MB 02-376: Sells, Willcox and Davis-Monthan AFB, AZ

REC files comments in response to Lakeshore responding to Journal Bc

REC Networks today has filed a response to Lakeshore Broadcasting, licensee of KWCX, Willcox AZ.

Lakeshore is attempting to move KWCX from Willcox to Davis Monthan AFB, a locality surrounded by the City of Tucson, an urbanized area.

In Journal Broadcasting's (licensee of several Tucson FMs) Reply Comments in this proceeding, they claimed that DMAFB is not listed on the Census and should not be considered as a community for allotment purposes. REC had made similar claims in our Reply Commnents.

On the community status issue, Lakeshore responds using Speedway, IN as an example that a community completely surrounded by a major city can still qualify as a community for allotment purposes.

In our latest reply, we make note that Lakeshore missed one very important point, Speedway is listed in the US Census as a community of 11,000+ people while DMAFB is not listed in the Census.

REC's policy on allotments is that unless there is a significant public interest issue that justifies the allotment, that a designation by the Census is the absolute minimum for community status. REC cites cases such as Essex, CA (an old Route-66 town but in a very isolated area of I-40), Littlefield, AZ (area not listed in the Census but receives several nearby FMs including vacant allotments) and indirectly mentions the current proceeding in Amboy (another Route-66 situation similar to Essex).

Lakeshore's counterproposal will move Clear Channel's KZZP Mesa off of South Mountain (the major transmitter site in Phoenix) to a ground level location and require the construction of a tower that would be contraversial due to flight safety concerns.

A copy of our filing can be found at http://www.recnet.com/fcc/02-376b.pdf.