Federal Communications Commission FCC 08-218
CONCURRING STATEMENT OF
COMMISSIONER JONATHAN S. ADELSTEIN 
Re: Amendment of Section 73.202(b), Table of Allotments, FM Broadcast Stations, (Vinton, 
Louisiana, Crystal Beach, Lumberton and Winnie, Texas), MM Docket No. 02-212.
I concur in this item, because the reallotment proposal we adopt today will provide new 
FM radio service to more than a quarter of a million people.  So without question, that is a 
substantial public interest benefit.
However, I continue to believe that the Commission needs to re-examine our entire 
licensing and allotment process, especially our application of the Tuck factors.  While our 
procedures and criteria may not be “impermissibly subjective,” as the petitioners in this case 
argue, there is some validity to the contention 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.  
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 a significant 
incentive to relocate radio stations from relatively underserved rural areas to suburban 
communities that are closer to well-served urban markets.  
I am pleased the Commission is re-examining our licensing and allotment process, 
especially our application of the Tuck factors, to ensure that we are meeting our statutory 
obligation to distribute radio service throughout the United States in a fair, efficient and 
equitable manner.