More Consolidation is Not the Answer to Poor Business Decisions

[bobdavcav]

Rolley James is an 80-something-year-old woman who lives in Globe, Arizona. She owns and operates two radio stations from there: a commercial FM country station and an AM outlet, KJAA, at 1240 kHz that is really her own personal oldies jukebox. I've never heard any commercials on it (it's streamed online as well as the FM) and she certainly doesn't have any live and local personalities on it, just her own automated voice after every two or three songs identifying what the listener is listening to.

She also hosts an Internet only radio station called "The Rolley (or is it eye?) James Show," which is mostly her talking with guests, many from the broadcasting industry. A few years ago, I was listening to one of her shows on that internet-only station and I heard her relate the following story:

She was traveling by car in North Dakota. The weather was getting bad so she tried to find a radio station that might say how bad it was going to be (she thought that a tornado may have been coming). She couldn't find one so she drove on to the hotel as the weather was worsening. When she got to the hotel, she commented to the front desk clerk how she couldn't find out anything about the weather on her car radio when she was coming in. The clerk reached into his pocket, pulled out his cell phone, and explained this was how he kept track of the weather now. Any emergency weather statements were texted to him and an alarm went off on his phone when he received them.

The point of this story is that a lot of younger people believe they don't need radio anymore to get the information that you and I used to depend on it for. And that leaves nothing for radio but to provide a jukebox of sorts (or controversial talk programming) just to try to gain an audience. But, as has been noted by others, more niche-oriented (and sometimes customizeable) jukeboxes are available online that radio cannot hope to do over the air.

Where I think the youngsters have it wrong (and I say this as a 62-year-old totally blind person) is the belief that the Internet and cell phone service will always be there and available when needed. As noted on this and other threads, cell phone and Internet service are not available in some sparsely populated areas; in addition, it may be easier when under attack to stop Internet and cell phone service than to stop an over-the-air broadcaster. Finally, there is the raging battle between broadcasters, webcasters and the recording industry about the rates the former should pay the latter. It is possible that the rates could go so high as to make the possibility of niche formats on the Internet nonexistent.

Ted,
Your story reminds me of a conversation I had with a friend yesterday, and one that comes up when talking to this particular friend every once in a while. She lives in Oswego, New York and talks frequently about the ice storm they got in April 2003. At the time, as is the case today, the Oswego stations, once locally focused, were simulcasting stations from Syracuse, some 40 miles away. Since the storm didn't affect that area, there was no mention at all of it on local radio. She has even interned at one of the stations supposedly serving Oswego, but when she confronts management about not serving the community, she is repeatedly told that if it doesn't affect Syracuse, we shouldn't talk about it. I have a hard time getting my mind around such a situation, as when we get bad weather, it generally affects the entire listening area, but if weather can be that drastically different in one part of your market from another, there should be some local coverage.
She knows there are a few local businesses that want to advertise on local radio but don't want to pay Syracuse rates. Whether those local clients would be enough to sustain a radio station, I have no idea, as I have no idea how many businesses there are or what they are in fact willing to pay. She believes a station could be viable, but then again this is the same person who would buy a 3 W day 2 W night station on 1240 Khz licensed to Wilkeson, WA. I can tell you right now that about the only viable path for such a station would be travelers information for those visiting Mt. Rainier National Park. People going there or taking their child to summer camp are the only ones who would go through Wilkeson, whose permanent population is about 500.

 

[ted chittenden]

Ted,
Your story reminds me of a conversation I had with a friend yesterday, and one that comes up when talking to this particular friend every once in a while. She lives in Oswego, New York and talks frequently about the ice storm they got in April 2003. At the time, as is the case today, the Oswego stations, once locally focused, were simulcasting stations from Syracuse, some 40 miles away. Since the storm didn't affect that area, there was no mention at all of it on local radio. She has even interned at one of the stations supposedly serving Oswego, but when she confronts management about not serving the community, she is repeatedly told that if it doesn't affect Syracuse, we shouldn't talk about it. I have a hard time getting my mind around such a situation, as when we get bad weather, it generally affects the entire listening area, but if weather can be that drastically different in one part of your market from another, there should be some local coverage.
She knows there are a few local businesses that want to advertise on local radio but don't want to pay Syracuse rates. Whether those local clients would be enough to sustain a radio station, I have no idea, as I have no idea how many businesses there are or what they are in fact willing to pay. She believes a station could be viable, but then again this is the same person who would buy a 3 W day 2 W night station on 1240 Khz licensed to Wilkeson, WA. I can tell you right now that about the only viable path for such a station would be travelers information for those visiting Mt. Rainier National Park. People going there or taking their child to summer camp are the only ones who would go through Wilkeson, whose permanent population is about 500.

Interesting. In roughly 2010, i began to see two noncommercial listings in Glenoma, WA, quite a ways south and a bit east of Wilkeson and also in the Cascades. I think these community stations (I forget their callsigns and frequencies now) were on the air for roughly three years(?) But the community wasn't large enough to support one noncommercial operation, let alone two. Both licenses were turned in to the FCC, and we'll see whenever the next window for full power FMs opens up again if somebody else tries to snag up the frequency spots. (I rather doubt it because of the sparse population in the area and the tiny ranges the stations whose antenna heights above average terrain were in the minus numbers, if memory serves, covered). The point, of course, is that while noncommercial outlets don't have to make a profit, they do need to have enough financial support to break even.

 

[K.M. Richards]

Re: regulations. I read the Inside Radio article about what regulations should be eliminated, and while relaxing second-adjacent spacing requirements makes some sense, I don't see under the current situation how allowing the fill-in stations as we'll call them will allow many stations to move from AM to FM as some have proposed. Let's look at several markets I'm familiar with for examples why.
Los Angeles, there's lots of non-commercial spacing issues here that I'm not going to get into, so let's just focus on the commercial band in this market.
92.7, I could see EMF canceling two licenses here and moving the remaining license to Mount Wilson as a full class B.
93.5 same situation, currently a simulcast with one station in the suburbs and one in Riverside County.
94.3 same situation, with an additional 105.5 which we'll get to later.

It doesn't work that way. The FCC does not allow combining co-channel Class A licenses into a single higher-powered one. They are separate allocations, each with their own community of license.

Even if it were to be proposed as new rulemaking, whichever COL lost "its" station would rightfully complain that the Rules do not allow removing a COL's sole licensed station.

I invite you to consult a lawyer versed in the Rules and Regs. It sounds like you need to have someone explain it to you.

In fact ... oh, Scott Fybush? Reality check needed here!

96.7 is currently an Orange County signal, I'm not familiar enough with what else is on that frequency to give any speculation on whether that would be able to move north.

Ventura County. COL Santa Paula. Happens to be the first station I was PD of back in 1978.

97.5 is a big signal in Riverside, unlikely to be able to get anything else in there.

Spacing at the minimum distance already from a grandfathered super power in Santa Barbara (which I also worked at later in my career).

99.9 KOLA puts a big signal over a good portion of the market.

And has to be spaced to (again) Santa Barbara.

100.7 might work, but you'd run into co-channel issues with San Diego.

KHAY in Ventura. Another station grandfathered at higher ERP than present rules would allow.

103.1 see 92.7, 93.5, and 94.3 above.

Santa Monica and Newport Beach 103.1s were short-spaced from the start. There's also one in the Antelope Valley, IIRC.

107.9 is a class B licensed to Orange County, but not sure if the owners would want to move it into Los Angeles if that's even possible.

Second adjacent to KLVE at 107.5 ... and I think Calvary Chapel would have moved it already if it were technically feasible.

I don't know enough about the other markets, but based on all the erroneous presumptions you made here, I doubt any of those are feasible either.

 

[bobdavcav]

Interesting. In roughly 2010, i began to see two noncommercial listings in Glenoma, WA, quite a ways south and a bit east of Wilkeson and also in the Cascades. I think these community stations (I forget their callsigns and frequencies now) were on the air for roughly three years(?) But the community wasn't large enough to support one noncommercial operation, let alone two. Both licenses were turned in to the FCC, and we'll see whenever the next window for full power FMs opens up again if somebody else tries to snag up the frequency spots. (I rather doubt it because of the sparse population in the area and the tiny ranges the stations whose antenna heights above average terrain were in the minus numbers, if memory serves, covered). The point, of course, is that while noncommercial outlets don't have to make a profit, they do need to have enough financial support to break even.

And those were FM stations, I would think AM would have an even bigger challenge. Being blind and at least somewhat familiar with the geography of this area, are you familiar with Sunset Lake camp? That's probably the only thing in Wilkeson of note.

 

[bobdavcav]

It doesn't work that way. The FCC does not allow combining co-channel Class A licenses into a single higher-powered one. They are separate allocations, each with their own community of license.

Even if it were to be proposed as new rulemaking, whichever COL lost "its" station would rightfully complain that the Rules do not allow removing a COL's sole licensed station.

I invite you to consult a lawyer versed in the Rules and Regs. It sounds like you need to have someone explain it to you.

In fact ... oh, Scott Fybush? Reality check needed here!



Ventura County. COL Santa Paula. Happens to be the first station I was PD of back in 1978.



Spacing at the minimum distance already from a grandfathered super power in Santa Barbara (which I also worked at later in my career).



And has to be spaced to (again) Santa Barbara.



KHAY in Ventura. Another station grandfathered at higher ERP than present rules would allow.



Santa Monica and Newport Beach 103.1s were short-spaced from the start. There's also one in the Antelope Valley, IIRC.



Second adjacent to KLVE at 107.5 ... and I think Calvary Chapel would have moved it already if it were technically feasible.

I don't know enough about the other markets, but based on all the erroneous presumptions you made here, I doubt any of those are feasible either.

There is the issue of not currently being able to combine allocations into one signal that would be at higher power, which would exacerbate the issues with moving more AM stations to FM in Los Angeles. Thank you for trying to fill in some of the gaps in my knowledge of the radio dial down there. I've only been in that market twice, and both times were in Orange County.
Right now, it's not technically feasible to move 107.9 any closer to Los Angeles under the current rules, but that's not the point I was making. In all three example markets, I was trying to demonstrate that even if second-adjacent spacing rules were completely eliminated, and all the new allocations that opened up were strictly for AM stations, there wouldn't be many, if any, available spots on the dial due to the way things have been allocated until now. Even if some of what I proposed were able to be done under revised rules in Los Angeles, we are talking about moving existing stations around, not making new space for AM stations to move to FM. In the other markets, there's more room for new FM stations, but those signals aren't going to be competitive with the existing class C FM stations because they have to protect co-channels close by.

 

[vchimpanzee]

It doesn't work that way. The FCC does not allow combining co-channel Class A licenses into a single higher-powered one. They are separate allocations, each with their own community of license.

Even if it were to be proposed as new rulemaking, whichever COL lost "its" station would rightfully complain that the Rules do not allow removing a COL's sole licensed station.

I invite you to consult a lawyer versed in the Rules and Regs. It sounds like you need to have someone explain it to you.

In fact ... oh, Scott Fybush? Reality check needed here!

Similar issue here. https://radiodiscussions.com/threads/rip-104-7-the-fish.774578/page-6#post-6807282

 

[fybush]

Seeing that I got tagged into this discussion -

Barring a massive change in the rules, there's really not anything constructive to discuss about a market like LA.

It's a massively crowded market already, and even if you could combine allocations (which you can't) and eliminate second-adjacent restrictions (which would be a massive upheaval), you STILL have other spacing issues to confront. Take KWVE - if you start trying to move 107.9 north, you also run into spacing issues with the 107.9 in Bakersfield, just to give one example.

The only incremental moves that have been possible over the years involve the many second-adjacent stations that were authorized before 1964 and thus don't have the same spacing restrictions. The Arcadia 107.1A (the old KMAX) used that loophole to move to Mount Wilson, but it was so low in power from up there that it ended up moving back down.

In other large markets, the pre-64 rule has been used to better effect - it's how 94.3 came all the way into Chicago from the suburbs, and how 93.5 and 103.9 now transmit from within NYC city limits.

 

[ted chittenden]

And those were FM stations, I would think AM would have an even bigger challenge. Being blind and at least somewhat familiar with the geography of this area, are you familiar with Sunset Lake camp? That's probably the only thing in Wilkeson of note.

No. I had an uncle who lived in Maple Valley which is how I got to know a little bit about the radio landscape in your neck of the woods. (My Family traveled there twice between 1979 and 2001 when I took radios along.) And I'd never been through Glenoma, but I'm guessing from a radio entertainment site that I visit often, that it is a very sparsely populated area of Washington, indeed.

 

[ted chittenden]

Seeing that I got tagged into this discussion -

Barring a massive change in the rules, there's really not anything constructive to discuss about a market like LA.

It's a massively crowded market already, and even if you could combine allocations (which you can't) and eliminate second-adjacent restrictions (which would be a massive upheaval), you STILL have other spacing issues to confront. Take KWVE - if you start trying to move 107.9 north, you also run into spacing issues with the 107.9 in Bakersfield, just to give one example.

The only incremental moves that have been possible over the years involve the many second-adjacent stations that were authorized before 1964 and thus don't have the same spacing restrictions. The Arcadia 107.1A (the old KMAX) used that loophole to move to Mount Wilson, but it was so low in power from up there that it ended up moving back down.

In other large markets, the pre-64 rule has been used to better effect - it's how 94.3 came all the way into Chicago from the suburbs, and how 93.5 and 103.9 now transmit from within NYC city limits.

As a person who spent the first nine years of his life in the Los Angeles suburbs and who came back for college in west Los Angeles between 1981 and 1985, I can tell you that there are only two possible adjacent channels that might be used for AM move-ins but their antennas would have to be highly directional and neither would cover the entire Los Angeles area.

The first possibility would be at 99.1 FM. KGGI in Riverside is the only station that can be heard in parts of the Los Angeles area, and there is no other station on that frequency until you get to Santa Maria. It would therefore be theoretically possible for an new station at 99.1 FM on the west side of the San Fernando Valley that might serve, say, Granada Hills and Van Nuys but would not reach the L.A. city proper.

The other possibility would be even more tenuous. The two stations licensed at 101.5 mHz are licensed to San Diego and Bakersfield respectively. While you could theoretically place a new station on that frequency, say from the southern part of the San Fernando Valley to serve Hollywood and Burbank (and maybe even parts of northern Los Angeles), you would run into a lot of problems during the tropospheric seasons (spring through fall) when KGB-FM's signal from San Diego can, at times, come in as good as a local in nearly all of the Los Angeles area, including the San Fernando Valley. (The Bakersfield station has never been able to get its signal over the Grapevine so there would be no problems there.)

So yeah. Moving AM stations to FM adjacent frequencies really wouldn't be a good idea for the Los Angeles area, and it would be only a marginally better idea in my current hometown of Phoenix, AZ.

 

[bobdavcav]

Seeing that I got tagged into this discussion -

Barring a massive change in the rules, there's really not anything constructive to discuss about a market like LA.

It's a massively crowded market already, and even if you could combine allocations (which you can't) and eliminate second-adjacent restrictions (which would be a massive upheaval), you STILL have other spacing issues to confront. Take KWVE - if you start trying to move 107.9 north, you also run into spacing issues with the 107.9 in Bakersfield, just to give one example.

The only incremental moves that have been possible over the years involve the many second-adjacent stations that were authorized before 1964 and thus don't have the same spacing restrictions. The Arcadia 107.1A (the old KMAX) used that loophole to move to Mount Wilson, but it was so low in power from up there that it ended up moving back down.

In other large markets, the pre-64 rule has been used to better effect - it's how 94.3 came all the way into Chicago from the suburbs, and how 93.5 and 103.9 now transmit from within NYC city limits.

Los Angeles aside, I have a hard time figuring out how moving AM stations to second-adjacent FM frequencies would work in lots of places. Portland would probably work the best of any of the markets I talked about in my original post about this, and I lay out all the co-channel issues you would run into there. I did not write out Spokane, Eugene, or Bend, but those markets have a few more openings. Even there though, if I dug into things a bit further, I would probably find fewer openings than I thought would exist initially. Even as I wrote this out, I think one is off the table in both Eugene and Bend. I had initially thought that a 92.5 could work in one of those markets, but I forgot about the big 92.5 in Klamath Falls. I think that would prevent the C1 I had thought would work in Bend, and moving it either north or west would run into issues with first-adjacents 92.3 and 92.7. I suppose it could be moved east, but I'm not sure who, if anyone, such an allocation could be granted to, as you're then getting into the middle of nowhere high desert.

 

[davideduardo]

The first possibility would be at 99.1 FM. KGGI in Riverside is the only station that can be heard in parts of the Los Angeles area, and there is no other station on that frequency until you get to Santa Maria. It would therefore be theoretically possible for an new station at 99.1 FM on the west side of the San Fernando Valley that might serve, say, Granada Hills and Van Nuys but would not reach the L.A. city proper.

You are forgetting the Entravision FM KLYY which gets so much signal into the Los Angeles MSA that they have even elected to have Nielsen list them as "Home" to that market.

 

[davideduardo]

Barring a massive change in the rules, there's really not anything constructive to discuss about a market like LA.

This discussion made me think about the origins of "city of license" rules and procedures.

This concept came out of the regulations of radio from the late 1920's to the earlier 1930's. The media world was made up of newspapers and magazines before that. Newspapers had a physical challenge to distribute beyond the city they published in and the immediate suburbs, so the concept of a "market" was not well developed then. In fact, far suburbs and nearby towns had their own paper.

Before urban sprawl and the plethora of independent suburban towns surrounding the "big city", media was focused on cities and not metropolitan areas. We didn't call them "markets" and instead referred to each city and town.

So it was natural that the FRC and FCC would "give" stations to individual cities, not market areas.

In particular, after WW II prosperity and population growth made the surrounding towns of a central city as big... or bigger... than the big city itself. So today, we look at many markets were the named city is less than a quarter of the market population. But the FCC continues to license stations to "serve" specific cities and not so much their total coverage area.

It would be interesting to contemplate what might happen if the FCC converted all licenses to name the Metropolitan Statistical Area or Metro Survey Area while non-metro stations would be home to their county and not a specific town or village. "First local service" would be abolished, and every station would belong to their MSA or home county instead.

 

[ted chittenden]

You are forgetting the Entravision FM KLYY which gets so much signal into the Los Angeles MSA that they have even elected to have Nielsen list them as "Home" to that market.

I didn't bring KLYY-FM into my post because it was *not* on one of the two theoretically available adjacent frequencies I was considering. As K.M. Richards noted above, 97.5 could not theoretically get an AM adjacent allocation because of both KLYY-FM in Riverside and KLSB-FM in Santa Barbara.

 

[K.M. Richards]

I didn't bring KLYY-FM into my post because it was *not* on one of the two theoretically available adjacent frequencies I was considering. As K.M. Richards noted above, 97.5 could not theoretically get an AM adjacent allocation because of both KLYY-FM in Riverside and KLSB-FM in Santa Barbara.

This reminds me to clarify by addition something in my original post on this: In addition to Santa Paula (KLJR-FM), the 96.7 in Santa Ana (KWIZ) also has spacing issues with KCAL-FM in Redlands on that frequency.

And it is 105.5 that has stations in both Long Beach and Ojai and Rosamond in the AV.

 

[TheBigA]

Rolley James is an 80-something-year-old woman who lives in Globe, Arizona.

I think she's a little bit younger than that. But she's been in radio for most of her life. I got to meet her at a conference a few years ago.

The point of this story is that a lot of younger people believe they don't need radio anymore to get the information that you and I used to depend on it for.

Maybe. They have no experience with the full service AM stations of the 60s. So while they don't "need radio" to get the information, they're not opposed to using radio if it provides unique information or entertainment that can't be obtained elsewhere. Therein lies the challenge. But I find they have respect for radio, and those who are in it are very passionate about it.

 

[fybush]

I realize that we have some blind members in this discussion, and it's probably not easy to run a table through a screen reader, but:

Section 73.207 of the FCC's rules has been in place in its current form for over 30 years now, setting the minimum distances between FM allocations. Once you study its distances, you can see that there's simply nowhere that you could slot a full-power 99.1 between Riverside and Santa Maria, or a 101.5 up against KGB.

A lot of much better minds than mine pored over the allocation tables in the 1980s, the last time the FCC significantly loosened them, and I promise you that any possibility of adding any new allocation in any spot with any real population at all was filled up 30 years ago or more.

I'm not just talking LA or Chicago - there's nothing left to be found or filled in Bend or La Grande or Umatilla. The dial has been packed as full as the current spacing rules will allow.

 

[K.M. Richards]

Rolley James is an 80-something-year-old woman who lives in Globe, Arizona.

I think she's a little bit younger than that. But she's been in radio for most of her life. I got to meet her at a conference a few years ago.

Rollye, under her birth name Bornstein, started out in radio at WQAM in Miami as their production corridor, shifted to the record business, first with Epic Records and then as the publicity manager for Charlie Rich in Nashville, then in the late 1970s got back into radio on-air, first at WDNC in Durham NC and then with WIBC in Indianapolis. (I turn 69 in a couple of weeks, so she's probably in her 70s based on that timeline.)

She moved to L.A. in 1979, first as program director at KPOL and then as news director at KHTZ before being hired by Watermark in 1980 to be the producer for their "Soundtrack of the '60s".

Billboard hired her in 1983 to assume responsibility for the "Vox Jox" column after Claude Hall left. She lasted there until 1986 and turned up at KOA in Denver the next year as night talk host, which is when she adopted the "Rollye James" airname. She did fill-in at KFI in the early 1990s.

No more references in Billboard after that, and all I could find in searching the Radio & Records archive at our esteemed Señor Gleason's World Radio History site was that she did a night talk show at WPHT Philadelphia that was also carried on the Radio America network. I can't tell when that began but by September 2001 she had parted ways with the network. She apparently self-syndicated a midday show after that (it was listed in R&R's list of syndicated programming in 2004).

KJAA, which she calls "Cooler Oldies Jukebox 1240" has been under her ownership for literally one decade (3/11/2015) along with her FM, KQSS. She apparently had been working for the immediate previous owner and acquired the stations from his estate. The translator K291CU only dates from 2020, during the "AM Revitalization Act" process. It is therefore linked permanently to 1240 (I checked the authorization at the FCC just to be certain). Actual COL for both stations is Miami AZ.

KQSS is branded as "Gila 101.9" playing "monster Country hits from your local news leader". Sounds like she combined her knowledge of both music and news for that operation.

And she still has her nightly program (10pm-1am CT) on WGN, and her website has her blog in which she recaps the previous evening's show. Apparently she sneaks in her favorite obscure Oldies between calls.

The Rollye James Show

The Rollye James Show

www.rollye.net

And, to quote the late Paul Harvey: Now you know ... the rest of the story.

 

[TheBigA]

(I turn 69 in a couple of weeks, so she's probably in her 70s based on that timeline.)

That's my guess, like maybe 73. I really enjoyed meeting her. She was a firecracker.

 

[bobdavcav]

I realize that we have some blind members in this discussion, and it's probably not easy to run a table through a screen reader, but:

Section 73.207 of the FCC's rules has been in place in its current form for over 30 years now, setting the minimum distances between FM allocations. Once you study its distances, you can see that there's simply nowhere that you could slot a full-power 99.1 between Riverside and Santa Maria, or a 101.5 up against KGB.

A lot of much better minds than mine pored over the allocation tables in the 1980s, the last time the FCC significantly loosened them, and I promise you that any possibility of adding any new allocation in any spot with any real population at all was filled up 30 years ago or more.

I'm not just talking LA or Chicago - there's nothing left to be found or filled in Bend or La Grande or Umatilla. The dial has been packed as full as the current spacing rules will allow.

Two points on this Scott:
1. You are absolutely right about the current spacing rules, there is nowhere any new allocations can go in most cities. When what is now 94.9 in Terrebonne, OR signed on, it was originally at 106.5 and had to move to 94.9 due to issues with air traffic communications. In the Bend area, I could potentially see 106.5 as a future new signal, but I think that would be it under the current rules. My post above was specifically about relaxed or eliminated second-adjacent spacing rules, which I'm sure would cause you and other engineers in the business to pour over those allocation tables again.
2. I've actually seen the spacing tables, and there are also rules that govern spacing between U.S. and foreign stations that appear to be routinely broken. I can think of several examples that have been discussed on the Seattle board, the most noteable of which is 105.7 in Cedro-Woolley. How does that work under the current spacing rules? I think 97.7 in Oakville works similarly, though there's quite a bit more space between that and Vancouver. I don't follow the Buffalo board, but from what I understand there are several examples of stations across the border not being protected by the existing spacing rules in that area either.

 

[K.M. Richards]

2. I've actually seen the spacing tables, and there are also rules that govern spacing between U.S. and foreign stations that appear to be routinely broken. I can think of several examples that have been discussed on the Seattle board, the most noteable of which is 105.7 in Cedro-Woolley. How does that work under the current spacing rules? I think 97.7 in Oakville works similarly, though there's quite a bit more space between that and Vancouver. I don't follow the Buffalo board, but from what I understand there are several examples of stations across the border not being protected by the existing spacing rules in that area either.

Scott can of course correct me on this, but it has always been my understanding that the spacing rules between the U.S. and both Mexico and Canada are negotiated by treaty every time that becomes a factor in an application. So the tables aren't necessarily gospel in these cases.