bulmer was able to take advantage of an fcc policy that allowed him to be granted the wzoo call sign on fm (as wzoo-fm) by obtaining the written permission from wzoo (am) in asheboro, north carolina. mr. bulmer paid the licensee of wzoo (am) $1,000 to grant him permission. hence, "102 zoo" was born. wzoo-fm was one of five construction permits granted to bulmer in the late 1980s/early '90s. at that time, prior to fcc auctions for frequencies, bulmer discovered a not-widely-known fcc policy whereby if a filing window closed and there were no applications filed, the fcc would then grant a construction permit (authority to build the radio station) under "first come/first served" processing rules. while the general public was often stampeding to the next newly opened filing window, bulmer was combing the fcc's records for windows that had just closed to ascertain what fcc filing windows drew no applications for a particular community.