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City of License Requirement

In reading the thread discussing the pros and cons of call letters and whether or not they're obsolete, I thought of another important aspect of the TOH Legal ID, the city of license. Especially with the FM move-ins of the past 30 years, are the cities of license still relevant enough to require their being mentioned, when the only connection many stations currently have to that community is providing a city grade signal to it. For example, in the Raleigh-Durham, NC market, the FM dial looks like this:

WKNC 88.1 FM*
WRTP 88.5 FM
WXDU 88.7 FM*
WSHA 88.9 FM*
WXYC 89.3 FM*
WCPE 89.7 FM*
WVRD 90.5 FM
WNCU 90.7 FM*
WUNC 91.5 FM*
WYFL 92.5 FM
WKSL 93.9 FM
WQDR 94.7 FM*
WBBB 96.1 FM*
WYMY 96.9 FM
WQOK 97.5 FM
WCMC 99.9 FM
WRVA 100.7 FM
WZTK 101.1 FM
WRAL 101.5 FM*
WWPL 102.3 FM
WPLW 102.5 FM
WKIX 102.9 FM*
WNNL 103.9 FM
WFXK 104.3 FM
WDCG 105.1 FM*
WRDU 106.1 FM
WKVK 106.7 FM
WFXC 107.1 FM*

Of these 29 stations, only the 13 with a "*" are licensed to Raleigh, Durham or Chapel Hill (the core cities of the market), and of those above 92 MHz, all but three have their studios in Raleigh and are essentially "Raleigh" stations (even the two commercial FMs licensed to Durham, the state's fifth-largest city with more than 228,000 residents), and two of those three are basically unattended non-commercial transmitters for BBN and K-Love.

And, these cities of license tend to change as well, though not with the frequency of call letters. Quite a few around here have done so in the past six years alone.

So your thoughts on the pros and cons of cities of license...
 
I think the FCC aught to change the COL thing and actually make people announce the city their tower is located in. It would actually make more sense. It might even make some sense to announce where the studio is as that's where that wonderful public file is located we waste tons of hours of manpower on yearly to keep the FCC paper tiger from stealing some of revenue from us.
 
In the Chicago market, there are 4 stations licensed to the suburbs, but have their studios & transmitter in Chicago.

101.9 WTMX Skokie

102.7 WVAZ Oak Park

105.1 WOJO Evanston

105.9 WCFS Elmwood Park

All 4 of these stations ID with their COL, then Chicago after the COL. So for WTMX, they ID as WTMX & WTMX HD-1 Skokie/Chicago.

For 105.9, had they signed on under the current rules, they'd be lucky if they could be a 6kw Class A, due to being short spaced with WSRB Lansing, IL on 106.3. They might also not be allowed to transmit out of Chicago either under the current rules, but they're a pre-1964 short-spaced station, & allowed to be a Class B station (WSRB is also a pre-1964 short-spaced station).
 
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