**Before the**

**Federal Communications Commission**

**Washington, D.C. 20554**

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| In the Matter of                 | *  | MB Docket No. 03-120         |
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| Amendment of Section 73.202(b),  | ** | RM-10591                     |
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| Table of Allotments,             | *  | RM-10839                     |
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| FM Broadcast Stations.           | ** |                              |
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| (Lake City, Chattanooga,         | *  |                              |
| Harrogate, and                   | *) |                              |
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| Halls Crossroads, Tennessee)[^1] |    |                              |
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**REPORT AND ORDER**

**Adopted: November 23 , 2005 Released: November 25, 2005**

By the Assistant Chief, Audio Division, Media Bureau:

1.  The Audio Division has before it: (1) a *Notice of Proposed Rule
    Making* ("*NPRM*")[^2] issued at the request of Ronald C. Meredith
    ("Petitioner"); (2) supporting comments filed by the Petitioner; (3)
    a counterproposal filed by JBD Incorporated ("JBD"); (3) two reply
    comments filed by the Petitioner in response to the *NPRM* and the
    *Public Notice* of JBD's counterproposal; and (4) other related
    pleadings.[^3] For the reasons discussed below, we grant JBD's
    counterproposal and deny the Petitioner's rulemaking petition.

    **BACKGROUND**

2.  At the request of the Petitioner, the *NPRM* proposed the allotment
    of Channel 244A to Lake City, Tennessee (pop. 1,888) as a first
    local service. To accommodate this new allotment, the *NPRM*
    proposed to downgrade Station WDOD-FM, Chattanooga, Tennessee, from
    Channel 243C to Channel 243C0. The Petitioner filed brief supporting
    comments, reiterating his continuing interest to file an application
    to construct an FM station on Channel 244A at Lake City.

3.  In response to the *NPRM*, JBD, licensee of Station WXJB(FM),
    Harrogate, Tennessee, timely filed a counterproposal[^4] to
    substitute Channel 244A for Channel 243A at Harrogate, to reallot
    Channel 244A to Halls Crossroads, Tennessee, and to modify the
    license for Station WXJB(FM) to specify operation on Channel 244A
    pursuant to the provisions of Section 1.420(i) of the Commission's
    Rules.[^5] JBD contends that its counterproposal meets the
    requirements for a station to change its community of license
    because (1) the proposed use of Channel 244A at Halls Crossroads is
    mutually exclusive with the current use of Channel 243A at
    Harrogate; (2) Harrogate (pop. 2,865) will not be deprived of its
    only local service as Stations WLMU(FM), Channel 217A, and WRWB(AM),
    740 kHz, will remain licensed to Harrogate; and (3) the provision of
    a first local service at Halls Crossroads (pop. 11,683)[^6] under
    Priority 3 of the FM Allotment Priorities will result in a
    preferential arrangement of allotments over the retention of a third
    local service at Harrogate under Priority 4.[^7]

4.  Because Halls Crossroads is partially located within the Knoxville,
    TN, Urbanized Area, JBD submitted a *Tuck*[^8] showing, seeking to
    demonstrate the independence of Halls Crossroads from Knoxville, and
    to justify a first local service at Halls Crossroads. JBD further
    contends that the proposed reallotment and change of community of
    license will result in a gain of service to 391,354 persons and a
    loss of service to 64,786 persons for a net gain of 326,568 persons
    and the elimination of three existing short-spacings. JBD also
    alleges that the loss area will continue to remain well served with
    five or more reception services.

5.  JBD's counterproposal is mutually exclusive with the Petitioner's
    rulemaking petition because Channel 244A at Lake City, TN, is
    short-spaced to Channel 244A at Halls Crossroads.[^9] Although both
    proposals would provide first local services, triggering Priority 3,
    JBD argues that Halls Crossroads should be preferred under
    established precedent because of its greater population.[^10]

6.  In its first reply comments, the Petitioner submits a technical
    statement, seeking to demonstrate that JBD's counterproposal is not
    eligible for consideration because the proposed transmitter site for
    Channel 244A at Lake City will not provide sufficient line of sight
    coverage to the community of license. Specifically, the Petitioner
    submits ten path studies which assume that Station WXJB(FM) will
    operate with an HAAT of no more than 125 meters to demonstrate lack
    of city-grade coverage in Halls Crossroads.

7.  In its second reply comments, the Petitioner contends that Halls
    Crossroads is not a community for allotment purposes. The Petitioner
    states that Halls Crossroads cannot be presumed to be a community
    for allotment purposes because it is not incorporated or listed in
    the U.S. Census. Indeed, the Petitioner alleges that JBD overstated
    the area and population of Halls Crossroads and that its population
    is 1900.[^11] Further, the Petitioner questions the indicia of
    community status relied upon by JBD. For example, while JBD listed
    numerous businesses, the Petitioner contends that JBD has not shown
    that these businesses are intended to serve the residents of Halls
    Crossroads as opposed to the North Knoxville area. In addition, the
    Petitioner questions JBD's *Tuck* showing and argues that a majority
    of the factors do not demonstrate the independence of Halls
    Crossroads from the Knoxville Urbanized Area.

8.  In its Supplement, JBD seeks to rebut the Petitioner's assertion
    that a terrain obstruction will prevent Station WXJB(FM) from
    providing the requisite city-grade coverage to Halls Crossroads. In
    support of this position, JBD argues that the Petitioner made an
    incorrect assumption that the proposed HAAT for Station WXJB(FM)
    will be, at most, 125 meters. However, the Petitioner states that
    the proposed tower for Station WXJB will be between 175 and 205
    meters AGL (or between 232 and 252 meters HAAT) and that at this
    height, both the standard predicted 70 dBu contour and the
    Longley-Rice 70 dBu contour of WXJB(FM) will cover 100 percent of
    Halls Crossroads.

9.  Finally, with respect to the Petitioner's arguments about the *Tuck*
    showing, JBD responds that the Petitioner confuses the city of
    Knoxville with Knox County. Although JBD acknowledges that Halls
    Crossroads is located in Knox County and is dependent on Knox County
    for some of its municipal services, JBD contends that that it is
    common for an independent community to rely on county services. JBD
    emphasizes that Halls Crossroads does not rely on Knoxville for
    these services.

    **DISCUSSION**

10. As a threshold matter, we must address the Petitioner's objections
    to JBD's counterproposal. First, with respect to the alleged terrain
    obstruction, the Commission's rules permit construction of, and JBD
    is willing to construct, a tower high enough to clear the alleged
    terrain obstruction.[^12] Further, we agree with JBD's technical
    study that an HAAT of between 232 and 252 meters will provide a
    clear line of sight to the community of Halls Crossroads and that
    the standard predicted 70 dBu contour will cover 100 percent of
    Halls Crossroads.[^13] Accordingly, JBD's counterproposal complies
    with the Commission's technical requirements.

11. Second, contrary to the Petitioner's assertions, we find that Halls
    Crossroads is a community for allotment purposes. Although Halls
    Crossroads is not incorporated or listed in the U.S. Census, JBD has
    demonstrated sufficient indicia of community status consistent with
    leading Commission level decisions on this subject [^14]
    Specifically, the Petitioner has shown the existence of businesses,
    health care facilities, churches, a weekly newspaper, and civic
    organizations in Halls Crossroads. Further, while the Petitioner
    alleges that some of these businesses are intended to serve more
    than the residents of Halls Crossroads, JBD has identified numerous
    businesses that have "Halls Crossroads" in their names, establishing
    a nexus between these businesses and Halls Crossroads.[^15]

12. Third, we find that JBD's *Tuck* showing demonstrates that Halls
    Crossroads is sufficiently independent of the Knoxville, Tennessee,
    Urbanized Area to warrant a first local service because a majority
    of the eight *Tuck* factors are present.[^16] We will briefly review
    each of these factors.

13. The first factor, the extent to which the community residents work
    in the larger metropolitan area, rather than the specified
    community, has not been sufficiently documented to support a finding
    of independence. Although JBD generally alleges, based upon the
    opinion of a staff member of the *Halls Shopper News,* that a large
    number of Halls Crossroads residents both live and work in Halls
    Crossroads, the Petitioner provides demographic information from the
    U.S. Census, showing that the mean travel time to work for the 1,910
    members of the workforce in Census Tract 62.02 and the 2,169 members
    of the workforce in Census Tract 62.03 was 26 minutes and 23
    minutes, respectively. Taking into account traffic, speed limits,
    and travel distances, the Petitioner argues that these average
    commuting times demonstrate that a majority of the Halls Crossroads
    residents work in Knoxville or other parts of the Knoxville
    Urbanized Area. However, we have found that a small percentage of
    the workforce, such as 16 percent[^17] or 14.6 percent,[^18]
    employed in the community is significant and can justify a favorable
    finding under *Tuck* factor 1. Nevertheless, JBD has not documented
    that this level of employment of local residents in Halls Crossroads
    has been met.

14. The second factor, whether the smaller community has its own
    newspaper or other media that covers the community's needs and
    interests, supports a finding of independence and is evidenced by
    the *Halls Shopper News*, a weekly newspaper. Although the
    Petitioner alleges that this publication is not exclusively for the
    Halls Crossroads area but rather the region of North Knoxville/North
    Knox County, the presence of a local newspaper covering a
    community's local needs and interests is sufficient for a favorable
    finding on this issue.[^19] In this regard, JBD has shown that the
    *Halls Shopper News* contains local community and business news, a
    classified section, and advertisements. Further, JBD submits e-mails
    from many readers, commenting on coverage of local issues covered by
    the newspaper.

15. The evidence submitted on the third factor, whether community
    leaders and residents perceive the specified community as being part
    of, or separate from, the larger metropolitan area, favors a finding
    of independence. JBD has submitted the view of the Branch Manager of
    the Halls Branch Library and e-mails from readers of the *Halls
    Shopper News*, showing that they perceive Halls Crossroads as having
    an identity separate from the Urbanized Area.[^20] The Petitioner
    seeks to rebut this evidence by stating that the Halls Crossroads
    area is included in the 4^th^ District of the Knoxville City Council
    and District 7 of the Knox County Commission, that one of the County
    Commissioners, who lives in the Halls Crossroads area, serves on the
    boards of various Knoxville organization, and that other community
    leaders, by their affiliations, residences, and places of business,
    demonstrate that there is no separation from Knoxville. Further, the
    Petitioner submits several letters from Lake City, Tennessee,
    residents and leaders, contending that the Halls Crossroads area is
    part of Knoxville and that Lake City has a greater need for a radio
    station than Halls Crossroads. However, the location of parts of
    Halls Crossroads within Knox County or Knoxville or the
    participation of a County Commissioner on the Boards of various
    Knoxville organizations does not sufficiently rebut the views of
    local residents who perceive their community as having an identity
    separate from the Urbanized Area. Likewise, the Petitioner's letters
    reflect the views of several residents of the competing community of
    Lake City, Tennessee, on this matter as opposed to the opinions of
    the actual residents of Halls Crossroads.

16. The fourth factor, whether the specified community has its own local
    government and elected officials, is not present. JBD acknowledges
    that Halls Crossroads is unincorporated and does not have a local
    government or elected officials, yet JBD seeks to rely upon the
    presence of a County Clerk Office branch and recycling center in
    Halls Crossroads in support of this factor. However, the Petitioner
    points out that the branch office and recycling center are operated
    by Knox County, not the community of Halls Crossroads.

17. The fifth factor, whether the smaller community has its own local
    phone book or zip code, is met. Halls Crossroads is listed as a
    separate section of a local telephone book even though the community
    does not have its own zip code.

18. The sixth factor, whether the community has its own commercial
    establishments, health facilities, and transportation systems,
    supports a finding of independence. JBD has established that Halls
    Crossroads is home to a variety of businesses, commercial
    establishments, and health care providers.[^21] Although the
    Petitioner contends that not all of these businesses are located
    within Halls Crossroads, we find that many of the listed businesses
    identify with the community by using "Halls" in their names.[^22]

19. The evidence on the seventh factor, the extent to which the
    specified community and the central city are part of the same
    advertising market, favors a finding of independence. Although JBD
    contends that local businesses can advertise in the *Halls Shopper
    News*, enabling them to reach the residents of Halls Crossroads
    without relying primarily on Knoxville media sources, the Petitioner
    responds that the *Halls Shopper News* does not primarily rely on
    the residents of the Halls Crossroads area but also serves Union
    County, Fountain City, Gibbs, Corryton, Powell, Copper
    Ridge/Brickery, along with the Halls Crossroads area. Further,
    according to the Circulation/Research Department at the *Knoxville
    News-Sentinel*, 8,798 subscriptions to the *Knoxville News-Sentinel*
    exist within the zip coade 37938, which was listed by JBD as
    encompassing the Halls Crossroads area, indicating that Halls
    Crossroads may not be a separate advertising market. However, we
    have found that the ability of local businesses to advertise in a
    local newspaper is sufficient for a favorable finding on this
    issue.[^23] Even though the *Halls Shopper News* serves other nearby
    communities, it is available as an advertising vehicle for local
    businesses without having to rely on other Knoxville media sources,
    which justifies a favorable finding on this factor.

20. The eighth factor, the extent to which the specified community
    relies on the larger metropolitan area for various municipal
    services such as police, fire protection, schools, and libraries,
    supports a finding of interdependence. Although JBD contends that
    the Halls Center provides many municipal services to its residents
    including Marriage and Drivers Licenses, other motor vehicle
    services, notary public, business license tax, and computer lab, the
    Petitioner demonstrates that all of these services are provided by
    Knox County, not Halls Crossroads. Indeed, the Petitioner points out
    that the schools, fire department, and police department are also
    provided by Knox County.

21. Overall, five of the eight factors[^24] support a finding of
    independence, and three of the factors[^25] support interdependence.
    Because a majority of the *Tuck* factors favor independence, we
    conclude that Halls Crossroads is sufficiently independent from the
    Knoxville Urbanized Area to warrant being credited with a first
    local service for purposes of implementing the FM Allotment
    Priorities.[^26]

22. We next must determine whether the proposed reallotment and change
    of community of license for Station WXJB(FM) from Channel 243A at
    Harrogate to Channel 244A at Halls Crossroads meets the requirements
    of Section 1.420(i) of the Commission's rules and our policies on
    change of community of license and is, therefore, eligible for
    comparison with the proposed new allotment at Lake City. In this
    regard, we find that the reallotment would result in a preferential
    arrangement of allotments. Specifically, the reallotment of Channel
    244A to Halls Crossroads (pop. 11,683) could provide that community
    its first local service, triggering Priority 3. By way of
    comparison, the retention of Channel 243A at Harrogate (pop. 2,865)
    would provide the community with its third local service, triggering
    less significant Priority 4. Although there would be loss of service
    to 64,786 persons, those people are already well served with five or
    more reception services.

23. Conflicting proposals are comparatively considered under the
    Commission's FM allotment priorities. A staff study has revealed
    that there is no alternative Class A channel available for Lake City
    or Halls Crossroads. Accordingly, the proposals must be compared.
    Although each proposal would result in a first local service,
    triggering Priority 3, a first local service to Halls Crossroads
    (pop 11,683) is preferred over a first local service to the smaller
    community of Lake City (pop. 1,888).[^27] We recognize, however,
    that the Petitioner disputes the population figure of 11,683 for
    Halls Crossroads submitted by JBD and asserts that the population
    is 1900. However, even using the more conservative estimate by the
    Petitioner, Halls Crossroads would still be favored because its
    population is greater than the population of Lake City, which is
    1,888.[^28]

24. We will, therefore, reallot Channel 244A to Halls Crossroads,
    Tennessee.[^29] We will also downgrade Station WDOD-FM, Chattanooga,
    Tennessee, from Channel 243C to Channel 243C0 in view of Station
    WDOD-FM's response to the reclassification *Order to Show
    Cause*.[^30]

25. Accordingly, pursuant to the authority contains in 47 U.S.C.
    Sections 4(i), 5(c)(1), 303(g) and (r), and 307(b), and 47 C.F.R.
    Sections 0.61, 0.204(b), and 0.283, IT IS ORDERED, That effective
    January 9, 2006. the FM Table of Allotments, 47 C.F.R. Section
    73.202(b), IS AMENDED, with respect to the communities listed below,
    as follows:

    [Community]{.underline} [Channel No.]{.underline}

    Chattanooga, Tennessee 222C, 243C0, 293C

    Halls Crossroads, Tennessee 244A

    Harrogate, Tennessee \--

26. IT IS FURTHER ORDERED, That, pursuant to Section 316 of the
    Communications Act of 1934, as amended, the license for Station
    WXJB(FM) Channel 243A, Harrogate, Tennessee, IS MODIFIED to specify
    operation on Channel 244A at Halls Crossroads, Tennessee, subject to
    the following conditions:

```{=html}
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(a) Within 90 days of the effective date of this *Order*, the licensee
    shall submit to the Commission a minor change application for a
    construction permit (Form 301), specifying the new facility;

(b) Upon grant of the construction permit, program tests may be
    conducted in accordance with 47 C.F.R. Section 73.1620; and

(c) Nothing contained herein shall be construed to authorize a change in
    transmitter location or to avoid the necessity of filing an
    environmental assessment pursuant to 47 C.F.R. Section 1.1307,
    unless the proposed facilities are categorically excluded from
    environmental processing

```{=html}
<!-- -->
```
27. Pursuant to 47 C.F.R. Sections 1.1104(1)(k) and 3(l), JBD,
    Incorporated is required to submit a rulemaking fee in addition to
    the fee required for the application to effectuate the change of
    community of license for Station WXJB(FM) at the time its Form 301
    application is submitted.

28. The Commission will send a copy of this *Report and Order* in a
    report to be sent to Congress and the Government Accountability
    Office pursuant to the Congressional Review Act, *see* 5 U.S.C. §
    801(a)(1)(A).

29. IT IS ORDERED, That the rulemaking petition (RM-10591) filed by
    Ronald C. Meredith IS DENIED.

30. IT IS FURTHER ORDERED, That the counterproposal (RM-10839) filed by
    JBD Incorporated IS GRANTED.

31. IT IS FURTHER ORDERED, That this proceeding IS TERMINATED.

32. For further information concerning this proceeding, contact
    Andrew J. Rhodes, Media Bureau, (202) 418-2180.

    FEDERAL COMMUNICATIONS COMMISSION

    John A. Karousos

    Assistant Chief

    Audio Division

    Media Bureau

[^1]: The communities of Harrogate and Halls Crossroads, TN, have been
    added to the caption.

[^2]: *Lake City and Chattanooga, TN,* 18 FCC Rcd 10393 (MB 2003).

[^3]: On August 19, 2004, JBD filed a Motion to Accept Supplement and a
    Supplement to inform the Bureau of a recent case that it contends is
    relevant to one of the issues in this proceeding. On September 20,
    2004, the Petitioner filed a Motion to Strike the supplement,
    contending that the Supplement goes beyond apprising the Commission
    of *Banks, Redmond, Sunriver, Corvallis, and The Dalles, OR,* 19 FCC
    Rcd 10068 (2004) ("*The Dalles*"), and seeks to respond to the
    Petitioner's reply comments. On September 30, 2004, JBD filed an
    Opposition to Motion to Strike. We deny the Motion to Strike and
    accept the Supplement because it will facilitate resolution of this
    case.

[^4]: JBD's counterproposal was placed on *Public Notice* on January 12,
    2004, Report No. 2643.

[^5]: This rule permits the modification of a station's authorization to
    specify a new community of license without affording other
    interested parties an opportunity to file competing expressions of
    interest.

[^6]: Because Halls Crossroads is not listed in the U.S. Census, JBD
    submitted a population figure determined by a demographic specialist
    at the Knoxville Area Chamber Partnership, using 2000 U.S. Census
    data. Specifically, the population figure of 11,683 was arrived at
    by adding Census Tracts 62.02 (pop. 3,701), 62.03 (pop. 4,482),
    which the Petitioner contends consist exclusively of Halls
    Crossroads residents, and an estimated 3,500 of the 8,646 residents
    of Census Tract 62.04, who are also allegedly Halls Crossroads
    residents.

[^7]: The FM allotment priorities are: (1) first full-time aural
    service; (2) second full-time aural service; (3) first local
    service; and (4) other public interest matters. \[Co-equal weight is
    given to priorities (2) and (3).\] *See Revision of FM Assignment
    Policies and Procedures,* 90 FCC 2d 88 (1982).

[^8]: *Faye and Richard Tuck,* 3 FCC Rcd 5374, 5378 (1988).

[^9]: *See* 47 C.F.R. § 73.207. The required spacing between Channel
    244A at Lake City and Channel 244A at Halls Crossroads is 115
    kilometers whereas the actual spacing between these proposals is 23
    kilometers.

[^10]: *See, e.g., Blanchard, LA, and Stephens, AR,* 10 FCC Rcd 9828
    (1995). An application (BPED-19960710MA) for a noncommercial
    educational FM radio station was pending for Lake City prior to the
    filing of the Petitioner's rulemaking petition, which could have
    provided a first local service to Lake City; however, that
    application was dismissed by letter July 29, 2005. *See DA* 05-2025.

[^11]: Based upon information obtained from a staff member of the
    Knoxville Metropolitan Planning Commission, the Petitioner contends
    that the area of Halls Crossroads is the corner in which Census
    Tracts 62.01, 62.02, 62.03, and 62.04 intersect. The Petitioner's
    source for its population figure is the Rand McNally Map Company.

[^12]: 47 C.F.R. § 73.211(b)(2). Although the standard HAAT for Class A
    FM stations is 100 meters, this section provides that the standard
    HAAT can be exceeded if its ERP is reduced such that the reference
    distance does not exceed the class contour distance.

[^13]: *See The Dalles,* 19 FCC Rcd at 10074.

[^14]: *See, e.g., Kenansville, Florida,* 10 FCC Rcd 9831 (1995) (the
    presence of two indicia, civic organizations and businesses,
    warranted a finding of community status); *Beacon Broadcasting,* 2
    FCC Rcd 3469 (1987); and *Seven Locks Broadcasting, Co.,* 37 FCC 82
    (1964).

[^15]: *See* JBD's Counterproposal at 7-8.

[^16]: *See, e.g., Wallace, ID, and Lolo, MT,* 14 FCC Rcd 21110 (MMB
    1999) (the community of Lolo found to be interdependent on Missoula,
    MT, Urbanized Area because a majority of the *Tuck* factors have not
    been met); *Chillicothe, Dublin, Hillsboro, and Marion, OH,* 20 FCC
    Rcd 6305 (MB 2005) (all of the *Tuck* factors need not favor a
    reallotment; a majority of the factors must be present).

[^17]: *See Anniston and Ashland, AL, and College Park, GA,* 16 FCC Rcd
    3411, 3413 (MMB 2001).

[^18]: *See Talladega and Munford, AL,* 20 FCC Rcd 13010 (MB 2005).

[^19]: *See, e.g., Anniston and Ashland, AL, and College Park, GA,* 16
    FCC Rcd at 3413.

[^20]: *See, e.g., Pleasanton,, Bandera, Hondo, and Schertz, TX,* 15 FCC
    Rcd 3068 (MMB 2000) (letter from community leader demonstrated
    independence of community).

[^21]: *See Farmersville, Texas,* 12 FCC Rcd 4099 (MMB 1997) (community
    found to be independent because of presence of some local
    businesses, churches, parks, and a library); *Mechanicsville,
    Ruckersville, Williamsburg, and Fort Lee, VA,* 11 FCC Rcd 5758 (MMB
    1996).

[^22]: *See, e.g., Talladega and Munford, AL,* 20 FCC Rcd at 13012.

[^23]: *See Anniston and Ashland, AL, and College Park, GA,* 16 FCC Rcd
    at 3413; and *Ada, Newcastle, and Watonga, OK,* 11 FCC Rcd 16896
    (MMB 1996).

[^24]: *Tuck* factors 2, 3, 5, 6, and 7.

[^25]: *Tuck* factors 1, 4, and 8.

[^26]: *See, e.g., Parker and Port St. Joe, FL,* 11 FCC Rcd 1095, 1096
    (MMB 1996) (majority of the eight factors indicate that Parker is
    independent of the Panama City, FL, Urbanized Area); *Talladega and
    Munford, AL,* 20 FCC Rcd at 13012-13 (majority of *Tuck* factors
    demonstrate that Munford is independent of urbanized area); and
    *Chillicothe, Dublin, Hillsboro, and Marion, OH,* 20 FCC Rcd at 6305
    (majority of *Tuck* factors show that Dublin is independent of
    Columbus, OH, Urbanized Area).

[^27]: *See, e.g., Ardmore, AL,* 17 FCC Rcd 16331, 16334-35 (MB 2002);
    *Three Oaks and Bridgman, MI,* 5 FCC Rcd 1004 (MMB 1990); and
    *Blanchard, LA, and Stephens, AR,* 10 FCC Rcd 9828 (1995).

[^28]: As a collateral matter, the Petitioner submitted a memorandum of
    events surrounding a meeting with a principal of JBD's engineering
    consultants, regarding what the Petitioner believes to be JBD's
    motivation to "move-in" a small rural station into the Knoxville
    Urbanized Area in order to increase the value of the station. JBD
    responds that the Petitioner had previously offered to buy Station
    WXJB(FM) at a price that JBD felt was unacceptable and alleges that,
    following that attempt, the Petitioner filed its Lake City Petition
    in this proceeding, which appears to be an attempt to block the
    proposed relocation of Station WXJB(FM) from Harrogate to Halls
    Crossroads. These allegations, however, do not warrant further
    action. The Petitioner's argument regarding the economic motivation
    of JBD to increase the value of its station and to serve Knoxville
    is speculative and is more appropriately raised when a license
    renewal application is filed. *See Magnolia, AR, and Oil City, LA,*
    18 FCC Rcd 8542, 8543 (MB 2003). By way of contrast, our concern at
    the allotment stage is whether the proposal would serve the public
    interest under the established allotment criteria discussed above.
    Further, no extrinsic evidence has been submitted, indicating that
    the Petitioner's rulemaking petition was filed as a "strike
    petition" or that the Petitioner does not have an intent to provide
    service to Lake City.

[^29]: The reference coordinates for Channel 244A at Halls Crossroads
    are 36-09-43 and 83-58-33.

[^30]: The reference coordinates for Channel 243C0 at Chattanooga are
    35-09-39 and 85-19-11.