Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554

In the Matter of

Future of Media and Information Needs GN Docket No. 10-25 of Communities in a Digital Age

COMMENTS OF BELO CORP.

Belo Corp. (“Belo” or “the Company”)1 hereby submits its Comments in response to the FCC’s Public Notice released on January 21, 2010 in the above-referenced proceeding, in order to assist the Commission in its assessment of Americans’ access to vibrant, diverse sources of news and information. As discussed in more detail below,

Americans have access to a vast amount of diverse news and information content, thanks in no small part to the public service provided by Belo and other broadcasters. Moreover, although digital television is still in its infancy, it already has allowed Belo and other television broadcasters to implement innovative new services and pursue new opportunities to better serve their audiences. Television operators surely will continue to explore new ways to use DTV technology to enhance their roles as public servants. Most importantly, the Commission should recognize that Belo, like many other broadcasters,

1 Belo is one of the nation’s largest pure-play, publicly-traded television companies. It owns and operates 20 television stations, reaching more than 14 percent of U.S. television households in 15 markets. Belo stations consistently deliver distinguished journalism for which they have received significant industry recognition including 12 Alfred I. duPont- Columbia University Silver Baton Awards; 11 George Foster Peabody Awards; and 26 national Edward R. Murrow Awards – all since 2000, and in each case more than any other commercial station group in the nation. Additionally, the Company has created regional cable news channels in Texas and the Northwest increasing its impact in those regions.

provides exemplary pubic services not because of regulatory obligations, but because such service is at the core of the Company’s business model and defines its role in the community.2 Additional regulatory burdens in this regard, therefore, are not needed and would be counterproductive.

Belo Stations Exemplify the Outstanding And Unique Public Services TV Broadcasters Across the Country Consistently Provide to Their Communities

During Belo’s approximately 60 years as a television broadcaster, the Company’s television stations have upheld a tradition of journalistic excellence, providing their home communities with free local news, sports, and weather reports, up-to-the-minute emergency information, extensive coverage of local elections and politics, and community- oriented programming. Belo, like many television operators across the country, recognizes that broadcasters are an integral part of the communities they serve, and therefore are better-positioned than many of their competitors to provide such content. Three quarters of Belo’s full-power television stations produce original local newscasts, with most offering 30 hours or more per week of such programming on their primary channels alone.

Not surprisingly, Belo stations routinely receive awards acknowledging the

Company’s high journalistic standards and commitment to serving its stations’ local communities. For example, Belo station KHOU-TV, which serves Houston, TX, recently received a Peabody Award, a duPont-Columbia Award, the IRE Medal from Investigative

Reporters and Editors, and a National Headliner Award for a two-year series of stories and

2 Belo has demonstrated to the Commission on many occasions that locally-oriented journalism and community service are at the core of the Company’s business. See, e.g., Comments of Belo Corp. in response to NBP Public Notice #26, GN Docket Nos. 09-47, 09-51, and 09-137 (Dec. 21, 2009) (“Belo NBP #26 Comments”); Comments of Belo Corp., MB Docket No. 04-233 (April 28, 2008) (“Belo Localism Comments”).

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a documentary broadcast last summer about discrimination within the Texas National

Guard. The series Under Fire: Discrimination and Corruption in the Texas National

Guard detailed discrimination against female soldiers in the Texas National Guard and resulted in the appointment of a new commanding general and the dismissals of three

Texas National Guard generals.

Americans also have access to extensive free, up to date information during local emergencies, thanks to the efforts of Belo and other local broadcasters. Broadcast stations are by far the best mechanism for disseminating such information efficiently throughout communities, because broadcasters are part of those communities and because they employ a one-to-many distribution model, in contrast to the less-efficient one-to-one model employed by some of their competitors. Belo’s stations consistently provide emergency information to the communities they serve, and remain committed to doing so.

For example, Belo station WWL-TV, New Orleans, Louisiana provided extensive emergency coverage of Hurricane Katrina in 2005. WWL was the only local television news outlet to remain on-the-air throughout the various stages of this devastating storm, providing emergency coverage for 15 straight days before resuming carriage of CBS network programming. The station’s coverage began three days before Katrina made landfall, ensuring that the community was aware of the impending danger, as well as critical evacuation and safety plans. WWL remained on the air throughout the crisis, broadcasting from its own transmitter facilities as well as temporary studios at Louisiana

State University in Baton Rouge and the facilities of Louisiana Public Broadcasting.

Cell phones and other communications devices were severely limited by the storm.

As a result, WWL was the main source of ongoing information about the storm and its

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impacts, as well as about how members of the community could get help or assist in relief efforts. Local government officials relied extensively on WWL to communicate information to the public, because, in many cases, local government could not do so itself.

Belo and other communications entities took additional, creative steps to ensure that members of the community had access to WWL’s emergency content. For example,

WWL’s coverage of Hurricane Katrina was carried throughout all of Louisiana and

Mississippi on a network of digital channels, public television stations, and cable channels.

Several radio stations simulcasted the audio portion of WWL’s feed, and Echostar retransmitted WWL’s signal to communities in Texas that were assisting in the evacuation efforts. WWL also streamed its broadcasts live on its Web site, experiencing unprecedented use by the public. In recognition of these extraordinary efforts, WWL became the first station ever to win the prestigious triple crown of news journalism – a duPont-Columbia award, a national Edward R. Murrow award, and a Peabody award – for coverage of the same event.

KHOU-TV also is committed to keeping its community informed during local emergencies. In 2005, KHOU provided 60 hours of continuous, commercial-free coverage of Hurricane Rita. Similarly, the station provided 91 hours of uninterrupted coverage of

Hurricane Ike in 2008.3

Because they are integral parts of the communities they serve, local television and radio stations also are in the best position to provide the communities they serve with extensive local and regional political coverage. Like many broadcasters, Belo takes its obligation to provide such programming seriously. For example, since 1996, Belo stations

3 See, e.g., Belo NBP #26 Comments at 5-6.

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have offered vast amounts of free airtime to state and federal candidates. They also provide extensive political coverage in the weeks leading up to elections and often sponsor and air numerous candidate debates for both local and national races.

Broadcasters enhance the community services of local non-profit organizations.

Besides the millions of dollars raised year after year by broadcasters to support local non- profits, broadcasters are even more directly involved. When the Southern Arizona Big

Brothers and Big Sisters organization had severe problems recruiting mentors for young men and women in Tucson, Arizona, Belo’s KMSB-TV took the media lead and dedicated public service announcements on air and numerous news stories during the campaign to recruit new mentors. The goal was to recruit 100 new mentors. When the campaign concluded a month later, over 400 new volunteers came forward and the number kept growing after the campaign ended. The station leveraged its services for one month and the local community will benefit for years to come.

Belo and Other Television Broadcasters Are Using Digital Television Technology to Implement Innovative New Services and Pursue New Opportunities to Better Serve Their Local Communities

Even though digital television is still in its infancy, and the DTV transition cost broadcasters an estimated one billion dollars, much of which was borne during the continuing economic downturn, Belo and other broadcasters are already using nascent

DTV technology effectively to provide more content to the communities they service in new ways. In addition to HD programming, Belo stations are using DTV technology to provide multicast channels and other enhanced offerings to their local communities. Belo currently operates 17 multicast channels, with plans to launch several more by year’s end.

Several Belo stations provide extensive local news programming – both time-shifted and

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additional content – on their multicast channels, which makes local news and information content far more accessible to viewers. For example, Belo station KTVB, Boise, Idaho, has dedicated its multicast capacity almost exclusively to the provision of local news, information, and public affairs. One multicast stream offers 16 or more hours of local news on weekdays and more than 25 hours of local news on weekends. Another stream simulcasts a regional cable news network owned by Belo, thereby making that extensive local content available to more people, free and over-the-air, on a 24-hour basis.

Multicast channels allow broadcasters to increase the reach of their emergency information programming as well. Belo stations routinely use multicast channels to provide emergency weather reports and other emergency information, including Amber

Alerts, school closings, and information about time-sensitive environmental or health situations. Like many other TV broadcasters, Belo also uses its stations’ multicast channels to provide expanded coverage of community events, political content, local and regional sports programming, and other local and hyper-local programming that was not feasible in a single-channel environment. Belo’s multicast channels also provide programming to niche and underserved audiences. For example, Belo stations now provide the Spanish-language programming of the Estrella TV network on multicast channels in four markets.4

4 The U.S. Government Accountability Office recently concluded that a disproportionately large proportion of Spanish language speakers residing in the U.S. rely exclusively on over-the-air television for video service. See Digital Broadcast Television Transition Estimated Cost of Supporting Set-Top Boxes to Help Advance the DTV Transition, GAO- 05-258T, at 4 (Feb. 17, 2005) (“Additionally, non-white and Hispanic households are more likely to rely on over-the-air television than are white and non-Hispanic households.”), available at http://www.gao.gov/new.items/d05258t.pdf. This is the case in several of Belo’s markets. For example, Nielsen Company estimates that, while 17.9% of total households in the Houston Designated Market Area (where Belo owns and operates station

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In addition, Belo and many other broadcasters are committed to developing mobile television service as a new and robust means to deliver news and information content to

Americans. Belo has been actively involved in the Open Mobile Video Coalition

(“OMVC”), an alliance of U.S. commercial and public broadcasters formed to accelerate the development and rollout of mobile DTV products and services. Belo station WCNC-

TV serves as a mobile DTV test station, and Belo stations KONG(TV), Everett,

Washington and KVUE(TV), Austin, Texas, are serving as OMVC primary model stations, providing consumer electronics manufacturers an opportunity to test receivers and consumer devices with a real-world over-the-air signal.5 Similarly, Belo – along with Cox,

Fox, Gannett, Hearst, ION Television, Media General, Meredith, NBC, Post-Newsweek,

Raycom Media, and Scripps – recently formed a standalone joint venture called Pearl

Mobile DTV Company LLC to develop a new national mobile video content service. This service will use existing broadcast spectrum provided by several members of the joint venture that has the capacity to reach approximately 150 million U.S. residents to provide content such as local and national news, sports and entertainment programming, and both live and on-demand video to mobile devices. 6

KHOU) rely on over-the-air television, 37.8% of the Hispanic households in the Houston DMA are dependent on over-the-air service. Accordingly, use of DTV multicast channels to serve Spanish-speaking audiences by Belo and other broadcasters is an important mechanism for providing news and information content to members of the community that otherwise would be unserved.

5 See, e.g., Belo NBP #26 Comments at 5-6.

6 See, e.g., digitalmediawire, Broadcasters' Joint Venture to Create Mobile TV Network, April 13, 2010, available at http://dmwmedia.com/news/2010/04/13/broadcasters039- joint-venture-create-mobile-tv-network.

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Broadcasters will be able to use mobile TV to make information, entertainment, and other content accessible from virtually any location. In emergency situations like

Hurricane Katrina, when other forms of communication are limited or unavailable, mobile

DTV devices will provide vital and useful information to the public on a real time basis.

Mobile DTV also will offer a critical public service when Web sites containing local news and information become overloaded from significant and sudden increases in page views and cannot perform with the same effectiveness, quality, and consistency of normal operations.

Ill-Advised Public Service Regulations Would Hamper the Ability of Belo and Other Television Broadcasters to Provide News and Information Content to Americans

As noted above, Belo’s stations provide excellent news and information content to the communities they serve not because of regulatory command, but because Belo’s stations are integral parts of those communities and because public service is a central part of the Company’s history, culture, and business model. Ill-advised regulatory requirements relating to the provision of local news and information will not help Belo or other broadcasters better serve their communities. Indeed, such regulations would have precisely the opposite effect.

It is no secret that the recent economic downturn has been difficult for businesses generally, and broadcasters in particular. Broadcasters faced steep declines in local advertising revenues (which represent 90 percent of all station revenues) and growing competition from new media. At the same time, broadcasters have just shouldered the enormous cost burden associated with the DTV transition, and must invest additional time and resources to maximize their use of DTV technology to serve their local communities.

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As a result of these and other economic pressures, TV newsrooms increasingly must produce more – and more innovative – news and information content with fewer people and resources.7 In order to sustain their commitment to local service, broadcasters must be able to allocate their limited resources efficiently. To do so, broadcasters must have regulatory certainty and must avoid diverting resources best employed for creating local news, information, and entertainment content to other unnecessary and counterproductive tasks.

In this regard, Belo and others have provided extensive evidence to demonstrate that the exponential expansion of the broadcasters’ information collection and reporting requirements contemplated in the ongoing enhanced disclosure proceeding would result in enormous additional burdens on broadcasters and their resources, with no significant public interest benefit.8 Similarly, while the obligations contemplated in the Commission’s ongoing broadcast localism proceeding will require a large expenditure of stations’ time, manpower, and resources, they will do little or nothing to improve stations’ service to their communities.9 Instead of imposing additional and unnecessary regulatory burdens, the

FCC should encourage broadcasters like Belo to expend their resources doing what they do

7 See, e.g., Radio Television Digital News Association, News Release, RTDNA/Hofstra Survey Finds TV Doing More With Less, Optimism On Staffing (April 14, 2010), available at http://www.rtdna.org/pages/posts/rtdnahofstra-survey-finds-tv-d.oing-more-with-less- optimism-on-staffing920.php.

8 See, e.g., Comments of Broadcast Industry Coalition on Proposed Information Collection Requirements, MM Docket Nos. 00-44 and 00-168, and OMB Control No. 3060-0214 (May 12, 2008). Belo was part of the coalition that submitted these comments.

9 See, e.g., Belo Localism Comments.

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best – developing local news, information, and entertainment content and providing it to members of the communities they serve.

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At the dawn of the digital age, we have every reason to be excited about

Americans’ access to news and information. Americans get a wide range of such content from a wide variety of sources, and broadcast television remains an important and essential part of the mix. The implementation of digital technology has provided broadcasters with new and unique ways to provide local news and information to Americans, especially underserved and niche audiences. As a result, broadcast stations are even more important sources of news and information today than they have been in the past. Belo and other broadcasters remain committed to providing important news and information content to the communities they serve and, absent counterproductive and crippling regulation, will continue to do so well into the future.

Respectfully submitted,

Belo Corp.

By: /s/ / Guy H. Kerr Executive Vice President/Law and Government Russell F. Coleman Senior Vice President/General Counsel BELO CORP. 400 South Record Street Dallas, Texas 75202 May 7, 2010 (214) 977-6606

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