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 In Re Renewals of BROADCAST LICENSES FOR ARKANSAS, LOUISIANA AND MISSISSIPPI, 1973; Part 1 of 2

FEDERAL COMMUNICATIONS COMMISSION

42 F.C.C.2d 3

MAY 31, 1973 

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JUDGES:

THE COMMISSION BY COMMISSIONERS BURCH (CHAIRMAN), ROBERT E. LEE, H. REX LEE, REID, WILEY, AND HOOKS, WITH COMMISSIONER JOHNSON DISSENTING AND ISSUING A STATEMENT, APPROVED STAFF ACTION REVIEWING BROADCAST LICENSES FOR ARKANSAS, LOUISIANA AND MISSISSIPPI FOR 1973.

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OPINIONBY: JOHNSON

DISSENTBY: JOHNSON

DISSENT:

DISSENTING OPINION OF COMMISSIONER NICHOLAS JOHNSON

For my entire term I have dissented to the automatic renewal of licensees guilty of substandard performances in programming and (more recently) employment.  The 1973 Arkansas-Louisiana-Mississippi renewals represent the last group that will cross my desk during my official tenure as Federal Communications Commissioner.  Therefore, I and my staff and seminar students have prepared a major report on broadcasting in America, incorporating many of the complaints and suggestions of my seven years, for this one final renewal dissent.

BROADCASTING IN AMERICA

The Performance of Network Affiliates

in the Top 50 Markets

July 1973 -- A case study prepared by FCC Commissioner Nicholas

Johnson and his staff and seminar students

TABLE OF CONTENTS

	Page
Table of Contents	4
Table of Tables	4
Credits	5
INTRODUCTION (and overall programming ranking)	6
Chapter 1.  PROGRAMMING PERFORMANCE
I.  Introduction	14
II.  News & Public Affairs	16
III.  Commercialization	25
IV.  Local Programming	30
V.  Confidential Financial Information	38
Chapter 2.  EMPLOYMENT
I.  Introduction	49
II.  Analysis of Minority Employment	52
III.  Analysis of Female Employment	59
IV.  Remedies for Claims of Employment Discrimination	61
V.  National Employment Analysis	64
Chapter 3.  PATTERNS OF OWNERSHIP	68
Chapter 4.  HOW YOU CAN IMPROVE TELEVISION IN YOUR COMMUNITY
I.  What Can You Do?  (an Introduction)	100
II.  How Do You Prepare?	103
III.  What Action Can You Take?	118
Appendix A.  Systems Methodology	123
Appendix B.  Citizens' Organizations & Resource Materials	126
Appendix C.  Additional Tables of Information	128
Appendix D.  The Ten Best and Ten Worst Stations	166
Appendix E.  Setting Minimum Levels of Performance	170
Appendix F.  The Top 50 Markets	171
TABLE OF TABLES
Table 1.  Ranking the network affiliates
in the top 50 markets on their overall
programming performance	7
Table 2.  Overall programming ranking
including rank in each of the
programming criteria	14
Table 3.  Ranking of performance in
news, public affairs and "other"
programming	19
Table 4.  Ranking of performance in
category of Public Service announce-
ments	23
Table 5.  Ranking of performance in
commercialization category	28
Table 6.  Ranking of performance in local programming	34
Table 7.  Ranking based on the percentage
of gross revenues allocated to
program expenditures	44
Table 8.  Ranking of the total percentage
of minority employees relative
to the percentage of minorities in the SMSA	53
Table 9.  Ranking of the percentage
of minorities employed in high pay
positions	57
Table 10.  Ranking of the percentage
of women employed in high pay
positions	59
Table 11.  National total of full time,
minority and women employees of
affiliates in the study in 1972	64
Table 12.  Stations reporting fewer than
5 minority employees in 1972	64
Table 13.  Total full time, minority and
women employees in high pay
positions in 1972	65
Table 14a.  Stations employing 0 or 1
minorities in high pay positions in
1972	65
Table 14b.  Stations employing 0 or 1
women in high pay positions in 1972	65
Table 15.  Stations showing a decrease
in employment of minorities or
women in 1972	66
Table 16.  Cross reference of owners to call letters	74
Table 17.  Ownership Information	77

CREDITS

This report is very much the product of a multi-group effort.  The groups involved included my own staff, a group of Georgetown University law students in a seminar I was teaching, FCC employees outside of my office, and guests appearing before the seminar.

After the markets and stations were selected, decisions had to be made as to which categories of data to include and exclude, and the analyses to which they should be subjected.  The data had to be extracted from FCC files.  Computer programs were written.  Additional research, writing and editing produced the text.  The text and charts were laid out and typed many times.  Each of these tasks involved uncounted hours of labor.

The principal participants in my own office were Larry Gage and Elaine Weiss.  It was they who did the lion's share of the administration of the group effort, following up on the thousands of details necessary to the project's timely completion, editing the seminar students' contribution, and adding their own substantial segments of text.  Karen Possner, a doctoral candidate in Communications at the University of Iowa, made valuable contributions to the seminar sessions and this report.  Chuck Shepherd helped out with some of the charts.  Bonnie Herbert and Karen Margrave bore the considerable burdens of typing and preparing this substantial manuscript at a time when their normal tasks were especially heavy.

The Georgetown law students were: Phil Argento, Thomas J. Collin, Raymond C. Fay, Ronald G. Gabler, Larry Harbin, Karen B. Possner, Lucilla A. Streeter, James R. Tanfield, David Wagner, James B. Wilcox, Jr. and Brady Williamson.  They participated in my seminar with the advance knowledge that the burdens would be substantial and executed the assignment with great ability and good spirits.  Derrick A. Humphries participated in the first two months of the seminar.  The contribution of Larry Harbin in preparing and executing our computer programs warrants special mention.

Those FCC employees outside of my office who gave us invaluable assistance include: Pearl Cook, Larry Eads, John Foret, Alex Korn, Quentin Proctor, Allan Stillwell, Wally Johnson, David Westin and Harold Kassens.  We very much appreciate their cooperation -- occasionally requiring their staying well beyond the FCC's normal 4:30 pm. closing time.

Seminar guests who gave us an evening of their time included: Sam Buffone, a former seminar student and currently an associate in Stern Concern; former FCC Commissioner Kenneth A. Cox; former FCC General Counsel Henry Geller, currently with the Rand Corporation; Dr. Everett Parker, Director of the United Church of Christ Office of Communications; Tracy Westen, a former legal assistant of mine and currently Director of Stern Concern; and Dr. Clay T. Whitehead, Director of the White House Office of Telecommunications Policy -- as well as most of the FCC employees mentioned above.  Each contributed in his or her own way to the seminar participants' understanding of the performance and regulation of broadcasting in America.

The other friends and advisors who have had some input during the past seven years to my thinking about broadcast regulation in general and this approach to it in particular are too numerous to itemize but are no less important to the end product.

With thousands of pieces of data copied and handled many times, there are undoubtedly errors somewhere in this report.  All I can say is that we have done our best to keep such errors to an absolute minimum and express our regrets in advance to any broadcaster who has been adversely affected by such error.

NICHOLAS JOHNSON, Washington, D.C.

June 1973

INTRODUCTION

The revelations surrounding Watergate have only dramatized what many concerned citizens and public interest lawyers have known for a long time: we cannot rely on government to solve our problems.  The regulatory agencies set up to serve the public interest all too often end up almost totally subservient to industry pressure.

Whatever may be the case elsewhere, however, the Federal Communications Commission is a classic case of what now Chief Justice Burger once called "a curious neutrality in favor of the licensee." n1

n1 Office of Communication of the United Church of Christ v. Federal Communications Commission, 359 F 2d 994 (D.C. Cir. 1966).

Seemingly congenital pro-industry bias, of course, is no reason to give up on the agency.  Quite the contrary.  It must be watched all the more closely.  There must be appeals to the courts and Congressional and press exposes of the FCC's most egregious decisions.  There must be public participation in license renewal hearings, fairness doctrine complaints, FCC rule makings, Congressional hearings involving the agency, and so forth.  Still, it is only the better part of wisdom and imagination to try to come up with alternatives to government at the same time efforts are being made to maximize the potential of the FCC.

One such alternative is represented by this report.  It is, quite simply, an effort to use public disclosure of broadcasters' performance, and comparative rankings of those broadcasters, as a means of rewarding the better stations and punishing the worst.

It is true, of course, that this analysis of what is, after all, FCC data, may attract the attention of FCC staff or Commissioners, or may provide an incentive to outraged citizens to file license renewal challenges against the worst stations.  This report may be more seriously considered by broadcasters because they are aware of that potential threat.  But that is not the principal purpose of the report.  The major hope is simply that the mere publishing of this data will, standing alone, provide reinforcement for the better stations and an incentive to improvement by the worst.

It is true that an FCC Commissioner was involved in the preparation of this document.  But in many ways that should be irrelevant to its impact.  The data used is publicly available from the FCC's files.  And broadcasters have little to fear from the vote of one dissenting Commissioner on a seven-person Commission.  In short, this is the kind of study that any group should be able to do -- nationally, as this one, or locally, and in more depth.

This report represents the attempt of one Commissioner, his staff, and seminar students to analyze the performance of each of the network affiliates in the top fifty television markets in the country.  Because the findings are presented in the form of rankings of those stations, in areas of performance from employment to programming, it is perhaps fitting to begin the report with the overall composite ranking of the affiliates with regard to their programming performance.

Quite simply, this table ranks each of the stations in the study based on a composite of all of the programming criteria analyzed in Chapter one.  In this table KPIX-TV, San Francisco, ranks as the best-programmed station in the top fifty markets, and WCCB, Charlotte, N.C., ranks as the worst.

TABLE 1. -- Network affiliates ranked by composite of all programming criteria

Rank	Call letters	Net. aff.	Mkt. No,	Location
1	KPIX	CBS	8	San Francisco
2	WJZ	ABC	19	Baltimore
3	KING	NBC	16	Seattle-Tacoma
4	KDKA	CBS	9	Pittsburgh
5	KYW	NBC	4	Philadelphia
6	WPLG	ABC	18	Miami
7	WMAL	ABC	10	Washington D.C.
8	WTAE	ABC	9	Pittsburgh
9	WFMY	CBS	48	Gnsb-High Pt-Win Sal
10	KGW	NBC	26	Portland
11	WWL	CBS	31	New Orleans
12	WRC	NBC	10	Washington D.C.
13	WABC	ABC	1	New York City
14	KNBC	NBC	2	Los Angeles
15	WIIC	NBC	9	Pittsburgh
16	WTIC	CBS	22	Hartford-New Haven
17	WNAC	ABC	6	Boston
18	KATU	ABC	26	Portland
19	WHAS	CBS	36	Louisville
20	KCRA	NBC	27	Sacramento-Stockton
21	KOIN	CBS	26	Portland
22	WBNS	CBS	28	Columbus
23	KTAR	NBC	45	Phoenix
24	KOMO	ABC	16	Seattle-Tacoma
25	WLWT	NBC	20	Cincinnati
26	WCBS	CBS	1	New York City
27	KMOX	CBS	12	St Louis
28	WSM	NBC	30	Nashville
29	WKY	NBC	41	Oklahoma City
30	WAST	ABC	37	Albany-Schenectady-T
31	WSB	NBC	17	Atlanta
32	WBZ	NBC	6	Boston
33	KSL	CBS	50	Salt Lake City
34	WMAR	CBS	19	Baltimore
35	WZZM	ABC	41	Kalamazoo-Gr Rapids
36	WDSU	NBC	31	New Orleans
37	WRTV	NBC	14	Indianapolis
38	WBFN	CBS	25	Buffalo
39	WNBC	NBC	1	New York City
40	KNXT	CBS	2	Los Angeles
41	KPRC	NBC	15	Houston
42	WCPO	CBS	20	Cincinnati
43	WMAQ	NBC	3	Chicago
44	KOVR	ABC	27	Sacramento-Stockton
45	WITI	ABC	21	Milwaukee
46	WCAU	CBS	4	Philadelphia
47	WSYR	NBC	43	Syracuse
48	WBAL	NBC	19	Baltimore
49	WBRC	ABC	38	Birmingham
50	WPVI	ABC	4	Philadelphia
51	WPRI	CBS	34	Providence
52	WAPI	NBC	38	Birmingham
53	KUTV	NBC	50	Salt Lake City
54	KWTV	CBS	41	Oklahoma City
55	WTOP	CBS	10	Washington D.C.
56	WCKT	NBC	18	Miami
57	WSOC	NBC	35	Charlotte
58	WOAI	NBC	45	San Antonio
59	KSTP	NBC	13	Minneapolis-St Paul
60	WAGA	CBS	17	Atlanta
61	WSIX	ABC	30	Nashville
62	WOTV	NBC	41	Kalamazoo-Gr Rapids
63	WXII	NBC	48	Gnsb-High Pt-Win Sal
64	KTRK	ABC	15	Houston
65	WLWI	ABC	14	Indianapolis
66	KSD	NBC	12	St Louis
67	WTVJ	CBS	18	Miami
68	KTVI	ABC	12	St Louis
69	WWJ	NBC	5	Detroit
70	KHOU	CBS	15	Houston
71	WLCY	ABC	24	Tampa-St Petersburg
72	WFBC	NBC	40	Gnville-Sptnbg-Ashvi
73	WKBW	ABC	25	Buffalo
74	WTMJ	NBC	21	Milwaukee
75	WBBM	CBS	3	Chicago
76	KGO	ABC	8	San Francisco
77	WJW	CBS	7	Cleveland
78	KSAT	ABC	45	San Antonio
79	WVUE	ABC	31	New Orleans
80	WTVT	CBS	24	Tampa-St Petersburg
81	WAVY	NBC	44	Norf-Newp News-Hamp
82	WBTV	CBS	35	Charlotte
83	WLWD	NBC	39	Dayton
84	WCCO	CBS	13	Minneapolis-St Paul
85	WFAA	ABC	11	Dallas-Fort Worth
86	WLAC	CBS	30	Nashville
87	KCMO	CBS	23	Kansas City
88	WTEV	ABC	34	Providence
89	WMC	NBC	29	Memphis
90	WTEN	CBS	37	Albany-Schenectady-T
91	KOCO	ABC	41	Oklahoma City
92	WLKY *	ABC	36	Louisville
93	WBAP	NBC	11	Dallas-Fort Worth
94	WJAR	NBC	34	Providence
95	WTNH	ABC	22	Hartford-New Haven
96	KFMB	CBS	49	San Diego
97	KTVK	ABC	45	Phoenix
98	WTOL	CBS	45	Toledo
99	KMGH	CBS	32	Denver
100	WDHO *	ABC	45	Toledo
101	KDFW	CBS	11	Dallas-Fort Worth
102	KABC	ABC	2	Los Angeles
103	WHNB *	NBC	22	Hartford-New Haven
104	WISH	CBS	14	Indianapolis
105	KXTV	CBS	27	Sacramento-Stockton
106	WAVE	NBC	36	Louisville
107	WNYS	ABC	43	Syracuse
108	WHEN	CBS	43	Syracuse
109	KCPX	ABC	50	Salt Lake City
110	WHTN	ABC	33	Charleston-Huntingto
111	WLOS	ABC	40	Gnville-Sptnbg-Ashvi
112	KGTV	NBC	49	San Diego
113	KOA	NBC	32	Denver
114	KIRO	CBS	16	Seattle-Tacoma
115	WLS	ABC	3	Chicago
116	WKYC	NBC	7	Cleveland
117	WXYZ	ABC	5	Detroit
118	WRGB	NBC	37	Albany-Schenectady-T
119	WSPD	NBC	45	Toledo
120	WKRC	ABC	20	Cincinnati
121	WCHS	CBS	33	Charleston-Huntingto
122	KNSP	ABC	13	Minneapolis-St Paul
123	WGR	NBC	25	Buffalo
124	WSAZ	NBC	33	Charleston-Huntingto
125	WEWS	ABC	7	Cleveland
126	WHIO	CBS	39	Dayton
127	WFLA	NBC	24	Tampa-St Petersburg
128	WREC	CBS	29	Memphis
129	WSPA	CBS	40	Gnville-Sptnbg-Ashvi
130	KENS	CBS	45	San Antonio
131	WLWC	NBC	28	Columbus
132	WISN	CBS	21	Milwaukee
133	WJBK	CBS	5	Detroit
134	WDAF	NBC	23	Kansas City
135	KMBC	ABC	23	Kansas City
136	WTVN	ABC	28	Columbus
137	WVEC	ABC	44	Norf-Newp News-Hamp
138	WKZO	CBS	41	Kalamazoo-Gr Rapids
139	WBMG *	CBS	38	Birmingham
140	KOOL	CBS	45	Phoenix
141	WHBQ	ABC	29	Memphis
142	KBTV	ABC	32	Denver
143	WQXI	ABC	17	Atlanta
144	WCCB *	ABC	35	Charlotte

* Denotes UHF network affiliate.

This report represents an effort to do more than just charge the Commission once again with the refusal to develop any positive standards for the performance of its broadcast licensees.  Such charges have often been made, in any different forums.  This is an effort to demonstrate the type of analysis that could be made of the available indicia of a licensee's performance prior to the renewal of its right to profit from the public airwaves.

The Commission has often been confronted with the opportunity to develop minimum standards in areas of programming, ownership and employment.  Each time those standards have either been rejected or thoroughly emasculated by the Commission majority.  n2 When former Commissioner Kenneth A. Cox was Chief of the Broadcast Bureau, he sent letters to stations with percentages of news and public affairs programming below certain minimum levels -- a practice swiftly ended by the full Commission. 

n2 The most celebrated, of course, was the 1946 "Blue Book," Part II, which attempted for the first time to set minimum standards for service to the public; it did not last the decade.  It is reprinted in F. Kahn, ed., Documents of American Broadcasting 141-146 (rev'd. ed. 1972).  Most recently, former Commission General Counsel Henry Geller proposed a minimum level of performance below which a broadcaster would be questioned at renewal time; his proposal -- that broadcasters program at least 15% local, 10% news and 5% public affairs, both overall and in prime time -- was never seriously considered by the Commission majority.

The major problem seems to arise from the broadcasters' (and most Commissioners') refusal to accept the fact that there is most emphatically a difference between censorship of programming, which the Communications Act of 1934 specifically prohibits, n3 and assurance of adequate levels of service in areas important to the listening or viewing public regardless of the subject matter or content of the programming presented.  n4

n3 47 U.S.C. §  326.

n4 For an excellent explication of the broadcaster's point of view, see Kalven, "Broadcasting, Public Policy and the First Amendment," 10 J. Law & Econ. 15 (1967).

When Kenneth Cox was an FCC Commissioner he attempted to come up with some method at license renewal time for determining whether or not a licensee had adequately served the public interest -- or whether it deserved further inquiry because of poor performance.  One simple standard used the data available on the license renewal form.  It merely required the licensee to demonstrate that 5% of its program week had been devoted to news, 1% to public affairs, and 5% to "other" non-entertainment programming (which came to be known as the "5-1-5" standard) -- far too low, especially for television licensees.

Other approaches were also tried.  The occasion of the Oklahoma renewals (all the licenses in any given state expire at the same time) was used to do a book-length study of broadcasting in the state of Oklahoma, describing the communities in detail, noting the various sources of information available, from print as well as broadcast media, and generally describing the performance of the licensees seeking renewal at that time.  n5

n5 Renewal of Standard Broadcast and Television Licenses, an Oklahoma Case Study, 14 F.C.C. 2d 1 (1968).

Later, in the state of New York, n6 and for the renewals processed jointly from Washington, D.C., Maryland and Virginia, n7 still another approach was used.  Stations were ranked by all the criteria available from their license renewal form -- news and public affairs, the number of public service announcements, and so forth -- in a manner that is similar in some ways to the procedure of this larger study of network affiliates. 

n6 Renewal of Standard Broadcast and Television Licenses, 18 F.C.C. 2d 268, 269, 322 (1969).

n7 Renewals of Standard Broadcast and Television Licenses, 21 F.C.C. 2d 35 (1969).

The impact of each of these efforts upon the Commission was minimal, although it has recently adopted a badly-needed new renewal application which somewhat improves the quality of the data collected from licensees.  n8 It has not, however, acted favorably on any proposals for minimum standards on that information.  n9

n8 In the Matter of Formulation of Rules and Policies Relating to the Renewal of Broadcast Licensees, Docket No. 19153, FCC 73-451 (May 4, 1973).

n9 For example, see the Henry Geller proposal discussed in note 2 supra.

The impact upon the industry, however, has been somewhat more significant, and has been a motivating factor in this study.  For example, even though broadcasters and their lawyers know that a failure to meet the 5-1-5 standard will have no effect whatsoever upon license renewals, they are increasingly programming to meet those standards if only because they dislike even the minimal adverse attention of a dissenting opinion buried deep within the official FCC Reports.  When the New York and Washington studies were published, broadcasters were quite pleased to attract public and advertiser attention to their high ratings -- and very quick to call Commissioners' attention to any miscalculation that resulted in even a slightly lower rating than they felt they deserved.

In attempting to mount a project that would have an effect on as wide a segment of American broadcasting as possible, there has been great selectivity in both the stations chosen and the criteria used.  It would have been impossible to evaluate each and every one of the more than 8,000 radio and television stations in this country.  First, television was chosen over radio, because its influence is more widely felt and also, quite frankly, because it was an easy way to eliminate the vast majority of licensees at the outset.  The 50 largest television markets in the country were selected from among the some 12,000 communities in the United States, because they contain more than 65% of the American population and constitute the most "cost effective" focus.  n10 The "top 50" have often been selected by the FCC as a natural break in its broadcasting regulations.  Finally, the three network affiliates in each market were selected (rather than including independent television stations as well) because those are the choice of roughly 85% of the nation's viewers at any given moment.  n11 Moreover, as they tend to have the largest revenue of any stations in the industry, one can fairly hold them to the highest standards.  Theoretically, then, that produces a population of some 150 stations (three network affiliates in each of 50 markets).  However, factors intervened to reduce the final sample to 144, although for some purposes (such as employment there was information available on 147.  n12

n10 The "top 50 markets" used in this study were determined on the basis of the most recent rankings by the American Research Bureau, published in ARB's 1972 Television Market Analysis on November 20, 1972.  No more current data will be published until after September 1, 1973.  The market's rank is determined according to the average number of households reached from 9 a.m. to midnight within a survey area.  Survey areas are the geographic areas comprised of those counties in which ARB estimates 98% of the net weekly circulation of home market stations occurs.  Because the average number of households is reported by thousands, two markets are tied for the 41st rank and three are tied for the 45th.  Accordingly, we list no 42nd, 46th or 47th rank.

The only exception to ARB's top 50 markets was our deletion of Wilkes Barre-Scranton, which would have been number 49, from our study and the concomitant elevation of Salt Lake City, otherwise market number 51.  This was done because we felt it unfair to compare the results in Wilkes Barre-Scranton, an all-UHF market, with those of its VHF competitors, even though we retained five markets in which one network affiliate broadcasts on UHF (they are appropriately identified in the rankings).

The top 50 markets include parts of some 43 different states and help send over 82% of the members of the House of Representatives to Congress.

n11 That is not to say there aren't a few enormously successful independents that should have been included in a study of America's biggest broadcasters.  However, we felt we had to draw the line somewhere, and we could not have justified the inclusion of independents in less than all the top 50 markets.

n12 Three network affiliates located in the top 50 markets were eliminated from our study.  Three additional stations were excluded from the over-all ranking and public service announcement portions of our report, but were included in the employment and ownership portions.  The details are listed below:

Call sign	KSCT
Channel	39
Affiliation	ABC
City	San Diego
Market number	49
Excluded from	Entire Study
KSCT became San Diego's ABC
affiliate early this year.  Prior to this, XETV, a
Mexican station, was the ABC affiliate.
The Commission has no jurisdiction over,
and therefore no data pertaining to,
broadcasters outside the U.S.
Call sign	KRON
Channel	4
Affiliation	NBC
City	San Francisco
Market Number	8
Excluded from	Entire Study
KRON's 1968 renewal was designated
for hearing on 3/19/69; a final decision
was not made until 5/3/73.  During
this period, the station was "in docket" and
not required to submit renewal application
information.  Thus, we had no more recent
data than that reflecting the station's
performance between 1965 and 1968.
Call sign	WCVB
Channel	5
Affiliation	ABC
City	Boston
Market number	6
Excluded from	Entire Study
WCVB is just barely into its second
year of operation after a Commission and
court battle that lasted nearly a decade;
its licensee was a successful competing
applicant for the frequency formerly
licensed to WHDH, Inc.
Call sign	WGHP
Channel	8
Affiliation	ABC
City	Greensboro
Market number	48
Excluded from	Composite ranking and public service announcements only
WGHP was renewed in 1966, but its
1969 renewal application was designated for
hearing on 6/1/70.  As yet unresolved,
the most recent renewal application data
reflects the station's performance between
1963 and 1966.
Call sign	WKEF
Channel	22
Affiliation	ABC
City	Dayton
Market number	39
Excluded from	Composite ranking and public service announcements only
WKEF is a new UHF station which
only commenced operation in 1969.
Call sign	WTAR
Channel	3
Affiliation	CBS
City	Norfolk
Market number	44
Excluded from	Composite ranking and public service announcements only
WTAR was renewed in 1966, but its
1969 renewal application was designated for
hearing on 1/21/70.  As yet unresolved,
the most recent renewal application data
reflects the station's performance between
1963 and 1966.

As an additional footnote, we wish to underscore the competitive problems faced by the five UHF affiliates that have been included in our study (WLKY, Louisville, 91st in our composite programming ranking; WDHO, Toledo, 100th; WHNB, Hartford, 103rd; WBMG, Birmingham, 139th; and WCCB, Charlotte, 144th).  UHF stations are traditionally at a severe disadvantage in competing for viewers in a market, even when they are affiliated with a network.  Virtually all UHF stations operate deeply in the red for years after they go on the air, and it can be expected that their performance will radically improve as they edge toward profitability.  Finally, it must be noted that at least one of the UHF stations in this study, WDHO, Toledo, has been ranked on the basis of data submitted to the FCC before it had acquired even the financial stimulus of a network affiliation.

The analysis of the performance of those stations has been limited to information supplied by the broadcasters themselves on official U.S. Government forms in public files at the FCC.  n13 No monitoring (viewing or listening) of any of the stations was undertaken.  Nor was there even an examination of TV Guide or local newspaper listings for additional information.  There was neither the time nor the manpower, and there was an affirmative desire to avoid any data gathering or subjective analyses that would subject the findings to "tis-taint't" arguments with broadcasters. 

n13 In order to provide the broadest possible view of television in the top 50 markets, it was occasionally necessary to use station data reported by former licensees.  For example, if a station received its license renewal in June, 1972, and was sold in August, 1972, our data was taken from the information of the earlier licensee.  This was the case with the seven stations listed below:

KBTV, Channel 9, ABC, Denver, Colorado.

Present licensee: Combined Communications Corp.

Former licensee: Mullins Broadcasting Co.

Date of change: September 19, 1972

KGTV, Channel 10, NBC, San Diego, California

Present licensee: McGraw-Hill Broadcasting Co.

Former licensee: Time-Life Broadcasting, Inc.

Date of change: June 1, 1972

Former call letters: KOGO

KMGH, Channel 7, CBS, Denver, Colorado

Present licensee: McGraw-Hill.

Former licensee: Time-Life.

Date of change: June 1, 1972

Former call letters: KLZ

KOCO, Channel 5, ABC, Oklahoma City

Present licensee: Combined Communications

Former licensee: Cimaron Television Corp.

Date of change: August 29, 1972

WCHS, Channel 8, CBS, Charleston-Huntington, W. Va.

Present licensee: Rollins Telecasting, Inc.

Former licensee: WCHS AM-TV Corp.

Date of change: April 30, 1973

WRTV, Channel 6, WBC, Indianapolis

Present licensee: McGraw-Hill

Former licensee: Time-Life

Date of change: June 1, 1972

Former call letters: WFMB

WTMJ, Channel 4, NBC, Milwaukee

Present licensee: WTMJ, Inc.

Former licensee: The Journal Co.

In addition, data other than form 303 programming data from the seven stations listed below was partially affected by similar changes in licensees:

Financial and Employment Data:

WXII, Channel 12, NBC, Greensboro/Winston Salem/High Point, N.C.

Present licensee: Multimedia, Inc.

Former licensee: Triangle Broadcasting Corp.

Date of change: October 2, 1972

WBTV, Channel 3, CBS, Charlotte, N. Carolina

Present licensee: Jefferson-Pilot Broadcasting Co.

Former licensee: Jefferson-Standard Broadcasting Co.

Date of change: November 7, 1972

WDSU, Channel 6, NBC, New Orleans

Present licensee: Cosmos Broadcasting of Louisiana

Former licensee: WDSU-TV, Inc.

Date of charge: November 29, 1972

Financial data only (taken partially from former and partially from present licensee):

WPVI, Channel 6, ABC, Philadelphia

Present: Capital Cities

Former: Triangle Publications

Date of change: April 27, 1971

WSAZ, Channel 3, NBC, Charleston-Huntington, W. Va.

Present licensee: Lee Enterprises, Inc.

Former licensee: Capital Cities

Date of change: April 27, 1971

WTEN, Channel 10, CBS, Albany-Schenectady-Troy, N.Y.

Present licensee: Albany TV, Inc.

Former licensee: Capital Cities

Date of change: April 27, 1971

WTNH, Channel 8, ABC, Hartford/New Haven

Present licensee: Capital Cities

Former licensee: Triangle Publications

Date of change: April 27, 1971

Finally, station WWYS-TV, Syracuse, New York, was granted a modification on December 12, 1972 that changed the name of the licensee from WRG Baker Television Corp. to WNYS-TV.  The actual owners of the station remained substantially the same.  And station WOTV, Grand Rapids-Kalamazoo was granted a change of call letters on July 1, 1972, from WOOD, although the licensee also remains the same.

The findings are grouped into three separate chapters dealing with programming performance, minority and female employment statistics, and ownership information.  A fourth chapter is devoted to the use of this information by interested community groups or individuals.  Appendices have been added that deal with the computer programming methodology, potential sources of information and assistance for those interested in pursuing the subject further, and additional information not included in the main body of the report.

The method of analyzing the stations' performance has been to select the most precise criteria available from the data collected and then simply rank the stations based on their performance.  Thus, in programming, some four factors were isolated and explored.  They were then combined for determination of a single overall ranking based on a composite computation of programming performance.

By this method, television station KPIX, San Francisco, owned by the Westinghouse Broadcasting Company, was the best-programmed station among network affiliates in the top 50 markets as of June, 1973; WCCB, Charlotte, N.C., was the worst.  There is often a wide range of performance among affiliates within a city.  But Pittsburgh and Portland would appear to be among the best, and Charleston-Huntington, W. Va., and Kansas City, Mo., among the worst.  Baltimore seems to have the best performance overall in local programming, Washington in news. public affairs and other; Syracuse scores lowest in both categories.  Oklahoma City stations have the most public service announcements; Nashville stations the fewest.  Westinghouse Broadcasting Company's five television stations ranked 1, 2, 4, 5 and 31, thus making Westinghouse by far the best multiple owner in the country.  The stations of Taft, ranked 49, 120, 123, 134 and 136, showed that corporate owner to be one of the worst.

In the employment chapter, stations with low or non-existent minority or female employment are singled out for special mention, and all the stations in the study are ranked on the basis of total employment as well as employment of minorities and women in high-paying positions.  Stations WTEV, Providence, WNYS, Syracuse, and WCAU, Philadelphia were among the best, while KSL, Salt Lake City, KMSP, Minneapolis and WKZO, Kalamazoo-Grand Rapids were among the worst.

In the ownership chapter, the findings have been collated and rearranged to show the performance of individual owners, especially when (as is most often the case) they own two or more stations.  In each section Commission policy is considered and its shortcomings pointed out, but the most important part of this report is the information regarding the relative performance of each network affiliate in the top 50 markets.  See Appendix D for a summary of the ten best and ten worst stations in each area of programming and employment and Appendix E for a summary of what we consider to be the minimum tolerable levels of performance in each of those areas.

Finally, Chapter 4 is included on the assumption that anyone interested in improving the quality of broadcasting in this country can use this study as a handbook for the further pursuit of those improvements.  This report is necessarily incomplete.  Only the action of concerned people in their own local communities can ensure that it will have maximum impact on improving broadcasters' performance.

Chapter 1

PROGRAMMING PERFORMANCE

I.  INTRODUCTION

The composite programming ranking announced in the Introduction to this report consists of an evaluation of the programming of each of 144 network affiliates in the top 50 markets on the basis of four distinct programming criteria: a combination of news, public affairs and other programming; local programming; commercialization; and allocation of financial resources to program expenditures.  Each of these areas will be explained in detail, and individual area rankings given, in the four sections of this chapter below.  The composite programming ranking that precedes the substantive discussion in this chapter was determined by transposing the quantitative performance of each licensee in each of the four areas onto a scale of 0 to 100, then weighting them equally in determining the final average on which the overall ranking was based.  For a more complete explanation of the analytical models used in this section, see Appendix A.  The programming criteria are presented in Table 2 in the form of the station's rank in each of the four areas.  For a composite ranking that presents the criteria based on the relative scale of 0 to 100, see Table 1-a in Appendix C.

Network affiliates ranked by composite of all programming criteria

	Call	Net.	Mkt.
Rank	letters	aff.	No.	Location
1	KPIX	CBS	8	San Francisco
2	WJZ	ABC	19	Baltimore
3	KING	NBC	16	Seattle-Tacoma
4	KDKA	CBS	9	Pittsburgh
5	KYW	NBC	4	Philadelphia
6	WPLG	ABC	18	Miami
7	WMAL	ABC	10	Washington, D.C.
8	WTAE	ABC	9	Pittsburgh
9	WFMY	CBS	48	Gnsb-HighPt-Win Sal
10	KGW	NBC	26	Portland
11	WWL	CBS	31	New Orleans
12	WTC	NBC	10	Washington, D.C.
13	WABC	ABC	1	New York City
14	KNBC	NBC	2	Los Angeles
15	WIIC	NBC	9	Pittsburgh
16	WTIC	CBS	22	Hartford-New Haven
17	WNAC	ABC	6	Boston
18	KATO	ABC	26	Portland
19	WHAS	CBS	36	Louisville
20	KCRA	NBC	27	Sacramento-Stockton
21	KOIN	CBS	26	Portland
22	WBNS	CBS	28	Columbus
23	KTAR	NBC	45	Phoenix
24	KOMO	ABC	16	Seattle-Tacoma
25	WLWT	NBC	20	Cincinnati
26	WCBS	CBS	1	New York City
27	KMOX	CBS	12	St. Louis
28	WSM	NBC	30	Nashville
29	WKY	NBC	41	Oklahoma City
30	WAST	ABC	37	Albany-Schenectady-T
31	WSB	NBC	17	Atlanta
31	WBZ	NBC	6	Boston
33	KSL	CBS	50	Salt Lake City
34	WMAR	CBS	19	Baltimore
35	WZZM	ABC	41	Kalamazoo-Gr Rapids
36	WDSU	NBC	31	New Orleans
37	WRTV	NBC	14	Indianapolis
38	WBEN	CBS	25	Buffalo
39	WNBC	NBC	1	New York City
40	KNXT	CBS	2	Los Angeles
41	KPRC	NBC	15	Houston
42	WCPO	CBS	20	Cincinnati
43	WMAQ	NBC	3	Chicago
44	KOVR	abc/	27	Sacramento-Stockton
45	WITI	ABC	21	Milwaukee
46	WCAU	CBS	4	Philadelphia
47	WSYR	NBC	43	Syracuse
48	WDAL	NBC	19	Baltimore
49	WBRC	ABC	38	Birmingham
50	WPVI	ABC	4	Philadelphia
51	WPRI	CBS	34	Providence
52	WAPI	NBC	38	Birmingham
53	KUTV	NBC	50	Salt Lake City
54	KWTV	CBS	41	Oklahoma City
55	WTOP	CBS	10	Washington D.C.
56	WCKT	NBC	18	Miami
57	WSOC	NBC	35	Charlotte
58	WOAI	NBC	45	San Antonio
59	KSTP	NBC	13	Minneapolis-St Paul
60	WAGA	CBS	17	Atlanta
61	WSIX	ABC	30	Nashville
62	WOTV	NBC	41	Kalamazoo-Gr Rapids
63	WXII	NBC	48	Gnsb-High Pt-Win Sal
64	KIRK	ABC	15	Houston
65	WLWI	ABC	14	Indianapolis
66	KSD	NBC	12	St. Louiis
66	WTVJ	CBS	18	Miami
68	KTVI	ABC	12	St. Louis
69	WWJ	NBC	5	Detroit
70	KHOU	CBS	15	Houston
71	WLCY	ABC	24	Tampa-St. Petersburg
72	WFBC	NBC	40	Gnville-Sptnbg-Ashvi
73	WKBW	ABC	25	Buffalo
74	WTMJ	NBC	21	Milwaukee
74	WBBM	CBS	3	Chicago
76	KGO	ABC	8	San Antonio
77	WJW	CBS	7	Cleveland
78	KSAT	ABC	45	San Antonio
79	WVUE	ABC	31	New Orleans
80	WTVT	CBS	24	Tampa-St. Petersburg
81	WAVY	NBC	44	Norf-Newp News-Hamp
82	WBTV	CBS	35	Charlotte
83	WLWD	NBC	39	Dayton
84	WCCO	CBS	13	Minneapolis-St. Paul
85	WFAA	ABC	11	Dallas-Fort Worth
86	WLAC	CBS	30	Nashville
87	KCMO	ABC	23	Kansas City
88	WTFV	ABC	34	Providence
89	WMC	NBC	29	Memphis
90	WTEN	CBS	37	Albany-Schenectady-T
91	KOCO	ABC	41	Oklahoma City
92	WLKY	ABC	36	Louisville
93	WBAP	NBC	11	Dallas-Fort Worth
94	WJAR	NBC	34	Providence
95	WTNH	ABC	22	Hartford-New Haven
96	KFMB	CBS	49	San Diego
97	KTVK	ABC	45	Phoenix
98	WTOL	CBS	45	Toledo
99	KMGH	CBS	32	Denver
100	WDHO	ABC	45	Toledo
101	KDFW	CBS	11	Dallas-Fort Worth
102	KABC	ABC	2	Los Angeles
103	WHNB	NBC	22	Hartford-New Haven
104	WISH	CBS	14	Indianapolis
105	KXTV	CBS	27	Sacramento-Stockton
106	WAVE	NBC	36	Louisville
107	WNYS	ABC	43	Syracuse
108	WHEN	CBS	43	Syracuse
109	KCPX	ABC	50	Salt Lake City
110	WHTN	ABC	33	Charleston-Huntington
111	WLOS	ABC	40	Gnville-Sptnbg-Ashvi
112	KGTV	NBC	49	San Diego
113	KOA	NBC	32	Denver
114	KIRO	CBS	16	Seattle-Tacoma
115	WLS	ABC	3	Chicago
116	WKYC	NBC	7	Cleveland
117	WXYZ	ABC	5	Detroit
118	WRGB	NBC	37	Albany-Schenectady-T
119	WSPD	NBC	45	Toledo
120	WKRC	ABC	20	Cincinnati
121	WCHS	CBS	33	Charleston-Huntington
122	KMSP	ABC	13	Minneapolis-St. Paul
123	WGR	NBC	25	Buffalo
124	WSAZ	NBC	33	Charleston-Huntington
125	WEWS	ABC	7	Cleveland
126	WHIO	CBS	39	Dayton
127	WFLA	NBC	24	Tampa-St. Petersburg
128	WREC	CBS	29	Memphis
129	WSPA	CBS	40	Gnville-Sptnbg-Ashvi
130	KENS	CBS	45	San Antonio
131	WLWC	NBC	28	Columbus
132	WISN	CBS	21	Milwaukee
133	WJBK	CBS	5	Detroit
134	WDAF	NBC	23	Kansas City
135	KMBC	ABC	23	Kansas City
136	WTVN	ABC	28	Columbus
137	WVEC	ABC	44	Norf-Newp News-Hamp
138	WKZO	CBS	41	Kalamazoo-Gr Rapids
139	WBMG	CBS	38	Birmingham
140	KOOL	CBS	45	Phoenix
141	WHBQ	ABC	29	Memphis
142	KBTV	ABC	32	Denver
143	WQXI	ABC	17	Atlanta
144	WCCB	ABC	35	Charlotte

		News,	Commer.	Financial
Rank	Local	Pa
		and other
1	31	13	1	103
2	6	59	4	24
3	76	48	6	3
4	4	6	30	57
5	2	7	23	123
6	10	1	81	52
7	28	40	41	9
8	52	60	10	15
9	96	38	2	76
10	67	35	49	2
11	7	24	70	31
12	49	15	101	7
13	63	77	49	1
14	3	3	138	35
15	17	53	101	8
16	68	28	5	110
17	37	41	24	59
18	50	96	24	13
19	35	84	33	20
20	27	14	70	69
21	84	29	57	12
22	22	19	81	61
23	8	64	63	48
24	32	66	57	28
25	1	118	129	44
26	75	4	108	27
27	59	11	101	36
28	24	97	63	16
29	16	78	36	70
30	135	119	8	4
31	5	56	49	116
31	15	16	49	138
33	57	90	88	6
34	11	25	78	104
35	112	45	41	14
36	20	55	81	55
37	65	39	36	64
38	55	21	57	80
39	60	17	88	58
40	21	8	121	88
41	29	22	78	94
42	40	49	98	33
43	41	2	132	74
44	134	120	16	5
45	72	111	16	41
46	42	9	121	73
47	117	127	13	10
48	19	33	88	101
49	23	12	49	144
50	14	62	112	45
51	115	94	3	113
52	126	46	16	63
53	83	104	63	11
54	77	82	70	25
55	79	10	117	50
56	71	27	41	117
57	122	75	16	47
58	58	88	30	93
59	43	91	57	71
60	70	5	121	79
61	82	125	30	22
62	48	37	106	67
63	118	105	28	21
64	18	95	63	100
65	64	26	129	37
66	36	68	70	108
66	105	87	33	46
68	86	140	24	19
69	9	31	129	112
70	25	30	108	127
71	61	44	81	96
72	104	63	13	130
73	78	106	13	130
74	13	92	106	89
74	33	18	141	65
76	94	70	98	30
77	69	43	101	77
78	90	131	28	38
79	107	112	41	34
80	80	32	117	51
81	121	54	36	84
82	46	52	88	120
83	30	42	137	83
84	12	74	139	72
85	47	114	70	85
86	39	101	114	49
87	54	69	101	97
88	130	110	41	32
89	38	80	114	92
90	110	103	70	39
91	62	124	81	53
92	136	142	11	23
93	132	50	36	115
94	114	47	70	91
95	81	81	57	124
96	51	20	132	128
97	88	122	49	75
98	87	71	63	122
99	44	73	117	98
100	139	144	6	29
101	26	34	121	141
102	123	115	88	17
103	116	23	63	136
104	73	65	78	135
105	101	36	121	66
106	95	85	88	86
107	144	143	8	18
108	127	89	88	54
109	142	136	16	40
110	140	107	16	102
111	143	137	12	60
112	111	102	88	62
113	56	79	108	132
114	66	83	108	125
115	53	61	142	68
116	113	86	121	43
117	89	116	132	26
118	100	121	36	129
119	124	113	41	107
120	74	138	33	133
121	85	132	24	140
122	109	141	13	126
123	141	109	41	81
124	119	58	70	139
125	92	134	98	56
126	45	123	132	87
127	120	51	132	78
128	131	108	57	114
129	103	57	117	121
130	106	93	81	134
131	99	67	121	118
132	97	98	121	82
133	93	99	114	106
134	34	72	144	131
135	102	133	88	90
136	128	130	63	105
137	137	135	41	95
138	108	100	88	142
139	125	117	49	143
140	98	76	140	119
141	138	139	49	111
142	91	128	142	42
143	129	126	112	99
144	133	129	81	137

II.  NEWS AND PUBLIC AFFAIRS

"60 per cent of all Americans over the age of 21 rely on television as their primary source of news." Barry Cole, Television (1970).

To argue that Congress intended television to be dedicated summarily to the aggrandizement of the personal or corporate fortunes of its licensees is to argue the absurd.  Rather, Congress intended that television frequencies be used to serve the public, n1 and any reasonable interpretation of "serving the public" must include equipping them to be better citizens, via the informational programming most often encountered in the rather cumbersome categories known to the Commission as "news," "public affairs" and "other." n2

n1 See 47 U.S.C. §  307(a)(b).  Indeed, the Commission stated early in its development that:

It is axiomatic that one of the most vital questions of mass communications in a democracy is the development of an informed public opinion through the public dissemination of news and ideas concerning the vital issues of the day...  It is this right of the public to be informed, rather than any other right on the part of the government, any broadcast licensee or any individual member of the public to broadcast his own particular views of any matter, which is the foundation stone of the American system of broadcasting.

Quoted in Walter Emery, National and International Systems of Broadcasting, at 13, Michigan State University Press (1969).  For legislative history of the Communications Act, see Rosenbloom, "Authority of the Federal Communications Commission," in Coons, ed., Freedom and Responsibility in Broadcasting at 96 (1961).

n2 The categories of "news" and "public affairs" are self-explanatory.  "Other" programming is described as all programming not falling in those two categories or in the categories of "entertainment" or "sports."

The Commission first determined that news and public affairs were "critical programming categories" and began collecting this data in its current form in 1966, when it adopted the license renewal application now in use.  n3 But collecting this data and putting it to significant use are two entirely different things, and the practice of this Commission to date has been to make no inquiry whatsoever into a licensee's news, public affairs, and other non-sports, non-entertainment programming, no matter how badly a station had performed, and more than a few stations have been renewed notwithstanding a total failure to deliver programming in one or more of these categories.  n4 Even a major television station like WCCO-TV, a Minneapolis CBS affiliate, was renewed automatically in March, 1968, despite no public affairs shown during the composite week and only 30 minutes weekly proposed for the future. 

n3 FCC 2d 175 (1966).

n4 See, e.g., Herman C. Hall, 11 FCC 2d 344 (1968).

Although the Commission has never set standards in its renewal procedures for weighing the news and public affairs data it receives, a 5% news, 1% public affairs and 5% "other" standard thought to be comparable to the minimum diet necessary to stave off complete informational starvation was established and discussed at one time by just two of the seven Commissioners (Cox and Johnson).  n5 Since those standards have been so minimal and so easy to comply with, many previously offending broadcasters have made an effort to do so, as can be seen by a glance at the raw data in the three categories.  n6 There continues to be some, however, who do not choose even to provide that infinitesimal level of public service, who regularly devote more minutes of time to commercials than to the three informational categories combined; and yet the staff continues to do nothing every two months but provide, as a gesture of courtesy, a compilation of those stations falling below the 5-1-5 standard in each bimonthly "package" of renewals for the remaining concerned Commissioner to use in his lonely dissents. 

n5 See discussion of these studies at notes 5, 6 and 7 in the Introduction to this Report.

n6 The ten best and ten worst stations in each category may be found in Appendix D.

The news, public affairs, and other programming information required of a licensee on his renewal application is collected in the form of hours and minutes of air time devoted to each.  Of course, quality of programming cannot be determined from this data.  It is impossible to tell without actual observation, for example, whether a station's news operation is of the wire service "rip and read" variety or whether there are mobile camera units roaming the city to provide original feeds at all hours.  Until such information is available, however, we must rely on what the stations are required to tell the Commission quantitatively about their programming operations.  For, although a station broadcasting only 8 hours of news in a 140-hour week may in fact be investing more time, expense, and imagination in its production than one airing 14 hours in the same week, the only presumption we can make is the contrary -- the more news, the better the potential for service to the public.  We proceed therefore on the assumption that, all other factors being equal, a station running 14 hours of news on a weekly basis better serves the public interest and need than a station running 8 hours.  The same reasoning would apply to public affairs and other programming.

Another shortcoming of the existing renewal application is that it makes no inquiry into when during the broadcast day news, public affairs, and other programming are being aired.  It is conceivable, for example, that a station may air one hour of public affairs between 3:30 am and 4:30 am daily and, when this is added to its other public affairs programs, post a total of 10 hours for the week.  n7 It should be self-evident, however, that the seven hours of programming in the early morning can be written off as little more than no programming at all, reaching such a small audience as to be of virtually no service to the public.  This lacuna in our information must be borne in mind when reviewing these figures, and local program guides or station logs should be consulted to learn the distribution of news, public affairs and other programming in a particular station's broadcast week. 

n7 In addition, many commercial stations will run the same public affairs special more than once, thereby getting credit for two or even three hours of programming for just one show.

Our ranking of station programming performance is based solely on the hours of programming presented.  For the overall ranking of this performance factor, we have simply added together the number of hours and minutes of news, public affairs and other programming presented during the composite week and ranked the stations on the basis of that total.  We list the number of hours of each of the three categories separately, and provide a ranking for each.  For example, the top station in the overall news-public affairs-"other" ranking, station WPLG, Miami, can be seen to be number 9 in news, number 7 in public affairs and number 12 in other programming.  These additional statistics are provided in this chapter because a station's failure to devote substantial time to any one of them is indefensible whatever its overall raking, and such a station should be singled out for further inquiry.  n8

n8 WLWI, Indianapolis, for example, was number 26 in its overall news, public affairs and other ranking, due to a fine showing in the latter two categories (32nd and 4th).  Its news programming, however, placed it an abysmal 127th, thereby clearly delineating an area in which the licensee could improve.

Although the percentage of the total programming week devoted by a licensee to each of these categories is available from the station's license renewal form and has been used in similar studies in the past, n9 we have decided in this study to use the raw total of hours.  This has been done because the use of percentages, we feel, tends to favor those broadcasters with a shorter broadcast week.  For example, a station on the air 120 hours a week with 12 hours of news would be programming 10% news, while a station broadcasting 146 hours a week with 13 hours of news would actually show a lower percentage.  We feel the additional hours of news programmed by the latter should be given greater credit than the higher percentage of the former, and have acted accordingly. 

n9 See the studies cited in notes 5, 6, and 7 in the Introduction to this Report.

In addition to the hours of news, public affairs, and other programming broadcast by a station in the composite week, the disparity between a station's promised performance and its actual performance and the decrease (or increase) in performance levels from one renewal period to the next can also be revealing measures of a station's service.  Indeed, the Commission has said as much in a few specific instances in the past.  n10 And even the current Commission, which at one time or another has indicated that it favors the total elimination of existing Commission programming standards, concedes that a station's "promise vs. performance" is a valid indication of its performance in the public interest.  n11 While we have not attempted, due to the length of this study, to relate the licensees' most recent performance to either his current or his previous promises, the necessary information is readily available, in the licensee's public file or at the FCC for those who are interested. 

n10 See, e.g., WKBN Broadcasting Corp., 30 FCC 2d 958, 975 (1971); Southern Broadcasting Co., 26 FCC 2d 998 (1970); WMOZ, Inc., 36 FCC 201, 241 (1964); and KORD, Inc., 31 FCC 85, 88 (1961).

n11 See Letter from Clay T. Whitehead, Director of Office of Telecommunications Policy, to Rep. Carl Albert, March 13, 1973.

Network affiliates ranked by total hours of news, Public Affairs, and "Other" in composite week

Rank	Call letters	Net. aff.	Mkt. No.	Location	News and rank
1	WPLG	ABC	18	Miami	17.90	9
2	WMAQ	NBC	3	Chicago	19.98	4
3	KNBC	NBC	2	Los Angeles	22.00	1
4	WCBS	CBS	1	New York City	16.13	27
5	WAGA	CBS	17	Atlanta	17.72	12
6	KDKA	CBS	9	Pittsburgh	20.20	2
7	KYW	NBC	4	Philadelphia	18.55	6
8	KNXT	CBS	2	Los Angles	17.05	19
9	WCAU	CBS	4	Philadelphia	16.37	25
10	WTOP	CBS	10	Washington D.C.	172.12	17
11	KMOX	CBS	12	St. Louis	16.25	26
12	WBRC	ABC	38	Birmingham	13.97	54
13	KPIX	CBS	8	San Francisco	16.62	23
14	KCRA	NBC	27	Sacramento-Stockton	20.15	3
15	WRC	NBC	10	Washington D.C.	14.83	41
16	WBZ	NBC	6	Boston	18.53	7
17	WNBC	NBC	1	New York City	15.08	39
18	WBBM	CBS	3	Chicago	14.28	49
19	WBNS	CBS	28	Columbus	13.60	55
20	KFMB	CBS	49	San Diego	19.27	5
21	WBEN	CBS	25	Buffalo	15.90	30
22	KPRC	NBC	15	Houston	15.80	32
23	WHNB	NBC	22	Hartford-New Haven	15.20	36
24	WWL	CBS	31	New Orleans	16.77	20
25	WMAR	CBS	19	Baltimore	15.07	40
26	WLWI	ABC	14	Indianapolis	8.17	127
27	WCKT	NBC	18	Miami	14.37	46
28	WTIC	CBS	22	Hartford-New Haven	13.58	56
29	KOIN	CBS	26	Portland	14.03	53
30	KHOU	CBS	15	Houston	14.65	44
31	WWJ	NBC	5	Detroit	14.80	42
31	WTVT	CBS	24	Tampa-St. Petersburg	16.77	20
33	WBAL	NBC	19	Baltimore	14.07	52
34	KDFW	CBS	11	Dallas-Fort Worth	16.65	22
35	KGW	NBC	26	Portland	16.48	24
36	KXTV	CBS	27	Sacramento-Stockton	17.22	16
37	WOTV	NBC	41	Kalamazoo-Gr Rapids	14.68	43
38	WFMY	CBS	48	Gnsb-High Pt-Win Sal	12.82	67
39	WRTV	NBC	14	Indianapolis	12.62	69
40	WMAL	ABC	10	Washington D.C.	10.43	101
41	WNAC	ABC	6	Boston	11.43	84
42	WLWD	NBC	39	Dayton	11.83	74
43	WJW	CBS	7	Cleveland	11.57	81
43	WLCY	ABC	24	Tampa-St. Petersburg	8.08	129
45	WZZM	ABC	41	Kalamazoo-Gr Rapids	6.25	137
46	WAPI	NBC	38	Birmingham	15.63	33
47	WJAR	NBC	34	Providence	13.35	63
48	KING	NBC	16	Seattle-Tacoma	13.48	61
49	WCPO	CBS	20	Cincinnati	11.27	88
50	WBAP	NBC	11	Dallas-FortWorth	15.02	29
51	WFLA	NBC	24	Tampa-St. Petersburg	16.10	28
52	WBTV	CBS	35	Charlotte	15.13	38
53	WIIC	NBC	9	Pittsburgh	17.55	13
54	WAVY	NBC	44	Norf-Newp News-Hamp	13.50	58
55	WDSU	NBC	31	New Orleans	17.12	17
56	WSB	NBC	17	Atlanta	17.40	15
57	WSPA	CBS	40	Gnville-Sptnbg-Ashvi	11.32	87
58	WSAZ	NBC	33	Charleston-Huntington	14.37	46
59	WJZ	ABC	19	Baltimore	11.58	79
60	WTAE	ABC	9	Pittsburgh	11.82	75
61	WLS	ABC	3	Chicago	9.50	114
62	WPVI	ABC	4	Philadelphia	9.32	117
63	WFBC	NBC	40	Gnville-Sptnbg-Ashvi	11.33	86
64	KTAR	NBC	45	Phoenix	17.85	10
65	WISH	CBS	14	Indianapolis	18.42	8
66	KOMO	ABC	16	Seattle-Tacoma	12.88	66
66	WLWC	NBC	28	Columbus	9.33	116
68	KSD	NBC	12	St. Louis	17.47	14
69	KCMO	CBS	23	Kansas City	11.72	77
70	KGO	ABC	8	San Francisco	10.05	107
70	WIOL	CBS	45	Toledo	13.37	62
72	WDAF	NBC	23	Kansas City	17.75	11
73	KMGH	CBS	32	Denver	11.58	79
74	WCCO	CBS	13	Minneapolis-St. Paul	13.50	58
75	WSOC	NBC	35	Charlotte	13.50	58
76	KOOL	CBS	45	Phoenix	15.33	34
77	WABC	ABC	1	New York City	10.58	98
77	WKY	NBC	41	Oklahoma City	14.58	45
79	KOA	NBC	32	Denver	14.32	48
80	WMC	NBC	29	Memphis	15.82	31
81	WTNH	ABC	22	Hartford-New Haven	8.87	121
82	KWTV	CBS	41	Oklahoma City	12.25	72
83	KIRO	CBS	16	Seattle-Tacoma	14.23	50
84	WHAS	CBS	36	Louisville	15.27	35
85	WAVE	NBC	36	Louisville	11.47	82
86	WKYC	NBC	7	Cleveland	11.73	76
87	WTVJ	CBS	18	Miami	12.05	73
88	WOAI	NBC	45	San Antonio	15.17	37
89	WHEN	CBS	43	Syracuse	11.37	85
90	KSL	CBS	50	Salt Lake City	10.57	99
91	KSTP	NBC	13	Minneapolis-St. Paul	14.10	51
92	WIMJ	NBC	21	Milwaukee	12.40	71
93	KFNS	CBS	45	San Antonio	12.82	67
94	WPRI	CBS	34	Providence	12.98	65
95	KIRK	ABC	15	Houston	10.97	91
96	KATU	ABC	26	Portland	10.85	94
97	WSM	NBC	30	Nashville	13.00	64
98	WISN	CBS	21	Milwaukee	10.23	104
99	WJBK	CBS	5	Detroit	10.05	107
100	WKZO	CBS	41	Kalamazoo-Gr Rapids	8.58	124
101	WLAC	CBS	30	Nashville	10.83	95
102	KGTV	NBC	49	San Diego	13.57	57
103	WTEN	CBS	37	Albany-Schenectady-T	10.62	97
104	KUTV	NBC	50	Salt Lake City	10.32	102
105	WXII	NBC	48	Gnsb-High Pt-Win Sal	10.88	93
106	WKBW	ABC	25	Buffalo	8.75	123
107	WHTN	ABC	33	Charleston-Huntington	10.22	105
108	WREC	CBS	29	Memphis	11.05	89
109	WGR	NBC	25	Buffalo	10.50	100
110	WTEV	ABC	34	Providence	11.63	78
111	WITI	ABC	21	Milwaukee	9.55	113
112	WVUE	ABC	31	New Orleans	10.08	106
113	WSPD	NBC	45	Toledo	9.68	111
114	WFAA	ABC	11	Dallas-Fort Worth	12.62	69
115	KABC	ABC	22	Los Angeles	9.75	110
116	WXYZ	ABC	5	Detroit	10.30	103
117	WBMG	CBS	38	Birmingham	7.73	132
118	WLWT	NBC	20	Cincinnati	11.00	90
119	WAST	ABC	37	Albany-Schenectady-T	9.22	119
120	KOVR	ABC	27	Sacramento-Stockton	9.57	112
121	WRGB	NBC	37	Albany-Schenectady-T	11.47	82
122	KTVK	ABC	45	Phoenix	9.50	114
123	WHIO	CBS	39	Dayton	8.38	125
124	KOCO	ABC	41	Oklahoma City	8.00	130
125	WSIX	ABC	30	Nashville	5.35	141
126	WQXI	ABC	17	Atlanta	9.22	119
127	WSYR	NBC	43	Syracuse	9.25	118
128	KBTV	ABC	32	Denver	9.97	109
129	WCCB	ABC	35	Charlotte	5.08	142
130	WTVN	ABC	28	Columbus	7.42	133
131	KSAT	ABC	45	San Antonio	10.95	92
132	WCHS	CBS	33	Charleston-Huntington	8.85	122
133	KMBC	ABC	23	Kansas City	7.37	134
134	WEWS	ABC	7	Cleveland	8.12	128
135	WVEC	ABC	44	Norf-Newp News-Hamp	10.63	96
136	KCPX	ABC	50	Salt Lake City	6.00	139
137	WLOS	ABC	40	Gnville-Sptnbg-Ashvi	8.00	130
138	WKRC	ABC	20	Cincinnati	5.88	140
139	WHBQ	ABC	29	Memphis	6.47	136
140	KTVI	ABC	12	St. Louis	6.15	138
141	KMSP	ABC	13	Minneapolis-St. Paul	8.20	126
142	WLKY	ABC	36	Louisville	4.53	143
143	WNYS	ABC	43	Syracuse	6.55	135
144	WDHO	ABC	45	Toledo	1.67	144

Rank	Pub. affairs and rank		Other and rank
					Composite
1	11.12	7	16.82	12	45.833
2	9.10	15	14.00	21	43.083
3	10.03	9	10.78	70	42.817
4	4.10	83	21.72	1	41.950
5	4.97	59	18.92	6	41.600
6	7.13	31	13.50	27	40.833
7	11.43	3	10.83	69	40.817
8	4.10	83	19.63	5	40.783
9	3.62	98	20.12	3	40.100
10	9.92	10	12.52	38	39.550
11	4.70	68	18.22	8	39.167
12	6.07	39	18.72	7	38.750
13	10.72	8	11.37	59	38.700
14	7.67	20	10.57	77	38.383
15	9.37	13	13.78	23	37.983
16	7.78	19	11.17	65	37.483
17	11.13	6	11.08	66	37.300
18	5.57	48	17.42	9	37.267
19	5.60	47	16.87	11	36.067
20	4.22	80	12.08	46	35.567
21	7.45	23	12.05