Bayview MA

[Scott Fybush]

On 9/10/2013 8:02 PM, Jeff Lehmann wrote:
> Are you sure about that?
>
> Bayview is not independent at all. I'd certainly never heard of it
> before WPMW came along.
>
> Middleborough Center, the COL of 1530 WVBF and 88.5 WRRS is not
> separate from Middleborough.
>
> Mount Washington is another example of this, of course.

The FCC's standards for establishing a useable community of license are 
a little odd.

As Dave noted earlier, there are no COL standards for unprotected 
secondary service (class D, LPFM, translator), which is why you get 
something like "Cell Site MT" or "Beacon Hill and East Cambridge MA." It 
really is just a way to fill in a space on the paperwork, nothing more.

For full-power protected service, as a baseline, you have to have a 
community with defined borders over which you can show a sufficient 
level of service.

For new commercial allocations, or for moves of existing stations, the 
FCC wants to see a showing that the proposed community meets a 
sufficient number of the indicia it looks for. If it's an incorporated 
community recognized by the census, that's generally enough. If not, as 
in the case of Bayview, the FCC would look for more: a "Tuck analysis" 
demonstrating some combination of local government services, businesses 
using the community's name, a zip code, a local telephone directory, a 
local newspaper, and so on. Because municipal configurations vary so 
widely in different parts of the country, this may be the only rational 
way to do it.

"Middleborough Center" may not be incorporated, but it's a much closer 
entity to what we'd call a "village" in New York or a "borough" in 
Pennsylvania or a "town" in most of the Midwest, while "Middleborough," 
although incorporated, is more akin to a "township" here or in most of 
the midwest. The FCC prefers to look at something like a "village" or 
"town" as a COL rather than a "township," though some noncommercial 
stations in the midwest are licensed to "Something Township." In some 
cases out west, the FCC has even accepted Air Force bases as having 
sufficient indicia to qualify as COLs.

"Mount Washington," while it has a post office, is simply grandfathered 
from the early days of FM - don't forget that the earliest FM up there 
was nominally licensed to Boston! There are some grandfathered examples 
near me, where early Rural Radio Network FMs remain licensed to places 
like "Wethersfield Township" and "South Bristol Township." Those are 
actually incorporated towns in New York parlance, and they wouldn't 
generally qualify today as commercial COLs.

(There are other factors, too, that have come into play more recently 
that limit stations' ability to move to urban communities of license 
from outlying areas.)

You wouldn't be able to show that Bayview (or Tatnuck, or "Baptist 
Village," a noncomm COL near Springfield) would qualify as a COL for a 
commercial station. Had someone seriously challenged the applications, 
Bayview and Baptist Village might not even have qualified for full-power 
noncomm use. But nobody did, and so the stations exist.

(There is actually a filing as part of one of WPMW's applications 
showing 70 dBu coverage of all of "Bayview," and I haven't a clue where 
they even got those boundaries from.)