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37jC:,Xj\  P6G;XP 07nC:,4Xn4  pG;X 22a=5,r&a\  P6G;&P 12e=5,d[&e4  pG;& 0_=5,%]&_*f9 xr G;&X+H5!,),5\  P6G;,P\,{,W80,%BZW*f9 xr G;X'2e=5,&e4  pG;&\60_=5,%&_*f9 xr G;&XP:% ,J:\  P6G;JPxxxxxxxxxxxxxxxxxxxxxxN+HH+7<)5<<<(ԍ47 U.S.C. 534(h)(1)(C).C In considering such requests, the 1992 Cable Act provides that: the Commission shall afford particular attention to the value of localism by taking into account such factors as (I) whether the station, or other stations located in the same area, have been historically carried on the cable system or systems within such community; (II) whether the television station provides coverage or other local service to such community; (III) whether any other television station that is eligible to be carried by a cable system in such community in fulfillment of the requirements of this section provides new coverage of issues of concern to such community or provides carriage or coverage of sporting and other events of interest to the community; and"x,p(p(88"Ԍ(IV) evidence of viewing patterns in cable and noncable households within the  S(areas served by the cable system or systems in such community.\t {O@(ԍMust Carry Order, 8 FCC Rcd 2965, 2976 (1993).\  S(4. ` ` The legislative history of this provision indicates that: where the presumption in favor of ADI carriage would result in cable subscribers losing access to local stations because they are outside the ADI in which a local cable system operates, the FCC may make an adjustment to include or exclude particular communities from a television station's market consistent with Congress' objective to ensure that television stations be carried in the areas in which they serve and which form their economic market.  S (X` hp x (#%'0*,.8135@8:  yO@(ԍPetition at Exhibit D.>  xInterMedia points out that in a previous ADI decision involving the Atlanta ADI, the Cable Services  xBureau ("Bureau") noted that "[w]hile carriage on nearby cable systems is not a factor specified in the  xstatute, such carriage serves to demonstrate the belief of both the stations and systems involved that there  xis a market nexus between the broadcast station and the communities where the station is carried and thus  S( x*provides evidence as to the scope of a station's market."o X {O (ԍSee Paxson Atlanta License, Inc., 13 FCC Rcd 20087, 20100 (1998).o InterMedia maintains that in this case the  xabsence of such carriage demonstrates that there is no market nexus between WATC and the cable communities herein.  Sp( ` < 11. ` ` Second, InterMedia states that WATC's Grade B contour does not encompass the system  SH ( x8communities.>H  yO(ԍPetition at Exhibit E.> In addition, InterMedia indicates that WATC's transmitter is located, on average, nearly  x100 kilometers (62.1 miles) from the cable communities. InterMedia points out that the Bureau has  S ( x`previously considered distances lower than this adequate to justify exclusion.* z {O( xԍSee, e.g., Armstrong Utilities, Inc., 12 FCC Rcd 2498 (1997)(6389 kilometers); AR Cable Services, Inc., 11  {O(FCC Rcd 21080 (1996)(77 kilometers); and Time Warner Cable, 11 FCC Rcd 13149 (1996)(72 kilometers).* InterMedia maintains that  xit is not surprising, therefore, that WATC does not provide an adequate signal to the system and does not serve the communities within the meaning of the modification criteria.  SX( `  12. ` ` Third, InterMedia states that WATC's program lineup provides no evidence of any  x programming specifically targeted to viewers in the instant communities. Although in its demand for  xcarriage WATC made vague references to future plans to create weekly programming relating to the  xAthens area, InterMedia argues that the Bureau does not credit such speculative representations.  S( x<InterMedia states that in Budd Broadcasting Co., the Bureau stated that "we cannot conclude that [WGFL xpTV] is a "Local Station" based upon future intentions. . . . For the purposes of determining whether a  xvstation is local to a specific market at a given point in time, our focus is on the programming being  SB( xaired."B {O( xԍ13 FCC Rcd 15462, 154688 (1998) (citing TCI Communication of Texas v. Paxson Houston License, Inc., 12 FCC Rcd 12031, 12039 (1997)). Moreover, InterMedia asserts that WATC's failure to offer local programming is not mitigated  xby its specialized format. It states that the Bureau has stated that "[t]he fact that a station is of specialized  xappeal does not mean that its logical market area is without limits or that it should be exempt from the  S( xSection 614(h) market modification process."w0  {O"(ԍSee RifkinNarragansett of South Florida, 11 FCC Rcd 21090, 21104 (1996).w In any event, InterMedia states that its cable communities  S(already receive ample local programming from the television stations it currently carries.sX  yO%( xԍPetition at 7. As examples, InterMedia points to WNEGTV (CBS), Greenville, South Carolina, which reported  xon 350 news stories specific to the AthensClarke County area in 1998, and WXIATV (NBC), Atlanta, Georgia, which reported a total of 125 stories specific to the communities in 1997 and 1998.s "z,p(p(88z"Ԍ S( `  13. ` ` Fourth, InterMedia argues that although it has not commissioned an audience survey for  xWATC in the instant communities, there is little hope that the station will show any appreciable  xvviewership given its lack of a Grade B signal and its carriage on nearby cable system. In addition,  xInterMedia indicates that WATC is not listed in the television program listings of the area's daily  S`(newspaper, the Athens BannerHerald/Daily News, or in the local edition of TV Guide.  S( ` p 14. ` ` Finally, InterMedia states that in this instance, the cable communities it serves, with  xAthens as their cultural and economic focal point, form a distinct and separate market from that of Atlanta,  S( xto which WATC is licensed.  yO* ( xnԍIndeed, InterMedia argues that the Bureau came to this same conclusion in a previous modification proceeding  {O (involving an Athens station. See MediaOne, Inc., 12 FCC Rcd 12155, 12169 (1997).  It points out that the University of Georgia, which is located in Athens,  S( xpprovides a vibrant recreational and cultural scene in which the Athens Banner newspaper's circulation  St( xvdwarfs that of the AtlantaJournalConstitution. Also, InterMedia states that not only does Rand  xBMcNally's Basic Trading Area ("BTA") system, its Ranally Metropolitan Area ("RMA") standard and its  xBPrincipal Business Center ("PBC") standard all place Atlanta and Athens in separate BTAs, but the U.S.  S ( xOffice of Management and Budget's Metropolitan Statistical Area ("MSA") classification does as well.> " yO(ԍPetition at 10 and 11.>  xLIn addition, InterMedia states, the counties in which the communities are located are in a totally separate congressional district than is Atlanta and its surrounding areas.  S^( ` 15. ` ` In opposition, WATC states that, although it is licensed as a noncommercial educational  xstation ("NCE"), it is not eligible to receive a community service grant from the Corporation for Public  xBroadcasting and, therefore, can never assert must carry rights as a "qualified" NCE station pursuant to  S( xSection 614(1)(1)(A).C yO8(ԍ47 U.S.C. 615(1)(1)(A).C Therefore, WATC states that it must rely on donations from the public to  xmaintain operations rather than sell advertising and the audience it reaches via cable is critical to its  x`continued viability. WATC indicates that it is currently operating at an effective radiated power ("ERP")  Sn( x$of 1740 kw, but has a pending application for a construction permit to increase its power to 5,000 kw.@nB yOP(ԍOpposition at Exhibit A.@  xDespite its lower ERP, however, WATC states that it has worked diligently in obtaining cable carriage  xand it is now carried on 8 cable systems and will shortly be carried on a ninth. As part of its efforts in  xobtaining carriage, WATC states that it requested carriage on InterMedia's system, but was denied such  xcarriage based on a claim of inadequate signal strength. WATC maintains that InterMedia's denial was  x*merely a pretense for the filing of its modification request and that if InterMedia had tested WATC's  xsignal at higher than 25 feet on its headend tower, it would have received an adequate signal and been obligated to commence carriage of the station.  S( ` 16. ` ` With regard to historic carriage, WATC points out that Section 614(h) of the  x Communications Act provides that the Bureau must consider "whether the station, or other stations located  xin the same area, have been historically carried on the cable system or systems" within the communities  S( x.at issue.G yO'(ԍ47 U.S.C. 614(h)(C)(ii)(I).G WATC states that in this case, InterMedia's own Exhibit D establishes that its Athens system"b ,p(p(88"  xhas historically carried 7 other television stations licensed to Atlanta WSB, WATL, WGNX, WAGA,  x.WTBS, WXIA and WUPA. WATC argues that not only does InterMedia carry nearly every other full xjpower television station licensed to Atlanta, but those stations represent the bulk of the television stations  xcarried on the Athens system's basic tier. WATC maintains that InterMedia's carriage of its fellow  xAtlantabased stations is convincing and sufficient evidence that the "natural" market of Atlantaarea  xstations includes Athens, Georgia and its surrounding communities. WATC states that, in refusing to grant  xsimilar market modification requests, the Bureau has repeatedly held that historical carriage evidence of  S( xa station's competitors is so compelling that it must be given "overriding" weight.^ {OP( xԍSee, e.g., TWI Cable, Inc., 12 FCC Rcd 13187, 13192 (1997); G Force, L.L.C., 13 FCC Rcd 10386, 10390  {O ( xJ(1998); Adelphia Cable Communications, 13 FCC Rcd 99, 106 (1997); North Texas CableVision, Ltd., 12 FCC Rcd  {O (17528, 17535 (1997); and Service Electric Cable TV, Inc., 12 FCC Rcd 13299, 13309 (1997). Moreover, WATC  xindicates that, despite InterMedia's claims, it is carried on cable systems serving communities in Gwinnett  xand Rockdale counties and will soon commence carriage in Walton County. In any event, WATC argues  xthat the Bureau should consider that WATC's lack of historical carriage is not only due to its specialty  xHformat and its recent onair date, but can also be attributed to the fact that its application for a power increase has not yet been acted on due to the Commission's digital television proceedings.  S ( ` 17. ` ` WATC argues that Congress never intended for the Cable Act to be used by cable  xoperators like InterMedia to deprive the public of choices in areas such as Athens which are located  xoutside of major metropolitan areas, particularly when doing so would be discriminatory. WATC states  xit is not trying to assert that its market has no limits, but rather that it is simply seeking to have a coequal  xright with its fellow Atlantabased stations. WATC maintains that its lack of a Grade B signal is  xtinsignificant in this instance because the Bureau has routinely denied requests for exclusion of nonGrade  xB or geographically distant stations where a grant of the modification would discriminate against one  S( xstation among several licensed to the same community. {OF( xxԍSee, e.g., TWI Cable, Inc., 12 FCC Rcd at 13192; G Force, L.L.C., 13 FCC Rcd at 10389; and Adelphia Cable,  yO(13 FCC Rcd at 1067. WATC points out that its Grade B contour falls  xzroughly 7 miles short of the Oconee County border. However, WATC argues that given the fact that  xtInterMedia carries 7 of WATC's competitors, a grant of the requested exclusion would result in disparate  xcable carriage, unfairly deny WATC to opportunity to reach viewers in the communities and allow InterMedia to discriminate among several stations licensed to Atlanta.  S( ` 18. ` ` WATC asserts that its use of a translator to deliver a good quality signal to the  S( x.communities is consistent with Commission policy and Congressional intent.H {O( xԍSee, e.g., Must Carry Order, 8 FCC Rcd 2965, 2991 (1993); and Clarification Order, 8 FCC Rcd 4142, 4145 (1993). Contrary to InterMedia's  xRsuggestion, WATC states that it is not claiming that the translator is entitled to carriage on the Athens  xsystem, but WATC itself. Moreover, WATC points out that the 61 miles separating WATC and its  xtranslator distinguishes its use from other Bureau's decisions involving translators where the separation  S(distances were significantly greater. {OB%( x2ԍSee, e.g., Dynamic Cablevision,11 FCC Rcd 9880, 9889 (1997); Paragon Cable, 12 FCC Rd 21923, 21929  {O &((1997); and Rifkin/Narragansett South Florida, 11 FCC Rcd 21090, 211056 (1996).  " ,p(p(88@"Ԍ S( ` 19. ` ` WATC argues further that the communities requested for exclusion are not so far distant  xin terms of mileage. For instance, it points out that the nearest community, Bogart, is only 52 miles away  x.from Atlanta, and the nearest unincorporated county areas in Oconee County are 46 miles distant, while  x.the average distance of all of the communities is 57 miles. WATC states that the Bureau has previously  xtconcluded that stations and cable communities as far apart as 75 miles were nevertheless close enough to  S8( xbe deemed part of the station's natural market.8 {O(ԍSee Maranatha Broadcasting Company, Inc. v. Garden State Cable TV, DA 971167 (released June 5, 1997). And in cases where the Bureau found discrimination was  S( xa factor, WATC states that the distance in one case, Adelphia Cable Communications, is nearly identical  S( xat 53 miles.BZ yO (ԍ13 FCC Rcd 99, 106 (1997).B Moreover, in this case, WATC states that there is no state line, mountain range, national  xforest or other naturally occurring geographic feature separating Atlanta from the cable communities herein.  SJ ( ` 20. ` ` WATC maintains that its specialty programming provides a valuable local service to the  x8residents of the subject cable communities. It indicates that there are nearly 200 established churches in  xAthens and its environs which is a direct reflection of the priority the communities' hold for religion and  xa Christian lifestyle. As attested to by the general manager of Athens' only Christian radio station, the  S ( xLaudience for Christian content television programming is substantial in the communities.D  yO4(ԍSee opposition at Exhibit L.D WATC states  xthat its programming is directly targeted to churchgoers like those in the communities and numerous  SZ( xindividuals from the communities and beyond have appeared on WATC's locallyproduced programs.<Zz yOt(ԍOpposition at 1213.<  xIndeed, WATC indicates that its programming is uniquely sought out by North Georgians because the  xstation is recognized as a leader in locallyoriented religious programming. WATC states that  x`InterMedia's claim that programming from religious station WHSGTV, Monroe, Georgia, is the same as  xthat aired by WATC is inaccurate. WATC states that WHSGTV's Trinity Broadcasting Network  xprogramming is overwhelmingly nationallybased while WATC's is locallyproduced. WATC maintains  xthat, just like home shopping stations which were found to provide "an important service to viewers," it  xis providing a valuable local service to those members of the public who choose to worship in the privacy  S(of their homes.~   {O(ԍSee Home Shopping Station Issues, Report and Order, 8 FCC Rcd 5321, 5327 (1993).~  S( ` 21. ` ` Rather than support its request for exclusion, WATC argues that InterMedia's reliance on  xtthe local programming it receives from other stations, particularly the Atlanta stations, only reinforces the  xfact that WATC serves the communities. WATC states that it is noteworthy that InterMedia makes no  xattempt to claim that the two stations licensed to Athens, WGTV and WNGM, provide local coverage.  xWATC indicates that WGTV simply retransmits statewide and national PBS network programming, while  xWNGM airs Video JukeBox 24 hours a day. Clearly, WATC argues, InterMedia has had to look to other  xstations for its local coverage arguments. However, WATC points out that InterMedia cannot rely on the  x8programming it cites from WNEGTV, as that station is not one "eligible to be carried by a cable system" ,p(p(88&"  S( x\in such community in fulfillment of the requirements of this section. . ."L! yOh(ԍ47 U.S.C. 614(h)(1)(C)(ii)(III).L WATC states that without  xreliance on WNEGTV, WGTV and WNGM, InterMedia's local coverage argument can only be based on the Atlantaarea stations it carries.  S`( ` n22. ` ` While WATC acknowledges that its ratings are probably not significant in the communities  xzat issue, it maintains that these insignificant ratings do not illustrate that the cable communities are not  xtpart of WATC's market. It points out that the Bureau has acknowledged that a lack of significant ratings  xor established viewing patterns can often be attributed to specialized formats and how recently a station  S( xhas begun broadcasting."X {O ( xԍSee, e.g., Kansas City Cable Partners, 77 RR 2d 1403, 1407 (1995); and Time Warner Cable/Harris County,  yO (10 FCC Rcd 6663, 6667 (1995). WATC states that, as a religious station, its programming is specialized and it has been ontheair for less than three years.  SH ( ` 23. ` ` Finally, WATC asserts that the very political and economic statistics that InterMedia  x4declares divides the Atlanta and Athens areas are flatly disregarded by every Atlantabased television  xstation seeking to attract Athens viewers and their advertising dollars. Moreover, InterMedia itself carries  xlthose stations notwithstanding that Athens residents are represented by different governments and  xrepresentatives and located in a separate basic trading areas. WATC states that whatever political and  xDeconomic market distinctions exist between Atlanta and Athens are irrelevant to the communities'  xresidents. For instance, WATC indicates that construction has recently been completed on a new fourlane highway linking Atlanta and Athens and there are plans for a commuter rail line in the future.  S( ` V24. ` ` In reply, InterMedia argues that WATC mistakenly claims that the Bureau must ignore  xthe four statutory criteria established by Congress and limit its focus to the fact that InterMedia carries  xHcertain other Atlanta stations on its system. InterMedia asserts that there is no basis for such a novel  xtposition. InterMedia states that WATC has claimed that its lack of carriage is "directly attributable to the  S@( xcursory and unsound signal testing done by InterMedia personnel.">#@ yO(ԍOpposition at 2, n. 9.> InterMedia argues that the fault lies  x\in WATC locating its transmitter at a site from which it cannot deliver an adequate signal to the more  xsparsely populated areas beyond the Atlanta metropolitan area. InterMedia states that no amount of testing  xcould have detected a viewable signal by WATC and, indeed, when it requested carriage WATC conceded  xHthat its signal would be delivered by a translator. In addition, InterMedia states that WATC does not  xattempt to refute the evidence demonstrating that cable operators serving neighboring communities do not  xcarry its signal, but instead points to its carriage on systems in Gwinnet and Rockdale Counties. However,  xInterMedia states that none of the communities at issue are located in either of those counties and none  xof the systems identified by WATC are contiguous to InterMedia's system. Moreover, InterMedia  xzindicates that all of the communities identified by WATC as receiving its signal are encompassed by a  xGrade B or better signal from the station, are located substantially closer to Atlanta than to Athens, and are part of the Atlanta MSA rather than the Athens MSA.  &"X  1&"X25.1  S8( ` 825. ` ` InterMedia maintains further that WATC's suggestion that its lack of carriage is due to  x.the pendency of its construction permit is without merit. InterMedia states that even assuming the grant  xof WATC's application and the construction of increased facilities, the contour map submitted by WATC" B#,p(p(88"  xJin its opposition reveals that the station would still be unable to deliver a Grade B signal to the  S( xcommunities.@$ yO@(ԍOpposition at Exhibit A.@ While WATC makes much of the fact that a recentlyconstructed translator will deliver  xits signal to the communities, InterMedia points out that the Commission has repeatedly held that coverage  x0by a translator does not excuse the inability of the main station to provide technical service to the  S`( x8communities at issue in a market modification proceeding.%F`X {OX( xԍSee Charter Communications Entertainment I, 12 FCC Rcd 12173, 12184 n. 44 (1997)("We also disagree with  x2WCEETV's contention that we should have treated WCEETV's use of translator stations to boost its signal as the  xequivalent of a station upgrade. Television translator stations do not have carriage rights under Sec. 614, and their  {O ( xnpresence or absence is not itself a sufficient indicator of a television broadcast station's natural market.") See also  {O| ( xTMarket Modifications and the New York Area of Dominant Influence, 12 FCC Rcd 12262, 12269 (1997)("translator  xjcoverage, particularly in highly dense population areas . . . , does not lessen the relevance of the parent station's  xfailure . . . to place a Grade B contour over the subject cable communities as Grade B coverage is one indication of the station's natural market"). InterMedia states that the plain language of  x8Section 614 of the Act does not bestow must carry rights on any translators, even those located within a  xcertain preset distance. Moreover, InterMedia argues that WATC's translator is not "fulfilling [its]  xptraditional role of filling in gaps in the station['s] service areas. Instead, [it is] extending the station['s]  xcoverage to areas well beyond the reach of the [its] Grade B contour[] and, as such, cannot rely on the  S(translator to demonstrate service to the communities."&f  {O(ԍMarket Modifications and the New York Area of Dominant Influence, 12 FCC Rcd at 12269.  SH ( ` V26. ` ` With regard to geographic distance, InterMedia states that WATC's attempt to obscure  xtthe average 100 kilometer distance of its main transmitter to the communities by calculating the distances  x8to the westernmost borders of Oconee and Clarke Counties does not negate the fact that the Bureau has  xfound distances of 63, 72, 77 and 89 kilometers to be more than ample to demonstrate the absence of a  S ( xmarket nexus between stations and cable communities.8'  yO@(ԍSee footnote 12.8 Further, InterMedia argues that WATC's  xopposition only confirms the fact that the station does not air any programming that can be considered  xlocal with respect to the instant communities. InterMedia contends that, despite the general interest  x0Christian programming may have for viewers in the communities and despite the residence in the  xVcommunities of a small fraction of the guests on programs aired by WATC, the programming by WATC  xis not specifically tailored to the needs and interests of Athens area viewers. InterMedia points out that  xWATC does not dispute the fact that the Athens cable system receives ample local programming from  xother stations nor that it has no significant ratings in the counties in which the communities are located.  xrIn addition, InterMedia asserts that WATC's attempts to downplay the economic, political and demographic market classifications of Atlanta and Athens do nothing to change this conclusion.  S( ` R27. ` ` Finally, InterMedia contends that WATC's assertion that the Athens cable system's  xcarriage of other Atlanta stations provides sufficient justification for the Bureau to disregard the market  xmodification criteria is misplaced. InterMedia states that Congress' decision to provide a market  xmodification mechanism belies any suggestion that all television stations licensed to a community have  SP( xidentical must carry rights throughout an ADI.z(P  {Ox'(ԍSee Time Warner Entertainment, DA 99615 (released April 1, 1999) at 11.z In addition, InterMedia points out that the"P (,p(p(88"  xHCommunications Act directs the Commission to consider explicitly four criteria when evaluating such  xpetitions. Also, InterMedia states that the Bureau has never held that carriage of other stations from a  xparticular ADI requires the carriage of all other stations licensed to the same ADI, but instead has rejected  S( xthat argument.)& {O( xԍSee, e.g., Guy Gannett Communications, Inc., 13 FCC Rcd 23470 (1998); Budd Broadcasting, 13 FCC Rcd at  {O( x15464; Broad Street Television, L.P., 10 FCC Rcd 5576 (1995). See also Market Modification and the New York  {O( xArea of Dominant Influence, 12 FCC Rcd 12262, 122268 (1997)(rejecting broadcasters' suggestions that "they are essentially guaranteed the right to carriage throughout the ADI"). Moreover, InterMedia argues that the cases cited by WATC are distinguishable from the  xinstant situation because in each case the Bureau concluded that the operators' petitions failed to satisfy  xthe statutory criteria. Lastly, InterMedia maintains that WATC's claims of discrimination are devoid of  xmerit and common sense. InterMedia contends that discrimination can only occur where a cable operator  xtreats similarlysituated television stations differently. In the case, InterMedia states that the 7 Atlanta  xstations it carries all place a Grade B signal over some or all of the communities and they broadcast programming which is directed to Athens area viewers.  SH ( IV. MUST CARRY COMPLAINT  S ( ` n28. ` ` In support of its complaint, WATC states that, by letter dated January 19, 1999, it advised  xInterMedia that it had commenced providing television service to Athens, Georgia via Translator W42AO  S ( x*and requested carriage on InterMedia's cable system serving Athens and surrounding communities.?*  yO(ԍComplaint at Exhibit A.?  x$WATC states that on March 4, 1999, InterMedia refused carriage based on the claim that WATC failed  SX( xto deliver an adequate signal to the cable system headend.?+XF yO>(ԍComplaint at Exhibit B.? WATC indicates that InterMedia reported that  xit performed signal tests on February 1 and 22, 1999, but it argues that neither was conducted in  S( xaccordance with accepted engineering standards.", {O~( xPԍSee Implementation of the Cable Television Consumer Protection and Competition Act of 1992, Broadcast  {OH(Signal Carriage Issues, Order on Reconsideration ("Reconsideration Order"), 9 FCC Rcd 6723, 67356736 (1993)." Further, WATC states that InterMedia failed to provide  xthe information and documentation required when carriage requests are denied based on inadequate signal  S( x*strength.B-2  yO(ԍ47 C.F.R. 76.61(a)(2).B WATC points out that the February 1 test, besides failing to meet acceptable engineering  xstandards, also was conducted by InterMedia at an antenna height of only 25 feet. WATC states that the  xBureau has specifically required that, in their signal quality tests, cable operators use the same antenna  S@( xzand receiving equipment at the same height as that currently used to receive other broadcast signals..@  {O!( xPԍSee Implementation of the Cable Television Consumer Protection and Competition Act of 1992, Broadcast  {Ol"(Signal Carriage Issues ("Clarification Order"), 8 FCC Rcd 4142, 4144 (1993).  xFurther, WATC states that although InterMedia's February 22nd test failed to detect WATC's signal on  xRChannel 42, this was due to the fact that a lightning strike caused the translator to be offtheair from  xFebruary 2027, a fact which would have been made known to InterMedia if it had contacted the station.  xWATC concludes that InterMedia's flawed tests fail to prove that WATC is not entitled to carriage and requests the Commission to order InterMedia to commence carriage of its signal. "P .,p(p(88$"Ԍ S( ` L29. ` ` InterMedia's opposition to the complaint references its pending modification petition to  xexclude WATC for must carry purposes and requests that action on the instant complaint be deferred until  xsuch time as a decision is issued regarding the modification request. Also, InterMedia reserves the right  xto contest the quality of the signal WATC delivers to the Athens headend due to the translator's erratic  xperformance. InterMedia indicates that a test it conducted in coordination with WATC on May 12, 1999, showed an adequate signal strength, but also revealed some signal quality inadequacies.  S( ` `30. ` ` In reply, WATC argues that any signal tests conducted by InterMedia prior to the May  x12th test have no decisional significance as they were either conducted without meeting specific  xLengineering criteria or during periods when the translator was not operational. WATC maintains that the  xMay 12th test, which was conducted in accordance with engineering criteria and at a height of 300 feet,  xBis undisputed by InterMedia in proving that WATC delivers a signal of adequate strength to the system's  xheadend. However, WATC takes objection to InterMedia's claims that there are flaws in WATC's picture  xHquality (i.e., audio levels and color phase shift) and argues that picture quality is not a basis by which  S ( xInterMedia can deny carriage.3/  yO8(ԍReply at 4.3 For instance, WATC points out that InterMedia's technician  x.acknowledged that the color phase shift was probably attributable to the television set being used for the  xtest and adjustments by WATC's engineer appeared to resolve any reported audio level distortions.  SX( xFinally, WATC argues that since InterMedia has already acknowledged that WATC's signal strength is sufficient, it has no basis for reserving a right to change its mind on this issue later.  S( V. DISCUSSION  S(A. Modification  S@( ` 31. ` ` Based on our analysis of the evidence relating to the four statutory and other relevant  xfactors, we deny InterMedia's petition to delete the subject communities from WATC's television market.  xAlthough WATC itself has not been carried by InterMedia in the past, InterMedia has and continues to  xVcarry numerous stations licensed to the same city, Atlanta, as WATC. In setting out the historic carriage  xfactor, Congress clearly held that historic carriage would exist if other stations in the same area are  xcarried. In this instance, InterMedia carries seven other stations that broadcast from the same general  x$location as WATC. Carriage of these other stations located in the same area is persuasive evidence that  S(( xthe market served by all these stations is essentially the same.i0(X {O (ԍSee Paxson San Jose License, Inc., 12 FCC Rcd 17520 (1997).i Evidence of historic carriage is especially  xpersuasive where the station seeking to be deleted captures low audience ratings throughout an ADI as  xis the case in this instance. We note that because of its specialized format and the relatively short time  xontheair, WATC has not had a full opportunity to build a presence in its market place. We note also  xthat a review of the offair audience data for in the area in question does not suggest that the communities in question are associated with any other market area.  S ( ` 32. ` ` With respect to the second statutory factor, we note that WATC's Grade B contour does  xnot encompass the communities at issue. Ordinarily, we might have concluded because of this that the  xcommunities were too distant to be considered part of WATC's television market. In the instant case,  xhowever, we have taken special notice of and given significant weight to InterMedia's carriage of 7 out  xrof the other 10 television stations which are licensed to the same city as WATC. We find that"p# 0,p(p(88 !"  xBInterMedia's carriage of these 7 television stations, in general, undermines its claim that the communities  xare not part of the same economic market for broadcast television purposes. With regard to geographic  xtdistance, we find that the average distance of 100 kilometers (or 62.1 miles) serves to attenuate WATC's  xconnection to the cable communities and we find that the significance of geographic distance can be  x\mitigated by other factors such as the carriage of similarlysituated television stations. With regard to  xprogramming, WATC has not demonstrated that its programming is focused on the interests of the  xresidents of the communities at issue and we find that WATC's programming is currently insufficient to  xestablish a specific programming nexus to the relevant communities. With regard to local programming  xfrom other stations, we find in this instance that the majority of the local stations InterMedia cites are from  xthe same area as WATC. Thus, if anything, InterMedia's carriage of these other local stations provides  xsupport for the proposition that the areas in question are part of WATC's market rather than evidence that  xRlocal service is provided by stations from other communities. Insofar as the fourth statutory factor is  xconcerned, although WATC has no measurable viewing in the specified cable communities, we are not  xconvinced that negligible ratings provide reason enough to grant the market modification request,  xparticularly in view of its specialized format and short time onair. In view of the above, we deny  xVInterMedia's request to delete the designated communities in Oconee and Clarke Counties, Georgia from the market of WATC for mandatory carriage purposes.  S0( B. Must Carry  S( ` < 33. ` ` According to Section 76.55(e) of the Commission's rules, commercial television broadcast  S( x$stations, such as WATC, are entitled to carriage on cable systems located in the same ADI.?1 yO (ԍ47 C.F.R. 76.55(e).? WATC is  xlocated in the Atlanta, Georgia ADI, which is also where the cable system served by InterMedia is located.  x4While InterMedia initially denied carriage based on its contention that WATC did not provide a good  xzquality signal to its system's principal headend, it subsequently agreed, after a joint signal strength test  xRconducted with WATC, that the station provided an adequate signal. With regard to the reservations  x expressed by InterMedia as to WATC's picture quality, we do not find that InterMedia has provided  xsufficient information to justify denial of WATC's on this ground. In any event, WATC in its reply  x appears to have adequately resolved this issue. In view of the above, we find that grant of WATC's request to be in the public interest.  SP( &"X "P X1,p(p(88"  S(2&"X!34. 2 VI. ORDERING CLAUSES  S( ` F!34. ` ` Accordingly, IT IS ORDERED , pursuant to Section 614(h) of the Communications Act  xof 1934, as amended (47 U.S.C. 534(h)), and Section 76.59 of the Commission's rules (47 C.F.R.  x76.59), that the petition for special relief (CSR5387A) filed on behalf of Brenmor Cable Partners, L.P.  S8(d/b/a InterMedia Partners IS DENIED.  S(  S( ` "35. ` ` IT IS FURTHER ORDERED that the must carry complaint filed by Community  S( x2Television, Inc. (CSR5393M) IS GRANTED pursuant to Section 614(d)(3) of the Communications Act  S( xof 1934, as amended (47 U.S.C. 534). InterMedia IS ORDERED to commence carriage of WATC on  Sp( xits Athens, Georgia cable system sixty (60) days from the released date of this Order. WATC shall notify  xInterMedia in writing of its carriage and channel position elections (76.56, 76.57, and 76.64(f) of the Commission's rules) within thirty (30) days of the release date.  S ( ` <#36. ` ` This action is taken pursuant to authority delegated by Section 0.321 of the Commission's  S (rules.<2  yO(ԍ47 C.F.R. 0.321.<  ` `  ,hhhFEDERAL COMMUNICATIONS COMMISSION ` `  ,hhhWilliam H. Johnson, Deputy Chief ` ` ,hhhCable Services Bureau