Federal Communications Commission DA 10-106 
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Carriage Complaints Against 
Trust Cable of Mississippi Inc.,
James Cable LLC,
Southern Cable Services LLC,
KFW Communications, and
Envision Media, Inc.
By 
The Board of Trustees of the University of 
Alabama, Licensee of WUOA, Tuscaloosa, 
Alabama
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CSR-8205-M
CSR-8207-M
CSR-8209-M
CSR-8210-M
CSR-8249-M
MEMORANDUM OPINION AND ORDER
Adopted: January 20, 2010 Released:  January 20, 2010
By the Senior Deputy Chief, Policy Division, Media Bureau:
I. INTRODUCTION
1. Pending before us are five mandatory carriage complaints1 brought by the Board of Trustees 
of the University of Alabama (“Trustees”), licensee of local commercial television station WUOA-DT, 
Tuscaloosa, Alabama (“WUOA”) against Trust Cable of Mississippi Inc. (“Trust Cable”), James Cable 
LLC (“James Cable”), Southern Cable Services LLC (“SCS”), KFW Communications (“KFWC”), and 
Envision Media, Inc (“Envision”).2 WUOA is assigned to the Birmingham, Alabama Designated Market 
Area (“DMA”), and it is seeking carriage on cable systems located in the same market.  All five carriage 
complaints are unopposed, and we consolidate and grant these complaints for the reasons discussed 
below.
II. BACKGROUND AND DISCUSSION
2. Pursuant to Section 614 of the Communications Act of 1934, as amended (the “Act”), and 
implementing rules adopted by the Commission, commercial television broadcast stations such as 
WUOA, are entitled to assert mandatory carriage rights on cable systems located within their market.3 A 
  
1 These complaints are brought pursuant to Sections 76.7 and 76.61 of our rules.  47 C.F.R. §§ 76.7 and 76.61.
2 Petition for Special Relief of Trustees against Trust Cable (CSR-8205-M), filed Sept. 15, 2009 (“Trust 
Complaint”), James Cable (CSR-8207-M), filed Sept. 17, 2009 (“James Cable Complaint”), SCS (CSR-8209-M), 
filed Sept. 11, 2009 (“SCS Complaint”), KFWC (CSR-8210-M), filed Sept. 11, 2009 (“KFWC Complaint”), and 
Envision (CSR-8249-M), filed Nov. 30, 2009 (“Envision Complaint”).
3 See Implementation of the Cable Television Consumer Protection and Competition Act of 1992, Broadcast Signal 
Carriage Issues, MM Docket No. 92-259, Report and Order, 8 FCC Rcd 2965, 2975-77, ¶¶ 41-46 (1993) (“Must 
Carry Order”).  The Commission has subsequently extended mandatory carriage rights to digital television stations 
under Section 614(a) of the Act and has amended its rules accordingly.  See Carriage of Digital Television 
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Federal Communications Commission DA 10-106 
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station’s market for this purpose is its “Designated Market Area,” or DMA, as defined by Nielsen.4 The 
term DMA is a geographic market designation that defines each television market exclusive of others, 
based on measured viewing patterns.  Pursuant to the Commission’s must carry rules, cable operators 
have the burden of showing that a commercial television station that is located in the same DMA is not 
entitled to carriage.5
3. WUOA-DT is a local commercial television station licensed to Tuscaloosa, Alabama, which 
has been operating in the Birmingham, Alabama DMA since before the October 1, 2008 carriage election 
deadline – the deadline applicable to the 2009-2011 triennial carriage cycle.  WUOA did not elect 
retransmission consent for the current carriage cycle, and is consequently a must-carry station.6 After 
WUOA began broadcasting an over-the-air digital signal on June 12, 2009, it noted that it was not being 
carried on cable systems serving communities in the DMA that were operated by Trust Cable, James 
Cable, SCS, KFWC, and Envision, and accordingly, it mailed demands for carriage to each of these cable 
operators.7 WUOA asserts that the thirty-day period for each cable operator to respond or comply with 
each carriage request letter has expired.8 Therefore, WUOA argues that it filed its must carry complaints 
within the relevant sixty-day deadline and asks the Bureau to compel carriage of its local signal on these
cable systems.9  
4. The Bureau has received no response to WUOA’s mandatory carriage complaints and deems 
them unopposed.  Based on the facts presented, we find that WUOA is a local commercial10 television 
station that may exercise mandatory carriage rights for its broadcast signal on the cable systems at issue.11  
  
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Broadcast Signals First Report and Order, See 16 FCC Rcd 2598, 2606 ¶¶ 15-16, 2610 ¶28 (2001) (“DTV Must 
Carry Order”); see also 47 C.F.R. §76.64(f)(4).
4 Section 614(h)(1)(C) of the Communications Act, as amended by the Telecommunications Act of 1996, provides 
that a station’s market shall be determined by the Commission by regulation or order using, where available, 
commercial publications which delineate television markets based on viewing patterns.  See 47 U.S.C. 
§ 534(h)(1)(C).  Section 76.55(e)(2) of the Commission’s rules specifies that a commercial broadcast television 
station’s market is its Designated Market Area as determined by Nielsen Media Research.  47 C.F.R. § 76.55(e)(2).
5 See Must Carry Order, 8 FCC Rcd at 2990, ¶ 102.
6 See Trust Complaint at 3-4, James Cable Complaint at 3-4, SCS Complaint at 4, KFWC Complaint at 4,, and 
Envision Complaint at 3-4.
7 See Trust Complaint, Ex. 1, Carriage Request Letter dated June 12, 2009, from M. Scott Johnson, Counsel to 
Trustees to Trust Cable; James Cable Complaint, Ex. 1, Carriage Request Letters dated June 12 & 15, 2009, from M. 
Scott Johnson to James Cable; SCS Complaint, Ex. 1, Carriage Request Letters dated June 12 & June 15, 2009, from 
M. Scott Johnson to SCS; KFWC Complaint, Ex. 1, Carriage Request Letter dated June 12, 2009, from M. Scott 
Johnson to KFWC, at 2; Envision Complaint, Ex. 1, Carriage Request Letter dated Sep. 24, 2009, from Thomas J. 
Dougherty, Counsel to Trustees to Envision, at 1 (collectively, the “Carriage Request Letters”).  WUOA attaches 
return receipts to each of these Carriage Request Letters showing receipt by the cable operator.
8 See 47 C.F.R. § 76.61(a)(2).
9 See 47 C.F.R. §§ 76.61(a)(3)(ii), 76.61(a)(5)(i) & (ii). 
10 WUOA’s Complaints and Carriage Request Letters noted that it was a commercial station affiliated with the “This 
TV” network and that it featured the extensive TV and film libraries of the MGM and United Artists studios, 
syndicated programming, local news, and University of Alabama sports and cultural programming.  See Trust 
Complaint at 1, James Cable Complaint at 1, SCS Complaint at 1, KFWC Complaint at 1, and Envision Complaint
at 1; see also Carriage Request Letters at 2.
11 Each full-power commercial television station that elected mandatory carriage on October 1, 2008, actually or 
constructively, was entitled to receive must carry rights for its post-transition digital signal without any gap in 
carriage.  See Carriage of Digital Television Broadcast Signals: Amendment to Part 76 of the Commission’s Rules, 
(continued....)
Federal Communications Commission DA 10-106 
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Because WUOA has fulfilled all requirements for asserting its mandatory carriage rights, and because the 
cable operators have put forth no reason why WUOA should be denied carriage on their cable systems, 
we grant WUOA’s mandatory carriage complaints.
V. ORDERING CLAUSES
5. Accordingly, IT IS ORDERED, that the Mandatory Carriage Complaints (CSR-8205-M, 
CSR-8207-M, CSR-8209-M, CSR-8210-M, and CSR-8249-M) filed by The Board of Trustees of the 
University of Alabama, licensee of local commercial television station WUOA-DT, Tuscaloosa, Alabama 
ARE GRANTED; and,
6. IT IS FURTHER ORDERED THAT within 45 days of the date of this order, Trust 
Cable of Mississippi Inc., James Cable LLC, Southern Cable Services LLC, KFW Communications, and 
Envision Media MUST COMMENCE CARRIAGE OF WUOA-DT on each cable system they operate 
that serves communities within the Birmingham, Alabama DMA.
7. This action is taken under authority delegated by Section 0.283 of the Commission’s 
rules, 47 C.F.R § 0.283.
FEDERAL COMMUNICATIONS COMMISSION
Steven A. Broeckaert
Senior Deputy Chief, Policy Division
 Media Bureau
  
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Declaratory Order, 23 FCC Rcd. 14254, 14258 ¶ 13 (2008).  Furthermore, there is no time limit on the right to 
exercise must-carry rights and they may be invoked at any time in the triennial election cycle.  See Must Carry 
Order, 8 FCC Rcd. at 2994, ¶ 119 (“[W]henever a local commercial television station believes that a cable operator 
has failed to meet its must-carry obligations, the station must notify the operator, in writing, of the alleged failure.”); 
see also Implementation of the Cable Television Consumer Protection and Competition Act of 1992: Broadcast 
Signal Carriage Issues, Clarification Order, 8 FCC Rcd. 4144, ¶ 15 (1993) (“We reiterate our clarification that 
broadcast stations may assert their carriage and channel positioning rights at any time so long as they have not 
elected retransmission consent…. Therefore, a time limit on the exercise of must-carry rights is not only contrary to 
the 1992 Act and our rules, but is unrealistic.”)