*Pages 1--12 from Microsoft Word - 33824* Federal Communications Commission DA 03- 3698 Before the Federal Communications Commission Washington, D. C. 20554 In the Matter of Applications of WINSTAR WIRELESS FIBER CORP. For Renewal of Licenses to Provide Microwave Service In the 38.6 – 40. 0 GHz Band ) ) ) ) ) ) ) ) ) ) ) File Nos. 0000347849, 0000351950, 0000346785, 0000346747, 0000347755, 0000346756, 0000347639, 0000348427, 0000345891, 0000348363, 0000351124, 0000346761, 0000346180, 0000346779, 0000352808, 0000347947, 0000348584, 0000346758, 0000346769, 0000347479, 0000351147, 0000346748, 0000346782, 0000348460, 0000346766 MEMORANDUM OPINION AND ORDER Adopted: November 18, 2003 Released: November 28, 2003 By the Chief, Public Safety and Private Wireless Division, Wireless Telecommunications Bureau: I. INTRODUCTION 1. We have before us twenty- five renewal applications filed by Winstar Wireless Fiber Corp. (Winstar) for point- to- point microwave service and private operational fixed (POF) microwave service in the 38.6 – 40.0 GHz Band (39 GHz band). For the reasons discussed below, we grant Winstar’s above- captioned applications for renewal of the 39 GHz band licenses set forth in the attached Appendix. II. BACKGROUND A. Microwave Licensing Framework 2. Prior to August of 1996, point- to- point microwave services were licensed under Part 21 while POF services were licensed under Part 94 of the Commission’s Rules. Under Part 21, the Commission issued licenses for a period up to ten years. 1 Licensees who received authorizations under Part 21 received eighteen months to construct their facilities. 2 In contrast, under Part 94, generally, the Commission issued licenses for a term of five years from the date of original issuance, modification, or 1 See 47 C. F. R. § 21.45 (1995) (point- to- point microwave radio station licenses issued for a period not to exceed 10 years. Unless otherwise specified by the Commission, the expiration of regular point- to- point microwave licenses was on February 1 in the year of expiration. 2 See Reorganization and Revision of Parts 1, 2, 21, and 94 of the Rules to Establish a New Part 101 Governing Terrestrial Microwave Fixed Radio Services, WT Docket No. 94- 148, Report and Order, 11 FCC Rcd 13449, 13463- 4 ¶ 31 (Part 101 R& O). 1 Federal Communications Commission DA 03- 3698 2 renewal. 3 Licensees who received authorizations under Part 94 received twelve months to construct their facilities. 4 3. Effective August 1, 1996, the Commission consolidated the microwave licensing rules under Part 101 of the Commission’s Rules. As a result of this consolidation, the Commission adopted a ten- year license term for all Part 101 licensees, including those for POF services, issued on or after August 1, 1996. 5 POF licenses issued before August 1, 1996 were subject to a fixed expiration date of February 1, 2001. 6 In addition, the Commission adopted an eighteen- month construction period for all Part 101 licenses. 7 As a result, Part 101 licensees, including those licensees with a February 1, 2001 license expiration date, were required to construct and place in operation each station authorized under Part 101 within eighteen months of the initial dates of their respective license grants. 8 4. In 1997, the Commission adopted a renewal expectancy and modified the performance requirements for 39 GHz band microwave licensees. 9 Specifically, the Commission required 39 GHz band licensees to demonstrate “substantial service” in their license areas in connection with applications for license renewal. 10 Although the Commission declined to exempt the incumbent 39 GHz band licensees from the "substantial service" renewal standard, 11 the Commission sought to provide 39 GHz band licensees with a significant degree of flexibility in meeting their performance requirement. 12 The Commission was concerned that an inflexible performance requirement might impair innovation and unnecessarily limit the types of service offerings 39 GHz band licensees can provide. 13 Thus, the Commission determined that permitting licensees to demonstrate that they are meeting the goals of a performance requirement with a showing tailored to their particular type of operation avoids this pitfall. 14 5. The Commission also noted that licensees must receive a reasonable amount of time to establish a viable operation, develop market plans, secure necessary financing, develop and incorporate new technology in their systems, accommodate equipment manufacturers’ production schedules and build a customer base to meet a performance requirement. 15 Although the Commission rejected several proposals as restrictive, burdensome and unnecessarily limiting licensees’ service options, 16 the 3 See 47 C. F. R. § 94.39( a) (1995) (The Commission could issue a license with a shorter term of one to five years could be applied to permit the orderly scheduling of renewal applications). 4 Part 101 R& O, 11 FCC Rcd at 13463- 4 ¶ 31. 5 See Amendment of the Commission’s Rules Regarding the 37. 0- 38. 6 GHz and 38. 6- 40.0 GHz Bands, Report and Order and Second Notice of Proposed Rulemaking, 12 FCC Rcd 18600, 18620- 18621 ¶ 36 (1997) (39 GHz R& O). 6 Id. 7 Part 101 R& O, 11 FCC Rcd at 13464 ¶ 33. 8 See 47 C. F. R. § 101.63( a) (1996); See also 39 GHz R& O, 12 FCC Rcd at 18622 ¶ 39. 9 See 39 GHz R& O, 12 FCC Rcd at 18626 ¶ 49. 10 See 47 C. F. R. § 101.17. 11 See 39 GHz R& O, 12 FCC Rcd at 18624 ¶ 46. 12 Id. at ¶ 42. 13 Id. 14 Id. 15 Id. at 18625 ¶ 47– 48. 16 Id. at 18623- 24 ¶ 43– 45. 2 Federal Communications Commission DA 03- 3698 3 Commission provided a “safe harbor” example of a substantial service showing as “four links per million population within a service area.” 17 B. 39 GHz Band Renewal Applications 6. The authorizations of POF 39 GHz band licensees issued before August 1, 1996 expired on February 1, 2001. 18 On August 15, 2001, the Division granted 321 renewal applications filed by such licensees. 19 In granting those applications, the Division concluded that the stations in question provided substantial service because the licensee operated at least one link for each 250,000 people located within its service area. 20 7. On March 7, 2002, the Division granted another 102 renewal applications for 39 GHz band licenses. 21 In the Renewal Grant Order, the Division noted that, although the substantial service standard was based on a ten- year license term, licensees actually had less than one- third of a full ten- year license term to satisfy the substantial service requirement. 22 We evaluated the substantial service submissions in light of the reduced amount of time that these licensees received to comply with the substantial service requirement. Our review of the applications focused on whether the licensees were developing the spectrum they had been assigned and using the spectrum to provide service to the public. 23 The applications granted resulted in two categories: (1) licensees operating at fifty percent or better of the Commission “safe harbor,” and (2) licensees demonstrating significant construction. With respect to licenses in the first category, we found that licensees established viable operations, developed market plans, secured needed financing, accommodated equipment manufacturers’ production schedules and built a customer base in each market providing service at a level of about one link per 500,000 population. 24 With respect to licensees in the second category, we indicated that those who constructed at least ten links within their service area during the course of the shortened period showed that they were making substantial use of the spectrum, as opposed to warehousing the spectrum. Moreover, we believed 17 Id. at 18624 ¶ 46. We note that, although the Commission did not use the exact words “safe harbor” in the 39 GHz band context, we believe the Commission intended for this example to serve as an example of a “safe harbor.” This determination is consistent with similar examples the Commission has provided to licensees in other services. Amendments to Parts 1, 2, 87, and 101 of the Commission’s Rules to License Fixed Services at 24 GHz, WT Docket No. 99- 327, Report and Order, 15 FCC Rcd 16,934, 16951- 2 ¶ 38 (2000); Amendment of Part 95 of the Commission’s Rules to Provide Regulatory Flexibility in the 218- 219 MHz Service, WT Docket No. 98- 169, Report and Order and Memorandum Opinion and Order, 15 FCC Rcd 1497, 1537- 38 ¶ 70; Amendment of the Commission’s Rules Concerning Maritime Communications, PR Docket No. 92- 257, Third Report and Order and Memorandum Opinion and Order, 13 FCC Rcd 19,853, 19870 ¶ 34 (1998); Amend Parts 1, 2, 21, and 25 of the Commission’s Rules to Redesignate the 27. 5- 29. 5 GHz Frequency Band, to Reallocate the 29. 5 – 30. 0 GHz Frequency Band, to Establish Rules and Policies for Local Multipoint Distribution Service and for Fixed Satellite Services, CC Docket No. 92- 297, Second Report and Order, Order on Reconsideration, and Fifth Notice of Proposed Rulemaking, 12 FCC Rcd 12, 545, 12660- 1 ¶ 270 (1997); Amendment of the Commission’s Rules to Establish Part 27, the Wireless Communications Service, GN Docket No. 96- 228, Report and Order, 12 FCC Rcd 10, 785, 10843- 4 ¶ 113 (1997). 18 See note 8 supra. 19 See Wireless Telecommunications Service Grants 321 Renewals in the CF Radio Service, Public Notice, 16 FCC Rcd 15358 (WTB 2001) (Renewal Grant Public Notice). 20 Id. 21 Renewal of Licenses to Provide Microwave Service In the 38. 6 – 40. 0 GHz Band, 17 FCC Rcd 4404 (WTB PSPWD 2002) (Renewal Grant Order). 22 Id. at 17 FCC Rcd 4406 ¶ 8. 23 See 39 GHz R& O, 12 FCC Rcd at 18622 ¶ 39. 24 Renewal Grant Order, 17 FCC Rcd at 4407 ¶ 10. 3 Federal Communications Commission DA 03- 3698 4 that, given the truncated license period to which they were subject, licensees operating ten or more links in their service area showed the provision of substantial service. 25 C. Winstar’s Applications for Renewal 8. Winstar filed the twenty- five applications listed in the Appendix over the course of four days in January 2001. Winstar appended a ten- page attachment with each renewal application. For the most part, each attachment is identical and consists of a description of the company and its broadband network. Included therein is a description of a company- wide financial overview, the company’s network (including Winstar’s end- to- end network architecture, switching and data centers, building access rights, customer traffic on the network, network and customer support, and Winstar International), Winstar’s services (voice, internet and data transport, web design and hosting, on- line business content and applications, application service provider, vertical solutions), advertising and sales information, and a description of its commitment to community service. With respect to each station for which it seeks renewal, each respective attachment provided estimated population and number of links in service as follows: Call Sign Market Approximate Population 26 Number of Links in Service WPJE537 Rockford, Illinois 629,000 one WMT603 Buffalo, New York 1,237,000 one WMT604 Phoenix, Arizona 2,682,000 one WMT672 Memphis, Tennessee 1,097,000 one WMT817 Richmond, Virginia 1,043,000 one WMT822 Norfolk, Virginia 1,714,000 one WMW290 Raleigh- Durham, North Carolina 1,199,000 two WPJC609 Jackson, Mississippi 507,000 one WPJC613 Battle Creek, Michigan 1,182,000 one WPJC615 Toledo, Ohio 839,000 one WPJC617 Columbia, South Carolina 775,000 one WPJC619 Poughkeepsie, New York 577,000 one WPJD394 Greensboro, North Carolina 1,150,000 two WPJC569 Norfolk, Virginia 1,714,000 one WPJC572 Las Vegas, Nevada 1,058,000 one WPJC577 Salt Lake City, Utah 1,430,000 two WPJC578 Tampa, Florida 1,650,000 one WPJD862 Poughkeepsie, New York 1,450,000 one WPJD865 Rockford, Illinois 629,000 one WPJE531 Poughkeepsie, New York 1,427,000 one WPJE539 Wichita, Kansas 614,000 one WMW520 Memphis, Tennessee 1,183,000 one WMW521 Omaha, Nebraska 742,000 one WMW861 New Orleans, Louisiana 1,518,000 one WMW862 Richmond, Virginia 1,191,000 two 25 Id. at ¶ 11. 26 Differences in the approximate population numbers of the Poughkeepsie, New York market are due to differences in license coverage area. 4 Federal Communications Commission DA 03- 3698 6 Table 1 Call Sign Market Branch( Division) Incorporated Into Number of Employees (Location) WPJE537 Rockford, Illinois Chicago (North) 190 (Illinois) WMT603 Buffalo, New York New York Metro (North) 650 (New York) WMT604 Phoenix, Arizona Phoenix (West) 75 (Phoenix) WMT672 Memphis, Tennessee Atlanta (South) 5 (Tennessee) WMT817 Richmond, Virginia Washington- Baltimore (South) 2,000 (Virginia) WMT822 Norfolk, Virginia Washington- Baltimore (South) 2,000 (Virginia) WMW290 Raleigh- Durham, North Carolina Atlanta (South) Not Provided WPJC609 Jackson, Mississippi Houston (South) Not Provided WPJC613 Battle Creek, Michigan Detroit (North) 70 (Michigan) WPJC615 Toledo, Ohio Detroit (North) 260 (Ohio) WPJC617 Columbia, South Carolina Atlanta (South) Not Provided WPJC619 Poughkeepsie, New York New York Metro (North) 650 (New York) WPJD394 Greensboro, North Carolina Atlanta (South) Not Provided WPJC569 Norfolk, Virginia Washington- Baltimore (South) 2,000 (Virginia) WPJC572 Las Vegas, Nevada Los Angeles- Orange County (West) Not Provided WPJC577 Salt Lake City, Utah Phoenix (West) 4 (Salt Lake City) WPJC578 Tampa, Florida Miami- Tampa- St. Petersburg (South) 45 (Florida) WPJD862 Poughkeepsie, New York New York Metro (North) 650 (New York) WPJD865 Rockford, Illinois Chicago (North) 190 (Illinois) WPJE531 Poughkeepsie, New York New York Metro (North) 650 (New York) WPJE539 Wichita, Kansas St. Louis- Kansas City (South) Not Provided WMW520 Memphis, Tennessee Atlanta (South) 5 (Tennessee) WMW521 Omaha, Nebraska St. Louis- Kansas City (South) Not Provided WMW861 New Orleans, Louisiana Houston (South) Not Provided WMW862 Richmond, Virginia Washington- Baltimore (South) 2,000 (Virginia) 10. On May 13, 2002, the Division’s Policy and Rules Branch, pursuant to Section 308( b) of the Communications Act of 1934, as amended, 27 directed Winstar to provide further information regarding twenty- four pending applications for renewal of stations in the Common Carrier Microwave Radio Service in order to determine if Winstar has provided substantial service for its stations. 28 Specifically, the Division directed Winstar to: 1) describe the competition existing in the market served by the stations for services that Winstar, through these stations, offers to customers in those markets; 27 See 47 U. S. C. § 308( b). 28 See Letter to Joseph M. Sandri, Jr. from John J. Schauble, Chief, Policy and Rules Branch, Public Safety and Private Wireless Division (PSPWD) (May 13, 2002) (Section 308( b) Letter). In requesting the information, the request was made for twenty- four stations listed in the Appendix, and one of the stations listed in the Appendix inadvertently was omitted from the letter. 6 Federal Communications Commission DA 03- 3698 7 2) state whether Winstar constructed any facilities for the stations during the license term that later were dismantled; and if so, the location of the facilities, the date the facilities were constructed and the date they were dismantled, and reason( s) the facilities were dismantled; 3) describe efforts Winstar has made to obtain customers in the market serviced by the stations during the license term; and 4) provide any other information specific to the market served by the stations which Winstar believed showed that Winstar provided substantial service during the last license term. 29 D. Winstar’s Response to the 308( b) Letter 11. On June 12, 2002, Winstar responded to the request for information. 30 In responding, Winstar provided information concerning the twenty- five pending license renewal applications listed in the Division’s letter and provided the requested information for another station’s pending renewal application not listed in the Section 308( b) Letter. 31 Winstar expressed its belief that it had provided substantial service regarding the twenty- five stations at issue. 32 Winstar’s response consisted of system-wide information and some station- specific information. Below, we analyze Winstar’s specific responses to the four questions posed in the 308( b) Letter. 12. Existing competition in the market. Winstar stated that, in each of the twenty- five markets at issue, it competes with the incumbent local exchange carrier (“ ILEC”) and, in many of the markets, it also competes with competitive local exchange carriers (“ CLECs”) and private line carriers. 33 Winstar said ILECs know, at a minimum, the identity of carriers operating in different areas due to ILEC-CLEC interconnection arrangements; but where Winstar does not operate its own switches, it does not have similar arrangements with other CLECs and, thus, cannot provide the Commission with a thorough response to the requested information beyond noting that Winstar competes with at least the ILEC in each market. 34 Winstar stated it operates its own switches in Phoenix and Tampa, and, thus, listed its CLEC competitors in those markets. 35 It also said it could not determine precisely which CLECs and other competitive providers currently provide which services in other markets. 36 13. Construction of facilities during the license term that were later dismantled. Winstar provided the following information regarding six stations. 29 Section 308( b) Letter at 2. 30 See Letter to Roberto Mussenden, PSPWD, from Brian Finkelstein, Chief Executive Officer (June 12, 2002) (Winstar Response to 308( b) Letter). 31 Id. at 1. In short, Winstar indicates it is providing information for the twenty- five stations listed in the Appendix. 32 Id. 33 Id. at 2. 34 Id. 35 For the Phoenix market, Winstar lists Adelphia, AT& T, ELI, Qwest, Time Warner, and WorldCom; and for the Tampa market, it lists Adelphia, Allegiance, Teligent, US LEC, Verizon, and XO Communications. Id. 36 Winstar indicates general awareness of the fixed service operations of XO Communications, Teligent, First Street (assets formed partially from the restructured Advanced Radio Telecom), and a number of unlicensed operators (such as Air2Lan, etc.). Id. at 2- 3. Moreover, it says each State public utility commission maintains a list of certificated local exchange carriers in each state, each one theoretically being able to provide competition with Winstar. Further, Winstar sales teams, which have undergone substantial transformations as Winstar migrated into and out of Chapter 11, report CLEC competition existing in each of Winstar’s markets from companies such as WorldCom, AT& T, Time Warner Telecom and XO Communications. Id. at 3. 7 Federal Communications Commission DA 03- 3698 9 network. It contended that its investment in a national network combined with the facilities it has constructed in many of its licensed markets demonstrate substantial service warranting license renewal. 43 E. Winstar’s Response to Request for Supplemental Information 17. On November 3, 2003, Winstar responded to a Commission staff request for supplemental information concerning its 39 GHz band license renewal applications that remained pending. 44 First, Winstar corrected its June 2002 letter to indicate that all of its twenty- five 39 GHz band license areas up for renewal at this time, not just twenty of the twenty- five, consist of the residual parts of rectangular service areas that are not covered by Winstar’s overlapping EA authorizations. 45 The company provided a chart showing the population of those sliver- shaped residual areas and the number of links provided by Winstar throughout the rectangular service areas under which the slivers were originally licensed. That information is reproduced in pertinent part below: 43 Id. at 1- 2. 44 Letter from Joseph M. Sandri, Jr., Senior Vice President and Regulatory Counsel, Winstar Communications, LLC, to Robert Mussenden, Federal Communications Commission, Nov. 3, 2003 (November 2003 Letter). Commission staff requested the additional information at an October 8, 2003, meeting with Winstar representatives. 45 Id. at 1- 2. 9 Federal Communications Commission DA 03- 3698 10 Table 2 Call Sign 46 Market Approximate Population of Residual “Sliver” Links in Service Throughout Rectangular License Area WPJE537 Rockford, Illinois 3,000 one WPJD865 Rockford, Illinois 20,000 one WMT603 Buffalo, New York 25,000 one WMT604 Phoenix, Arizona 1,000 one WMW520 Memphis, Tennessee 45,000 one WMT672 Memphis, Tennessee 17,000 one WMW862 Richmond, Virginia 45,000 two WMT817 Richmond, Virginia 15,000 one WPJC569 Norfolk, Virginia 8,500 one WMT822 Norfolk, Virginia 8,500 one WMW290 Raleigh- Durham, North Carolina 40,000 two WPJC609 Jackson, Mississippi 11,000 one WPJC613 Battle Creek, Michigan 20,000 one WPJC615 Toledo, Ohio less than 47 110,000 one WPJC617 Columbia, South Carolina 43,000 one WPJC619 Poughkeepsie, New York 8,000 one WPJD862 Poughkeepsie, New York 3,500 one WPJE531 Poughkeepsie, New York 3,500 one WPJD394 Greensboro, North Carolina 16,000 two WPJC572 Las Vegas, Nevada 5,000 one WPJC577 Salt Lake City, Utah 100 two WPJC578 Tampa, Florida 5,000 one WPJE539 Wichita, Kansas 600 one WMW521 Omaha, Nebraska 60,000 one WMW861 New Orleans, Louisiana 30,000 one III. DISCUSSION 18. We note, as an initial matter, that regardless of our disposition of this subject application, with respect to each of the licenses in question, Winstar would still be able to operate within most of the existing service area because it holds an overlapping EA license for most of the area in question. Thus, the pertinent question is whether Winstar should be allowed to continue operating in those “slivers” that are outside the service areas of the EA licensees. In making that determination, we believe it is appropriate to evaluate Winstar’s level of service relative to the population within those residual slivers. As noted above, the Commission has stated that four 39 GHz links per million population within a service area – or one link per 250,000 population – would qualify for “safe harbor” treatment denoting substantial service sufficient for renewal expectancy. 48 All of the Winstar sliver areas in question have populations far less than a quarter million. Thus, to the extent that Winstar is operating at least one link under each 46 In the 39 GHz band, the Commission issued a separate license for one channel in a rectangular service area, and the service areas encompassing a given city were often of different sizes and only partially overlapping. 47 Winstar says that 110, 000 is the estimated Toledo RSA population. It says the sliver population is significantly less but that it has not been able to calculate it with precision. November 2003 Letter, Exhibit 1at 2. 48 See note 17 and accompanying text. 10 Federal Communications Commission DA 03- 3698 11 license, we believe it has adequately demonstrated that it is providing substantial service under each license. This conclusion is consistent with our decision to grant those applications meeting the Commission’s safe harbor and the Renewal Grant Order’s flexible approach to substantial service. 49 19. Further, so long as Winstar demonstrates that a link is being operated under the authority of the license in question – i. e., that the link is located within the rectangular service area authorized by the original license – it should not be required to demonstrate that the individual link is physically located within the sliver. The Commission envisioned a flexible substantial service standard that would be inclusive as opposed to exclusive. 50 We have previously noted that provision of 39 GHz band wireless local loop services “changes constantly to accommodate the unique and varying demands of customers” and that such links are often provided as a temporary solution to precede deployment of optical fiber. 51 Service providers often deploy such links in response to requests for service from specific customers, and later remove the wireless links once fiber is deployed. Thus, service providers use the 39 GHz band in a dynamic, customer- responsive fashion to meet service needs when they arise, and can quickly redeploy that equipment as customer needs evolve. IV. CONCLUSION AND ORDERING CLAUSES 20. For the reasons set forth above, we conclude that Winstar has demonstrated, as required by Section 101.17 of the Commission’s rules, 47 C. F. R. § 101.17, that it is providing substantial service in the markets that are the subject of the renewal applications listed in the Appendix. 21. Accordingly, IT IS ORDERED, that, pursuant to Sections 4( i) and 308( b) of the Communications Act of 1934, as amended, 47 U. S. C. §§ 154( i) 308( b), and Section 101.17 of the Commission's Rules, 47 C. F. R. § 101. 17, that the Licensing and Technical Analysis Branch, Public Safety and Private Wireless Division, Wireless Telecommunications Bureau SHALL PROCESS the applications for renewal in the common carrier microwave service contained in the Appendix to this Memorandum Opinion and Order. 22. This action is taken under delegated authority pursuant to Sections 0.131 and 0.331 of the Commission’s Rules, 47 C. F. R. §§ 0.131, 0.331. FEDERAL COMMUNICATIONS COMMISSION D’wana R. Terry Chief, Public Safety and Private Wireless Division Wireless Telecommunications Bureau 49 See Renewal Grant Public Notice; Renewal Grant Order, 17 FCC Rcd at 4406- 07 ¶¶ 8- 11. 50 See 39 GHz R& O, 12 FCC Rcd at 18623 ¶ 42. 51 Biztel, Inc., Memorandum Opinion and Order, 18 FCC Rcd 3308, 3310- 3311 ¶¶ 6 -7 (WTB PSPWD 2003). 11 Federal Communications Commission DA 03- 3698 12 APPENDIX File No. Call Sign Location 0000347849 WPJE537 Rockford, Illinois 0000351950 WMT603 Buffalo, New York 0000346785 WMT604 Phoenix, Arizona 0000346747 WMT672 Memphis, Tennessee 0000347755 WMT817 Richmond, Virginia 0000346756 WMT822 Norfolk, Virginia 0000347639 WMW290 Raleigh- Durham, North Carolina 0000348427 WPJC609 Jackson, Mississippi 0000345891 WPJC613 Battle Creek, Michigan 0000348363 WPJC615 Toledo, Ohio 0000351124 WPJC617 Columbia, South Carolina 0000346761 WPJC619 Poughkeepsie, New York 0000346180 WPJD394 Greensboro, North Carolina 0000346779 WPJC569 Norfolk, Virginia 0000352808 WPJC572 Las Vegas, Nevada 0000347947 WPJC577 Salt Lake City, Utah 0000348584 WPJC578 Tampa, Florida 0000346758 WPJD862 Poughkeepsie, New York 0000346769 WPJD865 Rockford, Illinois 0000347479 WPJE531 Poughkeepsie, New York 0000351147 WPJE539 Wichita, Kansas 0000346748 WMW520 Memphis, Tennessee 0000346782 WMW521 Omaha, Nebraska 0000348460 WMW861 New Orleans, Louisiana 0000346766 WMW862 Richmond, Virginia 12