Urbanized Areas
What are urbanized areas?
The United States Census Bureau
determines the 'urbanized areas' within the United States.
How they relate to broadacst allotments
When considering an allotment, especially ones where migration from a rural location to a location
closer to the urbanized area is being made, the FCC must take into consideration the impact of the
change on the rural area as a result of the station being moved to the well served urban areas.
When is additional information required?
In the event that the relocation of a station would put it's 70dBu City Grade contour over at least
50% of the urbanized area (by population), then the burden is on the petitioner to make a showing that
the new community is independent of the urbanized area. The FCC outlines this process in the case
of Faye and Richard Tuck, 3 FCC Rcd 5374 (1988). This process is referred to as a
Tuck Analysis.
What is a Tuck Analysis?
The Tuck Analysis are eight different items that have to be addressed in order for the FCC
to determine that the proposed community is indeed independent of the urbanized area. These criteria
include:
The extent to which the residents work in the larger community, rather than the specified
community. Determine the work habits of the local community. Is there work in town? (such as a
factory, mining or call center town) or do most people have to commute to the urban area to work. Look
at public transportation schedules, the types of roads that connect the urbanized area and the local
community. Any information on company websites about vanpool programs are a good clue.
Whether the community has it's own newspaper or other media that covers the community's
local needs or interests. Does the community have a local newspaper? I do not consider a version
of the Pennysaver as such a newspaper. Even a weekly paper counts in the eyes of the FCC. Other media
would include a local TV or LPTV station that broadcasts local information, especially those who have been
given "Class-A" status.
Whether community leaders and residents perceive the specified community as being an integral
part of, or separate from, the larger metropolitan area. Do residents feel "independent" from the
urbanized area? Look for local websites to see how they advertise the community. Real Estate sites are
a good place to go for this.
Whether the specified community has its own local government and elected officials. What is
the government structure of the community? Is it dependent on the urbanized area? Good example is a
community that gets a majority of its services from the county seat in the urbanized area. Does the
local community have a mayor?, city council members? I would argue that a county supervisor that
covers that community along with other communities does not qualify.
Whether the smaller community has its own telephone book provided by the local telephone
company or zip code. These days, virtually every speck on the map has it's own ZIP code. If arguing
against an allotment moving towards an urbanized area, I would look at which phone book gets distributed
to local residents. If it is the urbanized community's book, then you have a good case.
Whether the community has its own commercial establishments, health facilities and
transportation systems. This one is self explanatory.
The extent to which the specified community and the central city are part of the same advertising
market. In communities without a local LPTV station, you can look no farther than the cable TV
lineup and the local stations that must be carried in the market. Also look at broadcast stations that
are in the small community's 60dBu service area. If they are mostly stations from the urbanized area then
you have a good case to claim that the stations are in the same ad market. Especially if businesses
from the smaller community advertise on the larger community's stations. This could be a car dealer,
casino, etc.
The extent to which the specified community relies on the larger metropolitan area for various
municipal services such as police, fire protection, schools and libraries. Many rural communities
have local fire protection districts and volunteer fire departments. If the community is served by the
county fire department, you may have a better chance. Many rural communities do not have their own
law enforcement. This is usually done by a county sheriff. Elementary school children may go to school
in town but where do the high school kids go? What about community college? Does the community have
a library? How many days a week is it open? If there is no library, is there a bookmobile that comes
in to town. If so, from where? The urbanized area?
Be forewarned that not all of these criteria need to be satisfied to determine independence. Parker
and Port St Joe Florida, 11 FCC Rcd 1095, para 9-11 (1996). (Community lacked local phone directory
and local newspaper and was listed in the urbanized Arbitron market).
How do I determine the boundary of the urbanized area?
To get information on the boundaries of Urbanized Areas, visit the Census Bureau's
American Factfinder website. You will have to
use the options to remove the other boundaries and leave only the urban areas in. Please note that the
Census Bureau also has areas called "Urban Clusters" (UC). These are not considered as urbanized areas
for the determination of a Tuck Analysis.
Hopefully this information will help you if you are fighting an allotment or if you are considering
requesting a rural allotment and you are concerned about urban encroachment.
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