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The FCC noted that the appellants suffered from  W a "basic misunderstanding of our channel exchange policy and our short-spacing rules," explaining  W that "while petitioners are correct that the channel exchange rule applies to construction permits  X3 W Gas well as licenses, neither the rule nor the cases they cite require approval of the instant proposal  X3 W which would result in a short-spaced commercial allotment." Id. at 19,651 (emphasis added).  X3 W The appellants argued, inter alia, that because the FCC had already determined that the technical  W difficulties in constructing a facility on Cheyenne Mountain were not so great as to deny a  W short-spacing waiver to USC, the FCC should therefore either transfer the pre-existing waiver to  W 'Sangre de Cristo or approve Sangre de Cristo for a waiver based upon the identical technical  W 7considerations. The FCC rejected the appellants' arguments, noting that "the waiver granted to  W USC was also based upon the clear and substantial benefits to noncommercial, educational service  XI3 W Ywhich the relocation [to Cheyenne Mountain] would permit."  Id. at 19,652. The Commission  W stated that, "[b]ecause the educational station would no longer enjoy the benefits of the short  W Xspaced Cheyenne Mountain site under the subject channel exchange proposal, the [FCC] staff was  W required to determine anew, for a commercial station, whether a short spacing requirement would  X3 W be appropriate." Id. Because the appellants had made "no showing of compelling need or  W extraordinary circumstances ... sufficient to outweigh the public interest benefit of observing the integrity of the TV Table of Allotments and the minimum spacing rules," the FCC concluded:  rXpX` ` We agree with the staff's determination that the overall public  rinterest is better served by denial of the waiver request and  rpreservation of the integrity of the spacing requirements in this  rcase. In weighing the public interest in this case, we also note that  ras many as 20,000 people or more would lose their only primary  X"(3  r(i.e., full-service, protected) commercial off-air service if the""(0*0*0*+"  r@waiver were granted and KOAATV were to change its transmitter site.x` Xp(#  X3Id.S X43ԍ The FCC also found "unpersuasive petitioners' argument that consideration of the noncommercial educational status of Station KTSC(TV) in granting the waiver violates the  X3First Amendment." MO&O, 11 F.C.C.R. at 19,653.  X3 plpUSC and Sangre de Cristo now ask this Court to reverse the Commission's Memorandum  Vz3Opinion & Order.  XL3C3 II. ă  ppWe review FCC decisions "under the arbitrary and capricious review standard" and "do  W not 'substitute [our] judgment for that of the agency' but rather look to see 'whether the decision  W was based on a consideration of the relevant factors and whether there has been a clear error of  X 3 W Yjudgment.' " Freeman Eng'g Assocs., Inc. v. FCC, 103 F.3d 169, 178 (D.C. Cir. 1997) (quoting  X 3 W Motor Vehicles Mfrs. Ass'n of the United States, Inc. v. State Farm Mutual Auto. Ins. Co., 463 U.S. 29, 43 (1983)).  ppHere, however, it is unclear what the FCC believed to be the "relevant factors" in its  W ruling. It is undisputed that, before the 1991 waiver of the minimum spacing requirement granted  W to USC, the Commission did not take the commercial or non-commercial status of short-spacing  X<3 W waiver applicants into account. See, e.g., Appellee Br. at 21 ("This case presented the  W Commission with an issue of first impression."). But the waiver letter to USC signed by Barbara  X3 W Kreisman, Chief of the MMB's Video Services Division, was obscure on this point: it began by  X3 W 7noting that the FCC was "mindful of the unique role played by many noncommercial television  W 'stations in providing public television service to wide areas" and then catalogued eight other  X3 W factors supporting waiver, none of which it identified as dispositive. See Kreisman Letter, supra,  X3 W %at 2 (emphasis added). In apparent contrast, the MMB's NPRM indicated that "USC was granted  X3 W a waiver ... based upon its stated need to continue providing noncommercial educational  X3 W television service to Colorado Springs without relying on a translator to provide a viewable signal  W Jto that community." 8 F.C.C.R. at 4753 (emphases added). Even though the appellants'  W proposed channel swap would in fact enable USC to improve its service to the Colorado Springs  W Hcommunity in conformity with 47 C.F.R.  1.420(h), the FCC nevertheless concluded that "the  W Ypublic benefits that would be derived from the short-spaced allotment [the petitioners seek] are  W not large enough to outweigh the public interest benefit of the integrity of the TV Table of  X3 W Allotments and the minimum spacing rules." Report & Order, 10 F.C.C.R. at 7667; see also  X3 W HMO&O, 11 F.C.C.R. at 19,652 ("We agree with the staff's determination that the overall public  W interest is better served by denial of the waiver request and preservation of the integrity of the spacing requirements in this case."). ""M0*0*0*%"Ԍ p9pWe conclude that the FCC did not adequately explain why the "public interest benefit of  W \the integrity of the TV Table of Allotments and the minimum spacing rules" would be  W 6out-weighed by USC's short-spaced broadcasts but not by Sangre de Cristo's. The FCC may well  X3 jdecide to factor the commercial status vel non of an applicant into its short-spacing waiver  X3 jdecisions, as it appears to have done, or it may develop an alternative rule.GS X3ԍ In this regard, we note that the FCC enjoys "a broad measure of discretion in dealing  X3with the many and complicated problems of allocation and distribution of service." Television  X3Corp. of Mich. v. FCC, 294 F.2d 730, 733 (D.C. Cir. 1961).G Whatever the  jCommission decides, it must better explain the basis for its action (particularly in light of its past  jpractice which did not consider the commercial/noncommercial status of an applicant) than it has  Xa3 j|done. aOS Xa 3ԍ To the extent the Commission used a commercial/noncommercial distinction, it appears  XJ 3to be inconsistent with its earlier decision in Applications of Open Media Corp., 8 F.C.C.R. 4070 (1993), which described its "policy of refusing to base waivers of rules designed to prevent interference upon non-technical considerations such as ownership or programming."  X3Id. at 4071. The Commission did not even mention Open Media in its opinion below. See, e.g., Committee for Community Access v. FCC, 737 F.2d 74, 77 (D.C. Cir. 1984)  j(Commission "cannot silently depart from previous policies or ignore precedent"). And if the  jFCC does elect to consider the commercial/noncommercial status of an applicant, it must ground its modification in a manner  $9NJ consistent with the First Amendment.  X 3`" III. ă  jWhile we cannot say that "the agency's reasons for declining the waiver were 'so  X 3 jinsubstantial as to render that denial an abuse of discretion,' " Thomas Radio Co. v. FCC, 716  jF.2d 921, 924 (D.C. Cir. 1983) (citation omitted), at the same time we cannot discern with  jprecision on what basis the FCC made its ruling. Indeed, the FCC conceded during oral  jargument that it had not definitively addressed the importance of the commercial/noncommercial  jstatus of a short-spacing waiver applicant. Accordingly, and for the reasons set forth above, we remand to the FCC for further proceedings consistent with this opinion.  X 3`(#So ordered. $9NX