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The Federal Communications Commission is charged by the Federal Communications Act' with allocating use of the public airwaves by dispensing renewable broadcast licenses for particular frequencies on the basis of the "public convenience, interest or necessity.12 Although the FCC's task3 is much more difficult whenever two or more applicants apply for the use of the same or interfering frequencies, the Commission has over the years at least been able to set standards for choosing among original applicants through the procedure known as the comparative broadcast hearing.4 Where, on the other hand, one of the applicants is a current incumbent applying for renewal of its license and a so-called comparative renewal hearing is held, the FCC's record has been poorer:5 it did not issue a policy statement regarding comparative renewal hearings until 1970,6 and this policy was vacated by the D.C. Court of Appeals.7

Comparing the Incomparable: Towards a Structural Model for FCC Comparative Broadcast License Renewal Hearings