Federal Communications Commission FCC 15-89
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
WGBH Educational Foundation 
Applications for Renewal of Licenses of
WGBH(FM), Boston, Massachusetts, and
WCRB-FM, Lowell, Massachusetts
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File No. BRED-20131202BIA
Facility ID No. 70510
File No. BRH-20131202BIR
Facility ID No. 23441
MEMORANDUM OPINION AND ORDER
Adopted:  July 16, 2015 Released: July 16, 2015
By the Commission:
1. The Commission has before it an Application for Review (“AFR”) filed January 9, 2015, 
by the Committee for Community Access (“CCA”).  CCA seeks review of a Media Bureau (“Bureau”)
decision,
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dismissing for lack of standing CCA’s Petition for Reconsideration of a prior Letter Decision.
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In the Letter Decision, the Bureau treated as an informal objection CCA’s March 4, 2014, pleading styled 
as a “Petition to Deny” the captioned renewal applications (“Applications”)
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of the WGBH Educational 
Foundation (“Foundation”) due to CCA’s late filing of a supporting affidavit.
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  The Bureau denied CCA’s 
objection, rejecting its argument that the Foundation exercised insufficient control over programming and 
its request to reexamine the Format Policy Statement
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in the context of this proceeding.
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2. On review, CCA argues that: (1) the Bureau erred in not treating CCA’s untimely filing 
as a petition to deny; (2) the Reconsideration Decision is in conflict with Commission precedent 
regarding licensee control over station programming and improperly placed the burden of proof on it 
rather than the Foundation; and (3) the Bureau’s decision not to reexamine the Format Policy Statement
in the context of this license renewal proceeding should be reversed.
3. Upon review of the AFR and the entire record, we conclude that the Bureau properly 
decided the matters raised in the Letter Decision and Reconsideration Decision, and we uphold its
                                                     
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See Philip R. Olenick,, Esq., and Eve Pogoriler, Esq., Letter, Ref. 1800B3-AJR (Dec. 10, 2014) (“Reconsideration 
Decision”).    
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See Philip R. Olenick, Esq., and Eve Pogoriler, Esq., Letter, Ref. 1800B3-JFS (Aug. 20, 2014) (“Letter Decision”). 
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The Applications sought the renewal of the licenses for noncommercial educational (“NCE”) Stations 
WGBH(FM), Boston, Massachusetts, and WCRB(FM), Lowell, Massachusetts.
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Specifically, the CCA Petition was filed on March 4, 2014, the deadline for filing petitions to deny against the 
Applications, but CCA did not submit a supporting affidavit until March 6, 2014.
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Changes in the Entertainment Formats of Broadcast Stations, Memorandum Opinion and Order, 60 FCC 2d 858 
(1976) (subsequent history omitted) (“Format Policy Statement”) (establishing a policy of non-intervention in 
broadcast station entertainment format changes).
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The Foundation filed an Opposition on January 26, 2015.  CCA filed a Reply on February 5, 2015. 
Federal Communications Commission FCC 15-89
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decision for the reasons stated therein.
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  Accordingly, IT IS ORDERED that, pursuant to Section 5(c)(5) 
of the Communications Act of 1934, as amended, and Sections 1.115(b) and (g) of the Commission’s 
Rules, 47 C.F.R. §§ 1.115(b), (g), the Application for Review filed by the Committee for Community 
Access IS DISMISSED IN PART to the extent noted in footnote 7 and in all other respects IS DENIED.
FEDERAL COMMUNICATIONS COMMISSION
Marlene H. Dortch
Secretary
                                                     
7
We also note that, throughout both its AFR and Reply, CCA makes reference to arguments contained in its 
previous pleadings. Such incorporation by reference is not allowed under our rules. Rather, the burden is on the 
party seeking review to set forth fully its argument and all underlying relevant facts in the application for review. 47 
C.F.R. § 1.115(b)(2)(i). The Commission is not required to sift through the prior pleadings to supply the reasoning 
that the Rule requires be so provided, “with particularity,” in the application for review.  See Tama Radio Licenses 
of Tampa, FL, Inc., Memorandum Opinion and Order, 25 FCC Rcd 7588, 7589 (2010), aff’d sub nom., Cherry v. 
FCC, 641 F.3d 494 (D.C. Cir. 2011); Red Hot Radio, Inc., Memorandum Opinion and Order, 19 FCC Rcd 6737, 
6745 n.63 (2004).  We therefore dismiss the AFR to the extent it seeks to incorporate by reference arguments that 
CCA made in previously filed pleadings.  See Ernesto Bustos, Memorandum Opinion and Order, 29 FCC Rcd 
12863, 12863-64 n.8 (2014).