Federal Communications Commission FCC 08-227
STATEMENT OF
COMMISSIONER MICHAEL J. COPPS
Re:  Amendment of Section 73.202(b), Table of Allotments, FM Broadcast Stations 
(Emmetsburg, Sanborn and Sibley, Iowa, and Brandon, South Dakota, MM Docket No. 
01-65, et al.; Applications of Kidd Communications for a Construction Permit for a New 
AM Station at Truckee, California, Pamplin Broadcasting-Oregon, Inc. for a 
Construction Permit for a New AM Station at Jacksonville, Oregon, File Nos. BNP-
20000201AFK and 20000131ABP; Royce International Broadcasting Co., Application 
for a New AM Broadcast Station at Folsom, California, File No. BP-19970829AA, et al.
I have discussed previously the need to revisit our radio allotment priorities in order to 
ensure that we are meeting our statutory obligation to provide “a fair, efficient, and equitable 
distribution of radio licenses.”1 Section 307(b) means that rural as well as urban communities 
are entitled to a fair distribution of service.  I am concerned, however, that our existing allotment 
rules may unduly favor urban applicants by awarding, for instance, a dispositive preference to 
proposals that serve the greater number of people—even if that number is relatively small. The 
end result is that rural applicants often never even get the chance to bid at auction because the 
urban applicants are awarded a dispositive preference, typically under the catch-all priority for 
“other public interest matters.”
I am pleased that my colleagues have agreed to examine our radio allotment and 
assignment criteria as part of the recently released Rural Radio Service Notice of Proposed 
Rulemaking.2 In the meantime, these cases adhere to current precedent and I therefore accept the 
results.
  
1See 47 U.S.C. § 307(b); See also Concurring Statement of Commissioner Michael J. Copps, In re Applications of 
Jeffrey B. Bate for a New AM Broadcast Station at Mesquite, Nevada and Jeffrey Eustis for a New AM Broadcast 
Station at Johnstown, Colorado,  and In re Applications of Jeffrey B. Bate for a New AM Broadcast Station at St. 
George, Utah and Andrew Johnson for a New AM Broadcast Station at Winchester, Nevada.
2 Policies to Promote Rural Radio Service and Streamline Allotment and Assignment Procedures, Notice of 
Proposed Rule Making, FCC 09-30, (rel. Apr. 20, 2009).