November 19, 1996
                                    
     1800E1-JMG

Raycom Media Subsidiary III, Inc.
c/o David H. Pawlik
Skadden, Arps, Slate, Meagher & Flom
1440 New York Avenue, N.W.
Washington, D.C. 20005-2111

AFLAC Broadcast Group, Inc.
c/o John E. Fiorini
Carton & Douglas
1301 K Street, N.W.
East Tower, Suite 900
Washington, D.C.  20005

Re:Application for Assignment of License 
for Station WAFB(TV),
Baton Rouge, Louisiana
BALCT-960909ID

Dear Gentlemen:

     This refers to the above-captioned application  seeking consent to the assignment of
license of station WAFB(TV), Baton Rouge, Louisiana, from AFLAC Broadcasting Group,
Inc. ("ABG"), to Raycom Media Subsidiary III, Inc. ("Raycom III").  Raycom III's parent
company, Raycom Media, acquired control of WJTV(TV), Jackson, Mississippi, on September
12, 1996.  Because the Grade B contours of stations WAFB(TV) and WJTV(TV) overlap,
Raycom III requests a permanent waiver of Section 73.3555(b) of the Commission's Rules,
the duopoly rule, which generally proscribes common ownership of television stations whose
Grade B service contours overlap.  

     The Commission's duopoly rule seeks to promote diversity in programming sources
and viewpoints and to prevent an undue concentration of economic power by fostering
economic competition in broadcasting.  Multiple Ownership Rules, 22 FCC 2d 306, 307
(1970), recon. granted in part, 28 FCC 2d 662 (1971).  In adopting the duopoly rule's fixed
standard of prohibiting overlap of Grade B service contours, the Commission also
acknowledged the need for "flexibility" in that rule's application, noting that waivers should
be granted where rigid conformance to the rule would be "inappropriate."  Multiple
Ownership of Standard, FM and Television Broadcast Stations (Multiple Ownership), 45 FCC
2d 1476 n.1, recon. granted in part, 3 RR 2d 1554 (1964).  To that end, the Commission has
developed a set of factors to be considered in evaluating requests for both permanent and
temporary waiver of the duopoly rule, including the extent of the overlap, the distinctiveness
of the respective markets, the number of media voices available in the overlap area, and the
concentration of economic power resulting from the combination.  See, e.g. Capital
Cities/ABC, Inc., 11 FCC Rcd 5841, 5862-63 (1996) (citations omitted).  After weighing the
factors, the Commission considers any public interest benefits proposed by the applicant to
determine whether, in light of the overlap, the benefits outweigh any detriment which may
occur from grant of the waiver.  See, e.g., Iowa State University Broadcasting Corp., 9 FCC
Rcd 481, 487-88 (1993); aff'd sub nom. Iowans for WOI-TV, Inc. v. FCC, 950 F.3d 1096
(D.C. Cir. 1995).  Waiver will only be granted if the Commission concludes that to do so
would serve the public interest.  

     Further, the Commission has allowed common ownership of stations with overlapping
Grade B contours where signal overlap is de minimis, see, e.g., Hubbard Broadcasting, Inc., 2
FCC Rcd 7374 (1987), or where the public interest benefits to be gained from  waiving the
rule would be greater than any detrimental effects resulting from the overlap.  See, e.g.,
Capital Cities Communications, 59 RR 2d 451, 465 (1985).  Our past cases have
characterized a de minimis signal overlap as one in which the overlap area represents less than
one percent of both the area and the population of the Grade B contour of each station. 
Hubbard Broadcasting, 2 FCC Rcd at 7374.  

      Raycom III states that initially no overlap of the Grade B contours of the two stations
was expected.  Now, however, engineering analysis reveals that there will be a very slight
overlap.  Raycom III submits an engineering analysis stating that the area of overlap is 72
square kilometers and affects 320 people.  This overlap represents .18% of the area and .04%
of the population of station WJTV(TV)'s Grade B contour and .19% of the area and .02% of
the population of WAFB(TV)'s Grade B contour.  The stations serve two different markets: 
the Jackson DMA is ranked 91st and is served by seven television stations, including
WJTV(TV), while the Baton Rouge DMA is ranked 98th and served by five television
stations, including WAFB(TV).  These cities are in different states and are 140 miles apart. 
Further, the entire overlap area is served by three other television stations.  

     Upon review of the engineering data, we agree that the overlap area is de minimis. 
Accordingly, we find that grant of the waiver request, which is unopposed, would be in the
public interest.   

     Having determined that the applicant is fully qualified and that a grant of the
application will serve the public interest, the request of Raycom Media Subsidiary III, Inc.,
for waiver of the duopoly rule, Section 73.3555(b) of the Commission's Rules, to permit
common ownership of stations WAFB(TV) and WJTV(TV) and the application to assign the
license of WAFB(TV) to Raycom Media Subsidiary III, Inc., ARE GRANTED.

     Sincerely,



     Roy J. Stewart
     Chief, Mass Media Bureau