Montana State University Modification of License to Noncommercial Status Station KMTF(TV), Helena, MT (Fac ID 68717)

Request for Waiver of Main Studio Location Rule

Montana State University (“Montana State”) respectfully requests a waiver of the main studio location requirements of Section 73.1125 of the FCC’s Rules in connection with this application to convert television station KMTF(TV), Helena, Montana (the “Station”) from commercial to noncommercial educational (“NCE”) status. Montana State proposes to operate the Station as a satellite of its co-owned, existing NCE station KUSM-TV, Bozeman, Montana (FCC Facility ID No. 43567) from a consolidated main studio in Bozeman. The FCC has previously granted main studio waivers to other KUSM-TV network NCE stations, as indicated below.

Montana State was established in 1893 in Bozeman, Montana as the state’s land-grant university. Montana State’s mission is to educate students, create knowledge and art, and serve communities by integrating learning, discovery and engagement. As Montana’s largest university, Montana State has an enrollment of more than 15,000 undergrad and graduate students. Montana State is accredited by the Northwest Commission on Colleges and Universities.

Montana State has operated noncommercial station KUSM-TV, d/b/a MontanaPBS, in Bozeman for more than 30 years. MontanaPBS also operates noncommercial educational television stations KBGS-TV in Billings, Montana, KUGF in Great Falls, Montana, and KUKL- TV in Kalispell, Montana, each as a satellite of KUSM-TV pursuant to a main studio waiver granted by the Commission and from the Bozeman main studio location of KUSM-TV. MontanaPBS seeks to provide all Montanans with local, public television that is fully supported by the citizens, businesses, foundations and public representatives of its state. MontanaPBS also seeks to broadcast programs that educate its people, discuss current issues and reveal history. In addition, MontanaPBS chooses programs based on community impact and seeks to connect the residents of its state to each other, to their country and their world through the use of broadcast television, the internet and community outreach projects.

Montana State is the proposed assignee of television Station KMTF(TV), Helena, Montana in FCC File No. BALCDT-20150710ABE. By this application, Montana State seeks to convert the Station form commercial to noncommercial educational status, and by this waiver request Montana State seeks authorization to operate the Station as a satellite of KUSM-TV, re- broadcasting that station’s programming from the existing, consolidated MontanaPBS main studio location in Bozeman.

The requested waiver and satellite status will serve the public interest by permitting Montana State to use its existing studio facilities and infrastructure to provide the highest quality and quantity of public television offerings to the Helena community. The Commission has stated that “[we] have recognized the benefits of centralized operations for noncommercial educational stations, given the limited funding available to these stations, and we have granted waivers to state and regional public television and radio networks to operate ‘satellite’ stations that do not

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necessarily meet the requirements of a main studio,” subject to a showing of good cause why the Commission should grant such a waiver.1

There are significant public interest gains that will result from use of the consolidated studio facilities. A main studio waiver will allow Montana State to conserve limited financial resources and eliminate the need for unnecessary duplication of equipment and personnel. Conservation of resources is vitally important for a nonprofit educational institution such as the applicant.

By avoiding the need for duplicative studio, personnel, and administrative costs, use of the consolidated main studio operation in Bozeman will enhance Montana State’s ability to provide quality local and national public television programming to viewers in the Helena community. Otherwise, it would be difficult for Montana State to both maintain a separate local studio and provide high quality program content. However, taking advantage of the existing administrative and technical facilities that KUSM-TV (and the other MontanaPBS stations) already use as a production space will benefit viewers in Helena by allowing Montana State to provide statewide public television services in a cost-conscious manner.

In addition, individual and organizational support provided by members of the local community is a vital source of funding for the television operations of MontanaPBS, which relies on local donations and sponsorship to contribute to its operating revenues. The studio co- location will allow the community of Helena, a small city with a population of approximately 29,596, and the rural service area, to enjoy the same high-quality public television service enjoyed and financially supported by the larger Bozeman and Montana State community.2 As a public television broadcaster and state educational institution, Montana State is committed to providing the same high level of noncommercial programming to residents in Helena that it provides to residents in Bozeman and other communities throughout the state.

Thus co-locating the main studio for the Station with KUSM-TV and Montana State’s other satellite stations in Bozeman will allow Montana State to fulfill its educational mission in a manner consistent with the realities of the current public broadcasting funding situation. It is vitally important for Montana State to conserve financial resources wherever possible, as each extra expense in any area of operation means fewer resources available for other programs.

Moreover, Montana State submits that the grant of a main studio waiver will not have an adverse effect on its ability to ascertain the needs of the Helena community and address them through its programming:

1 See In re Main Studio and Program Origination Rules for Radio and Television and Television Broadcast Stations, Memorandum Opinion and Order, 3 FCC Rcd 5024 (1988).

2 See U.S. Census Population Figures, http://quickfacts.census.gov/qfd/states/30/3035600.html. 2

Montana State University Modification of License to Noncommercial Status Station KMTF(TV), Helena, MT (Fac ID 68717)

 Bozeman, Montana is approximately only 79 miles from Helena, Montana, and Montana State has ties to Helena through students and alumni.

 The residents of the Helena community will be able to contact Montana State’s KUSM- TV MontanaPBS station studios via a toll-free telephone number.

 MontanaPBS maintains an active station website at http://www.montanapbs.org/home/ which invites viewers to contact station staff by various means, including email, mail, toll free phone, and fax in order to comment on programming and station operations, or to provide suggestions for staff. The website also provides a programming schedule, program information, general station information, and information for kids, parents and educators.

 MontanaPBS publishes a program guide that it distributes to members, underwriters, and selected community organizations.

 MontanaPBS will periodically review newspapers and/or online sources and other media that cover the Helena community.

 MontanaPBS will conduct a quarterly ascertainment review of the needs and interests of the Helena community.

 MontanaPBS has direct contact with communities across the state, including Helena, through the “Friends of MontanaPBS,” a station support organization with goals including community engagement and advocacy. The Friends of MontanaPBS board is composed of more than 16 member representatives from the various communities served by the MontanaPBS network of public television stations and translators, and already has a board member from Helena. The Friends of MontanaPBS work to raise funds for MontanaPBS, provide advice, and give a voice to the thousands of members across Montana. The board members meet quarterly, either electronically or in-person.

These efforts will help Montana State, as licensee of the Station, to select programming that is responsive to the needs of the Helena community. For example, MontanaPBS already produces and broadcasts a number of local programs focused on issues of special interest to those in Montana, including the Helena area. These include programs like “Backroads of Montana” (visiting unique people and places across the state), “Remembering the Columbia Gardens” and “The Montana Summer Symphony” (including broadcasts of concerts from the campus of Carroll College in Helena) which allow local viewers to reflect on the colorful history of their region and its unique people and cultures. In addition, programs such as “Montana Focus” (in-depth news and public affairs addressing issues across the state relating to politics and government, natural resources, business development and social changes), “Meth: Dark Cloud Over the Big Sky” and “Montana Ag Live” (a call-in information program addressing local agricultural issues), and many others, foster important discussion about the issues of concern to

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Montana State University Modification of License to Noncommercial Status Station KMTF(TV), Helena, MT (Fac ID 68717) local viewers. See also http://www.montanapbs.org/programs/ for information concerning many other MontanaPBS programs, including local public affairs and news offerings.

As a result, Montana State will offer the Station’s viewers many locally-produced and nationally-produced programs of particular interest to its local residents. Montana State’s connection to the Helena community, and its efforts to further ascertain and serve the needs of local residents, will thus ensure that the programming provided on the Station serves the needs of that community. In sum, Montana State submits that its commitment to ascertain and serve the needs of the Helena community by providing high quality public television programming, the likelihood that the Helena community might not otherwise be able to support a comparable standalone noncommercial public television outlet, and the necessity of conserving scarce financial resources justify the grant of a main studio waiver.

For all of these reasons, Montana State respectfully requests a waiver of Section 73.1125 of the Commission’s rules to co-locate the main studio for the Station with that of Montana State’s existing NCE station KUSM-TV, FCC Facility ID No. 43567, in Bozeman, Montana. Montana State submits that the public interest will be well served by authorizing the Station as a satellite of KUSM-TV from its consolidated Bozeman main studio location.

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