Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC
In the Matter of ) ) Docket No.: Tobacco Valley Communications ) )
PETITION FOR SPECIAL RELIEF
Michael Strand STRAND LAW FTRM, PLLC P.O. Box 21117 Billings, MT 59104 ( 406) 465-5792
1 TABLE OF CONTENTS
I. Background...... 4
a. Petitioner and Communities at lssue ...... 4
b. Purpose of this Petition ...... 5
II. Applicable Rules ...... 5
a. Must-Carry Legislation ...... 5
b. OMA Modification: Congressional lntent...... 6
c. DMA Modification: Federal Statute ...... 6
d. Standardized Evidence Approach ...... 7
e. Modifications to Occur on a Community-by-Community Basis ...... 8
Ill. Facts ...... 8
a. Spokane, Washington ...... 8
b. Evidence Common to the Spokane Stations ...... 9
1. Distance...... 9
2. Time Zone ...... 9
3. Shopping and Labor Market...... 10
4. Published Audience Data ...... 10
c. Station-by-Station Evidence: Spokane DMA...... 13
1. KXLY-ABC/Spokane ...... 13
2. KREM-CBS/Spokane ...... 15
3. KHQ-NBC/Spokane ...... 15
4. KAYU-FOX/Spokane ...... 16
d. Missoula/Kalispell, Montana ...... 17
e. Evidence Common to the Missoula Stations...... 18
2 1. Distance ...... 18
2. Time Zone ...... 19
3. Shopping and Labor Market...... 19
f. Station-by-Station Evidence: Missoula DMA...... 22
1. KTMF-FOX & ABC/Missoula ...... 22
2. KPAX-CBS/Missoula ...... 22
3. KCFW-NBC/Kalispell ...... 23
g. Programming Guides and Channel Line-Up Cards ...... 24
IV. Conclusion ...... 24
3 I. Background
a. Petitioner and the Communities at Issue
The petitioner, Tobacco Valley Communications (hereafter "TVC"), is a cable television company
that provides service to 400 subscribers across the northern portion of Lincoln County, Montana.
Located just to the west of Glacier National Park, Lincoln County is a sparsely populated,
mountainous, rural area in northwestern Montana. TVC's service area encompasses the very small
communities of Eureka, Rexford, Trego, Fortine, West Kootenai and Stryker, along with the rural areas
surrounding these communities. (See exhibit A)
Eureka, population 1,037,1 is by far the largest of these communities. Anticipating that this
petition would be filed, TVC registered the entire Eureka/North Lincoln County area with the FCC as
"community unit MT0196" under the community name "Eureka." (See exhibit B) So for the purposes of
this petition, TVC will simply use the term "Eureka" to refer to TVC's service area in northern Lincoln
County.
Eureka is currently part of the Spokane, Washington, designated market area (hereafter "OMA")
and, in fact, is the only Montana county that is part of the Spokane OMA. (See exhibit C) In large part,
this is a historical accident. When the Spokane OMA was formed, the cable television systems in
Montana were still being constructed. So even if the FCC might have preferred to assign Eureka to a
Montana DMA, such an action simply wasn't possible at that time. Thus Eureka became part of the
designated market areas of stations being broadcast from two states and one time zone away (See
exhibit D).
Please also note that back in the 1960s, when off-air signals from Spokane were available to
Eureka, 1) the signals were available for only two networks, 2) the translators were owned and operated
by the "Pinkem TV Club," and 3) the signal quality was very poor (well below a Grade B). Of particular
I 1 2010 Census 4 importance is the fact that these translators were only in place until the 1980s. Therefore, none of the
Spokane networks have been available off-air in Eureka for nearly 30 years.
b. Purpose of this Petition
This Petition seeks to modify the television markets for certain stations based in Spokane,
Washington and Missoula, Montana. Specifically, petitioner seeks to exclude the community of Eureka,
Montana,2 from the markets of four Spokane stations, and include it within the markets of four Missoula
stations. This request is consistent with the market modification provisions of the federal
Communications Act. With respect to a particular television broadcast station, the Act directs the
Commission to "include additional communities within its television market or exclude communities
from such station's market to better effectuate the purposes of this section." As this petition will show,
the purposes of the Act would be better effectuated if the requested modifications were enacted.
Among other matters, the stations in the Missoula, Montana, OMA are far more likely to carry
programming of local interest to the residents of Eureka, such as local news, weather and sports as well
as commercial/political advertising, extreme weather alerts, forest fire announcements and Amber
alerts.
II. Applicable Rules.
a. Must-Carry legislation.
Pursuant to Section 614 of the Communications Act and implementing rules adopted by the
Commission, commercial television broadcast stations are entitled to assert mandatory carriage rights
(also referred to as "must carry" rights) on cable systems located within their markets.3 A station's
market is its "designated market area," or DMA... a geographic market designation that defines each television market exclusive of others, based on measured viewing patterns.
2 Again, Eureka includes several small communities and the rural areas that surround those communities as reflected in TVC's registration of the area with the FCC as MT0196 3 Implementation of the Cable Television Consumer Protection and Competition Act of1992, Broadcast Signal Carriage Issues, 8 FCC Red 2965, 2976-2977 (1993)("Must Carry Order").
5 b. OMA Modification: Congressional Intent.
However, Congress did not intend that the county-by-county DMA designations be set in stone
for all time. To the contrary, "the legislative history of the provision [Section 614 of the
Communications Act] states that: ... the FCC may make an adjustment to include or exclude particular
communities from a television station's market consistent with Congress' objective to ensure that
television stations be carried in the area in which they serve and which form their economic market."4
Indeed, the intent of Congress was to "preserve the local service provided by television broadcasters,
including local news, public affairs offerings, and emergency broadcasts."5
c. OMA Modification: Federal Statute
As a result of this intent, Congress enacted legislation that provided a mechanism for the FCC to
modify designated market areas where the original, Nielsen-based designations no longer adequately
address particular communities' need to access programming and other content that is truly local. That
mechanism is set forth in Section 534(h)(l)(C) of the U.S. Code, which states, in pertinent part:
(i) For purposes of this section, a broadcasting station's market shall be determined by the Commission by regulation or order using, where available, commercial publications which delineate television markets based on viewing patterns, except that, following a written request, the Commission may, with respect to a particular television broadcast station, include additional communities within its television market or exclude communities from such station's television market to better effectuate the purposes of this section. In considering such requests, the Commission may determine that particular communities are part of more than one television market.
(ii) In considering requests filed pursuant to clause (i), the Commission shall afford particular attention to the value of localism by taking into account such factors as- (1) whether the station, or other stations located in the same area, have been historically carried on the cable system or systems within such community;
4 H.R. Rep. 102-628, 102d Cong.,, 2d Sess. 97 (1992) 5 S. Rep. No. 92, 102d Cong., 2nd Sess. 42 (1992)
6 (II) whether the television station provides coverage or other local service to such community; (Ill) whether any other television station that is eligible to be carried by a cable system in such community in fulfillment of the requirements of this section provides news coverage of issues of concern to such community or provides carriage or coverage of sporting and other events of interest to the community; and (IV) evidence of viewing patterns in cable and noncable households within the areas served by the cable system or systems in such community.
This petition, then, is the "written request" referred to in subsection (i) of the above statute.
TVC respectfully requests that the Commission modify the existing market areas for the indicated
Spokane, Washington television stations as well as the indicated Missoula, Montana stations by
excluding the community of Eureka from the former and including it in the latter.
d. Standardized Evidence Approach
The Commission has established that in a market modification proceeding, petitioners must follow a "standardized evidence approach" whereby the following six categories of evidence must be
submitted by the Petitioner in support of the proposed modification(s) or the petition will be dismissed
without prejudice:
(1) A map or maps illustrating the relevant community locations and geographic features, station transmitter sites, cable system head end locations, terrain features that would affect station reception, mileage between the community and the television station transmitter site, transportation routes and any other evidence contributing to the scope of the market.
(2) Grade B contour maps delineating the station's technical service area and showing the location of the cable system head ends and communities in relation to the service areas.
{3) Available data on shopping and labor patterns in the local market.
(4) Television station programming information derived from station logs or the local edition of the television guide.
(5) Cable system channel line-up cards or other exhibits establishing historic carriage, such as television guide listings.
7 (6) Published audience data for the relevant station showing its average all day audience (i.e., the reported audience averaged over Sunday Saturday, 7 a.m.-1 a.m., or an equivalent time period) for both cable and noncable households or other specific audience indicia, such as station advertising and sales data or viewer contribution records.6
e. Modification to Occur on a Community-by-Community Basis.
Note that the modification requested by this Petition involves moving the community of Eureka
as it pertains to the four major networks (ABC, NBC, CBS and FOX) rather than moving the entire county
in which Eureka is located. This is consistent with the Commission's preferred approach: "In adopting
rules to implement this provision, the Commission indicated that requested changes should be
considered on a community-by-community basis rather than on a county-by-county basis, and that they
should be treated as specific to particular stations rather than applicable in common to all stations in the
market."7 Therefore, the proper analysis here is to identify the stations at issue in each of the
designated market areas and then determine how each station fares under the standardized evidence
approach adopted by the Commission.
Ill. Facts
a. Spokane, Washington
This petition seeks to modify the market areas of the following Spokane, Washington, commercial broadcast stations:8 KXLY-ABC, KREM-CBS, KHQ-NBC and KAYU-FOX (See Exhibit E). Looking at each of these stations under the standardized evidence approach, however, some of this evidence is common to each station. For example, all of the Spokane stations are pretty much the same distance
6 47 C.F.R. § 76.59(b} 7 Must Carry Order, 8 FCC Red 2965, 2977 n.139 8 Note that 47 U.S.C. § 534(h}(l) defines "local commercial television station" as "any full power television broadcast station," and it explicitly excludes "low power television stations" from this definition.
8 from Eureka, Montana, and NONE of the Spokane networks provide an off-air signal to Eureka or
anywhere else in North Lincoln County. Rather than provide this same evidence over and over for each
station, this petition will first identify the relevant evidence required under the standardized evidence
approach that is common to all of the Spokane stations and then identify the relevant evidence that is
specific to each individual station. The petition will then repeat this process for the stations in the
Missoula, Montana, designated market area.
b. Evidence Common to the Spokane Stations
Spokane, Washington, is located on the eastern plains of the State of Washington. ft is a large
city by the standards of the Northwestern United States, with a population of 471,221.9 Spokane is
located within a large agricultural area. The major industries in the city itself include trade,
transportation, utilities and manufacturing. (See exhibit E).
1. Distance
As noted above, all of the Spokane stations are pretty much the same distance from Eureka, give
or take a few miles, given that the stations are scattered across the city. That distance is 226.7 miles
according to MapQuest, which estimated the driving time between the communities to be 4 hours and
11 minutes. (See exhibit F). Moreover, the twisting and turning nature of the highways between
Spokane and Eureka, coupled with the elevations reached on certain sections of those highways, makes the trip particularly treacherous and time-consuming during cold or otherwise extreme weather - a
common occurrence in this part of the Northern Rocky Mountains.
2. Time Zone
Additionally, all of the Spokane stations are located in a state that is two states away from
Eureka (Washington and Montana are separated by the Idaho panhandle) as well as being located in a
9 Id.
9 different time zone from Eureka. Spokane is in the Pacific Time Zone, and Eureka is in the Mountain
Time Zone (See exhibit D). The Missoula DMA, including Kalispell, is also in the Mountain Time Zone. So
programs that ostensibly occupy "Prime Time" for residents of Spokane actually appear an hour later in
Montana. Further, and perhaps more importantly, residents of Eureka cannot rely on the programming
schedules issued by the Spokane stations and must allow for the additional hour when using local
program guides (e.g., the programming guides published in local newspapers).
3. Shopping and Labor Market
Also common to all of the Spokane stations is the analysis of the local shopping and labor
patterns. As the material in exhibit E demonstrates, Spokane cannot be considered to be a local
shopping or labor market for residents of Eureka. TVC submits that the two communities are so far
apart and the driving time between them is so lengthy that daily commutes or quick shopping trips from
one to the other are highly unlikely. Spokane is a large city by the standards of this part of the country
(population 471,221 as of the 2010 census), and Eureka is quite small (population 1,037). So there
would be little reason for people to go from Spokane to Eureka for work or shopping. On the other
hand, there are several communities in Montana that are smaller than Spokane but considerably larger than Eureka as well as being significantly geographically closer to Eureka than Spokane (e.g., Missoula
(population 66,788) and Kalispell (population 20,008, etc.). A resident of Eureka would be far more
likely go to one of these Montana communities to shop or work than to travel all the way to Spokane.
For the typical Eureka resident, a trip to Spokane would be in the nature of an uncommon event, something to be done perhaps once or twice a year.
4. Published Audience Data
As TVC has seen in other DMA petitions to the Commission involving very small communities,
published audience data or data regarding viewership is not easily gathered for a community as small as
10 Eureka. TVC is not aware of any published audience data for Eureka such as ratings data or even sales or advertising data. TVC contacted Nielsen for ratings information and were told that Nielsen does not break its ratings down below the county level.10 This petition seeks OMA modifications involving only the northern portion of Lincoln County, Montana, which is separated from southern Lincoln County by roughly 70 miles of mountainous terrain. Grade B off-air signals from Spokane ARE NOT available in the northern portion of Lincoln County (but are available in the southern portion of Lincoln County) ..
Nielsen has viewership information for Lincoln County as a whole, but TVC is unaware of any way to determine what proportion of those viewership numbers are attributable only to the northern - and less populous - portion of Lincoln County where, as noted above, the Grade B signals for the Spokane networks are not available.
TVC has, whenever possible, offered its customers Montana stations rather than Spokane stations. Of the four major commercial network stations (ABC, CBS, NBC and FOX), the only Spokane station carried by TVC since 2009 has been the FOX affiliate (KAYU), which is accessed via satellite and re-broadcast to TVC's cable customers. So any ratings numbers for the other Spokane stations (i.e., those affiliated with NBC, CBS or ABC) with respect to viewership in Eureka would represent customers of satellite television providers DirecTV and DISH. These two providers offer only the Spokane OMA networks in the Eureka area. They do not offer any of the Missoula DMA stations to Eureka viewers. So even if such data were available, viewers using satellite service would skew any viewership numbers for those networks for this very rural and sparsely populated area.
While TVC has been unable to locate a source for the precise numbers of satellite versus cable viewers in Eureka, even a casual observation of the area reveals that satellite viewers significantly outnumber cable viewers. TVC's own estimate of the proportion of satellite viewers to cable viewers in
10 Petitioner would also note that Nielsen indicated that even if it had the viewership information TVC sought, company policy is to not appear in court in support of its ratings numbers.
11 Eureka is roughly 80%/20%. Therefore, viewership would be skewed in favor of the Spokane stations by the mere fact that under the "must carry" rules, the satellite providers offer only the Spokane stations.
However, the issue of viewership might also be addressed by reference to the sheer number of
Eureka residents who have affirmatively indicated their desire to receive the Montana stations out of
Missoula and Kalispell rather than a Washington station out of Spokane. A petition containing 800 signatures from North Lincoln County was collected in TVC's North Lincoln County office (See exhibit G).
Copies were forwarded to the offices of Montana's Congressional Delegation, all of whom have also been supportive of this effort. Additionally, the Legislative Consumer Committee of the Montana State
Legislature has indicated its support of TVC' s desire to modify the cable station markets as requested in this petition (See exhibit G). To provide a context for the 800 signatures, the population of Eureka is
1,037.
TVC also notes with interest an FCC decision from 2002 (referred to in this Petition as "the
MMM Case"), involving one of the Spokane stations and the community of Kalispell.11 In that case,
KTMF Missoula filed a petition for special relief seeking waiver of the FCC's "significantly viewed" exception to the network non-duplication rules. In essence, the Missoula station wanted the FCC to forbid the Spokane station from duplicating its programming on the grounds that the Spokane station was not "significantly viewed" in Kalispell, a community served by both stations. The FCC's Media
Bureau granted the Missoula station's petition, partly on the grounds of viewership data that was available for a community the size of Kalispell (population approximately 20,000). In its reasoning, the
Bureau also made specific note of other factors:
KTMF points out that KXLY-T V's transmitter site is approximately 140 miles from Kalispell and is separated from that community not only by the state of Idaho, but also by mountainous terrain. Moreover, KTMF states that not only does KXLY-TV's Grade B contour fall short of
11 In the Matter of MMM License LLC for Waiver of Section 76.92(f) of the Commission's Rules, Cause No. CSR- 5837-N, DA 02-2755 (Released October 12, 2002}
12 Flathead County, but its signal is delivered to the cable head end by microwave.12
The Bureau held that the Spokane station KXLY was not significantly viewed and therefore granted the
petition. (See exhibit H).
TVC would simply observe that while viewership data of the kind submitted by the Missoula
station (KTMF) in the above-cited case is not available for Eureka (again, such numbers are not available
below the county level), the remaining factors in that case are similar to those that are the basis for this
Petition. The transmitters for all of the Spokane stations are more than 200 miles from Eureka. The
Spokane stations are separated from Eureka not only by the state of Idaho but also by mountainous
terrain. Indeed, the distance between Kalispell and Spokane - 238 miles - is very nearly the same
distance of 224 miles between Eureka and Spokane.
Just as none of the Spokane station signals in the above-referenced MMM case were capable of
reaching Kalispell, none of the Spokane station signals reaches Eureka or any of the remainder of North
Lincoln County. Further, none of the Spokane stations provide off-air signals, nor do the Grade B
contours of any of the Spokane stations cover Eureka. In fact, the only possible way any of the Spokane
stations could be considered significantly viewed in Eureka is if they reached that threshold due to viewership of the satellite television providers (DirecTV and DISH) since those providers strictly abide by the must-carry rules and offer only the Spokane stations - despite the clearly-expressed wishes of
Eureka residents for the Missoula stations.
c. Station-by-Station Evidence: Spokane OMA
1. KXLV-ABC/Spokane
For KXLY-Spokane, a map illustrating the relevant community locations, geographic features and transportation routes is attached as Exhibit I. Exhibit I also shows the relevant transmitter sites, head
12 Id. at page 2, paragraph number 5.
13 end locations, terrain features that would affect reception, and the mileage between the community and the television station transmitter site.
KXLY's Grade B contour map is attached as Exhibit J. As is evident from the map, KXLY's signal does not reach Eureka.
In determining how best to exhibit programming information, the authors of this Petition immediately encountered the difficulty of providing exhibits comprised of video of local content (and the even more difficult proposition of providing examples of a LACK of video of local content).
Therefore, the exhibits showing local content (or a lack thereof) were obtained via searches of the websites of the stations, since stations commonly expand upon their broadcast news by directing viewers to their websites for additional information.
An exhibit covering KXLY's programming information has been attached as Exhibit K. It shows that when the search term "Eureka" was used on KXLY's website, 13 pages of results appeared.
However, NOT A SINGLE result actually referred to the community of Eureka, Montana. Moreover, the
KXLY website demonstrated that the station LACKED local coverage (news, weather, sports, advertising, political speech, emergency alerts, etc.) not only of Eureka and Lincoln County but also of any other part of Montana. In short, KXLY's local coverage is limited almost exclusively to happenings within the State of Washington.
An exhibit establishing KXLY's historical carriage (or lack thereof} on TVC's network is attached as Exhibit L.
14 2. KREM-CBS/Spokane
For KREM-Spokane, a map illustrating the relevant community locations, geographic features
and transportation routes is attached as Exhibit I. Exhibit I also shows transmitter sites, head end
locations, terrain features that would affect reception, and the mileage between the community and the
television station transmitter site.
KREM's Grade B contour map is attached as Exhibit M. As is evident from the map, KREM's
signal does not reach Eureka.
An exhibit covering KREM's programming information has been attached as Exhibit N. It shows
that when the search term "Eureka" was used on KLEWs website, NO results appeared. Moreover, the
KREM website demonstrated that the station LACKED local coverage (news, weather, sports, advertising,
political speech, emergency alerts, etc.) not only of Eureka and Lincoln County but also of any other part
of Montana. In short, KREM's local coverage is limited almost exclusively to happenings within the State
of Washington.
An exhibit establishing KREM's historical carriage (or lack thereof) on TVC's network is attached
as Exhibit L.
3. KHQ-NBC/Spokane
For KHQ-Spokane, a map illustrating the relevant community locations, geographic features and transportation routes is attached as Exhibit I. Exhibit I also shows transmitter sites, head end locations, terrain features that would affect reception, and the mileage between the community and the television station transmitter site.
KHQ's Grade B contour map is attached as Exhibit 0. As is evident from the map, KHQ's signal does not reach Eureka. 15 An exhibit covering KHQ's programming information has been attached as Exhibit P. It shows that when the search term "Eureka" was used on KHQ website, more than 50 results appeared.
However, NOT ONE of the entries actually dealt with the community of Eureka, Montana. Moreover, the KHQ website demonstrated that the station LACKED local coverage (news, weather, sports, advertising, political speech, emergency alerts, etc.) not only of Eureka and Lincoln County but also of any other part of Montana. In short, KHQ's local coverage is limited almost exclusively to happenings within the State of Washington.
An exhibit establishing KHQ's historical carriage (or lack thereof) on TVC's network is attached as
Exhibit L.
4. KA YU-FOX/Spokane
For KAYU-Spokane, a map illustrating the relevant community locations, geographic features and transportation routes is attached as Exhibit I. Exhibit I also shows transmitter sites, head end locations, terrain features that would affect reception, the mileage between the community and the television station transmitter site is attached as Exhibit I.
KAYU' s Grade B contour map is attached as Exhibit Q. As is evident from the map, KHQ' s signal does not reach Eureka.
An exhibit covering KAYU's programming information has been attached as Exhibit R. It shows that when the search term "Eureka" was used on KAYU website, NO results appeared. Moreover, the
KAYU website demonstrated that the station LACKED local coverage (news, weather, sports, advertising, political speech, emergency alerts, etc.) not only of Eureka and Lincoln County but also of any other part of Montana. In short, KAYU's local coverage is limited almost exclusively to happenings within the State of Washington.
16 An exhibit establishing KAYU's historical carriage (or lack thereof) on TVC's network is attached
as Exhibit L.
d. Missoula/Kalispell, Montana
The Missoula, Montana designated market area (OMA) includes the following commercial
broadcast stations:13 KCFW-NBC, KTMF-FO, KTMF-AB, KPAX-CBS (See Exhibit S). The reason this brief
treats Missoula and Kalispell together is that Kalispell is located within the Missoula OMA, and one of
the stations TVC would like to continue to carry is broadcast from Kalispell. TVC has carried KCFW-
NBC/Kalispell for over 20 years and continues to carry the station to this day. Therefore, evidence
regarding Kalispell and the station broadcast from Kalispell is also relevant to this petition.
TVC has made significant efforts to enable its subscribers to access the Missoula networks,
including maintaining translator sites for two networks broadcast from the Missoula OMA. The first
translator site is owned by KCFW /NBC/Kalispell, which has been serviced by TVC for more than 20 years.
The second translator site is for KPAX/CBS/Missoula and has been owned by TVC since 1998 (see Exhibit
L, Bill of Sale dated 3/31/1998; the FCC License Renewal Authorization form, Exhibit L; and photographs
of the translator site at Exhibit L).
TVC has historically tried to meet its subscribers' demands for local content by entering into
retransmission consent agreements with these "out of OMA" Montana networks. By carrying the
Montana stations, TVC ensures t hat its Northwestern Montana subscribers can view local content
generated by the Montana stations, including Montana news, weather, sports, etc.
This arrangement appeared to work well for TVC and its subscribers until 2012, when KXLY-
ABC/ Spokane determined that it would enforce its rights under the network exclusivity rules, refusing to allow TVC to renew its Retransmission Consent Agreement with KTMF-ABC/Missoula, an "out of
13 Note that 47 U.S.C. § 534(h}(l) defines "local commercial television station,, as "any full power television broadcast station," and it explicitly excludes "low power television stations" from this definition.
17 DMA" Montana network. As a result, TVC was forced to go dark with its ABC network. TVC's subscribers
have therefore had no access to any ABC television station since May 30, 2012.
The foregoing circumstances are the primary reason for this petition by TVC. The process of
obtaining retransmission consent agreements every few years - and risking the possibility that one or
more of the Spokane stations will enforce their exclusivity and non-duplication rights and refuse to
negotiate - is unwieldy, time-consuming, expensive and uncertain. TVC would prefer that the
community of Eureka be moved from the markets of the four Spokane DMA stations that are affiliated
with the four major commercial broadcast networks (ABC, NBC, CBS and FOX) to the markets of the four
Missoula DMA stations that have the same commercial broadcast network affiliations. That way, all of
TVC's customers can receive Montana network stations that- unlike the Spokane stations - actually
carry local news, weather, sports and other content of interest to the residents of Eureka.
e. Evidence Common to the Missoula OMA Stations
1. Distance
All of the Missoula stations are approximately the same distance from Eureka, 189.4 miles
according to MapQuest, which estimated the driving time between the communities to be 3 hours and
24 minutes (See exhibit T) Kalispell is 66 miles from Eureka, a drive of approximately one hour. (See
exhibit U). The terrain between Eureka, Missoula and Kalispell is mountainous, but the elevation
changes are not as extreme as those between Eureka and Spokane. Therefore, the drive between
Eureka, Missoula and Kalispell is not slowed by terrain nearly as much as the drive between Eureka and
Spokane.
18 2. Timezone
Since Missoula, Kalispell and Eureka are all in the same time zone (See exhibit D), program
listings in the various media in those communities have the same starting and ending times. Spokane,
however, is in a different time zone (one hour earlier), so viewers must determine whether or not the
listings they see have been adjusted to take the time zone difference into account... or not. Clearly, this
requirement is an ongoing inconvenience to viewers - particularly if the viewer misses one or more
programs as a result.
3. Shopping and labor Market
Within Montana, the northwestern part of the state is probably best known for Glacier National
Park and the Flathead Lake area. This area is particularly noted for its outdoor recreation opportunities,
including hiking, backpacking, boating, hunting, fishing, snowmobiling, skiing, camping, etc. Therefore,
tourism and the service industries in general are of particular importance. All three communities share
these attributes, while Spokane does not. Eureka, Missoula and Kalispell are all located in Northwestern
Montana.
Missoula is the second largest city in Montana and by far the largest city in the northwestern
Montana area that includes Eureka. For example, Montana Department of Labor and Industry reports that as of 2010 Missoula had 527 retail establishments, employing 7,640 persons. Missoula also had 247
restaurants, employing 4,410 people and 119 arts, entertainment and recreation businesses, employing
1,358 persons (See Exhibit V). As such, Missoula is an attractive and convenient shopping, dining and
recreational destination for residents of Eureka, whose population is a tiny fraction of Missoula's.
With respect to Kalispell, Montana, according to the 2009 annualized quarterly census of the
Montana Department of Labor and Industry (attached as Exhibit W) there were 484 retail
19 establishments, employing 5,519 persons. There were 244 food services and drinking places, employing
3,380 persons. There were 121 arts, entertainment and recreation businesses, employing 1,333
persons. There were 92 amusements, gambling and recreation businesses, employing 1,213 persons.
Missoula is the home of the University of Montana educational system, and Kalispell is home to
Flathead Community College, the largest community college in Montana. Not only do many Eureka
residents attend these educational institutions, many if not most are fans of their various sports teams
and consumers of news pertaining to them.
Missoula and Kalispell are also important destinations for Eureka residents who need services
such as medical treatment, repair services, and government services and programs. Local news and
advertising for such businesses is broadcast on all of the Missoula and Kalispell stations at issue in this
petition.
The Petitioner has attached a fact sheet regarding Lincoln County (the county within which
Eureka is located) as exhibit X. That document demonstrates that the Eureka area, like the Missoula and
Kalispell areas is heavily forested and significantly reliant on the timber industry. Especially given the
nature of winter weather and the difficulties it causes for travel in this area, Eureka residents are simply
far more likely to shop or work in nearby Kalispell or Missoula than to drive all the way to Spokane for
such activities.
In the opinion of the authors of this petition, the FCC should understand the particular
importance of local sports news in rural Montana. In very small communities, the local schools tend to
be the centers of those communities. Just as high school football is of particular importance in rural
Texas and high school basketball is of particular importance in rural Indiana, so too are both sports
(along with baseball, wrestling and track and field) of particular importance to communities in rural
Montana. Missoula OMA stations tend to report the scores and highlights of small-town sports teams in
20 the Eureka area, along with segments on local athletes and events. This reporting is unsurprising since
Eureka's high school is in the same divisional sports district as the schools in Missoula and Kalispell. That
content is simply not available from the Spokane DMA stations.
Because the Eureka area is made up of such rugged, mountainous terrain quite near the
Canadian border, local weather information is important both in terms of road conditions, which can
deteriorate rapidly and in terms of agricultural interests and the threats presented by local wildlife
when, for example, the grizzly bears emerge hungry from their long winter hibernation and as wildlife
descends from the mountains during particular seasons. Warnings and other information on forest
fires, blizzard conditions, icy roads, sudden heavy rains, fog (particularly in the valleys) and other
conditions are also of great importance to the residents of the Eureka area. Again, the Spokane DMA
stations do not cover such stories for the Eureka area while the Missoula DMA stations do.
Additionally, the Montana State Legislature meets every other year for approximately four
months each term. There are quite often bills before the Legislature that are of vital importance to the
residents of the Eureka area that go completely unreported by the Spokane DMA stations but ARE
available via the Missoula OMA stations. In addition to the Legislature, important information from the
various city, county and state administrative agencies and other governmental entities are
communicated by the Missoula OMA stations but not by the Spokane OMA stations. In a related issue,
the Spokane OMA networks provide no coverage of political election advertising or information for
Montana (such as poll results, election results, information on referenda, etc.) while the Missoula DMA
networks provide full coverage of Montana elections, debates and political advertising.
Eureka and communities of similar size in Montana rarely produce newspapers. When they do,
the papers are nearly always weekly rather than daily. The only daily newspaper delivered in Eureka is the Daily Interlake, published in Kalispell (home to KCFW/NBC, within the Missoula DMA). No Spokane
21 newspapers are delivered in Eureka - nor are they even available for purchase in Eureka stores. TVC submits that this is further evidence that Eurekans lack interest in Spokane news, weather, sports or other events.
f. Station-by-Station Evidence: Missoula OMA
1. KTMF-FOX & ABC/Missoula
For KTMF, a map illustrating the relevant community locations, geographic features and transportation routes is attached as Exhibit I. Exhibit I also shows transmitter sites, head end locations, terrain features that would affect reception, and the mileage between the community and the television station transmitter site.
KTMF's Grade B contour map is attached as Exhibit Y. As is evident from the map, KTMF 's signal does not reach Eureka.
An exhibit covering KTMF's programming information has been attached as Exhibit Z. It shows that when the search term "Eureka" was used on KTMF's website, 83 results appeared, and every result dealt with the community of Eureka, Montana.
An exhibit establishing KTMF's historical carriage on TVC's network is attached as Exhibit L.
2. KPAX-CBS/Missoula
For KPAX, a map illustrating the relevant community locations, geographic features and transportation routes is attached as Exhibit I. Exhibit I also shows transmitter sites, head end locations, terrain features that would affect reception, and the mileage between the community and the television station transmitter site.
22 G. Programming Guides and Channel Line-Up Card
Among the evidence required by the standardized evidence approach are programming guides and channel line-up cards. TVC has included as exhibit Lan example of a programming guide from the year 2004, which identifies both the "out of DMA" Montana networks and the Spokane networks being carried by TVC at the time. However, carrying stations from both DMAs has since become cost prohibitive. Further, TVC discontinued printing programming guides in 2006, moving to a strictly dedicated channel guide. Consequently, today only one newspaper (The Kalispell Daily Interlake) publishes a TV guide showing TVCs programming - and that newspaper is not even in Lincoln County. It is published in neighboring Flathead County and its guide makes no reference to programming for the
Spokane DMA stations, listing the Missoula stations instead. An example of a programming guide from the Daily Interlake is included in Exhibit L, attached hereto.
IV. Conclusion
The Spokane stations identified in this petition: 1) are geographically distant from Eureka; 2) fail to provide grade B signal contour coverage of Eureka; and 3) fail to broadcast programming of local interest or import to residents of Eureka. Moreover, 800 residents of Eureka have indicated via their signatures on a petition that they would like to receive their television programming from Missoula or
Kalispell. Therefore, TVC respectfully requests that the Commission modify the market areas of the stations identified in this petition.
24 RESPECTFULLY SUBMITTED this { ~~ day of --:fl.N)e , 2015.
~~ Michael Strand STRAND LAW FIRM, PLLC P.O. Box 21117 Billings, MT 59104 (406) 465-5792 [email protected]
Counsel for Tobacco Valley Communications
25 TABLE OF EXHIBITS
Exhibit A: Lincoln County Area Map
Exhibit B: FCC Registration of the Community of Eureka
Exhibit C: Area Maps of the Spokane and Missoula DMAs
Exhibit D: Time Zone Map
Exhibit E: List of Spokane Stations, Statistics Pertaining to Spokane's Labor and Shopping Markets
Exhibit F: MapQuest Map with Distance and Driving Directions from Eureka to Spokane
Exhibit G: 800-Signature Petition from Tobacco Valley Customers and Minutes of State Legislative
Committee
Exhibit H: FCC Memorandum Opinion and Order in the Matter of MMM License LLC
Exhibit I: Map of Cable Headends, Transmitters, Terrain, Transportation Routes, Etc., and Highway Map
Exhibit J: B Contour Map for KXLY-TV Spokane
Exhibit K: Document Demonstrating Absence of Content Local to Eureka on KXLY-TV Spokane
Exhibit L: Affidavit of Tobacco Valley General Manager Regarding Historical Carriage of Spokane Stations
(with Retransmission Agreements and Correspondence); Translator transfer to TVC; Photographs of
Translator Site and Translator; Channel Line-up Card; Programming Guide
Exhibit M : B Contour Map for KREM-TV Spokane
Exhibit N: Document Demonstrating Absence of Content Local to Eureka on KREM-TV Spokane
Exhibit 0: B Contour Map of KHQ-TV Spokane
Exhibit P: Document Demonstrating Absence of Content Local to Eureka on KHQ-TV Spokane
Exhibit Q: B Contour Map for KAYU-TV Spokane
Exhibit R: Document Demonstrating Absence of Content Local to Eureka on KAYU-TV Spokane
26 Exhibit S: List of Missoula OMA Stations, Statistics Pertaining to Missoula's Labor and Shopping Markets
Exhibit T: MapQuest Map Showing Distance and Driving Directions from Eureka to Missoula
Exhibit U: MapQuest Map Showing Distance and Driving Directions from Eureka to Kalispell
Exhibit V: Document from Montana Department of Labor and Industry Showing Statistics for Missoula
Area
Exhibit W: Document from Montana Department of Labor and Industry Showing Statistics for Kalispell
Area
Exhibit X: Lincoln County Fact Sheet
Exhibit Y: B Contour Map for Missoula
Exhibit Z: Documents Showing Large Number of Stories on KTMF Involving Content Local to Eureka,
Along with Examples
Exhibit AA: B Contour Map for KPAX-TV Missoula
Exhibit BB: Document Showing Large Number of Stories on KPAX Involving Content Local to Eureka
Exhibit CC: B Contour Map for KCFW-TV Kalispell
Exhibit DD: Document Showing Large Number of Stories on KCFW Involving Content Local to Eureka
27 CERTIFICATE OF SERVICE
~ - I, Michael Strand, do hereby certify that on the fl..:. day of ~\...>..ll\. -e.. , 2015, the foregoing
Petition for Special Relief was served upon the following entities by first class mail, postage pre-paid:
KTMF Linda Gray, President & GM 2200 Stephens Avenue Missoula, MT 59801
KPAX Robert Hermes, President & GM 1049 West Central Avenue Missoula, MT 59801
KREM Jamie Aitken, President & GM 4103 South Regal Street Spokane, WA 99223
KCFW Rebecca Swan, VP & GM 401 lst Avenue East Kalispell, MT 59901
KHQ P.O. Box600 Spokane, WA 99201
KAYU General Manager 4600 South Regal Street Spokane, WA 99201
KXLY General Manager 500 West Boone Avenue Spokane, WA 99201
Michael Strand
28 EXHIBIT A
LINCOLN COUNTY AREA MAP Lincoln County Area Map
British Columbia
~ Northwest Kootenai Peak Scenic Area
Legend
.t. Unincorporated Towns 0 Incorporated Towns - Rivers/Streams - Highways/Roads 5 0 5 10 15 20 - --- IViles EXHIBIT B
FCC REGISTRATION OF THE COMMUNITY OF EUREKA FCC CABLE TV REGISTRATION
Community Unit Communi!Y.. Name County MU ~nicipalit}'t_!dY. .Pte a '"(f ... t +- --- .. _.,, .t_ d_ Ith ""' . ' " t... "' ~ a '!!.e . -- . ,~ . rnnco·rpora e .a e . a 1acen ,o or oo,nnec e w an 1n~o~pma e"' MI9~2...-.. ;~, >E!.1Bf.IS8:. __..,.'\ 0 •._:.'i ... ,t.!_. .:.cmnm~ . . .
Legal Name Assumed Name status TOBACCQ· VALl.;~Y CQMM!liKCATJQNS v Ctl8.~LTf.i 11
Merged Date Zip
C~!2, _ ~ PSID __2..e_eration'!!_ ..... ~~~ ft . PO Box .,9ty_ _ ~~-~ L,:. ~~Q .i!4.§.7_ B/_lL195Z a · · 77 . B48 'EYBElSA ~- MI•. ._ ·. · 59JU.Z EXHIBIT C
AREA MAPS OF THE SPOKANE AND MISSOULA DMAs Designated Market Area Detail Map Page I of 1
Okanogan
B:>nner
____,l_ { '
Koo1ena ,I
County names shown in highlighted market area.
Designated Market Area (OMA): Spokane, WA Television households in OMA: 403,820 Market Ranking: 77
Disclaimer: OMA territory boundaries and the number of television households within that territory can change. Newport Media makes every effort to maintain current territory maps and subscription information, but does not guarantee the accuracy of the OMA area information presented above.
Copyright 2008 Newport Media
httn://www.newoortmedia.com/maos/countvinfo.oho?m=77 5/10/2014 Designated Market Area Detail Map Page I of 1
County names shown in highlighted market area.
Designated Market Area (OMA): Missoula, MT Television households in OMA: 108,510 Market Ranking: 167
Disclaimer: OMA territory boundaries and the number of television households within that territory can change. Newport Media makes every effort to maintain current territory maps and subscription information, but does not guarantee the accuracy of the OMA area information presented above.
Copyright 2008 Newport Media
htto://www.newuortmedia.com/maos/countvinfo.oho?m=l 67 5/10/2014 EXHIBIT D
TIME ZONE MAP •
(
n c: •>
...... I IJ •.luttz. ."""..... 1...... Y ~·'Jk• 1 t•.uv ...... EXHIBIT E
LIST OF SPOKANE DMA STATIONS, STATISTICS PERTAINING TO SPOKANE'S LABOR AND SHOPPING MARKETS TVB - Market Profiles Page I of 4
I I \ /r.:a. Local Media I V U Marketing Solutions
Markets &. Stations
Local media advertising reaches viewers where they live and make purchases. This section highlights the unique characteristics of each local market, as well as local broadcast stations, digital channels, and online platforms, to help advertisers harness the opportunities that local markets offer.
TVB Members: Customize your station profile. Select your station from the list below to get started. FAQ
Choose a OMA, Station or Broadcast Group Profile:
Profile Type: IMarket vi Choose: !Spokane, VI/A v j OMA: Spokane, 'WA To contribute market information, contact [email protected].
OMA Rank TV Households Population 2+ 73 424,790 1,027,991
African American Hispanic Asian Cable ADS HH Rank HH Rank HH Rank Penetration Penetration 144 74 72 34.5 51.4
Station Affiliation Primary Channel Website KAYU-TV FOX ~ww. myfoxspokane. com KCDT-TV PBS
KGPX-TV ION ~ww. iontelevision. com
KHQ-TV " NBC ~w.khq . com KLEW-TV CBS WWW. klewtv. com KQUP-TV RELIGIOUS KREM-TV • CBS ~w.krem.com KSKN-TV • cw http://www.spokanescw22.com/ KSPS-TV PBS KUID-TV PBS KWSU-TV PBS
KXLY-TV • ABC ~ww.kxly.com KXMN-LD MeTV rwww.mykxmn.com "TVB Member
Profile
7/7/2014 TVB - Market Profiles Page 2of4
Spokane, WA - Local Economy & Culture
Key Industry/Employment
• Spokane is a city located in the Northwestern U.S in the state of Washington .
0 It is the largest city and county seat of Spokane County, and the metropolitan center of the Inland Northwest region.
0 It is the principal city of the Spokane Metropolitan Statistical Area, which is used synonymously with Spokane County. • The leading industry sectors in Spokane by employment, 2010 are trade, transportation and utilities employing a total of 41,200 residents, followed by Educational and Health Services with total employee strength of 40,500. • Government and healthcare and social assistance are two of the major sectors of the Spokane economy.
o Healthcare and Social Assistance sector employs a regional workforce of 34, 100
0 Healthcare companies represent some of the top regional employers including Sacred Heart Medical Center and Children's Hospital and Deaconess Medical Center.
o A total of 36,300 residents of the Spokane area are on the payroll of the Government. • Some of the leading employers amongst Educational Institutes include Gonzaga University, Eastern Washington University, Central Valley School District and Community Colleges of Spokane. • Spokane's manufacturing industry is one of its key economic drivers. The industry is on an expansion mode and has added over 10,000 jobs over the past few years.
o The Spokane region is home to over 500 manufacturing businesses and has a workforce of over 18,000, representing 9% of the region's total employment.
0 Aerospace manufacturing is one of the key growing areas in the manufacturing industry in the region. Over 60 aerospace companies are currently based or have major operations in the area.
o These businesses span multiple industries including aluminum casting, metal products for the semiconductor industry, carbon aircraft brakes and engines for the aerospace industry, phannaceutical products and other devices for the medical industry, rugged wireless laptops etc. • Information technology and telecommunication is also one of the emerging sectors in the Spokane region.
0 The region has become a recognized networking and telecommunications hub in the Pacific Northwest, primarily due to its wide base of research and academic resources.
o The Industry is led by companies such as Itron, Inc., the world's largest electronic meter reading and energy management software company, Purcell Systems, a manufacturer of integrated telecommunication cabinets and Telect, a producer of network infrastructure equipment. Local Economy
nttn·/lwurw tvh oro/m~rkP.ts sfat1ons 717/2014 TVB - Market Profiles Page 3 of4
• The Spokane region had a population of 471,221 as of 2010. The Spokane county witnessed a population growth of 12.7% in the past decade, having added 53,282 resident. • Spokane region has a low cost of living. • Spokane Metropolitan Statistical Area's composite index for 2010 was 93.8, 6.2% lower than the national average. • Spokane's health care costs were 9.8% higher t han the national average, but housing and utility costs were considerably below average. • Housing costs were 14.5% below the U.S average, and utilities 10.3% less. Transportation ranked 9.1 % over the national average, however, grocery items and miscellaneous goods and services were 7.6% and 3.5% below the national average, respectively. • A University District is located in the heart of Spokane.
0 The district is home to the Riverpoint Campus housing Washington State University and Eastern Washington University classrooms, Sirti, and Gonzaga University.
0 Investments of up to $843 million have been made in the University District since 2004.
o Currently, approximately 11 ,400 students are enrolled in the district, which has almost doubled from 7 ,838 in 2004. • Downtown Spokane has seen significant investment over the past few years.
o Private developers and government revitalization projects have invested over $3. 7 billion since 1999.
0 These projects are aimed at bringing new retail and entertainment opportunities to the city's downtown district. • Spokane's total retail sales for 2009 were $7.7 billion, of which over 600 million was spent in restaurants and bars. Approximately S 400 million was spent on clothes and other apparel. Unique Characteristics
• Spokane was recognized as the cheapest place to live in the Pacific Region by Forbes Magazine in July, 2009. • The regional hospitals of Spokane were recognized as nation's most wired by Inland Northwest Health Services (INHS) in July, 2009. ° Kootenai Medical Center in Coeur d'Alene, Idaho and Providence Sacred Heart Medical Center and Children's Hospital in Spokane were named two of the nation's most wired hospitals.
0 The use of information technologies for customer service, public health and safety, business processes and workforce issues helped these hospitals secure this recognition. • Spoken was recognized as a hot spot for young professionals by Next Generation Consulting in June, 2009.
0 It was rated as a top "mighty micro" (cities with a population of 100,000 - 200,000) for young professionals.
httn·//www tvh oro/m::irke.ts st~t1ons 7/7/2014 TVB - Market Profiles Page 4of4
0 Spokane's overall cost of living and a rejuvenated downtown area were some of the factors that helped the region earn the recognition. • The region houses the University of Washington School of Medicine, which is a nationally recognized medical school and has been ranked the #1 primary care medical school in the country for 16 consecutive years. • Spokane was ranked 22nd in Inc. Magazine's "Best Midsize US Cities for Doing Business" in 2008; It was also ranked 9th out of 200 MSAs for "Best Places for Businesses and Careers" by Forbes Magazine in 2008. Sources
U.S Census Bureau, The Spokesman Review, Greater Spokane, Developing Spokane
RELATED ITEMS Nielsen 2013-2014 OMA Ranks
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o 2014, Television Bureau of Advertising, Inc. All rights reserved. Republication and redistribution of this report in total, other than by TVB members or its authorized agents or designees, without written permission is strictly forbidden. Any republication, in whole or in part, must include credit to TVB and its sources. Terms of Use .
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httn·//ururw tvh nra/m::irlcP.tc: c:fatinnc: 7/7/?.014 Occupations in Spokane City, Washington
Male:
• Management, Professional, And Related Occupations: 30.6% • Service Occupations: 15. 3% • Sales And Office Occupations: 20.5% • Farming, Fishing, And Forestry Occupations 0.4% • Construction, Extraction, And Maintenance Occupations: 14. 5%
Female:
e Management, Professional, And Related Occupations: 34.3% • Service Occupations: 22. 3% • Sales And Office Occupations: 37.0% • Farming, Fishing, And Forestry Occupations 0.3% • Construction, Extraction, And Maintenance Occupations: 0.8%
Source: www.citymelt.com Spokane: Economy - Major Industries and Commercial Activity Page 1of3
City-Data.com :: Cities of the United States :: The West Spokane: Economy
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Major Industries and Commercial Activity
Natural resources have traditionally provided much of the economic activity for the Spokane area, a major center for the timber, agriculture, and mining industries in the region. A number of manufacturing companies have located in Spokane, drawn by the easy access to raw materials. Finished wood products, metal refinery and fabrication, and food processing are among the leaders in manufacturing. The outlying areas are part of an abundant agricultural system, providing a large amount of the nation's apples, peas, hops, pears, asparagus, lentils, soft wheat, and sweet cherries. A number of wineries and breweries also operate in the area. These industries continue to be important elements in the local economy, but in recent years the economy has diversified to encompass high-technology and service companies. Health-related industries employ more people than any other industry in Spokane. The city provides specialized care to many patients from the surrounding areas, as far north as the Canadian border. The city is also the wholesale and retail trade and service center of the 80,000- square-mile Inland Northwest region. In addition, the educational services industry employed the most workers in 2002 with more than 17,000 jobs.
All branches of the U.S. armed forces are represented in Spokane County. The largest military facility is Fairchild Air Force Base, which employs 3,359 military and 863 civilian personnel. The military units and their personnel combine to have an economic impact on the regional economy of $411 million annually. Tourism is the fourth largest industry in the state, and Spokane is a center for tourist activity. Health care accounts for approximately 13.5 percent of the local employment base. Spokane has also seen the recent development of economic activity in the lucrative high-tech and biotech sectors. The city is the site of a 100-block wireless network- the largest of its kind in the country-which is seen as symbolic of its dedication to the development of technological opportunities and resources.
In 2002 Kaiser Aluminum, a major employer with a 60-year presence in the region, filed for bankruptcy. Despite the loss of jobs and revenue, Spokane has rebounded by working to make the city attractive to retail and small businesses.
Items and goods produced: silver, lead, zinc, timber, poultry, dairy, vegetable, fruit, and meat products, aluminum, magnesium, clay and cement products, machinery and metal products, flour, feed, cereal, petroleum products, paper, electrical fixtures
Incentive Programs-New and Existing Businesses
Local programs
The Spokane Area Economic Development Council works with businesses to locate and utilize local and state business incentives. The Spokane Neighborhood Economic Development Alliance offers two revolving loans to businesses and nonprofits expanding or creating new jobs in Spokane.
State programs
A wide variety of tax incentives exist at the state level for businesses operating, expanding, or relocating to Spokane. Industry- and area-specific tax incentives are available, as well as loans, bonds, credits, and grants.
Job training programs
Spokane businesses are assisted largely by working with the higher education community, including such organizations as Applied Technology Center, part of the Community Colleges of Spokane; ITI Technical Institute, which focuses on preparing graduates for careers in technology, and the Spokane Intercollegiate Research and Technology Institute, which uses the collective resources of local colleges to accelerate the development of technology companies. The Spokane Area Workforce
httn·//um.m1 ritv-rl~fa r.om'11c:-r.itiP.c:IThP.-WP.c:t/Snok::mP.-Fr.onomv html 6121/2014 Spokane: Economy - Major Industries and Commercial Activity Page 2of3
Development Council administers employment and training programs for local economically disadvantaged youths and adults through the Spokane City-County Employment and Training Consortium. The Council also supports local economic growth by working to improve the workforce development system.
Development Projects
In 2000, the Spokane Symphony purchased the 1931 Art Deco Fox Theater and is conducting a $28.4 renovation and restoration of the building. Development is also ongoing in the Davenport Arts District, a 10-block area adjacent to the Davenport Hotel (which was reopened in 2002 after renovations), which is filled with new and proposed galleries, restaurants, performance venues, and a jazz club. Spokane's River Park Square, a downtown redevelopment project that is considered one of the city's most ambitious in decades, has continued to expand. The 400,000-square-foot property includes two full-service restaurants; each fills 8,000 square feet and has its own entrance. The $110 million River Park Square mall is anchored by a 137,000-square-foot Nordstrom store and a 90,000-square-foot AMC Theatres multiscreen cinema.
In 2003, ground was broken for the new CenterPlace facility at the 77-acre, multi-use development Mirabeau Point in the Spokane Valley. Mirabeau Point already includes a 45,000-square-foot YMCA complex, a 37,000-square-foot cultural/senior center, a central plaza, hiking trails, an ice skating pond, and multiple park areas. Also begun in 2003 and slated for completion in 2007 is a major expansion of the Spokane Convention Center. Budgeted at $80 million total and working in phases, the renovation and construction consists of new amenities in the existing areas, and a new 100,000 square foot exhibition hall. Developers are committed to employing environmentally-friendly building techniques throughout the project, including non-toxic materials and utilizing energy efficiency, natural light, and water conservation.
Expected to begin in June 2005 the city of Spokane has set aside $117 million for street improvements over a 10-year period. The project will repair about 110 miles of residential streets and arterials throughout Spokane.
Economic Development Information: Economic Development Council, 801 West Riverside, Suite 302, Spokane, WA 99201; telephone (800)SPOKANE; email [email protected].
Commercial Shipping
More than 30 air freight companies operate facilities at Spokane International Airport, and the Burlington Northern and Union Pacific railroads also serve the city. Many motor freight concerns operate regularly scheduled trucks in and out of Spokane.
Labor Force and Employment Outlook
A large, experienced work force is available in Spokane; about 80 percent of workers are native Washingtonians. The health and service industries enjoy strong employment outlooks, as does manufacturing. Seasonal employment at harvest time is always available.
The following is a summary of data regarding the Spokane metropolitan area labor force, 2004 annual averages.
Size of non-agricultural labor force: 199,700
Number of workers employed in ...
mining and construction: 11,600
manufacturing: 17 ,200
transportation, trade, and public utilities: 41 ,000
information: 3,000
financial activities: 12,600
professional and business services: 20,800
education and health services: 33,000
leisure and hospitality: 18,200
l'\/?~/?O 14 Spokane: Economy - Major Industries and Commercial Activity Page 3 of3
other services: 8,900
government: 33,600
Average hourly earnings ofproduction workers employed in manufacturing: $18.27 (2004 annual statewide average)
Unemployment rate: 7.1% (February 2005)
l..i fr~11 t lf:'l"'-"eo .\ ~l't'#f('11~IU\ «1 I Jih.:bUJ Ah h C\'"t 9.l!iil: '."' 16 !'lo•T Largest employers Number of employees Fairchild Air Force Base 5,616 Sacred Heart Medical Center 3,232 U.S. Federal Government 3,174 Spokane School District 81 3, 126 State of Washington 2,878 Cost of living The following is a summary of data regarding key cost of living factors for the Spokane area. 2004 (3rd Quarter) ACCRA Average House Price: $255,323 2004 (3rd Quarter) ACCRA Cost of Living Index: 102.8 (U.S. average= 100.0) State income tax rate: None State sales tax rate: 6.5% (food and prescription drugs are exempt) Local income tax rate: None Local sales tax rate: 2% Property tax rate: Averages $14.94 in city, $14.21 in county, per $1,000 of assessed value (2005) Economic Information: Economic Development Council, 801 West Riverside, Suite 302, Spokane, WA 99201; telephone (800)SPOKANE; email [email protected]. Department of Revenue, Taxpayer Information and Education Section, PO Box 47478, Olympia, WA 98504-7478; telephone (800)829-1040; email [email protected]. Spokane Area Chamber of Commerce, 801 West Riverside Avenue, Spokane, WA 99201; telephone (509)624-1393; fax (509)747-0077; email [email protected] Discuss this city on our active forum. « Spokane: Municipal Government Spokane: Education and Research » ,______.! Search our site Copynght ~ 2009 Advameg. Inc EXHIBT F MAPQUEST MAP WITH DISTANCE AND DRIVING DIRECTIONS FROM EUREKA TO SPOKANE Driving Directions from Eureka, Montana to Spokane, Washington I MapQ1 Total Travel Estimate: 226.71 miles - about 4 hours 11 minutes FREE NAVIGATION APP Enter your moone: numu~1 SELECT: 0 !PHONE 0 ANDROID COLVILLE C-olv1l a 0 W.TiONAL FORCST ChllWIJl ilh 0 Nowporl Q IOAHO PAIHANDLE NATIONAl FORESTS ThO IT!p ~on r 0 ~3MapQuest - Portlons@2013 Nl.V1EQ I Terms I ~ ©2013 MapQuest, Inc. Use of directions and maps is subject to the MapQuest Tenns of Use. We make no guarantee of the accuracy of their content. road conditions or route usability. You assume all risk of use. View Tenns of Use 1 1 /") 1 /")() 1 '2 Driving Directions from Eurek~ Montana to Spokane, Washington I MapQuest Page 1 of 2 Notes m; mapquest· Trip to: Spokane, WJ:l 226.71 miles/ 4 hours 11 minutes Eureka, MT Download Free App 1. Start out going north on Dewey Ave I US-93 toward 3rd St E. Continue to follow 1.7 Mi • ' US-513. Map 1.7 Mi Total 2. Turn left onto MT-37. Mao 67.0Mi 68.7 Mi Total ,. {2i. 3. Tum right onto W 9th St I US-2. Continue to follow US-2 (Crossing into Idaho). Map 48.1 Mi ~ 116.8 Mi Total rsourn) 4. Tum left onto US-95 S I US-2 W. Continue to follow US-95 S. Map 79.1 Mi (ill 195.9 Mi Total t .t mm 5. Mc~rge onto 1-90 W toward Post Falls I Spokane (Crossing into Washington). Map 30.2Mi ~ 226. 1 Mi Total 6. Take the US-2 N I US-395 N exit, EXIT 281 , toward Newport I Colville. Map 0.3 Mi 226.4 Mi Total I EAST I 7. Tum slight right onto s Division St I US-2 EI US-395 N. Map 0.3 Mi ·GJ 226. 7 M1 Total 8. Take the 3rd left onto W Sprague Ave. Map 0.05Mi 226. 7 Mi Total • 9. Welcome to SPOKANE, WA. Map ' Spokane, WA EXHIBIT G 800-SIGNATURE PETITION FROM TOBACCO VALLEY CUSTOMERS AND MINUTES OF MONTANA STATE LEGISLATIVE COMMITTEE ..... Petition To Change Eureka OMA {Designsted Market Area) from Spokane WA to Missoula, MT CONTACT NUMBER 1 ,,.., , re.b /l2C L ~ ·_d'l7-- ~v:::. 2 3 4 5 6 7 s ..J.1-. ~ . r'>J'1-ff'IY~ > 1 ~ !:==?; , v ...... ~~ ~ · --'- -, , - / !:! / dt=-!.. ,, ~e.1 8-.n ~ r~t:N~ 10 11 12 13 14 15 ~6 17 rn<'fb\,"''/~ I -~-u 1~1,,._ /-r-r '-~I<,.,. I tr6 L--117z l-=z,,f\'fkV-1'(-'2'.'/'?='jp.co I 18 19 20 21 22 23 24 25 Petit io n To Change Eureka OMA (Oesignsted Market Area) from Spokane WA to Missoula, MT t1 (,()~\I. ADDRESS CONTACT NUMBER 1 L{O& - Y'~'f - 3 CJ> 4 0 2 ~bb-~t-~ ql{,15 3 ~ . Q~~ B .~~-353~ 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 .. . ~ "'. 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