Federal Communications Commission FCC 08-215
CONCURRING STATEMENT OF
COMMISSIONER JONATHAN S. ADELSTEIN
Re: Amendment of Section 73.202(b), Table of Allotments, FM Broadcast Stations, (Chillicothe and 
Ashville, Ohio), MM Docket No. 99-322.
I concur in this item, and I continue to believe that the Commission needs to re-examine our 
licensing and allotment process, especially our application of the Tuck factors.  I share the concern that 
our Tuck analysis does not provide any means of ensuring that the proposed station will be a meaningful 
local outlet and not just an additional service to the urbanized area.  There is merit to the Joint Petitioners’ 
argument that the Commission has “abandoned” the requirement that a licensee provide local service to 
its community of license.1
As I have said before, the Commission is supposed to keep the allotment/re-allotment “parlor 
game” honest, particularly because we know interested parties have significant incentives to relocate 
radio stations from relatively underserved rural areas to suburban communities that are closer to well-
served urban markets.  
Nevertheless, I am pleased the Commission is re-examining our licensing and allotment process 
to ensure that we are meeting our statutory obligation to distribute radio service throughout the United 
States in a fair, efficient and equitable manner.  
  
1 See FCC Report on Broadcast Localism and Notice of Proposed Rule Making (rel. January 24, 2008) (finding 
that “modification of certain of our rules, policies and practices may be necessary to address the deficiencies of 
many broadcasters in meeting their obligation to serve their local communities”).