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                             Before the 
                      Federal Communications Commission
                           Washington, D.C.  20554

In re: Applications of                  )
                              )
WINV, Inc.                         )    File Nos. BR-970203V7, BAL-970310ED
(Assignor)                         )
                              )
and                           )
                              )
WGUL-FM, Inc.                 )
(Assignee)                         )
                              )
For Renewal and Assignment of License of     ) 
WINV(AM), Inverness, Florida       )
 
                  MEMORANDUM OPINION AND ORDER

Adopted:  December 7, 1998              Released:  December 14, 1998

     By the Commission:

     1.  The Commission has before it an application for review filed February 3, 1998 by Dickerson
Broadcasting, Inc. ("Dickerson") and related pleadings.  Dickerson seeks review of the November 26, 1997
Mass Media Bureau ("Bureau") letter decision granting WINV, Inc.'s applications for renewal and
assignment of license for WINV(AM), Inverness, Florida to WGUL-FM, Inc.  For the reasons set forth
below, we dismiss the application for review.

     2.  Background.  Dickerson is the licensee of WEAG(FM), Channel 292A, Starke, Florida.  On
May 22, 1997, Dickerson filed a petition to deny the subject renewal and assignment applications, as well
as a modification application to change WINV's community of license to Beverly Hills, Florida (File No.
BP-970408AB).  Dickerson claimed that it had standing as a party in interest under 47 U.S.C.  309(d)
because the licensee of a third station, WXOF(FM), Channel 292C3, Beverly Hills, might seek permission
to change community of license, and the hypothetical application would be more likely to be granted if
WINV were licensed to Beverly Hills.  See, e.g., Memorandum Opinion and Order in MM Docket No. 88-
526, 5 FCC Rcd 7094, 7096-97 (1990) (removal of a community's sole local broadcast service is
restricted).  Dickerson did not explain how a change in WXOF's community of license would adversely
affect Dickerson.  The Bureau determined that Dickerson lacked standing as a party in interest to file a
petition to deny.  Nevertheless, the Bureau considered Dickerson's arguments against the assignment and
renewal applications on their merits as informal objections and denied them.  The Bureau deferred action
on the WINV modification application and stated that it would consider Dickerson's arguments concerning
that application as informal objections in conjunction therewith.  Dickerson now argues that the Bureau
erred by concluding that it lacked standing and committed substantive errors in addressing the merits of its
arguments.   

     3.  Discussion.  We need not address Dickerson's arguments because we conclude that it lacks
standing as an applicant for review.  In order to show that it is "aggrieved" by an action taken pursuant to
delegated authority, as required by 47 C.F.R.  1.115(a), an applicant for review must demonstrate an
actual or threatened injury to itself as a direct result of the challenged action.  See Hanford FM Radio, 11
FCC Rcd 8509, 8511 (1996) (applicant for review must identify "direct economic or other connection"
between its interests and grant of the challenged applications), citing Clarke Broadcasting Corp., 11 FCC
Rcd 3057 (1996); see also Matter of Warren Ache, 9 FCC Rcd 2464, 2467 (1993) ("A party seeking to
establish standing to file a petition to deny must demonstrate not only a direct or threatened distinct and
palpable injury, but also a causal link between the claimed injury and the challenged action.") (citations
omitted).  Dickerson does not allege competitor or listener status with regard to WINV and does not allege
that operation of the station has any technical impact on WEAG, the station licensed to Dickerson.  See
Hanford FM Radio, 11 FCC Rcd at 8511.  Although Dickerson alleges that grant of the WINV
modification application might enable WXOF's licensee to change WXOF's community of license,
Dickerson has not explained how such a change would harm its interests.  Furthermore, any injury to
Dickerson would be the direct result of WXOF's relocation rather than the Bureau's challenged action.  See
id., 11 FCC Rcd at 8511 (applicant for review not "aggrieved" for purposes of Section 1.115(a) where
grant of assignment application allegedly affected its comparative chances in a separate proceeding for a
new FM station in a different market).  Accordingly, we shall dismiss the application for review for lack of
standing.  
     
     4.  For the foregoing reasons, IT IS ORDERED that the application for review filed February 3,
1998 by Dickerson Broadcasting, Inc. in the above-captioned matter IS DISMISSED.   
  
                         FEDERAL COMMUNICATIONS COMMISSION



                         Magalie Roman Salas
                         Secretary