City of license


In North American broadcasting, a city of license or community of license is the community that a radio station or television station is officially licensed to serve by that country's broadcast regulator.
In North American broadcast law, the concept of community of license dates to the early days of AM radio broadcasting. The requirement that a broadcasting station operate a main studio within a prescribed distance of the community which the station is licensed to serve appears in U.S. law as early as 1939.
Various specific obligations have been applied to broadcasters by governments to fulfill public policy objectives of broadcast localism, both in radio and later also in television, based on the legislative presumption that a broadcaster fills a similar role to that held by community newspaper publishers.

United States

In the United States, the Communications Act of 1934 requires that "the Commission shall make such distribution of licenses, frequencies, hours of operation, and of power among the several States and communities as to provide a fair, efficient, and equitable distribution of radio service to each of the same." The Federal Communications Commission interprets this as requiring that every broadcast station "be licensed to the principal community or other political subdivision which it primarily serves." For each broadcast service, the FCC defines a standard for what it means to serve a community; for example, commercial FM radio stations are required to provide a field strength of at least 3.16 millivolts per meter over the entire land area of the community, whereas non-commercial educational FM stations need only provide a field strength of 1 mV/m over 50% of the community's population. This electric field contour is called the "principal community contour".
The Federal Communications Commission makes other requirements on stations relative to their communities of license; these requirements have varied over time. One example is the requirement for stations to identify themselves, by call sign and community, at sign-on, sign-off, and at the top of every hour of operation. Other current requirements include providing a local telephone number in the community's calling area. The former requirement to maintain an official main studio within 25 miles of the community's geographic center was discontinued in October 2017 when the regulation was amended.

Policy and regulatory issues

Nominal main studio requirements

The requirement that a station maintain a main studio within a station's primary coverage area or within a maximum distance of the community of license originated in an era in which stations were legally required to generate local content and the majority of a station's local, non-network programming was expected to originate in one central studio location. In this context, the view of broadcast regulators held that an expedient way to ensure that content broadcast reflected the needs of a local community was to allocate local broadcast stations and studios to each individual city.
The nominal main studio requirement has become less relevant with the introduction of videotape recorders in 1956, the growing portability of broadcast-quality production equipment due to transistorization, and the elimination of requirements that broadcasters originate any minimum amount of local content.
While the main studio concept nominally remains in US broadcast regulations, and certain administrative requirements are still applied, removal of the requirement that stations originate local content greatly weakens the significance of maintaining a local main studio. A facility capable of originating programming and feeding it to a transmitter must still exist, but under normal conditions there most often is no requirement that these local studio actually be in active use to originate any specific local programming.
In many cases, the use of centralcasting and broadcast automation has greatly weakened the role and importance of manual control by staff at the nominal local station studio facilities.
Exceptions to these rules have been made by regulators, primarily on a case-by-case basis, to deal with "satellite stations": transmitters which are licensed to comply with the technical requirements of full service broadcast facilities and have their own independent call signs and communities of license but are used simply as full-power broadcast translators to rebroadcast another station. These are most often non-commercial educational stations or stations serving thinly populated areas which otherwise would be too small to support an independent local full-service broadcaster.

Political considerations

The requirement that a full-service station maintain local presence in its community of license has been used by proponents of localism and community broadcasting as a means to oppose the construction and use of local stations as mere rebroadcasters or satellite-fed translators of distant stations. Without specific requirements for service to the local community of license, stations could be constructed in large number by out-of-region broadcasters who feed transmitters via satellite and offer no local content.
There also has been a de facto preference by regulators to encourage the assignment of broadcast licenses to smaller cities which otherwise would have no local voice, instead of allowing all broadcast activity to be concentrated in large metropolitan areas already served by many existing broadcasters.
When dealing with multiple competing US radio station applications, current FM allotment priorities are: first full-time aural service; second full-time aural service; first local aural transmission service; and Other public interest matters.
Similar criteria were extended to competing applicants for non-commercial stations by US legislation passed in 2000.

Suburban community problem

Any policy favoring applicants for communities not already served by an existing station has had the unintended effect of encouraging applicants to merely list a small suburb of a large city, claiming to be the "first station in the community" even though the larger city is well served by many existing stations. "The Suburban Community Problem" was recognized in FCC policy as early as 1965. "Stations in metropolitan areas often tend to seek out national and regional advertisers and to identify themselves with the entire metropolitan area rather than with the particular needs of their specified communities," according to an FCC policy statement of the era. In order "to discourage applicants for smaller communities who would be merely substandard stations for neighboring, larger communities," the FCC established the so-called "Suburban Community presumption" which required applicants for AM stations in such markets to demonstrate that they had ascertained the unmet programming needs of the specific communities and were prepared to satisfy those needs.
By 1969, the same issues had spread to FM licensing; instead of building transmitters in the community to nominally be served, applicants would often seek to locate the tower site at least halfway to the next major city. In one such precedent case, the FCC required a hearing before Berwick, a prospective broadcaster, could locate transmitters midway between Pittston, Pennsylvania, and a larger audience in Wilkes-Barre.
A related problem was that of 'move-in'. Outlying communities would find their small-town local stations sold to outsiders, who would then attempt to change the community of license to a suburb of the nearest major city, move transmitter locations or remove existing local content from broadcasts in an attempt to move into the larger city.
The small town of Anniston, Alabama, due to its location 90 miles west of Atlanta and 65 miles east of Birmingham, has lost local content from both TV and FM stations which were re-targeted at one of the two larger urban centers or moved outright.
The same is true for WJSU, which served East Alabama with local news until the station was merged into a triplex to form ABC 33/40 which focuses its coverage on the central part of the state.
A 1988 precedent case created the "Tuck Analysis" as a standard which attempts to address the Suburban Community Problem on a case-by-case basis by examining:
  1. the station's proposed signal coverage over the urbanized area ;
  2. the relative population size and distance between the suburban community and the urban market ; and
  3. the independence of the suburban community, based on various factors that would indicate self-sufficiency.
Despite the best intentions of regulators, the system remains prone to manipulation.

Licensing and on-air identity

While becoming less meaningful over the decades, stations are still required to post a public file somewhere within 25 miles of the city, and to cover the entire city with a local radio signal. In the United States, a station's transmitter must be located so that it can provide a strong signal over nearly all of its "principal community", even if it primarily serves another city. For example, American television station WTTV primarily serves Indianapolis; however, the transmitter is located farther south than the other stations in that city because it is licensed to Bloomington, 50 miles south of Indianapolis. In some cases, such as Jeannette, Pennsylvania-licensed WPKD-TV 19, the FCC has waived this requirement; the station claimed that retaining an existing transmitter site 25.6 miles southeast of its new community of license of Jeannette would be in compliance with the commission's minimum distance separation requirements. Another extreme example of a station's transmitter located far from the city of license is the FM station KPNT, formerly licensed to Ste. Genevieve, Missouri, and transmitting from Hillsboro, but serving the St. Louis and Metro East market to the north. In 2015, the station was allowed by the FCC to move their city of license to Collinsville, Illinois, and have a transmitter in St. Louis proper with a power decrease.
FCC regulations also require stations at least once an hour to state the station's call letters, followed by the city of license. However, the FCC has no restrictions on additional names after the city of license, so many stations afterwards add the nearest large city. For example, CBS affiliate WOIO is licensed to Shaker Heights, a suburb of Cleveland, and thus identifies as "WOIO Shaker Heights-Cleveland." Similarly, northern New York's WWNY-TV identifies as "WWNY-TV 7 Carthage-Watertown" as a historical artifact; the original broadcasts originated from Champion Hill in 1954 so the license still reflects this tiny location.
If the station is licensed in the primary city served, on occasion the station will list a second city or region next to it. For example, the Tampa Bay region's Fox owned-and-operated station WTVT is licensed to Tampa, Florida, its primary city, but identifies on-air as "WTVT Tampa/St. Petersburg", as St. Petersburg is another major city in the market. To encompass Appleton and the smaller cities clustered around the Fox River southwest of Green Bay, Wisconsin, stations in the Green Bay–Appleton area identify as "Green Bay/Fox Cities" ; Green Bay-licensed stations thus still carry an official identification, while providing the ability for stations licensed to other places in the region to officially prefix their name before the mention of "Green Bay/Fox Cities".
There is no longer a requirement to carry programs relevant to the particular community, or even necessarily to operate or transmit from that community. Accordingly, stations licensed to smaller communities in major metropolitan markets often target programming toward the entire market rather than the official home community, and often move their studio facilities to the larger urban centre as well. For instance, the Canadian radio station CFNY-FM is officially licensed to Brampton, Ontario, although its studio and transmitter facilities are located in downtown Toronto.
This may, at times, lead to confusion — while media directories normally list broadcast stations by their legal community of license, audiences often disregard the distinction. For instance, for a short time while resolving a license conflict and ownership transaction in 1989, the current day KCAL-TV in Los Angeles was licensed to the little-known southeast suburb of Norwalk, California, with the station's identifications at the time only vocally mentioning the temporary city of license in a rushed form, with Norwalk barely receiving any visual mention on the station; at no time were any station assets actually based in Norwalk, nor was public affairs or news programming adjusted to become Norwalk-centric over that of Los Angeles and Southern California. The station returned to its Los Angeles city of license after the transaction was complete.
Often, a station will keep a tiny outlying community in its licensing and on-air identity long after the original rationale for choosing that location is no longer truly applicable. Sneedville, Tennessee, as city of license for PBS member station WETP-TV originally made sense as a compromise location to serve both Knoxville and the Tri-Cities of Tennessee and Virginia on VHF channel 2. It met the minimum distance requirements to two other channel 2 stations in the region, WKRN in Nashville and WSB-TV in Atlanta. This became less important after full-power UHF satellite WKOP-TV signed on in Knoxville, and irrelevant once the 2003-09 DTV transition and 2016-21 repack moved WETP's main signal to physical channel UHF 24. Nonetheless, broadcasters and regulatory authorities are more likely to retain the original city of license, rather than bring unwanted scrutiny for taking away a small community's only station, which may be a mark of civic pride, only to move it to some larger center which already has multiple stations.