1
 
 
 
The Impact of the FCCs TV Duopoly Rule Relaxation on Minority and 
Women Owned Broadcast Stations 1999-2006 
 
 
 
 
 
 
 
 
 
 
By: 
Prof. Allen S. Hammond, IV, Santa Clara University School of 
Law, Founding Director, BroadBand Institute of California (BBIC) 
 
With: 
Prof. Barbara OConnor, California State University, Sacramento 
 And 
 Prof. Tracy Westin, University of Colorado 
 
Consultants: 
Prof. Alexander Field, Santa Clara University 
And 
Assoc. Prof. Catherine Sandoval, Santa Clara University School of 
Law, Co-Director, BBIC 
 
 2
The Impact of the FCCs TV Duopoly Rule Relaxation on Minority and 
Women Owned Broadcast Stations 1999-2006
1
 
 
Executive Summary 
 
This study was commissioned to ascertain the impact of the Television Duopoly 
Rule (TVDR) on minority and female ownership of television broadcast stations.  
Currently, the only FCC rule deemed to be favorable to minority and female 
broadcast ownership is the Failed Station Solicitation Rule (FSSR) of the TVDR. 
 
The TVDR originally prohibited the ownership of more than one television 
broadcast station in a market.  In 1996, due to industry efforts to protect market 
gains realized through the use of local management agreements (LMAs)
2
, the 
TVDR was amended to allow the ownership of two stations in certain markets 
provided only one of the two was a VHF station and the overlapping signals of 
the two owned stations originated from separate albeit contiguous markets.  In 
addition, the acquired station was required to be economically failing or failed 
or unbuilt.   
 
In an effort to afford market access to potential minority and female owners, the 
FCC required the owners of the station to be acquired to provide public notice of 
its availability for acquisition.  The FCC also curtailed the use of LMAs. 
 
A recent decision by the FCC to repeal the FSSR and further relax its TVDR 
waiver policy by increasing the number of television stations a single owner could 
own locally was rejected by the Court of Appeals for the Third Circuit.  The court 
found that the FCC had not given consideration to the impact of its decision on 
minority and female ownership of broadcast stations.  The FCC decision was 
remanded in part so that the FCC could consider the impact of its proposed 
changes.  The FCCs initiation of this study is a direct outgrowth of its response 
to the remand. 
 
The FCC began to collect data on the race and gender of broadcast owners in 
1999.  Prior to that time, the National Telecommunications and Information 
Administration of the U.S. Department of Commerce (NTIA) published periodic 
reports on the number of minority and female owned broadcast stations in the 
United States. 
 
                                        
1
 Professor Hammond acknowledges the invaluable contributions and assistance of 
his student researchers: Adam Marcus, Shane Lunceford and Eli Edwards as well as 
those of Jason Dawson. 
2
 Also called Local Marketing or Joint Marketing Agreements. 
 3
Because relatively reliable data on broadcast owner race and/or gender does not 
exist before 1998, researchers conducting this study are unable to successfully 
examine the impact of the FCCs broader set of ownership rule changes.  
Because the TVDR was the only ownership rule that was revised during the time 
period for which data on broadcast owner race and/or gender has been reliably 
recorded, researchers elected to examine its impact on minority and female 
broadcast television owners. 
 
The researchers found that from 1999 to 2006 the relaxation of the TVDR did not 
appear to have a positive impact on minority and female ownership of television 
stations.  Instead, the major beneficiaries were the largest twenty-five television 
broadcast station owners.  Specifically, the researchers found: 
 
 The relaxation of the TVDR codified the existing contractual 
relationships (local management agreements or LMAs) between group 
station owners and the stations they managed. 
 
 Some group station owners leveraged their control of LMAs into 
control of access to attractive syndicated programming as well as 
access to programming affiliations with emerging networks. 
 
 The majority of the broadcast group owners who benefited from the 
relaxation of the TVDR were the largest (top twenty-five) group 
broadcast owners (based on revenue, national market reach and/or 
number of stations owned).  Appendix ___  As of 2005, they 
accounted for 83 of the 109 (76%) duopolies identified.  Appendix ___ 
 
 Many of the group owners that managed sister stations acquired 
them outright once the TVDR was relaxed. 
 
 Only one minority-owned duopoly was created.  It has since been 
dissolved.   
 
 There were no surviving minority-owned duopolies  
 Across all markets in which minority-owned television stations 
operated between 1999 and 2006, the number of minority-owned 
television stations dropped by twenty-seven percent. 
 
 Within markets entered and or occupied by TV duopolies, the number 
of minority owned stations dropped by more than thirty-nine percent. 
 
 By contrast, in non-duopoly markets the number of minority-owned 
stations dropped by ten percent. 
 
 4
 The duopolies created in markets in which female owned television 
stations operated were non-female owned.   
 
 There were no female-owned television duopolies. 
 
 36% of the female owned stations operating in duopoly markets were 
sold.  All of the stations were sold to non-female, non-minority-owners. 
 
 Female owned stations were more likely to be found in non-duopoly 
markets. 
 
 The change to the TVDR has not had a positive impact on minority or 
female ownership of television stations. 
 
 5
Introduction: 
In November of 2006, the researchers were awarded a contract by the Federal 
Communications Commission (FCC) to conduct a study examining the impact of 
the FCCs ownership policies on minority and women owned broadcast stations.  
At the time of the contract, the only FCC rule in existence that was perceived to 
have an arguable beneficial impact on minority and female owner opportunities 
to enter the broadcast market was the failed station solicitation rule (FSSR).  The 
FSSR was a part of the FCCs TV Duopoly rule. 
 
A. The TV Duopoly Rule (TVDR) 
In 1999, the FCC modified the TVDR to allow signal area overlap if the television 
stations were in two separate Nielsen Designated Market Areas (DMAs) - industry 
accepted geographic areas for calculating station market audience share and 
advertising revenue share.  Under the 1999 change, a local market television 
duopoly would be allowed if: eight full-power independent commercial and non 
commercial television stations remained in the DMA post-merger; and one of the 
duopoly stations was not among the top four-ranked stations in the DMA based 
on audience share. 
 
The TV Duopoly Rule permits a waiver to allowing common ownership of two 
television stations in the same DMA where a same-market licensee is the 
only reasonably available buyer and the station purchased is a failing, failed or 
an unbuilt station.  A station waiver applicant eligible for acquisition as part of a 
TV duopoly has to demonstrate: 1) that the in-market buyer is the only 
reasonably available candidate willing and able to operate the station and 2) that 
selling the station to an out-of-market buyer will result in an artificially depressed 
price. 
 
 
 
 6
B. The Further Proposed Relaxation of the TV Duopoly Rule 
In 2003, the FCC proposed a further relaxation of the rule to allow a single 
company to own as many as three television stations in large broadcast markets 
and two in medium sized markets.  In the largest markets, the rule changes 
would allow a single company to own as many as three television stations, eight 
radio stations, the cable television system, cable television stations, and a daily 
newspaper.  In addition, the FCC proposed to eliminate the FSSR. 
 
 C. The Third Circuit Remand 
In Prometheus Radio Project vs. FCC
3
 the Court of Appeals for the Third Circuit 
reviewed the FCCs proposed relaxation of the TV Duopoly rule including the 
FCCs decision to repeal the FSSR.  The court let stand existing duopoly 
combinations of two stations in a market.  However, the FCCs proposed 
extension of duopolies to many mid-sized markets and extension of three-station 
ownership, or triopolies, in any market were stayed pending further FCC review 
and justification.  In addition, the circuit court directed the FCC undertake an 
examination of the impact of its ownership policies on minority and female 
ownership of broadcast stations. 
 
D. The FCC Contract 
The FCC contract to conduct this research study is a response to the Third 
Circuits remand of the FCCs decision to further relax TV Duopoly ownership 
rules by inter alia repealing the Failed Station Solicitation Rule.  The study, one 
of ten studies commissioned or conducted by the FCC, is to examine levels of 
minority and female ownership of media companies and barriers to entry that 
may be caused by the FCCs policies.   
 
 
                                        
3
 373 F.3d 372 (2004). 
 
 7
Study Methodology and Data Limitations 
A. Methodology 
The change to the TV duopoly rule provides a limited opportunity to determine 
the impact of one of the FCCs policy changes on minority and female ownership 
from 1999 to 2007.  The study seeks to ascertain the impact of the commissions 
rule by determining whether the number of minority and/or women owned 
broadcast stations changed during the period from 1999 to 2006.  The change is 
measured in several ways.   
 
First, the study identifies the transactions resulting in TV duopolies that could not 
have occurred before the rule change.  Of these transactions, how many are 
situations in which a non-minority, non-female owner purchased a non-minority, 
non female owned station?  How many of the transactions were situations in 
which a non-minority, non-female owner purchased a station owned by a 
minority or woman?  How many of the latter transactions, were situations in 
which the minority or female owner who sold their TV station into the resulting 
duopoly later acquired another TV station that was non-minority, non-female 
owned or was minority or female owned?  Finally, how many TV duopolies were 
acquired by minority or female owners of TV stations?  Where such acquisitions 
occurred, how many were duopolies in which the minority or female owner 
acquired a second non-minority, non female owned station and how many were 
situations in which the second station acquired was minority or female owned? 
 
Second, the study seeks to determine the number of commercial broadcast TV 
stations that were purchased (market entry) or sold (market exit) by minority or 
women owners in markets in which a TV duopoly was introduced that could not 
have existed before the passage of the FCCs rule.  Market entry is defined as the 
acquisition of a commercial broadcast station through the purchase of a 
broadcast property (license transfers) or the acquisition of a permit and the 
subsequent implementation of an operating ongoing station enterprise.  Market 
 8
exit is defined as the sale or transfer of a broadcast property by a minority or 
female owner to a non-minority, non-female owner or the cessation of station 
operations. 
 
TV Duopoly Inquiry Matrix 
Study Tier Data Required Relevance Result 
TV Duopoly 
Tier #1 
NMOS/
4
NFOS
5
 buys 
2
nd
 NMOS/NFOS in same 
market 
No increase or decrease in MO
6
 or FO
7
 
diversity unless decrease in competitive 
status of MO or FO station 
 
 NMOS/NFOS buys 2
nd
 MOS
8
 
or FOS
9
 in same market 
Potential reduction in MO or FO diversity  
 MOS or FOS buys 2
nd
 
NMOS/NFOS in same 
market 
Increase in potential competitiveness of 
MOS or FOS  
 
 MOS or FOS buys 2
nd
 MOS 
or FOS in same market 
No increase or decrease in MO of FO 
diversity unless increase in competitive 
status 
 
TV Duopoly 
Tier #2 
MO or FO entering market 
containing post rule TV 
duopoly  
Increase in MOS or FOS diversity  
 MO or FO leaving market 
containing post rule TV 
duopoly 
Decrease in MOS or FOS diversity   
TV Duopoly 
Tier #3 
MO or FO staying in market 
containing post rule TV 
duopoly  
Impact?  
 
 
                                        
4
 NMOS = Non Minority Owned Station 
 
5
 NFOS = Non Female Owned Station 
 
6
 MO = Minority Owner 
7
 FO = Female Owned 
8
 MOS = Minority Owner Station 
9
 FOS = Female Owned Station 
 9
B. Databases Used in the Study 
 
  1. CDBS Database (FCC) 
The primary database used in the study is the CDBS Database, available for 
download at http://www.fcc.gov/mb/databases/cdbs/.  It is probably the most 
useful database that exists for determining minority and female ownership 
status, but it is incomplete.  An interactive version of the database is available at 
http://svartifoss2.fcc.gov/prod/cdbs/pubacc/prod/cdbs_pa.htm, and this version 
seems to have more information that is not available in the downloadable 
version.   
 
A shortcoming of the data is that verifying minority and female ownership status 
is sometimes difficult.  For example, many stations that may be owned by 
minorities and females may not show up by merely searching the form 323 data 
in the database.  Cross-referencing the ownership information with other forms 
is also problematic.  Many of the stations are owned by corporations and holding 
companies that are wholly owned subsidiaries of corporations.  Some of these 
may still be listed as minority owned, but verification of ownership is extremely 
difficult.  Where the researchers have not been able to establish minority or 
female owner control of a broadcast entity via majority voting or equity control, 
the company in question, regardless of programming orientation, is not included 
as a minority owned broadcaster.  
 
In addition, stations listed as minority-owned but sold before the 1998 NTIA 
report have been deleted from the database for purposes of examining the 
impact of the change to the TVDR.  In a subsequent study, it would be useful 
reconstruct the 1968 to 1998 ownership data and examine the impact of various 
commission rules and policies including the tacit FCC support for LMAs. 
 
 
 10
  2. NABOB Membership Lists 
We compiled a list of black-owned television broadcast stations based on lists for 
the years 1991, 1996, 2001, and 2006 provided by the National Association of 
Black Owned Broadcasters (NABOB).  The list was compiled to supplement 
ownership data supplied by FCC databases and the Free Press study.  We did 
this in an effort to determine which stations appeared on the list one year and 
not the next (and vice versa).   
 
  3. BIA Database (Media Access Pro) 
Media Access Pro is considered the most comprehensive database for the 
broadcast industry.  Unfortunately, this database has no flags indicating minority 
or female ownership status.  The completeness of the data seems to be due in 
large part to the fact that a team of people are constantly calling stations and 
requesting updated information.  The database supplies market and advertising 
information such as how much money is spent on advertising in the market each 
year, what percentage of that money the station in question gets, who the 
competitors to the station are, and other useful information. 
 
The apparent downside of this database is that it seems to consider only stations 
currently in operation.  This is problematic because several stations we are 
interested in have changed call signs, and thus the "old" station is not in the 
database.  Searching by call sign may also be problematic when running large 
queries, since it appears that multiple stations (possibly only on different bands) 
across the country may have the same call letters.    
 
  4. The Free Press Study 
In addition to other sources, the Study relies on the data provided in Turner and 
Cooper, Out of the Picture: Minority and Female TV Station Ownership in the 
United States (2006). 
 
 11
C. Limitations of the Study 
1. Determination of Minority and Female Ownership 
Ultimately, determining what constituted a minority or female owned and/or 
controlled station was not a simple task.  Where the owner in question is an 
individual who self reported their status, ascertaining minority or female status 
was relatively easy.  Where the owner is a business organization, minority or 
female ownership status proved more difficult to ascertain.  The flexibility 
afforded corporate organizations in structuring equity and/or voting participation 
presented challenges.  For this reason, publicly traded companies, even when 
headed by a minority or woman, were not considered minority or female owned 
for purposes of this report.  Ultimately the researchers relied on the FCCs 
definitions of minority and the licensees self reporting of status which the FCC 
has historically allowed (subject to the caveat regarding publicly traded business 
organizations).   
 
Aside from the issue of whether or not the entity is currently minority or female 
owned, there is the issue of when it became and/or ceased to be minority or 
female owned.  Confirmation of the bonafides and duration of minority or female 
ownership status was sought using ownership lists published by the FCC, the 
NTIA, the Free Press and industry supplied ownership lists (when available) as 
well as resort to reports supplied through searches on Google, Wikipedia and 
Lexis. 
 
For purposes of this report, the universe is comprised of owned full power 
commercial television broadcast stations situated in the Continental United States 
(Conus), Alaska and Hawaii.  Low power television stations licensed in the fifty 
states
10
 as well as full and/or low power stations licensed in U.S territories such 
                                        
10
 The second class status of low power stations in terms of signal reach, priority for 
spectrum usage, access to programming and eligibility for cable must carriage 
support this decision. 
 12
as Puerto Rico are not considered.  It is recognized that this choice will have an 
impact on the number of minority owned stations reported and considered. 
 
2. Limitations of Available Data 
It was initially hoped that the study could begin to document the impact that the 
Commissions ownership, spectrum allocation, minority and female ownership 
policies have had on the number of minority and female owned broadcast 
stations in the market.  To properly document the impact of the FCCs multiple, 
minority and female ownership as well as spectrum allocation policies on minority 
and female ownership of broadcast stations one would have to engage in a 
longitudinal study.  Such a study would track the policy changes and their impact 
across the time period beginning with the identification of the lack of diversity of 
viewpoint that lead to the creation of the minority ownership and women 
ownership policies from 1968 and 1978 respectively until today.   
 
Unfortunately, minority and female ownership data are not available for the 
roughly 37 years from 1970 to 2007.  The larger database would have permitted 
a full longitudinal study of the impact of the various changes arguably wrought 
by each of the FCCs ownership rule and policy changes (as well as those of 
Congress) on minority and/or female ownership from 1970 to 2007.   
 
In addition, it might have been possible to begin to isolate the impact of new 
technologies on the audiences and revenues of minority and female owned 
broadcasters and their non-minority non-female owned counterparts over time. 
However, because the FCC did not begin requesting data on minority and female 
owner status until 1998, it could only provide a database covering the years 
1999 to 2006.   
 
Consequently, the study findings are constrained by the data limitation.  During 
the time period in question, the FCC, in response to substantial political pressure, 
 13
revised its TV duopoly rule ostensibly finding that the change was justified 
because of increased competition in the local market from alternative media.  In 
addition it established the FSSR.  As mentioned above, further revisions to the 
TVDR and the decision to jettison the FSSR are currently under further FCC 
review subsequent to court action. 
 
I. The TVDR in Context 
Among the policies that have affected the market entry and competitiveness of 
minority and women owned broadcasters are the minority and female ownership 
policies, the national ownership policies and the local ownership policies.  This 
study seeks to ascertain the impact of the TVDR and FSSR by examining them 
within the context of these other policies. 
 
A. Local Management Agreements (LMAs) and the TVDR 
The FCCs relaxation of the TVDR in 1999 was precipitated in part by the 
proliferation of local management agreements (LMAs).  LMAs are contractual 
arrangements made between television broadcasters in the same market to 
combine their operations.  LMAs are used to reduce the broadcasters costs by 
sharing staff and or programming; expand their market reach by combining 
signal coverage; increase their advertising revenue shares by controlling access 
to a larger percentage of a desirable market segment and/or providing more 
opportunities to air programming.  While the FCC prohibited broadcasters from 
outright ownership of a second television station in many local markets, LMAs 
allowed broadcasters to acquire control of a second station without actually 
owning the station. 
 
1. The Origin of LMAs 
LMAs were created in part as a response to the need for viable independent 
stations as programming outlets for then emerging networks such as the WB.  In 
some markets, the WB had lost out to other networks in securing viable station 
 14
affiliates.  As a result they were left with marginal
11
 or underachieving stations as 
potential affiliates.
12
  Using an LMA, a strong affiliate in a market could to take 
over the programming, sales and promotion of an underachieving independent 
station without changing its ownership.
13
  
 
In order to increase the likelihood of success of marginal stations with which it 
would have to affiliate, the WB approached group owners that successfully 
managed UHF independent stations and encouraged them to enter into LMAs 
with strategically located UHF non-network affiliated TV stations.
14
  The 
managing group owned stations could then steer more attractive non-prime time 
programming to the underachieving sister stations.  This would in turn enhance 
the likelihood that the network affiliated prime time programming would attract 
enough viewers to be successful.  In addition, LMAs were seen as a means for 
broadcasters to increase the number of channels of programming they could 
control in competition with the multi-channel cable and satellite providers. 
 
Despite their alleged potential value, the broadcast industry was not united in 
support for the creation of LMAs.
15
  Some prominent broadcasters viewed LMAs 
as anticompetitive and dangerous to diversity.
16
  Within two years however, 
                                        
11
 UHF stations with low or negligible ratings that scheduled mixtures of home 
shopping, religious and/or informercial programming.  John Dempsey, WB Credo: 
If You Can't Sign 'Em, Create 'Em, Variety, April 11, 1994 - April 17, 1994, Pg. 45. 
 
12
 Id 
13
 Id 
14
 Id 
15
 Christopher Stern, LMA's Waiting In The Lobby, Variety, January 27, 1997 - 
February 2, 1997, Pg. 29. 
 
16
 Phil Jones, then president of the Meredith Broadcasting Corp. publicly expressed 
opposition to LMAs stating: "I think it's a dangerous thing for the industryIt does 
limit the number of voices in the marketplace and it smacks of unfair competition."  
Christopher Stern, LMA's Waiting In The Lobby, Variety, January 27, 1997 - February 
2, 1997, Pg. 29. 
  
 
 15
broadcast groups began to see the value of LMAs in reducing the market power 
of program syndication companies, increasing the owners access to valuable 
popular programming
17
 and limiting market competitors access to this same 
programming.
18
  The reported originator and master of this strategy was Sinclair 
Broadcasting.
19
 
 
Another profitable strategy emerged as well.  The formerly underachieving, now 
better managed and better programmed UHF independent stations would garner 
more money as acquisition targets when the FCC relaxed its TV Duopoly rule.
20
 
                                        
17
 LMAs allow a broadcaster to control the programming of a second station in a 
market where it already owns a station.  Broadcasters use the arrangement to get 
around the current ban on owning more than one station in a single market.  By 
managing the programming on two stations, in a single market, the broadcaster has 
much more leverage with programmers.  Christopher Stern, LMA's Waiting In The 
Lobby, Variety, January 27, 1997 - February 2, 1997, Pg. 29.  Also see Jim Benson, 
Justice Dept. Seeks Info from L.A. Stations, Daily Variety, November 13, 1995, Pg. 
1. 
In response to Sinclairs $1.2 billion dollar acquisition of a broadcast station 
group, program syndicators expressed concern because between its owned stations 
and its LMAs Sinclair had garnered incredible leverage when it comes to buying 
programs. 
And that extends beyond the LMA markets. Many syndicators privately complain[ed] 
of having to sell a show to Sinclair in one market if they want clearances in other 
markets where the broadcaster has two outlets.  Joe Flint, Sinclairs Power Play, 
Daily Variety, April 12, 1996, Pg. 1. 
 
18
 Through LMAs, group owners such as Sinclair Broadcast Group and Clear 
Channel Television have been able to control two outlets in one market. That 
means that when it comes to negotiating with studios for programming, they can 
often dictate the terms of deals because they control the likely buyers. Sinclair, for 
example, controls two stations in several major markets including Baltimore, 
Pittsburgh, Milwaukee and Indianapolis.  Christopher Stern, FCC Duopoly Delight, 
Variety, November 11, 1996 - November 17, 1996, Pg. 76. 
 
 
19
 Joe Flint, Sinclairs Power Play, Daily Variety, April 12, 1996, Pg. 1; Joe Flint, 
Sinclair Puts on the Squeeze, Variety, January 8, 1996 - January 14, 1996, Pg. 88. 
 
20
 Michael Freeman, Waiting For A UHF Windfall - Paxson Yanks Two U's 
Off Block; Seen Anticipating OK On Duopolies, Mediaweek, November 25, 
1996; Christopher Stern, LMA's Waiting In The Lobby, Variety, January 
27, 1997 - February 2, 1997, Pg. 29. 
 
 16
By 1996, a scant two years after LMAs became a preferred broadcaster 
expansion strategy, the FCC acknowledged the potential adverse impact of 
duopolies and by implication LMAs on minority and female ownership of 
broadcast stations.
21
  And, when Congress did not include the grandfathering of 
LMAs into the Telecommunications Act of 1996, despite the existence of a 
provision in the house version of the bill
22
, the stage was set for a showdown 
between the industry and its Congressional supporters on the one hand, and the 
FCC, women and minority broadcasters and public interest advocates on the 
other. 
 
2. LMAs and Diversity of Ownership 
In November of 1996, the FCC issued a notice of proposed rulemaking soliciting 
comments on local management agreements.  Some broadcasters became 
concerned that the FCC might forbid or limit the duration of existing LMAs.
23
  
According to one Wall Street analyst, the FCCs response to broadcaster efforts 
to codify and expand the use of same market LMAs was based on alarm 
expressed by some in Congress, at the FCC and among some broadcasters that 
relaxation of ownership rules in radio required by the Telecommunications Act of 
                                        
21
 [Commissioner]Ness said Excessive consolidation . . . can drive out competition, 
reducing the diversity of voices...At what point does the loss from a reduction of 
voices and competition outweigh any benefits to the public? . . . I believe on balance 
local duopolies and some superduopolies have been good for radio . . . But, it would 
be unfortunate if everyone had to combine into multistation groups to have a chance 
of competing successfully." She went on query: at what point is a station kept from 
competing effectively; when does advertiser have trouble finding options; and at 
what point does "someone looking for a fresh, independent voice have a hard time 
finding one?"  FCC Officials Say They, Not DOJ, Will Oversee Concentration, 
Television Digest, October 14, 1996, Vol. 36, No. 42; Pg. 1. 
 
22
 Martin Peers and Joe Flint, Big Deals Brew with Bill OK, Daily Variety, February 2, 
1996, Pg. 1. 
 
23
 Alicia Mundy, Regulation: Hundt Outlines FCC Agenda, Mediaweek, November 11, 
1996. 
 
 17
1996 (TA96) had resulted in a wave of unprecedented market consolidation.
24
  
There was significant concern that relaxation of ownership limits in television 
would have the same effect.
25
  However, others in Congress argued that the FCC 
proposal to limit LMAs was contrary to Congress intent that LMAs be allowed 
and protected under TA96.
26
 
 
In 1997, a new commission panel and commission chairman later, the FCC still 
expressed concern about the rapid pace of consolidation in the broadcast 
marketplace and its impact on minority ownership of broadcast stations.
27
  At 
the time, minority owners accounted for less than 3% of all broadcast stations 
nationally.
28
  Industry consolidation was argued to be exacerbating the limited 
representation of minority owners.  The FCCs failure to prohibit LMAs by 
enforcing the TV Duopoly rule was identified as one of the chief mechanisms 
facilitating consolidation.
29
  By one estimate, seventy LMAs existed at the time.  
Despite Congressional pressure to grandfather all LMAs and allow ownership of 
one VHF and one UHF station in a market, the FCC did not modify its TV Duopoly 
                                        
24
 Television Digest, Act Affects Broadcasters Most, February 10, 1997 
 
25
 Merrill Lynch analyst Jessica Reif said industry certainly had expected wave 
of broadcast mergers, but they appeared to have been surprise to Congress.  As 
result of radio mergers, FCC appears to be moving slower on TV ownership 
rulesReaction among broadcasters has been mixed.  Groups that wanted to get 
bigger have done so.  Others, including some large TV 
groups -- such as Post-Newsweek Stations (PNS) -- and small operations say it has 
hurt diversity.  For instance, NAB TV board split 13-9 on whether to support FCC 
rulemaking to permit TV 
duopolies in same market and continue practice of approving local market 
agreements (LMAs).  Id 
26
 House Subcommittee Approves Budget Package, Communications Daily, June 11, 
1997 
 
27
 Christopher Stern, FCCs Kennard Airs On Side Of Diversity, Variety, November 10, 
1997 - November 16, 1997, Pg. 22. 
 
28
 Id 
29
 Civil rights advocate Jesse Jackson argued that the consolidation (driven in 
part by LMAs) in the radio and television industry was pushing minorities out of the 
business  Id 
 
 18
rule or retreat from its expressed concerns about the impact of LMAs on diversity 
and minority ownership.
30
 
 
In 1998, the FCC considered proposals that existing same-market LMAs entered 
into after November 7, 1998 might be terminated after one year, while others 
would be terminated in three years or at the end of their current contract terms, 
whichever is sooner.
31
  Broadcasters operating under LMAs, concerned about 
possible station divestitures and financial losses, responded swiftly demanding 
that the FCC grandfather all LMAs and provide duopoly relief.
32
  They argued 
that LMAs serve the public interest by facilitating enhanced TV service, 
construction of dormant stations, realization of economies of scale and 
introduction of local news and other programming improvements.
33
  These 
broadcasters argued that they used the LMA structure to build UHF stations that 
aired startup WB or UPN network programming, adding to viewer entertainment 
programming choices.
34
  They also alleged that the FCC had no evidence of harm 
from the industry practice of engaging in LMAs.
35
 
 
The FCCs supporters argued that LMAs undermined the FCCs diversity policies 
through the loss of potential or actual competitive voices in local communities.  
Further, LMAs were an unauthorized circumvention of the FCCs duopoly 
prohibition (creating de facto duopolies) and that grandfathering would 
                                        
30
 Id 
31
 Doug Halonen, Broadcasters Vow To Fight LMA Restraints, Electronic Media, 
November 23, 1998, Pg. 1. 
 
32
 Id 
33
 Id 
34
 Broadcast Changes On Tap, Frohlinger's Marketing Report, November 30, 1998, 
Pg. NA Vol. 11 No. 23 
 
35
 Broadcast Lobby Heats Up At FCC Against Tightened Ownership Rules, 
Communications Daily, December 3, 1998. 
 
 19
improperly reward those broadcasters who had violated the intent of the 
prohibition.
36
   
 
The FCC set December 17, 1998 as the date for a vote on LMAs.
37
  Among the 
proposals reported to be considered would have been attributing an ownership 
interest on the part of the broadcaster controlling the LMA.
38
  The FCC was also 
reported to be considering a relaxation of the duopoly rule, to allow the overlap 
of "B" contour signals (an approximate 70-mile radius from the transmitter), but 
not "A" contour signals (35-mile radius).
39
   
 
Congressional reaction was swift and mostly negative.  Rep. Billy Tauzin, (R-La.) 
(House Commerce Committee), Sen. John McCain, (R-Ariz.) (Senate Commerce 
Committee), and Sen. Conrad Burns, (R-Mont.), expressed strong disagreement 
with the FCCs proposals, urged the FCC to delay (or eschew) a decision on LMAs 
and threatened to hold hearings on the FCCs jurisdiction over LMAs and other 
ownership rules.
40
  The war of assertions between FCC and the broadcasters 
advocating for LMAs and their senators continued in the press for months.  It 
would grow to include pressure on the FCC from Rep. Dingell (D-Mich.), the 
                                        
36
 Doug Halonen, Broadcasters Vow To Fight LMA Restraints, Electronic Media, 
November 23, 1998, Pg. 1. 
37
 Id.  See also, Broadcast Changes On Tap, Frohlinger's Marketing Report, 
November 30, 1998, Pg. NA Vol. 11 No. 23. 
 
38
 Broadcast Changes On Tap, Frohlinger's Marketing Report, November 30, 1998, 
Pg. NA Vol. 11 No. 23. 
 
39
 Id 
40
 Brooks Boliek, McCain, Tauzin, Burns Urge FCC to Save LMAs, The 
Hollywood Reporter, December 3, 1998; Broadcast Lobby Heats Up At 
FCC Against Tightened Ownership Rules, Communications Daily, 
December 3, 1998; Christopher Stern, FCC vs. Congress: Senator Says 
Panel Shouldn't Oppose LMAs, Daily Variety, December 2, 1998, Pg. 22;  
Communications Daily, December 2, 1998, Sec. Mass Media; Broadcast 
Changes On Tap, Frohlinger's Marketing Report, November 30, 1998, Pg. 
NA Vol. 11 No. 23; Alicia Mundy, Regulation /FCC LMA Plan Irks McCain, 
Mediaweek, November 30, 1998. 
 
 
 20
senior Commerce Committee Democrat.
41
  By this time the number of LMAs had 
reportedly grown to seventy-eight.
42
 
 
In response to substantial pressure from Congress and broadcasters as well as 
internal FCC dissension, and despite support from Sen. Ernest Hollings, (D-S.C.), 
ranking minority member on the Senate Commerce Committee, the FCC 
chairman withdrew the LMA item from the December 17, 1998 agenda.
43
  
Nevertheless, congressional pressure on the FCC continued focusing on the 
national ownership limit as well as the FCC policy regarding TV duopolies and 
LMAs.
44
   
 
For many, the battle over LMAs was seen as a war of competing priorities.  
Efforts to maintain the diversity of voices in local broadcast markets, protecting 
small broadcasters and enhancing minority and female ownership were perceived 
to conflict with policies supporting the continued economic success of large 
                                        
41
 Broadcast Lobby Heats Up At FCC Against Tightened Ownership Rules, 
Communications Daily, December 3, 1998. 
 
42
 Brooks Boliek, McCain, Tauzin, Burns Urge FCC to Save LMAs, The 
Hollywood Reporter, December 3, 1998. 
 
 
43
 Brooks Boliek, FCC Punts On Ownership Rules Under Pressure From 
Biz, Lawmakers, Kennard Delays Vote, The Hollywood Reporter, 
December 7, 1998; Kennard Delays Action On Ownership Rules, 
Television Digest, December 7, 1998; David Hatch and Doug Halonen, 
FCC Drops Ownership Rule Changes: Planned LMA Crackdown, Electronic 
Media, December 07, 1998, Pg. 1; Christopher Stern, FCC Chief Kennard 
Delays Vote On Eliminating LMAs, Daily Variety, December 7, 1998, Pg. 
8; Communications Daily, December 7, 1998; Alicia Mundy, Washington 
/ Showdown Over LMAs, Mediaweek, December 07, 1998;  
 
44
 McCain Opposes Ownership Cap, Television Digest, December 14, 
1998; Christopher Stern, Capping FCC Power: McCain Bill Would Limit 
B'cast Ownership Regs, Daily Variety, December 9, 1998, Pg. 47; McCain 
Opposes TV Ownership Cap, Communications Daily, December 8, 1998. 
 21
group owners and networks on the other.
45
  By this time, it was estimated that 
there were more than eighty LMAs operating across the nation.
46
   
 
During the entire time that the FCC had fought to limit local market consolidation 
and preserve diversity and minority and female ownership opportunities in the 
face of industry and congressional opposition, the number of LMAs had been 
growing. 
 
3. TVDR Relaxation 
Less than a year later, in a policy turnaround, the FCC relaxed its TV duopoly 
rule by creating the waiver policy which gave large broadcasters and networks 
much of what they had sought.
47
  Group and network owners could formally 
acquire the second stations many already operated as if they owned them.  If 
they had unofficially acquired them, they were now officially allowed to keep 
them.  A flurry of broadcast acquisitions by large group and network station 
owners was anticipated.
48
 
 
                                        
45
 Kennard doesn't like LMAs because he believes they enable consolidation. 
And consolidation, according to Kennard, is not friendly to minorities.  "I have talked 
to many people who have aspirations to become owners of radio and television 
stations," said Kennard last week, adding, "It's harder today because of 
consolidation, particularly in the major markets."  By tightening ownership rules --- 
or at least making the agency's 34-year-old ban on local duopoly effective --- 
Kennard hopes to create more opportunity for minorities. Minorities now make up 
less than 3% of all radio and television owners, but major networks and large station 
groups insist that they are the ones who are endangered.  Christopher Stern, 
Consolidation Issue Crystallizes FCC, Variety, December 14, 1998 - December 20, 
1998, Pg. 37. 
 
46
 Id 
47
 David B. Wilkerson, FCC Seen Loosening Local TV Ownership Rules, 
CBS MarketWatch, August 4, 1999. 
 
48
 Jennifer Files and Catalina Camia, FCC's Rule Change May Set Off Flurry of TV-
Station Deals, The Dallas Morning News, August 7, 1999. 
 
 22
When the FCC announced its change in policy, many television group owners 
applied for permission to acquire stations they already operated under existing 
LMAs.     Among the groups were Belo, Capitol, Clear Channel, CBS-Viacom, 
Gannett, Granite, Hubbard, Sinclair, and Tribune.
49
  These requests appeared to 
be the logical consequence of the contractual provisions of many LMAs that 
reportedly included options to buy the managed stations at prices based on 
multiples of the stations revenues or cash flow.
50
  As the rule change caused the 
value of some stations to be bid up, these options gave holders of LMAs an 
advantage over other bidders.  The LMA holders had first shot at their partner 
(sister station) at a bargain price.
51
   
 
In an effort to foreclose the future use of the LMA vehicle, the FCC limited its use 
to a 2-5 year window of opportunity after the rule change.
52
  In addition, the 
FCC tied the number of duopolies in a market to the number of stations in a 
market.  Thus in smaller markets with a limited number of stations, many 
broadcasters were likely to have to abandon a contractual relationship with 
another station in the same market when the window of opportunity closed.
53
  
Finally, the FCC instituted new attribution rules.
54
 
                                        
49
 Station Groups Move On Duopoly Rules, Television Digest, November 22, 1999. 
50
 Jon Lafayette, Next: $2b Buying Spree?  Electronic Media, August 09, 1999, Pg. 1. 
51
 Id 
52
 Under the rules LMAs were banned, but broadcasters were given time to either 
buy the LMA stations or exit the contract. Broadcasters entering into LMAs before 
Nov. 5, 1996, were afforded a five years window to curtail the relationship or acquire 
the managed station outright. Broadcasters entering into LMAs in or after November 
1996 had a two year window to curtail the contractual relationship. Christopher 
Stern, Stations Dance To Duopoly, Variety, August 9, 1999 - August 15, 1999, Pg. 
19, 
53
 Christopher Stern, TVs Double Vision: FCC Votes Changes to 
Ownership Rules, Daily Variety, August 06, 1999, Pg. 1. 
54
 Rule change also makes it more difficult to use debt to control broadcast outlets.  
In addition to old 5% voting stock test for whether broadcast station is considered 
attributable (legally owned by entity holding stock), FCC set new "equity/debt plus" 
test.  Under test, station is attributable if entity's equity plus debt holding equals 
33% of station's assets, plus if entity either provides more than 15% of station's 
programming or owns another outlet in same market.  FCC did ease attribution 
 23
4. The Failed Station Solicitation Rule (FSSR) 
At the same time, the FCC adopted the FSSR to provide potential minority and 
women owners notice of the availability of a failing, dark or unbuilt station in a 
broadcast market.  The positive impact was expected to be the receipt of 
published notice of stations available for purchase.  It remained to be seen what 
impact that notice, if received, would have on the acquisition of stations.  In 
addition, it remained to be seen just how many viable opportunities for market 
entry remained after the earlier market entry of LMAs. 
 
Under the 1999 TVDR waiver policy, in order to meet part of its burden of proof, 
a waiver applicant had to comply with the Failed Station Solicitation rule (FSSR).  
The FSSR required a waiver applicant (the station to be purchased/acquired) to 
provide public notice of the sale to potential out-of-market buyers before it could 
sell the failed, failing, or unbuilt television station to an in-market buyer.   
 
The FSSR notice requirement gave minorities and women interested in 
purchasing a station an opportunity to bid when they might not otherwise have 
had timely notice.  At the time of its implementation, the FSSR was the only 
remaining FCC rule perceived to facilitate minority and female ownership of 
broadcast stations.   
 
B. The Minority and Female Ownership Policies 
Between 1978 and 1994, the FCC implemented and operated its minority 
ownership and female broadcast ownership policies.  The policies were initiated 
and maintained as a response to a documented lack of diversity in the 
presentation of viewpoints in the broadcast medium.  These policies were 
                                                                                                                    
benchmark for passive investors (bank trust department, mutual fund, insurance 
company) to 20% from 10%.  FCC Eases Duopoly Broadcast Ownership, Tightens 
Other Rules, Communications Daily, August 6, 1999. 
 24
promulgated at a time when there were significant limits on national and local 
ownership of radio and television stations. 
 
1. The Minority Ownership Policies 
The minority ownership policy consisted of three major components: a tax 
certificate policy; a distress sales policy; and a comparative plus awarded for 
minority ownership in the FCCs then competitive broadcast spectrum allocation 
procedure.   
 
The Tax Certificate Policy allowed existing broadcasters who sold to minority 
entrepreneurs to defer taxation of the capital gains from the sale by reinvesting 
in a communications related enterprise within a specified time after the sale.  
The capital gains would not be taxed until the seller sold the subsequently 
acquired communications interest.  The Distress Sales Policy allowed 
incumbent broadcast owners designated for an FCC hearing on potentially 
disqualifying issues (faced with the potential loss of their broadcast license) to 
sell to a minority entrepreneur at 75% of the fair market value.  Prior to the 
Telecommunications Act of 1996 (TA96), the FCC was required by statute to 
allocate broadcast spectrum licenses through a comparative allocation process.  
Among the criteria the FCC developed for comparing competing applicants was 
the participation of minorities and /or women in a broadcast applicants 
ownership structure.  Broadcast license applicants having significant minority or 
women participation in ownership received a Comparative Plus in the 
comparative allocation process. 
 
In 1992, Congress repealed 1071 Internal Revenue Code Tax Certificate Policy 
Exemption for minority ownership of broadcast stations as a budget restructuring 
measure.  Subsequently, the remaining two minority ownership policies were 
essentially neutralized after the Supreme Court overturned its prior holding in 
Metro Broadcasting that the FCCs minority ownership policies were 
 25
constitutional. The decision in Adarand Constructors required the application of 
strict rather than intermediate scrutiny to race based federal government 
programs.  The court concluded that the application of the more stringent level 
of scrutiny required adherence to new standards of proof.  While the FCC 
considered how to proceed in light of the Courts decision, the comparative plus 
and the distress sales policies were tabled. 
 
2. The Female Ownership Policy 
In 1978, the FCC extended the comparative plus policy to women.  The FCC 
concluded that merit for female ownership and participation is warranted upon 
essentially the same basis as the merit given for black ownership and 
participation, but that it is a merit of lesser significance.
55
  The FCC did not 
determine that there was a nexus between female ownership program diversity 
prior to award of the comparative plus.
56
  The failure to establish the existence 
of a nexus proved the undoing of the female ownership policy.
57
  The female 
ownership policy was overturned by the D.C. Circuit in 1992.  The court 
concluded the FCC had failed to establish the factual nexus between female 
ownership and program diversity.  In responding to the negative decision, a 
spokeswoman for American Women in Radio and Television (AWRT) stated: The 
lack of definitive studies on female ownership of broadcast facilities has been a 
source of concern to AWRT for many years and AWRT has urged the FCC to 
undertake such studies. 
 
 
 
                                        
55
 Reexamination of the Commissions Comparative Licensing, Distress Sales and Tax 
Certificate Policies Premised on Racial, Ethnic or Gender Classifications, 1 F.C.C. Rcd. 
at 1315 (1986), citing Mid-Florida Television Corp., 69 F.C.C.2d 607, 652 (Rev. Bd. 
1978). 
 
56
 Id. at 1315-6. 
57
 Lamprecht v. F.C.C., 958 F.2d 382, 384 (1992). 
 26
3. Quantfying Minority and Female Ownership 
The Telecommunications Act of 1996 encouraged the FCC to promote more 
minority and female ownership in broadcasting.  In response, in 1998, the 
Commission, operating under the constraints of the Adarand Constructors ruling, 
amended its Annual Ownership Report form, FCC Form 323, to include a section 
requiring owners to identify their race or ethnicity and their gender.
58
  The 
Commission stated that the collection of data on the race and gender of owners, 
would allow it to: 
 
determine accurately the current state [of] minority and female 
ownership of broadcast facilities, to determine the need for 
measures designed to promote ownership by minorities and 
women, to chart the success of any such measures that we may 
adopt, and to fulfill our statutory mandate under Section 257 of the 
1996 Act and Section 309(j) of the Communications Act of 1934 to 
promote opportunities for small businesses and businesses owned 
by women and minorities in the broadcasting industry.
59
 
 
Recently, however, the FCCs execution of its collection and dissemination policy 
has met with significant criticism that the data is neither accurate nor 
comprehensive.  It has been suggested that the limited reliability of the data 
reflects a lack of concern and commitment regarding minority and female 
broadcast ownership on the part of the agency. 
 
4. The Impact of Other FCC Ownership Policies 
The now dormant minority and female ownership policies did not exist in a policy 
vacuum, however.  During the years that the policies were in existence, the FCC 
                                        
58
 In the Matter of 1998 Biennial Regulatory Review -- Streamlining of Mass Media 
Applications, Rules, and Processes; Policies and Rules Regarding Minority and Female 
Ownership of Mass Media Facilities, 13 F.C.C Rcd. 23056, 23095 (1998). 
59
 Id. 
 27
also adopted modifications to its television, radio and media cross ownership 
rules as well as its spectrum allocation policies.  For purposes of this study, the 
interaction of the national multiple ownership limits and the TVDR are of 
particular importance. 
 
The national multiple ownership rules limit the total number of television and 
radio stations an entity may own nationally, irrespective of location.  Initially, the 
national rule prohibited one entity from owning more than three television 
stations.  From 1953 to 1985 the national limit was raised to seven television 
stations.  After a rule change in 1984, the national limit was raised to twelve 
broadcast stations with no more than five of the stations being in the VHF band.  
Congress repealed the 12 station limit in the Telecommunications Act of 1996 
replacing it with a prohibition on owning stations allowing the owner to reach 
more than 35 percent of the nationwide television audience.  Presently, the 
national ownership limit has effectively stopped the largest broadcast station 
owners from acquiring television duopolies in markets where they do not already 
own a station.
60
 
 
According to industry sources, relaxation of the ownership limits tended to drive 
up the valuation and hence the purchase price of many broadcast stations as 
network and group owners bid up the prices of desirable stations.  This market 
response was said to have priced many potential purchasers (small businesses 
and broadcasters including minorities and women entrepreneurs and owners) out 
of the market.  However, the rise in prices may have benefited owners of 
existing stations by allowing them to sell out at higher prices.  It would have 
thereby benefited a class of minority owners, but it would not necessarily have 
benefited the goal of preserving or increasing minority ownership.  In addition, 
                                        
60
 Diane Mermigas, TV Station Economics Setback; Delayed Dereg Hurts 
Valuations, Mermigas on Media, September 10, 2003, Pg. 1. 
 
 28
station consolidation at the local and national level was said to have adversely 
affected smaller broadcasters.  Unlike their network or group owned 
counterparts, these stations did not enjoy the reduced costs, enhanced market 
reach and increased advertising revenues afforded by the economies of scale the 
policy changes facilitated. 
 
Conversely, increases in station licenses available in many local markets brought 
about by the FCCs liberalized spectrum allocation policies could be hypothesized 
to drive down or hold station prices constant.  In the past, it has been argued 
that an increase in the available stations within a broadcast market could dilute 
audiences and available local market advertising revenues and hence station 
profitability.
61
 
 
C. The TVDR Waivers Impact 
1. Benefits and Beneficiaries 
As of 2003, there were an estimated 119 TV station duopolies in the top 100 
markets, according to a report by JP Morgan.
62
  The researchers of this study 
were only able to confirm 109 duopolies as of 2006.
63
  Of that number, one, the 
proposed duopoly composed of KTBS-TV and KPXJ-TV in Shreveport, La., was 
reported to be pending (in 2003) due to the Prometheus decision.
64
   
                                        
61
 The broadcasting industry hates the idea of LPFM. The industry's man on the 
Hill is Rep. Billy Tauzin (R-La.), chairman of the House communications 
subcommittee. The National Association of Broadcasters has vociferously opposed 
the proposed rules from the beginning. Tauzin told a group of NAB executives in 
February that LPFM would cripple existing radio stations by stealing their audience 
and taking away advertising dollars and possibly causing interference.  Lydia 
Polygreen, The Death of "Local Radio, Washington Monthly, April 1, 1999, No. 4, Vol. 
31; Pg. 9 
 
62
 Diane Mermigas, TV Station Economics Setback; Delayed Dereg Hurts 
Valuations, Mermigas on Media, September 10, 2003, Pg. 1. 
 
63
 See Appendix ___. 
64
 Todd Shields, Dark Days for FCC Regs, Mediaweek, September 8, 2003. 
 
 29
The proliferation of duopolies can be explained by the benefits they afforded 
their owners.  Like the LMAs that preceded them, duopolies allow a broadcaster 
to increase advertising inventory and programming opportunities, expand market 
reach, and realize greater opportunities for cost cutting.  The reported 
experience of Fox Broadcasting in its use of TV duopolies is illustrative of the 
value of duopolies.  In 2003, due to its acquisition and management of its nine 
major market duopolies, Fox realized a substantial increase in station profits.  
Total station profits were reported to be approximately $1 billion.
65
  Roughly 
sixty percent of the reported TV station revenue base of $2.2 billion that 
accounted for the $1 billion in profits was generated by the TV duopolies.
66
 
 
2. The Impact on Minority Owners 
Historically minority broadcast owners have expressed concern about FCC 
proposals and decisions to relax the broadcast national and local ownership 
rules.
67
  The prior rule changes were said to result in a reduction in market entry 
and longevity opportunities for minority owners.  Rule relaxation caused an 
increased market demand for stations that were attractive as second TV 
properties in a market.  [S]oaring station prices after(relaxing the multiple 
ownership rules) put minority outlets in "'double jeopardy' . . . They couldn't 
afford to trade up to the better facilities in their markets and the stations against 
which they were competing were rapidly becoming parts of large broadcast 
groups, capable of bringing significant economies of scale to the market .   It has 
been argued that further rule relaxation would only exacerbate an already 
negative situation.
68
 
                                        
65
 Diane Mermigas, TV Station Economics Setback; Delayed Dereg Hurts Valuations, 
Mermigas on Media, September 10, 2003, Pg. 1. 
66
 Id 
67
 Harry A. Jessell, Sikes Ready To Move On TV Ownership: Chairman Wants To 
Expand Number Of Stations A Licensee May Own Both Locally And Nationally, 
Broadcasting, April 20, 1992, Vol. 122 ; No. 17 ; Pg. 10. 
 
68
 Sikes Unscathed at Hearing: FCC May Settle On Permitting Ownership Of 30 AMs, 
30 FMs; Change Duopoly Rule, Communications Daily, March 12, 1992, Pg. 1.  
 30
These observations appear to be borne out by the adverse impact of the rule 
change.  The origins of the adverse impact of the changes in the TVD rule in all 
likelihood predate the rule change to the extent that the rule codified the pre-
existing LMA relationship.  In this regard, impact is better measured from the 
introduction of LMAs into the respective television markets.  This conclusion is 
supported by several observations.  First, LMAs appear to include the more 
economically viable stations in a market (taking into account the management 
acumen of the partner station).  Second, many of the LMAs were subsequently 
converted into TVDs after the rule change. 
 
In this regard, one immediate adverse impact of the rule change for minorities 
and women owners was its inability to further dampen the market advantages 
the pre-existing LMA afforded the dominant LMA partner.  First, the partner had 
intimate knowledge of the sister stations availability and viability developed 
through the management of and/or investment in staff and facilities.  Second, 
the LMA often included a provision affording favorable purchasing rights (1
st
 
refusal) and rates to the dominant partner.  While the FSSR could partially offset 
the 1
st
 advantage (knowledge of the existence of a failing or failed station), it 
provided no offset for the other.  It is not surprising that only one TVD was 
reported to be minority owned. 
 
  D. Further Relaxation of the TVDR 
In 2003, the FCC voted to further relax the limits on media concentration.  The 
FCC proposed to: (1) increase the aggregate television ownership cap to enable 
one company to own stations reaching 45% of the national market (up from 
35%); (2) lift the ban on newspaper-television cross-ownership, and (3) allow a 
single company to own three television stations in large media markets and two 
                                                                                                                    
Quoting Pierre Sutton, Chairman of Inner City Broadcasting and the National Assn. of 
Black Owned Bcstrs. and Amancio Suarez, Secretary and Treasurer of American 
Hispanic Owned Radio Stations and of WAQI(AM). 
 31
in medium ones.  In the largest markets, the rule would allow a single company 
to own up to three television stations, eight radio stations, the cable television 
system, cable television stations, and a daily newspaper.  It was anticipated that 
once implemented the 2003 TVDR relaxation would result in more market 
consolidation. 
 
Wall Street broadcast market observers anticipated that investments would 
support the creation of strategic duopolies and triopolies by large network station 
owners like CBS and Fox.  These owners would receive relief from the increase 
the national ownership cap from 35% to 45% and have more room to add 
stations to their respective portfolios.
69
  The deregulation was expected to result 
in $325 million in duopoly driven cost savings
70
 and to generate as much as $6.5 
billion in new market value.
71
 
 
It was speculated that the proposed further deregulation would result in one 
company dominating the media outlets in most major markets except the top 
three.  In addition, the U.S. broadcast market might become two tiered with 
large networks and group owners dominating the first 150 markets and small 
players in the remaining markets.  Mid sized station group owners would be 
forced to sell out or become larger depending on strategic positioning and 
financing. 
 
Pure play television stations and group owners operating single channels were 
expected to be absorbed into larger horizontally or vertically integrated media 
companies.
72
  According to one Wall Street analyst: [t]he] publicly traded pure-
                                        
69
 The Hollywood Reporter, June 3, 2003; Mermigas on Media, June 3, 2003. 
 
70
 Id 
71
 Id 
72
 Mermigas on Media, June 3, 2003 
 32
play TV companies most likely to be absorbed include Young Broadcasting, 
Sinclair Broadcast Group, LIN Television, Gray Broadcasting, Fisher 
Communications, Granite Broadcasting, Liberty Corp. (not Liberty Media Corp.) 
and Acme Communications.
73
   
 
Large group owners like Hearst-Argyle Television, E.W. Scripps, Belo, Gannett 
and LIN Television were expected to merge to create mega powerhouse station 
groups that would have the negotiating clout to reshape network-affiliate 
relations.
74
  Because of duopoly and triopoly driven synergies, Wall Street 
predicted a heightened interest in TV station purchases which would in turn 
inflate station prices.
75
 
 
According to a study by J.P.Morgan media analysts, it was projected that the rule 
change would result in an additional 123 TV duopolies.
76
  While duopolies would 
still be banned in 92 markets, significant concern was voiced about the likely 
consolidation and loss of diversity that would occur in the market once the rule 
change was implemented.
77
 
 
II. Regulation and Market Dynamics 
To properly understand the possible impact of the FCCs ownership policies on 
minority and female broadcast ownership, it is appropriate to examine how they 
might affect broadcast ownership generally.  This in turn requires a brief 
understanding of broadcast market dynamics.  To date, broadcasters primary 
ability to generate revenues has been directly related to their ability to attract 
                                        
73
 Mermigas on Media, June 3, 2003, quoting Jessica Reif Cohen, analyst at Merrill 
Lynch. 
74
 Id 
75
 Id 
76
 Id 
77
 The Times (London), June 2, 2003; Los Angeles Times, May 30, 2003. 
 
 33
viewers desirable to advertisers.  Secondarily, some broadcasters generate 
revenues through the sale of programming. 
 
A. Generating Advertising Revenues 
A commercial broadcast stations ability to generate advertising revenues is 
affected by the size of its market (geographic area and population), the number 
of station competitors, its audience share and demography (age, gender, race, 
ethnicity, income, consumption patterns) as well as its service type (VHF or 
UHF), signal reach (geographic area covered) and signal strength (ease of 
receiving the signal within the geographic area covered).  These characteristics 
(along with general business competence) affect the size and desirability of the 
broadcasters audience for advertising purposes.  Consequently they affect the 
broadcasters ability to generate revenue and profits. 
 
Beyond market, station type and signal, a television stations revenue and 
profitability can depend on membership in a broadcast group, a broadcast 
network or affiliation with a network.  Membership in such entities affords 
members economies of scale in staffing and bargaining power and in production 
and distribution of programming (costs).  Economies of scale are also realized in 
the production of higher quality programming to attract desirable audiences 
(revenues) as well as in the sale of advertising (revenues). 
 
Possession of cable TV must carry status (regulatory entitlement) or of 
retransmission consent fees (ownership of programming desirable to cable 
operators
78
, broadcast satellite or telephone multi-channel providers) also 
                                        
78
 Under Sections 614 and 615 of the Communications Act, cable operators must set 
aside up to one third of their channel capacity for the carriage of commercial 
television stations and additional channels for noncommercial stations depending on 
the system's channel capacity. Commercial broadcast television stations may elect 
carriage on cable systems pursuant to either mandatory carriage (must carry) or 
retransmission consent. If a television station elects must carry, the cable operator is 
required to carry the signal without compensation. Alternatively, when a station 
 34
positively affects revenues by extending the stations market coverage and 
essentially enhancing it signal reception for purposes of ad sales. 
 
Some broadcasters can elect to eschew must carry status and require multi-
channel video providers to pay a fee in return for retransmission of the 
broadcasters programming.  These fees provide another source of revenues.
79
  
In addition, some television broadcasters have begun to seek advertising 
revenues from the provision of online content via the Internet as well as from 
the broadcast of digital channels.
80
 
 
Competition from other broadcasters and other video distribution platforms such 
as cable TV, telephone and satellite firms and the Internet
81
 can also affect a 
                                                                                                                    
elects retransmission consent, the cable operator and broadcaster negotiate the 
terms of carriage. Broadcast television stations carried pursuant to either 
retransmission consent or must carry count towards the required set-aside for the 
carriage of commercial broadcast stations.  FCC Issues Notice Of Inquiry Regarding 
Annual Assessment Of Status Of Competition In Market For Delivery Of Video 
Programming, US Fed News, October 20, 2006. 
 
79
 Currently, cable and satellite operators are required to carry only one digital 
broadcast feed from stations.  Allison Romano, Digital Delivery; With Analog Exiting, 
Stations Launch Wave of Channels, Broadcasting and Cable, April 24, 2006, Pg 6. 
 
80
 Some stations have begun multicasting local weather and news channels   on their 
digital broadcast space.  NBCs channel Weather Plus, has local versions in 90 
markets covering 75%   of the country. Rival networks have built their own local 
news and weather channels in response.  Broadcasting multiple digital channels is 
possible now that 80% of approximately 2,000 U.S. TV stations have upgraded to 
digital technology. The increased digital spectrum offers local broadcasters the best 
opportunity to   launch new businesses such as high-definition broadcasting, transmit 
data or create new TV-delivery services as low-cost alternatives to cable and 
satellite.  Allison Romano, Digital Delivery; With Analog Exiting, Stations Launch 
Wave of Channels, Broadcasting and Cable, April 24, 2006, Pg 6. 
81
 For instance, NBC Universal has formed a digital broadband venture with its 213 
TV affiliates.  The network will share advertising dollars generated by the sale of local 
and network news, sports, weather and video to Web portals and Internet video 
outlets.  Similarly, Fox recently agreed to pay 150 TV affiliates 12.5% of the 
proceeds from post broadcast Internet downloads of 60% of its primetime series.  
Ironically, affiliates will have to give up network programming exclusivity to get the 
revenues.  Smaller affiliates may be particularly disadvantaged.  The ability to mine 
Internet revenues is peculiar to the large networks and group owners that have the 
ability to develop and distribute programming.  Single broadcast station owners who 
 35
broadcasters profitability.  For instance, it is asserted that the migration of 
advertisers and consumers to the Internet is increasing and irreversible and has 
a detrimental impact on local television broadcast stations.  According to some 
observers, local television station advertising sales are falling at the rate of 4% 
annually.  The reduction of stations advertising sales occurs despite the fact that 
broadcasting enjoys a 90% national market penetration rate in comparison to 
the internets 60% national market penetration rate.   
 
It has been argued that while the TV ad sales of all broadcasters combined 
barely keeps up with the growth in the gross domestic product (3%-4% per 
year), Internet advertising is growing at a pace of 40% per year.  It is asserted 
that the shrinking television ad market share allegedly caused by the increasing 
shift to the interactive Internet will generate increasingly fierce market 
competition for the remaining market share among one way local TV 
broadcasters.  However, at least one prominent broadcaster does not view this 
trend as a cause for alarm.
82
 
 
Broadcaster audience shares are measured by national ratings services.  The 
ratings measurement methodology used affects the calculation and reporting of 
the stations audience share and consequently affect its ability to sell advertising 
inventory. 
                                                                                                                    
already struggle with programming costs must compete with network owned and 
operated stations, network affiliated stations and group owned stations that have 
another revenue stream to tap.  Diane Mermigas, Mermigas on Media, The Hollywood 
Reporter, April 25, 2006. 
 
82
 "The claim that broadcast television is dying is nearly as old as broadcast 
television itself," Redstone said. "Our nation's broadcasters--our national networks 
and local radio and TV stations--have been intelligent enough, dynamic enough and 
creative enough to remain the most important, most vital and most responsive 
medium for disseminating news and entertainment ever invented."  Gary Dretzka, 
Chicago Tribune, April 11, 2000 Tuesday, Business Section, Pg. 3.  Quoting Sumner 
Redstone, chairman and chief executive officer of Viacom Inc. 
 
 36
Based on the foregoing identification of the market factors affecting broadcast 
station competitiveness and profitability, it is reasonable to conclude that the 
FCCs ownership policies are not the sole determinants of station viability.  
However, policies having a fundamental role in determining the number of like 
competitors in the market and the potential scope of their economies of scale 
necessarily have an impact on how the stations, whatever their economic 
position, manage the other market factors. 
 
For example, it is recognized that TV duopoly economics and the LMA economics 
which were codified when the TVDR was changed, affect several key market 
factors that broadcasters must control or at least manage in order to be 
successful.  The addition of a second station in the market expands signal reach 
thereby expanding the broadcasters potential audience.  It reduces costs by 
spreading them over a larger portion of the reachable market.  It increases 
audience size and enhances the ability to segment the audience while increasing 
advertising time available to generate income from the expanded audience.  In 
the hands of a skillful group owner, it can allow the exertion of control over 
advertising rates.  It can also facilitate greater access and control over 
syndicated program offerings.  For all of these reasons, the interaction between 
the national ownership cap and the TVDR is critical to broadcaster success.  The 
value of duopolies is recognized by Wall Street investors as reducing costs and 
enhancing value.  Consequently it is viewed by potential broadcast station sellers 
and buyers as a justification for increasing the perceived value of potential 
duopoly sister stations. 
 
 
 
 
 
III. Findings 
 37
A. The TVDR Waiver and Minority Owned Television Stations 
Because of the differences in the onset and duration of a minority-owned 
stations operation in a market and gaps in data as well as to facilitate data 
manipulation, the minority owned station data are reported in three segments: 
1998  2006; 2000  2006 and 2001  2006. 
 
1. Minority Owned Stations 1998 to 2006 
Thirty television stations were identified as minority owned by the 1998 NTIA 
survey on minority ownership and/or identified and confirmed based on Form 
323 filings with the FCC and/or findings of the Free Press study as well as resort 
to the popular press.  Two stations operated in markets where there was no 
duopoly.  Three stations operated in markets where there were LMAs operating 
but no duopoly.   
 
Twenty-five of the stations operated in markets in which a duopoly operated or 
entered.  Of those twenty-five stations, three minority owned stations operated 
in the San Francisco/San Jose metro.  Two stations operated in Los Angeles and 
two operated in Lansing.  The remaining eighteen stations each operated in a 
separate single market.  A total of twenty-one markets were home to thirty-four 
duopolies. 
 
Of the thirty minority-owned stations in this grouping, fifteen stations (50%) 
were sold to non-minority purchasers from 1998 to 2006.  Of the fifteen 
minority-owned stations sold between 1998 and 2006, five were sold after a TV 
duopoly entered the market.  Another one was sold in the same year that a TV 
duopoly entered the market.  One of the five minority-owned stations that left 
the market after the entry of a TVD was part of a duopoly that was dissolved 
when one of the stations was sold.  A new duopoly was then formed by NBC but 
the original minority owner (Granite) was excluded.  Granites short lived duopoly 
was the only minority owned duopoly formed during this time period.  
 38
Nine of the fifteen stations were sold before a TV duopoly entered the market.  
One of the nine stations, WPTT (Pittsburgh) was sold in 2000.  It was purchased 
back from its minority owner Eddie Edwards by the former seller Sinclair 
Broadcasting after the FCC revision to the TVD rule in 1999 allowed Sinclair to 
own a second station in the market.  This is one example of a non minority 
owner acquiring the minority owned station with a subsequent reduction in 
diversity of ownership in the market.  One station was sold in the same year that 
a duopoly entered its market. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table # 1: Minority Owned Stations in Duopoly Markets 1999-
2006 
 
 39
 Callsign
 
Cit
y
 
 
St
at
e 
 
DMA
 
 
Duopolies
 
1 KBFD Honolulu HI 72 2000 KHON, KGMB Emmis  
2 KBJR Duluth MN 137 LMA - KBJR Granite & KDLH Malara 
3 KBSP Salem (Portland) OR 23 2003 KPTV, KPDX Meredith;  
2006 KATU, KUNP Fisher Communications 
4 KBWB San Francisco CA 5 1999 KNTV, KBWB Granite; 
KNTV, KSTS NBC/Universal; KDTV, KFSF 
Univision; 
KPIX, KBCW Viacom/CBS; 
KTVU 2 Fox, KICU Cox 
5 KEYE Austin TX 52 1999 KNVA, KXAN, KXAM Lin TV 
6 KLTV Tyler-Longview TX 111 
2006 KLTV, KTRE Raycom Media 
7 KNTV San Jose CA 5 1999 KNTV, KBWB Granite; 
KNTV, KSTS NBC/Universal; KDTV, KFSF 
Univision; 
KPIX, KBCW Viacom/CBS; 
KTVU 2 Fox, KICU Cox 
8 KPST Vallejo CA 5 1999 KNTV, KBWB Granite; 
KNTV, KSTS NBC/Universal; KDTV, KFSF 
Univision; 
KPIX, KBCW Viacom/CBS; 
KTVU, KICU Cox 
9 KRCA Riverside (Los Angeles) CA  2 2002 KNBC, KVEA* NBC/Universal; 
KCAL, KCBS CBS/Viacom; 
KCOP, KTTV Fox; KMEX, KFTR Univision 
10 KSEE Fresno CA 55 2003 KFRE, KMPH Pappas Telecasting Co. *  
11 KSTV Ventura (Los Angeles) CA 2 2002 KNBC, KVEA NBC/Universal;  
KCOP, KTTV Fox; 2002 KMEX, KFTR Univision; 
KCAL, KCBS CBS/Viacom 
12 KTRE Lufkin TX 111 
2006 KLTV 7 ABC, KTRE 9 ABC Raycom Media 
13 KTVJ Denver CO 18 2005 KUSA 9 NBC,KTVD 20 MNTV Gannett 
14 WATL Atlanta  GA 9 2006 WXIA 11 NBC, WATL 36 MNTV Gannett 
15 WMBC Newton (New York) NJ  1 2002 WXTV 41 Univision, WFUT 68 Telefutura 
Univision;  
WNYW, WWOR Fox 
16 WEEK E. Peoria IL 116 LMA  WEEK Granite WAOE Four Seasons 
B/cast'g  
operated by Granite 
17 WGTW Burlington(Philadelphia) NJ  4 2006 WPSG, KYW CBS/Viacom 
18 WJJA Racine WI 33 
2004 WWJ, WKBD CBS/Viacom 
19 WJYS Tinley Park IL 3 2000 WMAQ, WSNS NBC/Universal; WFLD, WPWR 
Fox;  
WGBO, WXFT Univision 
20 WKBW Buffalo NY 49 2000 WNYO, WUTV Sinclair; 2006 WIVB, WNLO Lin 
TV 
21 WLAJ Lansing MI 112 2004 WWJ 62 CBS, WKBD 50 CW CBS/Viacom 
22 WLBT Jackson MS 87 
No Duopolies found 
23 WMYD Lansing MI 112 2004 WWJ 62 CBS, WKBD 50 CW CBS/Viacom *  
2007 Granite in Chapter 11 
24 WNOL New Orleans LA 54 1999 WGNO 26 ABC, WNOL 38 CW LA Tribune; 
2005 WUPL 54 MNTV, WWL  4 CBS Belo 
25 WPTA Ft. Wayne IN 106 LMA - WISE Granite & WPTA Malara operated by 
 40
Granite 
26 WPTT Pittsburgh PA 22 2006 WPGH, WPMY Sinclair; KDKA, WPCW 
CBS/Viacom 
27 WRBU East St. Louis IL 21 No Duopolies found  * Sold in 2007 beyond scope of 
study 
28 WTMW Arlington VA 8 2006 WTTG, WDCA Fox; WTMW > WFDC * Sold 
2007 
29 WTVH Syracuse NY 79 2006  WSTM, WSTQ Barrington B/ctg 2007 
Granite Chpt 11 
30 WVII Bangor  ME 152 1999 WCSH, WLBZ Gannett  
 
 
Table # 2: Minority Owned Station Activity in Duopoly Markets 
1999-06
83
 
 Callsign
 
Cit
y
 
St
at
e 
 
DMA
 
MOS  Activit
y
 
Mkt Act
i
v
i
ty
 
Duopoly Mkt Entr
y
 
1 KBFD Honolulu HI 72 MO 1999-06 SO 2000 
2 KBSP Salem (Portland) OR 23 Sold 1999 LBD          2003 
         2006 
3 KBWB San Francisco CA 5 Sold 2005 LAD 1999 
4 KEYE Austin TX 52 Sold 2000 LAD 1999 
5 KLTV Tyler-Longview TX 111 
Sold 2000 LBD 2006 
6 KNTV San Jose CA 5 
Sold 2002 LAD 
1999 
7 KPST Vallejo CA 5 Sold 2001 LAD 1999 
8 KRCA Riverside (LA) CA  2 
MO 2001-07 SO 
2002 
9 KSEE Fresno CA 55 MO 2001-07 SO* 2003 
10 KSTV Ventura (LA) CA 2 MO 1999-06 SO 2002 
11 KTRE Lufkin TX 111 
Sold 2000 LBD 2002 
12 KTVJ Denver CO 18 Sold 2003 LBD 2005 
13 WATL Atlanta  GA 9 
Sold 2006 LSYD 
2006 
14 WMBC Newton  (New York) NJ  1 MO 1999-07 SO 2002 
15 WGTW Burlington (Phila.) NJ  4 Sold 2004 LBD 2006 
16 WJJA Racine WI 33 
MO 1990-05 SO          2004 
17 WJYS Tinley Park IL 3 
MO 2003-05 EAD          2000 
18 WKBW Buffalo NY 49 
MO 1999-05 SO*          2000 
                                        
83
 MO = Minority Owned 
MOS = Minority Owned Station 
EAD = Entered market After Duopoly entered market 
ESYD = Entered market the Same Year as the Duopoly entered market. 
LAD = Left market After Duopoly entered market 
LBD = Left Before Duopoly entered market 
LSYD = Left market the Same Year as the Duopoly entered market. 
SO = Still Operating in market entered by duopoly. 
*  = Qualification 
Table does not include LMA markets or markets in which no duopoly was found.  A 
total of five stations/markets are excluded. 
 
 41
         2006 
19 WLAJ Lansing MI 112 Sold 1999 LBD          2004 
20 WMYD Lansing MI 112 MO 1999-05 SO*          2004 
21 WNOL New Orleans LA 54 Sold 2000* LAD          1999 
         2005 
22 WPTT Pittsburgh PA 22 Sold 2000 LBD          2006 
23 WTMW Arlington VA 8 Sold 2001 LBD          2006  
24 WTVH Syracuse NY 79 
MO 1998-06 SO*          2006  
25 WVII Bangor ME 152 Sold 1998 LBD 1999 
 
2. Minority Owned Stations 2000 to 2006 
Six television stations were identified as minority owned based on Form 323 
filings with the FCC in 2000.  These stations were not identified as minority 
owned in the 1994 or 1998 surveys conducted by NTIA.  Of the six minority 
owned stations, one is slated to be sold to a non-minority owner before the end 
of 2007.  It currently operates in a market having two duopolies.  The first 
duopoly entered the market in 2000 and the second one entered in 2006. 
 
Of the remaining five stations, one station entered a market in which a duopoly 
had been operating since 1999.  The station entered the market in 2001 and has 
continued to operate in the market.  Four stations in this group operated in 
markets where no TV duopoly operated. 
 
Table # 3: Minority Owned Stations in Duopoly Markets 2000-
06 
Callsign
 
City 
 
State 
 
DMA
 
Duopolies 
 
1 KCHF Santa Fe 
(Albuquerque)  
NM 45 1999 KWBQ, KASY Acme 
Communications 
2 WKBW Buffalo NY 49 2000 WNYO, WUTV Sinclair;  
2006 WIVB, WNLO Lin TV; 
 
 42
Table # 4: Minority Owned Station Activity in Duopoly Markets 
2000-06
84
 
 Callsign
 
City 
 
State
 
DMA 
 
Own/Sell/NMO
 
Own/Sell/NMO
 
Duopolies in
 Market
 
1 KCHF Santa Fe 
(Albuquerque)  
NM 45 
MO 2001-06 EAD 
                  
1999 
2 WKBW Buffalo NY 49 
MO 1999-06  SO* 
              
2000 
 
 
3. Minority Owned Stations 2001 to 2006 
A total of thirty television stations were identified as minority-owned between 
2001 and 2006.  These stations were not identified in the 1998 NTIA study nor 
were they identified in available FCC files prior to 2001. 
 
The thirty stations operated in twenty-six markets.  Thirteen markets had no 
identified TV duopoly.  As each contained a different minority owned station, it 
was concluded that the thirteen stations operated in markets with no operating 
duopoly.  Sixteen minority-owned stations operated in markets with at least one 
TV duopoly.  There were a total of twenty-five duopolies operating in thirteen 
markets.  Three of the markets (Dallas/Fort Worth, Miami/Key West and Tulsa) 
each had two operating minority owned stations.  These three markets 
accounted for six stations and nine duopolies.  The remaining ten minority 
owned stations operated in separate markets.  These markets contained sixteen 
                                        
84
 MO = Minority Owned 
MOS = Minority Owned Station 
EAD = Entered market After Duopoly entered market 
ESYD = Entered market the Same Year as the Duopoly entered market. 
LAD = Left market After Duopoly entered market 
LBD = Left Before Duopoly entered market 
LSYD = Left market the Same Year as the Duopoly entered market. 
SO = Still Operating in market entered by duopoly. 
*  = Qualification 
 
 43
duopolies.  One minority-owned station operated in a market in which two 
stations operated under an existing LMA but no duopoly existed. 
 
Of the thirty stations, three were sold to non-minority owners.  Two minority-
owned stations were sold after a TV duopoly began operation in their market.  
Both were sold to non minority owners.  The other station (WWRS) was 
essentially sold to a non-minority owner.  The station operated in a market in 
which no duopoly was present.  Three minority-owned stations entered their 
respective markets after a duopoly had entered. 
 
4. Minority-Owned Station Activity in Non-Duopoly 
Markets 
Combining all of the markets with minority-owned stations but no operating 
duopolies into one group was informative.  In the nineteen non duopoly 
markets only two minority owned stations were sold.  Ten percent of minority-
owned stations left the market in non-duopoly markets.   
 
Combining all of the markets with minority owned stations and entering or 
operating duopolies into one group was also informative.  Seventeen of the forty-
three minority-owned stations that operated in thirty-three markets in which 
duopolies entered or operated left the market.  More than thirty-nine percent of 
minority-owned stations left duopoly markets from 1999 to 2006.  Minority-
owned stations were four times more likely to be sold in duopoly markets than in 
non-duopoly markets. 
 
 44
Table # 5: Minority Owned Stations in Duopoly Markets 2001-
2006 
 Callsign
 
City
 
State 
 
DMA
 
Duopolies
 
1 KBFD Honolulu HI 72 2000 KHON, KGMB Emmis 
2 KCFG Flagstaff (Phoenix) AZ 13 2006 KSAZ, KUTP Fox; KTVW, KFPH 
Univision;  
KTVK, KASW Belo 
3  KFWD Ft. Worth (Dallas) TX 6 2004 KDFW, KDFI Fox; KXAS, KXTX 
NBC/Universal;  
KUVN, KSTR Univision;KTVT, KTXA 
CBS/Viacom 
4 KHCV Seattle WA 14 2007 KOMO, KUNS Fisher Communications 
5 KMPX Dallas/Ft. Worth TX 6 2004 KDFW, KDFI Fox) KXAS, KXTX 
NBC/Universal; 
KUVN, KSTR Univision; KTVT, KTXA 
CBS/Viacom 
6 KNMT Portland OR 23 2003 KPTV, KPDX Meredith; 2006 KATU, KUNP 
Fisher 
Communications 
7 KOTV Tulsa OK 62 2006 KOKI, KMYT Clear Channel 
8 KQCW Tulsa OK 62 2006 KOKI, KMYT Clear Channel 
9 KTDO El Paso TX 99 2004 KINT, KTFN Entravision 
10 KTRG 
Del Rio (San Antonio) TX 
37 
2005 KABB, KMYS Sinclair 
11 KWTV Oklahoma City OK 46 2002 KOCB, KOKH Sinclair 
12 KXLA Rancho Palos Verdes (LA) CA 2 2002 KNBC-TV, KVEA NBC/Universal; KCOP, 
KTTV 
Fox; 2002 KMEX, KFTR Univision;  
KCAL, KCBS CBS/Viacom 
13 KZJL Houston TX 10 
2004 KRIV, KTXH Fox; KXLN, KFTH Univision 
14 WGEN Key West (Miami) FL 16 2002 WTVJ, WSCV NBC/Universal;  
WLTV, WAMI Univision; WFOR, WBFS 
CBS/Viacom 
15 WISE Fort Wayne IN 106 LMA - WISE (Granite) + WPTA (Malara) 
(operated by Granite) 
16 WMGM Atlantic City (Philadelphia) NJ  4 2006 WPSG, KYW CBS/Viacom 
17 WSBS Key West (Miami) FL 16 2002 WTVJ, WSCV NBC/Universal;  
WLTV, WAMI Univision; WFOR, WBFS 
CBS/Viacom 
 
 
 45
Table # 6: Minority Owned Station Activity in Duopoly Markets 
2001-06 
 
 Callsign
 
City 
 
State 
 
DMA
 
Own/Sell/NMO
 
Mkt A
c
tivit
y
 
Duop. Mk
t Entry
 
1 KBFD Honolulu HI 72 MO 1999-06 SO 2000
2 KCFG Flagstaff (Phoenix) AZ 13 MO 2002-06 SO* 2006
3  KFWD Ft. Worth (Dallas) TX 6 MO 2001-06 SO 2004
4 KHCV Seattle WA 14 MO 2003-06 SO 2007
5 KMPX Dallas/Ft. Worth TX 6 MO 2004-06 SO 2004
6 KNMT Portland OR 23 "Sold" 2005 LAD 
LBD 
2003  
2006 
7 KOTV Tulsa OK 62 MO 2003-07 SO 2006
8 KQCW Tulsa OK 62 MO 2006-07 SO 2006
9 KTDO El Paso TX 99 MO 2006 EAD 2004
10 KTRG 
Del Rio (San Antonio) TX 
37 
Bnkpt 2006 LAD 2005
11 KWTV Oklahoma City OK 46 MO 2006 EAD 2002
12 KXLA Rancho Palos Verdes (LA) CA 2 MO 2003-06 SO 2002
13 KZJL Houston TX 10 
MO 2001-07 SO 2004
14 WGEN Key West (Miami) FL 16 MO 2004-06 SO 2002
15 WMGM Atlantic City (Philadelphia) NJ  4 MO 2001-07 SO 2006
16 WSBS Key West (Miami) FL 16 MO 2003-07 EAD 2002
 
MO = Minority Owned 
MOS = Minority Owned Station 
EAD = Entered market After Duopoly entered market 
ESYD = Entered market the Same Year as the Duopoly entered market. 
LAD = Left market After Duopoly entered market 
LBD = Left Before Duopoly entered market 
LSYD = Left market the Same Year as the Duopoly entered market. 
SO = Still Operating in market entered by duopoly. 
 
 46
Table # 7: Minority Owned Station Activity in Non-Duopoly 
Markets (Combined) 
 
 Callsign
 
City 
 
State 
 
DMA 
 
MO Ac
tivity
 
Duopoly Sta
t
us
 
1 KBEO Jackson (Idaho Falls) WY 163
MO 2001-06 
None 
2 KEJB El Dorado AR  
MO 2003-07 
None 
3 KIDA Sun Valley (Twin Falls) ID 191 MO 2006 None 
4 KNIN Boise ID 119 MO 2003-05 None 
5 KPIF Pocatello ID  
MO 2003-04 
None 
6 KRII Chisolm MN 137 MO 2005 None 
7 KSCW Wichita KS 67 Sale 2007 * None 
8 KTAS San Luis Obispo (Santa Barbara) CA 122 MO 2006 None 
9 KTGF Great Falls  MT 190 MO 2005 None
10 KTLM Mc Allen (Lower Rio Grande) TX 91 MO 2005 None 
11 KVAW Eagle Pass (San Antonio) TX 37 MO 2004-07 None
12 KVIQ Eureka CA 193
MO 2005-07 
None 
13 KVMD Twenty-Nine Palms (Los Angeles) CA 2 
MO 2003-06 
None 
14 KWKB Iowa City  IA  88 
MO 1999-05 
None 
15 WLBT Jackson MS 87 
Sold 2002 
None 
16 WRBU East St. Louis IL 21 MO-1999-06 None 
17 WRBJ Magee (Jackson) MS 89 
MO 2004-05 
None 
18 WWRS
85
 Mayville (Milwaukee) WI 34 MO??? None
19 WZRB Columbia SC 83 MO 2004-06 None 
 
 
4. Conclusions 
 There were no surviving minority-owned duopolies  
 The chief beneficiaries of the rule change were the top 25 group 
owners who as of 2005 accounted for 83 of the 109 (76%) duopolies 
identified. 
 Across all markets in which minority-owned television stations 
operated between 1999 and 2006, the number of minority-owned 
television stations dropped by twenty-seven percent. 
                                        
85
 Minority ownership status questionable as early as 2001.  A Challenge to TBN Growth; The 
FCC once ruled that a minority-owned company was a scheme to acquire more stations. Los 
Angeles Times September 20, 2004  Non Minority status clear as of 2005. 
 47
 Within markets entered and or occupied by TV duopolies, the number 
of minority owned stations dropped by more than thirty-nine percent. 
 
Combined over the 1998-2006 time period, non-minority owners accounted for 
sixty duopolies operating in thirty-six of the markets in which minority-owned 
stations operated.  Minority owners accounted for one short lived duopoly in one 
market.  Two minority-owned stations were acquired to form non-minority-
owned duopolies.
86
  All of the duopoly owners were networks or relatively large 
group owners.  The majority of duopoly owners were ranked in the top twenty-
five group owners in the United States by national market share and/or by 
revenues.
87
  None of the duopolies was formed by a single station owner 
acquiring a second station in the same market. 
 
It appears that the FCCs 1999 change to the rule had a negligible, fleeting 
positive impact on minority ownership if it is measured in the number of 
duopolies acquired.  Indeed, the net result of the duopoly relaxation was the loss 
of two minority owned stations with the acquisition of one station causing the 
loss of the only minority owned duopoly.  Of the sixty duopolies created in 
markets containing minority-owned stations from 1998 to 2006 the net number 
of minority-owned duopolies is zero.  Of the sixty duopolies formed in the time 
period in question, fifty-five were owned by groups ranked in the top twenty-five 
television group owners in terms of revenue or national market share for 2001-
2002.  It would seem that the true beneficiaries of the FCCs rule change were 
the large station group owners. 
                                        
86
 Query whether minority-owned stations were typically less desirable than other 
stations because they operated at a technical competitive disadvantage, were more 
reluctant to sell or were just one of many options for the entering duopolist. 
87
 See Dan Trigoboff, Less Is More As Viacom Retakes Top Spot, Broadcasting & 
Cable, April 08, 2002, Special Report; Pg. 46; Kim McAvoy, What the Top 25 Want, 
Broadcasting & Cable, January 21, 2002, Special Report; Pg. 44; Elizabeth A. 
Rathbun, Sly Fox Buys Big, Gets Back On Top, Broadcasting & Cable, April 23, 2001, 
Pg. 59. 
 
 48
From 1998 to 2006 there were sixty-two minority-owned television stations 
operating in forty-six markets.  By the end of 2006, twenty-seven percent of 
those stations had been sold to non-minority owners.  During the same time 
period, only ten percent of minority owned stations were sold in non-duopoly 
markets.  From 1999 to 2006 a total of five minority-owners acquired stations in 
markets already containing at least one TV duopoly.  Twenty-oner minority-
owned stations continued to operate in their respective markets after a duopoly 
was introduced.  Nineteen minority-owned stations operated in markets with no 
TV duopolies.  Minority-owners did not account for a single surviving duopoly. 
 
The net change in the number of minority-owned stations during the 1998 to 
2006 time period reflected a drop of twenty-seven percent in the number of 
minority-owned stations.  Minority owners were roughly three times more likely 
to leave a market than to enter it.  Minority owners were slightly more likely to 
leave a market prior to the introduction of a duopoly (9) than once a duopoly 
they had entered their market (7).  Again, the duopoly rule change does not 
appear to have had any positive impact on minority ownership of TV stations. 
 
Indeed, as mentioned above, the chief impact may have been negative.  The 
rule change stopped prospective use of the LMA but codified the pre-existing 
use.  As a result it failed to erase the market advantages the pre-existing LMA 
afforded the dominant LMA partner.  The dominant partners intimate knowledge 
of the sister stations availability and viability as well as its enjoyment of 
favorable purchasing rights and purchasing rates disadvantaged all other buyers 
including potential minority and female purchasers .  While the FSSR could 
partially offset this by making known the existence of a failing or failed 
station, it could not offset the favorable purchasing rights at favorable prices 
enjoyed by the dominant partner in an LMA.  It is not surprising that only one 
TVD was briefly reported to be minority owned.   Based on the demonstrable 
 49
benefit and detriment, the TV duopoly policy change appears to have benefited 
non-minority television station group owners and does not appear to have 
benefited minority-owned television owners. 
 
 50
Table # 7: Minority-Owned Television and Revision to the TVDR 
Tier Transaction Relevance Duopolies
Tier #1 NMOS buys 
2
nd
 NMOS in same market 
No increase or decrease in MO diversity 
unless decrease in competitive status of 
MOS 
60 
 NMOS buys 2
nd
 MOS in 
same market 
Potential reduction in MO diversity 2 
 MO buys 2
nd
 NMOS in 
same market 
Increase in potential competitiveness of 
FOS  
0 
 MO buys 2
nd
 MOS in same 
market 
No increase or decrease in MO diversity 
unless increase in competitive status 
0 
Tier #2 MO entering market 
containing post rule TV 
duopoly  
Increase in MOS diversity 5 
 MO leaving market 
containing post rule TV 
duopoly 
Decrease in MOS diversity  7 
 MO leaving market before 
duopoly enters 
Decrease in MOS diversity 9 
TV Duopoly 
Tier #3 
MO staying in market 
containing post rule TV 
duopoly  
Impact? 21 
 
 
 51
B. The TVDR Waiver and Female Owned Television 
Based on the available data and subject to the qualifications mentioned earlier in 
this study, sixty-four female owned stations in approximately forty-six markets 
were identified as operating between 1999 and 2006.  There were nineteen 
female owned stations operating in markets in which at least one post 1999 TV 
duopoly entered between 1999 and 2006.  All but one of the stations operated in 
the top seventy-five markets (DMAs).  Seven operated in top twenty-five 
markets.  Another seven operated in next tier of markets (26-50).  Four operated 
in third tier markets (51-75) and one in market #108.   
 
Of the nineteen stations, eight remained in their respective market subsequent 
to the duopolys entry.  Three female owners entered their respective television 
broadcast markets after duopolies had entered.  Seven female owned stations 
were sold to non-female owners.  Two of the seven stations became part of a TV 
duopoly.  Twenty-six duopolies were created in markets in which female owned 
stations operated or later entered.  However, no female owned broadcast 
duopolies were created. 
 
 
 
 
 
 
 52
Table # 8: Female Owned Stations in Duopoly Markets 
(Alphabetical by Call Sign) 1999-2006 
 Callsign
 
City 
 
State
 
 
DM
A
 
Duopolies by
 Year
 
1 KAIL Fresno CA  56 2003 KFRE-TV, KMPH-TV Pappas 
2 KCFG Flagstaff (Phoenix) AZ 13 2006 KSAZ, KUTP Fox; KTVW, KFPH Univision;  
KTVK, KASW Belo 
3 KCHF Santa Fe (Albuquerque) NM 45 
1999 KWBQ, KASY Acme Communications 
4 KCWE Kansas City MO 31 2001 KSHB, KMCI Scripps-Howard;  
2005 KMBC, KCWE Hearst-Argyle; KCTV, KSMO 
Meredith  
5 KFRE Sanger (Fresno) CA  56 2003 KFRE, KMPH Pappas 
6 KLEI 
Kailua Kona (Honolulu) 
HI 72 2000 KHON, KGMB Emmis 
7 KNMT Portland OR 23 2003 KPTV, KPDX Meredith Corp.;  
2006 KATU-TV, KUNP Fisher Comm. 
8 KSBI Oklahoma City OK  2002 KOCB, KOKH Sinclair B/Cast'g 
9 KTFL Flagstaff (Phoenix) AZ 13 2006 KSAZ, KUTP Fox; KTVW , KFPH Univision;  
KTVK, KASW Belo 
10 KTFQ  
Albuquerque                NM   45 1999 KWBQ, KASY Acme Communications 
11 KTMW Salt Lake City UT 35 2005 KTVX, KUWB & KTVX, KUCW Clear Channel; 
KUTH, KUTF Equity 
12 KTSF San Francisco CA  5 1999 KNTV, KBWB Granite>KNTV, KSTS 
NBC/Universal; 
KDTV, KFSF Univision; KPIX, KBHK>KBCW 
CBS/Viacom;  
KTVU, KICU Cox 
13 KVTN Little Rock (Pine Bluff) AR 57 2006 KLRT, KASN Clear Channel; KLRA, KWBF 
Equity; 
KNWA, KFTA Nextstar; KVTN, KVTH Victory 
14 WBPH Bethlehem  PA  4 2006 WPSG, KYW CBS/Viacom 
15 WGTW Burlington (Philadelphia) NJ  4 2006 WPSG, KYW CBS/Viacom 
16 WNYB Buffalo/Erie NY 49 2000 WNYO, WUTV Sinclair; 2006 WIVB, WNLO 
Lin TV  
17 WTXL Tallahassee FL  108 2006 WFXU, WTLH Pegasus 
18 WWRS Mayville (Milwaukee) WI 34 2004 WCGV, WVTV Sinclair 
19 WWSB Sarasota (Tampa) FL  12 2006 WFTT-TV, WVEA-TV Univision 
 
 
 
 
 
 
 
 
 
 
 53
Table # 9: Female Owned Stations in Non Duopoly Markets 
1999-2006 
 Callsign
 
Cit
y
 
 
St
at
e 
 
DMA
 
 
1 KBEO Jackson (Idaho Falls) WY 163 
2 KCEN Temple (Waco) TX 95 
3 KDKF Klamath Falls OR 141 
4 KDRV Medford OR 141 
5 KEJB El Dorado AR 135 
6 KEYC Mankato MN 200 
7 KEZI Eugene OR 120 
8 KGWC Casper WY 195 
9 KGWL Casper WY 195 
10 KGWR Casper WY 195 
11 KIDA Twin Falls ID 191 
12 KIDY San Angelo TX 197 
13 KLSR Eugene OR 120 
14 KMVT Twin Falls ID  
15 KNOE Monroe (El Dorado) LA 135 
16 KOBI Medford (Klamath Falls) OR 141 
17 KOTI Klamath Falls (Medford) OR 141 
18 KPIF Pocatello ID 163 
19 KPXJ Minden (Shreveport) LA 
20 KTBS Shreveport  LA  81 
21 KWKB Iowa City (Cedar Rapids) IA 88 
22 KXVA Abilene (Sweetwater) TX 164 
23 WACY Green Bay WI 69 
24 WCAV Charlottesville VA  
25 WDAY Grand Forks (Fargo)ND ND 119 
26 WDAZ Fargo (Grand Forks) ND 119 
27 WFMJ Youngstown OH  103 
28 WGSA Baxley (Savannah) GA 97 
29 WHIZ Zanesville OH  203 
30 WICU Erie PA 142 
31 WINK Fort Myers (Naples) FL  64 
32 WKBN Youngstown   OH  103 
33 WKTC Sumpter (Columbia) SC 83 
34 WLJC Beattyville (Lexington) KY 63 
35 WMYA Greenville-Spartansburg NC 36 
36 WNUV Baltimore MD 24 
37 WOAY Oak Hill (Bluefield) WV 150 
38 WRGT Dayton OH  58 
39 WTAT Charleston SC 65 
40 WTSF Ashland (Charleston) KY 
41 WTTE Columbus OH  32 
42 WTVA Tupelo MS 132 
43 WVAH Charleston WV 65 
44 WWNY Watertown NY 176 
45 WZVN Naples (Ft. Myers) FL 64 
 54
 C. Conclusions 
 
 There were no female-owned duopolies. 
 36% of the female owned stations operating in duopoly markets were 
sold. 
 All of the stations were sold to non-female, non-minority-owners. 
 The chief beneficiaries of the rule change were the top 25 group 
owners who as of 2005 accounted for 83 of the 109 (76%) duopolies 
identified. 
 More female owned stations were found in non duopoly markets 
 
Roughly thirty-six percent of the female owned stations operating in markets in 
which at least one post 1999 waiver duopoly entered between 1999 and 2006 
sold out to non-female, non-minority owned broadcast groups.  None of the 
duopolies created in markets in which female owned television stations operated 
were female owned.  While three female owners entered markets in which 
duopolies were operating, seven left in the same year the duopoly entered the 
market or afterwards.   
 
For the same reasons outlined above with regard to minority-owners, it would 
appear that the duopoly waiver did not have a positive impact on female 
ownership of television stations.  Again, as found with regard to the duopolies in 
markets in which minority owners operated, the majority of owners benefiting 
from the duopoly rule change in markets in which female owned stations 
operated were owners ranked among the top twenty-five in revenue or reach.  
They include: Belo, CBS/Viacom, Clear Channel, Emmis, Fox, Lin TV, Meredith, 
Pappas, NBC/Universal, Scripps-Howard, Sinclair and Univision. 
 
The ownership of broadcast television by women was more likely to be in 
markets in which fewer or no duopolies were present.  While seventeen female-
 55
owned television stations operated in the top 100 markets, twenty-eight 
operated in markets 101-203. 
 
Table #10: Female Owned Television Stations and the TVDR 
Tier Transaction Relevance Duopolies
Tier #1 NFOS buys 
2
nd
 NFOS in same market 
No increase or decrease in FO diversity 
unless decrease in competitive status of 
FOS 
26 
 NFOS buys 2
nd
 FOS in 
same market 
Potential reduction in FO diversity 2 
 FOS buys 2
nd
 NFOS in 
same market 
Increase in potential competitiveness of 
FOS  
0 
 FOS buys 2
nd
 FOS in same 
market 
No increase or decrease in FO diversity 
unless increase in competitive status 
0 
Tier #2 FO entering market 
containing post rule TV 
duopoly  
Increase in FOS diversity 3 
 FO leaving market 
containing post rule TV 
duopoly 
Decrease in FOS diversity  7 
TV Duopoly 
Tier #3 
FO staying in market 
containing post rule TV 
duopoly  
Impact? 8 
 
Recalibrate the Benefit 
The avowed rationale for relaxing the TV Duopoly rule was to render weak UHF 
stations more economically viable thereby increasing service to the public.  
Ironically, at a time when the number of potential program suppliers increased, 
the weaker UHF stations were not able to secure the valuable affiliations.  
Instead, in markets in which LMAs and later duopolies were allowed, those 
affiliations went to stations managed under LMAs which later became part of 
duopolies owned by broadcasters many of whom already enjoyed economies of 
scale regarding program creation and acquisition.  Minority and female owned 
 56
UHF television stations that had difficulty acquiring attractive programming were 
not aided by the changes to the TVDR.  The enhanced market position that 
access to attractive programming could provide, was placed out of reach. 
 
Instead, some minority and female owned stations became duopoly acquisition 
targets, others sold out perhaps because of increasing competition from 
duopolies and their LMA predecessors.  None of the stations that were sold were 
acquired by minority or female owners. 
  
Since the 1980s the FCCs broadcast ownership policies may be fairly categorized 
as bipolar.  The FCC seems to alternate between the more inclusive policies and 
the more consolidation oriented policies.  The TV Duopoly policy is a product of 
the tension between these policies.  Minority, female and small broadcast 
ownership is valued because as studies have shown, it increases the likelihood of 
diverse voices being represented in the marketplace of ideas.  In addition, it is 
fundamental that all Americans regardless of race or gender should have equal 
access to economic opportunity.  Market consolidation ostensibly benefits 
viewers of free TV by facilitating more viable broadcast competitors.  It is ironic 
that this benefit seems to come at the expense of maintaining and enhancing 
other broadcasters in the market.   
 
The number of minority-owned television stations has dropped by more than 
27%.  Thirty-nine percent of minority owned stations in TV duopoly markets 
have been sold to non-minority owners.  Thirty-six percent of the female owned 
stations operating in duopoly markets have been sold to non-female, non-
minority owners.  Neither group has benefited from the rule change.  Neither 
group of owners owns duopolies.  Meanwhile, the recent actions of some of the 
broadcasters who have benefited from the rule change have prompted even 
deregulations congressional advocates to question the continued advisability of 
the policy. 
 57
While it is certain that the public interest is greater than the interests of 
underrepresented minorities, women and small businesses.  It is also greater 
than the interests of Wall Street and vertically integrated media firms.  Neither is 
an end unto itself although both are essential.  The publics interest is that all 
Americans regardless of race, gender or religion have access to affordable 
communications and diversity of viewpoints.  The facilitation of diverse, 
economically viable broadcast television service is the essential goal.  The current 
TV duopoly policy appears to have resulted in a class of large, economically 
robust group owners and a continually dwindling number of smaller, often 
weaker players remaining to be plucked.  In this regard the rule change has 
exacerbated the problem it was promulgated to solve.  It is anticipated that  
further relaxation will exacerbate this already problematic result. 
 58
Appendix A: TV Duopolies List (Alphabetical by Market) 
Year Market Owner Outlets 
1999 Albuquerque, NM Acme Communications KWBQ-TV, KASY-TV 
 Austin, TX LIN TV Corp. KNVA-TV, KXAN-TV 
2005 Baltimore, MD Sinclair Broadcasting WBFF-TV/WNUV-TV (LMA)* 
 Birmingham, AL Sinclair Broadcasting WTTO-TV, WABM-TV 
2006 Boston, MA Hearst-Argyle Television WCVB-TV Ch. 5, WMUR-TV Ch. 9 
 Boston, MA Paxson/ION Media Networks WBPX-TV, WPXG-TV, WDPX-TV 
2006 Boston, MA Sunbeam Television Corp. WLVI-TV Ch. 56, WHDH-TV Ch. 7 
 Boston, MA Univision/Telefutura WUNI-TV, WUTF-TV 
2006 Boston, MA Viacom/CBS WBZ-TV Ch. 4, WSBK-TV Ch. 38 
 Buffalo, NY LIN TV Corp. WIVB-TV, WNLO 
2000 Buffalo, NY Sinclair Broadcasting WNYO-TV, WUTV-TV 
 Charlotte, NC Capitol Broadcasting Co. WJZY-TV, WMYT-TV 
 Charlotte, NC Cox Enterprises WSOC-TV, WAXN 
 Chicago, IL NBC Universal  WMAQ-TV, WSNS-TV 
2004 Chicago, IL News Corp. WFLD-TV, WPWR-TV 
 Chicago, IL Univision WGBO-TV, WXFT-TV 
 Cleveland, OH Raycom Media WOIO, WUAB 
 Dallas, TX News Corp. KDFW-TV, KDFI-TV  
 Dallas/Fort Worth, TX NBC Universal  KXAS-TV, KXTX-TV 
 Dallas/Fort Worth, TX Univision KUVN-TV, KSTR-TV 
 Dallas/Fort Worth, TX Viacom/CBS KTVT, KTXA 
2005 Denver Gannett Co., Inc. KUSA,KTVD 
 Detroit, MI Viacom/CBS WWJ, WKBD 
 El Paso, TX Entravision KINT-TV, KTFN-TV 
2003 Fresno, CA Pappas Telecasting Companies KFRE-TV, KMPH-TV 
 Grand Rapids, MI LIN TV Corp. WOOD-TV, WOTV-TV 
 Greenville, NC Media General WNCT, WYCW 
 Greenville, NC Paxson/ION Media Networks WEPX, WPXU-TV 
 Hartford, CT LIN TV Corp. WCTX-TV, WTNH-TV
2001 Hartford, CT Tribune Broadcasting WTIC-TV, WTXX 
2000 Honolulu, HI Emmis Comm. KHON, KGMB  
2004 Houston, TX News Corp. KRIV, KTXH 
 Houston, TX Univision KXLN-TV, KFTH-TV 
 Indianapolis, IN LIN TV Corp. WIIH-CA, WISH-TV, WNDY-TV  
2005 Indianapolis, IN Tribune Broadcasting WXIN, WTTV 
1999 Jacksonville, FL Clear Channel Communications WAWS-TV, WTEV-TV 
1999 Jacksonville, FL Gannett Co., Inc. WTLV TV-12, WJXX TV-25 
2005 Kansas City Hearst-Argyle Television KMBC, KCWE**** 
2001 Kansas City, KS Scripps Howard Broadcasting KSHB-TV, KMCI 
2005 Kansas City, MO Meredith Corporation KCTV-TV, KSMO-TV 
2001 Las Vegas, NV Sinclair Broadcasting KVMY, KVCW 
 59
 
Year Market Owner Outlets 
2006 Little Rock, AR Nexstar Broadcasting Group KNWA, KFTA 
 Little Rock, AR Clear Channel KLRT, KASN 
 Little Rock, AR Equity Broadcasting KLRA, KWBF 
 Little Rock, AR Victory Television Network KVTN, KVTH 
2002 Los Angeles, CA NBC Universal  KNBC-TV, KVEA-TV* 
2002 Los Angeles, CA News Corp. KCOP-TV, KTTV-TV 
 Los Angeles, CA Univision KMEX-TV, KFTR-TV 
2002 Los Angeles, CA Viacom / CBS KCAL-TV, KCBS-TV 
 Louisville, KY Block Communications WDRB, WMYO 
 Memphis, TN Clear Channel WPTY-TV, WLMT 
 Miami, FL NBC Universal  WTVJ, WSCV 
 Miami, FL Univision WLTV-TV, WAMI-TV 
2004 Miami, FL Viacom / CBS WFOR, WBFS 
 Milwaukee, WI Sinclair Broadcasting WCGV, WVTV 
 Minneapolis/St Paul, MN Hubbard Broadcasting KSTP-TV, KSTC 
 Minneapolis-St. Paul, MN News Corp. KMSP-TV, WFTC 
 Mobile,AL/Pensacola,FL Clear Channel WPMI-TV, WJTC 
 Mobile,AL/Pensacola,FL Emmis Comm. WALA-TV, WBPG-TV 
 Mobile,AL/Pensacola,FL LIN TV Corp. WALA-TV, WBPG-TV 
 Nashville, TN Sinclair Broadcasting WZTV, WUXP 
2005 New Oleans, LA Belo Corp. WUPL-TV, WWL-TV 
1999 New Orleans, LA Tribune Broadcasting WGNO-TV, WNOL-TV 
2003 New York, NY NBC Universal  WNBC-TV, WNJU 
2002 New York, NY News Corp. WNYW-Ch. 5, WWOR-Ch. 9.  
 New York, NY Univision WXTV-TV, WFUT-TV 
 Norfolk, VA LIN TV Corp. WAVY-TV, WVBT-TV 
 Oklahoma City, OK Sinclair Broadcasting KOCB, KOKH 
 Orlando, FL Cox Enterprises WFTV, WRDQ 
2006 Orlando, FL Hearst-Argyle Television WKCF-TV, WESH-TV 
 Orlando, FL News Corp. WOFL, WRBW 
 Orlando, FL Univision WVEN-TV, WOTF-TV 
 Philadelphia, PA Viacom/CBS WPSG, KYW 
 Phoenix, AZ Belo Corp. KTVK, KASW 
 Phoenix, AZ News Corp. KSAZ-TV, KUTP 
 Phoenix, AZ Univision KTVW-TV, KFPH-TV 
 Pittsburgh, PA Sinclair Broadcasting WPGH, WPMY 
 Pittsburgh, PA Viacom/CBS KDKA, WPCW 
2006 Portland, OR Fisher Communications KATU-TV, KUNP-TV 
2003 Portland, OR Meredith Corporation KPTV-TV, KPDX-TV 
2003 Providence, RI LIN TV Corp. WPRI, WNAC 
 Puerto Rico DR LIN TV Corp. WAPA-TV, WJPX-TV 
 Puerto Rico DR Univision/Telefutura WLII, WSUR-TV 
 Raleigh/Durham, NC Capitol Broadcasting Co. WRAL-TV, WRAZ-TV 
 Raleigh/Durham, NC Paxson/ION Media Networks WRPX, WFPX 
 Raleigh/Durham, NC Sinclair Broadcasting WLFL, WRDC 
 60
 
Year Market Owner Outlets 
 Sacramento, CA Hearst-Argyle Television KCRA-TV, KQCA 
2006 Sacramento, CA Viacom/CBS KOVR-TV, KMAX-TV 
2005 Salt Lake City, UT Clear Channel Communications KTVX-Ch. 4, KUWB-Ch. 30 
 Salt Lake City, UT Clear Channel Communications KTVX, KUCW 
 Salt Lake City, UT Equity KUTH, KUTF 
 San Antonio, TX Sinclair Broadcasting KABB, KMYS 
2006 San Francisco, CA Cox Enterprises KTVU, KICU  
1999 San Francisco, CA Granite Broadcasting KNTV-TV, KBWB-TV 
 San Francisco, CA NBC Universal  KNTV-TV, KSTS-TV 
 San Francisco, CA Univision KDTV-TV, KFSF-TV 
2006 San Francisco, CA Viacom/CBS KPIX-TV, KBHK-TV 
2006 Seattle, WA Fisher Communications KWOG-TV, KOMO-TV 
 Seattle/Tacoma, WA Belo Corp. KONG, KING-TV 
 Seattle/Tacoma, WA Tribune KCPQ, KMYQ 
 Spokane, WA Belo Corp. KREM, KSKN 
 Syracuse, NY Barrington WSTM, WSTQ 
 Tallahassee, FL Pegasus Communications WFXU, WTLH 
 Tampa, FL Univision WFTT-TV, WVEA-TV 
 Tucson, AZ Belo Corp. KMSB-TV, KTTU 
 Tucson, AZ Univision KUVE-TV, KFTU-TV 
 Tulsa, OK Clear Channel KOKI, KMYT-TV 
2006 Tyler, TX Raycom Media KLTV, KTRE 
 Washington, DC News Corp. WTTG-Ch. 5, WDCA-Ch. 20 
2003 Shreveport, LA On hold due to Prometheus ruling KTBS & KPXJ 
 
 
 61
Appendix B: Top 25 Station Groups with TV Duopolies and 
LMAs
88
 
#1 Viacom VIA (9 Duopolies) 
Station Market (affiliate; ch.) DMA Total FCC 
Coverage %    
KCBS Los Angeles (CBS; 2) 2 5.010 5.010 
KCAL Los Angeles (Ind.; 9) 2   
KYW Philadelphia (CBS; 3) 4 2.693 2.693 
WPSG Philadelphia (UPN; 57) 4   
WBZ Boston (CBS; 4) 5 2.207 2.207 
WSBK Boston (UPN; 38) 5   
KPIX San Francisco-Oakland (CBS; 5) 6 2.177 2.177 
 San Francisco-Oakland (UPN; 44) 6   
KTVT Dallas-Ft. Worth (CBS; 11) 7 2.115 2.115 
KTXA Dallas-Ft. Worth (UPN; 21) 7   
WKBD Detroit (UPN; 50) 10 1.793 0.897 
WWJ Detroit (CBS; 62) 10   
WFOR Miami-Ft. Lauderdale (CBS; 4) 17 1.381 1.381 
WBFS Miami-Ft. Lauderdale (UPN; 33) 17   
KOVR Sacramento-Stockton (CBS; 13) 19 1.213 1.213 
KMAX Sacramento-Stockton. (UPN; 31) 19   
KDKA Pittsburgh (CBS; 2) 22 1.094 1.094 
WNPA Pittsburgh (UPN; 19) 22   
 
 
 
 
 
 
 
                                        
88
 This document is derived from: George Winslow, How They Rank and Why: Top 25 
Station Groups, Broadcasting and Cable, April 18, 2005, Pg. 38.  The Top 25 Station 
Groups are ranked according to the percentage of the 109.6 million U.S. TV homes 
they reach, as measured by Nielsen Media Research. Stations reach is calculated to 
correspond with FCC ownership rules (listed as coverage FCC in the tables below). 
The FCC method discounts by half the reach of UHF stations, those channel 14 and 
above. The ranking also shows reach without the discount (coverage total). If a 
group owns other stations in a market, those stations coverage is not counted in the 
groups total. This year, BIA Financial Network, which collects the list of stations and 
computes coverage, excluded stations run under joint marketing and programming 
agreements. It also omitted stations operated under time-brokerage deals. As 
always, low-power stations, satellite stations, translators and stations that have only 
cable distribution were excluded. Sources: B&C, BIA Financial Network, Nielsen 
Media Research.  Id 
 62
#2 Fox TV Stations NWS (9 Duopolies) 
 
 
Station Market (affiliate; ch.) DMA Total FCC 
Coverage %   
WNYW New York (Fox; 5) 1 6.786 6.786 
WWOR New York (UPN; 9) 1   
KTTV Los Angeles (Fox; 11) 2 5.010 5.010 
KCOP Los Angeles (UPN; 13) 2   
WFLD Chicago (Fox; 32) 3 3.152 1.576 
WPWR Chicago (UPN; 50) 3   
KDFW Dallas-Ft. Worth (Fox; 4) 7 2.115 2.115 
KDFI Dallas-Ft. Worth (Ind.; 27) 7   
WTTG Washington (Fox; 5) 8 2.068 2.068 
WDCA Washington (UPN; 20) 8   
KTXH Houston (UPN; 20) 11 1.756 0.878 
KRIV Houston (Fox; 26) 11   
KMSP Minneapolis-St. Paul (Fox; 9) 14 1.537 1.537 
WFTC Minneapolis-St. Paul (UPN; 29) 14   
KSAZ Phoenix (Fox; 10) 15 1.473 1.473 
KUTP Phoenix (UPN; 45) 15   
WOFL Orlando-Daytona Beach, Fla. (Fox; 35) 20 1.202 0.601 
WRBW Orlando-Daytona Beach, Fla. (UPN; 65) 20   
 
 
#3 NBC Universal GE (6 duopolies) 
 
Station Market (affiliate; ch.) DMA Total FCC 
Coverage %    
WNBC New York (NBC; 4) 1 6.786 6.786 
WNJU New York (Tel.; 47) 1   
KNBC Los Angeles (NBC; 4) 2 5.010 5.010 
KWHY Los Angeles (Tel.; 22) 2   
KVEA Los Angeles (Tel.; 52) 2   
WMAQ Chicago (NBC; 5) 3 3.152 3.152 
WSNS Chicago (Tel.; 44) 3   
KNTV San Francisco-Oakland (NBC; 11) 6 2.177 2.177 
KSTS San Francisco-Oakland (Tel.; 48) 6   
KXAS Dallas-Ft. Worth (NBC; 5) 7 2.115 2.115 
KXTX Dallas-Ft. Worth (Tel.; 39) 7   
WTVJ Miami-Ft. Lauderdale (NBC; 6) 17 1.381 1.381 
WSCV Miami-Ft. Lauderdale (Tel.; 51) 17   
 63
#5 Tribune TRB (4 Duopolies) 
 
Station Market (affiliate; ch.) DMA Total FCC 
Coverage %    
KCPQ Seattle-Tacoma (Fox; 13) 12 1.560 1.560 
KTWB Seattle-Tacoma (WB; 22) 12   
WTTV Indianapolis (WB; 4) 25 0.971 0.971 
WXIN Indianapolis (Fox; 59) 25   
WTXX Hartford-New Haven, Conn. (WB; 20) 27 0.939 0.470 
WTIC Hartford-New Haven, Conn. (Fox; 61) 27   
WGNO New Orleans (ABC; 26) 43 0.624 0.312 
WNOL New Orleans (WB; 38) 43   
 
 
 
#7 Univision UVN (11 Duopolies) 
 
Station Market (affiliate; ch.) DMA Total FCC 
Coverage %    
WXTV New York (Uni.; 41) 1 6.786 3.393 
WFUT New York (TLF; 68) 1   
KMEX Los Angeles (Uni.; 34) 2 5.010 2.505 
KFTR Los Angeles (TLF; 46) 2   
WXFT Chicago (TLF; 60) 3 3.152 1.576 
WGBO Chicago (Uni.; 66) 3   
KDTV San Francisco-Oakland (Uni.; 14) 6 2.177 1.089 
KFSF San Francisco-Oakland (TLF; 66) 6   
KUVN Dallas-Ft. Worth (Uni.; 23) 7 2.115 1.058 
KSTR Dallas-Ft. Worth (TLF; 49) 7   
KXLN Houston (Uni.; 45) 11 1.756 0.878 
KFTH Houston (TLF; 67) 11   
KFPH Phoenix (TLF; 13) 15 1.473 1.473 
KTVW Phoenix (Uni.; 33) 15   
WLTV Miami-Ft. Lauderdale (Uni.; 23) 17 1.381 0.690 
WAMI Miami-Ft. Lauderdale (TLF; 69) 17   
KUVS Sacramento-Stockton. (Uni.; 19) 19 1.213 0.607 
KTFK Sacramento-Stockton. (TLF; 64) 19   
KFTV Fresno-Visalia, Calif. (Uni.; 21) 58 0.487 0.244 
KTFF Fresno-Visalia, Calif. (TLF; 61) 58   
KFTU Tucson, Ariz. (TLF; 3) 72 0.385 0.385 
KUVE Tucson, Ariz. (Uni.; 46) 72   
 
 
 64
#8 Gannett GCI (1 Duopoly) 
 
Station Market (affiliate; ch.) DMA Total FCC 
Coverage %    
WTLV Jacksonville, Fla. (NBC; 12) 52 0.565 0.565 
WJXX Jacksonville, Fla. (ABC; 25) 52   
 
 
#10 Hearst-Argyle HTV (2 Duopolies, 1 LMA) 
 
Station Market (affiliate; ch.) DMA Total FCC 
Coverage %    
WCVB Boston (ABC; 5) 5 2.207 2.207 
WMUR Boston (ABC; 29) 5   
KCRA Sacramento-Stockton. (NBC; 3) 19 1.213 1.213 
KQCA Sacramento-Stockton. (WB; 58) 19   
KMBC Kansas City, Kan.-Mo. (ABC; 9) 31 0.826 0.826 
KCWE* Kansas City (UPN; 29) 31   
 
 
#11 E.W. Scripps SSP (2 Duopolies) 
 
Station Market (affiliate; ch.) DMA Total FCC 
Coverage %    
WEWS Cleveland (ABC; 5) 16 1.436 1.436 
WOAC Cleveland (Ind.; 67) 16   
KMCI Kansas City, Kan.-Mo. (Ind.; 38) 31 0.826 0.413 
KSHB Kansas City, Kan.-Mo. (NBC; 41) 31   
 
 
#12 Belo Corp. BL (4 Duopolies, 1 LMA) 
 
Station Market (affiliate; ch.) DMA Total FCC 
Coverage %    
KING Seattle-Tacoma (NBC; 5) 12 1.560 1.560 
KONG Seattle-Tacoma (Ind.; 16) 12   
KTVK Phoenix (Ind.; 3) 15 1.473 1.473 
KASW Phoenix (WB; 61) 15   
KENS San Antonio (CBS; 5) 37 0.691 0.691 
KBEJ* San Antonio (UPN; 2) 37   
KMSB Tucson, Ariz. (Fox; 11) 72 0.385 0.385 
KTTU Tucson, Ariz. (UPN; 18) 72   
KREM Spokane, Wash. (CBS; 2) 80 0.354 0.354 
KSKN Spokane, Wash. (WB; 22) 80   
 65
#13 Sinclair SBGI (11 Duopolies, 9 LMAs) 
Station Market (affiliate; ch.) DMA Total FCC 
Coverage %   
WCWB Pittsburgh (WB; 22) 22 1.094 0.547 
WPGH Pittsburgh (Fox; 53) 22   
WBFF Baltimore (Fox; 45) 23 1.004 0.502 
WNUV* Baltimore (WB; 54) 23   
WLFL Raleigh-Durham, N.C. (WB; 22) 29 0.892 0.446 
WRDC Raleigh-Durham, N.C. (UPN; 28) 29   
WZTV Nashville, Tenn. (Fox; 17) 30 0.845 0.423 
WUXP Nashville, Tenn. (UPN; 30) 30   
WNAB* Nashville (WB: 58) 30   
WVTV Milwaukee (WB; 18) 32 0.818 0.409 
WCGV Milwaukee (UPN; 24) 32   
WSYX Columbus, Ohio (ABC; 6) 34 0.800 0.800 
WTTE* Columbus, Ohio ((Fox; 28) 34   
WLOS Greenville, S.C.-Ashville, N.C. (ABC; 13) 35 0.750 0.750 
WBSC* Greenville, S.C.-Asheville, N.C. (WB; 40) 35   
KABB San Antonio (Fox; 29) 37 0.691 0.345 
KRRT San Antonio (WB; 35) 37   
WTTO Birmingham, Ala. (WB; 21) 40 0.661 0.331 
WABM Birmingham, Ala. (UPN; 68) 40   
KOKH Oklahoma City (Fox; 25) 45 0.604 0.302 
KOCB Oklahoma City (WB; 34) 45   
WUTV Buffalo, N.Y. (Fox; 29) 46 0.601 0.301 
WNYO Buffalo, N.Y. (WB; 49) 46   
WXLV Greensboro-High Point, N.C. (ABC; 45) 48 0.599 0.299 
WUPN Greensboro-High Point, N.C. (UPN; 48) 48   
KVWB Las Vegas (WB; 21) 51 0.566 0.283 
KFBT Las Vegas (Ind.; 33) 51   
WKEF Dayton, Ohio (ABC; 22) 56 0.496 0.248 
WRGT* Dayton ((Fox; 45) 56   
WCHS Charleston-Huntington, W.Va. (ABC; 8) 62 0.470 0.470 
WVAH* Charleston (Fox; 11) 62   
WEAR Mobile, AL-Pensacola, Fla. (ABC; 3) 63 0.454 0.454 
WFGX Mobile, AL-Pensacola, Fla. (Ind.; 35) 63   
WSYT Syracuse, N.Y. (Fox; 68) 77 0.364 0.182 
WNYS*  Syracuse, N.Y. (WB; 43) 77   
KBSI Paducah, Ky. (Fox; 23) 79 0.355 0.178 
WDKA* Paducah, Ky. (WB; 49) 79   
WMMP Charleston, S.C. (UPN; 36) 101 0.261 0.131 
WTAT* Charleston, S.C. (Fox; 24) 101   
 66
#14 Cox Private (3 Duopolies, 1 LMA) 
 
Station Market (affiliate; ch.) DMA Total FCC 
Coverage %   
KTVU San Francisco-Oakland (Fox; 2) 6 2.177 2.177 
KICU San Francisco-Oakland (Ind.; 36) 6   
WFTV Orlando-Daytona Beach, Fla. (ABC; 9) 20 1.202 1.202 
WRDQ Orlando-Daytona Beach, Fla. (Ind.; 27) 20   
WSOC Charlotte, N.C. (ABC; 9) 28 0.926 0.926 
WAXN Charlotte, N.C. (Ind.; 64) 28   
KRXI Reno, NV (Fox; 11) 114 0.228 0.228 
KAME* Reno, NV (UPN; 21) 114   
 
 
#15 Clear Channel CCU (5 Duopolies, 1 LMA) 
 
Station Market (affiliate; ch.) DMA Total FCC 
Coverage %    
WHP Harrisburg-Lancaster, Pa. (CBS; 21) 42 0.649 0.324 
WLYH* Harrisburg, Pa. (UPN; 15) 42   
WPTY Memphis, Tenn. (ABC; 24) 44 0.607 0.304 
WLMT Memphis, Tenn. (UPN,WB; 30) 44   
WAWS Jacksonville, Fla. (Fox; 30) 52 0.565 0.283 
WTEV Jacksonville, Fla. (CBS; 47) 52   
KLRT Little Rock-Pine Bluff, Ark. (Fox; 16) 57 0.491 0.245 
KASN Little Rock-Pine Bluff, Ark. (UPN; 38) 57   
KOKI Tulsa, Okla. (Fox; 23) 60 0.471 0.236 
KTFO Tulsa, Okla. (UPN; 41) 60   
WPMI Mobile, Al.-Pensacola, Fla. (NBC; 15) 63 0.454 0.227 
WJTC Mobile, Al.-Pensacola, Fla. (UPN; 44) 63   
 
 
 67
#16 Pappas Telecasting Private (1 Duopoly, 3 LMAs) 
 
Station Market (affiliate; ch.) DMA Total FCC 
Coverage %    
KMPH Fresno-Visalia, Calif. (Fox; 26) 58 0.487 0.244 
KFRE Fresno-Visalia, Calif. (WB; 59) 58   
KPTM Omaha, Neb. (Fox; 42) 76 0.365 0.183 
KXVO* Omaha, Neb. (WB; 15) 76   
KHGI Lincoln-Hastings, Neb. (ABC; 13) 103 0.254 0.254 
KSNB* Lincoln-Hastings, Neb. (Fox; 4) 103   
KTVG*  Lincoln-Hastings, Neb. (Fox; 17) 103 
 
 
#17 Raycom Private (2 Duopolies) 
 
Station Market (affiliate; ch.) DMA Total FCC 
Coverage %    
WOIO Cleveland (CBS; 19) 16 1.436 0.718 
WUAB Cleveland (UPN; 43) 16   
KFVE Honolulu (WB; 5) 71 0.385 0.385 
KHNL Honolulu (NBC; 13) 71   
 
 
#18 Meredith MDP (2 Duopolies) 
 
Station Market (affiliate; ch.) DMA Total FCC 
Coverage %    
KPTV Portland, Ore. (Fox; 12) 24 1.003 1.003 
KPDX Portland, Ore. (UPN; 49) 24   
KCTV Kansas City, Kan.-Mo. (CBS; 5) 31 0.826 0.826 
KSMO Kansas City, Kan.-Mo. (WB; 62) 31   
 
 
#20 Media General MEG-A (1 Triopoly) 
 
Station Market (affiliate; ch.) DMA Total FCC 
Coverage %   
WSPA Greenville, S.C.-Ashville, N.C. (CBS; 7) 35 0.750 0.750 
WNEG Greenville, S.C.-Ashville, N.C. (CBS; 32) 35   
WASV Greenville, S.C.-Ashville, N.C. (UPN; 62) 35   
 
 
 
 68
#21 Entravision EVC (1 Duopoly, 1 LMA) 
 
Station Market (affiliate; ch.) DMA Total FCC 
Coverage %    
KCEC Denver (Uni.; 50) 18 1.293 0.647 
KTFD* Denver ((TLF; 14) 18   
KINT El Paso, Texas (Uni.; 26) 100 0.266 0.133 
KTFN El Paso, Texas (TLF; 65) 100   
 
 
#22 Emmis EMMS (2 Duopolies) 
 
Station Market (affiliate; ch.) DMA Total FCC 
Coverage %    
WALA Mobile, AL-Pensacola, Fla. (Fox; 10) 63 0.454 0.454 
WBPG Mobile, AL-Pensacola, Fla. (WB; 55) 63   
KHON Honolulu (Fox; 2) 71 0.385 0.385 
KGMB Honolulu (CBS; 9) 71   
 
 
#23 LIN TV TVL (5 Duopolies, 1 Quintopoly, 2 LMAs) 
 
Station Market (affiliate; ch.) DMA Total FCC 
Coverage %   
WISH Indianapolis (CBS; 8) 25 0.971 0.971 
WNDY Indianapolis (UPN; 23) 25   
WTNH Hartford-New Haven, Conn. (ABC; 8) 27 0.939 0.939 
WCTX Hartford-New Haven, Conn. (UPN; 59) 27   
WOOD Grand Rapids, Mich. (NBC; 8) 38 0.676 0.676 
WOTV Grand Rapids, Mich. (ABC; 41) 38   
WAVY Norfolk-Portsmouth, Va. (NBC; 10) 41 0.653 0.653 
WVBT Norfolk-Portsmouth, Va. (Fox; 43) 41   
WIVB Buffalo, N.Y. (CBS; 4) 46 0.601 0.601 
WNLO Buffalo, N.Y. (UPN; 23) 46   
WPRI Providence, R.I. (CBS; 12) 49 0.595 0.595 
WNAC* Providence, R.I. (Fox; 64) 49   
KXAN Austin, Texas (NBC; 36) 54 0.524 0.262 
KNVA* Austin, Texas (WB; 54) 54   
WAPA San Juan, P.R. (Ind.; 4) 999   
WTIN San Juan, P.R. (Ind.; 14) 999   
WNJX San Juan, P.R. (Ind.; 22) 999   
WJPX San Juan, P.R. (Pax; 24) 999   
WIRS San Juan, P.R. (REL; 42) 999   
 69
#25 Gray Television GTN (3 Duopolies, 1 Triopoly) 
 
Station Market (affiliate; ch.) DMA Total FCC 
Coverage %   
WVLT Knoxville, Tenn. (CBS; 8) 59 0.474 0.474 
WVLT-DT Knoxville, Tenn. (UPN; 30) 59   
WKYT-DT Lexington, Ky. (UPN; 13) 64 0.444 0.444 
WKYT Lexington, Ky. (CBS; 27) 64   
WYMT Lexington, Ky. (CBS; 57) 64   
KBTX Waco-Temple-Bryan, Texas (CBS; 3) 95 0.285 0.285 
KWTX Waco-Temple-Bryan, Texas (CBS; 10) 95   
WRDW Augusta, Ga. (CBS; 12) 115 0.228 0.228 
WRDW-DT Augusta, Ga. (UPN; 31) 115   
 
*Operated under LMA