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1025 Connecticut Avenue, NW Suite 1011 Washington, DC 20036 telephone 202.789.3120 facsimile 202.789.3112 www.telecomlawpros.com [email protected] 202.789.3115 August 22, 2017 VIA ELECTRONIC COMMENT FILING SYSTEM Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, SW Washington, D.C. 20054 Re: In the Matter of Assessment and Collection of Regulatory Fees for Fiscal Year 2017 MD Docket No. 17-134 Notice of Ex Parte Communication Dear Ms. Dortch: On August 22, 2017, undersigned counsel to Ramar Communications, Inc. (“Ramar”) held a telephone conversation with Holly Saurer, Acting Legal Advisor to Commissioner Jessica Rosenworcel. In the conversation, I addressed issues raised by Ramar in its June 22, 2017 Comments in MD Docket No. 17-134 relating to the “satellite” status of certain Ramar television stations in the Albuquerque-Santa Fe DMA (“ASFD”) for purposes of annual regulatory fees. Ramar asked that the Commission afford it equitable regulatory fee treatment vis-à-vis all other satellite television stations – i.e., those which need waivers pursuant to Note 5 of 47 C.F.R. § 73.3555 due to predicted signal contour overlap between parent and satellite, and those with no such overlap and no need for Note 5 waivers. Ramar pointed out that all satellite stations are “second class citizens” in the competitive marketplace, and that the Commission has historically assessed lower regulatory fees on all stations listed as satellites in standard industry publications, whether or not the station needed a Note 5 waiver. With respect to the AFSD, where Note 5 waivers are typically not needed by satellites because of that DMA’s vast geographic area, Ramar supplied illustrative maps, copies of which are attached hereto, showing the starkly inferior nature of the ASFD over-the-air coverage of satellite stations versus those stations’ parents. For example, KUPT covers only 3.26 percent of the ASFD’s population and 2.15 percent of its area. Ramar proposed that in this year’s regulatory fee order the Commission grant regulatory fee relief to any TV station not listed in Appendix E to the NPRM, FCC 17-62, which makes a two-pronged showing: (i) through a current listing in the Television and Cable Factbook or BIA, that it is {00113380;v1} August 22, 2017 Page 2 recognized within the industry as a satellite; and (ii) through an industry broker’s letter consistent with Commission Note 5 waiver precedent, that it is not a standalone station. Ramar asks the satellite fee be applied to stations that make both showings. In the alternative, drawing on the discussion in ¶ 22 of the NPRM, Ramar suggests that relief take the form of a fee that is 50 percent of the $5,000 Remaining Markets fee, or $2,500 (which is more than the Appendix E station fee). The predicate underlying Ramar’s proposal is that such industry-recognized, non-standalone satellite stations need and deserve relief from high full-market fees that imperil their future. Such high fees dwarf those of competing satellite stations which, due to the happenstance of signal contour overlap, need Note 5 waivers. The two prongs will ensure that the universe of stations entitled to this relief is small and self- contained (industry-recognized satellites only) and deserving (like Note 5 waiver satellites, these satellites are not standalone stations). Sincerely, /s/ Dennis P. Corbett Dennis P. Corbett of TELECOMMUNICATIONS LAW PROFESSIONALS PLLC cc (via email): Holly Saurer {00113380;v1} ATTACHMENT Colorado Springs Chesapeake RF Consultants, LLC Radiofrequency Consulting Engineers KASA-TV Santa Fe/ NM Digital Television and Radio Canon City Q Pueblo KUPT(DT) Hobbs, NM DMA and Coverage Contour prepared for Ramar Communications, Inc. July, 2016 0 Amanlfo Albuquerque - Santa Fe, NM DMA f,/,,, SM ,0 Snyder 0 0 SweeiWBt'erôss'em £ A/A Q Big Spring 0 ^sdlland 8row\ San Angsh Heros'ca lôgafes 0 Coverage Contour Within DMA Population (201D Census) Albuquerque - Santa Fe, NM Persons Percent of DMA Scale 1:5,000,000 DMA Total 1,899,485 308,818 KASA-W Santa Fe, NM 1/160,551 61.10% 58,372 18.90% 70 140 210 KUPT(DT) Hobbs, NM 62,004 3.26% 6,641 2.15% Colorado Springs Chesapeake RF Consultants, LLC [^\&o\soo\cS:î£\ Radiofrequenc/ Consulting Engineers KRQE(DT) Albuquerque, NM Digital Television and Radio Canon City Q \_^vs^ Paehta KBIM-TV Roswell/ NM DMA and Coverage Contour prepared for Ramar Communications, Inc. July, 2016 KRQE Ch. 13 Albuquerque, NM 36 dBp Contour (NLSQ Albuquerque - Santa Fe, MM DMA \,.^. 8row\ Heroica ôgafes Aws'prieta 0 Coverage Contour Within DMA Population (2010 Census) Albuquerque - Santa Fe, NM Persons Percent of DMA DMA Total 1/899,485 308,818 km KRQE Albuquerque, NM 1,159,437 61.04% 58,208 18.85% 70 140 210 KBIM-TV Roswell, NM 181,868 9.57% 35,920 11.63% Colorado Springs \^^^^j Chesapeake RF Consultants, LLC Radiofrequenc/ Consul ting Engineers KOB(DT) Albuquerque, NM Digital Television and Radio Canon City Q Puebto KOBR(DT) Roswell/ NM DMA and Coverage Contour prepared for Ramar Communications/ Inc. July, 2016 KOB Ch. 26 Albuquerque, NM 41 dBp Contour (NLSC) 0 AmanHo Albuquerque - Santa Fe, NM DM^, 0 -escc't.i' ~Â 0 Peor.^ PhGemx 0 Casa Gr8!~aSe Q . .0 Sweetivater AbHem 0 Tucson 0 Green VaSSey Brow\ 0 Sierra Vista Ssn Ange/c Hsrosca ^fogaies Aaue'pneta 0 Coverage Contour Within DMA Population (2010 Census) Albuquerque - Santa Fe, MM Persons Percent of DMA Scale 1:5,000,000 DMA Total 1,899,485 308,818 KOB Albuquerque, MM 1,157,063 60.91% 54,935 17.79% 70 140 210 KOBR Roswell, NM 174,528 9.19% 31,915 10.33% Coforado Spring, Chesapeake RF Consultants, LLC Radiofrequenc^ Consulting Engineers KWBQ(DT) Santa Fe, NM Digital Television and Radio Canon Oty Q KRWB-TV Roswell, MM Pueblo DMA and Coverage Contour prepared for Ramar Communications/ Inc. KWBQ Ch. 29 Santa Fe, NM 41 dBp Contour (NLSQ Albuquerque - Santa Fe, NM DMA 0 Peor^ Phoenix Roswell, MM 41 dBu Contour (NLSC) 0 0 Swee!:wst:er^'lene Coverage Contour Within DMA Population (2010 Census) Albuquerque - Santa Fe, NM Persons Percent of DMA (sq km) Percent of DMA Scale 1:5,000,000 DMA Total 1,899,485 308,818 KWBQ Santa Fe, MM 1/152,967 54,032 KRWB-TV Roswell NM 106,479 15,265.

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