliate until 2008, when San Diego-licensed KSWB-TV took over the affiliation. The digital age allowed XETV to affiliate with Televisa's Canal 5 network using their DT2 signal, and for over a year until it was signed off in mid-July 2013, the analog signal carried Canal 5, made XETV the only North American station at the time to carry both an American-originated and Mexican-originated network on their signal. The station lost its affiliation to the CW after failing to reach an agreement with the network, which later switched to KFMB-DT2 and shut down its news operation. It ended English-language programming on May 31, 2018, with Canal 5 programming moving to 6.1|
|XHAS-TDT 33 Azteca América||San Diego||Tijuana, Baja California||A Spanish language broadcaster licensed to Tijuana, Mexico, this station is fed from studios in San Diego, USA. The same US-based facilities also formerly fed English language XHDTV-TV (My 49, Tecate, Baja California) until it itself switched to carrying Milenio Television in September 2018. The station was formerly a Telemundo affiliate until June 30, 2017 after NBC, which owns KNSD in San Diego, announced plans to create a Telemundo O&O station. Telemundo programming was later moved to the recently acquired KUAN-LD where it has been a Telemundo O&O Station since 2017.|
|XHITZ-FM 90.3||San Diego||Tijuana, Mexico||Finest City Broadcasting holds a programming and local marketing agreement with Mexican XHITZ, XETRA-FM and XHRM-FM, delivering programming from San Diego studios across the U.S.-Mexico border. Direct competitor XHMORE-FM, also licensed to Tijuana, markets itself as "Blazin' 98.9 FM, San Diego's official hip-hop station."|
|XHRIO-TV 2 The CW||Rio Grande Valley, Texas||Matamoros, Tamaulipas, Mexico||Like the former CW affiliate XETV, CW 15 Rio-Grande formerly broadcast news via a Mexican-owned station fed from a US-based studio. It is a sister station of KNVO-DT3, a subchannel of an Entravision-owned Spanish language Univisión station licensed to McAllen, Texas. It formerly broadcast Telemundo, UPN, Fox, and MundoFox/MundoMax programming. As of 2016, it has now broadcast CW programs.|
|WYUL 94.7||Montreal||Chateaugay, New York||Like WLYK, the station has a contemporary hit radio format serving a larger city on the Canadian side of the border from a city on the U.S. border. Its city-grade signal reaches the southwestern parts of Greater Montreal, other parts of southwestern Quebec, and Cornwall, Ontario, along with Malone and Massena on the New York side of the border. Its class C2 signal reaches much of Montreal proper, and even some of its northern suburbs such as Laval. It has studios located in Pointe-Claire, Quebec, a southern inner suburb.|
- The last-available frequency allocation
- In the early days of television, the majority of stations could be found on the VHF band; in North America, this currently represents just twelve possible channels and in large markets any suitable allocations in this range were mostly full by the early 1950s. Occasionally, a prospective broadcaster could obtain one of these coveted positions by acquiring an existing station or permit in an adjacent community - although in some cases this meant a move out-of-state.
|Broadcaster||City||Community of license||Comments|
|WCTV 6 CBS||Tallahassee||Thomasville, Georgia||First broadcast in 1955 from a studio in Tallahassee, but was licensed to Thomasville using a transmitter in Metcalf, Georgia. The FCC had allocated only one VHF channel to Tallahassee, which was already in use by Florida State University's noncommercial WFSU-TV 11. WTLH Fox 49 also covers Tallahassee from a transmitter in Metcalf, Georgia.|
|WHYY-TV 12 PBS||Philadelphia||Wilmington, Delaware||Originally licensed in 1957 as channel 35 Philadelphia. In an era where TV manufacturers were not required to provide UHF tuners, few could receive the station. When WVUE 12 Wilmington went off the air in 1958, WHYY applied to serve Wilmington as channel 12 was the nearest available VHF allocation.|
|WNET 13 PBS||New York||Newark, New Jersey||One of the victims of the September 11, 2001 attacks, WNET once broadcast from a shared master antenna atop the former World Trade Center. Its community of license is Newark because the only means to acquire scarce VHF-TV spectrum in New York City was to purchase existing Newark independent WATV. An on-air identifying logo displays initially as "WNET Newark, New Jersey", then transitions to "WNET New York"; the station provides New Jersey local public-affairs coverage through its co-operated sister network for that state, NJTV, but is located entirely in New York City. Currently, WNET transmits from atop the Empire State Building, however, it has plans to move to 1 World Trade Center by 2018, where other New Jersey licensees including WWOR-TV 9 Secaucus and WNJU 47 Linden currently transmit.|
- The use of an adjacent market
- Occasionally, a station owner would reach a legal limit on concentration of media ownership, already having the maximum number of commonly owned stations in a market. Additional stations would be possible by transmitting the extra signals from a station technically in an adjacent market.
|Broadcaster||City||Community of license||Comments|
|CKBY-FM 101.1||Ottawa||Smiths Falls||As station owner Rogers Communications already has multiple stations licensed to Ottawa, limits on concentration of media ownership restrict it from moving additional stations into that city. The city of license has therefore remained at Smiths Falls, a small town of roughly 80 km distant, and the station is absent from the Ottawa-Hull digital radio cluster as that signal would not reach the community of license. Despite this the station effectively acts as an adjunct to the Ottawa radio market, and has undergone frequent format, branding and call sign changes based on market conditions in Ottawa.|
- The arbitrary nominal location
- In some cases, stations were constructed or acquired with the express purpose of driving a regional or province-wide chain of full-power repeaters. Which of these "satellite stations" would be designated as the main signal could be an arbitrary choice, as the programming carried on all stations in the system would be identical.
|Broadcaster||City||Community of license||Comments|
|CHLF-TV 39 TFO||Toronto||Hawkesbury||TFO (Télé-Française d'Ontario) was a repeater chain broadcasting the same signal in 17 cities and towns with large francophone communities; it relied primarily on cable television for distribution in much of Ontario. Studios are in Toronto, the provincial capital, as TFO belongs to Ontario's government, although the station is not physically available over-the-air in that community. As such, the choice of which of the multiple repeaters to designate as the primary station was arbitrary; Hawkesbury was chosen because that signal crossed the Ontario-Quebec border into Montreal, Canada's largest francophone television market. As of 2012, TFO is no longer available over the air.|
|CIII-TV 6 Global||Toronto||Paris||From its launch in 1974 until 2009, this station's primary city of license was Paris, a small town near Brantford, although the main studios were located in Toronto. A chain of repeaters covering most of Ontario, the choice for the nominal primary station was an arbitrary one. Toronto could have reasonably been chosen as nominal city of license, but to do so would be to name a suburban UHF outlet as the main station. Eventually UHF's perceived disadvantage was tampered down by cable and the start of the digital era, and the station's Toronto rebroadcaster on Channel 41, CIII-TV-41 became the originating broadcaster legally as defined by the CRTC for the CIII/Global Ontario network in mid-2009.|
|CKMI-TV 20 Global||Montreal||Quebec City||Similarly, from the station's launch until 2009, Quebec was the city of license and Montreal 46 / Sherbrooke 11 merely repeaters constructed after acquisition of the existing Quebec station. As the studios, master control facilities and largest audience are in Montreal, and the number of anglophones in mostly francophone Quebec City is small, this was a Montreal station in all but name. Like its sister station CIII, the station's license was moved to Montreal in 2009.|
- Silverman, David M.; Tobenkin, David N. (May 2001). "The FCC's Main Studio Rule: Achieving Little for Localism at a Great Cost to Broadcasters" (PDF). Federal Communications Law Journal. Bloomington, Indiana: Indiana University Maurer School of Law. 53 (3): 471. Archived from the original (PDF) on September 16, 2012.
- Text as amended, 47 U.S.C. § 307(b).
- 47 C.F.R. 73.1120
- 47 C.F.R. 73.315 paragraph (a). Retrieved 2010-04-07.
- 47 C.F.R. 73.515. Retrieved 2010-04-07.
- 47 C.F.R. 73.1201. Retrieved 2010-04-08.
- 47 C.F.R. 73.1125(e). Retrieved 2010-04-08.
- 47 C.F.R. 73.1125(a)(3). Retrieved 2010-04-08.
- Blair, Linda (1998-10-16). "Re: Modification of Facilities of KGAC(FM), Saint Peter, MN (BPED-970203IC)" (PDF). Washington, D.C.: Federal Communications Commission.[permanent dead link]
- ON THE RADIO: Corporate bigfoot CSN tunes out community stations, MIKE MILIARD, Boston Phoenix Archived March 3, 2016, at the Wayback Machine
- [dead link]
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- Spectrum efficiency and the public interest, Journal of Broadcasting & Electronic Media, Dec 2006, Alan G. Stavitsky, Tad Odell
- Fybush Northeast Radio Watch tower sites - Anniston, Alabama
- Copps/Adelstein, FCC, 2008, re: FM (Evergreen, Alabama and Shalimar, Florida, MB Docket 04-219), (Lincoln and Sherman, Illinois, MM Docket 01-120)[dead link]
- FCC Rules §73.24, §73.315 and §73.625
- MM Docket No. 97-96 Table of Allotments, RM-8756 TV Broadcast Stations (Johnstown and Jeannette, Pennsylvania)
- RECnet Archived August 14, 2007, at the Wayback Machine, About the FM Table of Allotments
- Commission adopts Table of Allotments for DTV (MM DOCKET NO. 87-268)
- MM Docket No. 89-686 Table of Allotments FM Broadcast Stations. RM-7035 (Eatonton and Sandy Springs, Georgia)
- WorkingSpace&trad;. "Milwaukee TV Horror Hosts - TV History". Milwaukee-horror-hosts.com. Archived from the original on 2008-08-27. Retrieved 2010-02-21.CS1 maint: Multiple names: authors list (link)
- "A selection from a decade of visits to tower and studio sites in the Northeast and beyond". Fybush.com. Retrieved 2010-02-21.
- "WISN-TV's 50th Anniversary - MilwaukeeHDTV.org Forums". Milwaukeehdtv.org. Retrieved 2010-02-21.[permanent dead link]
- Gary Shea. "Analog TV in Milwaukee History lecture review". Garyshea.com. Retrieved 2010-02-21.
- FCC notice of proposed rule making Archived September 30, 2007, at the Wayback Machine, MM Docket No. 99-238, RM-9669 (North Pole and Plattsburgh, New York)
- (PDF) https://web.archive.org/web/20110810230737/http://transition.fcc.gov/Daily_Releases/Daily_Business/2011/db0105/DA-10-2443A1.pdf. Archived from the original (PDF) on August 10, 2011. Retrieved February 23, 2011. Missing or empty
- CRTC Decision 2010-533.
- NBC to buy San Jose's KNTV, Silicon Valley / San Jose Business Journal, December 17, 2001
- FCC notice of proposed rule making (Johnstown and Jeannette, Pennsylvania)
- FCC report and order Table of Allotments, RM-8756 (Johnstown and Jeannette, Pennsylvania)
- FCC In re Petition of: Venture Technologies Group, Inc. CSR-5094-A For Modification of Market of Station WNPA-TV
- WNPA-TV moves under KDKA umbrella, Pittsburgh Business Times, September 13, 2000
-  Archived June 25, 2008, at the Wayback Machine
- Future of NYC Broadcast TV Moving to 1 WTC
- Broadcasting Decision CRTC 2002-364, 13 November 2002, Rogers Broadcasting, Transitional digital radio undertaking associated with CIOX-FM Smiths Falls (CKBY-FM), (denied) Archived February 19, 2005, at the Wayback Machine
- CRTC Decision 2009-409