purpledevil said:
Ok. I tried to beat around the bush, but that didn't work so I'll be more forward. After 50 years in the business, you should know that a COL is a "Community of License" not a "City of License".
Au contraire. The broadening of the term "city of license" to "community of license" is due to the fact that stations may be licensed to cities, towns, townships, municipalities and even "places" (the administrative law basis for this came from the Humble, NM, application about 40 years ago when Humble was unincorporated and had no post office). So the broad term "community" is applied to the place a station is licensed to. The original FCC rules, and documents such as the earliest FM tables of allocations, referred to "cities" where stations might be licensed.
But as far as service is concerned, "community" (sans "of license") the "community" is the primary service area, incuding cities, towns, suburbs, townships and even rural areas or unincorporated places within the service area. When proactive ascertainment was required (such as including an appendix in each 3-year renewal application), applications would be returned or found lacking if just the COL (city or community at your option... they mean the same thing in that context) were ascertained. While the term was never used, anyone who had to file a license renewal (and I did too many of them...) knew that "community ascertainment" did not mean talking to leaders just in the place named on the station instrument of authorization.
Stations do, and must, serve the areas they cover with primary signals. There is no way to separate Hialeah from Miami, Pasadena from Los Angeles, Parma from Cleveland, Cicero from Chicago, etc., etc. And that is why the FCC does not look for just service to the place / community / city / jurisdiction the station is licensed to, but for service to the primary coverage area.
There is no such thing as a "City of License", only a "Community of License" abbreviated "COL".
The earliest FCC rules, and those well into thre 50's, used "city" and "community" simultaneously or with the same meaning. In references to the license, and even in those involving station IDs, the reference was simply to "location" (3.406 in the rules in force in 1948, for example).
In any case, you are confusing the use of "community" as in today's ID requirements (which in most cases is also the incorporated city of licnese) and the "community" that is served, which is much broader than the location the station is licensed to.
For example, "Los Angeles" is KFI's city of license (since Los Angles is a city) but all of LA, Orange, Ventura counties and much of Riverside and San Bernardino counties are community served.
It is no wonder why we are having this argument in the first place. That long in the business, and no clue as to what a COL is. No wonder communities aren't being served.
Communities are being served. And the community, city, town or jurisdiction of license is usually one of the components of the service-based community.
A classic case would be WIVV, Vieques, PR, which throughout the 60's and 70's broadcast entirely in English from the island Municipality of Vieques, PR. (PR has no cities, no towns, no communities... just Municiplalities). However, during that period, it is provable that not one English dominant person permanently resided in the Municipality of Vieques. However, in the community of service, which consisted mostly of the US Virgin Islands, English was widely spoken. While licensed to Vieques, the community of service was broader and the station served it, although in this case it gave absolutely no service to the place it was licensed to. During those years, the staiton went through 7 or 8 3-year renewals and did the required ascertainment... and, in fact, was given many awards and recognitions for its community service. Again, the community of service was not the location of license, where probably nobody listened due to language.
I don't mean to be disrespectful in any way, but that is ridiculous.
When you are able to talk about doing ascertainment and understand the differences in the service community and the strict location of the license, then you get a certain amount of credibility in this issue. As evidenced by your post, you don't understand what area has to be served and what a station is licensed to.
By the way, the link below contains the FCC rules in force for almost every year over a near-50-year span, including the years when extensive community ascertainment was a requirement (and where "community" meant service area, not the license location).
