The entire operation is a joint powers authority consisting of the city, county and coliseum commission. I believe the enabling legislation established an agency at the state level even though the most of the land is in city and county ownership. None the less the FCC licenses are in the name of the state so I'm in agreement with you, but I would include the admin and maintenance frequencies as well. Cal Expo is also listed at the county level as an attraction and amusement park. It should also be under the state listings.