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Before the FEDERAL COMMUNICATION COMMISSION Washington 25, D. C. In re ) ) Clear Channel Hearings ) Docket No. 6741 ) MEMORANDUM BRIEF ON BEHALF OF NATIONAL ASSOCIATION OF EDUCATIONAL BROADCASTERS The National Association of Educational Broadcasters is composed of 65 members, which include universities, colleges, and other educational or pub¬ lic service agencies engaged in the ownership or operation of educational or non-commercial broadcasting (Ex. 383). The membership comes from 24 states and the Territory of Hawaii, and at the present time operates 22 AM and 19 FM stations (R. 6016). Of the 22 AH stations, only four operate unlimited time. The remaining 18 operate either daytime only, or on a share-time basis(Com- mission Records). The stations licensed to the members of the NAHB are especially equipped to serve, and in fact, do serve specialized local and regional audiences (R. 6017). The programs broadcast over these facilities include a wide range of subjects t such as, for example, special farm and market reports, classroom lectures, edu¬ cational talks and discussions on matters of public interest which are not generally carried by other stations (R. 6017). However, the ability of the sta¬ tions to perform their outstanding and unique service has been circumscribed by the limitations imposed upon the hours during which they may operate. Not only are the hours confined to daytime, but are irregular and vary from month to month. Some of the results of these limitations are to deprive the listeners in the Columbus, Ohio area of concerts by the Columbus