Before the

**Federal Communications Commission**

**Washington, D.C. 20554**

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MEMORANDUM OPINION AND ORDER

**Adopted:** February 15, 2001 **Released:** February 28, 2001

By the Commission: Commissioner Furchtgott-Roth issuing a statement

Table of Contents

Heading Paragraph \#

I. INTRODUCTION 1

II\. BACKGROUND and history 2

III\. New Selection process 4

IV\. Requests for Reconsideration and Clarification 9

A. Objections to Overall Process 10

1\. Rejection of Lotteries 11

2\. Constitutional Concerns 15

B. Time for Calculating Points/Enhancement of Proposals 22

1\. Timing for Future Applications 23

2\. Timing and Enhancement for Pending Mutually Exclusive Applications
27

a\. Closed Groups 28

b\. Pending Applications Subject to Future Competition 33

C. Fair Distribution of Service as a Threshold Issue (Radio Only) 35

D. Point System Factors 45

1\. Established Local Applicants 45

2\. Technical Parameters 53

3\. Diversity of Ownership 55

4\. State-wide Networks 59

a\. Curriculum 60

b\. Number of Schools Served within Contours of Overlapping Stations 64

c\. Small Institutions/Aggregation of Stations Licensed to Different
Entities 68

E. Point Factors Not Selected/New Point Proposals 71

1\. Local Program Origination and Other Localism Points 72

2\. Radio Reading Services 75

F. Tie Breakers 76

G. Attribution of Full Service and Translator Stations 80

H. Application Processing Issues 86

1\. General Procedures 86

2\. Procedural Issues For Future Window Applications 91

3\. Terminated Hearing Proceedings 94

I. Settlements 96

V. PROCEDURAL MATTERS AND ORDERING CLAUSES 100

# INTRODUCTION

1.  On April 4, 2000 we adopted a new simplified system to select among
    applicants competing to construct noncommercial educational ("NCE")
    broadcast stations, thereby eliminating the lengthy traditional
    hearings which we had used for 30 years. The new approach uses a
    point system to select among mutually exclusive proposals to build
    FM, TV, and FM translator stations on channels reserved for NCE use.
    The system for awarding points is based on such factors as
    diversity, localism, signal coverage, and service to schools, with a
    permit awarded to the applicant with the highest score. When NCE
    entities compete on channels also available for commercial use, we
    concluded that adoption of auction procedures was statutorily
    mandated. We now consider seventeen Petitions for Reconsideration or
    Clarification, ranging from requests for minor clarifications to
    advocacy of vastly different policy results. Upon considering these
    views, we basically affirm our initial decision but clarify various
    details, provide additional information, and amend several rule
    sections.

# BACKGROUND and history

2.  Due to the finite nature of and strong demand for broadcast
    spectrum, we often cannot authorize an NCE station to every
    qualified entity that wants to build one in a particular area.
    Rather, we frequently must choose among multiple applicants. From
    the earliest days of broadcasting, the Commission conducted
    traditional evidentiary hearings to make these selection decisions.
    The factors we considered in hearings depended upon which of two
    types of channels the applicants wanted to use. For "reserved"
    channels, which are for noncommercial educational use only, we
    considered \"the extent to which each of the proposed operations
    will be integrated into the overall educational operations and
    objectives of the respective applicants.\" [See]{.underline} *New
    York University*, 10 RR 2d 215, 217-18 (1967). For "non-reserved"
    channels, which are for all types of broadcasting, commercial and
    noncommercial, we used several comparative criteria. For example, we
    considered diversity of ownership and the "integration" of ownership
    and management, which presumed that a station would offer better
    service if its owners were involved in the station's day-to-day
    management. [See]{.underline} *Policy Statement on Comparative
    Broadcast Hearings*, 1 FCC 2d 393 (1965). In comparative contests
    between NCE and commercial applicants on non‑reserved channels, the
    applicants were evaluated using the commercial criteria.

3.  As discussed in greater detail earlier in this proceeding, several
    events in the 1990's led to our eventual change of the comparative
    selection process both for NCE and commercial stations, and for both
    reserved and non-reserved channels. These events included the
    conclusion of the Commission's Review Board that the NCE criteria
    had, over time, become \"meaningless\" in distinguishing between
    applicants, and a federal court's finding that the core integration
    criterion used to evaluate non-reserved channel applications was
    "arbitrary and capricious, and therefore unlawful." *FCC v.
    Bechtel*, 10 F.3d 875, 878 (D.C. Cir. 1993) (*Bechtel*); *Real Life
    Educational Foundation of Baton Rouge, Inc*., 6 FCC Rcd 2577, 2580,
    n.8 (Rev. Bd. 1991). As a result of Commission proceedings
    soliciting public comment, and Congress' decision on related matters
    in the Balanced Budget Act of 1997,[^1] we implemented a system of
    competitive bidding for awarding permits on non-reserved
    channels[^2] and adopted new point-based comparative standards for
    reserved channel noncommercial educational proceedings.[^3] The NCE
    rules under review in this proceeding became effective on August 7,
    2000.

# New Selection process

4.  Our [NCE Order]{.underline}[^4] established that the nature of the
    channel, not the nature of the applicant, should govern selection
    procedures. We decided that we were required by statute to use
    auctions to select among all mutually exclusive applicants for
    non-reserved channels, because such channels can be used for
    commercial purposes. We designed a point system, described in
    greater detail below, to select among applicants on reserved
    channels. We determined that this bifurcated, channel-specific
    selection method is consistent with the Balanced Budget Act's dual
    directives to recover for the public the value of commercially
    available channels, but to use a different selection method for
    stations that cannot be used commercially. All requests for agency
    reconsideration or clarification focus on our point system decision
    for reserved noncommercial channels; none address our decision to
    apply auction procedures when NCE entities are among the applicants
    competing for non-reserved channels.[^5] Accordingly, in this order
    we revisit reserved channel procedures only.

5.  The [NCE Order]{.underline} requires reserved channel applicants to
    apply during specific filing windows to be announced by public
    notice. The staff will examine all applications received within the
    window, to determine whether any two or more of those proposals are
    mutually exclusive, *i.e.* to determine whether the proposed
    stations would cause prohibited interference to each other and thus
    cannot all be authorized. If a particular application is not
    mutually exclusive, and the applicant is subsequently found
    qualified, the staff will grant that application. For mutually
    exclusive applications received during the filing window, the staff
    will compare the proposals, considering which would best serve the
    public interest under our new point system.

6.  When competing FM applications propose to serve different
    communities, a proposal would be considered best, as a threshold
    matter, if it would provide service to significant unserved or
    underserved populations.[^6] This threshold factor is considered
    pursuant to 47 U.S.C. § 307(b), which charges the Commission with
    ensuring fair distribution of broadcast service. This process does
    not apply to television proceedings because fair distribution issues
    are addressed prior to application by the allotment of TV channels
    to particular communities in TV allotment proceedings.

7.  Most mutually exclusive FM applications for reserved channels
    (*i.e*., those not resolved on 307(b) grounds) and all such TV
    applications will be compared under a point system, in which we
    assign points to aspects of each proposal and select the applicant
    with the highest score. We would award points as follows: (a) 2
    points for diversity of ownership, *i.e.* if there is no overlap of
    the principal community contour of the proposed station and any
    other station attributable to the applicant; (b) 1 to 2 points for
    the best technical proposal in terms of both area and population
    served; (c) 3 points for applicants that have been local to the
    community for at least two years; and (d) 2 points for certain
    state-wide networks providing programming to accredited schools. In
    the event of a tie, we would apply several tie breakers, first
    preferring the applicant with the fewest existing authorizations;
    and second, the applicant with the fewest pending applications. If
    applicants remain tied after all of these factors are considered, we
    would require tied full service applicants to share time equally.
    Among tied FM translator applicants, we would select the first
    applicant to file. We would apply these procedures both to pending
    applications and to applications received in the future.

8.  After completion of this process, we would conduct a study of the
    tentative selectee's application to determine whether it meets all
    of our standards for acceptability. At that time we would also
    consider petitions to deny against the tentative selectee only. If
    the tentative selectee is found qualified in all respects, we would
    award a permit to that applicant. Applicants prevailing in the point
    system would be subject to a four-year holding period, permitting
    the station's license to be assigned or transferred during that
    period only to an entity qualifying for equal or greater points, and
    for consideration that does not exceed the assignor's expenses of
    filing and prosecuting its application and constructing its
    station's authorized facilities.

# Requests for Reconsideration and Clarification

9.  Existing and potential applicants ask us to reconsider or clarify
    various aspects of our filing and selection processes. A few
    petitioners question our fundamental choices, for example,
    advocating the use of lotteries instead of a point system. Most,
    however, endorse our adoption of a point system, and ask only that
    we change or clarify a particular portion of our decision. Some have
    concerns relating only to pending applications or to future
    applications, while others raise issues potentially affecting all
    applications. We consider each of these concerns.

## Objections to Overall Process

10. Two petitioners object to the point system in its entirety.
    Broadcasting for the Challenged, Inc., a licensee providing
    programming for disadvantaged individuals, believes that a lottery
    would have been far preferable. Broadcasting for the Challenged
    argues that we did not sufficiently justify our decision not to use
    lotteries. Educational Media Foundation, which operates a nationwide
    network of 23 FM stations programmed from a religious perspective,
    does not advocate a particular alternative but considers our point
    system discriminatory. It argues that the point system favors some
    speakers over others, to the detriment of religious broadcasters.

### Rejection of Lotteries

11. The Commission has authority to use random selection (lottery)
    procedures to choose among NCE applicants. 47 U.S.C. § 309(i). If we
    use such procedures, the statute requires us to weight the lotteries
    to provide substantial preferences to racial minorities and
    applicants with few other stations. *Id.* We considered using such
    lotteries, but found that a point system was preferable for several
    reasons. [NCE Order]{.underline}, ¶ ¶ 11 -- 15. We identified the
    primary benefits of lotteries as speed and simplicity. Against these
    benefits, we weighed three major disadvantages of lotteries: (1)
    greater potential for speculation; (2) no assurance of selecting the
    most qualified applicant; and (3) the likely delay from litigation
    over the required lottery preferences. We determined that lotteries
    would achieve only part of our goal to improve the NCE selection
    process, and thus rejected lotteries in favor of a point system.

12. Broadcasting for the Challenged ("BFTC") maintains that the
    Commission has not adequately justified rejection of lotteries, and
    should have supported each concern with empirical evidence, as it
    believes is required under *Bechtel*. BFTC disputes each of the
    three drawbacks that we included in our analysis. It disagrees with
    commenters concerned that lotteries would produce speculation,
    arguing that there is little potential for financial gain in NCE
    broadcasting, and that the Commission eliminated this potential by
    establishing a holding period. With respect to applicant
    qualifications, it argues that it is impossible to verify whether
    one qualified applicant will actually be better than another, and
    thus that we should consider all applicants as being equal if they
    meet our basic qualifications. Finally, BFTC does not believe that
    there is any legal impediment to our use of a weighted lottery, as
    required by statute, because we previously used such a lottery to
    select Low Power Television (LPTV) applicants.

13. We are not persuaded to reverse our policy judgment that a point
    system is preferable to a lottery for the award of NCE permits.
    First, BFTC's reading of the requirements of *Bechtel* is overbroad.
    *Bechtel* holds simply that any predictive judgments used to select
    among broadcast applicants must have factual support. *Bechtel* does
    not, as BFTC argues, prevent the Commission from considering
    concerns presented in comments and applying its expertise to choose
    a selection method that it determines would best serve the public
    interest. Here, where both lotteries and point systems (a simplified
    form of comparative hearing) are presented to the Commission as
    options by statute, the Commission need not present empirical data
    to support the viability of either choice. Rather, we must select
    one of these options, offering a reasonable explanation that is
    supported by the record.[^7] Then, the value of any predictive
    factors included within the option selected must be explained and
    supported, as we did in adopting point factors. Further, BFTC's
    suggestion that we erred in considering the potential for lotteries
    to spur speculation is based on its belief that NCE stations are
    immune to speculation either because such stations have limited
    monetary value or because they are subject to a holding period.
    Speculation, however, is not a concept limited to the quick "turn
    over" of stations for an inflated monetary value, something that our
    holding period addresses. NCE spectrum is a finite resource, with
    intrinsic value as an outlet for different educational viewpoints.
    Lotteries, due to their random nature, encourage mass filings of
    applications to increase the statistical "odds" that the applicant
    will obtain [any]{.underline} station, [anywhere]{.underline}. That
    too is speculation. Moreover, such practices are harmful to
    competing applicants because the random selection of an applicant
    that could have met its goals anywhere will preclude the selection
    of an applicant that can fulfill its mission in only one location,
    such as where its campus or school system is located.

14. We cannot agree with BFTC's suggestion that an applicant's basic
    qualifications are all that matter in an educational broadcasting
    context. The Commission has in NCE broadcasting always sought to
    select the best applicant, not just any qualified applicant. BFTC
    provides no reason for us to depart from that policy. Finally, we
    explained that a decision to use weighted lotteries would likely
    prompt lengthy litigation, thereby causing significant delays in
    initiation of new NCE broadcast service. [^8] It is reasonable for
    us to consider the potential for lengthy litigation in making policy
    choices.[^9] Our previous use of weighted lotteries in the LPTV
    service provides no comfort or certainty because those lotteries
    were held prior to the Supreme Court's decision in *Adarand v.
    Pena,* 515 U.S. 200 (1995), when there was a lesser likelihood of a
    challenge to weighted lotteries.

### Constitutional Concerns

15. Educational Media Foundation ("EMF") argues that our point system
    violates the First and Fifth Amendments to the U.S. Constitution,
    which limit government intrusion on free speech and on the free
    exercise of religion, and provide for equal protection under the
    law.[^10] EMF acknowledges that the Commission expressed content
    neutral and speaker neutral reasons for adopting the point system.
    Nevertheless, EMF argues that the government's professed content and
    speaker neutrality does not necessarily make a rule constitutional,
    if the rule's effect is to discriminate against certain speakers or
    content. [Petition of EMF]{.underline} at 21 *citing* *Turner
    Broadcasting System, Inc. v. FCC*, 512 U.S. 622, 641-643, 645
    (1994). While recognizing that no party has an absolute right to
    receive an NCE license, but rather has, at most, a right to compete
    for a license, EMF argues that comparison must be fair and
    nondiscriminatory. EMF argues that our point system is unfair. It
    charges that the Commission engaged in results-oriented rulemaking
    with the explicit intention of discriminating against private
    speakers airing religious content and in favor of government
    speakers airing secular content. Thus, it argues that under "strict
    scrutiny," we must demonstrate that our point system is narrowly
    tailored to serve a compelling government interest.[^11] EMF bases
    its arguments almost entirely on its conclusion that it and six
    other religiously oriented NCE broadcasters would not be selected in
    a point system if competing against government entities. It
    maintains that because religious broadcasters generally run national
    networks, do not provide programming to schools, and have many other
    existing stations and applications, such broadcasters could not
    likely qualify for points based on localism or state-wide networks,
    and would not fare well in tie breakers.[^12]

16. The Center for Media Education ("Media Education") disputes EMF's
    constitutional arguments. It argues that there is no constitutional
    right to a broadcast license and that EMF's reading of *Turner* as
    requiring strict scrutiny is incorrect. Media Education cites to
    language in *Turner* which states "such heightened scrutiny is
    unwarranted when the differential treatment is 'justified by some
    special characteristics' of the medium being regulated." [Media
    Education Opposition]{.underline} at 4 *citing Turner
    Broadcasting v. FCC,* 512 U.S. 622, 660-61 (1994). It further states
    that the Supreme Court traditionally considers broadcast cases under
    a more relaxed review, due to the special attributes of
    broadcasting. *Id.* at 5 *citing Reno v. ACLU,* 521 U.S. 844, 868
    (1997). In any event, it maintains that because our point system
    does not require or prohibit the carriage of a particular point of
    view, it is content neutral, and would be subject to lesser
    scrutiny. *Id. citing* *Time Warner Entertainment v. U.S.,* 211 F.3d
    1313 (D.C. Cir. 2000). Media Education believes that the implication
    that the Commission has an "anti-religion agenda" is baseless, as
    evidenced by the Commission's grant of large numbers of licenses to
    religious broadcasters.[^13]

17. We do not believe that there is any constitutional infirmity in our
    point system. Each factor within the point system is speaker and
    subject matter neutral. If, as EMF claims, it will be disadvantaged
    by the rules, it is not because the rules favor secular applicants
    over religiously affiliated applicants. Rather it is because EMF is
    a national organization that is already the licensee of many NCE
    stations, while the Commission sought in the rules to encourage
    localism and diversity of ownership. A secular national organization
    licensed to operate many NCE stations would have the same
    disadvantage under the point system. EMF's religious focus has no
    bearing on the operation of the rules. In the [NCE
    Order]{.underline} we explained:

> We have considered, but disagree with, the minority viewpoint that a
> credit for localism would adversely impact religious organizations or
> small organizations. A localism credit is religion-neutral and
> size-neutral. Whether religious or secular, large or small, an
> organization based in the local community would qualify for the
> credit. Moreover, organizations both with and without religious
> affiliation, and of varying sizes support a credit for localism.

[NCE Order]{.underline} ¶52.

18. Because the point system does not reflect a government preference
    for the content or viewpoint of a particular speaker, strict
    scrutiny does not apply. [See]{.underline} *Turner Broadcasting v.
    FCC*, 512 U.S. 622, 656-59 (1994); *Time Warner Entertainment v.
    U.S.,* 211 F.3d 1313 (D.C. Cir. 2000) (*Time Warner*). A content
    neutral regulation passes intermediate scrutiny if it advances
    important governmental interests, unrelated to the suppression of
    free speech, and does not burden substantially more speech than
    necessary to further those interests. *Time Warner,* 211 F.3d
    at 1318. A more deferential standard of review has been applied to
    broadcast regulation. [See, e.g.]{.underline}, *FCC v. Pacifica
    Foundation*, 438 U.S. 726, 748 (1978). Our point system advances
    important government interests in local broadcasting and
    education.[^14] Further, the point system is not a new burden on any
    particular speaker, but rather a system that incorporates several
    longstanding policy goals into one cohesive method for selecting
    among mutually exclusive applicants. For example, the importance of
    localism in noncommercial educational broadcasting is longstanding
    and reflected in the statute. [NCE Order]{.underline} ¶¶44-51.
    Similarly, the Commission's decision to award a permit in the event
    of a tie to the applicant with the fewest existing authorizations,
    is consistent with our longstanding focus on diversity of ownership
    of broadcasting stations. Our decision to award points to applicants
    that are part of state-wide networks is consistent with our
    longstanding policy of considering an NCE applicant's participation
    in state-wide education plans.[^15]

19. As EMF acknowledges, there is no constitutional right to a broadcast
    license. [See]{.underline} *Red Lion Broadcasting Co. v. FCC*, 395
    U.S. 367, 388-89 (1969). Given the nature of spectrum licensing**,**
    our grant of one mutually exclusive broadcast application under any
    selection method will inevitably mean our denial of another
    application. Whether our selection decision is made pursuant to a
    point system or some other method, it is well established that
    denial of an application for a broadcasting license "if valid under
    the \[Communications\] Act, is not a denial of free speech."
    *National Broadcasting Co. v. United States*, 319 U.S. 190, 227
    (1943).

20. EMF claims that the Commission had some unstated goal to
    disadvantage religious broadcasters. That is simply not so. Indeed,
    the record indicates that the Commission was responsive to the
    concerns of NCE organizations with religious affiliations as well as
    those without such affiliations. For example, we expanded the
    definition of state-wide network, which was originally expressed in
    terms of participation in government educational plans, to also
    include private networks offering significant service to schools.
    [NCE Order]{.underline} at ¶ 59. We indicated that religious
    organizations that operate schools, such as the Catholic Archdiocese
    or religious universities, might qualify for state-wide network
    points. *Id.* at ¶¶ 57-59. Given that our decision concerned award
    of permits to provide noncommercial [educational]{.underline}
    broadcast service, we believe that it was eminently reasonable to
    encourage, though not require, service to schools.

21. Accordingly, we reject the constitutional challenges to our use of a
    point system. Having found that our choice of a point system over
    other options is sound overall, we now will examine various aspects
    of our decision to determine whether modifications or clarifications
    of that system would be useful.

## Time for Calculating Points/Enhancement of Proposals

22. Generally, the [NCE Order]{.underline} provided that we would award
    points for the relative merits of an applicant's proposal as of the
    time of filing, provided that the applicant maintains the qualities
    for which points are awarded.[^16] Several petitioners, including
    Colorado Christian University and Jimmy Swaggart Ministries
    anticipate timing concerns not specifically addressed in our
    decision or rules and request clarification. Of particular concern
    is how the Commission will view changes that occur after the time of
    application, such as an applicant's attempt to enhance its proposal
    or changes in census data that occur naturally over time. This issue
    is relevant to all NCE proceedings, but is especially of concern to
    organizations with pending applications.[^17] In order to address
    apparent uncertainties regarding both current and future applicants,
    we here clarify with more specificity the process for counting
    points in future proceedings and the similar, but somewhat modified,
    process that will govern pending applications.

### Timing for Future Applications

23. In the [NCE]{.underline} Order we established the "time of filing"
    as the time for determining points. We did not provide an in-depth
    discussion of that choice, however, and we now elaborate in order to
    clarify our decision. We selected the time of filing so that there
    would be no need for the staff and applicants to constantly
    recalculate points and to minimize one-upsmanship. Applicants may
    not continuously amend their proposals and qualifications in
    attempts to surpass other mutually exclusive applicants, but rather
    must present initially, their proposal to provide the best possible
    service to the public regardless of whether or what any competing
    applicants may file. An applicant's characteristics at the time of
    filing establish a "snap shot" that we will generally use to
    determine the applicant's maximum points and its maximum position in
    a tie breaker. However, points can be lost through changes that
    detract from the original proposal.

24. Our rules require applicants to inform us of material changes in
    their applications after the time of filing, which, in the context
    of a point system, will include all changes that negatively affect
    its claimed points and tie breaker position. 47 C.F.R. § 1.65. A
    future applicant's maximum points and its standing in a tie breaker
    can thus go down, but not up as a result of changes made after
    filing. For example, if an applicant loses its transmitter site and
    amends its application in a way that results in lost points, the
    applicant will only be allowed to claim the amended points. In this
    way, the applicant will not benefit from any early proposals that it
    is unable to honor. However, if the applicant amends and attempts to
    enhance points, the applicant will only be allowed to claim its
    earlier lesser points. In this manner, applicants with superior
    initial proposals will not be disadvantaged by any competing
    applicant's later attempts at enhancement. This will also encourage
    applicants to come forward with the best possible proposal and
    minimize the potential for any manipulation of the system. In
    addition, we believe that a proposal crafted without knowledge of
    competing proposals is a more reliable indicator of future service
    than one crafted with an eye to outdoing a competing applicant.

25. Similarly, for tie breakers, the applicant's best position is
    established at the time of application, but can be reduced. For
    example, in our primary tie breaker, which selects the applicant
    with the fewest number of broadcast authorizations at the time of
    filing, an applicant cannot enhance its position by selling one of
    its existing stations, but can diminish its position by acquiring an
    additional station. Thus, an applicant with no existing stations at
    the time of application will benefit from its "zero" stations in tie
    breakers only until such time as it receives a first authorization.
    It will be required, pursuant to 47 C.F.R. § 1.65, to update its
    pending applications and so will not be able to continue claiming
    zero authorizations, when it has, in fact, already had applications
    granted in several proceedings, perhaps now surpassing a tied
    competing applicant in terms of stations authorized.[^18]

26. When future applicants report population and other stations serving
    an area, as they might for fair distribution purposes under 47
    U.S.C. § 307(b),[^19] they should use the data that is the most
    current at the close of any filing window. It is inevitable that
    there will be shifts in population and in number of services
    authorized in a region between close of a window and the time we act
    on an application. However, such inevitable changes will not reduce
    a future applicant's standing, and thus we will not require such
    applicants to notify us if these expected changes occur after the
    close of the window. Of overall concern to us in this area is that
    we are comparing applications that use the same data. Reliance on
    information as of the close of the window will ensure that
    applicants have essentially a common reference date. With a common
    reference date and a common method of calculating population[^20],
    the staff will analyze applicants on a similar basis.

### Timing and Enhancement for Pending Mutually Exclusive Applications

27. Applicants with pending applications filed prior to adoption of the
    point system must supplement their application to provide us with
    additional information needed to consider their applications under
    the new comparative standards. As we will be unable to consider any
    pending application that does not contain the new information, we
    will assume that any applicant that fails to file a supplement is no
    longer interested and dismiss its application.[^21] We now clarify
    the procedures for filing these supplements, which will depend upon
    whether the applicant is in a group that is considered "closed" or
    "open" in terms of whether it is subject to future competition from
    additional parties.

#### Closed Groups

28. Due to a processing freeze that has been in place while we establish
    and review the NCE comparative criteria,[^22] there are some groups
    of mutually exclusive applications which have been pending for a
    considerable time, and which are no longer subject to additional
    competing applications. These groups are referred to as "closed"
    groups. As stated in the [NCE Order]{.underline}, existing
    applicants in these "closed" groups will need to file supplements to
    claim points so that we can compare them under the new system. We
    delegated to the Mass Media Bureau responsibility to announce the
    procedures for filing these supplements. We did not specify whether
    longstanding applicants might enhance their proposals and claim
    points for changes made in response to the [NCE Order]{.underline}.
    Colorado Christian University asks us to "freeze" an existing
    applicant's points at a particular point in time, to avoid the
    potential for pending applicants to become "moving targets." Jimmy
    Swaggart Ministries suggests that we examine an existing applicant's
    points as of the date of application to avoid uncertainties
    associated with applications that have been pending for a
    considerable time. For example, it argues that, for purposes of our
    fair distribution analysis, which considers whether applicants will
    provide a first or second NCE radio signal to an underserved area,
    pending applicants that proposed first or second service at the time
    of application should benefit, even if the Commission since has
    authorized additional stations.

29. Educational Media Foundation notes that, for some pending closed
    mutually exclusive groups, we have not issued B cutoff notices.[^23]
    EMF further notes that under the A/B cutoff procedures that existed
    prior to adoption of the point system, applicants could amend as a
    matter of right until issuance of a "B" cutoff notice, and the
    Commission considered these amended proposals, rather than the
    original proposals, in comparative hearings. [See]{.underline} 47
    C.F.R. § 73.3522(b). Based on this line of reasoning, EMF believes
    that we should permit all types of enhancing amendments to existing
    applications, including technical amendments. The National
    Federation of Community Broadcasters argues that, with respect to
    changes in technical proposals, applicants should only be able to
    enhance their points by making changes considered "minor" under our
    rules.

30. We have attached as Appendix D a list of closed mutually exclusive
    groups, *i.e.* groups in which we issued an "A" cut-off list under
    the old rules and for which the time for filing responsive,
    competing applications has closed. Most of the point principles
    enunciated above for future applications will govern our treatment
    of applications in these pending "closed" groups. However, we will
    make several adjustments to account for the fact that these older
    applications did not contain point information as filed, and that
    applicants must now file supplements to claim points. To the extent
    possible, we will use a recent date for purposes of taking a "snap
    shot" of applicant qualifications. As a result, we will be able to
    consider recent information rather than information that may be
    several years old. A recent "snap shot" date will also give
    pre-point system applicants an opportunity to incorporate into their
    proposals point factors that we adopted and clarified after their
    original filing date, and which we have since indicated are
    desirable and in the public interest. Specifically, the date that
    pending applicants must use for reporting population/service data
    for 307(b) determinations and for most point data is the "supplement
    date," a date after release of the current decision that the staff
    will announce by public notice, and by which pending applicants must
    file supplements to claim points. By the supplement date, applicants
    in closed groups must file either settlement agreements, as
    discussed *infra* at paras 96-99, or supplements. Those filing
    neither will be dismissed. We will use the supplement date to
    examine all data, except for the applicant's technical proposal, for
    which we will use the earlier date discussed further below. So as
    not to unduly delay this proceeding, the staff should set a due date
    for supplements that is approximately 30 days after the public
    notice. The staff will evaluate any non-technical changes to an
    applicant's proposal pursuant to the criteria established in the
    point system. For example, if an applicant unconditionally withdraws
    previously filed applications or consummates approved assignments of
    authorized stations to other entities prior to the supplement date,
    those stations would not count against the applicant for purposes of
    a tie breaker, regardless of how many applications or authorizations
    they may have held at the time of original application. [^24] An
    applicant that changed its board composition or established a local
    campus in response to our point system, however, would not be able
    to claim points as an established local applicant because our point
    system recognizes such local indicia only if they have been
    maintained for at least two years.

31. With respect to the applicant's technical proposal, we will
    calculate points based on an earlier date. We are compelled to reach
    this result because the staff has already fully studied all
    applications in closed groups based on earlier claimed coverage to
    determine which applications are mutually exclusive. Technical
    changes now would cause undue delay, requiring reexamination of new
    technical proposals for potential conflict with over a thousand
    applications on file, not just with respect to other applications
    within each closed group.[^25] For closed groups in which both "A"
    and "B" cut-off notices have issued, we will calculate technical
    points as of the date of the "B" notice, which announced
    applications in the mutually exclusive group and cut off the
    opportunity to file amendments as of right under the rules then in
    effect. Thus, these applicants will have the same amendment as of
    right period that they would have received under our previous rules.
    For closed groups in which no "B" cut off notice has issued, we will
    examine technical proposals as of April 21, 2000, the release date
    of the [NCE Order]{.underline}. We ceased issuing "A" and "B" lists
    as of that date. Applicants in this category will thus also have had
    some time to make technical amendments as of right, albeit less than
    they might have received had the Commission not eliminated its use
    of cut-off lists. After the relevant date, applicants may not amend
    their proposals except for good cause pursuant to 47 C.F.R §
    73.3522(b), such as an applicant's involuntary loss of its
    transmitter site. With respect to good cause amendments, applicants
    will not receive additional points, and may lose points for any such
    amendments that decrease the applicant's proposal. A technical
    amendment that removes a mutual exclusivity, thereby permitting our
    grant of an application, would be considered a good cause amendment.

32. We do not agree with Jimmy Swaggart Ministries that we should use
    data that dates back many years in analyzing fair distribution
    issues for applicants in closed groups. Traditionally, in examining
    fair distribution pursuant to Section 307(b) of the Communications
    Act, proposals are analyzed as of the date that 307(b) information
    is requested. For many NCE applicants, we have not yet requested any
    307(b) information. It would not be appropriate or practical to ask
    such applicants to now submit such information as of a date long
    passed, because this would require applicants to undertake a
    [more]{.underline} difficult process in order to provide the
    Commission with [less]{.underline} accurate information. For some
    other NCE applicants, we may have requested 307(b) information in
    hearings that were conducted under old standards and that were not
    dispositive. In the [NCE Order]{.underline} we established new
    standards for conducting Section 307(b) analyses, and any
    information submitted under the old standards would be inadequate or
    incomplete under the new standards. Thus, even applicants that
    previously submitted 307(b) information will need to submit
    different 307(b) information as of the "supplement date."
    Accordingly, the supplement date will serve as the "snap shot" date
    for 307(b) information. Applicants supplementing their applications
    with population data should use the 2000 census, if available by the
    supplement date.

#### Pending Applications Subject to Future Competition

33. West Coast Public Radio ("West Coast") seeks special consideration
    for a specific type of pending application, *i.e.,* those that are
    still subject to competing applications because they were neither
    filed in response to an "A" notice nor themselves placed on an "A"
    notice. We stated in the [NCE Order]{.underline} that, because the
    opportunity to file competing applications has not yet run, we will
    consider these pending applications in the first filing window,
    along with any additional applications filed during that window.
    This result creates a timing issue with respect to when to calculate
    the points of the pending applications and the future applications
    with which they will be competing.

34. West Coast is particularly concerned that future applicants filing
    in the first window may attempt to tailor mutually exclusive
    proposals to claim more points than existing applicants who must
    also compete within that window. West Coast bases this belief on the
    assumption that existing applicants will claim points as of their
    original date of application, whereas the future applicants with
    whom they will compete will be able to claim points as of a date
    within the window. It suggests that we award additional points to
    the existing applicants so that they will be able to compete
    effectively with future applicants. We decline to do so. We clarify,
    however, that such existing applicants may be able to claim more
    points than those for which they qualified at the time of their
    original application. They have two options available to them.
    First, they may choose to amend their pending applications during
    the first filing window to enhance their proposals and provide
    comparative information. Alternatively, they may withdraw their
    pending applications prior to the first filing window and file new
    proposals in the first filing window. In either case, existing
    applicants that are subject to competition will have the same
    opportunity as new applicants to submit their best proposals during
    the first filing window.

## Fair Distribution of Service as a Threshold Issue (Radio Only)

35. Several parties ask for clarification of our fair distribution
    process. We decided in the [NCE Order]{.underline} that, if mutually
    exclusive NCE radio applicants specify different communities, we
    would first consider, pursuant to Section 307(b) of the
    Communications Act, whether grant of one proposal over the other is
    warranted based on fair distribution of service principles. An
    applicant would receive a decisive preference, as a threshold
    matter, if it would provide a first or second NCE aural service to
    10% of the people within the proposed station's 60dBu contour, but
    to no fewer than 2,000 people. If more than one applicant meets this
    standard, we would award a preference only if one proposal provides
    first or second service to 5,000 more people than the other. This
    standard is similar in some respects to the 307(b) standard
    previously applied in traditional NCE hearings, but borrows some
    factors used in the 307(b) analysis of commercial applications.[^26]
    To maintain the benefits of fair distribution, we stated that
    applicants selected based on NCE fair distribution standards would
    not be permitted to downgrade service to the area on which the
    credit was based. Because applicants chosen through fair
    distribution would not be subject to a point system, however, they
    would not be subject to four year holding period provisions, which
    require applicants to maintain factors for which they received
    points and limit the terms on which the applicant may transfer the
    station to another party.

36. Jimmy Swaggart Ministries argues that the fair distribution analysis
    should be expanded to all mutually exclusive applications, not just
    those proposing to serve different communities. In contrast, Station
    Resource Group ("SRG"), an association representing NCE licensees,
    argues that 307(b) considerations should be given lesser importance,
    examined as part of a point system, and not as a threshold issue.
    SRG argues that Section 307(b) of the Communications Act does not
    compel us to consider fair distribution as a threshold issue, and
    maintains that in traditional comparative hearings this factor was
    given less weight.

37. The scope of our fair distribution analysis was an issue fully
    considered in the [NCE Order]{.underline}. By the express terms of
    47 C.F.R. § 73.7002(a), adopted therein, the 307(b) analysis is
    conducted only if applicants propose to serve different communities.
    Differences in coverage among proposals to serve the same community
    are adequately considered within the point system, which includes a
    consideration of technical parameters. Differences in area and
    population served within the same community are considered by
    awarding points for technical parameters. *See also* paras 75-76
    *infra*. Our decision is entirely consistent with our responsibility
    under Section 307(b), as long interpreted by the courts and the
    Commission. The statute is explicit that the Commission must
    distribute broadcast licenses "among the several States and the
    communities so as to provide a fair, efficient, and equitable
    distribution of radio service to each of the same," but does not
    mandate a particular procedure that the Commission must follow.
    [See]{.underline} *Competitive Bidding*, 13 FCC Rcd 15920, 15963
    (1998). While Swaggart urges us to expand the 307(b) threshold to
    encompass all applications with different reception areas as well as
    different communities of license, nothing in the language of the
    statute, with its explicit reference to "communities" supports such
    an extension. Nor does Swaggart cite any Commission-level precedent
    in which any applicant received a preference for such matters. The
    Commission's use of a threshold 307(b) determination in NCE cases
    was thus fully consistent with the statute, as interpreted by the
    Commission and the courts. *FCC v. Allentown Broadcasting Corp.*,
    349 U.S. 358 (1955); *Pasadena Broadcasting Co. v. FCC,* 555 F.2d
    1046 (D.C. Cir. 1977); *Competitive Bidding*, 13 FCC Rcd 15920,
    15963 (1998).

38. With respect to the question of whether to consider fair
    distribution individually or to integrate it into a point system, we
    concluded that we should give this factor decisive weight prior to
    any point system. [NCE Order]{.underline} at ¶ 24. There is no merit
    to SRG's suggestion that our approach is inconsistent with agency
    precedent. It relies on *New York University*, 10 RR 2d 215 (1967),
    the first NCE comparative case. SRG alleges that the modified
    hearing designation order in that case afforded the Administrative
    Law Judge discretion to give whatever weight he deemed appropriate
    to the 307(b) issue and that the judge did not give that issue
    dispositive "threshold" weight. However, the Review Board's
    subsequent opinion in that case makes clear that 307(b) issues can
    be dispositive, as long as the differences are not slight, as they
    were in that proceeding. *New York University*, 19 FCC 2d 358,
    370-71 (Rev. Bd. 1969). By means of the formula prescribed in 47
    C.F.R. § 73.7002(b), we have ensured that only significant 307(b)
    differences are decisional, just as the Review Board envisioned in
    *New York University*. When two applicants have only small
    differences under 307(b), we proceed to consider them pursuant to a
    point system. Differences among applicants for the same community
    are considered under the point system's technical factor, if
    significant in terms of both area and population.

39. We do, however, note that our discussion of 307(b) in the [NCE
    Order]{.underline} did not contemplate the possibility that two
    applicants offering similar levels of new NCE service pursuant to
    307(b), and therefore proceeding to consideration under a point
    system, could be part of a larger mutually exclusive group with
    applicants proposing to provide service not deserving a 307(b)
    preference or deserving a lesser 307(b) preference. We clarify that
    under such circumstances, only the applicants that are entitled to
    equal Section 307(b) preferences will proceed to consideration under
    a point system.[^27] The other applications, which are entitled
    either to lesser or no preferences under Section 307(b), will not be
    considered along with those applicants in a point system, consistent
    with our determination that fair distribution of service should be
    given decisive weight.

40. Colorado Christian University asks whether the new fair distribution
    standard developed for NCE stations will be based only on first or
    second service [received]{.underline} or also, as in commercial
    allocations proceedings, on first transmission service [licensed
    to]{.underline} a community. It is concerned about potential abuses
    that may occur if first licensed transmission service is applied in
    an NCE context. Station Resource Group also shares this concern. It
    believes that an applicant proposing to provide a first or second
    NCE reception service is providing a more important service than an
    applicant merely licensed to a community. In particular, SRG
    observes that under the rules applicable at the time of its
    comments, reserved channel NCE-FM stations had no obligation to
    place a city grade contour over their nominal communities of
    license, and could designate any community within the 60dBu contour
    as the community of license.

41. The fair distribution standard that we adopted was based only on
    provision of the first or second NCE reception service for a
    significant population. Applicants would receive no preference by
    proposing the first station to be licensed to a city or town, when
    that community already receives two or more NCE signals. First aural
    service licensed to a community is considered in commercial
    broadcasting, which has longstanding community coverage
    requirements, but has not played any significant role in NCE
    broadcasting which until recently had no community coverage
    requirements and now has requirements that are significantly less
    stringent than those applicable to commercial broadcasters.[^28] We
    do not believe that consideration of first service licensed to a
    community would serve the same purpose in NCE broadcasting as it
    does in commercial broadcasting. Further, as commenters stated
    earlier in this proceeding, our crediting only service received
    reduces the potential for abuse. Otherwise, NCE applicants might
    identify small communities that they would not fully serve,
    receiving a decisive preference over applicants with nearly
    identical service areas but that propose to be licensed to larger
    communities. [NCE Order]{.underline} at ¶ 22. Accordingly, our NCE
    fair distribution analysis is based on new service received, not on
    first transmission service licensed to a particular community.

42. Next we consider the views of Munn-Reese Engineering Consultants and
    the University of Northern Ohio, which ask us to clarify whether,
    for purposes of our 307(b) analysis, stations operating
    noncommercially in the non-reserved portion of the FM band or in the
    AM band will count as NCE aural signals received. If so, they ask
    what factors we would use to determine whether such a station
    provides NCE service. Munn-Reese notes, for example, that although
    stations can operate noncommercially in the non-reserved portion of
    the band, some are licensed as commercial stations subject to filing
    fees, while others are licensed as noncommercial stations and are
    exempt from filing fees.

43. In determining whether a significant population receives NCE aural
    service, *i.e.,* whether it is unserved or underserved by existing
    NCE stations, we will count as first and second signals only
    [reserved channel]{.underline} NCE-FM stations. Historically, the
    Commission has only considered stations operating on reserved
    channels to determine the level of NCE service already received, and
    we see no reason to change that practice in this context.
    [See]{.underline} *New York University*, 10 RR 2d 215 (1967). As we
    noted in the [NCE Order]{.underline}, stations operating on
    non-reserved channels voluntarily choose to provide NCE service, but
    can readily become commercial stations by filing a simple form with
    us. In contrast, noncommercial service on reserved channels is
    mandatory and permanent. Due to this potential for rapid change in
    the nature of non-reserved channel stations, we do not believe that
    the NCE service provided by these stations is sufficiently fixed to
    be counted in our analysis. Thus, in an NCE fair distribution
    analysis, we would grant an application proposing to provide the
    first reserved channel FM service a preference, without regard to
    whether nearby AM and non-reserved channel FM stations currently
    operate with noncommercial educational formats.

44. Colorado Christian University raises additional fair distribution
    concerns, asking us to apply all aspects of our four-year holding
    period to applicants receiving their permits as a result of a fair
    distribution preference. Colorado Christian acknowledges that we
    already prevent technical downgrades to the area on which we granted
    a fair distribution preference, but believes that other holding
    period restrictions should apply as well. It argues that there is
    the need to prevent speculation by all successful applicants, not
    only those awarded by a point system. It further maintains that
    because an applicant receiving a 307(b) preference has a decisive
    advantage over other applicants, it is especially important to hold
    such applicants to every part of their proposals. We disagree with
    this reasoning. To uphold the integrity of the point system and
    prevent speculation, we require each point system selectee to
    operate the station for four years either itself or by assigning the
    station to another party with equivalent point credentials for
    consideration not to exceed reasonable expenses. If an applicant is
    selected on the basis of fair distribution criteria, its point
    claims are not relevant and are never examined. Thus, a requirement
    that any successor in interest have "equal points" would not be
    especially meaningful and not necessary to preserve the integrity of
    our process. We believe that it would be overly restrictive to
    require applicants to maintain attributes for which they claimed
    points if those attributes are not decisional. What matters in the
    fair distribution context is that any successor in interest
    continues to provide service to the area for which the original
    applicant received its fair distribution preference, as our current
    rules already require. The particular weight given to 307(b)
    considerations does not in itself justify placing additional
    non-307(b) obligations on the applicant.

## Point System Factors

### Established Local Applicants

45. Our point system awards the largest percentage of points to
    established local applicants. Initially, we expressed concern that
    awarding credits in a point system for an applicant's local
    characteristics might be difficult to support under the standards
    enunciated in the *Bechtel* case. As discussed previously, that case
    invalidated the use of the "integration" credit, which awarded a
    significant comparative advantage to commercial broadcast applicants
    proposing to work at their proposed stations as owner-managers. The
    court found that there was no empirical evidence supporting the use
    of this criterion. We reexamined our concern, however, in response
    to strong commenter support for localism points, including some that
    provided statistical and historical evidence of the important role
    that localism plays in educational broadcasting. Ultimately, we
    found the comments sufficiently convincing that we chose localism as
    the single most important factor in our NCE point system. Under the
    point system, an applicant that has been local for at least the two
    years immediately preceding application, *i.e.*, that has
    continuously maintained its headquarters, campus, or the primary
    residences of 75% of its board members within 25 miles of the
    central coordinates of its community of license, receives three
    points out of a possible seven. We stated that governments would be
    considered local within their areas of jurisdiction.

46. Broadcasting for the Challenged (BFTC) argues that the Commission's
    decision is contrary to *Bechtel*. According to BFTC, our decision
    was not supported by empirical evidence that an applicant that is
    local before filing an application is superior to an applicant that
    becomes local after its application is granted. In response to the
    Commission's reliance on the 1967 Carnegie Report as historical
    evidence, BFTC argues that the Report's use of the term "local
    stations" did not mean only those built by local groups.[^29] It
    maintains that a national group can build a local station and become
    very involved in the community. Similarly, Educational Media
    Foundation maintains that that there is no nexus between where a
    station's board members live or where its headquarters is located
    and the type of programming it will carry. It notes, for example,
    that the Commission has not set any required amount of time that a
    local licensee must devote to locally produced programming or local
    issues. EMF argues that the Commission should not favor local
    broadcasters based on a belief that national NCE broadcasters can
    apply elsewhere, because national NCE broadcasters will likely be
    competing against a local broadcaster in every market.

47. We affirm our decision in the [NCE Order]{.underline} regarding
    localism for the reasons discussed therein. In brief, a localism
    credit is fully consistent with the *Bechtel* court's concerns.
    Commenters provided convincing empirical evidence of public benefits
    resulting from localism in NCE broadcasting.[^30] They also
    demonstrated that localism is a factor that has historically been
    considered the lynchpin of excellent NCE service because local NCE
    licensees are knowledgeable of the community's educational needs,
    responsive, and accountable to the community.[^31] In response to
    EMF's concern, we clarify that being knowledgeable and responsive
    does not necessarily require that a local NCE licensee must air
    programs produced by local citizens, especially if, in the informed
    judgment of the licensee, other programs are better suited to
    meeting the station's educational goals. Local organizations are,
    however, more likely to be aware of locally produced programs that
    are available and thus to consider such programs. We do not imply
    that a non-local organization that receives a broadcast
    authorization and begins operating within a community may not, with
    time, acquire the knowledge of the community to be responsive to its
    educational needs and to become such a part of the community as to
    have local accountability. But an organization that has already been
    local for two years or more, as required for the credit, has those
    qualities prior to its very first broadcast and can thus "hit the
    ground running." We also continue to believe that it is efficient to
    meet the spectrum needs of NCE applicants in the local areas
    surrounding their headquarters and campuses because distant
    locations may be unsuitable for their needs. In observing that some
    non-local applicants with broad goals will be able to apply
    elsewhere if they do not prevail in a particular community, we
    indicate merely the additional opportunities available to such
    applicants. We do not, as EMF indicates, assume that it will always
    be easy for such applicants to prevail elsewhere. Finally, we stand
    by our decision to award 3 out of a possible 7 points to established
    local applicants. This weighting reflects the importance of localism
    in NCE broadcasting. Further, as we noted in the [NCE
    Order]{.underline}, this proportion is similar to one used in the
    Instructional Television Fixed Service, another educational
    communications service in which localism is strongly encouraged.

48. Having affirmed our three-point credit for established local
    applicants, we next consider the proposal of several petitioners
    that we broaden the class of applicants that would be considered
    local. West Coast Public Radio and Station Resource Group both ask
    us to expand the measure by which an applicant's headquarters,
    campus, and board members are considered local, replacing our
    25-mile standard with a 100-mile benchmark. According to West Coast,
    the 25-mile standard is used as a basis for main studio
    location[^32] but only because of concerns about studio
    accessibility, and does not necessarily reflect what the community
    considers local. It states that TV and Class C FM stations may cover
    as much as 50 miles. The National Federation of Community
    Broadcasters ("NFCB") similarly proposes a standard of localism
    based on each station's coverage area, noting that rural stations
    may serve larger areas than urban stations.

49. West Coast and SRG both also ask us to incorporate into 47 C.F.R. §
    73.7000 the concept that government applicants are local within
    their jurisdiction. Real Life Educational Foundation proposes that
    an organization should be considered local if a majority (instead of
    75%) of its board consists of local residents, because control rests
    with a majority of the board. It further asks us to clarify whether
    a new organization would qualify for points if board members who
    have been local for two years form it. Real Life maintains that we
    should give credit to long time residents regardless of the length
    of time that their organization has been in existence, arguing that
    to do otherwise is arbitrarily giving credit only for "brick and
    mortar." Real Life also asks us to clarify how we will apply our
    localism criteria to organizations that have had applications
    pending for substantial periods.

50. We affirm but clarify the standards for localism announced in the
    [NCE Order]{.underline}. Applicants with a headquarters, campus, or
    75% of board member residences within 25 miles of the reference
    coordinates of the community of license will be considered local.
    Governmental units will be considered local as well within their
    areas of jurisdiction. In the [NCE Order]{.underline}, we
    specifically rejected as too broad a proposal to use 100 miles
    rather than 25 miles as our localism standard. We continue to view
    25 miles as a reasonable distance applicable to all full service NCE
    broadcast stations for the reasons discussed therein. We decline to
    individualize the definition of "local" to vary with a particular
    station's technical capabilities, finding it preferable to apply
    uniform mileage standard. In this manner, an applicant needing to
    replace a resigning member of its local governing board will be able
    to make that decision based on easily understood mileage standards,
    without having to determine how the technical capabilities of the
    proposed station affects the localism of the new board member. The
    only instance in which the [NCE Order]{.underline} individualized
    localism standards concerned governmental entities, in recognition
    of their broad accountability throughout their areas of
    jurisdiction. Due to recognizable extrinsic factors, such as where a
    person pays taxes and what school district he lives in, the
    government entity can readily identify whether board members live
    within the area of jurisdiction. As several petitioners note,
    however, our stated policy that governments are considered local
    throughout their jurisdiction was not incorporated into any rule. We
    agree that it would be useful to codify this policy into a rule, and
    hereby modify Section 73.7000 of our rules accordingly.

51. We disagree that it is too stringent to require an applicant without
    a local headquarters or campus to have 75% of its governing board
    members comprised of local residents to qualify for localism points.
    The Commission has discretion to exercise judgment in setting
    thresholds and drawing appropriate lines. [Attribution of Broadcast
    and Cable/MDS Interests]{.underline}, MM Docket No. 94-150, 14 FCC
    Rcd 12,559, 12,590 (1999). We acknowledge that a percentage as low
    as 51% could constitute a voting majority and therefore exercise
    legal control of an organization. That is why we permit NCE
    television applicants that are not governments or schools to
    establish their basic eligibility by demonstrating that a simple
    majority of their board is composed of representative community
    elements.[^33] Our point system, however, must distinguish between
    minimally qualified applicants and exceptionally qualified
    applicants. Reducing our comparative standard to a 51 % local board
    would, in the case of television applicants, result in the award of
    points to all minimally qualified applicants, making the localism
    credit meaningless in television proceedings. Further, we believe
    that it is reasonable to require a high level of local Board
    membership - a super-majority rather than a bare majority - to
    qualify the applicant for a preference as an established local
    applicant. In our judgment, an NCE applicant Board comprised of 75%
    established local residents is likely to be familiar with local
    needs and interests, and also have extensive ties to the community
    that will facilitate continuing interaction with the community.
    Equally important, that level of local Board membership is likely to
    assure a sufficient level of influence and control over policies and
    direction of the licensee such that the local Board members\'
    familiarity with local needs and interests and continuing
    interaction with their community will be reflected in the station\'s
    policies and programming. With a 75% local Board, local members are
    likely to control station decisions even if one local board member
    is absent or abstains from a particular decision. Finally, we note
    that it is far easier for an applicant to establish local
    credentials by appointing local residents to its board than by
    maintaining a physical presence by means of a school or
    headquarters. Thus, there is a greater potential for abuse of the
    point system among applicants that establish their credentials by
    appointing local board members. Requiring 75% local board members,
    rather than a mere majority, reduces the potential for abuse of our
    process. Thus, we decline to reduce the level of local Board
    membership required to qualify for points as an established local
    applicant where the applicant has no local school campus or
    headquarters and is not a local government authority.

52. With respect to new organizations formed by local citizens, an
    organization in existence for less than two years prior to our "snap
    shot" date may be "local" but cannot be considered "established."
    Thus, it would not receive points as an "established local
    applicant." Comments received earlier in this proceeding indicated a
    concern that if the Commission did not set a minimum period of time
    for which an organization itself must be local, non-local
    organizations would likely engage in abuse by "renting" local
    citizens for their boards, or by setting up new local corporations
    with "straw-men" local incorporators. It would be too difficult
    without a lengthy hearing process for the Commission to distinguish
    between such abusive "local" applications, and legitimate local
    applications. Thus, in adopting the requirement that organizations
    be "established" in the [NCE Order]{.underline}, we stated that this
    requirement would serve to limit the feigning of local
    qualifications, to establish the applicant's educational credentials
    in a particular locality, and to foster participation by truly local
    entities in noncommercial educational broadcasting. Accordingly, we
    affirm our decision to grant localism points only to organizations
    that have been established in the community for at least two years
    prior to application, similar to the standard adopted for Low Power
    FM applications.[^34] Regarding applications currently on file, the
    applicant must have qualified as a local applicant continuously for
    two years prior to the supplement date to be considered for points
    as an established local applicant. It cannot claim such a credit now
    by virtue of adding local citizens to its board, regardless of the
    length of time those citizens have lived in the community.

### Technical Parameters

53. We adopted a credit for the applicant with the best technical
    proposal. Specifically, we determined that the applicant proposing
    to cover the largest area [and]{.underline} population of all those
    in a mutually exclusive group would get 1 point if its proposed area
    and population is 10% greater than the next best proposal or 2
    points if 25% greater than the next best proposal. Connecticut
    College Broadcasting Association asks if and how this standard will
    be applied to applications seeking modifications of existing
    facilities. In particular, it asks whether, among two applications
    for major modification, we would compare only the newly proposed
    coverage of the stations or their total coverage areas (existing
    coverage as well as proposed).

54. We clarify that factors in the point system are applicable to
    applications for major modifications of existing stations as well as
    to applications for new stations. When we examine a station's
    technical parameters, we will focus on the applicant's proposal. For
    modification applications, the proposal is the area of newly added
    service only. For new stations the proposal is the entire area to be
    served by the new station. We recognize that, as so viewed, a
    proposal for new service is much more likely to receive points for
    its technical parameters than a competing proposal to modify
    existing facilities. This result is consistent with our desire to
    provide additional service to as many people, living in as broad an
    area, as possible. Specifically, our grant of an application to
    construct a new station will bring a new signal to the entire area
    and population within the new station's service area, whereas our
    grant of a major modification brings new service to only a portion
    of the population within the modified station's service area.

### Diversity of Ownership

55. Our point system awards two points for local diversity, *i.e.*, if
    the proposed station's principal community (city grade) contour[^35]
    does not overlap such contours of any other station in which the
    applicant, its parent, subsidiaries, or members of their governing
    boards, have any attributable interests. We stated that this point
    factor would enable the listening public to receive the viewpoints
    of different NCE broadcasters. We recognized that the governing
    boards of NCE entities change frequently, and that differences in
    attributable broadcast interests of incoming and outgoing board
    members create an uncertainty about whether an organization that
    qualifies for the credit today will be able to maintain diversity
    into the future. Accordingly, we stated that we would award credit
    for diversity only to applicants whose own governing documents
    require that diversity of ownership is maintained.

56. Two petitioners ask us to clarify the governing document
    requirement. First, Jimmy Swaggart Ministries asks us to clarify
    whether pending applicants can amend their governing documents now,
    and thus be considered for diversity points even if their governing
    documents did not contain such provisions at the time of
    application. As established above, for pending applicants, we will
    calculate the applicant's maximum points as of a "supplement date"
    to be announced by public notice. A pending applicant can claim
    points for diversity if, as of that supplement date, it has no
    stations with overlapping principal community contours, and it has
    included in its governing documents a provision to maintain that
    diversity in the future.

57. Next, we consider a question from the University of Kansas
    ("Kansas"), which asks us to clarify how an organization without
    traditional governing documents will be able to meet the governing
    document requirement. This question is relevant both to pending and
    future applicants. Unlike NCE corporations, governed by a
    constitution and bylaws that members or a board can readily amend,
    Kansas is organized by a state charter passed in 1863, and its
    operation is, in part, governed by state statute. Kansas maintains
    that any change would require an act of the state legislature. It
    requests an exemption from the governing document safeguard, and
    offers instead to certify that it will not apply for any facilities
    that create contour overlap with other facilities for which it has
    applied or has been authorized. It would agree that any failure to
    meet this requirement would result in dismissal of its future
    applications. It further argues that the governing documents
    provision is overbroad, because it could prevent applicants from
    applying for stations in proceedings where it is not seeking any
    diversity credit.

58. The governing document safeguard aims to maintain governing board
    characteristics for which the applicant received credit, even if the
    composition of that board and its attributable broadcast interests
    change due to resignation and replacement of board members. We do
    not believe that the requirement is overbroad. Applicants may word
    the language as they deem best for their organization. For example,
    they may specify that this future safeguard provision will become
    effective only if the applicant claims a credit for diversity and
    receives an authorization as a result of that claim. Kansas'
    proposal to certify that it will not apply for additional stations
    does not fully address the purpose of the governing document
    requirement, because Kansas does not address the potential that
    future members of its governing board may hold or acquire
    attributable interests in broadcast stations licensed to others. We
    do, however, recognize that it might be very difficult for
    state-chartered organizations, like the University of Kansas, to
    obtain legislative amendments to their charter. While we will not
    exempt such organizations from providing a safeguard, we will
    consider alternative safeguards from such organizations if they
    reasonably assure that board characteristics will be maintained
    during the four-year holding period. For example, the University of
    Kansas states that it is governed by a Board of Regents appointed by
    the governor. We would consider a certification from University
    making a commitment to maintain the Board characteristics on which
    it bases its diversity claim, accompanied by a description of
    procedures it has in place to effectively notify appointing
    officials and board members, both current and future, of their need
    to act consistently with the University's diversity representations
    to the Commission. While it would be preferable and simpler to have
    the commitment in the organization's charter, if possible, we
    believe that in circumstances such as those that Kansas describes we
    can rely on appointing officials, who know of the organization's
    representations to the Commission, to make appointments consistent
    with those representations. We specifically limit the availability
    of this option to entities whose governing documents cannot be
    amended without legislative action.

### State-wide Networks

59. The Commission has long recognized the value of state-wide networks
    of NCE stations operating pursuant to state-wide educational plans.
    State-wide networks have been pioneers in NCE broadcasting,
    particularly in television, ensuring that educational programming is
    available throughout an area in a coordinated and organized manner,
    especially to schools. We adopted a two-point credit in the [NCE
    Order]{.underline} for state-wide networks serving large numbers of
    accredited schools, and repealed a rule that required more general
    consideration of applicant participation in state-wide plans.
    [See]{.underline} [NCE Order]{.underline} at ¶ 61 *citing* 47 C.F.R.
    § 73.502. We recognized that, due to the locations of the multiple
    school campuses or school districts they serve, state-wide networks
    may be unable to avoid overlapping signals, and thus may not be able
    to qualify for diversity of ownership points. By awarding an equal
    two-point credit for state-wide networks whose service to schools
    disqualifies them for diversity of ownership points, we intended to
    level the playing field. Thus, applicants providing service to many
    schools, that cannot do so without some signal contour overlap and
    resulting loss of the diversity credit, would not be placed at a
    disadvantage in comparison to applicants serving a smaller number of
    schools or serving general listeners in locations that, unlike
    schools, are not site-specific. The credit is available to public
    and private state-wide networks, as defined in 47 C.F.R. §
    73.7003(b)(3). That rule generally requires that the applicant's
    stations will provide programming to 50 accredited full time
    elementary/secondary schools, or five accredited full time college
    campuses in a single state, in furtherance of the school curriculum.
    Several petitioners urge us to either eliminate or modify our credit
    for state-wide networks. They object primarily to our inclusion of
    school curriculum in the definition of state-wide network and to the
    large number of schools that applicants must serve to qualify for
    the credit.

#### Curriculum

60. Educational Media Foundation (EMF) and Station Resource Group (SRG)
    seek elimination of the state-wide network credit. EMF believes that
    the credit amounts to a value judgment that instructional
    programming is better than general educational programming. It
    believes that the Commission is trying to limit the programming that
    an NCE station can broadcast, contrary to a recent decision in which
    the Commission withdrew advice on the types of programming that are
    educational. Station Resource Group opposes the credit on different
    grounds, arguing that virtually no radio broadcaster would qualify
    for the credit as currently defined, and that it would be preferable
    to substitute different, more readily available, credits. Colorado
    Christian University and West Coast Public Radio would retain the
    credit for state-wide networks, but would delete the requirement
    that programming be used in furtherance of a school curriculum.
    According to Colorado Christian University, 65% to 75% of its adult
    students enroll at the college after listening to non-curriculum
    programs on the radio. Several commenters argue that the credit is
    of more value to television applicants than to radio applicants
    because radio stations are not as readily used as an instructional
    medium as television stations.

61. As indicated, we adopted points for state-wide networks to recognize
    a compelling educational reason that some NCE applicants may not be
    able to achieve the desirable goal of local diversity, and to avoid
    disadvantaging those applicants under our point system. When service
    to large numbers of schools is the reason for an educator's
    inability to qualify for the "diversity" credit, our point system
    values service to schools equally with diversity of ownership. We
    disagree with EMF's view that favoring school-based education on
    educational broadcast channels favors government speakers over
    private and religious speakers. A wide range of speakers, public and
    private, religious and secular, operate schools. A wide range of
    broadcast programming can further the curriculum of such schools.
    Perhaps, as some parties note, some applicants that operate schools
    will not qualify for this credit, because they target their
    broadcast service at the broader public, do not use their stations
    in connection with their school curriculum, or operate only one
    school. Perhaps, as others contend, television applicants will be
    more likely to qualify than radio applicants will. None of these
    factors would diminish our commitment to this credit. We did not
    expect this to be a widely available credit, but rather a tailored
    credit meant specifically to counterbalance the disadvantage
    otherwise suffered by applicants that lose diversity points because
    they regularly provide curriculum service to large numbers of
    schools. If fewer radio licensees will qualify for the state-wide
    network credit, that is only because fewer such entities will suffer
    the disadvantage under our point system for which this credit is
    intended to compensate. State-wide networks have played a more
    prominent role in television than in radio, and thus it is not
    surprising that more television than radio applicants would qualify.
    Moreover, television applicants serving schools may need this credit
    more than radio applicants may because television stations cover
    greater distances and have greater potential for overlap with
    co-owned stations.

62. We will not eliminate the inclusion of curriculum in our definition
    of state-wide networks. Under the non-curriculum-based credit urged
    by some commenters, any large system of schools or colleges would
    get the credit, regardless of whether its stations play any role in
    student education. The compelling reason for the applicant's
    inability to qualify for the diversity credit \-- the applicant's
    need to serve the schools \-- would no longer exist. The proponents
    of the alternative definition do not demonstrate that large schools
    that want to operate multiple stations for non-curriculum purposes
    should be treated any differently from other NCE applicants that
    want to operate multiple stations for non-curriculum purposes.

63. Connection to a school curriculum must be more than, as one
    petitioner suggests, a potential recruitment tool to attract
    students to attend a university. However, programming that furthers
    a curriculum need not be solely "instructional" *i.e.,* a broadcast
    of a teacher in a classroom. A college radio station operated by
    students as part of a class on broadcasting could also qualify
    regardless of the type of programming the students select. News or
    public affairs programming could further a curriculum if designed
    for use in a school to teach journalism or current events. Music and
    drama programs could be scheduled for use in a music or art
    appreciation curriculum.

#### Number of Schools Served within Contours of Overlapping Stations

64. Petitioners also ask us to adjust the number of schools that an
    applicant must serve to be considered for the credit. Station
    Resource Group believes that our numbers are arbitrary, failing to
    account for different sizes of student populations. It states, for
    example, that an applicant providing service to five small colleges
    would qualify for the credit, while an applicant providing service
    to 45 large high schools would not qualify, even if the high schools
    had more students than the colleges.

65. Colorado Christian University similarly asks that we loosen a
    requirement in the state-wide network credit concerning station
    contours. As adopted, the combined contours of the applicant's
    authorized stations and the one proposed station, must encompass the
    schools to be served. Colorado Christian asks that we consider the
    contours of all of the applicant's pending proposals. It maintains
    that applicants may want to serve large numbers of campuses, but
    that stations needed to cover those schools have not yet been
    authorized due to their mutual exclusivity with stations proposed by
    other applicants.

66. With respect to identifying an applicant's stations that will count
    as serving schools in our analysis, we will consider only existing
    authorizations, and the one proposed station under consideration.
    The diversity credit that we seek to counterbalance limits
    consideration to these same stations. As an applicant would not be
    disadvantaged by any other proposed stations for purposes of the
    diversity credit, we will not consider such proposals for purposes
    of the state-wide network credit. Further, while an educator may
    have applications pending to construct additional stations that
    could serve more schools, it may or may not ever be authorized to
    operate such stations.

67. We clarify that the schools to be served need not be of a particular
    size, because the size of the student population served is not
    necessarily related to the applicant's inability to avoid
    overlapping service contours. We recognize, as SRG predicts, that
    there may be individual instances in which an applicant serving
    fewer students will receive a credit as a state-wide network over an
    applicant serving more students. Such a result is not troublesome
    because the state-wide network credit is not, for example, intended
    to promote service to colleges with large enrollments over colleges
    with small enrollments. Rather, we are making a distinction based on
    the number of campuses receiving broadcast service. A college that
    operates multiple stations to provide broadcast signals to each of
    its many campuses is more likely to experience overlap of its
    signals than another college in the same state seeking to provide
    broadcast service to fewer campus locations. Accordingly, to
    counteract any disadvantage in qualifying for a diversity credit, it
    is appropriate for the state-wide network credit to consider number
    of campuses rather than student population.

#### Small Institutions/Aggregation of Stations Licensed to Different Entities

68. We also clarify that even small schools and colleges with few
    campuses can qualify for the state-wide network credit if, through
    consortia arrangements, they will provide curriculum programming to
    schools in additional to their own. We make this clarification in
    response to concerns of Santa Monica Community College District
    ("Santa Monica") and the American Association of Community Colleges
    ("AACC"), which represents over 1,100 community colleges nationally.
    For example, AACC notes that although Rhode Island and Delaware
    community colleges operate pursuant to state-wide educational plans
    they each have fewer than five campuses. AACC also states that
    community colleges often are not part of the state university
    system, and that because the degree of centralized authority at the
    state level varies, there is some uncertainty over which schools
    individual community colleges could count within their network.[^36]
    For example, Santa Monica operates only one college campus. It is
    concerned that it might not receive a state-wide network credit for
    future stations, because Santa Monica does not have authority over
    campuses licensed to other districts within California, and does not
    provide programming to any single institution with more than five
    campuses.

69. Community colleges or other small entities are not by virtue of size
    or organizational structure precluded from qualifying as state-wide
    networks, but the manner in which any particular organization might
    qualify for the credit will vary depending on such factors. First,
    if a central community college board or similar entity exerts
    control over individual districts, in the same manner that a parent
    entity controls subsidiaries that have their own governing boards,
    the stations of any community college district in the state would be
    attributable to the same parent entity. If the applicant's stations
    encompass five campuses with a common parent entity, and are used in
    the curriculum of those campuses, it could qualify for the
    state-wide network credit. This might occur, for example, if one
    district has a particular expertise in broadcasting, and therefore
    sister districts choose to use the service of this district rather
    than to operate their own stations.

70. Alternatively, an applicant could qualify for the credit if its
    multiple stations are used in the curriculum of its own single
    campus and those of four separately operated college campuses,
    through an agreement with the separate colleges. For example, public
    and/or private four-year universities might regularly use a
    community college's broadcast programs that also relate to their
    curriculum. Similarly, a school district with fewer than 50
    elementary and secondary schools could qualify for the state-wide
    network credit if it also will provide programming to a neighboring
    school district, if the requisite number of schools in both
    districts combined will use the programming in their respective
    curricula. Accordingly, we clarify that consortiums of schools
    coordinating broadcast programming for use in their respective
    curricula, and non-schools serving such consortiums, can qualify for
    the state-wide network credit pursuant to 47 C.F.R. §
    73.7003(b)(3)(c),[^37] if in the aggregate they serve five college
    campuses or 50 elementary and/or secondary schools. Applicants
    cannot, however, aggregate colleges and elementary/secondary schools
    served. For example, an applicant serving four college campuses and
    ten high schools, will not be treated as equivalent to an applicant
    serving five college campuses. As colleges tend to be spaced further
    apart than lower level schools, it is not unanticipated that there
    would be several elementary/secondary schools within the vicinity of
    a college and vice/versa. Serving these additional schools would not
    generally require the applicant to cover a significantly larger
    area, and thus would not affect its ability to receive a diversity
    credit. Additionally, if the applicant is simply operating multiple
    radio stations to serve its own single campus and to reach the
    general public beyond its campus, without being used in a curriculum
    by the requisite number of schools, it would not be able to receive
    a state-wide network credit regardless of the number of schools that
    might happen to be located within its service area. In sum,
    applicants that provide curriculum service to the requisite number
    of schools, through arrangements with those schools, can claim a
    state-wide network credit even if all of the schools are not under
    one common authority.

## Point Factors Not Selected/New Point Proposals

71. In the [NCE Order]{.underline} we considered, but decided not to
    adopt, several other point system factors. A few petitioners urge us
    to reconsider factors previously rejected, or to consider adding new
    factors to the point system.

### Local Program Origination and Other Localism Points

72. Broadcasting for the Challenged and National Federation of Community
    Broadcasters believe that we should provide credit for additional
    local factors beyond the established local applicant credit
    discussed above. BFTC states that it is inconsistent to award a
    credit for established local applicants, but not for local program
    origination by non-local applicants. It urges us to give three
    points to non-local applicants that intend to involve the local
    community in their stations, as a way to recognize that, in BFTC's
    opinion, community-minded non-local broadcasters are equivalent to
    those already present in the local community. Specifically BFTC
    urges us to award credits for applicants that would (a) establish
    local advisory boards; (b) employ 80% local employees; (c) train
    local interns and students; and (d) provide at least 50% locally
    produced programming. NFCB supports credits for local program
    origination as well. It notes that LPFM stations can receive points
    for local program production, and states that LPFM service is not a
    substitute for full service local programming. NFCB argues that a
    credit for locally produced programming would be consistent with
    Commission and court cases supporting local program origination and
    believes that the [NCE Order]{.underline} does not adequately
    explain the reason for departure from an existing policy. Further,
    NFCB would award points to stations that are locally funded, which
    it believes is a good indication of community support, and for use
    of local talent or provision of airtime to local residents, which it
    believes will increase diversity of viewpoint. Community Television,
    Inc. opposes these suggestions. It views our existing localism
    points as disfavoring religious-oriented broadcasters, and argues
    that adding more localism factors would be entirely unsupportable.

73. With respect to BFTC's suggestion of awarding points to a non-local
    applicant planning to provide community service, we note that the
    various steps that BFTC identifies may be helpful to non-local
    applicants in efforts to learn about the community's educational
    needs and to maintain good community relations. We decline, however,
    to award points based on an applicant's mere intention to implement
    such procedures. BFTC's suggestions involve plans for the future,
    and are not readily verifiable upon application. An applicant with
    the best of intentions may fail to live up to such promises if, for
    example, it finds that there are insufficient local residents
    skilled in broadcasting and thus it cannot fulfill its earlier plan
    to hire locally. We believe that it is better policy to award points
    for factors that can be verified at the time of application.
    Further, the record before us does not identify non-local NCE
    licensees that have instituted such policies in the past or provide
    information about the service records of any such stations. Thus we
    do not have a sound basis on which to conclude that non-local
    applicants would provide service equivalent to local applicants if
    the former were to establish local advisory boards, employ local
    residents, or train local interns and students. Nor does it appear
    to us that any of those mechanisms would ensure that a station's
    service is responsive to local community needs and interests to the
    same extent as if the licensee were awarded to a locally based
    organization. Accordingly, we will not adopt BFTC's suggestion.

74. NFCB's proposed credits for local programming, public access, and
    local funding are similar to proposals considered but rejected in
    the [NCE Order]{.underline}. We decline to adopt those factors for
    the reasons stated therein. Given the difficulties in receiving
    financial backing for a non-profit venture like construction of an
    NCE station, applicants should have the flexibility to finance
    construction using whatever sources, local or non-local, are
    available. Similarly, full service NCE applicants should have the
    flexibility to air the programming that they conclude will best
    serve the needs and interests of the community, whoever produces it,
    and wherever that production takes place.

### Radio Reading Services

75. West Coast Public Radio suggests that we award two points to FM
    applicants that would make their subcarrier frequencies available to
    organizations that provide reading services for the blind. NFCB,
    while acknowledging the good work of radio reading services, opposes
    this suggestion because the proposal does not take into account
    whether reading services in an area need more outlets to transmit
    their services, or whether existing options are already adequate. We
    agree with NFCB's critique. We also note that radio reading services
    are but one of many possible ways which FM subcarrier frequencies
    might be used to address a community need. For example, such
    frequencies can also be used to provide foreign language
    programming. Further, regardless of whether subcarriers are used for
    radio reading services or other worthwhile endeavors, subcarrier
    signals are not received by the general public, but only by a
    distinct subset of listeners with specially designed receivers.
    Therefore, to establish a credit for radio reading services, we
    would need to conclude that reading services are superior to all
    other possible subcarrier uses, and that subcarrier service
    requiring special receive equipment deserves points similar to radio
    service that everyone can receive. Such conclusions are not
    supportable under the current record. Thus, we will not award any
    points for this factor.

## Tie Breakers

76. In the [NCE Order]{.underline} we recognized that some mutually
    exclusive applicants might qualify for equal points. For such
    scenarios we established tie breaker mechanisms. If applicants
    differ in terms of their number of existing authorizations, we would
    award the permit to the applicant with the fewest authorizations. If
    that factor fails to break the tie, we would select the applicant
    with the fewest pending applications. If applicants nevertheless
    remain tied, and are unable to settle among themselves, we
    instituted mandatory time sharing as a tie breaker of last resort
    for full service stations.

77. Several commenters object to our tie breakers. Broadcasting for the
    Challenged argues that an applicant's distant stations and
    applications are irrelevant because they have no impact on the
    proposed station or local listeners. Station Resource Group argues
    that our tie breakers are inconsistent with our recognition
    elsewhere of the benefits of centralized NCE operations, and with
    our grant of main studio waivers. Educational Media Foundation is
    concerned that a speculative applicant without any existing stations
    would prevail over an existing broadcaster with stations in a
    different part of the country. It also questions the propriety of
    counting stations without considering the size of the communities
    served. It gives as an example, a tie breaker between an applicant
    with one existing station serving a million people, and a competing
    applicant with two stations serving rural areas with far fewer
    people combined. EMF argues that we should not favor the first
    applicant just because it has fewer stations, as it would be
    inaccurate to consider the first applicant as having a more limited
    opportunity to air its viewpoint to the public. NFCB, while
    supporting our tie breakers based on authorizations and
    applications, objects to use of time sharing as a tie breaker of
    last resort. It views mandatory time sharing as an abdication of the
    Commission's responsibility for choosing among applicants, which
    aims to force applicants into private negotiations among themselves.

78. We acknowledge that the tie breaker selection factors highlight
    relatively minor differences between applicants. We also acknowledge
    that mandatory time sharing is unpopular and can be difficult for
    applicants with different missions, philosophies, or formats. Thus,
    these factors are considered only as tie breakers among applicants
    that are equally qualified under the primary selection factors. As
    tie breakers, these factors are fair. An applicant with more
    stations than its competitor already has more outlets to air its
    viewpoint and programming. It would be unnecessarily complex to
    compare for tie breaking purposes whether any of those stations are
    superior to others in terms of coverage or population served.
    Moreover, it is an efficient use of limited spectrum to award a
    permit to the applicant that applies in a few carefully chosen areas
    most suitable to its educational goals. An equally qualified
    applicant that has additional applications pending for other
    locations has more options available to it. As a last resort, time
    sharing recognizes the equal qualifications of applicants that have
    survived several tie breakers by giving the applicants partial, but
    equal, authority to broadcast. It has been a longstanding Commission
    practice to use time sharing to break ties in comparative broadcast
    cases, and we do not consider it an abdication of responsibility.
    *See, e.g., Southeastern Bible College, Inc*., 85 FCC 2d 936 (Rev.
    Bd. 1981).

79. Whatever shortcomings our tie breakers may have, the petitioners
    suggest no better alternatives. The only alternative presented is a
    tie breaker lottery. As noted in the [NCE Order]{.underline}, the
    statute governing our use of lotteries requires that substantial
    preferences be given in lotteries for minority control, a
    requirement that may well be challenged on constitutional grounds,
    resulting in litigation that would delay the award of licenses under
    our new procedures. Such additional delays would be particularly
    intolerable after the prolonged delays in processing NCE
    applications due to the comparative hearing freeze. Further, we do
    not see how use of a lottery, a process of random selection, is
    likely to result in the licensing of the applicant best qualified to
    serve its proposed audience, the factor that the petitioners argue
    is lacking in our chosen tie breaker system. Accordingly, we affirm
    our tie breaker system.

## Attribution of Full Service and Translator Stations

80. Because several factors in the NCE point system, including diversity
    of ownership, localism, and tie breakers, are based on whether the
    applicant also has interests in other broadcast stations, we
    established attribution rules for NCE organizations. These rules are
    similar to those applicable to commercial broadcasters, attributing
    the interests of the applicant, its parents, and its subsidiaries,
    their officers and members of their governing boards. To implement
    these attribution standards we modified Section 73.3555 of our rules
    concerning ownership. The rule, which previously stated that none of
    its provisions applied to NCE applicants, now says that the rule,
    including its attribution provision, is applicable to NCE applicants
    to the extent that they are compared pursuant to Subpart K, which
    sets forth our new comparative criteria.

81. DeLaHunt Broadcasting states that the relevance of attribution to
    NCE applicants is not limited to the point system in Subpart K. For
    example, it notes that Subpart G, which governs the low power FM
    (LPFM) service, provides that a party with an attributable broadcast
    interest cannot hold an attributable interest in a low power FM
    (LPFM) licensee. DeLaHunt also believes that Subpart I, governing
    auctions of non-reserved channels, counts attributable interests in
    noncommercial stations for determining whether an applicant
    qualifies for a noncommercial bidding credit. In amending the notes
    to Section 73.3555, we meant to clarify that commercial attribution
    standards also apply to NCE stations, to the extent that attribution
    is relevant to such stations. Attribution is certainly relevant for
    Subpart K, but we should have included it as an example only.
    Accordingly, we will now modify Section 73.3555 to use Subpart K as
    an example only. Whenever attribution issues are relevant for NCE
    purposes, the standards in Section 73.3555 will apply.

82. Educational Communications of Colorado Springs asks whether the
    Commission will provide attribution relief similar to that provided
    to commercial entities, in considering the attributable interests of
    officers and directors whose responsibilities are wholly unrelated
    to broadcasting.[^38] For example, it notes that an officer of an
    NCE applicant may sit on the board of a university or church whose
    primary mission is distinct from broadcasting, but which may have a
    broadcast station. Educational Communications of Colorado Springs
    believes that the officer should be relieved from attributable
    interests if he is willing to recuse himself from the secondary
    broadcast-related business of the other organization. As a
    safeguard, it proposes that an officer no longer willing to recuse
    himself on one board, must resign from the other.

83. We clarify that the commercial attribution principles contained in
    the notes to Section 73.3555 are generally applicable to NCE
    applicants for comparative purposes. The specific provision to which
    the petitioner refers, 47 C.F.R. § 73.3555, n.2(h), establishes that
    if an entity engages in a primary business other than broadcasting,
    applicants may request that the Commission waive attribution for any
    officer or director of the company whose responsibilities are wholly
    unrelated to broadcasting. NCE applicants may similarly request
    waivers, asking us to find as non-attributable an officer's position
    with another entity because it has demonstrated that the officer's
    duties and responsibilities with that entity are wholly unrelated to
    that entity's broadcast business. Applicants should indicate the
    points for which it would qualify both if the waiver were granted
    and if the waiver were denied, so that we will not need to request
    additional information from the applicant.

84. We also clarify *sua sponte,* the extent to which applicants should
    count translator stations in determining local diversity and tie
    breaker matters. The text of the [NCE Order]{.underline} and the
    full service rules adopted therein, generally reflect our intent
    that for determining local diversity points we will consider overlap
    of the proposed station with attributable NCE and commercial
    stations, "comparing radio to radio and television to television."
    [NCE Order]{.underline} at ¶ 35; 47 C.F.R. § 73.7003(b)(2).
    Similarly, for tie breakers, they state that we would consider the
    number of an applicant's existing authorizations and applications
    "in the same service (radio or television)." [NCE Order]{.underline}
    at ¶72; 47 C.F.R. § 73.7003(c)(1). [See also]{.underline} 47 C.F.R.
    § 73.7003(c)(2) ("same service"). We note, however, that tie breaker
    language elsewhere in the document could give a mistaken impression
    that we intended translator stations to have no tie breaking impact
    on full service stations and vice versa. [See]{.underline} [NCE
    Order]{.underline}, n.59; Appendix A (Tiebreaker A); 47 C.F.R. §
    74.1233(e)(3).[^39] Accordingly, as discussed below, we clarify our
    intent.

85. In applying for a reserved channel station, whether full service or
    FM translator, the radio applicant generally should include its
    translators for purposes of determining diversity points and tie
    breakers. It would report all attributable commercial and
    noncommercial radio stations: AM, FM, and non-fill-in FM
    translators, [i.e.]{.underline}, translators that extend the area of
    a full service station.[^40] We will recognize an exception to this
    principle, however, for any radio translator licensee that, in the
    particular application involved, is seeking a full service station
    to replace its existing translator station(s). Such applicants may
    exclude, on that application, any existing translator station that
    will cease operating when the proposed full service station
    commences operation. We will, however, permit full service
    television applicants to exclude TV translators and Low Power
    Television (LPTV) stations when reporting attributable commercial
    and noncommercial TV stations. As a result of the transition from
    analog to digital television, translators may be an important
    resource in resolving interference issues, and we do not wish to
    preclude that possibility until that matter has been addressed. Due
    to the impact the transition to DTV has on LPTV and TV translator
    stations, we will not require full service television applicants to
    count LPTV or TV translators. Accordingly full service TV applicants
    applying for reserved channels should report all attributable
    commercial and noncommercial television stations: UHF and VHF, and
    Class A, but excluding TV translators and LPTV stations.

## Application Processing Issues

### General Procedures

86. The manner in which we will process applications is relevant both to
    pending applications and future applications. For pending reserved
    channel applications in closed groups, which are not subject to
    additional competing applications, the staff has already reviewed
    these proposals for mutual exclusivity only and has determined the
    members of each closed group.[^41] As described previously, these
    applicants will need to supplement their applications to provide
    point information. As to future applications, in the [NCE
    Order]{.underline} we decided to open short filing windows
    periodically. These applications will be filed on a new Form 340,
    which asks for the information needed to determine the points for
    which an applicant would qualify. All applications received during a
    particular window will be examined initially for mutual exclusivity
    only. As described above, and for the first filing window only, the
    staff will examine for mutual exclusivity any applications filed
    prior to adoption of the [NCE Order]{.underline} which are still
    subject to competing applications, along with applications filed
    within the first window.

87. After analyzing mutually exclusive applications under our new
    comparative standards, the Commission will issue an order or
    decision letter announcing the tentative selectee in a particular
    proceeding.[^42] As we will have initially examined applications for
    mutual exclusivity only, we will consider whether any tentative
    selectee's application (FCC Form 340 or 349) has defects. If found
    acceptable, we will announce that fact by a public notice generated
    by the Consolidated Database System (CDBS) entitled "Broadcast
    Applications." Petitions to deny the application must be filed
    within 30 days following release of the Broadcast Applications
    Public Notice announcing acceptance of the application at issue.
    Interested parties should monitor these Broadcast Applications
    public notices. If a tentative selectee's application has
    acceptability defects, it will be returned so that the applicant may
    have one opportunity to cure the defect. If the defect is cured
    consistent with the standards for acceptable applications the staff
    will generate a public notice via CDBS, triggering a 30-day period
    for petitions to deny. Failure to correct the defect, however, will
    render the application unacceptable and we will proceed to
    tentatively select the applicant with the next highest number of
    points. So that interested parties may verify or dispute the
    tentatively selected applicant's point tally, we would require
    applicants to file documentation of their point claims at the time
    of application both in their local public inspection files and with
    the Commission. The staff also would conduct random audits of points
    claimed. Other than specifying these broad guidelines, we did not
    establish processing procedures either for pending or future
    applications, instead delegating that responsibility to the Mass
    Media Bureau. Several petitioners ask us to clarify or establish
    additional processing requirements and guidelines, which would be
    generally applicable both to pending and future NCE applicants.

88. First, we consider a request from Spring Arbor College, which asks
    us to clarify that we will enable competing applicants to act as
    private attorneys general, disputing a tentative selectee's claims,
    rather than just conducting random audits. We clarify that the
    applicant's documentation, as specified and submitted in accordance
    with the instructions to the NCE application, Form 340, will be
    available for public review. Interested parties can provide useful
    analysis of such information in the context of petitions to deny or
    informal objections filed in response to public notices announcing
    our choice of tentative selectees. For example, if our tentative
    selectee claimed points as a state-wide network, it would have been
    required to provide information about the schools to be served.
    Interested parties will be able to examine the basis for the
    applicant's certification, and thus may independently verify, for
    example, whether the schools served operate full time and are
    accredited, as required. In addition, the Commission will randomly
    conduct audits of the information submitted. The process adopted
    thus provides reasonable assurance that the statements made will be
    verified for accuracy, either by competing applicants, the
    Commission, or the general public.

89. Next, we consider two petitions asking us to specify the processing
    order of applications. Station Resource Group, which focuses on
    pending applications, suggests a chronological order, resolving the
    earliest groups to file before considering later filed pending
    groups. University of Northern Ohio ("Northern Ohio"), whose views
    raise issues relevant to all applications, suggests geographical
    processing, and would only use chronology if there were two groups
    of applications for the same city. In support of this position,
    Northern Ohio states that local competing applications may be in
    conflict with a distant co-channel operation and that, by
    approaching the applications geographically, we could maximize the
    number of licenses awarded. For example, it maintains that in a
    situation where there is a chain of mutually exclusive applications,
    it is possible that applications at either end of the chain would
    not be mutually exclusive with each other, except for the existence
    of the middle applicant(s). Northern Ohio asks us to resolve the
    middle applications first, and then, if the resolution of that
    situation removes a conflict with another proposal, to grant that
    other proposal as well.

90. We do not believe that it is appropriate or necessary at this time
    to specify in the abstract a particular processing order, *i.e.*,
    the order in which we will resolve the mutually exclusive groups of
    NCE applications on file or the order in which we will analyze any
    particular applications within those groups. We will process
    applications in a manner that will be most administratively
    efficient and that will be most likely to result in selection of the
    best qualified applicants as judged by the point system adopted in
    this proceeding. In that regard, we note that, while the "upside" of
    Northern Ohio's "geographic" proposal is that it may permit the
    selection of more than one applicant from any single mutually
    exclusive group, it also has a clear "downside." Specifically, after
    the best qualified applicant is selected, it is possible that
    remaining applicants that are not mutually exclusive with this
    primary selectee and thus potentially secondary selectees, may also
    be significantly inferior to other applicants that are eliminated
    because they [are]{.underline} mutually exclusive with the primary
    selectee. Rather than issue authorizations to applicants whose
    potential for selection stems primarily from their position in the
    mutually exclusive chain, we believe it is appropriate to dismiss
    all of the remaining applicants and permit them to file again in the
    next filing window.

### Procedural Issues For Future Window Applications

91. Station Resource Group and West Coast Public Radio raise processing
    issues relevant specifically to applications filed in future
    windows. First, to limit potential speculation, they ask us to limit
    to five or ten the number of applications that any organization may
    file in a single filing window. Second, they ask us to commit to
    open at least one window, scheduled to coincide with the due date of
    funding requests to the Public Telecommunications Funding Program
    (PTFP), which is administered by the National Telecommunications
    Information Agency (NTIA), and upon which many NCE applicants rely.
    Because NTIA accepts funding requests only once a year, and requires
    their applicants to indicate that they have filed a broadcast
    application with the Commission, some organizations are concerned
    that they may lose the opportunity to apply in an NTIA funding cycle
    if we do not open an application filing window immediately before
    NTIA applications are due.

92. The suggestion to limit the number of applications submitted in any
    particular filing window is essentially the same as one that was
    considered but rejected in the [NCE Order]{.underline}. [NCE
    Order]{.underline} at ¶¶ 85-86. We did not believe that such limits
    were needed to prevent speculative applications, because other
    aspects of our new procedures, including the window procedure itself
    and a four-year holding period, serve to discourage speculation.
    Further, the tie breaker mechanism favors applicants with fewer
    applications. We do, however, reserve the right to establish such a
    limit in the future by public notice, if the number of applications
    filed exceeds our expectations. Petitioners do not provide
    persuasive reasons for changing our decision at this time.

93. With respect to funding, we appreciate concerns of commenters that
    need to apply to the Commission in time to also apply for funding
    available from another agency. The Commission and its staff are well
    aware of the importance of PTFP funding, especially to smaller
    organizations that could not construct a station without this
    program's financial assistance. Our staff therefore has always
    coordinated closely and in a timely manner with NTIA staff to ensure
    that both agencies can fully consider the applicants' related
    proposals. We expect that coordination between the Commission and
    NTIA will continue and will result in the opening of sufficient
    Commission filing windows for applicants to meet the requirements of
    NTIA.

### Terminated Hearing Proceedings

94. In the [NCE Order]{.underline}, we terminated "any traditional
    comparative hearing proceedings to which a noncommercial educational
    applicant is a party." [NCE Order]{.underline} at ¶ 129. Jimmy
    Swaggart Ministries ("Swaggart") and Real Life Educational
    Foundation of Baton Rouge, Inc. ("Real Life"), which are mutually
    exclusive with each other and have already been through a
    comparative hearing in MM Docket No. 88-308, ask for clarification
    of the process that will apply to former hearing applicants. Real
    Life believes that the prior hearing process has been replaced by a
    point system which will apply to such applicants, while Swaggart
    maintains that it would be inefficient and unfair to completely
    discard the results of hearings that have already taken place.

95. We believe that the proceeding between Real Life and Swaggart is the
    only pending proceeding that was once subject to a full evidentiary
    hearing. That case is essentially before us for a new initial
    selection among the applicants. We will apply a point system to that
    proceeding, identical to that applied to all other pending
    applications for which no initial selection was made prior to the
    effective date of the point system.[^43] Although not specifically
    suggested by Swaggart or Real Life, we considered the possibility of
    using the old hearing results as a final tie breaker, in the event
    that the hearing parties are found otherwise equal under the point
    system and the usual tie breakers set forth in 73.7003(c) do not
    result in a winner. However, given the vagueness of our former
    hearing standards, we cannot say with a certainty that such result
    would be better than time sharing, the ultimate tie breaker that
    would otherwise resolve the matter. In fact, the hearing case
    between Real Life and Swaggart was one which was an impetus for
    revamping the standards for comparing NCE applicants, with the
    Review Board finding very little distinguishing among their
    proposals under the vague hearing criteria then in effect.[^44]
    Accordingly, the pending Real Life and Swaggart applications will be
    considered under the new point system in all respects.[^45]

## Settlements

96. We briefly discussed settlements in the [NCE Order]{.underline}. We
    stated that settling parties would be limited to reimbursement of
    their reasonable and prudent expenses. We also stated that we would
    not "adopt a formal settlement period, so as not to unduly delay the
    award of points in cases where the parties are not interested in
    settlement, but stress that parties are free to settle at any time
    during the process." [NCE Order]{.underline} at ¶ 74.
    [See]{.underline} 47 C.F.R. § 73.7003(d). Although pending NCE
    applicants have been able to settle with each other for a
    considerable time, both before and after the [NCE
    Order]{.underline}, few have filed settlements. To foster
    settlements, the University of Kansas believes that we should
    provide for existing applicants to amend out of a mutually exclusive
    group by specifying any other available channel for which no one has
    applied. It asks us to modify Section 73.3573 of our rules to
    consider such action as a minor change. Kansas believes that such
    action would be consistent with 74.1233(e)(2) used to resolve
    mutually exclusive FM translator applications.

97. We do not adopt Kansas's proposal because it would preclude other
    full service applicants from applying for the available frequencies
    in the next filing window. Under existing rules, an applicant may
    make engineering changes to bring about a settlement if the change
    is "minor", *e.g.,* proposing to move to an adjacent channel. 47
    C.F.R. § 73.3573. Because existing stations can also file
    applications for minor changes outside of filing windows, minor
    changes to pending applications made outside of filing windows do
    not adversely affect the rights of existing licensees. In contrast,
    the settlements based on major changes that Kansas proposes could
    preclude existing stations from filing major changes in the next
    window. We will not permit this. If the applicant that desired to
    make the major change to its proposal does not prevail in a point
    proceeding, it may file its alternate proposal in the next filing
    window, subject to competition from any additional applicants with
    similar plans for that channel. We recognize that our rules are more
    lenient, in this regard, for FM translator stations. Translators are
    secondary services, however, and thus allowing a translator to amend
    to another channel does not have a preclusive effect on future
    applicants for full service stations.

98. We will, however, provide additional clarification of the settlement
    policies that will apply to mutually exclusive NCE groups.[^46]
    Settlement of NCE proceedings can be beneficial both to applicants
    and to the Commission. Applicants are able to achieve a solution
    that is most acceptable to the parties, and the Commission is able
    to conserve the resources we would spend to select among them. Two
    types of settlement agreements will be acceptable: universal
    settlements and technical settlements, each of which allows
    immediate grant of an authorization. Universal settlements resolve
    the claims of all applications within a mutually exclusive group.
    Technical settlements make it possible, by means of minor
    engineering changes, for one applicant to remove itself from the
    group on the four corners of its own application without affecting
    the viability of any other applicants. Thus, through a technical
    settlement, the Commission can authorize one applicant immediately,
    while also considering later which of all of the other applicants
    should build a second NCE station. An example is a unilateral action
    or agreement between applicants at the end of a chain, making it
    possible to grant one of those applicants, while not affecting the
    rights of the others to compete. We will not accept partial
    settlement agreements such as those in which applicants withdraw
    from one proceeding in return for the promise of a competing
    applicant to withdraw from another proceeding, but fail to achieve
    any grantable application or to settle with the remaining applicants
    in each group. Such settlements potentially prejudice the remaining
    non-settling applicants. Partial settlements also encourage
    applicants to eliminate the best competing proposals without any
    resulting public benefit such as faster initiation of service.
    Considering proceedings with partial settlements would not take any
    less time, and could actually take longer because the settlement
    creates a two-step process for the Commission (acting on the
    settlement and comparing the remaining group or groups of
    applicants) instead of the one-step process of comparing all of the
    applicants.

99. Finally, for a short period ending with the date on which existing
    groups of mutually exclusive NCE applicants must file supplements to
    claim points, we will entertain settlement agreements that exceed
    the applicant's reasonable and prudent expenses. We have been unable
    to process mutually exclusive NCE applications since 1995 due to the
    lack of workable NCE comparative standards. Under similar
    circumstances, we permitted competing ITFS applicants to settle
    without any limitations on payments to withdrawing applicants.
    [See]{.underline} *First Report and Order, Competitive Bidding,* 13
    FCC Rcd 15920, ¶ 206 (1998). We believe that our consideration of
    such settlements among closed groups of NCE applicants will
    facilitate resolution of these long-frozen comparative initial
    licensing proceedings. Thus, by the date that the staff announces
    for the acceptance of supplemental filings, applicants will file
    either supplements to claim points, universal settlements resolving
    the entire group, or technical settlements providing for the grant
    of an application as a result of minor engineering changes. Any
    applicants that have settlement agreements already on file pursuant
    to previous settlement policies may continue to pursue those
    settlement agreements, but have an affirmative obligation to submit
    a written statement to the staff by the supplement date referencing
    the pending settlement. Applicants with neither a settlement nor
    supplement on file by the supplement date will be dismissed. For
    settlements received by the supplement date, the Commission will
    waive any of its rules, such as 47 C.F.R. § 73.3525(a)(3), that
    preclude the receipt of any money or other consideration in excess
    of legitimate and prudent expenses in exchange for the dismissal of
    an application, but due to the nature of the NCE service we will not
    waive our policy against "white knight" settlements involving
    non-applicant third parties. This is a one-time opportunity. We do
    not envision waiving our rules beyond the period provided herein.
    Thus, while we always encourage settlements among NCE applicants,
    any settlements filed after the deadline for point supplements will
    be subject to the monetary limits in our rules.

# PROCEDURAL MATTERS AND ORDERING CLAUSES

100. As required by the Regulatory Flexibility Act, 5 U.S.C. § 601 *et
     seq.*, a Supplemental Final Regulatory Flexibility Analysis has
     been completed and is attached as Appendix C hereto.

101. Authority for issuance of this Memorandum Opinion and Order is
     contained in Sections 4(i), 303(r), 403, and 405 of the
     Communications Act of 1934, as amended, 47 U.S.C. §§ 154(i),
     303(r), 403, and 405.

102. The actions taken in this Memorandum and Order have been analyzed
     with respect to the Paperwork Reduction Act of 1995, and found to
     impose no new or modified reporting and recordkeeping requirements
     or burdens on the public.

103. Accordingly, IT IS ORDERED that the petitions for reconsideration
     and clarification listed in Appendix A ARE GRANTED to the extent
     provided herein and otherwise ARE DENIED pursuant to Sections 4(i),
     303(r), 403, and 405 of the Communications Act of 1934, as amended,
     47 U.S.C. §§ 154(i), 303(r), 403, and 405, and Section 1.429(i) of
     the Commission's rules, 47 C.F.R. § 1.429(i).

104. IT IS FURTHER ORDERED that the Commission's Consumer Information
     Bureau, Reference Information Center, SHALL SEND a copy of this
     Memorandum Opinion and Order including the Supplemental Final
     Regulatory Flexibility Analysis, to the Chief Counsel for Advocacy
     of the Small Business Administration.

105. IT IS FURTHER ORDERED that the Commission's rules ARE AMENDED as
     set forth in Appendix B. IT IS FURTHER ORDERED that the provisions
     of this Memorandum Opinion and Order and the rule amendments set
     forth in the Appendix SHALL BE EFFECTIVE 30 days following
     publication in the Federal Register.

106. IT IS FURTHER ORDERED that this proceeding IS TERMINATED.

107. For additional information concerning this proceeding, contact
     Irene Bleiweiss, Mass Media Bureau, Audio Services Division, (202)
     418-2700.

     **FEDERAL COMMUNICATIONS COMMISSION**

     **Magalie Roman Salas**

     **Secretary**

**SEPARATE STATEMENT OF COMMISSIONER HAROLD W. FURCHTGOTT-ROTH**

**In re Reexamination of the Comparative Standards for**

**Noncommercial Educational Applicants**

**Memorandum Opinion and Order in MM Docket No. 95-31**

I write today to acknowledge the constitutional concerns expressed by
religious broadcast advocates, such as the Educational Media Foundation,
in this proceeding. As I have stated before, the Commission must be
diligent in crafting rules that fully respect the spectrum of freedoms
guaranteed to all Americans under the First Amendment of the United
States Constitution. While the point system refinements adopted by the
Commission today are not perfect, they are in the main, speaker and
subject matter neutral. Suffice it to say, the point system is far more
preferable, and less constitutionally suspect, than the comparative
hearing process, a lottery system, or any other existing regulatory
mechanism in selecting among competing applicants for broadcast services
on channels reserved for noncommercial educational use.

**APPENDIX A**

**List of Participants**

American Association of Community Colleges

Broadcasting for the Challenged, Inc.

Center for Media Education, et al.

Colorado Christian University

Community Television, Inc.

Connecticut College Broadcasting Association, Inc.

De La Hunt Broadcasting

Diocese of St. Augustine

Educational Communications of Colorado Springs, Inc.

Educational Media Foundation

Jimmy Swaggart Ministries

Lay Catholic Broadcasting Network

Munn-Reese, Inc.

National Federation of Community Broadcasters, et al.

Real Life Educational Foundation of Baton Rouge, Inc.

Santa Monica Community College District

Spring Arbor College

Station Resource Group

University of Kansas

University of Northern Iowa

WAY-FM Media Group, Inc.

West Coast Public Radio, et al.

**APPENDIX B**

**RULE CHANGES**

Parts 73 and 74 of Chapter 1 of Title 47 of the Code of Federal
Regulations are amended as follows:

PART 73 - RADIO BROADCAST SERVICES

1\. The authority citation for part 73 continues to read:

Authority: 47 U.S.C. 154, 303, 334, and 336.

2\. Section 73.3555 is amended by revising the last sentence of
paragraph (f) to read as follows:

§ 73.3555 Multiple ownership.

\(f\) \* \* \* However, the attribution standards set forth in the Notes
to this section will be used to determine attribution for noncommercial
educational FM and TV applicants, such as in evaluating mutually
exclusive applications pursuant to Subpart K.

3\. Section 73.7000 is amended by adding a final clause to the
definition of Local Applicant to read as follows:

§ 73.7000 Definition of Terms (as Used in Subpart K only).

\*\*\*\*\*

Local Applicant: an applicant physically headquartered, having a campus,
or having 75% of board members residing within 25 miles of the reference
coordinates for the community to be served, or a governmental entity
within its area of jurisdiction.

\*\*\*\*\*

4\. Section 73.7002 is amended by revising paragraph (b) to read as
follows:

§ 73.7002 Fair distribution of service on reserved band FM channels.

\*\*\*\*\*

\(b\) In an analysis performed pursuant to paragraph (a), a full service
FM applicant that will provide the first or second reserved channel
noncommercial educational (NCE) aural signal received by at least 10% of
the population within the station's 60dBu (1mV/m) service contours will
be considered to substantially further fair distribution of service
goals and to be superior to mutually exclusive applicants not proposing
that level of service, provided that such service to fewer than 2,000
people will be considered insignificant. First service to 2,000 or more
people will be considered superior to second service to a population of
any size. If only one applicant will provide such first or second
service, that applicant will be selected as a threshold matter. If more
than one applicant will provide an equivalent level (first or second) of
NCE aural service, the size of the population to receive such service
from the mutually exclusive applicants will be compared. The applicant
providing the most people with the highest level of service will be
awarded a construction permit, if it will provide such service to 5,000
or more people than the next best applicant. If none of the applicants
in a mutually exclusive group would substantially further fair
distribution goals, all applicants will proceed to examination under a
point system. If two or more applicants will provide the same level of
service to an equivalent number of people (differing by less than
5,000), only those equivalent applicants will be considered together in
a point system.

\*\*\*\*\*

5\. Section 73.7003 is amended by revising adding two new sentences to
the end of paragraphs (b)(2) and (c)(1) and adding new paragraphs (e)
and (f) to read as follows:

§ 73.7003 Point system selection procedures.

\*\*\*\*\*

\(b\) \*\*\*

\(2\) \*\*\* Radio applicants will count commercial and noncommercial
AM, FM, and FM translator stations other then fill-in stations.
Television applicants will count UHF, VHF, and Class A stations.

\*\*\*\*\*

\(c\) \*\*\*

(1) \*\*\* Radio applicants will count commercial and noncommercial AM,
    FM, and FM translator stations other than fill-in stations.
    Television applicants will count UHF, VHF, and Class A stations.

    \*\*\*\*\*

    \(e\) For applications filed after April 21, 2000, an applicant's
    maximum qualifications are established at the time of application
    and will be reduced for any post-application changes that negatively
    affect any evaluation criterion.

    \(f\) For applications filed on or before April 21, 2000, applicants
    will establish their qualifications according to the following: (1)
    If the applicant is in a group for which a "B" cutoff notice issued
    prior to April 21, 2000 its maximum non-technical qualifications are
    established as of the date by which applicants must supplement their
    applications to supply point information, and its maximum technical
    qualifications are established as of the date of the "B" cut-off
    notice; (2) If the applicant is in a group for which an "A" cutoff
    notice issued prior to April 21, 2000 but for which no "B" cutoff
    notice issued, its maximum non-technical qualifications are
    established as of the date by which applicants must supplement their
    applications to supply point information, and its maximum technical
    qualifications are established as of April 21, 2000; (3) If the
    applicant was neither placed on an "A" cut-off list prior to April
    21, 2000 nor filed in response to such an "A" cutoff list, it is
    subject to competition from applications filed within the first
    filing window, and its maximum technical and non-technical
    qualifications will be determined as of the close of the first
    filing window. After the relevant date for determining an
    applicant's maximum points, points will be reduced for any changes
    that negatively affect any evaluation criterion.

    PART 74 -- EXPERIMENTAL RADIO, AUXILIARY, SPECIAL BROADCAST AND
    OTHER PROGRAM DISTRIBUTIONAL SERVICES

1\. The authority citation for part 74 continues to read:

Authority: 47 U.S.C. 154, 303, 334, and 554.

2\. Section 74.1233(e)(3) is amended by revising subparagraph (e)(3) to
read as follows.

§ 74.1233 Processing FM translator and booster station applications.

\*\*\*\*\*

\(e\) \* \* \*

(3)\*\*\*

##### Existing Authorizations. Each applicant's number of existing radio authorizations (licenses and construction permits for AM, FM, and FM-translators but excluding fill-in translators) as of the time of application shall be compared, and the applicant with the fewest authorizations will be chosen as tentative selectee. If each applicant is applying for a fill-in translator only, and consideration of its other radio stations is not dispositive, its number of existing fill-in translator authorizations will also be considered, and the fill-in applicant with the fewest fill-in authorizations will be chosen as tentative selectee.

##### Existing Applications. If a tie remains, after the tie breaker in section (i), the remaining applicant with the fewest pending radio new and major change applications (AM, FM, and non fill-in FM translators) will be chosen as tentative selectee. If each applicant is applying for a fill-in translator only, and consideration of its other radio stations is not dispositive, its number of existing fill-in translator applications will also be considered, and the fill-in applicant with the fewest fill-in authorizations will be chosen as tentative selectee..

\*\*\*\*\*

**APPENDIX C**

**SUPPLEMENTAL FINAL REGULATORY FLEXIBILITY ANALYSIS**

As required by the Regulatory Flexibility Act (\"RFA\"),[^47] an Initial
Regulatory Flexibility Analysis (\"IRFA\") was incorporated in the
Further Notice of Proposed Rulemaking and a Final Regulatory Flexibility
Analysis (FRFA)was incorporated in the Report and Order.[^48] This
present Supplemental Final Regulatory Flexibility Analysis
(\"Supplemental FRFA\")[^49] conforms to the RFA.[^50]

**Need For and Objectives of the Memorandum Opinion and Order:**

In the Report and Order, the Commission established a point system, a
type of simplified paper hearing, to select among applicants competing
to construct new noncommercial educational (NCE) broadcast stations on
channels reserved for NCE use. The Commission received petitions
requesting reconsideration and clarification of a variety of issues.
This Memorandum Opinion and Order affirms the use of a point system and
the elements therein, but makes the following clarifications: (1)
attribution standards applicable to NCE stations are clarified, (2) the
stated policy that government entities are considered local throughout
their areas of jurisdiction is incorporated into the rules, (3) it is
clarified that first and second NCE aural signals received, rather than
those licensed to a community, will be considered for the threshold fair
distribution analysis and that, if fair distribution is not decisive
only equivalent mutually exclusive applications with respect to fair
distribution will proceed to be considered under a point system, (4) the
manner in which applicants will claim points is clarified, (5) the
manner in which to count translator stations is clarified. Additionally,
the Memorandum Opinion and Order gives applicants in pending closed
groups of mutually exclusive applications a limited opportunity to
settle for more than reasonable and prudent expenses.

**Summary of Significant Issues Raised by the Public Comments in
Response to the FRFA:**

No comments were received in **direct** response to the FRFA in MM
Docket No. 95‑31. Two Petitioners for Reconsideration, while not
addressing the FRFA, ask for clarification of whether small community
colleges with fewer than five campuses can qualify for state-wide
network points. The Memorandum Opinion and Order clarifies that small
colleges that form consortiums with other colleges, so that at least
five campuses are served, can so qualify. [See]{.underline}
[infra.]{.underline}

**Description and Estimate of the Number of Small Entities to Which
Rules will Apply:** The RFA directs agencies to provide a description of
and, where feasible, an estimate of the number of small entities that
will be affected by the rules.[^51] The RFA generally defines the term
"small entity" as having the same meaning as the terms "small
organization," "small business," and "small governmental jurisdiction."
In addition, the term "small business" has the same meaning as the term
"small business concern" under the Small Business Act. [See]{.underline}
5 U.S.C. § 601(3); 15 U.S.C. § 632. A small business concern is one
which: (1) is independently owned and operated; (2) is not dominant in
its field of operation; and (3) satisfies any additional criteria
established by the Small Business Administration (\"SBA\").[^52] A small
organization is generally "any not-for-profit enterprise which is
independently owned and operated and is not dominant in its field."[^53]
Nationwide, as of 1992, there were approximately 275,801 small
organizations.[^54] "Small governmental jurisdiction" generally means
"governments of cities, counties, towns, townships, villages, school
districts, or special districts, with a population of less than
50,000."[^55] The Census Bureau estimates that this ratio is
approximately accurate for all governmental entities. Thus, of the
85,006 governmental entities, we estimate that 81,600 (91 percent) are
small entities.

The rules adopted in this Order will apply to television and radio
stations licensed to operate on channels reserved as \"noncommercial
educational.\" Specifically, the rules will affect reserved channel FM,
FM translator, and TV stations that apply to make major changes to those
existing stations and to applicants for permits to construct new
reserved channel FM, FM translator, and TV stations. Stations that
operate on non-reserved channels, such as TV translator stations and AM
stations are not affected. Stations in low power services (LPTV and
LPFM) also are not affected.

With respect to television stations, the Small Business Administration
defines a television broadcasting station that has no more than \$10.5
million in annual receipts as a small business. Television broadcasting
stations consist of establishments primarily engaged in broadcasting
visual programs by television to the public, except cable and other pay
television services. Television stations that the Federal Communications
Commission (FCC) would consider commercial, as well as those that the
FCC would consider noncommercial educational, are included in this
industry. Also included are other establishments primarily engaged in
television broadcasting and which produce taped television program
materials. Separate establishments primarily engaged in producing taped
television program materials are classified under another SIC number.

For 1992 the total number of television stations that produced less than
\$10.0 million in revenue was 1,155 of the 1,509 television stations
then operating, both commercial and noncommercial, or 77 percent. As of
February 1, 2001, of the 1,667 total television stations, 374 were
noncommercial educational. Thus, we estimate that the proposed rules
will potentially affect 288 (77 percent of 374) noncommercial
educational television stations that are small businesses. These
existing stations would only be affected if they file an application for
major modification of their existing facilities, and if another
applicant files a mutually exclusive application. These estimates may
overstate the number of small entities since the revenue figures on
which they are based do not include or aggregate revenues from
non-television affiliated companies. On the other hand they may
understate the number of small entities, because we believe that a
larger percentage of noncommercial educational stations are small
businesses than the percentage applicable to the television industry as
a whole. We recognize that the proposed rules may also affect minority
and women owned stations, some of which may be small entities. In 1997,
minorities owned and controlled 38 (3.2%) of 1,193 commercial television
stations in the United States. Comparable figures are not available for
noncommercial stations. According to the U.S. Bureau of the Census, in
1987 women owned and controlled 27 (1.9%) of 1,342 commercial and
noncommercial television stations in the United States. The proposal
would also affect pending and future mutually exclusive applications for
noncommercial television stations. As of February 2001, there are
currently 89 pending applications for 31 channels reserved for
noncommercial educational television usage.

The rules would also affect noncommercial educational radio stations.
The SBA defines a radio broadcasting station that has no more than \$5
million in annual receipts as a small business.[^56] A radio
broadcasting station is an establishment primarily engaged in
broadcasting aural programs by radio to the public.[^57] Radio stations
that the Federal Communications Commission (FCC) would consider
commercial, as well as those that the FCC would consider noncommercial
educational, are included in this industry. Also included are entities
which primarily are engaged in radio broadcasting and which produce
radio program materials. However, radio stations which are separate
establishments and are primarily engaged in producing radio program
material are classified under another SIC number. The 1992 Census
indicates that 96 percent of radio station establishments produced less
than \$5 million in revenue in 1992.[^58] Official Commission records
indicate that 11,334 individual radio stations were operating in
1992.[^59] As of February 1, 2001, Commission records indicate that
12,751 radio stations were operating. Of that radio station total**,**
2,170 stations were noncommercial educational FM radio stations. Thus,
we estimate that 2,083 (96%) of these noncommercial educational stations
are small businesses, possibly more because we believe that a greater
percentage of noncommercial educational stations are small businesses
than of the radio industry overall. These existing stations would only
be affected by the proposal if they choose to file applications for
major modification of facilities and if their applications are mutually
exclusive with the application of another noncommercial entity.
Applicants for new NCE radio stations would also potentially be
affected. As of February 2001 there were 439 pending mutually exclusive
groups of 1,356 applications, for new noncommercial FM radio stations.
We also note that this proposal will affect future full service FM
applications. It also will affect pending and future noncommercial FM
translator applicants. As of February 1, 2001 there were 43 pending
mutually exclusive groups of 97 applications for reserved channel FM
translator stations.

**Description of Projected Reporting, Recordkeeping and Other Compliance
Requirements**:

Most of the provisions of the Report and Order are unchanged by the
Memorandum Opinion and Order. As noted in the Report and Order, the
point system is expected to reduce the overall administrative burden of
the Commission\'s application processes on applicants and the
Commission. Use of a point system will eliminate the expense of
preparing for and appearing at lengthy traditional hearings. Applicants
should also receive decisions faster, because the Commission will make
numerical calculations instead of preparing detailed hearing decisions.
These savings should more than offset the time that would be required
for applicants to gather and submit documentation supporting the points
claimed. No additional professional services are required by applicants
filing under these revised rules. Further, the cost of compliance will
not vary between large and small entities.

**Steps Taken to Minimize Significant Economic Impact on Small Entities,
and Significant Alternatives Considered:**

All significant alternatives presented in the petitions and responsive
comments were considered. The alternatives considered generally would
affect all reserved channel applicants, regardless of whether they are
small or large entities, and whether they are seeking to construct small
or large stations. For example, the Commission considered but did not
adopt suggestions to use lotteries rather than a point system, to adjust
the previously established qualifications needed to receive various
points, and to adopt points for new factors such as radio reading
services. While generally affirming the choices made previously in its
Report and Order in this proceeding, MM Docket No. 95-31, 15 FCC Rcd
7386 (2000), the Commission clarified various matters. Only one
clarification specifically affects small entities. In response to a
concern raised by community colleges, the Commission clarified that
existing rules permit applicants with fewer than 5 colleges/50 secondary
schools of their own to qualify as state-wide networks if through a
consortium or similar arrangement they are also able to count schools
under the authority of other educators to which they regularly provide
curriculum programming. This option may benefit small entities. We
expect that there is no significant economic impact on small entities as
a result of this clarification. We will continue to consider small
entities favorably in the point system, in that they are more likely
than large entities to qualify for the points awarded for diversity of
ownership, established local entity, and in a tie breaker for number of
existing authorizations and applications.

**Report to Congress**

The Commission will send a copy of the *Memorandum Opinion and Order*,
including this Supplemental FRFA, in a report to be sent to Congress
pursuant to the Congressional Review Act. [See]{.underline} 5 U.S.C. §
801(a)(1)(A). In addition, the Commission will send a copy of this
*Memorandum Opinion and Order*, including this Supplemental FRFA, to the
Chief Counsel for Advocacy of the Small Business Administration. A copy
of the *Memorandum Opinion and Order* and Supplemental FRFA, (or
summaries thereof) will also be published in the Federal Register
pursuant to 5 U.S.C. § 604(b).

**APPENDIX D**

**CLOSED GROUPS OF PENDING APPLICATIONS**

This Appendix identifies mutually exclusive groups of applications for
reserved channel noncommercial educational broadcast stations that are
not subject to competition from additional applicants. Applications have
been studied only to determine mutual exclusivity with applications of
the same type, and the appearance of an application on this list does
not necessarily mean that it is grantable. Full service FM applications
were studied based on technical rules in place at the time of filing.
The staff did not consider changes in the protection ratios adopted in
[Streamlining of Radio Technical Rules]{.underline}, MM Docket No. 98-93
(November 1, 2000), untimely amendments, or post April 21, 2000
amendments. The Appendix is organized by service, with full service
television applicants listed first, FM translator applicants second, and
full service FM applicants third. Television applicants are listed
alphabetically by city. Full service FM applicants are listed by the
filing date of the lead applicant. Similarly, FM translator applicants
are organized chronologically.

1\. TELEVISION CLOSED GROUPS

  ------------------ --------- ---------------------------- ------------------
  **City, State**    **Ch.**   **Applicants**               **File Nos.**

                                                            

  Ames, Iowa         34\*      Community Television         BPET-960930KE
                               Educators                    

                               Family Educational           BPET-960712KL
                               Broadcasting, Inc.           

                               Global Educational           BPET-960701KE
                               Development, Inc.            

                               Ames Family Television       BPET-960222KF

                                                            

  Anchorage, Alaska  9\*       Alaska Public                BPET-961115KE
                               Telecommunications           

                               Alaska Broadcast TV, Inc.    BPET-960916KE

                                                            

  Bellingham,        34\*      State Board for Community    BPET-950908KG
  Washington                   Television                   

                               KCTS Television              BPET-951122KT

                                                            

  Clarksdale,        21\*      Community Television         BPET-970331SD
  Mississippi                  Educators                    

                               Mississippi Authority for    BPET-960919KK
                               Educational TV               

                                                            

  Coolidge, Arizona  43\*      American Legacy Foundation   BPET-960710LC

                               Global Educational           BPET-960709KP
                               Development, Inc.            

                                                            

  Corning, New York  30\*      Changing Perspectives, Inc.  BPET-960401KF

                               WSKG Public                  BPET-960126KE
                               Telecommunications Council   

                                                            

  Del Rio, Texas     24\*      Community Television         BPET-961118KF
                               Educators                    

                               Faith Pleases God Church,    BPET-960726KM
                               Inc.                         

                                                            

  Des Moines, Iowa   43\*      Community Television         BPET-960930KF
                               Educators                    

                               Community Television, Inc.   BPET-960724KM

                               Family Educational           BPET-960715KG
                               Broadcasting, Inc.           

                               Global Educational           BPET-960709KT
                               Development, Inc.            

                               Iowa Public Broadcasting     BPET-960508KE
                               Corp.                        

                               Des Moines Family Television BPET-960222KG

                                                            

  Dothan, Alabama    39\*      Community Television         BPET-960920KM
                               Educators                    

                               Acts II Educational Corp.,   BPET-970331LQ
                               Inc.                         

                                                            

  Durango, Colorado  20\*      Rocky Mountain Public        BPET-961001KP
                               Broadcasting                 

                               Global Educational           BPET-960709KQ
                               Development, Inc.            

                                                            

  El Dorado,         30\*      Kaleidoscope Foundation,     BPET-970331LG
  Arkansas                     Inc.                         

                               Lamb Broadcasting of         BPET-960920KK
                               Arkansas, Inc.               

                                                            

  Enid, Oklahoma     26\*      Community Television         BPET-970331SF
                               Educators                    

                               Family Educational           BPET-960920IQ
                               Broadcasting, Inc.           

                                                            

  Flagstaff, Arizona 16\*      Arizona Educational          BPET-961001KK
                               Broadcasting Foundation,     
                               Inc.                         

                               Arizona Board of Regents     BPET-960710KT

                                                            

  Hot Springs,       20\*      Broadcasting for the         BPET-961001KG
  Arkansas                     Challenged                   

                               Community Television         BPET-960923KH
                               Educational, Inc.            

                               Second Baptist Church        BPET-960520KE

                                                            

  Laredo, Texas      39\*      Laredo Community College     BPET-960809KI

                               Faith Pleases God Church,    BPET-960726KK
                               Inc.                         

                                                            

  Logan, Utah        22\*      Arizona Educational          BPET-961001KL
                               Broadcasting Foundation,     
                               Inc.                         

                               University of Utah           BPET-960627KM

                                                            

  Memphis, Tennessee 14\*      Kaleidoscope Foundation,     BPET-960405KF
                               Inc.                         

                               Cossitt Library              BPET-960111KZ

                               Mid-South Public             BPET-950811KE
                               Communications Foundation    

                                                            

  Memphis, Tennessee 56\*      Broadcasting for the         BPET-961118KJ
                               Challenged                   

                               Compassionate Friends        BPET-961211KE

                               Cossitt Library              BPET-961211KK

                               Mid-South Public             BPET-961212KH
                               Communications Foundation    

                               Kaleidoscope Foundation,     BPET-970331LE
                               Inc.                         

                                                            

  Nogales, Arizona   16\*      Faith Pleases God Church,    BPET-960726KQ
                               Inc.                         

                               Community Television         BPET-961118KG
                               Educators                    

                               Broadcasting for the         BPET-961119KH
                               Challenged                   

                                                            

  Ogden, Utah        18\*      Global Educational           BPET-960722KV
                               Development, Inc.            

                               Faith Pleases God Church,    BPET-960726KR
                               Inc.                         

                               Community Television         BPET-961118KE
                               Educators                    

                               Broadcasting for the         BPET-961119KK
                               Challenged                   

                                                            

  Palatka, Florida   42\*      Community Television         BNPET-960923AAL
                               Educators                    

                               WJCT, Inc.                   BPET-960724KQ

                               Compassionate Friends        BPET-960920WY
                               Educational Network          

                                                            

  Raleigh, North     34\*      Achievement School, Inc.     BPET-960920WJ
  Carolina                                                  

                               Community Television, Inc.   BPET-960628KM

                                                            

  Salt Lake City,    26\*      Community Television         BPET-970331SE
  Utah                         Educators                    

                               Global Educational           BPET-960917KH
                               Development, Inc.            

                               Kaleidoscope Foundation,     BPET-970331LL
                               Inc.                         

                               Broadcasting for the         BPET-970331SB
                               Challenged                   

                                                            

  Santa Fe, New      9\*       Global Educational           BPET-960709KO
  Mexico                       Development, Inc.            

                               Regents of the University of BPET-961001KJ
                               New Mexico                   

                                                            

  Seattle,           62\*      KCTS Television              BPET-951207KJ
  Washington                                                

                               Washington Family            BPET-960726KO
                               Broadcasting Association     

                                                            

  Senatobia,         34\*      Family Educational           BPET-960716KF
  Mississippi                  Broadcasting, Inc.           

                               Oral Roberts University      BPET-960724KL

                               Broadcasting of the          BPET-961001KI
                               Challenged                   

                               Global Educational           BPET-960701KF
                               Development, Inc.            

                                                            

  Tulsa, Oklahoma    63\*      Oral Roberts University      BPET-960621KE

                               Creative Educational Media   BPET-960701KG
                               Corp., Inc.                  

                               Global Educational           BPET-960917KE
                               Development, Inc.            

                               Family Educational           BPET-960927KE
                               Broadcasting, Inc.           

                               Community Television         BPET-960930KG
                               Educators                    

                               Faith Pleases God Church,    BPET-961001KE
                               Inc.                         

                               Broadcasting for the         BPET-961001KH
                               Challenged                   

                                                            

  Waverly, New York  57\*      WSKG Public                  BPET-961213KE
                               Telecommunications           

                               Changing Perspectives, Inc.  BPET-961213KF

                                                            

  Weaverville,       32\*      Northern California Public   BPET-960920KV
  California                   Television                   

                               Redding Institute of         BPET-970324KE
                               Religion                     

                                                            

  Wichita, Kansas    42\*      Way of the Cross of          BPET-960528KP
                               Hutchinson, Inc.             

                               Faith Pleases God Church,    BPET-960726KJ
                               Inc.                         

                               Oral Roberts University      BPET-960920KJ

                               Community Television         BPET-960930KH
                               Educators                    

                                                            

  Wichita, Kansas    15\*      President's College, Inc.    BPET-960423KE

                               Oral Roberts University      BPET-960724KP

                               Community Television         BPET-960930KI
                               Educators                    
  ------------------ --------- ---------------------------- ------------------

### FM TRANSLATOR CLOSED GROUPS

**GROUP \# FILE NUMBER CITY ST APPLICANT NAME**

grp001 BPFT 19960731TB PUEBLO CO CALVARY CHAPEL OF TWIN FALLS

grp001 BPFT 19970116TB PUEBLO CO PIKES PEAK COMMUNITY COLLEGE

grp002 BPFT 19970606TE EDGEMONT CO EDUCATIONAL MEDIA FOUNDATION

grp002 BPFT 19971014TC EDGEMONT CO WAY-FM MEDIA GROUP, INC.

grp003 BPFT 19970624TA MOBERLY MO AMERICAN FAMILY ASSOCIATION

grp003 BPFT 19971016TC MOBERLY MO COMMUNITY BROADCASTING, INC.

grp004 BPFT 19970911TH ST. JOSEPH MO EDUCATIONAL MEDIA FOUNDATION

grp004 BPFT 19980219TA ST. JOSEPH MO COMMUNITY BROADCASTING, INC.

grp004 BPFT 19980220TG ST. JOSEPH MO PENSACOLA CHRISTIAN COLLEGE, INC.

grp005 BPFT 19981102TQ CHARLOTTESVILLE VA COMMONWEALTH PUB B'CASTING
CORP

grp005 BPFT 19980720TC CROZET VA CALVARY CHAPEL OF TWIN FALLS, INC.

grp006 BPFT 19990505TD TRACY CA UNIVERSITY OF THE PACIFIC

grp006 BPFT 19981102TR TRACY CA EDUCATIONAL MEDIA FOUNDATION

grp007 BPFT 19990129TG SANTA PAULA/CAMARILL CA LIVING WAY MINISTRIES,
INC.

grp007 BPFT 19990621TF SANTA PAULA CA CA STATE UNIVERSITY AT NORTHRIDGE

grp008 BPFT 19990412TE NEWHALL CA LIVINGWAY MINISTRIES, INC.

grp008 BPFT 19990426TF SANTA SUSANA CA LIVING WAY MINISTRIES, INC.

grp008 BPFT 19990609TC RAYMER CA LIVING WAY MINISTRIES, INC.

grp008 BPFT 19990621TE AGOURA HILLS CA CA STATE UNIVERSITY OF NORTHRIDGE

grp008 BPFT 19990129TH AGOURA HILLS CA LIVING WAY MINISTRIES, INC.

grp009 BPFT 19990204TE BRUSH CO EDU. COMMUNICAT. OF CO SPRINGS, INC.

grp009 BPFT 19990730TB BRUSH CO COLORADO CHRISTIAN UNIVERSITY

grp010 BPFT 19990415TF POST FALLS ID LIVING WAY MINISTRIES, INC.

grp010 BPFT 19990913TC COEUR D\'ALENE ID SPOKANE PUBLIC RADIO

grp011 BPFT 19990419TA ARLINGTON FL CALVARY CHAPEL OF TWIN FALLS, INC.

grp011 BPFT 19990902TC STOCKADE FL COMMUNITY PUBLIC RADIO

grp012 BPFT 19990430TB BRENTWOOD TN CALVARY CHAPEL OF TWIN FALLS, INC.

grp012 BPFT 19990913TB BRENTWOOD TN MIDDLE TENNESSEE STATE UNIVERSITY

grp013 BPFT 19990506TA EDMOND OK CALVARY CHAPEL OF TWIN FALLS, INC.

grp013 BNPFT 19991019AAG EDMOND OK COMMUNITY PUBLIC RADIO, INC.

grp014 BNPFT 19991018AAH LINCOLN PARK CO EDUC COMMUNICATIONS OF CO
SPRINGS, INC.

grp014 BPFT 19990528TB LINCOLN PARK CO CALVARY CHAPEL OF TWIN FALLS,
INC.

grp015 BPFT 19990614TB OPAL CITY OR PACIFIC CASCADE COMMS. CORP.

grp015 BPFT 19990225TA PRINEVILLE OR CALVARY CHAPEL OF TWIN FALLS, INC.

grp016 BPFT 19990701TE RAYTOWN MO LIVING WAY MINISTRIES, INC.

grp016 BNPFT 20000120AAY RAYTOWN MO CALVARY CHAPEL OF TWIN FALLS, INC.

grp016 BNPFT 20000330ABW RAYTOWN MO COMMUNITY BROADCASTING, INC.

grp017 BPFT 19990727TD CAVE JUNCTION OR PACIFIC CASCADE COMMNS. CORP.

grp017 BNPFT 20000303AAX CAVE JUNCTION OR SOUTHERN OREGON UNIVERSITY

grp018 BPFT 19990809TB WEEHAWKEN NJ LIVING WAY MINISTRIES, INC

grp018 BNPFT 19991130AAO UNION CITY NJ PENSACOLA CHRISTIAN COLLEGE, INC.

grp019 BPFT 19990813TD LIVINGSTON TX FAMILY WORSHIP CENTER CHURCH, INC.

grp019 BNPFT 20000301ABR GOODRICH TX PACIFICA FOUNDATION

grp020 BPFT 19990820TH NEWPORT OR CALVARY CHAPEL OF TWIN FALLS, INC.

grp020 BNPFT 20000113AAF OTTER ROCK OR CATHOLIC BROADCASTING NORTHWEST,
INC.

grp020 BMPFT20001215ABD FLORENCE OR CALVARY CHAPEL OF TWIN FALLS, INC.

grp021 BPFT 19990831TC NEW CASTLE CO EDUCATIONAL COMNS OF CO SPRINGS,
INC

grp021 BNPFT 20000118ABO GLENWOOD SPRINGS CO COLORADO CHRISTIAN
UNIVERSITY

grp022 BPFT 19990910TD EDENTON NC FAMILY WORSHIP CENTER CHURCH, INC.

grp022 BNPFT 20000223AAX EDENTON NC GRACE CHRISTIAN SCHOOL

grp023 BNPFT 19990920AAQ HUNTSVILLE TX FAMILY WORSHIP CENTER CHURCH,
INC.

grp023 BNPFT 20000301ABV HUNTSVILLE TX PACIFICA FOUNDATION

grp024 BNPFT 19990921AAJ NARBERTH PA WORLD REVIVALS, INC.

grp024 BNPFT 20000118AEF NARBERTH PA CALVARY CHAPEL OF TWIN FALLS, INC.

grp025 BPFT 19990910TE ELIZABETH CITY NC FAMILY WORSHIP CENTER CHURCH,
INC.

grp025 BNPFT 20000223ABK ELIZABETH CITY NC GRACE CHRISTIAN SCHOOL

grp025 BNPFT 20000224ABG ELIZABETH CITY NC CALVARY CHAPEL OF TWIN FALLS,
INC.

grp026 BPFT 19990910TG MONROE NC FAMILY WORSHIP CENTER CHURCH, INC.

grp026 BNPFT 20000223ABH MONROE NC GRACE CHRISTIAN SCHOOL

grp027 BNPFT 19991005AAO FARMINGTON NM PAULINO BERNAL EVANGELISM

grp027 BNPFT 19991022AAE FARMINGTON NM YOUR CHRISTIAN COMPANION, INC.

grp028 BNPFT 19991020AAF TAMPA FL THE MOODY BIBLE INSTITUTE OF CHICAGO

grp028 BNPFT 19991020AAG OLDSMAR FL RADIO TRAINING NETWORK, INC.

grp028 BNPFT 20000302ABP CLEARWATER FL FAITH PLEASES GOD CHURCH CORP.

grp029 BNPFT 19991029AAD PENDLETON OR CALVARY CHAPEL OF TWIN FALLS, INC.

grp029 BNPFT 20000424ABU PENDLETON OR OREGON PUBLIC BROADCASTING

grp030 BNPFT 19991104AAD MEDINA MN PENSACOLA CHRISTIAN COLLEGE, INC.

grp030 BNPFT 20000316AAE MINNEAPOLIS MN MINNESOTA PUBLIC RADIO

grp031 BNPFT 19991104AAE BRENHAM TX KSBJ EDUCATIONAL FOUNDATION

grp031 BNPFT 20000330ABV BRENHAM TX IXOYE PRODUCTIONS, INC.

grp032 BNPFT 19991129AAD HOLLY SPRINGS GA PENSACOLA CHRISTIAN COLLEGE,
INC.

grp032 BNPFT 20000103AAV LEBANON GA CALVARY CHAPEL OF TWIN FALLS, INC.

grp033 BNPFT 20000511AAW WARNER ROBINS GA COMMUNITY PUBLIC RADIO, INC.

grp033 BNPFT 19991203AAF WARNER ROBINS GA PENSACOLA CHRISTIAN COLLEGE,
INC.

grp034 BNPFT 20000515AAO EL PASO TX LIFE CHALLENGE INTERNATIONAL, INC.

grp034 BNPFT 19991203AAH EL PASO TX EDUCATIONAL MEDIA FOUNDATION

grp035 BNPFT 20000515ABC KINGSPORT TN WAY-FM MEDIA GROUP, INC.

grp035 BNPFT 19991206AAE KINGSPORT TN EDUCATIONAL MEDIA FOUNDATION

grp036 BNPFT 20000407ABL ELKO NV FAITH PLEASES GOD CHURCH CORP.

grp036 BMJPFT19991220AAA ELKO NV CALVARY CHAPEL OF TWIN FALLS, INC.

grp037 BNPFT 20000419AAJ WESTVILLE CT CONNECTICUT PUBLIC BROADCASTING,
INC.

grp037 BNPFT 20000516AAH WOODBRIDGE CT LIVING WAY MINISTRIES, INC.

grp037 BNPFT 19991227AAN WESTVILLE CT SACRED HEART UNIVERSITY, INC.

grp038 BNPFT 20000407AAR GAINESVILLE GA FAITH PLEASES GOD CHURCH CORP

grp038 BNPFT 20000516AAG GAINESVILLE GA LIVING WAY MINISTRIES, INC.

grp038 BNPFT 19991228ABE GAINESVILLE GA COMMUNITY PUBLIC RADIO, INC.

grp039 BNPFT 20000515ABD DELTA, ETC FL WAY-FM MEDIA GROUP, INC.

grp039 BNPFT 19991229AAU NORTH PALM BEACH FL PENSACOLA CHRISTIAN
COLLEGE, INC.

grp040 BNPFT 20000410AAE RAPID CITY SD EDUCATIONAL MEDIA FOUNDATION

grp040 BNPFT 20000103AAX RAPID CITY SD CALVARY CHAPEL OF TWIN FALLS,
INC.

grp041 BNPFT 20000320AAK SEDONA AZ CALVARY CHAPEL OF TWIN FALLS, INC.

grp041 BNPFT 20000107ABP FLAGSTAFF AZ YOUR CHRISTIAN COMPANION, INC.

grp042 BNPFT 20000119ACI DALHART TX FAMILY WORSHIP CENTER CHURCH, INC.

grp042 BNPFT 20000112AAA DALHART TX GREAT PLAINS CHRISTIAN RADIO

grp043 BNPFT 20000313AAM DICKSON TN CALVARY CHAPEL OF TWIN FALLS, INC.

grp043 BNPFT 20000114AAS DICKSON TN FAMILY WORSHIP CENTER CHURCH, INC.

### FULL SERVICE FM CLOSED GROUPS

### \# = See Text of MO&O, Section IV(H)(3) re: Terminated Hearing Cases  {#see-text-of-moo-section-ivh3-re-terminated-hearing-cases .unnumbered}

\% = **Dismissal Reversed and Remanded** to Commission in \"State of
Oregon v. FCC,\" 102 F. 3d 583 (DC Cir. 1996)

\* = Appeal currently under review

  -------- ---------- --- ------- ------------- ----------------- ---- --------------------------------
                                                                       

  MX       LEAD                                                        

  GROUP    CUTOFF                 FILE                                 

  NUMBER   DATE                   NUMBER        CITY              ST   APPLICANT

                                                                       

  88031E   08/22/84   A   BPED    19840322CA    BATON ROUGE       LA   REAL LIFE ED FOUND OF BATON
                                                                       ROUGE \#

  88031E                  BPED    19840822IF    BATON ROUGE       LA   JIMMY SWAGGART MINISTRIES \#

                                                                       

  84091E   05/31/89   A   BPED    19840907IB    OJAI              CA   FAMILY STATIONS, INC.

  84091E              B   BPED    19890526MF    OJAI              CA   EDUCATIONAL B/C OF VENTURA
                                                                       COUNTY

  84091E              B   BPED    19890530MB    SANTA BARBARA     CA   KCBX, INC.

  84091E              B   BPED    19890531MD    OJAI              CA   SHEPHERD COMMUNICATIONS, INC.

                                                                       

  880611   01/10/90   A   BPED    19880610ML    REDDING           CA   THE UNIV.FOUND. CA STATE UNIV,
                                                                       CHICO

  880611              B   BPED    19900129MH    REDDING           CA   STATE OF OREGON %

                                                                       

  89101E   12/07/93   A   BPED    19891019MA    CROWN POINT       IN   HYLES-ANDERSON COLLEGE

  89101E              B   BPED    19910409MF    CROWN POINT       IN   THE MOODY BIBLE INSTITUTE

                                                                       

  90032E                  BPED    19910617ID    BOSTON            MA   TRUSTEES OF BOSTON UNIVERSITY

  90032E   06/17/91   A   BPED    19900327MG    NEW LONDON        CT   CONNECTICUT COLLEGE BROADCAST
                                                                       ASSN.

                                                                       

  92102E   03/24/93   A   BPED    19921026MA    WHITEHALL         OH   LOU SMITH MINISTRIES, INC.

  92102E              A   BPED    19921029MB    COLUMBUS          OH   CHRISTIAN BROADCASTING SERVICES,
                                                                       INC

  92102E              B   BPED    19921104MA    COLUMBUS          OH   THE CEDARVILLE COLLEGE

                                                                       

  93041E   12/07/93   A   BPED    19930423MA    BOISE             ID   PEOPLE OF ACTION

  93041E              B   BPED    19931206MB    MIDDLETON         ID   SOUTHERN IDAHO CORPORATION

  93041E              B   BPED    19931207MD    BOISE             ID   CALVARY CHAPEL OF TWIN FALLS,
                                                                       INC.

                                                                       

  93112E   04/20/94   A   BPED    19931112MD    NORTH DARTMOUTH   MA   UNIVERSITY OF MASSACHUSETTS

  93112E              B   BPED    19940420MB    NORTH DARTMOUTH   MA   GRANITE STATE EDUC. FELLOWSHIP,
                                                                       INC

                                                                       

  94065E   04/17/95   A   BPED    19940629MC    WICHITA FALLS     TX   CAMERON UNIVERSITY

  94065E              B   BPED    19950417MT    WICHITA FALLS     TX   NORTH TEXAS PUBLIC BROADCASTING,
                                                                       INC

                                                                       

  9406SX   07/06/95   A   BPED    19940624MA    MARIANNA          FL   MARIANNA EDUC. B/CNG FOUNDATION

  9406SX              B   BPED    19941122MK    THOMASVILLE       GA   SOUTHEAST EDUCATIONAL RADIO,
                                                                       INC.

                                                                       

  941007                  BMPED   19950629ID    TITUSVILLE        FL   FLORIDA PUBLIC RADIO, INC.

  941007   10/23/96   B   BMPED   19951011MK    KISSIMMEE         FL   HISPANIC BROADCAST SYSTEMS, INC.

                                                                       

  94106E   07/14/95   A   BPED    19941026MA    NORMAN            OK   AMERICAN FAMILY ASSOCIATION

  94106E              B   BPED    19950714MD    NORMAN            OK   SISTER SHERRY LYNN FOUNDATION
                                                                       INC

                                                                       

  941116   03/28/96   A   BPED    19941114MA    ASHLAND           KY   AMERICAN FAMILY ASSOCIATION

  941116              B   BPED    19950524MF    HURRICANE         WV   HURRICANE BIBLE CHURCH

  941116              B   BPED    19960328MC    ASHLAND           KY   POSITIVE ALTERNATIVE RADIO, INC.

  941116              B   BPED    19960328MI    HURRICANE         WV   POSITIVE ALTERNATIVE RADIO, INC.

                                                                       

  94111E   04/17/95   A   BPED    19941121MA    FLINT CITY        AL   NORTH ALABAMA EDU. FOUNDATION

  94111E              B   BPED    19950215MA    TRINITY           AL   AMERICAN FAMILY ASSOCIATION

  94111E              B   BPED    19950413ME    HARVEST           AL   SOUTHWEST FL COMMUNITY RADIO,
                                                                       INC

                                                                       

  94112E   05/11/95   A   BPED    19941221MD    EFFINGHAM         IL   BD OF TRUSTEES, SOUTHERN IL UN

  94112E              B   BPED    19941110MA    CASEY             IL   WORD POWER, INC.

  94112E              B   BPED    19941229MA    CHARLESTON        IL   WISCONSIN VOICE/ CHRIST. YOUTH,
                                                                       INC

  94112E              B   BPED    19950126MC    SALEM             IL   AMERICAN FAMILY ASSOCIATION

                                                                       

  94114E   11/08/95   A   BPED    19941103MC    BRISTOL           VA   AMERICAN FAMILY ASSOCIATION

  94114E              B   BPED    19951023IB    EMORY             VA   EMORY & HENRY COLLEGE

  94114E              B   BPED    19951108NC    BRISTOL           VA   VIRGINIA TECH FOUNDATION, INC.

                                                                       

  94123E              B   BPED    19950213MB    OTTUMWA           IA   IOWA ST UN OF SCIENCE &
                                                                       TECHNOLOGY

  94123E   05/24/95   A   BPED    19941209MB    OTTUMWA           IA   GRASSROOTS BROADCASTING, CO.,
                                                                       INC.

  94123E              B   BPED    19950515ML    FAIRFIELD         IA   AMERICAN FAMILY ASSOCIATION

                                                                       

  950120   05/24/95   A   BPED    19950117MB    PASCAGOULA        MS   AMERICAN FAMILY ASSOCIATION

  950120              B   BPED    19950329MC    PASCAGOULA        MS   JUDAH BROADCASTING NETWORK, INC.

  950120              B   BPED    19950524MI    PRICHARD          AL   MOODY BIBLE INISTITUE OF CHICAGO

                                                                       

  950215   05/03/96   A   BPED    19950210MA    MCCLOUD           CA   SOUTHERN OREGON STATE COLLEGE

  950215              B   BPED    19960503MG    MCCLOUD           CA   FATIMA RESPONSE INC DBA

                                                                       

  95026E   12/06/95   A   BPED    19950206NB    CHAMPLAIN         NY   NEW YORK EDUCATIONAL
                                                                       BROADCASTERS

  95026E              B   BPED    19951206MB    SCHUYLER FALLS    NY   CHRISTIAN MINISTRIES INC.

                                                                       

  95031E   07/14/95   A   BPED    19950327MA    REDDING           CA   CHRISTIAN ARTS AND EDUCATION,
                                                                       INC.

  95031E              B   BPED    19950713MB    REDDING           CA   ST OF OR ACTING & THROUGH THE ST
                                                                       BD

  95031E              B   BPED    19950714ME    REDDING           CA   EDUCATIONAL MEDIA FOUNDATION INC

  95031E              B   BPED    19950714MF    RED BLUFF         CA   TEHAMA COUNTY COMMUNITY
                                                                       BR'CASTERS

                                                                       

  950331                  BPED    19971126MC    LOMPOC            CA   CSN INTERNATIONAL

  950331                  BPED    19971202MB    COALINGA          CA   FAMILY STATIONS INC

  950331   12/02/97   A   BPED    19970328MD    SANTA MARIA       CA   PEOPLE OF ACTION

                                                                       

  95058E   01/18/96   A   BPED    19950530MB    PORTAGEVILLE      MO   WORD OF VICTORY OUTREACH CENTER
                                                                       INC

  95058E              B   BPED    19950626MB    BLYTHEVILLE       AR   AMERICAN FAMILY ASSOCIATION

                                                                       

  95059E   01/18/96   A   BPED    19950512MA    MESQUITE          NV   SOUTHERN NEVADA ED BROADCASTERS

  95059E              B   BPED    19960118MK    LAS VEGAS         NV   NEVADA PUBLIC RADIO CORPORATION

                                                                       

  95061E   04/18/96   A   BPED    19950608MB    BEAUFORT          NC   APPALACHIAN EDUCATIONAL COMMUN
                                                                       CORP.

  95061E              B   BPED    19950928MD    BEAUFORT          NC   AMERICAN FAMILY ASSOCIATION

                                                                       

  95062E   03/28/96   A   BPED    19950628MA    LYNCHBURG         VA   POSITIVE ALTERNATIVE RADIO, INC

  95062E              B   BPED    19960327MA    LYNCHBURG         VA   VISION COMMUNICATIONS INC

  95062E              B   BPED    19960328MD    RUSTBURG          VA   EDUCATIONAL MEDIA CORPORATION

                                                                       

  95064E   12/15/95   A   BPED    19950615MZ    BENTONVILLE       AR   AMERICAN FAMILY ASSOCIATION

  95064E              B   BPED    19951215MF    NEOSHO            MO   BRIDGE BUILDERS EDUC.
                                                                       ASSOCIATION

                                                                       

  95072E   01/18/96   A   BPED    19950718MA    TAHOE CITY        CA   THOMAS ACQUINAS SCHOOL

  95072E              B   BPED    19951113MB    RENO              NV   STOCKTON CHISTIAN LIFE COLLEGE

  95072E              B   BPED    19951127MA    RENO              NV   BD OF REGENTS / UN OF NV --
                                                                       TRUCKEE

  95072E              B   BPED    19960118MH    HAWTHORNE         NV   AMERICAN EDUCATIONAL
                                                                       BROADCASTING

                                                                       

  95075E   01/18/96   A   BPED    19950724ME    GREENVILLE        TX   AMERICAN FAMILY ASSOCIATION

  95075E              B   BPED    19960118MG    GREENVILLE        TX   SISTER SHERRY LYNN FOUNDATION,
                                                                       INC.

                                                                       

  95076E   12/15/95   A   BPED    19950711MB    PERRY             IA   AMERICAN FAMILY ASSOCIATION

  95076E              B   BPED    19951215ME    PERRY             IA   IOWA STATE UNIV. OF SCIENCE &
                                                                       TECH

                                                                       

  95077E                  BPED    19960416MB    TEHAMA            CA   N VALLEY ED COMMUNITY RADIO INC

  95077E   04/18/96   A   BPED    19950720MA    PARADISE          CA   NORTHERN CA ED BROADCASTERS

  95077E              B   BPED    19960417MD    BURNEY            CA   OREGON STATE BOARD OF HIGHER ED.

                                                                       

  95083E   04/18/96   A   BPED    19950814MA    HONOLULU          HI   BIBLE BROADCASTING NETWORK, INC

  95083E              B   BPED    19960416MA    HONOLULU          HI   CALVARY CHAPEL OF HONOLULU, INC

  95083E              B   BPED    19960418MB    KANEOHE           HI   MAKA\'AINANA BROADCASTING CO,
                                                                       LTD

                                                                       

  95093E   04/18/96   A   BPED    19950905MG    AURORA            NC   DOWN EAST PUBLIC RADIO, INC

  95093E              B   BPED    19960417MB    AURORA            NC   FRIENDS OF DOWN E PUBLIC RADIO
                                                                       INC

                                                                       

  95094E   04/04/96   A   BPED    19950906MM    ST. MARTINVILLE   LA   AMERICAN FAMILY ASSOCIATION

  95094E              B   BPED    19960404MA    ABBEVILLE         LA   COMMUNITY RADIO ALLIANCE

                                                                       

  95095E   05/03/96   A   BPED    19950905MD    BECKLEY           WV   SHOFAR BROADCASTING CORPORATION

  95095E              B   BPED    19960502MH    BECKLEY           WV   POSITIVE ALTERNATIVE RADIO, INC.

                                                                       

  95102E                  BPED    19960429IC    CHARLOTTE         NC   UNIVERSITY RADIO FOUNDATION,
                                                                       INC.

  95102E   05/03/96   A   BPED    19951027ME    WILKESBORO        NC   WILKES COMMUNITY COLLEGE

                                                                       

  95111E   05/17/96   A   BPED    19951128MA    PRINCESS ANNE     MD   MARANATHA INC.

  95111E              B   BPED    19960516ME    OCEAN CITY        MD   EXEC. COMM. BD. OF TRUST OF
                                                                       AMER. U

                                                                       

  951129   05/17/96   A   BPED    19951129MA    ST. JOSEPH        MO   AMERICAN FAMILY ASSOCIATION

  951129              B   BPED    19951121MF    ST. JOSEPH        MO   BAPTIST TEMPLE SCHOOL

  951129              B   BPED    19960514MA    ST. JOSEPH        MO   GOOD NEWS MINISTRIES, INC.

  951129              B   BPED    19960517MG    ST. JOSEPH        MO   COMMUNITY BROADCASTING, INC.

                                                                       

  95124E   07/12/96   A   BPED    19951208MB    TUCSON            AZ   EDUCATIONAL MEDIA FOUNDATION

  95124E              A   BPED    19960229MA    MAMMOTH           AZ   MAMMOTH EDUCATIONAL FOUNDA, INC

  95124E              B   BPED    19960517MF    TUCSON            AZ   FAMILY LIFE BROADCASTING, INC.

  95124E              B   BPED    19960712MA    TUCSON            AZ   AMERICAN ED BROADCASTING INC

  95124E              B   BPED    19960712MH    GLOBE             AZ   AMERICAN ED BROADCASTING INC

                                                                       

  960121                  BPED    19970626MA    PLACERVILLE       CA   AMERICAN FAMILY ASSOCIATION

  960121                  BPED    19970626MC    CAMINO            CA   CHRISTIAN COMPANION NETWORK,
                                                                       INC.

  960121                  BPED    19970626MD    POLLOCK PINES     CA   HOWELL MOUNTAIN BROADCASTING CO.

  960121   06/26/97   A   BPED    19960118MM    POLLOCK PINES     CA   AMERICAN EDUCATIONAL
                                                                       BROADCASTING

                                                                       

  960122   06/19/96   A   BPED    19960118MJ    ARDMORE           OK   CAMERON UNIVERSITY

  960122              B   BPED    19960404MB    ADA               OK   AMERICAN FAMILY ASSOCIATION

                                                                       

  96014E   08/22/96   A   BPED    19960116ML    JASPER            IN   GOOD SAMARITAN EDUCATIONAL
                                                                       RADIO, IN

  96014E              B   BPED    19960423MB    OWENSBORO         KY   BOWLING GREEN COMMUNITY BROADC/G
                                                                       INC

                                                                       

  960206   10/23/96   A   BPED    19960206MD    KLAMATH FALLS     OR   EDUCATIONAL MEDIA FOUNDATION

  960206              B   BPED    19961022MA    KLAMATH FALLS     OR   ST BD OF HIGHER ED & FOR
                                                                       SOUTHERN

                                                                       

  9602AA   09/05/96   A   BPED    19960209MB    CHARLESTON        IL   VCY/AMERICA, INC.

  9602AA              B   BPED    19960905MA    CHARLESTON        IL   ILLINOIS BIBLE INSTITUTE INC

  9602AA              B   BPED    19960905ME    MARTINSVILLE      IL   WORD POWER, INC

                                                                       

  960303   06/19/96   A   BPED    19960325MD    CHEHALIS          WA   WASHINGTON STATE UNIVERSITY

  960303              B   BPED    19960619ME    LITTELL           WA   SHEPHERD COMMUNICATIONS, INC.

                                                                       

  960304   06/19/96   A   BPED    19960328MH    MADISONVILLE      KY   BOARD OF REGENTS, MURRAY STATE
                                                                       UNIV.

  960304              A   BPED    19960619MD    MADISONVILLE      KY   LIFE ANEW MINISTRIES, INC.

                                                                       

  960308   04/17/97   A   BPED    19960326MB    BAKER             FL   OKALOOSA PUBLIC RADIO, INC.

  960308              B   BPED    19970417MC    THOMASVILLE       AL   NATIONWIDE INSPRIATIONAL B/G

                                                                       

  960310   02/20/97   A   BPED    19960328MA    PENSACOLA         FL   FLORIDA PUBLIC RADIO, INC.

  960310              B   BPED    19970220MD    PANAMA CITY       FL   BIBLE BROADCASTING NETWORK INC

  960310              B   BPED    19960923MC    PANAMA CITY       FL   AMERICAN FAMILY ASSOCIATION

                                                                       

  960315   08/22/96   A   BPED    19960312MA    OTTUMWA           IA   GLASSROOTS BROADCASTING COMPANY,
                                                                       INC

  960315              B   BPED    19960820MC    OTTUMWA           IA   UNIVERSITY OF NORTHERN IOWA

                                                                       

  96032E   08/22/96   A   BPED    19960307MD    PONCA CITY        OK   THE LOVE STATION, INC,

  96032E              B   BPED    19960524MB    STILLWATER        OK   AMERICAN FAMILY ASSOCIATION

                                                                       

  96036E   08/22/96   A   BPED    19960307ME    SEBRING           FL   RADIO TRAINING NETWORK, INC.

  96036E              B   BPED    19960820MB    SEBRING           FL   THE MOODY BIBLE INSTITUTE OF
                                                                       CHICAGO

  96036E              B   BPED    19960822MA    CLEWISTON         FL   AMERICAN ED BROADCASTING INC

                                                                       

  96039E   07/12/96   A   BPED    19960328ME    WAUBUN            MN   NIIJII BROADCAST CORPORATION

  96039E              B   BPED    19960712MG    SEBEKA            MN   LIFETALK BROADCASTING
                                                                       ASSOCIATION

                                                                       

  960406   10/23/96   A   BPED    19960412MB    COWETA            OK   CREATIVE EDUCATIONAL MEDIA
                                                                       CORP., INC.

  960406              B   BPED    19960412MA    TULSA             OK   THE UNIVERSITY OF TULSA

                                                                       

  96054E   09/26/96   A   BPED    19960521MA    WESTMINSTER       CO   S W FLORIDA COMMUNITY RADIO INC

  96054E              B   BPED    19960926MD    LAKEWOOD          CO   COLORADO CHRISTIAN UNIVERSITY
                                                                       INC

  96054E              B   BPED    19960926ME    WESTMINSTER       CO   EDUCATIONAL MEDIA FOUNDATION

                                                                       

  96059E   12/17/96   A   BPED    19960523MZ    RALEIGH           NC   NORTH CAROLINA STATE UNIVERSITY

  96059E              B   BPED    19961217MD    ELON COLLEGE      NC   ELON COLLEGE

                                                                       

  96064E   10/23/96   A   BPED    19960607MC    CLARKSVILLE       TN   AMERICAN FAMILY ASSOCIATION

  96064E              B   BPED    19960729MB    CLARKSVILLE       TN   CEN-TENN COMMUNICATIONS, INC.

  96064E              B   BPED    19961021MB    CLARKSVILLE       TN   WAY-FM MEDIA GROUP INC.

                                                                       

  960606   03/12/97   B   BPED    19961023MA    KAPLAN            LA   NORTH ALABAMA EDUC. FOUNDATION

  960606   03/12/97   B   BPED    19961023MG    BROUSSARD         LA   MARY V. HARRIS FOUNDATION

                                                                       

  960709   12/03/96   A   BPED    19960710MA    LAKE CITY         TN   AMERICAN FAMILY ASSOCIATION

  960709              B   BPED    19961203ME    NEWPORT           TN   BIBLE BELIEVERS NETWRK INC

                                                                       

  960710   12/17/96   A   BPED    19960724MG    LONGVIEW          TX   AMERICAN FAMILY ASSOCIATION

  960710              B   BPED    19960920ME    JEFFERSON         TX   HOUSTON CHRISTIAN BROADCASTERS
                                                                       INC

  960710              B   BPED    19961217ME    WHITE OAK         TX   EDUC. RADIO FNDTN OF E. TEXAS,
                                                                       INC.

                                                                       

  9607B1   11/12/96   A   BPED    19960705MB    WESTDALE          LA   AMERICAN FAMILY ASSOCIATION

  9607B1              B   BPED    19960814MD    COTTON VALLEY     LA   ED RADIO FOUNDATION OF E TX INC

  9607B1              B   BPED    19961031MA    JONESBORO         LA   AMERICAN FAMILY ASSOCIATION

  9607B1              B   BPED    19961112MC    BLANCHARD         LA   MISSIONARY ACTION PROJECTS

                                                                       

  9607B3                  BPED    19961112MD    LOVELAND          CO   COLORADO CHRISTINA UNIVERSITY

  9607B3                  BPED    19961112ME    FORT COLLINS      CO   S.W. FLORIDA COMMUNITY RADIO,
                                                                       INC.

  9607B3                  BPED    19961112MF    EATON             CO   EDUCATIONAL MEDIA FOUNDATION

  9607B3   11/12/96   A   BPED    19960731MA    FORT COLLINS      CO   PUBLIC RADIO FOR THE FRONT RNGE

                                                                       

  960811   03/13/97   A   BPED    19960918ME    PARRISH           AL   AMERICAN FAMILY ASSOCIATION

  960811              B   BPED    19960819MC    TUSCALOOSA        AL   THE MOODY BIBLE OF CHICAGO

                                                                       

  960812   03/13/97   A   BPED    19960830ME    MADISONVILLE      TX   HOUSTON CHRISTIAN BROADCASTERS,
                                                                       INC.

  960812                  BPED    19970108MH    CROCKETT          TX   AMERICAN FAMILY ASSOCIATION

                                                                       

  960813              B   BPED    19970312MC    BETTENDORF        IA   AUGUSTANA COLLEGE

  960813   03/13/97   A   BPED    19960805MA    KEWANEE           IL   AMERICAN FAMILY ASSOCIATION

  960813              B   BPED    19960927MA    BETTENDORF        IA   UNIVERSITY OF NORTHERN IOWA

                                                                       

  960815                  BPED    19970312MD    HUDSON            TX   LUFKIN EDUCATIONAL B/CING
                                                                       FOUNDATION

  960815                  BPED    19970417MA    ATHENS            TX   AMERICAN FAMILY ASSOCIATION

  960815                  BPED    19970417MB    BEAUMONT          TX   AMERICAN ED BROADCASTING INC

  960815                  BPED    19970417MG    WACO              TX   AMERICAN ED BROADCASTING INC

  960815   04/17/97   A   BPED    19960830MF    LUFKIN            TX   HOUSTON CHRISTIAN BROADCASTERS,
                                                                       INC.

                                                                       

  960820   02/20/97   A   BPED    19960826ME    MANHATTAN         KS   AMERICAN FAMILY ASSOCIATION

  960820              B   BPED    19970220MC    MANHATTAN         KS   BIBLE BROADCASTING NETWORK INC

                                                                       

  96086E   01/09/97   A   BPED    19960806MA    FAYETTEVILLE      NC   AMERICAN FAMILY ASSOCIATION

  96086E              B   BPED    19970109MG    FAYETTEVILLE      NC   BIBLE BROADCASTING NETWORK INC

  96086E              B   BPED    19970109MN    WADE              NC   COVENANT ED FELLOWSHIP INC

                                                                       

  96088E   01/09/97   A   BPED    19960802MF    ADA               OK   AMERICAN FAMILY ASSOCIATION

  96088E              B   BPED    19970109ME    SHAWNEE           OK   THE LOVE STATION INC

  96088E              B   BPED    19970109MM    ADA               OK   SISTER SHERRY LYNN FOUNDATION
                                                                       INC

                                                                       

  960903   03/13/97   A   BPED    19960910MB    ST. JOSEPH        MO   AMERICAN FAMILY ASSOCIATION

  960903              B   BPED    19970313MA    SAVANNAH          MO   COMMUNITY BROADCASTING INC

  960903              B   BPED    19970313MM    ST. JOSEPH        MO   CALVARY CHAPEL /ST. JOSEPH, MO.
                                                                       INC

                                                                       

  960904   03/13/97   A   BPED    19960906MA    GLENWOOD SPRINGS  CO   PUBLIC BROADCASTING OF CO INC

  960904              B   BPED    19970312MA    CARBONDALE        CO   PITKIN COUNTY

                                                                       

  960908   05/16/97   A   BPED    19960920MA    LANCASTER         NY   HOLY FAMILY COMMUNICATIONS, INC.

  960908                  BPED    19970516MA    WILLIAMSVILLE     NY   MARY V. HARRIS FOUNDATION \*

                                                                       

  960911   03/27/97   A   BPED    19960911MH    CAIRO             GA   AMERICAN FAMILY ASSOCIATION

  960911              B   BPED    19970326MB    QUINCY            FL   OKALOOSA PUBLIC RADIO, INC.

                                                                       

  96097X   03/27/97   A   BPED    19960930MA    WENATCHEE         WA   THE MOODY BIBLE INITITUTE OF
                                                                       CHICAGO

  96097X              B   BPED    19970327MC    EAST WENATCHEE    WA   DOUGLAS COUNTY ED RADIO
                                                                       ASSOCIATION

                                                                       

  9609R1   04/17/97   A   BPED    19960924MF    MART              TX   AMERICAN FAMILY ASSOCIATION

  9609R1              B   BPED    19970131MA    WACO              TX   UNIV. OF TEXAS AT AUSTIN KUT
                                                                       RADIO

  9609R1              B   BPED    19970417ME    TEMPLE            TX   AMERICAN ED BROADCASTING INC

                                                                       

  961010   03/13/97   A   BPED    19961028MB    PIEDMONT          OK   THE LOVE STATION, INC.

  961010              B   BPED    19970110MD    YUKON             OK   EDUCATIONAL MEDIA FOUNDATION

  961010              B   BPED    19970226MB    EL RENO           OK   AMERICAN FAMILY ASSOCIATION

  961010              B   BPED    19970313MD    PIEDMONT          OK   COMMUNITY BROADCASTING INC

  961010              B   BPED    19970313ML    CRESCENT          OK   PENSACOLA CHRISTIAN COLLEGE, INC

                                                                       

  961011   03/27/97   A   BPED    19961010MC    FAIRFIELD         IA   AMERICAN FAMILY ASSOCIATION

  961011              B   BPED    19970321MB    FAIRFIELD         IA   UNIVERSITY OF NORTHERN IOWA

                                                                       

  961012   03/13/97   A   BPED    19961024MD    PERALTA           NM   EDUCATIONAL MEDIA FOUNDATION

  961012              B   BPED    19970312MB    GRANTS            NM   AMERICAN FAMILY ASSOCIATION

  961012              B   BPED    19970313IE    ALBUQUERQUE       NM   BOARD OF REGENTS UNIV. OF NEW
                                                                       MEXICO

  961012              B   BPED    19970313MB    GRANTS            NM   FAMILY STATIONS INC

                                                                       

  961120              B   BPED    19971121MG    MILFORD           NH   KNOWLEDGE FOR LIFE

  961120   04/17/97   A   BPED    19961122MB    NORWICH           VT   NH PUBLIC RADIO/VERMONT

  961120              B   BPED    19961224MA    NASHUA            NH   NEW HAMPSHIRE PUBLIC RADIO, INC.

  961120              B   BPED    19970417MJ    PETERBOROUGH      NH   NORTHEASTERN ED RADIO FELLOWSHIP
                                                                       INC

                                                                       

  961121   04/17/97   A   BPED    19961104MD    PEACHTREE CITY    GA   COMMUNITY PUBLIC RADIO, INC.

  961121              B   BPED    19970407MD    PEACHTREE CITY    GA   AMERICAN FAMILY ASSOCIATION

  961121              B   BPED    19970416MB    GRIFFIN           GA   SECOND BAPTIST CHURCH INC

  961121              B   BPED    19970416ME    PEACHTREE CITY    GA   AUGUSTA RADIO FELLOWSHIP
                                                                       INSTITUTE

  961121              B   BPED    19970416MF    PEACHTREE CITY    GA   LIFE RADIO MINISTRIES INC

                                                                       

  961122   05/09/97   A   BPED    19961129MN    BENTON            MO   AMERICAN FAMILY ASSOCIATION

  961122              B   BPED    19970508MD    JACKSON           MO   I G W T COMMUNITY RADIO INC

                                                                       

  961126   07/25/97   A   BPED    19961105MA    WAVERLY           IA   AMERCIAN FAMILY ASSOCIATION

  961126              B   BPED    19970210MD    WAVERLY           IA   WARTBURG COLLEGE

                                                                       

  961127   05/09/97   A   BPED    19961114MB    GOODLAND TOWNSHIP MI   SUPERIOR COMMUNICATIONS

  961127              B   BPED    19970508MG    IMLAY CITY        MI   GOSPEL RADIO INTERNATIONAL, INC.

                                                                       

  961208   06/13/97   A   BPED    19961231MA    FOLKSTONE         NC   FAMILY RADIO NETWORK INC

  961208              B   BPED    19970612ME    JACKSONVILLE      NC   AMERICAN FAMILY ASSOCIATION

  961208              B   BPED    19970613MC    SNEADS FERRY      NC   PRAISE BROADCASTING NETWORK,
                                                                       INC.

                                                                       

  961209                  BPED    19970625MD    GALAX             VA   POSITIVE ALTERNATIVE RADIO, INC.

  961209   06/26/97   A   BPED    19961218MB    MOUNT AIRY        NC   AMERICAN FAMILY ASSOCIATION

                                                                       

  961210   06/26/97   A   BPED    19961223ME    SANTA MARIA       CA   CALVARY CHAPEL OF SAN LUIS
                                                                       OBISPO INC

  961210              B   BPED    19970626MB    SANTA MARIA       CA   PEOPLE OF ACTION

  961210              B   BPED    19970626ME    SANTA MARIA       CA   FAMILY STATIONS, INC.

                                                                       

  970108   05/09/97   A   BPED    19970123MA    HIAWATHA          IA   FRIENDSHIP COMMUNICATIONS INC

  970108              B   BPED    19970508MC    ANAMOSA           IA   UNIVERSITY OF NORTHERN IOWA

  970108              B   BPED    19970509MB    CEDAR RAPIDS      IA   AMERICAN FAMILY ASSOCIATION

                                                                       

  970109              B   BPED    19970807MU    INDIANOLA         MS   BROADCASTING FOR THE CHALLENGED
                                                                       INC

  970109   08/07/97   A   BPED    19970129MA    INDIANOLA         MS   AMERICAN FAMILY ASSOCIATION

                                                                       

  970110   08/07/97   A   BPED    19970109MF    LAYTONVILLE       CA   REDWOOD COMMUNITY RADIO INC

  970110              B   BPED    19970807MV    LAYTONVILLE       CA   CSN INTERNATIONAL

                                                                       

  970111   08/07/97   A   BPED    19970108MI    OTTUMWA           IA   AMERICAN FAMILY ASSOCIATION

  970111              B   BPED    19970321MA    OTTUMWA           IA   UNIVERSITY OF NORTHERN IOWA

                                                                       

  970112   08/07/97   A   BPED    19970127ME    UTICA             NY   SOULS HARBOR UNITED PENTECOSTAL

  970112              B   BPED    19970807MM    REMSEN            NY   WAMC

                                                                       

  970113   08/07/97   A   BPED    19970113MB    KIRKSVILLE        MO   AMERICAN FAMILY ASSOCIATION

  970113              B   BPED    19970806MA    KIRKSVILLE        MO   GREAT COMMISSION BROADCASTING
                                                                       CORP

                                                                       

  970120   12/02/97   A   BPED    19970110MB    NASHVILLE         AR   AMERICAN FAMILY ASSOCIATION

  970120              B   BPED    19971202MA    FORT SMITH        AR   FAMILY STATIONS INC

                                                                       

  970209   05/09/97   A   BPED    19970212MB    ITHACA            NY   WSKG PUBLIC TELECOM COUNCIL

  970209              B   BPED    19970411MC    ITHACA            NY   THE COLLEGES OF THE SENECA

                                                                       

  970210   08/07/97   A   BPED    19970203ME    MCCONNELLSBURG    PA   MORRIS B/CASTING & COMMUN. INC.

  970210              B   BPED    19970422MB    SHIPPENSBURG      PA   SHIPPENSBURG UNIV. OF
                                                                       PENNSYLVANIA

  970210              B   BPED    19970806MC    MIDDLETON         PA   FOUR RIVERS COMMUNITY B'CASTING
                                                                       \*

                                                                       

  970211                  BPED    19970709MF    SHERMAN           TX   AMERICAN FAMILY ASSOCIATION

  970211                  BPED    19970807MD    DENISON           TX   DENISON EDUCATIONAL FOUNDATION

  970211                  BPED    19970807MK    DENISON           TX   RESEARCH ED FOUNDATION INC

  970211   08/07/97   A   BPED    19970219MA    DENISON           TX   BIBLE BROADCASTING NETWORK INC

                                                                       

  970214   07/25/97   A   BPED    19970228MA    FRANKFORT         IN   AMERICAN FAMILY ASSOCIATION

  970214              B   BPED    19970723MZ    LAFAYETTE         IN   HYMN TIME, INC

                                                                       

  970215   08/28/97   A   BPED    19970203MB    FANNETT           TX   AMERICAN FAMILY ASSOCIATION

  970215              B   BPED    19970828MJ    FANNETT           TX   DENISON EDUCATIONAL FOUNDATION

                                                                       

  970216   08/07/97   A   BPED    19970211MB    CUBA CITY         WI   AMERICAN FAMILY ASSOCIATION

  970216              B   BPED    19970226MA    DUBUQUE           IA   UNIVERSITY OF NORTHERN IOWA

  970216              B   BPED    19970807ML    CUBA CITY         WI   POSITIVE PROGRAMMING FOUNDATION

                                                                       

  970217                  BPED    19980224MB    FLORENCE          SC   FRANCIS MARION UNIVERSITY

  970217                  BPED    19980225MF    MARION            SC   MARY V. HARRIS FOUNDATION

  970217                  BPED    19980225MI    BROWNSVILLE       SC   FAMILY RADIO NETWORK INC.

  970217                  BPED    19980225MP    DILLON            SC   CSN INTERNATIONAL

  970217   02/25/98   A   BPED    19970220MB    DILLON            SC   AMERICAN FAMILY ASSOCIATION

                                                                       

  970218                  BPED    19971211MF    HAYFORK           CA   AMERICAN ED BROADCASTING INC

  970218                  BPED    19971211MH    MCKINLEYVILLE     CA   HOWELL MOUNTAIN BROADCASTING CO.

  970218                  BPED    19971211MI    GARBERVILLE       CA   FAMILY STATIONS INC

  970218   12/11/97   A   BPED    19970228MB    EUREKA            CA   PACIFIC CASCADE COMMUNICATIONS
                                                                       CORP.

                                                                       

  970219   08/07/97   A   BPED    19970203MA    CHICKASHA         OK   AMERICAN FAMILY ASSOCIATION

  970219              B   BPED    19970807MY    CHICKASHA         OK   SISTER SHERRY LYNN FOUNDATION
                                                                       INC

                                                                       

  970304   07/25/97   A   BPED    19970324MA    COACHELLA         CA   CREATIVE EDUCATIONAL MEDIA CORP.

  970304                  BPED    19970725MH    COACHELLA         CA   SHEPHERD COMMUNICATIONS, INC.

                                                                       

  970305                  BPED    19970725ML    LONGVIEW          WA   FAMILY STATIONS, INC.

  970305   07/25/97   A   BPED    19970318MA    PINE GROVE        OR   EDUCATIONAL MEDIA FOUNDATION

  970305              B   BPED    19970625ME    GRESHAM           OR   MT. HOOD COMMUNITY COLLEGE
                                                                       DISTRICT

                                                                       

  970306                  BPED    19970527IE    HOUSTON           TX   PACIFICA FOUNDATION

  970306   08/28/97   A   BPED    19970304MB    BRENHAM           TX   AMERICAN FAMILY ASSOCIATION

  970306              B   BPED    19970828MA    COLLEGE STATION   TX   HYMN TIME, INC.

                                                                       

  970310                  BMPED   19970303IB    BEREA             OH   BALDWIN-WALLACE COLLEGE

  970310   10/10/97   A   BPED    19970311MA    PAINESVILLE       OH   LA CADENA MUNDIAL HISPANA, INC.

                                                                       

  970312   12/11/97   A   BPED    19970331MA    ESKO              MN   LINCOLN HIGH SCHOOL ESKO,
                                                                       MINNESOTA

  970312              B   BPED    19971211MC    SUPERIOR          WI   ST OF WI EDUCATIONAL COMM. BOARD

  970312              B   BPED    19971211MN    WENTWORTH         WI   AMERICAN FAMILY ASSOCIATION

                                                                       

  970313   09/19/97   A   BPED    19970311MB    JORDAN VALLEY     OR   EDUCATIONAL MEDIA FOUNDATION

  970313                  BPED    19970919ME    PARMA             ID   SO. ID CORP. OF 7TH DAY
                                                                       ADVENTISTS \*

                                                                       

  970411                  BPED    19971001MC    HUEYTOWN          AL   AMERICAN FAMILY ASSOCIATION

  970411                  BPED    19971009MD    NORTHPORT         AL   MARY V HARRIS FOUNDATION

  970411                  BPED    19971010MA    CONCORDE          AL   ALABAMA HERITAGE ASSOCIATION

  970411                  BPED    19971010MF    BESSEMER          AL   BROADCASTING FOR THE CHALLENGED
                                                                       INC

  970411   10/10/97   A   BPED    19970424MA    BESSEMER          AL   THE MOODY BIBLE INSTITUTE OF
                                                                       CHICAGO

                                                                       

  970414   09/19/97   A   BPED    19970416MC    RAPID CITY        SD   AMERICAN FAMILY ASSOCIATION

  970414              B   BPED    19970918MI    RAPID CITY        SD   BETHESDA CHRISTIAN BROADCASTING
                                                                       INC

                                                                       

  970415   08/07/97   A   BPED    19970418MO    ASHLAND           VA   APPOMATTOX ED FOUNDATION

  970415              B   BPED    19970806MB    RICHMOND          VA   AMERICAN FAMILY ASSOCIATION

  970415              B   BPED    19970807MN    ASHLAND           VA   BROADCASTING FOR THE CHALLENGED
                                                                       INC

                                                                       

  970416   05/29/98   B   BPED    19971104MG    NEW BERLIN        IL   REFORMED BROADCASTING NETWORK,
                                                                       INC

  970416   05/29/98   B   BPED    19971112MC    TAYLORVILLE       IL   BIBLE BROADCASTING NETWORK INC

                                                                       

  9704AX   05/29/98   A   BPED    19970418MN    ELIZABETH CITY    NC   CSN INTERNATIONAL

  9704AX              B   BPED    19980319ML    ELIZABETH CITY    NC   AMERICAN FAMILY ASSOCIATION

  9704AX              B   BPED    19980528MF    ELIZABETH CITY    NC   ELIZABETH EDUCATIONAL
                                                                       INCORPORATED

  9704AX              B   BPED    19980529MJ    ELIZABETH CITY    NC   BROADCASTING FOR THE CHALLENGED
                                                                       INC

                                                                       

  9704P3   01/09/98   A   BPED    19970501MB    COLUMBUS          IN   GOOD SAMARITAN ED RADIO INC

  9704P3              B   BPED    19970403MJ    NASHVILLE         IN   AMERICAN FAMILY ASSOCIATION

                                                                       

  970510   08/28/97   A   BPED    19970519MA    PLAQUEMINE        LA   AMERICAN FAMILY ASSOCIATION

  970510                  BPED    19970828ME    PLAQUEMINE        LA   MARY V. HARRIS FOUNDATION

                                                                       

  970511   09/19/97   A   BPED    19970512MA    GREAT FALLS       MT   AMERICAN FAMILY ASSOCIATION

  970511              B   BPED    19970918ME    GREAT FALLS       MT   PENSACOLA CHRISTIAN COLLEGE,
                                                                       INC.

                                                                       

  970512   09/19/97   A   BPED    19970501MZ    LEVELLAND         TX   AMERICAN FAMILY ASSOCIATION

  970512                  BPED    19961206ME    MORTON            TX   MORTON COCHRAN CONUNT ED. FOUND.

                                                                       

  970514   09/19/97   A   BPED    19970501MF    NEW HAVEN         IN   AMERICAN FAMILY ASSOCIATION

  970514              B   BPED    19970919MB    LAFAYETTE         IN   SOUTHWEST ALLEN COUNTY SCHOOLS
                                                TOWNSHIP               

                                                                       

  970516   09/19/97   A   BPED    19970513MD    FREER             TX   PAULINO BERNAL EVANGELISM

  970516              B   BPED    19970918MD    FREER             TX   GOODNEWS BROADCASTING OF TEXAS

                                                                       

  970517              B   BPED    19971001MA    GOSHEN            IN   AMERICAN FAMILY ASSOCIATION

  970517              B   BPED    19971009MC    WAKARUSA          IN   BIBLE BROADCASTING NETWORK INC

  970517   10/10/97   A   BPED    19970521MD    GOSHEN            IN   PENSACOLA CHRISTIAN COLLEGE INC

                                                                       

  970518   11/14/97       BPED    19970602MC    LEMOORE           CA   LEMOORE UNION HIGH SCHOOL
                                                                       DISTRICT

  970518                  BPED    19971112MB    SELMA             CA   EDUCATIONAL MEDIA FOUNDATION

  970518                  BPED    19971114MM    HANFORD           CA   FAMILY STATIONS, INC

                                                                       

  970519   11/14/97   A   BPED    19970522MC    CAPE MAY COURT    NJ   MARANATHA MINISTRIES
                                                HOUSE                  

  970519              B   BPED    19971010MD    CAPE MAY          NJ   PENSACOLA CHRISTIAN COLLEGE INC
                                                COURTHOUSE             

                                                                       

  970520   11/14/97   A   BPED    19970505MC    MARION            IA   AMERICAN FAMILY ASSOCIATION

  970520              B   BPED    19971030MN    CENTER POINT      IA   FLORIDA PUBLIC RADIO, INC

  970520              B   BPED    19971110MC    MARION            IA   UNIVERSITY OF NORTHERN IOWA

  970520              B   BPED    19971114ME    MARION            IA   BROADCASTING FOR THE CHALLENGED
                                                                       INC

                                                                       

  970521   11/14/97   A   BPED    19970523MJ    RIDGECREST        CA   LIVING PROOF INC

  970521              B   BPED    19971114MG    CHINA LAKE        CA   FAMILY STATIONS INC

                                                                       

  970522   12/11/97   A   BPED    19970507MA    CHEYENNE          WY   AMERICAN FAMILY ASSOCIATION

  970522              B   BPED    19971210MA    CHEYENNE          WY   BROADCASTING FOR THE CHALLENGED
                                                                       INC

                                                                       

  970523              B   BPED    19980109MG    NORCO             LA   BROADCASTING FOR THE CHALLENGED
                                                                       INC

  970523   01/09/98   A   BPED    19970528MD    NORCO             LA   AMERICAN FAMILY ASSOCIATION

                                                                       

  970524   01/09/98   A   BPED    19970516MC    DE QUINCY         LA   AMERICAN FAMILY ASSOCIATION

  970524              B   BPED    19980108MJ    SULPHUR           LA   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

                                                                       

  970604   11/14/97   A   BPED    19970606MB    PUEBLO            CO   FAMILY STATIONS, INC.

  970604              A   BPED    19970702MC    RYE               CO   HARVEST RADIO CORPORATION

  970604              B   BPED    19970702MG    RYE               CO   HARVEST RADIO CORPORATION

  970604              B   BPED    19971112MD    WESTCLIFFE        CO   ED COMMUNICATIONS OF CO SPRINGS
                                                                       INC

  970604              B   BPED    19971114MC    COLORADO CITY     CO   BROADCASTING FOR THE CHALLENGED
                                                                       INC

  970604              B   BPED    19971110MB    COLORADO SPRINGS  CO   EDUCATIONAL COMM. OF CO SPRINGS,
                                                                       INC

  970604              B   BPED    19971112ME    WALSENBURG        CO   ED COMMUNICATIONS OF CO SPRINGS
                                                                       INC

                                                                       

  970605                  BPED    19971007IG    STOCKTON          CA   YOUR CHRISTIAN COMPANION
                                                                       NETWORK, INC.

  970605                  BPED    19971113MD    LODI              CA   EDUCATIONAL MEDIA FOUNDATION

  970605   11/14/97   A   BPED    19970612ML    RIO VISTA         CA   RIVER DELTA UNIFIED SCHOOL
                                                                       DISTRICT

                                                                       

  970608   11/14/97   A   BPED    19970609MF    VICTORIA          TX   PAULINO BERNAL EVANGELISM

  970608              B   BPED    19970918MC    VICTORIA          TX   GOODNEWS BROADCASTING OF TEXAS

  970608              B   BPED    19971114MA    BLOOMINGTON       TX   HOUSTON CHRISTIAN BROADCASTERS
                                                                       INC

  970608              B   BPED    19971114MB    VICTORIA          TX   BROADCASTING FOR THE CHALLENGED
                                                                       INC

                                                                       

  970609                  BPED    19980727MC    PANA              IL   PANA PUBLIC RADIO INC

  970609   07/29/98   A   BPED    19980121MF    PANA              IL   AMERICAN FAMILY ASSOCIATION

                                                                       

  970622   12/11/97   A   BPED    19970630MA    SELMA             AL   MOODY BIBLE INSTITUTE OF CHICAGO

  970622              B   BPED    19971211MA    SELMA             AL   BROADCASTING FOR THE CHALLENGED
                                                                       INC

                                                                       

  970623   12/11/97   A   BPED    19970620MD    ORCHARD VALLEY    WY   EDUCATIONAL MEDIA FOUNDATION

  970623              B   BPED    19970703ME    CHEYENNE          WY   AMERICAN FAMILY ASSOCIATION

  970623              B   BPED    19971117MK    FORT COLLINS      CO   PUBLIC RADIO FOR THE FRONT RANGE

  970623              B   BPED    19971209M1    LOVELAND          CO   COLORADO CHRISTIAN UNIVERSITY

  970623              B   BPED    19971210MB    ORCHARD VALLEY    WY   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

                                                                       

  970624   01/09/98   A   BPED    19970617MA    KALISPELL         MT   STOCKTON CHRISTIAN LIFE COLLEGE
                                                                       INC

  970624              B   BPED    19980108MF    KALISPELL         MT   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

                                                                       

  970625   01/09/98   A   BPED    19970620MF    LAMONT            CA   EDUCATIONAL MEDIA FOUNDATION

  970625              B   BPED    19970915ME    WASCO             CA   AMERICAN FAMILY ASSOCIATION

  970625              B   BPED    19980109MI    BAKERSFIELD       CA   FAMILY STATIONS, INC.

  970625              B   BPED    19980109MK    ARVIN             CA   BROADCASTING FOR THE CHALLENGED
                                                                       INC

  970625              B   BPED    19980109MN    WASCO             CA   MARY V HARRIS FOUNDATION

                                                                       

  970626                  BPED    19980109MJ    MIDLAND           TX   BROADCASTING FOR THE CHALLENGED
                                                                       INC

  970626   01/09/98   A   BPED    19970623MA    MIDLAND           TX   PAULINO BERNAL EVANGELISM

                                                                       

  970628   01/09/98   A   BPED    19970603MB    BROWNSVILLE       TN   HAYWOOD COUNTY BOARD OF
                                                                       EDUCATION

  970628              B   BPED    19980108MI    BROWNSVILLE       TN   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

                                                                       

  970630   03/20/98   A   BPED    19970630MC    PEORIA            IL   PINEBROOK FOUNDATION, INC.

  970630              B   BPED    19970703MF    PEORIA            IL   AMERICAN FAMILY ASSOCIATION

  970630              B   BPED    19980319MG    PEORIA            IL   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  970630              B   BPED    19980319MJ    PEORIA            IL   SIRIUS SYNCOPE INC.

                                                                       

  970631                  BPED    19980318MD    PONCA             NE   ST. GABRIEL COMMUNICATIONS LTD.

  970631   05/12/98   A   BPED    19970612MH    HUBBARD           NE   AMERICAN FAMILY ASSOCIATION

                                                                       

  970726   04/20/98   A   BPH     19970728MA    STRASBURG         CO   J P I RADIO INCORPORATED

  970726              B   BPED    19970814MA    STRASBURG         CO   BROADCASTING OF THE CHALLENGED
                                                                       INC

  970726              B   BPED    19980417MI    STRASBURG         CO   CSN INTERNATIONAL

  970726              B   BPED    19980420MJ    STRASBURG         CO   MARY V. HARRIS FOUNDATION

                                                                       

  970730   01/09/98   A   BPED    19970716MA    MISSOULA          MT   MOODY BIBLE INSTITUTE OF CHICAGO

  970730              B   BPED    19970915MD    MISSOULA          MT   AMERICAN FAMILY ASSOCIATION

  970730              B   BPED    19980108MH    MISSOULA          MT   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  970730              B   BPED    19980109MQ    BUTTE             MT   FAMILY STATIONS INC

                                                                       

  970733   02/25/98   A   BPED    19970701MA    NEW BEDFORD       MA   NEW BEDFORD CHRISTIAN RADIO,
                                                                       INC.

  970733                  BPED    19980225MC    NEW BEDFORD       MA   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

                                                                       

  970737              B   BPED    19980107MC    LEBANON           TN   CUMBERLAND UNIVERSITY

  970737              B   BPED    19980109MR    BOWLING GREEN     KY   WESTERN KENTUCKY UNIVERSITY

  970737   01/09/98   A   BPED    19970728MB    PORTLAND          TN   NASHVILLE CHAMBER OF COMMERCE

                                                                       

  970738   01/23/98   A   BPED    19970714MB    VAIL              CO   PUBLIC BROADCASTING OF COLORADO,
                                                                       INC

  970738              B   BPED    19980122MA    VAIL              CO   BROADCASTING FOR THE CHALLENGED
                                                                       INC

  970738              B   BPED    19980123MO    VAIL              CO   DENVER ED BROADCASTING INC

                                                                       

  970739   05/10/99   A   BPED    19970707MA    MADISON           FL   PUBLIC RADIO, INC.

  970739                  BPED    19990510MF    MONTICELLO        FL   EDUCATIONAL MEDIA FOUNDATION

  970739                  BPED    19990510ML    MONTICELLO        FL   FM 91.9, INC.

                                                                       

  970814   03/20/98   A   BPED    19970804MD    NANTUCKET         MA   NANTUCKET PUBLIC RADIO INC

  970814              B   BPED    19980319MH    NANTUCKET         MA   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

                                                                       

  970815   01/09/98       BPED    19980108MG    MONROEVILLE       AL   OKALOOSA PUBLIC RADIO, INC.

  970815                  BPED    19980226MD    MONROEVILLE       AL   AMERICAN FAMILY ASSOCIATION

                                                                       

  970817   01/09/98   A   BPED    19970801MH    SIOUX FALLS       SD   AMERICAN FAMILY ASSOCIATION

  970817              B   BPED    19980106MB    SIOUX FALLS       SD   CSN INTERNATIONAL

  970817              B   BPED    19980108MK    SIOUX FALLS       SD   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

                                                                       

  970823   02/25/98   A   BPED    19970820MA    RATHDRUM          ID   AMERICAN FAMILY ASSOCIATION

  970823              B   BPED    19980219MA    POST FALLS        ID   KOOTENAI COUNTY BAPTIST CHURCH

  970823              B   BPED    19980224MA    SPOKANE           WA   SPOKANE PUBLIC RADIO INC.

  970823              B   BPED    19980225MB    RATHDRUM          ID   BROADCASTING FOR THE CHALLENGED
                                                                       INC.

  970823              B   BPED    19980225MH    RATHDRUM          ID   MARY V. HARRIS FOUNDATION

  970823              B   BPED    19980225MO    RATHDRUM          ID   CSN INTERNATIONAL

                                                                       

  970824   02/25/98   A   BPED    19970818MB    LUMPKIN           GA   SPANISH CULTURAL EDUCATION, INC.

  970824              B   BPED    19980225MD    AMERICUS          GA   FAMILY STATIONS INC.

                                                                       

  970826                  BPED    19980611ME    KINGMAN           AZ   AMERICAN FAMILY ASSOCIATION

  970826                  BPED    19980619MH    KINGMAN           AZ   BROADCASTING FOR THE CHALLENGED
                                                                       INC.

  970826                  BPED    19980619MK    KINGMAN           AZ   MOHAVE COMMUNITY COLLEGE

  970826   06/19/98   A   BPED    19970822MA    KINGMAN           AZ   CSN INTERNATIONAL

                                                                       

  970830                  BPED    19980317MA    KEY WEST          FL   S. F. BROADCASTING CORP.

  970830                  BPED    19980318MF    KEY WEST          FL   BROADCASTING OF THE CHALLENGED
                                                                       INC.

  970830   03/20/98   A   BPED    19970815MA    KEY WEST          FL   GOOD IDEA INCORPORATED

                                                                       

  97091E   01/23/98   A   BPED    19970910MC    CLARKSTON         WA   UPPER COLUMBIA MEDIA ASSOCIATION

  97091E              B   BPED    19980123MB    ASOTIN            WA   LIVING FAITH FELLOWSHIP ED
                                                                       MINISTRIE

                                                                       

  970928                  BPED    19980226MB    BURAS             LA   EMPIRE BROADCASTING INC

  970928   02/25/98   A   BPED    19970903MA    BURAS             LA   AMERICAN FAMILY ASSOCIATION

                                                                       

  970929                  BPED    19980320MK    MASSEY            MD   UNIVERSITY OF MD EASTERN SHORE

  970929   03/20/98   A   BPED    19970915MB    HARRINGTON        DE   AMERICAN FAMILY ASSOCIATION

  970929              B   BPED    19980320MD    HARRINGTON        DE   EAGLE\'S NEST FELLOWSHIP CHURCH

  970929              B   BPED    19980320MM    HARRINGTON        DE   MARY V. HARRIS FOUNDATION

  970929              B   BPED    19980320MP    DENTON            MD   POSITIVE ALTERNATIVE RADIO INC

                                                                       

  970930   03/20/98   A   BPED    19970915MA    BISMARCK          ND   AMERICAN FAMILY ASSOCIATION

  970930              B   BPED    19980320ME    BISMARCK          ND   FAMILY STATIONS INC.

                                                                       

  970931   03/20/98   A   BPED    19970909MD    COOS BAY          OR   THE STATE OF OREGON

  970931                  BPED    19980318MI    ROSEBURG          OR   WILLIAM PATRICK DONNELLY
                                                                       MINISTRIES, INC.

  970931                  BPED    19980318MJ    EMIGRANT VALLEY   OR   EMIGRANT VALLEY PUBLIC RADIO,
                                                                       INC.

  970931                  BPED    19980319MM    HORNBROOK         CA   OREGON EDUCATIONAL RADIO
                                                                       SERVICES, INC.

  970931                  BPED    19980319MN    HORNBROOK         CA   HORNBROOK DEVELOPMENT CENTER,
                                                                       INC.

  970931                  BPED    19980319MO    EMIGRANT VALLEY   OR   EMIGRANT VALLEY CHRISTIAN CHURCH

  970931                  BPED    19980320ML    COOS BAY          OR   CSN INTERNATIONAL

                                                                       

  970932                  BPED    19971202IB    RICHMOND          VA   CENTRAL VIRGINIA EDUC. TV CORP.

  970932                  BPED    19980311MD    CAPE CHARLES      VA   AMERICAN FAMILY ASSOCIATION

  970932                  BPED    19980318MH    HEATHSVILLE       VA   CENTRAL VA ED TELECOMM.
                                                                       CORPORATION

  970932                  BPED    19980319MD    BELLE HAVEN       VA   MARY V. HARRIS FOUNDATION

  970932                  BPED    19980319MF    CAPE CHARLES      VA   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  970932                  BPED    19980320MI    CAPE CHARLES      VA   STOCKTON CHRISTIAN LIFE COLLEGE
                                                                       INC

  970932              B   BPED    19980320MJ    CHERITON          VA   DELMARVA EDUCATIONAL ASSOCIATION

  970932                  BPED    19980320MN    EASTVILLE         VA   BY THE CAPE BROADCASTING INC.

  970932   03/20/98   A   BPED    19970903MB    CAPE CHARLES      VA   EDUCATIONAL MEDIA CORPORATION

  970932              A   BPED    19971015MB    MATHEWS           VA   HAMPTON ROADS ED TELECOM ASSOC.
                                                                       INC

                                                                       

  970933   05/12/98   A   BPED    19970919MD    POCOLA            OK   EDUCATIONAL MEDIA FOUNDATION

  970933              B   BPED    19980512MS    POCOLA            OK   BROADCASTING FOR THE CHALLENGED
                                                                       INC

                                                                       

  970935                  BPED    19980617ME    LAKEPORT          CA   LAKE COUNTY COMMUNITY RADIO INC

  970935                  BPED    19980618MB    REDWOOD VALLEY    CA   REDWOOD VALLEY BROADCASTERS INC.

  970935                  BPED    19980619MI    LAYTONVILLE       CA   FAMILY STATIONS INC

  970935                  BPED    19980619ML    REDWOOD VALLEY    CA   STOCKTON CHRISTIAN LIFE COLLEGE

  970935   06/19/98   A   BPED    19970917ME    REDWOOD VALLEY    CA   EDUCATIONAL MEDIA FOUNDATION

                                                                       

  970936   03/20/98   A   BPED    19970929MB    TRIMBLE           CO   ED COMMUNICATIONS OF COLORADO
                                                                       SPRINGS, INC.

  970936              B   BPED    19980319ME    DURANGO           CO   PUBLIC BROADCASTING OF COLORADO
                                                                       INC.

                                                                       

  970937   05/29/98   A   BPED    19980306MC    FARMINGTON        MO   BD OF REGENTS, SE MISSOURI STATE
                                                                       UNIV.

  970937              A   BPED    19970925ME    PERRYVILLE        MO   EVANGELISTIC CENTER

  970937              B   BPED    19980529MH    FARMINGTON        MO   BROADCASTING FOR THE CHALLEGED
                                                                       INC

                                                                       

  970938   07/07/98   A   BPED    19970917MA    SCOTTS HILL       NC   FAMILY RADIO NETWORK INC

  970938              B   BPED    19980210MB    LOCK FOLLY        NC   GRACE MISSIONARY BAPTIST CHURCH
                                                TOWNSHIP               

  970938              B   BPED    19980701MA    SCOTTS HILL       NC   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  970938              B   BPED    19980707MB    OGDEN             NC   NORTH CAROLINA PUBLIC BROADCAST
                                                                       INC

                                                                       

  970939                  BPED    19981125MB    DESCHUTES RIVER   OR   WILLIAM PATRICK DONNELLY
                                                                       MINISTRIES, INC.

  970939                  BPED    19981127MD    BEND              OR   JESUIT MISSION, INC.

  970939                  BPED    19981203MO    REDMOND           OR   CSN INTERNATIONAL

  970939              B   BPED    19980605MD    REDMOND           OR   ST OF OREGON, ST BD OF HIGHER ED

  970939              B   BPED    19981203MF    SISTERS           OR   LANE COMMUNITY COLLEGE

  970939   12/03/98   A   BPED    19970925MF    SISTERS           OR   EDUCATIONAL MEDIA FOUNDATION

                                                                       

  970940                  BPED    19980812MI    ASPEN             CO   ASPEN PUBLIC RADIO INC.

  970940                  BPED    19980813MD    NEW CASTLE        CO   EDUC. COMMUN. OF COLORADO
                                                                       SPRINGS, I

  970940                  BPED    19980814MH    GLENWOOD SPRINGS  CO   PITKIN COUNTY

  970940   08/14/98   A   BPED    19970924MH    GLENWOOD SPRINGS  CO   PUBLIC BROADCASTING OF COLORADO
                                                                       INC

                                                                       

  970944                  BPED    19990506ME    RAEFORD           NC   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  970944   05/10/99   A   BPED    19970925MB    RAEFORD           NC   AMERICAN FAMILY ASSOCIATION

                                                                       

  971013                  BPED    19980415MB    SIDNEY            CO   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  971013                  BPED    19980417MC    GYPSUM            CO   COLORADO CHRISTIAN UNIVERSITY

  971013   04/20/98   A   BPED    19971014MB    SIDNEY            CO   ED COMMUNICATIONS OF CO SPRINGS
                                                                       INC

                                                                       

  971014              B   BPED    19971017MA    RAPID CITY        SD   BETHESDA CHRISTIAN BROADCASTING
                                                                       INC

  971014                  BPED    19980417MB    RAPID CITY        SD   CSN INTERNATIONAL

  971014                  BPED    19980420MG    RAPID CITY        SD   FAMILY STATIONS INC.

  971014   04/20/98   A   BPED    19971020MB    RAPID CITY        SD   AMERICAN FAMILY ASSOCIATION

                                                                       

  971015   04/20/98   A   BPED    19971009MA    MARSHALLTOWN      IA   AMERICAN FAMILY ASSOCIATION

  971015              B   BPED    19980417MH    MARSHALLTOWN      IA   MARSHALLTOWN ED PLUS INC.

                                                                       

  971016   05/12/98   A   BPED    19971016MC    RANDOM LAKE       WI   ST OF WI ED COMMUNICATIONS BOARD

  971016              B   BPED    19980506MD    PLYMOUTH          WI   AMERICAN FAMILY ASSOCIATION

  971016              B   BPED    19980512ME    KIEL              WI   JUBILATION MINISTRIES INC

  971016              B   BPED    19980512MG    FOND DU LAC       WI   CORNERSTONE COMMUNITY RADIO,
                                                                       INC.

                                                                       

  971017   05/12/98   A   BPED    19971008MA    HASTINGS          NE   AMERICAN FAMILY ASSOCIATION

  971017              B   BPED    19980512MH    GRAND ISLAND      NE   STOCKTON CHRISTIAN LIFE COLLEGE,
                                                                       INC

  971017              B   BPED    19980512MQ    HASTINGS          NE   BROADCASTING FOR THE CHALLENGED
                                                                       INC

                                                                       

  971018   05/12/98   A   BPED    19971016MD    BEND              OR   COMMUNICATIONS ADVISOR BD OF THE
                                                                       DIO

  971018              B   BPED    19980327MA    BEND              OR   PENSACOLA CHRISTIAN COLLEGE INC

  971018              B   BPED    19980417MF    BEND              OR   CSN INTERNATIONAL

  971018              B   BPED    19980430MB    BEND              OR   AMERICAN FAMILY ASSOCIATION

  971018              B   BPED    19980512MA    LA PINE           OR   EDUCATIONAL MEDIA FOUNDATION

                                                                       

  971019                  BPED    19980204MA    COATESVILLE       PA   AMERICAN FAMILY ASSOCIATION

  971019                  BPED    19980512MB    COATESVILLE       PA   FAMILY STATIONS INC

  971019                  BPED    19980512MF    COATESVILLE       PA   TEMPLE UN OF THE COMMONWEALTH
                                                                       SYS OF

  971019                  BPED    19980512MI    MORGANTOWN        PA   FOUR RIVERS COMMUNITY B/CASTING
                                                                       CORP

  971019   05/12/98   A   BPED    19971009ME    COATESVILLE       PA   MERCER COUNTY COMMUNICTY COLLEGE

                                                                       

  971022                  BPED    19981005ME    KUNA              ID   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  971022                  BPED    19981006MC    TWIN FALLS        ID   YOUR CHRISTIAN COMPANION
                                                                       NETWORK, INC.

  971022                  BPED    19981006MI    BUHL              ID   SO ID CORP OF SEVENTH-DAY
                                                                       ADVENTISTS

  971022                  BPED    19981006MJ    KUNA              ID   CSN INTERNATIONAL

  971022   10/06/98   A   BPED    19971027MC    KUNA              ID   EDUCATIONAL MEDIA FOUNDATION

                                                                       

  971029                  BPED    19990506MC    SELMER            TN   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  971029   05/10/99       BPED    19971027MA    SELMER            TN   AMERICAN FAMILY ASSOCIATION

                                                                       

  9710X3   03/20/98   A   BPED    19971020MA    GREAT FALLS       MT   AMERICN FAMILY ASSOCIATION

  9710X3              B   BPED    19980318ME    GREAT FALLS       MT   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  9710X3              B   BPED    19980320MG    GREAT FALLS       MT   PENSACOLA CHRISTIAN COLLEGE INC

  9710X3              B   BPED    19980320MO    GREAT FALLS       MT   FAMILY STATIONS INC

                                                                       

  971109   04/20/98   A   BPED    19971121MA    LOWELL            IN   AMERICAN FAMILY ASSOCIATION

  971109              B   BPED    19980127MB    LYNWOOD           IL   CHRISTIAN ED ASSOCIATION

  971109              B   BPED    19980415MA    LOWELL            IN   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  971109              B   BPED    19980417ME    LOWELL            IN   CSN INTERNATIONAL

                                                                       

  971110                  BPED    19980420IA    WOOSTER           OH   KENT STATE UNIVERSITY

  971110   04/20/98   A   BPED    19971117MS    NEWARK            OH   RIVERSIDE MINISTRIES

                                                                       

  971111   05/12/98   A   BPED    19971107ML    EDGEWATER         FL   MIMS COMMUNITY RADIO, INC.

  971111              B   BPED    19980512MK    DELTONA           FL   HISPANIC BROADCAST SYSTEM, INC.

                                                                       

  971112              B   BPED    19971125ID    FORT WORTH        TX   TEXAS CHRISTIAN UNIVERSITY

  971112              B   BPED    19980512MD    MINERAL WELLS     TX   TEXAS CHRISTIAN UNIVERISTY

  971112   05/12/98   A   BPED    19971117MJ    WEATHERFORD       TX   CSSI NON-PROFIT ED BROADCASTING
                                                                       CORP

                                                                       

  971113   05/12/98   A   BPED    19971103MD    FREELAND          MI   AMERICAN FAMILY ASSOCIATION

  971113              B   BPED    19980512MT    FREELAND          MI   CSN INTERNATIONAL

                                                                       

  971114   05/12/98   A   BPED    19971112MA    VALPARAISO        IN   AMERICAN FAMILY ASSOCIATION

  971114              B   BPED    19980512MU    CHESTERTON        IN   BROADCASTING FOR THE CHALLENGED
                                                                       INC

  971114              B   BPED    19980512MV    SOUTH HAVEN       IN   THE WBEZ ALLIANCE INC

  971114              B   BPED    19980512MP    VALPARAISO        IN   CSN INTERNATIONAL

                                                                       

  971115                  BPED    19980512MR    BUNKIE            LA   BROADCASTING FOR THE CHALLENGED
                                                                       INC

  971115   05/12/98   A   BPED    19971112MK    BUNKIE            LA   AMERICAN FAMILY ASSOCIATION

                                                                       

  971116   05/12/98   A   BPED    19971121MB    NORWALK           OH   CLEVELAND PUBLIC RADIO, INC.

  971116              B   BPED    19980512MW    NORWALK           OH   KENT STATE UNIVERSITY

                                                                       

  971117   05/12/98   A   BPED    19971117MD    ELWOOD            KS   AMERICAN FAMILY ASSOCIATION

  971117              B   BPED    19971201MA    COUNTRY CLUB      MO   COMMUNITY BROADCASTING INC

                                                                       

  971118   07/07/98   A   BPED    19971105MA    ARANSAS PASS      TX   PAULINO BERNAL EVAGELISM

  971118              B   BPED    19980701MB    ARANSAS PASS      TX   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  971118              B   BPED    19980707ME    ALICE             TX   FAMILY STATIONS INC

                                                                       

  971119                  BPED    19981006MF    MOSS BEACH        CA   CALIFORNIA HARDIVES INC.

  971119   10/06/98   A   BPED    19971113MB    PESCADERO         CA   PESCADERO PUBLIC RADIO SERVICES
                                                                       INC

                                                                       

  971147                  BPED    19980727ME    WINCHESTER        IL   WINCHESTER PUBLIC RADIO INC

  971147   07/29/98   A   BPED    19971211MB    WHITE HALL        IL   CORNERSTONE COMMUNITY RADIO INC

                                                                       

  971209                  BPED    19980512MC    RIVERSIDE         MI   SUPERIOR COMMUNICATIONS

  971209                  BPED    19980512MJ    MICHIGAN CITY     IN   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  971209   05/12/98   A   BPED    19971216MA    MICHIGAN CITY     IN   AMERICAN FAMILY ASSOCIATION

                                                                       

  971211   06/19/98   A   BPED    19971203MA    WEST POINT        CA   WAY-FM MEDIA GROUP INC

  971211              B   BPED    19980619MB    LIVINGSTON        CA   YOUR CHRISTIAN COMPANION
                                                                       NETWORK, INC.

  971211              B   BPED    19980619MD    EAST SONORA       CA   EDUCATIONAL MEDIA FOUNDATION

  971211              B   BPED    19980619MJ    SAN ANDREAS       CA   CALIFORNIA ST UN, SACRAMENTO

  971211              B   BPED    19980619MM    DORRINGTON        CA   STOCKTON CHRISTIAN LIFE COLLEGE

                                                                       

  971212   05/29/98   A   BPED    19971208MA    SHERIDAN          WY   AMERICAN FAMILY ASSOCIATION

  971212              B   BPED    19980206MB    SHERIDAN          WY   MONTANA STATE
                                                                       UNIVERSITY-BILLINGS

  971212              B   BPED    19980529MB    SHERIDAN          WY   CSN INTERNATIONAL

                                                                       

  971213   05/29/98   A   BPED    19971205MA    LOGAN             UT   LISTNERS COMMUNITY RADIO OF UTAH
                                                                       INC

  971213              B   BPED    19980529ME    LOGAN             UT   BROADCASTING FOR THE CHALLENGED
                                                                       INC

                                                                       

  971215                  BPED    19980824MA    LARAMIE           WY   BROADCASTING FOR THE CHALLENGED
                                                                       INC

  971215                  BPED    19980825MB    CHUGWATER         WY   COLORADO CHRISTIAN UNIVERSITY

  971215                  BPED    19980825MC    CENTENNIAL        WY   ED COMMUNICATIONS OF COLORADO
                                                                       SPRING

  971215                  BPED    19980825MG    LARAMIE           WY   LARAMINE UNION BROADCASTING INC

  971215   08/26/98   A   BPED    19971208MD    LARAMIE           WY   WESTERN INSPRIATIONAL
                                                                       BROADCASTERS I

                                                                       

  971216                  BPED    19980313IB    MONROE            CT   MONROE BOARD OF EDUCATION

  971216                  BPED    19980825MA    MONTGOMERY        NY   MONTGOMERY NYC BROADCASTING INC

  971216                  BPED    19980826MJ    MIDDLETOWN        NY   PENSACOLA CHRISTIAN COLLEGE,
                                                                       INC.

  971216   08/26/98   A   BPED    19971230MB    MONTGOMERY        NY   RIVER BROADCASTING INC

                                                                       

  971218              B   BPED    19980813MF    STERLING          CO   EDUC. COMMUN. OF COLORADO
                                                                       SPRINGS, I

  971218              B   BPED    19980814MI    STERLING          CO   BROADCASTING FOR THE CHALLENGED
                                                                       INC

  971218   08/14/98   A   BPED    19971222MB    STERLING          CO   COLORADO CHRISTIAN UNIVERSITY

                                                                       

  980102   06/19/98   A   BPED    19980123ME    CUERO             TX   PAULINO BERNAL EVANGELISM

  980102   01/29/01       BPED    19980513MC    CUERO             TX   GOOD NEWS BROADCASTING OF TEXAS

                                                                       

  980103                  BPED    19980619MF    SOUTH CHARLESTON  WV   BROADCASTING FOR THE CHALLENGED
                                                                       INC.

  980103   06/19/98   A   BPED    19980113MB    SOUTH CHARLESTON  WV   AMERICAN FAMILY ASSOCIATION

                                                                       

  980104                  BPED    19980618MF    CASPER            WY   CASPER LEARNING FM INC

  980104                  BPED    19980619MG    CASPER            WY   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  980104   06/19/98   A   BPED    19980112MB    CASPER            WY   AMERICAN FAMILY ASSOCIATION

                                                                       

  980105                  BPED    19980706MB    OLATHE            CO   COLORADO CHRISTIAN UNIVERSITY

  980105                  BPED    19980707MD    COLONA            CO   CSN INTERNATIONAL

  980105   07/07/98   A   BPED    19980107MB    COLONA            CO   ED COMMUNIC. OF COLORADO
                                                                       SPRINGS, INC.

                                                                       

  980106   07/07/98   A   BPED    19980113MA    STEPHENVILLE      TX   FRONTLINE INTERNATIONAL, INC.

  980106              B   BPED    19980122MD    STEPHENVILLE      TX   CSSI NONPROFIT EDUC.
                                                                       BROADCASTING CORP.

                                                                       

  980107                  BPED    19980602MA    SPRINGFIELD       OH   THE BOARD OF DIRECTORS OF
                                                                       WITTENBERG

  980107                  BPED    19980707MC    DELAWARE          OH   LIFE RADIO MINISTRIES

  980107   07/07/98   A   BPED    19980105MA    URBANA            OH   AMERICAN FAMILY ASSOCIATION

                                                                       

  980108                  BPED    19980710ME    YOAKUM            TX   HOUSTON CHRISTIAN BROADCASTERS
                                                                       INC

  980108                  BPED    19980724MD    GONZALES          TX   MARANATHA CHURCH OF LAREDO INC.

  980108                  BPED    19980729MA    GONZALES          TX   SPIRIT OF AMERICA ASSOCIATION

  980108                  BPED    19980729MJ    BAY CITY          TX   FAMILY STATION, INC.

  980108   07/29/98   A   BPED    19980123MD    GONZALES          TX   PAULINO BERNAL EVANGELISM

                                                                       

  980109   07/29/98   A   BPED    19980108MN    PRINCETON         WV   AMERICAN FAMILY ASSOCIATION

  980109              B   BPED    19980729MC    CRAB ORCHARD      WV   POSITIVE ALTERNATIVE RADIO INC

                                                                       

  980110                  BPED    19980424MA    BRECKENRIDGE      TX   AMERICAN FAMILY ASSOCIATION

  980110                  BPED    19980729ME    BRECKENRIDGE      TX   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  980110                  BPED    19980729MF    EASTLAND          TX   BROADCASTING FOR THE CHALLENGED
                                                                       INC.

  980110   07/29/98   A   BPED    19980122MB    EASTLAND          TX   CSSI NON-PROFIT ED BROADCASTING
                                                                       CORP

                                                                       

  980111                  BPED    19980602MC    NEW ULM           MN   MINN-IOWA CHRISTIAN B/G
                                                                       FOUNDATION

  980111                  BPED    19980729MG    NEW ULM           MN   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  980111   07/29/98   A   BPED    19980105MD    NEW ULM           MN   AMERICAN FAMILY ASSOCIATION

                                                                       

  980114   01/29/01       BPED    19980724ME    CEDAR CREEK       FL   CEDAR CREEK PUBLIC RADIO, INC.

  980114                  BPED    19980727MF    BUSHNELL          FL   WEST COAST EDUCATIONAL, INC.

  980114                  BPED    19980728MB    BUSHNELL          FL   FLORIDA PUBLIC RADIO, INC.

  980114                  BPED    19980610MD    WEBSTER           FL   WEBSTER CHRISTIAN EDUCATIONAL
                                                                       ASSN

                                                                       

  980115                  BPED    19980729MD    PAHALA            HI   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  980115   07/29/98   A   BPED    19980121ME    PAHALA            HI   KAU HIGH SCHOOL

                                                                       

  980116                  BPED    19980824ME    ROSWELL           NM   BROADCASTING FOR THE CHALLENGED
                                                                       INC

  980116                  BPED    19980826MG    SOCORRO           NM   FAMILY STATIONS, INC.

  980116   08/26/98   A   BMPED   19980123MG    ALAMOGORDO        NM   SOUTHERN NEW MEXICO RADIO
                                                                       FOUNDATION

                                                                       

  980117   08/26/98   A   BPED    19980126MD    BILLINGS          MT   WESTERN INSPIRATIONAL BRD/CATERS
                                                                       INC

  980117              B   BPED    19971113ME    BILLINGS          MT   AMERICAN FAMILY ASSOCIATION

  980117              B   BPED    19980824MC    BILLINGS          MT   BROADCASTING FOR THE CHALLENGED
                                                                       INC

  980117              B   BPED    19980824MD    BILLINGS          MT   BROADCASTING FOR THE CHALLENGED
                                                                       INC

  980117              B   BPED    19980824MG    BILLINGS          MT   BROADCASTING FOR THE CHALLENGED
                                                                       INC

  980117              B   BPED    19980825MF    PARK CITY         MT   COLORADO CHRISTIAN UNIVERSITY

                                                                       

  980118                  BPED    19980529MF    TELLURIDE         CO   BROADCASTING FOR THE CHALLEGED
                                                                       INC

  980118   05/29/98   A   BPED    19980107MF    PLACERVILLE       CO   EDUCATIONAL COMM. OF COLORADO
                                                                       SPRING

                                                                       

  980119              B   BPED    19980212MA    STEPHENVILLE      TX   AMERICAN FAMILY ASSOCIATION

  980119                  BPED    19980730ME    STEPHENVILLE      TX   THE NORTH TEXAS MUSIC
                                                                       FOUNDATION, IN

  980119                  BPED    19980901MH    STEPHENVILLE      TX   FT. WORTH STEPHENVILLE FM INC

  980119                  BPED    19980909MD    SELDEN            TX   FRONTLINE INTERNATIONAL INC.

  980119   09/09/98   A   BPED    19980122MC    BLUFF DALE        TX   CSSI NON PROFIT ED BROADCASTING
                                                                       CORP

                                                                       

  980120                  BPED    19980313IB    EDEN              OH   SHOFAR BROADCASTING CORP

  980120                  BPED    19980716MR    EDEN              OH   MARANATHA BROADCASTING INC.

  980120                  BPED    19980901MD    GROVE CITY        OH   AMERICAN FAMILY ASSOCIATION

  980120   09/09/98   A   BPED    19980113MD    WAVERLY           OH   LIFE RADIO MINISTRIES INC

                                                                       

  980121   09/09/98   A   BPED    19980115MB    BAY CITY          TX   AMERICAN FAMILY ASSOCIATION

  980121              B   BPED    19980901MF    BAY CITY          TX   HOUSTON BAY CITY INC

                                                                       

  980122                  BPED    19980814MJ    BRUSH             CO   BROADCASTING FOR THE CHALLENGED
                                                                       INC

  980122   08/14/98   A   BPED    19980115MA    BRUSH             CO   ED COMMUNICATIONS OF CO SPGS INC

                                                                       

  980125                  BPED    19980702MA    MIDLAND           TX   PENSACOLA CHRISTIAN COLLEGE,
                                                                       INC.

  980125                  BPED    19981001MB    MIDLAND           TX   MIDLAND STEREO REY INC.

  980125                  BPED    19981006MM    MIDLAND           TX   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  980125   10/06/98   A   BPED    19980120MH    MIDLAND           TX   AMERICAN FAMILY ASSOCIATION

                                                                       

  980127   07/29/98   A   BPED    19980105MC    ROCHESTER         IN   AMERCIAN FAMILY ASSOCIATION

  980127              B   BPED    19980727MA    ROCHESTER         IN   ROCHESTER COMMUNITY RADIO INC

                                                                       

  9801XX                  BPED    19980922MA    PORT SULPHUR      LA   NEW ORLEANS Y2K INC

  9801XX   09/23/98   A   BPED    19980120MG    PORT SULPHUR      LA   AMERICAN FAMILY ASSOCIATION

                                                                       

  980201                  BPED    19980729MK    ROSEBURG          OR   FAMILY STATIONS, INC.

  980201   07/29/98   A   BPED    19980205MA    ROSEBURG          OR   LANE COMMUNITY COLLEGE

                                                                       

  980202   05/29/98   A   BPED    19980204ME    POPLAR BLUFF      MO   BD OF REGENTS, SE MO ST
                                                                       UNIVERSITY

  980202              B   BPED    19980528MA    POPLAR BLUFF      MO   POPLAR BLUFF EDUCATIONAL INC

  980202              B   BPED    19980528MC    POPLAR BLUFF      MO   BIBLE BROADCASTING NETWORK INC

  980202              B   BPED    19980528MI    KENNETT           MO   AMERICAN FAMILY ASSOCIATION

  980202              B   BPED    19980529MI    POPLAR BLUFF      MO   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

                                                                       

  980204   05/29/98   A   BPED    19980204MC    CAVE JUNCTION     OR   THE ST BD HGHR ED/SO OR
                                                                       UNIVERSITY

  980204              B   BPED    19980123MM    SELMA             OR   EDUCATIONAL MEDIA FOUNDATION

  980204              B   BPED    19980528MB    CAVE JUNCTION     OR   PENSACOLA CHRISTIAN COLLEGE INC.

  980204              B   BPED    19980528MG    CAVE JUNCTION     OR   FAMILY STATIONS INC.

                                                                       

  980205                  BPED    19980901MG    COMFORT           TX   SAN ANTONIO COMFORT, INC

  980205                  BPED    19980908MC    DRIPPING SPRINGS  TX   AMERICAN B/CASTING EDUC.
                                                                       FOUNDATION

  980205   09/09/98   A   BPED    19980213MA    FREDERICKSBURG    TX   HOUSTON CHRISTIAN BROADCASTERS
                                                                       INC

                                                                       

  980206                  BPED    19980218MD    BEND              OR   CSN INTERNATIONAL

  980206                  BPED    19980626MA    BEND              OR   AMERICAN FAMILY ASSOCIATION

  980206                  BPED    19980826MI    LEBANON           OR   EDUCATIONAL MEDIA FOUNDATION

  980206   08/26/98   A   BPED    19980126MB    BEND              OR   LANE COMMUNITY COLLEGE

                                                                       

  980207                  BPED    19981005MD    SAN ANGELO        TX   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  980207   10/06/98   A   BPED    19980226MA    SAN ANGELO        TX   ANGELO CHRISTIAN MINISTRIES INC

                                                                       

  980208                  BPED    19980810MB    AUGUSTA           MI   AMERICAN FAMILY ASSOCIATION

  980208                  BPED    19980814MA    SPRINGFIELD       MI   CORNERSTONE BAPTIST EDUCATIONAL

  980208                  BPED    19980814MD    BELDING           MI   SUPERIOR COMMUNICATIONS

  980208                  BPED    19980814MG    AUGUSTA           MI   BROADCASTING FOR THE CHALLENGED
                                                                       INC.

  980208   08/14/98   A   BPED    19980218MB    AUGUSTA           MI   PENSACOLA CHRISTIAN COLLEGE INC

                                                                       

  980209              B   BPED    19980622MB    EUREKA SPRINGS    AR   NEW LIFE EVANGELISTIC CENTER,
                                                                       INC.

  980209              B   BPED    19990311MD    ANDERSON          MO   CSN INTERNATIONAL

  980209              B   BPED    19990311MJ    BARTLESVILLE      OK   EDUCATIONAL MEDIA FOUNDATION

  980209   03/11/99   A   BPED    19980225ME    GROVE             OK   GROVE BROADCASTING INC.

                                                                       

  980210                  BPED    19980909MO    TEXARKANA         AR   BROADCASTING FOR THE CHALLENGED
                                                                       INC

  980210   09/09/98   A   BPED    19980204MD    TEXARKANA         AR   PAULINO BERNAL EVANGELISM

                                                                       

  980211   11/10/98   A   BPED    19980220MF    LAKE CITY         MI   GREAT LAKES COMMUNITY B/CASTING,
                                                                       INC

  980211              B   BPED    19981110MP    LAKE CITY         MI   SUPERIOR COMMUNICATIONS

  980211              B   BPED    19981110MQ    LAKE CITY         MI   NASSAWADOX FM INC.

                                                                       

  98022S                  BPED    19980923MI    DANNEMORA         NY   AMERICAN EDUCATIONAL
                                                                       BROADCAST/G, IN

  98022S   09/23/98   A   BPED    19980202MA    MALONE            NY   MARS HILL BROADCASTING CO INC

                                                                       

  9802XC                  BPED    19980922MC    COLUSA            CA   SACRAMENTO BRAIN TRUST INC

  9802XC                  BPED    19980922MD    SUTTER            CA   CALIFORNIA STATE UN SACRAMENTO

  9802XC                  BPED    19980923ME    LIVE OAK          CA   FAMILY STATIONS, INC.

  9802XC                  BPED    19980923MJ    WILLIAMS          CA   EDUCATIONAL MEDIA FOUNDATION

  9802XC                  BPED    19980923MK    SUTTER            CA   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  9802XC   09/23/98   A   BPED    19980218MC    SUTTER            CA   CSN INTERNATIONAL

                                                                       

  980301                  BPED    19980826MH    ADAMS             WI   STATE OF WISC. EDUCATION COMM.
                                                                       BOARD

  980301   08/26/98   A   BPED    19980309MC    RICHLAND CENTER   WI   RICHLAND CENTER FELLOWSHIP

                                                                       

  980302   08/26/98   A   BPED    19980331MB    MAPPSVILLE        VA   MIRACLE TEMPLE OF FAITH
                                                                       MINISTIRES

  980302              B   BPED    19980824MF    MAPPSVILLE        VA   BROADCASTING FOR THE CHHALLENGED
                                                                       INC

  980302              B   BPED    19980825MH    NASSAWADOX        VA   NASSAWADOX FM INC

                                                                       

  980303   08/26/98   A   BPED    19980318MG    CHASE CITY        VA   CENTRAL VA ED TELECOMMUNICATIONS
                                                                       COR

  980303              B   BPED    19980826MB    CHASE CITY        VA   VISION COMMUNICATIONS INC

                                                                       

  980304   08/26/98   A   BPED    19980324MA    SALEM             OR   WESTERN BAPTIST COLLEGE

  980304              B   BPED    19980824MB    SALEM             OR   BROADCASTING FOR THE CHALLENGED
                                                                       INC

  980304              B   BPED    19980826ML    SALEM             OR   CSN INTERNATIONAL

                                                                       

  980305                  BPED    19980909MA    KEY WEST          FL   PUBLIC RADIO INC

  980305                  BPED    19980909MN    STOCK ISLAND      FL   MARY V. HARRIS FOUNDATION

  980305                  BPED    19980909MT    KEY WEST          FL   BROADCASTING FOR THE CHALLENGED
                                                                       INC

  980305   09/09/98   A   BPED    19980316MD    KEY WEST          FL   SOUTHERNMOST EDUCATIONAL INC

                                                                       

  980306   09/09/98   A   BPED    19980305MC    HARPSWELL         ME   BIBLE BROADCASTING NETWORK INC

  980306                  BPED    19980909MX    CONWAY            NH   NH EDUCATIONAL RADIO FOUNDATION

                                                                       

  980307   09/09/98   A   BPED    19980319MP    CASCADE           IA   COMMUNITY RADIO, INC

  980307                  BPED    19980908MA    DUBUQUE           IA   AMERICAN FAMILY ASSOCIATION

  980307                  BPED    19980909ML    PLATTEVILLE       WI   EDUCATIONAL COMMUNICATIONS BOARD

  980307                  BPED    19980909MU    DUBUQUE           IA   BROADCASTING FOR THE CHALLENGED
                                                                       INC

                                                                       

  980309                  BPED    19980619ME    LINCOLNTON        GA   AUGUSTA RADIO FELLOWSHIP INST.
                                                                       INC.

  980309                  BPED    19981023MF    THOMSON           GA   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  980309   10/23/98   A   BPED    19980319MI    THOMSON           GA   AMERICAN FAMILY ASSOCIATION

                                                                       

  980315                  BPED    19981230MB    NEWTON            IA   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  980315                  BPED    19990104MI    ADEL              IA   CSN INTERNATIONAL

  980315                  BPED    19990104ML    FORT DODGE        IA   FAMILY STATIONS, INC.

  980315   01/04/99   A   BPED    19980319MQ    MITCHELLVILLE     IA   UNIVERSITY OF NORTHERN IOWA

                                                                       

  98033P                  BPED    19980812MJ    HICKORY           NC   HICKORY EDUCATIONAL INC

  98033P                  BPED    19980814MQ    HICKORY           NC   RADIO TRAINING NETWORK, INC.

  98033P   08/14/98   A   BPED    19980316MB    HICKORY           NC   AMERICAN FAMILY ASSOCIATION

                                                                       

  9803HL                  BPED    19980923MG    COOS BAY          OR   FAMILY STATIONS, INC.

  9803HL   06/02/99   A   BPED    19980810MC    COOS BAY          OR   COOS BAY SCHOOL DISTRICT 9

                                                                       

  9803X3                  BPED    19980923MA    KUTZTOWN          PA   BERKS RADIO ASSOCIATION

  9803X3                  BPED    19980923MF    WYOMISSING        PA   FOUR RIVERS COMMUNITY B/G CORP

  9803X3   09/23/98   A   BPED    19980213ME    SHENANDOAH        PA   AMERICAN FAMILY ASSOCIATION

                                                                       

  980401                  BPED    19980421MC    LARAMIE           WY   COLORADO CHRISTIAN UNIVERSITY

  980401                  BPED    19980824MH    LARAMIE           WY   BROADCASTING FOR THE CHALLENGED
                                                                       INC

  980401                  BPED    19980825MD    LARAMIE           WY   ED COMMUN. OF COLORADO SPRINGS,
                                                                       INC.

  980401                  BPED    19980825ME    LARAMIE           WY   COLORADO CHRISTIAN UNIVERSITY

  980401                  BPED    19980826MK    LARAMIE           WY   UNIVERSITY OF WYOMING

  980401   08/26/98   A   BPED    19980407MD    LARAMIE           WY   AMERICAN FAMILY ASSOCIATION

                                                                       

  980402                  BPED    19980901MI    EARLHAM           IA   DES MOINES EARLHAM INC

  980402                  BPED    19980909MC    CRESTON           IA   FLORIDA PUBLIC RADIO INC

  980402   09/09/98   A   BPED    19980408MB    CRESTON           IA   AMERICAN FAMILY ASSOCIATION

                                                                       

  980404                  BPED    19980909MM    BENTON HARBOR     MI   PENSACOLA CHRISTIAN COLLEGE INC

  980404                  BPED    19980909MQ    BENTON HARBOR     MI   CORNERSTONE BAPTIST ED
                                                                       MINISTRIES INC

  980404   09/09/98   A   BPED    19980401MA    BENTON HARBOR     MI   AMERICAN FAMILY ASSOCIATION

                                                                       

  980405                  BPED    19980908MB    SANTA MARIA       CA   BELCHER SANTA MARIA B/CASTING
                                                                       CORP.

  980405                  BPED    19980909MV    LOMPOC            CA   BROADCASTING FOR THE CHALLENGED
                                                                       INC

  980405   09/09/98   A   BPED    19980414MD    LOMPOC            CA   CALVARY CHAPEL OF LOMPOC

                                                                       

  980406   09/09/98   A   BPED    19980406MB    EMPORIA           KS   UNIVERSITY OF KANSAS

  980406              B   BPED    19980601MB    EMPORIA           KS   BIBLE BROADCASTING NETWORK INC

                                                                       

  980407                  BPED    19981005MF    STANTON           TX   POPLAR BLUFF EDUCATIONAL INC.

  980407                  BPED    19981006ME    BIG SPRING        TX   BROADCASTING FOR THE CHALLENGED
                                                                       INC.

  980407   10/06/98   A   BPED    19980417MG    BIG SPRING        TX   PAULINO BERNAL EVANGELISM

                                                                       

  980409   10/06/98   A   BPED    19980420MH    PRINCETON         IL   ILLINOIS BIBLE INSTITUTE INC

  980409              B   BPED    19981006MN    SPRING VALLEY     IL   SPIRIT EDUCATION ASSOCIATION,
                                                                       INC.

  980409              B   BPED    19980428IE    PEKIN             IL   CENTRAL ILLINOIS RADIO
                                                                       FELLOWSHIP, INC.

                                                                       

  980410                  BPED    19981006MA    GLOBE             AZ   CSN INTERNATIONAL

  980410                  BPED    19981006ML    GLOBE             AZ   FAMILY STATIONS, INC.

  980410   10/06/98   A   BPED    19980408MC    GLOBE             AZ   LIFE TEEN INC.

                                                                       

  980411                  BPED    19980603MA    BELLEFONTE        PA   SOUTHPOINT EDUCATIONAL RADIO INC

  980411                  BPED    19981022MC    STATE COLLEGE     PA   INVISIBLE ALLIES MINISTRIES

  980411                  BPED    19981023MB    HALIFAX           PA   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  980411                  BPED    19981023MG    STATE COLLEGE     PA   FAMILY STATIONS, INC.

  980411   10/23/98   A   BPED    19980415MD    MIFFLIN           PA   JUNIATA COMMUNITY AWARENESS ASSN

                                                                       

  980412                  BPED    19981016MB    PLYMOUTH          IN   ROCHERSTER COMMUNITY RADIO INC.

  980412                  BPED    19981023MM    LOGANSPORT        IN   CSN INTERNATIONAL

  980412   10/23/98   A   BPED    19980414MB    PLYMOUTH          IN   AMERICAN FAMILY ASSOCIATION

                                                                       

  980413                  BPED    19981022MA    RIGBY             ID   EDUCATIONAL MEDIA FOUNDATION

  980413                  BPED    19981023MA    POCATELLO         ID   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  980413                  BPED    19981023ME    POCATELLO         ID   EDUCATIONAL MEDIA FOUNDATION

  980413                  BPED    19981023MJ    POCATELLO         ID   YOUR CHRISTIAN COMPANION
                                                                       NETWORK, INC.

  980413                  BPED    19981023ML    POCATELLO         ID   IDAHO STATE UNIVERSITY

  980413   10/23/98   A   BPED    19980410MB    POCATELLO         ID   CSN INTERNATIONAL

                                                                       

  980414   11/10/98   A   BPED    19980421MA    BEEKMAN           NY   MONROE BOARD OF EDUCATION

  980414              B   BPED    19981110MA    BEEKMAN           NY   MONTGOMERY NYC BROADCASTING INC.

                                                                       

  980415   12/03/98   A   BPED    19980427MQ    FARGO             ND   PIONEER PUBLIC BROADCASTING
                                                                       COMPANY

  980415              B   BPED    19981201MA    HORACE            ND   SELAH CORPORATION

  980415              B   BPED    19981202MG    GLYNDON           MN   MARY V. HARRIS FOUNDATION

  980415              B   BPED    19981203MC    FARGO             ND   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

                                                                       

  98043S                  BPED    19980922MF    LEXINGTON         KY   UNIVERSITY OF KENTUCKY

  98043S                  BPED    19980923MH    FRANKFORT         KY   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  98043S   09/23/98   A   BPED    19980409MA    FRANKFORT         KY   AMERICAN FAMILY ASSOCIATION

                                                                       

  9804X2                  BPED    19980515MO    COLLEGE STATION   TX   BRAZOS EDUCATIONAL RADIO

  9804X2                  BPED    19980909MP    BRYAN             TX   HOUSTON CHRISTIAN BROADCASTERS
                                                                       INC

  9804X2                  BPED    19980922MB    CALDWELL          TX   PHILOS BRAODCAST INC

  9804X2   09/23/98   A   BPED    19980410MA    BRYAN             TX   BRAZOS VALLEY COUNCIL ON ALCOHOL

                                                                       

  980501                  BPED    19981006MO    BUSHLAND          TX   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  980501                  BPED    19980629MA    BUSHLAND          TX   CSN INTERNATIONAL

  980501   10/06/98   A   BPED    19980501MA    BUSHLAND          TX   KANZA SOCIETY INC.

                                                                       

  980502                  BPED    19980527MA    BROKENBURG        VA   EDUCATIONAL OPPORTUNITIES INC.

  980502                  BPED    19981023MC    SPOTSYLVANIA      VA   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  980502                  BPED    19981023MP    FREDERICKSBURG    VA   CENTRAL VA. EDUC. TELECOM. CORP.

  980502   10/23/98   A   BPED    19980513MA    SPOTSYLVANIA      VA   EDUCATIONAL MEDIA CORPORATION

                                                                       

  980503                  BPED    19981023MK    ALTOONA           PA   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  980503                  BPED    19981023MD    BEDFORD           PA   FAMILY STATIONS, INC.

  980503   10/23/98   A   BPED    19980511MA    PATTON            PA   SOUTHPOINT EDUCATIONAL RADIO,
                                                                       INC

                                                                       

  980504                  BPED    19981023MN    MORGANTOWN        IN   CSN INTERNATIONAL

  980504   10/23/98   A   BPED    19980511ME    COLUMBUS          IN   GOOD SHEPHERD RADIO, INC.

                                                                       

  980506                  BPED    19980505MC    ROGERS HEIGHTS    MI   GREAT LAKES COMMUNITY BROADC/G
                                                                       INC.

  980506                  BMPED   19980909ME    WHITE STAR        MI   SUPERIOR COMMUNICATIONS

  980506                  BPED    19981231MF    CASS CITY         MI   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  980506                  BPED    19990104MO    ELKTON            MI   CSN INTERNATIONAL

  980506   01/04/99   A   BPED    19980505MD    GAGETOWN          MI   PLONTA BROADCASTING INC.

                                                                       

  980507   11/10/98   A   BPED    19980514MA    NANTY GLO         PA   EDUCATIONAL OPPORTUNITIES, INC.

  980507                  BPED    19981109MA    WESTMONT          PA   DUQUESNE UNIVERSITY OF THE HOLY
                                                                       GHOST

                                                                       

  980508                  BPED    19981110MD    PIERRE            SD   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  980508                  BPED    19981110MF    PIERRE            SD   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  980508   11/10/98   A   BPED    19980529MD    PIERRE            SD   VCY AMERICA INC

                                                                       

  980509                  BPED    19981110MH    KEY WEST          FL   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  980509   11/10/98   A   BPED    19980526MC    KEY WEST          FL   STAR RADIO INCORPORATED

                                                                       

  980510                  BPED    19981110MB    CAPE CANAVERAL    FL   WEST COAST EDUCATIONAL, INC

  980510                  BPED    19981110MI    CAPE CANAVERAL    FL   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  980510                  BPED    19981110MJ    CAPE CANAVERAL    FL   PUBLIC RADIO, INC.

  980510                  BPED    19981110MK    CAPE CANAVERAL    FL   FLORIDA PUBLIC RADIO, INC.

  980510   11/10/98   A   BPED    19980519MD    CAPE CANAVERAL    FL   CSN INTERNATIONAL

                                                                       

  980511                  BPED    19981110IA    FRESNO            CA   FAMILY STATIONS, INC.

  980511   11/10/98   A   BPED    19980519MC    FIREBAUGH         CA   CSN INTERNATIONAL

  980511              B   BMPED   19980818MD    HOLLISTER         CA   CENTRAL COAST EDUCATIONAL
                                                                       BROADCASTERS

  980511              B   BPED    19981110MC    MENDOTA           CA   CALIFORNIA HARDRIVES, INC

  980511              B   BPED    19981110ML    TRACY             CA   EDUCATIONAL MEDIA FOUNDATION

  980511              B   BPED    19981110MM    FIREBAUGH         CA   YOUR CHRISTIAN COMPANION
                                                                       NETWORK, INC.

                                                                       

  980512                  BPED    19981203MA    MICHIGAMME        MI   NORTHLAND COMMUNITY BRAODCASTERS

  980512                  BPED    19981203MI    IRONWOOD          MI   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  980512   12/03/98   A   BPED    19980521MG    IRONWOOD          MI   VCY AMERICA, INC.

                                                                       

  980513                  BPED    19990209MA    COLUMBUS          MS   PENSACOLA CHRISTIAN COLLEGE,
                                                                       INC.

  980513                  BPED    19990318MJ    COLUMBUS          MS   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  980513   03/19/99   A   BPED    19980526MB    COLUMBUS          MS   AMERICAN FAMILY ASSOCIATION

                                                                       

  980514                  BPED    19990318MF    BUTTE             MT   HI-LINE RADIO FELLOWSHIP, INC.

  980514                  BPED    19990506MA    BUTTE             MT   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  980514   05/10/99   A   BPED    19980506MC    BUTTE             MT   AMERICAN FAMILY ASSOCIATION

                                                                       

  980515                  BPED    19990719MG    COVENTRY          RI   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  980515                  BPED    19990719MH    EAST GREENWICH    RI   THE EDUC. RADIO/PUBLIC OF NEW
                                                                       MILLEN

  980515   07/19/99   A   BPED    19980519MZ    COVENTRY          RI   SOUTHERN RHODE ISLAND PUB. RAD.
                                                                       B/C

                                                                       

  980601                  BPED    19981016MA    CARBONDALE        PA   MONTGOMERY NYC BROADCASTING,
                                                                       INC.

  980601                  BPED    19981023MH    CARBONDALE        PA   FAMILY LIFE MINISTRIES, INC.

  980601                  BPED    19981023MI    CARBONDALE        PA   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  980601                  BPED    19981023MQ    HONESDALE         PA   FOUR RIVERS COMMUNITY B/C CORP

  980601   10/23/98   A   BPED    19980623MD    CARBONDALE        PA   SOUND OF LIFE INC

                                                                       

  980603   01/04/99   A   BPED    19980629MC    INDEPENDENCE      KS   CATHEDRAL OF PRAISE INC

  980603              B   BMPED   19981015MD    INDEPENDENCE      KS   AMERICAN FAMILY ASSOCIATION

                                                                       

  980604                  BPED    19981202MF    ANDALUSIA         AL   MONTGOMERY CHRISTIAN EDUC.
                                                                       RADIO,INC

  980604                  BPED    19981203MG    UNION SPRINGS     AL   PENSACOLA CHRISTIAN COLLEGE,
                                                                       INC.

  980604   12/03/98   A   BMPED   19980619MA    TROY              AL   AMERICAN FAMILY ASSOCIATION

                                                                       

  980605                  BPED    19981215MA    OSKALOOSA         IA   IA STATE UN OF SCIENCE &
                                                                       TECHNOLOGY

  980605                  BPED    19981215MC    OSKALOOSA         IA   FAMILY STATIONS, INC.

  980605   12/15/98   A   BPED    19980630MC    OSKALOOSA         IA   SALT & LIGHT COMMUNICATIONS INC

                                                                       

  980606                  BPED    19981211MB    ROCHESTER         MN   ROCHESTER COMMUNITY & TECHNICAL
                                                                       COL

  980606                  BPED    19981215MD    HAYFIELD          MN   LIFETALK BROADCASTING
                                                                       ASSOCIATION

  980606                  BPED    19981215ME    ALBERT LEA        MN   CSN INTERNATIONAL

  980606                  BPED    19981215MG    ALBERT LEA        MN   BROADCASTING FOR THE CHALLENGED
                                                                       INC.

  980606   12/15/98   A   BPED    19980603MB    AUSTIN            MN   MINNESOTA PUBLIC RADIO

                                                                       

  980608                  BPED    19981202MC    STEAMBOAT SPRINGS CO   ASPEN PUBLIC RADIO INC.

  980608                  BPED    19981215MF    HAYDEN            CO   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  980608                  BPED    19981215MH    STEAMBOAT SPRINGS CO   COLORADO CHRISTIAN UNIVERSITY

  980608                  BPED    19981215MJ    CRAIG             CO   COLORADO CHRISTIAN UNIVERSITY

  980608   12/15/98   A   BPED    19980610MA    HAYDEN            CO   ED\'L COMMUNICATIONS OF CO
                                                                       SPRINGS INC

                                                                       

  980609                  BPED    19981202MB    LA GRANGE         GA   N C PUBLIC BROADCAST
                                                                       INCORPORATED

  980609                  BPED    19981203MH    LA GRANGE         GA   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  980609                  BPED    19981203MJ    LA GRANGE         GA   FAMILY STATIONS, INC.

  980609   12/03/98   A   BPED    19980604MA    LA GRANGE         GA   COMMUNITY PUBLIC RADIO, INC.

                                                                       

  980610                  BPED    19981202MD    JUNIATA           NE   ASPEN PUBLIC RADIO, INC.

  980610                  BPED    19981203MD    GRAND ISLAND      NE   BROADCASTING FOR THE CHALLENDGED
                                                                       INC

  980610                  BPED    19981203MK    GRAND ISLAND      NE   FAMILY STATIONS, INC.

  980610   12/03/98   A   BPED    19980609MA    HASTINGS          NE   AMERICAN FAMILY ASSOCIATION

  980610              A   BPED    19980721MB    GRAND ISLAND      NE   EDUCATIONAL OPPORTUNITIES INC.

                                                                       

  980611                  BPED    19981203ME    DANVILLE          IL   BROADCASTING FOR THE CHALLENGED
                                                                       INC.

  980611   12/03/98   A   BPED    19980602MB    VEEDERSBURG       IN   GOOD SHEPHERD RADIO INC.

                                                                       

  980613                  BPED    19981231ME    WAVERLY           IA   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  980613   01/04/99   A   BPED    19980612MB    WAVERLY           IA   WARTBURG COLLEGE

                                                                       

  980614   01/04/99   A   BPED    19980629MB    MARSHALLTOWN      IA   CSN INTERNATIONAL

  980614              B   BPED    19981230MF    MARSHALLTOWN      IA   AMERICAN FAMILY ASSOCIATION

  980614              B   BPED    19981231MC    STATE CENTER      IA   MARSHALLTOWN EDUCATION PLUS,
                                                                       INC.

  980614              B   BPED    19990104MC    DES MOINES        IA   FAMILY STATIONS, INC.

                                                                       

  980615                  BPED    19981231MI    JACKSON           WY   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  980615                  BPED    19981231MK    JACKSON           WY   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  980615   01/04/99   A   BPED    19980618MA    JACKSON           WY   SOUTHPOINT EDUCATIONAL RADIO
                                                                       INC.

                                                                       

  980616   01/04/99   A   BPED    19980610MB    FAVORITA          FL   CHRISTIAN EDUCATIONAL
                                                                       ASSOCIATION

  980616              B   BPED    19981230MA    FLAGLER BEACH     FL   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  980616              B   BPED    19981231MB    FAVORETTA         FL   DAYSTAR PUBLIC RADIO, INC.

  980616              B   BPED    19990104MA    BEVERLY BEACH     FL   GOOD IDEA INC.

  980616              B   BPED    19990104MB    FAVORETTA         FL   PATHWAY PUBLIC RADIO

  980616              B   BPED    19990104MN    BEVERLY BEACH     FL   COMMUNITY PUBLIC RADIO, INC.

  980616              B   BPED    19990104MP    PALM COAST        FL   CENTRAL FL ED FOUNDATION INC

                                                                       

  980617   01/04/99   A   BPED    19980617MD    MERTZON           TX   SOLID ROCK BROADCASTING INC

  980617                  BPED    19981230MC    SAN ANGELO        TX   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

                                                                       

  980618                  BPED    19980727MD    CHERRY VALLEY     AR   IMPACT MINISTRIES INTERNATIONAL
                                                                       INC

  980618                  BPED    19990114MG    MARKED TREE       AR   NEW ORLEANS Y2K INCORPORATED

  980618                  BPED    19990120ME    MARKED TREE       AR   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  980618   01/20/99   A   BPED    19980611MC    MARKED TREE       AR   ESTHER EDUCATIONAL CORPORATION

                                                                       

  980619                  BPED    19990527MB    LARAMIE           WY   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  980619                  BPED    19990601MG    LARAMIE           WY   EDUC. COMM. OF COLORADO SPRINGS,
                                                                       INC

  980619                  BPED    19990602ML    WEST LARAMIE      WY   CSN INTERNATIONAL

  980619   06/02/99   A   BPED    19980625MB    LARAMIE           WY   SALT & LIGHT COMMUNICATIONS INC.

                                                                       

  980622   05/03/00   A   BPED    19980618MC    DORSEY            IL   LIBERTY COMMUNICATIONS INC.

  980622                  BNPED   20000428AAI   DORSEY            IL   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

                                                                       

  9806PP                  BPED    19990319MC    SEALY             TX   HOUSTON CHRISTIAN BROADCASTERS,
                                                                       INC.

  9806PP   03/19/99   A   BPED    19980610MC    SEALY             TX   CHRISTIAN EDUCATIONAL
                                                                       ASSOCIATION

                                                                       

  980701   01/04/99   A   BPED    19980713MD    SPRING ARBOR      MI   SPRING ARBOR COLLEGE
                                                                       COMMUNICATIONS

  980701              B   BPED    19981224MB    JACKSON           MI   GREAT LAKES COMMUNITY
                                                                       BROADCASTING

                                                                       

  980702                  BPED    19990104MJ    KELSO             WA   CSN INTERNATIONAL

  980702                  BPED    19990104MQ    RAINIER           OR   EDUCATIONAL MEDIA FOUNDATION

  980702   01/04/99   A   BPED    19980706MA    TILLAMOOK         OR   TILLICUM FOUNDATION

                                                                       

  980703                  BPED    19990104MD    NEWPORT           OR   FAMILY STATIONS INC.

  980703                  BPED    19990104MG    JUNCTION CITY     OR   CSN INTERNATIONAL

  980703                  BPED    19990104MU    DEPOE BAY         OR   LARAMIE UNION BROADCASTING, INC

  980703   01/04/99   A   BPED    19980707MG    GLENEDEN BEACH    OR   OREGON PUBLIC BROADCASTING

  980703              A   BPED    19980715ME    GLENEDEN BEACH    OR   KBPS PUBLIC RADIO FOUNDATION

  980703              A   BPED    19980826MF    MONROE            OR   FAMILY STATIONS, INC.

                                                                       

  980704                  BPED    19990104MM    LAKE LOOTAWANA    MO   COMMUNITY BROADCASTING, INC

  980704   01/04/99   A   BPED    19980717MA    LIBERTY           MO   WILLIAM JEWELL COLLEGE

                                                                       

  980705                  BPED    19990104MF    LAKE              MS   GREATER MISSISSIPPI
                                                                       BROADCASTING, INC

  980705   01/04/99   A   BPED    19980714MD    FOREST            MS   SALT & LIGHT COMMUNICATIONS,
                                                                       INC.

                                                                       

  980706                  BPED    19981230MD    SAULT STE. MARIE  MI   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  980706   01/04/99   A   BPED    19980707MH    SAULT STE. MARIE  MI   NORTHERN CHRISTIAN RADIO INC

                                                                       

  980708                  BPED    19990310MD    MONTAUK           NY   BROADCASTING FOR THE CHALLENDGED
                                                                       INC

  980708                  BPED    19990310MJ    MONTAUK           NY   MONTGOMERY NYC BROADCSTING, INC

  980708   03/11/99   A   BPED    19980713MF    MONTAUK           NY   WPKN, INC.

                                                                       

  980709                  BPED    19981013MA    COLUMBIA          MS   PENSACOLA CHRISTIAN COLLEGE,
                                                                       INC.

  980709                  BPED    19990311MH    HICKORY           MS   CSN INTERNATIONAL

  980709                  BPED    19990311MM    MERIDIAN          MS   FAMILY STATIONS, INC.

  980709   03/11/99   A   BPED    19980713ME    LAUREL            MS   AMERICAN FAMILY ASSOCIATION

                                                                       

  980710                  BPED    19990310MR    TRAFALGAR         IN   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  980710                  BPED    19990311MF    DANVILLE          IN   CALVARY CHAPEL OF CRAWFORDSVILLE
                                                                       IN.

  980710                  BPED    19990311MS    NEW WHITELAND     IN   HORIZON CHRISTIAN F/SHIP OF
                                                                       INDIANAP

  980710   03/11/99   A   BPED    19980716MS    TRAFALGAR         IN   HOOSIER BROADCASTING CORPORATION

                                                                       

  980712   03/19/99   A   BPED    19980730MB    MORRIS            IL   SOUTHWEST CHICAGO EDUCATIONAL
                                                                       INC.

  980712              B   BPED    19981228MA    MORRIS            IL   THE WBEZ ALLIANCE, INC.

  980712              B   BPED    19990318MD    MORRIS            IL   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

                                                                       

  980713                  BPED    19980827ME    ELGIN             IL   ILLINOIS BIBLE INSTITUTE, INC.

  980713                  BPED    19990319MH    CARPENTERSVILLE   IL   LIFETALK BROADCASTING
                                                                       ASSOCIATION

  980713   03/19/99   A   BPED    19980720MB    PINGREE GROVE     IL   COMMUNITY PUBLIC RADIO INC.

  980713              B   BPED    19980417MD    PINGREE GROVE     IL   CHRISTIAN EDUCATIONAL
                                                                       ASSOCIATION

                                                                       

  980714                  BPED    19990224MA    CUTHBERT          GA   AMERICAN FAMILY ASSOCIATION

  980714   03/19/99   A   BPED    19980727MH    EUFAULA           AL   FAITH BROADCASTING, INC.

                                                                       

  980715                  BPED    19990601MA    GRIDLEY           IL   AMERICAN FAMILY ASSOCIATION

  980715                  BPED    19990602MB    GRIDLEY           IL   BROADCASTING FOR THE CHALLENGED
                                                                       INC.

  980715                  BPED    19990602MS    BLOOMINGTON       IL   BLOOMINGTON-NORMAL B/CASTING
                                                                       ASSOCIATION

  980715   06/02/99   A   BPED    19980702MB    GRIDLEY           IL   PINEBROOK FOUNDATION, INC.

                                                                       

  980716                  BPED    19990120MI    LACEY             WA   FAMILY STATIONS, INC.

  980716                  BPED    19990120MJ    OLYMPIA           WA   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  980716   01/20/99   A   BPED    19980722MA    OLYMPIA           WA   WASHINGTON PUBLIC AFFAIRS
                                                                       NETWORK

                                                                       

  980801                  BPED    19990114MC    MARINETTE         WI   MARINETTE BROADCASTING
                                                                       FOUNDATION

  980801                  BPED    19990114MM    FORESTVILLE       WI   NASSAWADOX FM INCORPORATED

  980801                  BPED    19990120MB    STURGEON BAY      WI   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  980801                  BPED    19990120MD    PESHTIGO          WI   FRIENDS OF RADIO MARIA, INC.

  980801   01/20/99   A   BPED    19980811MH    STURGEON BAY      WI   VCY AMERICA INC.

                                                                       

  980802                  BPED    19990226MF    STERLING CITY     TX   CONCHO PUBLIC BROADCASTING

  980802                  BPED    19990310MM    BIG SPRING        TX   BROADCASTING FOR THE CHALLENGED,
                                                                       IN

  980802                  BPED    19990311ML    STANTON           TX   EDUCATIONAL MEDIA FOUNDATION

  980802                  BPED    19990430MB    BYRNE             TX   EL HISPANO, INC.

  980802   03/11/99   A   BPED    19980826MM    BIG SPRING        TX   EDUCATIONAL OPPORTUNITIES INC

  980802   05/10/99   A   BPED    19981120MD    BYRNE             TX   SOUTHPOINT EDUCATIONAL RADIO

                                                                       

  980803                  BPED    19990310MN    BROWNFIELD        TX   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  980803   03/11/99   A   BPED    19980820MA    BROWNFIELD        TX   SALT & LIGHT COMMUNICATIONS INC

                                                                       

  980804                  BPED    19990310ML    CASPER            WY   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  980804                  BPED    19990311MN    CASPER            WY   WCN, INC.

  980804   03/11/99   A   BPED    19980821MF    CASPER            WY   SOLID ROCK BROADCASTING INC

                                                                       

  980805                  BPED    19990310MA    LARAMIE           WY   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  980805                  BPED    19990310MF    LARAMIE           WY   LARAMIE UNION BROADCASTING
                                                                       INCORPORA

  980805                  BPED    19990310MI    LARAMIE           WY   ED COMMUNICATIONS OF CO SPRINGS,
                                                                       INC

  980805                  BPED    19990311MO    LARAMIE           WY   WCN, INC.

  980805                  BPED    19990311MP    ALBANY            WY   EDUCATIONAL MEDIA FOUNDATION

  980805                  BPED    19990311MR    LARAMIE           WY   MOUNTAIN WEST INSPIRATIONAL
                                                                       NETWORK

  980805   03/11/99   A   BPED    19980826MA    LARAMIE           WY   UNIVERSITY OF WYOMING

                                                                       

  980806                  BPED    19990304MC    EFFINGHAM         IL   THE CROSS FOUNDATION

  980806                  BPED    19990310MO    EFFINGHAM         IL   PANA PUBLIC RADIO, INC

  980806   03/11/99   A   BPED    19980810MA    EFFINGHAM         IL   AMERICAN FAMILY ASSOCIATION

                                                                       

  980807                  BPED    19990311MC    ANNA              OH   FRIENDS OF RADIO MARIA, INC.

  980807   03/11/99   A   BPED    19980821MB    BOTKINS           OH   ONLY BELIEVE MINISTRIES INC

                                                                       

  980810                  BPED    19990311MQ    ANCHORAGE         AK   EDUCATIONAL MEDIA FOUNDATION

  980810   03/11/99   A   BPED    19980819MB    PALMER            AK   CHRISTIAN BROADCASTING INC

                                                                       

  980811                  BPED    19990318ME    BELLINGHAM        WA   WESTERN WASHINGTON UNIVERSITY

  980811                  BPED    19990319MG    SEQUIM            WA   EDUCATIONAL MEDIA FOUNDATION

  980811   03/19/99   A   BPED    19980813ME    PORT ANGELES      WA   PACIFIC LUTHERAN UNIVERSITY,
                                                                       INC.

                                                                       

  980813   03/11/99   A   BPED    19980821MD    CUBA              MO   NEW LIFE EVANGELISTIC CENTER,
                                                                       INC.

  980813              B   BPED    19981125MA    SALEM             MO   MIRACLE RADIO, INC.

                                                                       

  980814                  BPED    19990602MF    WITTENBERG        WI   BROADCASTING FOR THE CHALLENGED
                                                                       INC

  980814   06/02/99   A   BPED    19980811MJ    WITTENBERG        WI   VCY AMERICA INC.

                                                                       

  980815                  BPED    19980918MG    ZIONSVILLE        IN   KIDS FIRST INCORPORATED

  980815                  BPED    19990420MB    LEBANON           IN   HOOISER BROADCASTING CORPORATION

  980815                  BPED    19990506MH    LEBANON           IN   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  980815                  BPED    19990510MG    JAMESTOWN         IN   MARY V. HARRIS FOUNDATION

  980815   05/10/99   A   BPED    19980817MZ    LEBANON           IN   HORIZON CHRISTIAN FELLOWSHIP OF
                                                                       INDI

                                                                       

  980818   06/02/99   A   BPED    19980804MB    FARMINGTON        NM   KUTE, INC.

  980818              B   BPED    19990527ME    FARMINGTON        NM   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

                                                                       

  980902                  BPED    19990310MC    BEAUMONT          TX   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  980902                  BPED    19990310MK    VIDOR             TX   HOUSTON BAY CITY INCORPORATED

  980902                  BPED    19990311ME    VIDOR             TX   FRIENDS OF RADIO MARIA, INC.

  980902   03/11/99   A   BPED    19980911MB    BEAUMONT          TX   CCS RADIO INC

                                                                       

  980903                  BPED    19990226MJ    OXFORD            AL   BAMA BROADCASTING, INC.

  980903                  BPED    19990302MI    HEFLIN            AL   COVENANT COMMUNICATIONS, INC.

  980903   03/19/99   A   BPED    19980910MB    HEFLIN            AL   JIMMY JARRELL COMMUNICATIONS
                                                                       FOUNDAT

                                                                       

  980904                  BPED    19990318MC    ALTOONA           PA   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  980904                  BPED    19990319MB    CHAMBERSBURG      PA   FOUR RIVERS COMMUNITY B/CASTING
                                                                       CORP

  980904   03/19/99   A   BPED    19980921MB    HOLLIDAYSBURG     PA   FRIENDS OF RADIO MARIA INC

                                                                       

  980905                  BPED    19990115MB    FRANKLIN          KY   LIFETALK BROADCASTING
                                                                       ASSOCIATION

  980905                  BPED    19990317MC    AUBURN            KY   WAY-FM MEDIA GROUP, INC

  980905                  BPED    19990319MI    BOWLING GREEN     KY   WESTERN KENTYCKY UNIVERSITY AC
                                                                       240

  980905   03/19/99   A   BPED    19980904MB    GLASGOW           KY   LOMERSET EDUC. B/CASTING
                                                                       FOUNDATION

                                                                       

  980906   06/02/99   A   BPED    19980901MM    HEREFORD          TX   SOUTHPOINT EDUCATIONAL RADIO

  980906              B   BPED    19990521MA    HEREFORD          TX   EL HISPANO, INC.

                                                                       

  980907   06/02/99   A   BPED    19980901ME    CHESTERFIELD      SC   CHRISTIAN EDUCATIONAL
                                                                       ASSOCIATION

  980907              B   BPED    19990528MB    CHESTERFIELD      SC   NORTH CAROLINA PUBLIC B/C
                                                                       INCORPORAT

                                                                       

  980910                  BPED    19981215MB    WINDOM            MN   MINN-IOWA CHRISTIAN BROADCASTING
                                                                       INC

  980910                  BPED    19990310MG    WINDOM            MN   DES MOINES EARLHAM INCORPORATED

  980910   03/11/99   A   BPED    19980925MA    WINDOM            MN   AMERICAN FAMILY ASSOCIATION

  980910              A   BPED    19990311MK    WILLMAR           MN   EDUCATIONAL MEDIA FOUNDATION

                                                                       

  980911                  BPED    19990716MB    BERNARDSVILLE     NJ   NEW JERSEY PUBLIC B/CASTING
                                                                       AUTHORIT

  980911   07/19/99   A   BPED    19980923MB    CHATHAM           NJ   WORLD REVIVALS INC

                                                                       

  980912                  BPED    19990719MC    FOND DU LAC       WI   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  980912   07/19/99   A   BPED    19980923MD    FOND DU LAC       WI   VCY AMERICA INC.

                                                                       

  9809W2                  BPED    19990318MI    UNION CITY        TN   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  9809W2   03/19/99   A   BPED    19980918MC    UNION CITY        TN   HEARTLAND MINISTRIES INC

                                                                       

  9809W3                  BPED    19990318ML    YAZOO CITY        MS   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  9809W3   03/19/99   A   BPED    19980922ME    YAZOO CITY        MS   BRIGHT LIGHT BROADCASTING INC

                                                                       

  981001                  BPED    19990310ME    COLUMBUS          MS   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  981001   03/11/99   A   BPED    19981029MA    COLUMBUS          MS   MISSISSIPPI UNIVERSITY FOR WOMEN

                                                                       

  981002                  BPED    19990310MB    YUCCA VALLEY      CA   BROADCASTING FOR THE CHALLENGED
                                                                       INC.

  981002                  BPED    19990310MQ    YUCCA VALLEY      CA   SACRAMENTO BRAIN TRUST
                                                                       INCORPORATED

  981002   03/11/99   A   BPED    19981013MB    YUCCA VALLEY      CA   PENFOLD COMMUNICATIONS, INC.

                                                                       

  981003                  BPED    19990318MB    ARKADELPHIA       AR   HENDERSON STATE UNIVERSITY

  981003                  BPED    19990318MH    ARKADELPHIA       AR   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  981003   03/19/99   A   BPED    19981030MC    ARKADELPHIA       AR   BRIGHT LIGHT BROADCASTING INC.

                                                                       

  981004                  BPED    19981023MO    BULLHEAD CITY     AZ   CSN INTERNATIONAL

  981004                  BPED    19990506MB    KINGMAN           AZ   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  981004                  BPED    19990510MD    LAKE HAVASU CITY  AZ   EDUCATIONAL MEDIA FOUNDATION

  981004                  BPED    19990510ME    ST. GEORGE        UT   EDUCATIONAL MEDIA FOUNDATION

  981004   05/10/99   A   BPED    19981013MO    KINGMAN           AZ   CEDAR BROADCASTING, INC.

                                                                       

  981005                  BPED    19990506MD    BILOXI            MS   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  981005                  BPED    19990507MC    BILOXI            MS   AMERICAN FAMILY ASSOCIATION

  981005                  BPED    19990510MC    BILOXI            MS   BIBLE BROADCASTING NETWORK, INC.

  981005                  BPED    19990510MJ    D\'IBERVILLE      MS   FRIENDS OF RADIO MARIA, INC.

  981005   05/10/99   A   BPED    19981026MB    BILOXI            MS   GREATER MISSISSIPPI BROADCASTING
                                                                       INC

                                                                       

  981006                  BPED    19990429MA    FOREST            MS   AMERICAN FAMILY ASSOCIATION

  981006   05/10/99   A   BPED    19981026MA    FOREST            MS   GREATER MISSISSIPPI BROADCASTING
                                                                       INC

                                                                       

  981008                  BPED    19990507MB    GRAND ISLAND      NE   ROCHESTER COMMUNITY RADIO
                                                                       INCORPORAT

  981008   05/10/99   A   BPED    19981014MA    GRAND ISLAND      NE   AMERICAN FAMILY ASSOCIATION

                                                                       

  981009                  BPED    19990402MC    PARIS             TN   ABUNDANT LIFE BROADCASTING

  981009                  BPED    19990506MF    PARIS             TN   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  981009   05/10/99   A   BPED    19981026MD    WAVERLY           TN   TENNESSEE ED INFORMATIONAL
                                                                       INCORPORA

                                                                       

  981010                  BPED    19990526MC    LOCKWOOD          MT   CSN INTERNATIONAL

  981010                  BPED    19990527MC    BILLINGS          MT   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  981010                  BPED    19990602MJ    BILLINGS          MT   BILLINGS COMMUNITY CABLE
                                                                       CORPORATION

  981010   06/02/99   A   BPED    19981030MB    BILLINGS          MT   SOLID ROCK BROADCASTING, INC.

                                                                       

  981011                  BPED    19990527MD    BISMARCK          ND   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  981011                  BPED    19990602MC    LINCOLN           ND   BRODCASTING FOR THE CHALLENGED,
                                                                       INC.

  981011                  BPED    19990602MD    BISMARCK          ND   EDUCATIONAL MEDIA FOUNDATION

  981011                  BPED    19990602MT    LINCOLN           ND   CSN INTERNATIONAL

  981011   06/02/99   A   BPED    19981019MA    LINCOLN           ND   EDUCATIONAL MEDIA FOUNDATION

                                                                       

  981012                  BPED    19990628MB    RENNERT           NC   BD OF TRUSTEES OF THE U OF
                                                                       NC-CHAPEL HILL

  981012   06/28/99   A   BPED    19981022MB    LUMBERTON         NC   BILLY RAY LOCKLEAR EVAN. ASSOC.,
                                                                       INC

                                                                       

  981014                  BPED    19980126MC    TROY              MO   MISSOURI RIVER CHRISTIAN
                                                                       BRAODCAST/G

  981014   09/07/99   A   BPED    19981020MC    BOWLING GREEN     MO   NEW LIFE EVANGELISTIC CTR, INC.

                                                                       

  981101                  BPED    19990301MC    HOBBS             NM   ABUNDANT LIFE BROADCASTING

  981101                  BPED    19990317MB    LOVINGTON         NM   YOUR CHRISTIAN COMPANION
                                                                       NETWORK, INC.

  981101                  BPED    19990318MK    HOBBS             NM   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  981101   03/19/99   A   BPED    19981112MA    HOBBS             NM   EL HISPANO, INC.

                                                                       

  981104                  BPED    19990528MH    GREENCASTLE       IN   HOOSIER BROADCASTING CORPORATED

  981104   06/02/99   A   BPED    19981120MA    GREENCASTLE       IN   PENSACOLA CHRISTIAN COLLEGE INC.

                                                                       

  981105                  BPED    19990528MD    BRAINERD          MN   ROCHESTER COMMUNITY RADIO
                                                                       INCORPORAT

  981105                  BPED    19990602MG    BAXTER            MN   CSN INTERNATIONAL

  981105   06/02/99   A   BPED    19981113MC    BRAINERD          MN   MINNESOTA PUBLIC RADIO

                                                                       

  981106                  BPED    19990601MB    CAMP WOOD         TX   CHRISTAN ED ASSOCIATION

  981106   06/02/99   A   BPED    19981119MB    CAMP WOOD         TX   HOUSTON CHRISTIAN BROADCASTERS,
                                                                       INC.

                                                                       

  981107                  BNPED   19991028AAM   SPRINGFIELD       OH   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  981107   11/04/99   A   BPED    19981105MF    SOUTH VIENNA      OH   SALT & LIGHT COMMUNICATIONS,
                                                                       INC.

                                                                       

  981108                  BNPED   19991026AAG   SAN ANGELO        TX   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  981108   11/04/99   A   BPED    19981105ME    CARLSBAD          TX   OPTIMUM IMPACT, INC.

                                                                       

  981201   05/10/99   A   BPED    19981231MA    MARLETTE          MI   GREAT LAKES COMMUNITY BROADC/G,
                                                                       INC.

  981201                  BPED    19990510MA    SPEAKER TWP.      MI   SPEAKER RADIO

                                                                       

  981202                  BPED    19990208MA    TRINIDAD          CO   AMERICAN FAMILY ASSOCIATION

  981202                  BPED    19990601MF    TRINIDAD          CO   EDUC. COMM. OF COLORADO SPRINGS,
                                                                       INC

  981202   06/02/99   A   BPED    19981208ME    STARKVILLE        CO   COLORADO COLLEGE

                                                                       

  981203                  BPED    19981009MA    LINTON            IN   BETHEL BAPTIST CHURCH

  981203                  BPED    19990525MA    CLOVERDALE        IN   HOOSIER BROADCASTING CORPORATION

  981203   06/02/99   A   BPED    19981203ML    LADOGA            IN   CSN INTERNATIONAL

  981203              A   BPED    19981203MB    OOLITIC           IN   GOOD SAMARITAN ED RADIO INC

                                                                       

  981204              B   BPED    19990602MA    GARDNER           MA   FRIENDS OF RADIO MARIA, INC.

  981204   06/02/99   A   BPED    19981207MA    WINCHENDON        MA   TOCCOA FALLS COLLEGE

                                                                       

  981206                  BPED    19990602MH    BAKER             OR   CSN INTRNATIONAL

  981206   06/02/99   A   BPED    19981221MB    BAKER             OR   AMERICAN FAMILY ASSOCIATION

                                                                       

  981207              B   BPED    19990628MG    SUGAR GROVE       IL   EDUCATIONAL MEDIA FOUNDATION

  981207   06/28/99   A   BPED    19981211MF    BRISTOL           IL   BEST MEDIA INC.

                                                                       

  981208   07/19/99   A   BMPED   19981230ME    MASON CITY        IA   AMERICAN FAMILY ASSOCIATION

  981208              B   BPED    19980520MB    LANESBORO         MN   BLUFF COUNTRY COMMUNITY RADIO,
                                                                       INC.

  981208              B   BPED    19990202MB    LAKE MILLS        IA   MINN-IOWA CHRISTIAN
                                                                       BROADCASTING, IN

                                                                       

  981209                  BPED    19990719MI    JANESVILLE        WI   FAMILY STATIONS, INC.

  981209   07/19/99   A   BPED    19981224MA    JANESVILLE        WI   VCY AMERICA, INC.

                                                                       

  981210                  BNPED   19991004AAB   LAYTONVILLE       CA   FAMILY STATIONS, INC.

  981210                  BNPED   19991004AAI   LAYTONVILLE       CA   EDUCATIONAL MEDIA FOUNDATION

  981210   10/04/99   A   BPED    19981215MI    LAYTONVILLE       CA   REDWOOD COMMUNITY RADIO, INC

                                                                       

  981211                  BNPED   19990924AAL   OAKLAND           ME   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  981211   10/04/99   A   BPED    19981211MC    OAKLAND           ME   LIGHT OF LIFE MINISTRIES INC

                                                                       

  981212                  BNPED   19991117ABJ   MADISONVILLE      KY   INDIANA COMMUNITY RADIO
                                                                       CORPORATION

  981212   11/17/99   A   BPED    19981211MA    MADISONVILLE      KY   PENNYRILE CHRISTIAN COMMUNITY,
                                                                       INC.

                                                                       

  981213                  BPED    19981203IA    HOWE              IN   CSN INTERNATIONAL

  981213                  BPED    19990720MD    ORLEANS           MI   PENSACOLA CHRISTIAN COLLEGE,
                                                                       INC.

  981213                  BNPED   19991116AIT   LEVEL PARK        MI   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  981213                  BNPED   19991117ABI   RICHLAND          MI   LIVING PROOF, INC.

  981213   11/17/99   A   BPED    19981208MF    LEVEL PARK        MI   PENSACOLA CHRISTIAN COLLEGE,
                                                                       INC.

                                                                       

  9812SS                  BPED    19990630MC    CROTHERSVILLE     IN   CSN INTERNATIONAL

  9812SS                  BPED    19990719MB    HOPE              IN   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  9812SS   07/19/99   A   BPED    19981224MC    HOPE              IN   GOOD SHEPHERD RADIO, INC.

                                                                       

  990101                  BPED    19990428MD    OSKALOOSA         IA   SOLID ROCK BROADCASTING, INC..

  990101   05/10/99   A   BPED    19990113MA    OSKALOOSA         IA   UNIVERSITY OF NORTHERN IOWA

                                                                       

  990102                  BPED    19990420ME    FROSTPROOF        FL   RADIO TRAINING NETWORK, INC.

  990102                  BPED    19990714MF    FROSTPROOF        FL   WEST COAST EDUCATIONAL
                                                                       INCORPORATED

  990102   07/19/99   A   BPED    19990119MA    LAKEMONT          FL   REVIVAL CHRISTIAN MINISTRIES
                                                                       INC.

                                                                       

  990104                  BPED    19990719MA    WESTWOOD          CA   CSN INTERNATIONAL

  990104   07/19/99   A   BPED    19990107MA    GREENVILLE        CA   IMMACULATE HEART RADIO

                                                                       

  990105                  BPED    19990126MD    OLSBURG           KS   THE UNIVERSITY OF KANSAS

  990105                  BPED    19990714MG    JUNCTION CITY     KS   REDWOOD VALLEY B/CASTERS INC.

  990105                  BPED    19990719MF    JUNCTION CITY     KS   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  990105   07/19/99   A   BPED    19990112MC    JUNCTION CITY     KS   VCY AMERICA, INC.

                                                                       

  990106                  BPED    19990610MD    WARRENTON         OR   PACIFIC LUTHERN UNIVERSITY INC.

  990106                  BPED    19990714MD    ASTORIA           OR   CATHOLIC BROADCASTING NORTHWEST,
                                                                       INC

  990106                  BPED    19990719MK    ROCKAWAY BEACH    OR   EDUCATIONAL MEDIA FOUNDATION

  990106   07/19/99   A   BPED    19990104ME    ASTORIA           OR   WORLD RADIO NETWORK INC

                                                                       

  990107                  BNPED   19990924AAX   CRAIG             CO   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  990107                  BNPED   19991004AAG   MEEKER            CO   EDUCATIONAL COMMUNICATIONS OF
                                                                       COLORADO SPRINGS, INC

  990107                  BNPED   19991004AAL   STEAMBOAT SPRING  CO   EDUCATIONAL COMMUNICATIONS OF
                                                                       COLORADO SPRINGS, INC

  990107   10/04/99   A   BPED    19990129ME    CRAIG             CO   PUBLIC BROADCASTING OF COLORADO,
                                                                       INC

                                                                       

  990109                  BPED    19990823MA    WEST CLARKSTON    WA   LIVING FAITH FELLOWSHIP
                                                                       EDUCATIONAL MINISTRIES

  990109                  BNPED   19991004AAC   GENESEE           ID   THE MOODY BIBLE INSTITUTE OF
                                                                       CHICAGO

  990109                  BNPED   19991004AAJ   CLARKSTON         WA   CSN INTERNATIONAL

  990109   10/04/99   A   BPED    19990129MD    WEST CLARKSTON    WA   UPPER COLUMBIA MEDIA CORP

                                                                       

  990110                  BPED    19990625MD    SCIENCE HILL      KY   WESTERN KENTUCKY UNIVERSITY
                                                                       AC240

  990110                  BPED    19990628MC    SOMERSET          KY   EDUCATIONAL MEDIA FOUNDATION

  990110   06/28/99   A   BPED    19990114ME    CORBIN            KY   EASTERN KENTUCKY UNIVERSITY

                                                                       

  990111   07/19/99   A   BPED    19990120MC    TIPTON            IN   EDUCATIONAL OPPORTUNITIES, INC.

  990111              B   BPED    19990714ME    MUNCIE            IN   HYMN TIME, INC.

                                                                       

  9901XP                  BPED    19990729MB    COCOA BEACH       FL   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  9901XP                  BPED    19990730MA    COCOA BEACH       FL   BLACK MEDIA WORKS, INC.

  9901XP                  BPED    19990730MB    MERRITT ISLAND    FL   CENTRAL FL. EDUC. FOUNDATION,
                                                                       INC.

  9901XP                  BPED    19990730MD    MERRITT ISLAND    FL   MERRITT ISLAND PLUBLIC RADIO,
                                                                       INC.

  9901XP   08/01/99   A   BPED    19990121MA    COCOA BEACH       FL   CSN INTERNATIONAL

                                                                       

  990201                  BPED    19990223MB    BOONEVILLE        AR   VISION MINISTRIES, INC.

  990201                  BPED    19990618MB    FORT SMITH        AR   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  990201                  BPED    19990628MD    VAN BUREN         AR   EDUCATIONAL MEDIA FOUNDATION

  990201   06/28/99   A   BPED    19990211MA    RUSSELLVILLE      AR   EDUCATIONAL OPPORTUNITIES, INC.

                                                                       

  990203                  BPED    19990826MA    FINDLAY           OH   ASSOCIATED CHRISTIAN
                                                                       BROADCASTERS, INC

  990203                  BPED    19990917ME    FINDLAY           OH   EDUCATIONAL MEDIA FOUNDATION

  990203   09/17/99   A   BPED    19990216MB    FINDLAY           OH   CHURCH OF THE LIVING GOD
                                                                       MINISTRIES

                                                                       

  990204                  BNPED   20000118AAB   PORT O\'CONNOR    TX   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  990204                  BNPED   20000118ADE   PORT O\'CONNOR    TX   SAN ANTONIO COMFORT INCORPORATED

  990204   01/18/00   A   BPED    19990218MA    PORT O\'CONNOR    TX   HOUSTON CHRISTIAN BROADCASTERS,
                                                                       INC.

                                                                       

  990302                  BPED    19990903MA    FRISCO            CO   EDUC. COMM. OF COLORADO SPRINGS,
                                                                       INC

  990302                  BPED    19990903MB    LEADVILLE         CO   EDUC. COMM. OF COLORADO SPRINGS,
                                                                       INC

  990302                  BPED    19990903MG    SALIDA            CO   ED COMMUNICATIONS OF CO SPRINGS
                                                                       INC

  990302   09/07/99   A   BPED    19990329MC    LEADVILLE         CO   TRUSTEES OF THE UN OF NORTHERN
                                                                       CO

                                                                       

  990303                  BPED    19990907MB    JAMESTOWN         ND   EDUCATIONAL MEDIA FOUNDATION

  990303   09/07/99   A   BPED    19990331MA    JAMESTOWN         ND   ABUNDANT LIFE BROADCASTING

                                                                       

  990304                  BPED    19990901MC    GALLUP            NM   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  990304                  BPED    19990907MC    GALLUP            NM   EDUCATIONAL MEDIA FOUNDATION

  990304   09/07/99   A   BPED    19990319ME    GRANTS            NM   THE CITY OF ALBUQUERQUE, NM

  990304              A   BPED    19990325MD    MENTMORE          NM   CSN INTERNATIONAL

                                                                       

  990305              A   BPED    19980316MD    KEY WEST          FL   SOUTHERNMOST EDUCATIONAL
                                                                       INCORPORTED

  990305                  BPED    19990901MD    LEXINGTON         OH   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  990305   09/07/99   A   BPED    19990302MG    LEXINGTON         OH   HELLINGER FOUNDATION, INC.

                                                                       

  990306                  BPED    19990329IA    MONTROSE          CO   NORTH FORK VALLEY PUBLIC RADIO,
                                                                       INC

  990306              B   BPED    19990505MA    DURANGO           CO   KUTE, INC.

  990306              B   BPED    19990916MB    DURANGO           CO   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  990306   09/17/99   A   BPED    19990318MG    DURANGO           CO   SAN JUAN COLLEGE

                                                                       

  990307                  BPED    19990916MC    WOODSTOCK         IL   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  990307                  BPED    19990917MI    WOODSTOCK         IL   FAMILY STATIONS INC.

  990307                  BPED    19990917MM    WOODSTOCK         IL   CORNERSTONE COMMUNITY RADIO INC.

  990307   09/17/99   A   BPED    19990316MG    WOODSTOCK         IL   PENSACOLA CHRISTIAN COLLEGE, INC

                                                                       

  990308                  BPED    19990914MA    DEL RIO           TX   HOUSTON BAY CITY INCORPORATED

  990308                  BPED    19990916MF    DEL RIO           TX   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  990308   09/17/99   A   BPED    19990316MF    DEL RIO           TX   WORLD RADIO NETWORK, INC

                                                                       

  990309                  BNPED   19991115AAR   ELIZABETHTOWN     OH   REDWOOD VALLEY BROADCASTERS
                                                                       INCORPORATED

  990309                  BNPED   19991116AIW   HARRISON          OH   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  990309                  BNPED   19991117ABN   MIAMITOWN         OH   COMMUNITY PUBLIC RADIO, INC.

  990309   11/17/99   A   BPED    19990325MC    MIAMITOWN         OH   SPRYEX COMMUNICATIONS, INC.

                                                                       

  990310                  BPED    19990719MD    DOVER             NJ   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  990310                  BPED    19990730ME    NETCONG           NJ   NEW JERSEY PUBLIC B/CASTING
                                                                       AUTHORITY

  990310   08/01/99   A   BPED    19990305MA    DOVER             NJ   CHRISTIAN EDUCATIONAL
                                                                       ASSOCIATION

                                                                       

  9903TP   12/15/99   A   BPED    19990301MA    JACKSON           WY   ABUNDANT LIFE BROADCASTING

  9903TP                  BNPED   19991210AAG   JACKSON           WY   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  9903TP                  BNPED   19991214ACD   JACKSON           WY   MOODY BIBLE INSTITUTE

                                                                       

  990401                  BPED    19990510MB    SEARCY            AR   HARDING UNIVERSITY

  990401                  BNPED   19990924AAY   SEARCY            AR   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  990401   10/04/99   A   BPED    19990402MB    MELBOURNE         AR   ABUNDANT LIFE BROADCASTING

                                                                       

  990402   10/04/99       BNPED   19990927AAP   BEATRICE          NE   AMERICAN FAMILY ASSOCIATION

  990402                  BNPED   19991004ABZ   HICKMAN           NE   EDUCATIONAL MEDIA FOUNDATION

                                                                       

  990403                  BPED    19990610MF    MARION            OH   THE CEDARVILLE COLLEGE

  990403                  BPED    19990901ME    MARION            OH   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  990403   09/07/99   A   BPED    19990426MB    MARION            OH   KAYSER BROADCAST MINISTRIES,
                                                                       INC.

                                                                       

  990404                  BPED    19990623ME    READING           MI   GREAT LAKES COMMUNITY B/CASTING,
                                                                       INC

  990404                  BNPED   19990928AAV   LAKE ODESSA       MI   GREAT LAKES COMMUNITY
                                                                       BROADCASTING, INC.

  990404                  BNPED   19991018AAJ   ALLEGAN           MI   PENSACOLA CHRISTIAN COLLEGE,
                                                                       INC.

  990404                  BNPED   19991026AAD   BATTLE CREEK      MI   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  990404                  BNPED   19991028AAE   COLDWATER         MI   MICHIANA CHRISTIAN BROADCASTERS,
                                                                       INC.

  990404                  BNPED   19991029AAF   CLYDE TOWNSHIP    MI   LARLEN COMMUNICATIONS INC.

  990404                  BNPED   19991104AAM   CLARKLAKE         MI   GREAT LAKES COMMUNITY
                                                                       BROADCASTING, INC.

  990404   11/04/99   A   BPED    19990406MB    BATTLE CREEK      MI   PENSACOLA CHRISTIAN COLLEGE,
                                                                       INC.

                                                                       

  990405   09/17/99   A   BPED    19990415MA    EMERALDA          FL   SUNBELT EDUCATIONAL BROADCASTING
                                                                       INC

  990405                  BPED    19990916MA    WEIRSDALE         FL   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  990405                  BPED    19990917MO    TAVARES           FL   CENTRAL FLORIDA ED FOUNDATION,
                                                                       INC

                                                                       

  990406                  BPED    19990916MG    BUTTE             MT   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  990406                  BPED    19990917MB    WHITEHALL         MT   COLORADO CHRISTIAN UNIVERSITY

  990406                  BPED    19990917MG    BUTTE             MT   FAMILY STATIONS, INC.

  990406                  BPED    19990917MJ    BOZEMAN           MT   EDUCATIONAL MEDIA FOUNDATION

  990406                  BPED    19990917ML    BUTTE             MT   YOUR NETWORK OF PRAISE INC.

  990406   09/17/99   A   BPED    19990430MA    BUTTE             MT   ABUNDANT LIFE BROADCASTING

                                                                       

  990407   01/18/00   A   BPED    19990407MC    INYOKERN          CA   LIVING PROOF, INC.

  990407                  BNPED   20000118AAE   INYOKERN          CA   BROADCASTING FOR THE CHALLENGED,
                                                                       INC

  990407                  BNPED   20000118AAQ   RIDGECREST        CA   EDUCATIONAL MEDIA FOUNDATION

  990407                  BNPED   20000118AAO   TEHACHAPI         CA   EDUCATIONAL MEDIA FOUNDATION

  990407                  BNPED   20000118AAN   BARSTOW           CA   EDUCATIONAL MEDIA FOUNDATION

                                                                       

  990408   01/18/00   A   BPED    19990407ME    WOOSTER           OH   THE CEDARVILLE COLLEGE

  990408                  BNPED   20000118AAK   BRUNSWICK         OH   CSN INTERNATIONAL

  990408                  BNPED   20000118AAR   WADSWORTH         OH   EDUCATIONAL MEDIA FOUNDATION

  990408                  BNPED   20000118AEN   WADSWORTH         OH   MARY V. HARRIS FOUNDATION

                                                                       

  990409                  BNPED   20000223AAM   SOCORRO           NM   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  990409                  BNPED   20000301AAX   SOCORRO           NM   EDUCATIONAL MEDIA FOUNDATION

  990409   03/03/00   A   BPED    19990428MC    SOCORRO           NM   REGENTS OF THE UN OF NEW MEXICO

                                                                       

  990410                  BNPED   19991004AAH   STIGLER           OK   EDUCATIONAL MEDIA FOUNDATION

  990410   10/04/99   A   BPED    19990420MF    STUART            OK   LIGHTHOUSE OF PRAYER, INC.

                                                                       

  990411                  BPED    19990907MA    KETTLEMAN CITY    CA   LIVING PROOF, INC.

  990411                  BNPED   20000518ACG   ROSEDALE          CA   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  990411                  BNPED   20000518ACI   SHAFTER           CA   BRIDGE BROADCASTING, INC.

  990411                  BNPED   20000518ACN   LOST HILLS        CA   SJD CHRISTIAN BROADCASTING, INC.

  990411   05/18/00   A   BPED    19990407MD    ROSEDALE          CA   CSN INTERNATIONAL

                                                                       

  990501                  BNPH    19991004AAD   CALHOUN           GA   LIFETALK BROADCASTING
                                                                       ASSOCIATION

  990501                  BNPED   19991004AAF   CALHOUN           GA   WEST COAST EDUCATIONAL
                                                                       INCORPORATED

  990501   10/04/99   A   BPED    19990519MI    REDBUD            GA   HELLINGER FOUNDATION OF GA.,
                                                                       INC.

                                                                       

  990502                  BPED    19990907MD    IDAHO FALLS       ID   EDUCATIONAL MEDIA FOUNDATION

  990502   09/07/99   A   BPED    19990527MF    RIRIE             ID   FAITH COMMUNICATIONS CORP.

                                                                       

  990503                  BNPED   19991026AAE   VALDOSTA          GA   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  990503                  BNPED   19991104AAJ   CROSS CITY        FL   SPIRIT RADIO OF NORTH FLORIDA,
                                                                       INC.

  990503   11/04/99   A   BPED    19990524MC    LIVE OAK          FL   MELODY CHRISTIAN ACADEMY

                                                                       

  990504                  BNPED   19991028AAF   MILLEDGEVILLE     GA   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  990504                  BNPED   19991103ABB   TOOMSBORO         GA   AUGUSTA RADIO FELLOWSHIP
                                                                       INSTITUTE, INC.

  990504   11/04/99   A   BPED    19990514MC    MILLEDGEVILLE     GA   LIFE RADIO MINISTIES

                                                                       

  990505                  BNPED   19991101ABN   WHITESBURG        GA   EDUCATIONAL MEDIA FOUNDATION

  990505                  BNPED   19991102AAM   WHITESBURG        GA   BELCHER SANTA MARIA BROADCASTING
                                                                       INC.

  990505   11/04/99   A   BPED    19990520ME    YATES             GA   BEST MEDIA, INC.

                                                                       

  990506                  BPED    19990902MA    MACKINAW CITY     MI   GREAT LAKES COMMUNITY
                                                                       BROADCASTING \*

  990506                  BNPED   19991028ACT   CHARLEVOIX        MI   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  990506                  BNPED   19991104AAP   GOOD HART         MI   MICHIGAN COMMUNITY RADIO

  990506                  BNPED   19991104ABG   RACO              MI   MICHIGAN COMMUNITY RADIO

  990506   11/04/99   A   BPED    19990528MG    CHARLEVOIX        MI   GREAT LAKES COMMUNITY
                                                                       BROADCASTING

                                                                       

  990508                  BNPED   19991029AAH   LAKE HOPATCONG    NJ   CSN INTERNATIONAL

  990508                  BNPED   19991101ABJ   HOPATCONG         NJ   EDUCATIONAL MEDIA FOUNDATION

  990508                  BPED    19991101ABM   SUSSEX            NJ   NEW JERSEY PUBLIC BROADCASTING
                                                                       AUTH.

  990508                  BNPED   19991104AAH   HOPATCONG         NJ   YOUNGSHINE MEDIA, INC.

  990508   11/04/99   A   BPED    19990519MB    HOPATCONG         NJ   BEST MEDIA, INC.

                                                                       

  990509   11/04/99   A   BPED    19990514MB    BROOKINGS         OR   PACIFIC CASCADE COMMUNICATIONS
                                                                       CORP.

  990509                  BNPED   19991028AAL   BROOKINGS         OR   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

                                                                       

  990510                  BNPED   19991029AAG   WHEELER           OR   TILLICUM FOUNDATION

  990510   11/04/99   A   BPED    19990503MA    TILLAMOOK         OR   OREGON PUBLIC BROADCASTING

                                                                       

  990511   11/17/99   A   BPED    19990526MB    GREENVILLE        TX   BILL R. WRIGHT

  990511                  BNPED   19991115AAS   COMMERCE          TX   FT. WORTH STEPHENSVILLE FM, INC.

  990511                  BNPED   19991116AIV   GREENVILLE        TX   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

                                                                       

  990512                  BNPED   20000118ABT   MARSHFIELD        MA   UNIVERSITY OF MASSACHUSETTS

  990512                  BNPED   20000118ADQ   MARSHFIELD        MA   THE TALKING INFORMATION CENTER

  990512   01/18/00   A   BPED    19990519MC    MARSHFIELD        MA   BEST MEDIA, INC.

                                                                       

  990514                  BNPED   19991213AAJ   ARCADE            NY   FAMILY LIFE MINISTRIES, INC.

  990514   12/15/99   A   BPED    19990630MA    ARCADE            NY   CSN INTERNATIONAL

                                                                       

  990516                  BNPED   20000229AAN   MORGANFIELD       KY   BISHOP COMMUNITY RADIO

  990516   05/03/00   A   BPED    19990505MB    STURGIS           KY   HEARTLAND MINISTRIES, INC.

                                                                       

  990601                  BNPED   19991013AAE   CHESANING         MI   GREAT LAKES COMMUNITY
                                                                       BROADCASTING

  990601                  BNPED   19991026AAF   JACKSON           MI   BROADCASTING FOR THE CHALLENGED,
                                                                       INC.

  990601                  BNPED   19991103ABT   EAGLE             MI   MICHIGAN COMMUNITY RADIO

  990601   11/04/99   A   BPED    19990607ME    JACKSON           MI   GREAT LAKES COMMUNITY
                                                                       BROADCASTING

                                                                       

  990602                  BNPED   19991102AAN   BATH              NC   NORTH CAROLINA PUBLIC BROADCAST
                                                                       INC

  990602   11/04/99   A   BPED    19990621MD    BATH              NC   EDUCATIONAL INFORMATION
                                                                       CORPORATION

                                                                       

  990604                  BPED    19990806MA    ASTORIA           OR   TILLICUM FOUNDATION

  990604                  BNPED   19991117ABK   TILLAMOOK         OR   EDUCATIONAL MEDIA FOUNDATION

  990604                  BNPED   19991117ABL   OCEAN PARK        WA   EDUCATIONAL MEDIA FOUNDATION

  990604   11/17/99       BPED    19990610ME    HAMMOND           OR   PACIFIC LUTHERN UNIVERSITY INC.

                                                                       

  990605                  BNPED   20000118ADC   PENDERGRASS       GA   BELCHER SANTA MARIA BROADCASTING

  990605   01/18/00   A   BPED    19990630MB    PENDERGRASS       GA   WAVES OF MERCY PRODUCTIONS, INC.

                                                                       

  990606   01/18/00   A   BPED    19990618MC    THOMASVILLE       GA   ST BD OF REGENTS OF FLORIDA

  990606                  BNPED   19991214AAJ   GREENVILLE        FL   CSN INTERNATIONAL

  990606                  BNPED   20000111AGV   PAVO              GA   LIVING PROOF, INC.

  990606                  BNPED   20000118AAL   ST. MARKS         FL   CSN INTERNATIONAL

  990606                  BNPED   20000118AEM   MONTICOLLO        FL   EDUCATIONAL MEDIA FOUNDATION

                                                                       

  990607   01/18/00   A   BPED    19990618MA    ORLEANS           MA   LOWER CAPE COMMUNICATIONS, INC.

  990607                  BNPED   20000118AAH   SCITUATE          MA   CSN INTERNATIONAL

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  990609                  BNPED   20000428AAJ   BARNEGAT          NJ   BROADCASTING FOR THE CHALLENGED,
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  990611                  BNPED   19991213AAD   IOWA CITY         IA   BROADCASTING FOR THE CHALLENGED,
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  990701                  BNPED   19991116AIU   SCOTTSBLUFF       NE   BROADCASTING FOR THE CHALLENGED,
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  990711                  BNPED   20000113AAN   BAKER CITY        OR   OREGON PUBLIC BROADCASTING

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  990801                  BNPED   19991117ABO   RUST TOWNSHIP     MI   MICHIGAN COMMUNITY RADIO

  990801   11/17/99       BPED    19990806MB    HUBBARD LAKE      MI   GREAT LAKES COMMUNITY
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  990802   01/18/00   A   BPED    19990830MJ    PAMPA             TX   SALT & LIGHT COMMUNICATIONS,
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  990803   01/18/00   A   BPED    19990824MA    DUMAS             AR   SOUTHPOINT EDUCATIONAL RADIO,
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  990807                  BNPED   20000223AAK   DIAMOND SPRINGS   CA   BROADCASTING FOR THE CHALLENGED,
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  990808   03/03/00   A   BPED    19990813MA    BEACH HAVEN       NJ   COMMUNITY MEDIA SNJ

  990808                  BNPED   20000223AAL   BEACH HAVEN       NJ   BROADCASTING FOR THE CHALLENGED,
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  990808                  BPED    20000224ABO   MANAHAWKIN        NJ   PENN JERSEY EDUCATIONAL RADIO
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  990808                  BNPED   20000229AAL   MEDFORD LAKES     NJ   HOPE CHRISTIAN CHURCH OF
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  990808                  BNPED   20000301AAG   BEACHWOOD         NJ   PENSACOLA CHRISTIAN COLLEGE,
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  990808                  BNPED   20000303AAZ   BRIDGATINE        NJ   CSN INTERNATIONAL

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  990809   05/03/00   A   BPED    19990830MA    COOLIDGE          AZ   LIVING PROOF, INC.

  990809                  BNPED   20000428AAM   COOLIDGE          AZ   BROADCASTING FOR THE CHALLENGED,
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  -------- ---------- --- ------- ------------- ----------------- ---- --------------------------------

[^1]: *Balanced Budget Act of 1997*, Pub. L. No. 105-33, 11 Stat. 251
    (1997) (Balanced Budget Act).

[^2]: *Notice of Proposed Rulemaking, Reexamination of the Policy
    Statement on Comparative Broadcast Hearings*, GC Docket No. 92-52, 7
    FCC Rcd 2664 (1992); *Further Notice of Proposed Rulemaking*, 8 FCC
    Rcd 5475 (1993); *Second Further Notice of Proposed Rulemaking*, GC
    Docket No. 92-52, 9 FCC Rcd 2821 (1994); *Notice of Proposed
    Rulemaking, Competitive Bidding for Commercial Broadcast and ITFS
    Service Licenses*, MM Docket No. 97-234, GC Docket No. 92-52, Gen.
    Docket No. 90-264, 12 FCC Rcd 22,363 (1997*); First Report and
    Order*, MM Docket No. 97-234, GC Docket No. 92-52, Gen. Docket No.
    90-264, 13 FCC Rcd 15920 (1998), *recon. denied Memorandum Opinion
    and Order*, 14 FCC Rcd 8724*, modified Memorandum Opinion and
    Order*, 14 FCC Rcd 12,541 (1999), *aff'd sub nom*. *Orion
    Communications, Ltd. v. FCC*, 213 F.3d 761 (D.C. Cir.2000)
    ("[Competitive Bidding]{.underline}").

[^3]: *Notice of Proposed Rulemaking, Comparative Standards for
    Noncommercial Educational Applicants*, MM Docket 95-31, 10 FCC Rcd
    2877 (1995); *Further Notice of Proposed Rulemaking*, MM Docket No.
    95-31, 13 FCC Rcd 21167 (1998) ("[NCE Notice]{.underline}"); *Report
    and Order*, MM Docket No. 95-31, 15 FCC Rcd 7386 (2000).

[^4]: *Report and Order, Comparative Standards for Noncommercial
    Educational Applicants*, MM Docket No. 95-31, 15 FCC Rcd 7386 (2000)
    ("[NCE Order]{.underline}").

[^5]: Currently, there are approximately 32 pending groups of
    non-reserved channel radio applicants, consisting of 192
    applications, in which at least one applicant is an NCE entity.
    There are 5 such groups of non-reserved channel television
    applicants, consisting of 22 applications. Parties disagreeing with
    our decision to auction non-reserved channels, including National
    Public Radio and the State of Oregon, brought their challenge
    directly to the U.S. Court of Appeals for the D.C. Circuit rather
    than seeking agency reconsideration. [See]{.underline} *National
    Public Radio, No. 00-1246* (filed June 12, 2000)*; State of Oregon,
    No. 00-1255* (filed June 16, 2000). Although two petitioners, Spring
    Arbor College and Lay Catholic Broadcasting, originally sought
    agency reconsideration with respect to this issue, they subsequently
    withdrew those requests.

[^6]: Specifically, an applicant would receive a decisive preference if
    it would provide first or second NCE aural service to at least 10%
    of the people within the proposed 60dBu (1mV/m) service contours,
    but not fewer than 2,000 people. If more than one applicant meets
    this standard, the differences between their proposals would be
    considered significant only if one provided first or second service
    to at least 5,000 more people than the other.

[^7]: [See]{.underline} *AT&T v. FCC*, 974 F.2d 1351, 1354 (D.C. Cir.
    1992).

[^8]: [NCE Notice]{.underline} at 7-8, n. 12 *citing* *Adarand v. Pena*,
    515 U.S. 200 (1995) and *Lutheran Church-Missouri Synod v. FCC*, 141
    F.3d 344, *petition for rehearing denied*, 154 F.3d 487, *petition
    for rehearing en banc denied*, 154 F.3d 494 (D.C. Cir. 1998). [See
    also]{.underline} *Telecommunications Research and Action Center v.
    FCC*, 836 F.2d 1349, 1358 (D.C. Cir. 1988)(agency using lotteries
    must use race-based weightings provided by statute).

[^9]: *Omnipoint Corp. v. FCC*, 78 F.3d 620, 633 (D.C. Cir. 1996) (\"an
    agency may properly consider the avoidance of litigation‑related
    delay when revising its rules").

[^10]: We note that another broadcaster raised similar arguments in an
    appeal filed directly with the U.S. Court of Appeals for the D.C.
    Circuit. [See]{.underline} *American Family Association*, *No.
    00-1310* (filed July 14, 2000).

[^11]: [Petition of EMF]{.underline} at 16-17 *citing FCC v. League of
    Women Voters*, 468 U.S. 364 (1984*); Police Department of Chicago v.
    Mosely,* 408 U.S. 92 (1972); and *Shuttlesworth v. City of
    Birmingham*, 394 U.S. 147 (1969).

[^12]: [See]{.underline} [Petition of EMF]{.underline} at 19-20.

[^13]: Media Education, citing an independent report, states that there
    are 1,731 radio and 285 television stations licensed to religious
    broadcasters, of which over 700 radio and 23 television stations are
    on reserved NCE channels. [Opposition of Center for Media
    Education]{.underline} at 6, n. 3 *citing* Jerold M. Starr, *Signal
    Degradation*, AMERICAN PROSPECT, Aug. 14, 2000, at 22.

[^14]: [See]{.underline} *Turner*, 512 U.S. at 663 (the importance of
    local broadcasting can scarcely be exaggerated); *Cable Television
    Consumer Protection and Competition Act of 1992*, Pub.L. 102-385,
    106 Stat. 1460, § 2(a)(8)(A) ("\[P\]ublic television provides
    educational and informational programming to the Nation's citizens,
    thereby advancing the Government's compelling interest in educating
    its citizens").

[^15]: Consideration of state-wide plans prior to adoption of the point
    system was codified in Section 73.502 of our rules, stating that
    "the Commission will take into consideration the extent to which
    each application meets the requirements of any state-wide education
    plan for noncommercial educational FM stations. . ." That rule has
    been superseded by the more specific state-wide network credit.
    [See]{.underline} [NCE Order]{.underline} at para. 61.

[^16]: [See]{.underline} 47 C.F.R. § 73.7003 (localism points and tie
    breaker factors considered as of date of filing); [NCE
    Order]{.underline}, Appendix A (technical parameters considered as
    of close of filing window); [NCE Order]{.underline} at ¶ 40
    (technical factors must be maintained).

[^17]: Currently pending are 1,369 reserved channel radio applications
    and 67 reserved channel television applications.

[^18]: Under 47 C.F.R. § 1.65 an applicant has an obligation to report
    any material changes in its pending application. For example, with
    respect to authorization count, which can change frequently,
    applicants must update their applications upon occurrence of a
    change that could reduce their position. We stress that the
    applicant has an affirmative Section 1.65 obligation to report any
    change potentially affecting their eligibility for points or
    position in a tie breaker, even with respect to matters on which the
    Commission itself has acted.

[^19]: [See]{.underline} ¶ 6 [supra]{.underline}.

[^20]: Population will be calculated using a block level centroid
    retrieval method, in which the applicant uses "centroid" points
    representing population at designated coordinates as identified by
    the U.S. Census Bureau, to determine the population within the
    applicant's proposed service area. [See]{.underline} [NCE
    Order]{.underline} at ¶¶ 26 and 40.

[^21]: However, the failure to file a point supplement because the
    applicant has instead filed a settlement consistent with paragraphs
    96 to 99 *infra* will not result in dismissal. Only in the event
    that the settlement is denied, and the applicant thereafter fails to
    file a supplement by a new date would such failure to file a
    settlement result in dismissal.

[^22]: [See]{.underline} Public Notice, *FCC Freezes Comparative
    Hearings*, 9 FCC Rcd 1055, *modified*, 9 FCC Rcd 6689 (1994),
    *further modified*, 10 FCC Rcd 2877, 2879; 10 FCC Rcd 12182 (1995).

[^23]: Under the former A/B cutoff procedures, the staff issued an "A"
    list announcing the filing of an initial "A" application. That list
    established an "A" cut-off date, 30 days later, by which any
    applications competing against the "A" application were due. If the
    staff, after study, determined that competing applications were
    received, it would issue a "B" list, identifying all mutually
    exclusive applications and inviting petitions to deny. However,
    given that the current proceeding proposed to change the criteria
    used to evaluate competing applications, issuance of "B" lists
    inviting petitions under the old criteria would have been an
    inefficient use of resources both for the staff and potential
    petitioners. Therefore, among the applications on file, are closed
    groups of applications for which no "B" list was issued.

[^24]: Applicants may not enhance their position based on matters that
    require additional Commission or applicant action. For example, they
    must consider as pending any applications for which their requests
    for withdrawal are conditioned on our approval of a settlement
    agreement. Similarly, they must include as existing authorizations
    any station for which an assignment of license has not yet been
    consummated, even if an application to assign has been filed or
    approved.

[^25]: To ensure efficient processing of NCE FM applications, we waive
    the city grade coverage requirement recently adopted in MM Docket
    No. 98-93 for all mutually exclusive radio applications subject to
    the comparative procedures adopted herein. Absent a waiver, these
    radio applicants would have been required to amend their
    applications by February 19, 2001 to provide a predicted 60 dBu
    strength signal to at least 50% of their communities of license or
    to 50% of the population of the community. [See]{.underline}
    *Streamlining of Radio Technical Rules,* MM Docket No. 98-93, FCC
    00-368, \_\_\_ FCC Rcd \_\_\_ (released November 1, 2000), 65 Fed.
    Reg. 79773 (December 20, 2000). Moreover, we will not accept
    amendments to those applications filed under the "good cause"
    standard where such amendments are intended to establish compliance
    with the new community coverage requirement. We note that petitions
    for reconsideration of this issue were filed in MM Docket No. 98-93,
    and we will act on those petitions in a subsequent order in that
    proceeding.

[^26]: To the extent that the 307(b) standards we will use for NCE
    stations are more stringent than those applied to commercial
    stations, we noted that areas underserved in terms of NCE service
    are not likely to be true "white" or "gray" areas, because areas
    with few NCE signals will likely receive additional service from
    commercial stations [NCE Order]{.underline} at n. 16. We also noted
    that the outcome of a successful 307(b) analysis in commercial TV
    and FM proceedings is the allocation of a channel to a community but
    not to any particular licensee, whereas in an NCE analysis the
    outcome is award of a license.

[^27]: For example, in a group of three applicants serving different
    communities, if two of the applicants would provide first NCE
    service to similarly sized populations, while the other applicant
    proposes only a second or third NCE service, we would conduct a
    point "hearing" only among the applicants proposing first service.
    We would dismiss the third applicant because either one of the
    remaining applicants would have prevailed over that applicant in a
    307(b) determination.

[^28]: NCE FM stations must provide a predicted 60 dBu signal to at
    least 50 percent of the area or population of the community of
    license, whereas commercial stations must provide a 70 dBu signal to
    the entire community of license. [See]{.underline} *Streamlining of
    Radio Technical Rules,* MM Docket No. 98-93, FCC 00-368, \_\_\_ FCC
    Rcd \_\_\_ (released November 1, 2000). [See also]{.underline} note
    25 *supra*.

[^29]: In describing to Congress the vision for educational television,
    the Carnegie Report identified "local stations," as having the
    "heart of the system . . . in the community," and maintaining "a
    firm grasp on the nature and needs of the people it serves." [NCE
    Order]{.underline} at ¶ 44.

[^30]: [See]{.underline} [NCE Order]{.underline} at ¶ 47 *citing*
    *Joint* *Comments of National Public Radio, Association of America's
    Public Television Stations* and the *Corporation for Public
    Broadcasting*.

[^31]: In this sense, we clarify that NCE licensees and the stations
    they operate, may be viewed as similar in many ways to school boards
    and the schools they operate. Our nation's schools are primarily
    locally controlled, with each public school board or private board
    of trustees having sufficient knowledge about its respective
    communities to run schools in a way that responds to that
    community's educational needs. Indeed, such boards have vested
    interests in being responsive because they will be held accountable
    to their communities for schools that do not live up to their
    community's standards.

[^32]: [See]{.underline} 47 C.F.R. § 73.1125(a)(3) (establishing 25
    miles from the reference coordinates of the center of the community
    of license as one of three acceptable locations for a broadcast
    station's main studio).

[^33]: [See]{.underline} [Ascertainment of Community Problems by
    Broadcast Applicants]{.underline}, 41 Fed. Reg. 1372, 1384 (January
    7, 1976). Although we no longer require formal ascertainment, the
    elements articulated in a "community leader checklist" continue to
    be used to determine whether NCE television applicants are broadly
    representative. [See]{.underline} [NCE Notice]{.underline} at n.27.

[^34]: *Creation of Low Power Radio Service*, MM Docket No. 99-25,
    *Report and Order*, 15 FCC Rcd 2205, *mod'd on other grounds*,
    *Memorandum Opinion and Order*, 15 FCC Rcd 19,208 (2000).

[^35]: With respect to radio, the principal community (city grade)
    contours are the 5 mV/m for AM stations under Section 73.24(I), and
    the 3.16 mV/m for FM stations calculated in accordance with Section
    73.313(c). With respect to television, a station's principal
    community (city grade) contour is either the 74, 77, or 80 dBu
    contour, depending on the particular channel on which it operates,
    as described further in Sections 73.684 and 73.685.

[^36]: AACC identifies four categories of community colleges: (1) those
    that are part of the state university system; (2) those under the
    direct control of state community college board; (3) those in which
    control is divided between state boards and locally elected or
    appointed officials; and (4) those in which a local board has all
    governing authority, with a state board serving a general
    coordination and policy function. [Comments of AACC]{.underline} at
    5.

[^37]: This rule section establishes the eligibility of "an
    organization, public or private, with or without direct authority
    over schools, that will regularly provide programming for and in
    coordination with \[entities with the required number of
    schools/campuses\] for use in the school curriculum." 47 C.F.R. §
    73.7003(b)(3)(c).

[^38]: [See]{.underline} 47 C.F.R. § 73.3555, n.2(h).

[^39]: Footnote 59 and rule section 74.1233(e)(3), could be understood
    as considering translators other than fill-in stations for purposes
    of tie breakers only in connection with an application for another
    non-fill-in translator station. The tie breaker summary in Appendix
    A might be read to exclude translator and AM stations.

[^40]: It generally should not count fill-in FM translator stations,
    which simply fill dead spots in the contours of the applicant's full
    service station. Only if the radio applicant is specifically seeking
    a fill-in translator station should the applicant report its number
    of other fill-in stations, to be used in the event that we receive
    mutually exclusive fill-in proposals.

[^41]: Specifically, there are 439 groups of reserved channel full
    service FM applicants, consisting of 1,356 applications, and 31
    groups of reserved channel television applicants, consisting of 89
    applications. There are 43 groups of FM translator applicants,
    consisting of 97 applications. Our preliminary studies only identify
    mutual exclusivity between applications of the same type, and not,
    for example, whether proposals in FM translator applications are
    consistent with facilities proposed in full service FM applications.
    Additionally, full service FM applications were studied based on
    technical rules in place at time of filing. Specifically, the staff
    did not consider technical changes in the protection ratios adopted
    in *Streamlining or Radio Technical Rules*, MM Docket No. 98-93, FCC
    00-368 (November 1, 2000), untimely amendments, or post April 21,
    2000 amendments.

[^42]: As discussed in the [NCE Order]{.underline}, use of the point
    system is considered a simplified hearing and the Communications Act
    does not yet allow the Commission to delegate authority over NCE
    point hearings to the staff. [See]{.underline} 47 U.S.C.§ 155(c).
    Thus, initially, these matters will be referred to the Commission.
    The Commission, as suggested by Station Resource Group, will request
    Congressional authority to delegate these matters to the staff
    similar to that received when point systems were used in the
    Instructional Fixed Television Service.

[^43]: We generally will not apply the point system to any comparative
    FM translator proceedings for which we made initial selections
    before the August 7, 2000 effective date of the point system. Any
    requests for reconsideration of those decisions will be examined
    under the rules in effect at the time of the initial selection.

[^44]: [See]{.underline} [NCE Order]{.underline} at ¶ 5, *citing Real
    Life Educational Foundation of Baton Rouge, Inc.*, 6 FCC Rcd 2577,
    2580, n.8 (Rev. Bd. 1991).

[^45]: [See]{.underline} *Community* *Television, Inc. v. Federal
    Communications Commission*, 216 F.3d 1133, 1143 (D.C. Cir. 2000);
    *Chadmoore Communications, Inc. v. Federal Communications
    Commission*, 113 F.3d 235, 240-241 (D.C. Cir. 1997) (application of
    rule changes to pending applications is not considered retroactive
    rulemaking).

[^46]: The settlement discussion herein does not affect the rights of
    any NCE television applicants that by July 17, 2000, filed
    settlements pursuant to the procedures set forth in DA 99-2605 (as
    extended by DA 00-536), which permitted applicants on television
    channels 60-69 and applicants in television freeze areas to settle
    their mutually exclusive applicant groups, to file petitions for
    rulemaking specifying a new \"core\" television channel (between 2
    and 51) and/or to amend their applications to provide the requisite
    interference protection to the digital television Table of
    Allotments. For those applicants, we will consider the settlement
    agreements and technical proposals already on file. *See* \"Mass
    Media Bureau Announces Window Filing Opportunity For Certain Pending
    Applications and Allotments Petitions for New Analog TV Stations,\"
    *Public Notice*, DA 99-2605, released November 22, 1999; and
    \"Window Filing Opportunity for Certain Pending Applications and
    Allotment Petitions for New Analog TV Stations Extended to July 15,
    2000,\" *Public Notice*, DA 00-536, released March 9, 2000.

[^47]: [See]{.underline} 5 U.S.C. § 603. The RFA, [see]{.underline} 5
    U.S.C. § 601 et. seq., has been amended by the Contract with America
    Advancement Act of 1996, Pub. L. No. 104‑ 121, 110 Stat. 847 (1996)
    (\"CWAAA\"). Title II of the CWAAA is the Small Business Regulatory
    Enforcement Fairness Act of 1996 (\"SBREFA\").

[^48]: *In the Matter of Reexamination of the Comparative Standards for
    Noncommercial Educational Applicants,* MM Docket No. 95-31, *Further
    Notice of Proposed Rule Making,* 13 FCC Rcd 21167 (1998) ([Further
    Notice]{.underline}); *Report and Order,* 15 FCC Rcd 7386 (2000).

[^49]: This FRFA conforms to the RFA, as amended by the Contract with
    America Advancement Act of 1966, Pub. L. 104‑121, 110 Stat. 847
    (1996) (\"CWAAA\"). Subtitle II of the CWAAA is The Small Business
    Regulatory Enforcement Fairness Act of 1996 (\"SBREFA\").

[^50]: [See]{.underline} 5 U.S.C. § 604.

[^51]: 5 U.S.C. § 603(b)(3).

[^52]: Small Business Act, 15 U.S.C. § 632 (1996).

[^53]: 5 U.S.C. § 601(4).

[^54]: 1992 Economic Census, U.S. Bureau of Census, Table 6 (special
    tabulation of data under contract to Office of Advocacy of U.S.
    Small Business Administration).

[^55]: 5 U.S.C. § 601(4).

[^56]: 13 C.F.R. § 121.201, SIC code 4832.

[^57]: 1992 Census, Series UC92-S-1, at Appendix A-9.

[^58]: The Census Bureau counts radio stations located at the same
    facility as one establishment. Therefore, each colocated AM/FM
    combination counts as one establishment.

[^59]: FCC News Release, No. 31327 (January 13, 1993).