Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C.

Examination of the Future of Media ) and Information Needs of ) Gen. Docket No. 10-25 Communities in a Digital Age )

COMMENTS OF BARRINGTON BROADCASTING GROUP, LLC, CORP., DISPATCH BROADCAST GROUP, FREEDOM BROADCASTING, INC., GANNETT CO., INC., POST-NEWSWEEK STATIONS, INC., AND RAYCOM MEDIA, INC.

Kurt Wimmer Elizabeth Canter COVINGTON & BURLING, LLP 1201 Pennsylvania Avenue, N.W. Washington, D.C. 20004-2401 (202) 662-6000

MAY 7, 2010

TABLE OF CONTENTS

Page

Introduction and Summary...... 1

I. Local Broadcast Journalism Is an Essential Part of the Media and Marketplace That Is Not Being Displaced by New Media...... 2

II. Local Broadcast Journalists Are Embracing New Technologies to Better Serve Their Local Communities...... 9

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Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C.

Examination of the Future of Media ) and Information Needs of ) Gen. Docket No. 10-25 Communities in a Digital Age )

COMMENTS OF BARRINGTON BROADCASTING GROUP, LLC, BELO CORP., DISPATCH BROADCAST GROUP, FREEDOM BROADCASTING, INC., GANNETT CO., INC., POST-NEWSWEEK STATIONS, INC., AND RAYCOM MEDIA, INC.

INTRODUCTION AND SUMMARY

The television broadcast stations of Barrington Broadcasting Group,

LLC, Belo Corp., Dispatch Broadcast Group, Freedom Broadcasting, Inc., Gannett

Co., Inc., Post-Newsweek Stations, Inc., and Raycom Media, Inc. serve the public in

almost 150 communities across the . The communities we serve range from top-ten cities to smaller towns, stretching from Maine to Hawaii.

We have seen firsthand how the content and advertising competition created by Internet sources and other new-media platforms has significantly challenged all news organizations, and local television journalism is no exception.

Broadcasters across the country must do more with fewer resources. Even as we create new efficiencies, however, television broadcast journalism remains a central foundation of the local media ecosystem in all of our markets. Our role — particularly in times of crisis — has not been, and will not be, displaced by new- media content providers. In fact, our role is being expanded and energized as we

deploy new digital technologies to engage with our audiences more directly, more

efficiently gather news, more efficiently distribute content on multiple screens, and

more creatively serve our communities.

These comments provide concrete examples of how local television

journalism is meeting the information needs of communities in a way that is not

being, and perhaps cannot be, fully met by new media. These examples are

qualitative only — they only provide examples of the hundreds of investigative,

emergency and other journalistic efforts being undertaken by television stations

every day. We also will provide an overview of how television broadcasters are, in

fact, new media— television journalists are embracing new-media technologies to

better serve local communities in markets of all sizes across the country.

I. Local Broadcast Journalism Is an Essential Part of the Media and Marketplace That Is Not Being Displaced by New Media.

There is no doubt that new technologies have created significant new diversity in content and competition for advertising in markets of all sizes across the United States. New technology has not, however, changed the primacy of local broadcasting as the central source for local news, sports, and weather coverage in our communities. This is particularly true in times of crisis, when emergency journalism becomes essential to the lives of those we serve.

Local television journalism has earned a central place in the local media ecosystem by being the trusted voice of the community. Recent survey research confirms that local broadcast journalism remains the most trusted medium

— to us, this result is not surprising but merely confirms our experience in

2 reporting daily in our communities.1 This trust enables local broadcasters to serve

their communities as investigative journalists, focusing, in many cases, on local

issues that do not receive attention on the national stage.

Television investigative journalism leads to changes in law and

regulation. In particular, local television journalists often expose serious

deficiencies in local law enforcement and safety regulation. Because of the

prominence that television journalists can give to these stories, the public can be

effectively alerted about dangers — and local political officials, law enforcement

officials, regulators and business owners often respond by correcting dangerous

conditions for the benefit of local communities.

For example, Station KMOV in St. Louis, Missouri, aired more than a

dozen reports over an eight-month period about the crime rate in East St. Louis,

Illinois and a pattern of problems within the East St. Louis police. As a result of its

coverage, city officials, including the chief of police, resigned and the city police

department relinquished jurisdiction over homicide cases to the Illinois State Police.

Station KTVB in Boise, Idaho, exposed a loophole in an Idaho law intended to

prevent registered sex offenders from living near schools: because the law failed to

task any law enforcement agency with monitoring and enforcing the law, no one

was monitoring or enforcing it, and KTVB uncovered several registered sex

1 The Pew Research Center for the People & The Press, PUBLIC EVALUATIONS OF THE NEWS MEDIA: 1985-2009, PRESS ACCURACY RATING HITS TWO DECADE LOW (September 12, 2009) (favorability ratings of local television news remains at the top of all media, with 73 percent of respondents considering it favorable).

3 offenders living in close proximity to schools. In Louisville, Kentucky, an

investigation by Station WHAS-TV on sexual contact between prison guards and

inmates led to a new state law signed into effect last month. And after Station

WPLG, Miami, Florida, uncovered that inmates, many of whom did not have

licenses to drive, were permitted to drive county vehicles while on work release,

Florida enacted a new law banning the practice.

Television reporting produces major changes in the behavior of local

businesses, as well. Following a story aired by Station WFAA, Dallas, Texas, about

serious problems in the infrastructure used to distribute natural gas throughout

North Texas — problems that may have caused the explosion of a home and two

deaths — the natural gas utility serving the region replaced more than 30,000 parts

throughout its system. When Station KSDK in St. Louis, Missouri exposed certain office supply stores that were overcharging Missouri public schools for school supplies, the state Attorney General launched his own investigation, and, as a result, state school districts will soon receive $300,000 in refunds.

Local television stations can commit to long-term investigative

journalism projects that benefit their communities. Television journalists also

are able to commit significant resources to long-term, team investigations of

important community issues in a way that most new media are not yet able to do.

For example, Station WFAA, Dallas, Texas, undertook a major investigative

initiative last year and, through in-depth research into legal documents and court

proceedings, demonstrated that more than 1,000 local felons (including 138 accused

4 murders and more than 400 accused child abusers) had simply been deported

without being prosecuted for their offenses, leaving them free to return and commit

additional crimes. As another example, Station KHOU, Houston, Texas, undertook

a two-year investigation into harassment and humiliation of women by the Texas

National Guard. This investigation uncovered not only that highly qualified women were being systematically drummed out of the Guard by an all-male leadership structure, but continued following leads that led the station to evidence of high-level embezzlement and theft. The story resulted in criminal and FBI probes, the firing of three generals, three new state laws, and the first-ever appointment of a woman as commanding general of the Guard.

Local television covers less high-profile issues that are nonetheless extremely important to local communities. Local broadcast journalism serves its communities by covering not only the high-profile issues that might be the most heavily discussed online, but also the day-to-day issues that are of great importance to our communities. When a local tax office in San Antonio garnered $7 million in overpayments but failed to adequately notify local taxpayers that they were due refunds, Station KSAT-TV uncovered the facts and provided coverage. Similarly, Station KPRC-TV, Houston, Texas, aired a story indicating that electric utility companies were employing billing practices that resulted in higher electric utility bills for viewers, prompting a Public Utility Commission review of the practice.

5 Television journalism plays an essential and unique role in

emergency journalism. The role of local broadcasting is particularly essential in

the case of emergency journalism. In case after case, local television journalists

provide life-saving information about weather emergencies and other crises, from

the collapse of the Mississippi River bridge in Minneapolis to season-after-season

coverage of hurricanes, tornadoes, snow storms, and wildfires. Stations routinely

provide around-the-clock, multi-day coverage of such weather events, at

extraordinary cost in station resources (and lost advertising revenue). Recently,

Station WFMY-TV, Greensboro, North Carolina interrupted its coverage of the

Sweet 16 Round of the NCAA basketball tournament to provide viewers with

critical information about tornadoes that had entered the region. The station

moved its coverage of the basketball game to a multicast channel and used its

primary signal to bring critical safety information to viewers. Viewers trust

television journalists to provide reliable and thorough coverage of life-threatening

emergencies. This role is supplemented by new technologies, national services and

other media, to be sure, but the central responsibility for emergency journalism in communities across the United States lies with local broadcasters. It is an

essential role that we embrace as part of the core of our service to our communities.

This is particularly true at stations in areas often affected by hurricanes, tornadoes and other seasonally recurring weather emergencies. For example, Stations WPEC, West Palm Beach, Florida, and KFDM, Beaumont, Texas, routinely air half-hour hurricane preparation programs (as well as online and print

6 hurricane survival guides) before emergencies occur, in addition to emergency

journalism coverage when emergencies do happen. Station KPRC-TV, Houston,

Texas, not only provided wall-to-wall coverage in the aftermath of Hurricane Ike, but deployed a phone bank that permitted viewers with particular needs to be matched with agencies and businesses that could help. Its efforts were credited with saving lives.

Television journalists cover health information in a way that uniquely helps communities grapple with illness. The same is true of local health information, where the reach and ubiquity of broadcasting can play an essential role in serving the needs of local communities. Last year’s H1N1 flu epidemic illustrates the vital function played by local broadcast stations with respect to local health information. National media outlets and Internet sites provided generally applicable information, but local broadcast stations provided county and community-specific information about precisely where vaccinations and medical care were available and how to obtain vaccinations and care. Stations continue to provide viewers additional types of health information targeted to local viewers. For example, Station WDIV-TV, Detroit, Michigan, regularly provides coverage of illnesses and health risks that are present in schools in specific communities in its market with an immediacy and breadth of coverage that has not been provided by online media.

The ability of local broadcast stations to add value to national stories is not limited to the health context. The national media provided coverage of federal

7 stimulus legislation enacted last year, but Station KPNX, Phoenix, Arizona

provided coverage designed to help local viewers secure loans from local banks.

Station KGW, Portland, Oregon similarly provided local coverage relating to the

national recall of millions of toys that contained lead paint. Station KGW went into

Oregon stores and found dozens of recalled toys on the shelves, prompting the

Oregon Attorney General’s Office and the Oregon state legislature to take action.

In Phoenix, Arizona, Station KTVK tackled the issue of the local impact of the

economic downturn by consulting with key business and community leaders and

broadcasting a two-hour town meeting, launched a weekly 30-minute public-affairs

program, and undertook continuing news coverage.

The continuing breadth of television coverage can coalesce

communities around essential issues as no other medium can. Television

journalism also has the ability to harness the power of broadcasting to coalesce a

community around issues or news events in a way that is unique in the media

ecosystem. For example, when the mayor of Detroit was facing a perjury prosecution, among other scandals, commentaries by a leading Detroit news anchor on Station WDIV-TV led to growing acceptance of the need for change on behalf of the community overall — much in the way that Walter Cronkite’s reporting on the

Vietnam War led to large-scale acceptance of the need for an end to the war.

Broadcast stations play a unique role serving their communities. Stations provide critical coverage of issues of local importance, and they do so as the trusted voices of their communities.

8 II. Local Broadcast Journalists Are Embracing New Technologies to Better Serve Their Local Communities.

While local stations continue to serve their communities by providing

local weather, sports, and news coverage that is unavailable among national media

outlets, digital technology has changed the way stations gather news and deliver

this programming. Broadcast stations across the country are making news

available to viewers when they demand it, and on any device they wish to use to

receive it. The era of newsrooms gathering and reporting the news solely for

evening news broadcasts is over. Instead, broadcast stations are now twenty-four hour-a-day and seven-day-a-week news operations that report news immediately on a wide variety of media. Stations now have interactive websites with sophisticated technology that allows for live-streaming, breaking news coverage that viewers can watch and on which they can also provide their own comments. These technologies enable stations to provide much fuller content.

For example, stations can use their online platforms to make available full-length interviews and fuller coverage of segments that were edited and shortened before appearing on the air. Because of time constraints, broadcasters might be able to include only a portion of a much longer story or interview on their linear over-the-air channels. But stations can make a longer story or a full interview available online. For example, one station implemented web streaming of five solid hours of election coverage on its website on election day, greatly supplementing the coverage available on its over-the-air broadcast. Stations can also operate and moderate live blogs during local elections and other important

9 events. In some larger markets, stations have devoted reporters exclusively to web

content.

Local broadcast journalism also is taking advantage of new mobile

technologies. Many stations have mobile-enhanced WAP sites for news, making

local journalism available to mobile phones. Stations have developed and are

developing applications for iPhones, the Google Android platform, and Blackberries,

making their content available to viewers any time and on any device. Viewers can

track severe weather using mobile technologies by visiting mobile sites; they often

can find additional content, such as high-school football games. Viewers also can

elect to receive email and text updates for weather and other news alerts.

Interactive web platforms also allow broadcast stations to involve

viewers directly in news coverage. User-generated content supplements station

coverage and provides information that stations might not otherwise have the

resources to gather and report. For example, stations used Twitter to solicit user

content relating to the lines at polling places during last November’s election.

Stations would not otherwise have had the resources to provide up-to-date information about waiting times at dozens of polling place to those at home getting

ready to vote. By soliciting user content on Twitter and then posting those

comments on a website and using that information as an on-air resource, broadcast

stations provided viewers with information that would not otherwise have been

available to them. User-generated content applications also allow viewers to

contribute to the resolution of community issues that are reported in broadcast

10 stories. In the event of a missing child, for example, users can comment on web platforms to share their sympathy and also to give information that may be vital to locating the child.

Increasingly, broadcast news is a two-way street with users driving content in many respects. Broadcast stations find stories and news through many different means, but new technologies empower viewers to bring the stories to stations. One example of how viewers drive the content of story lines is the “Take

Back the Neighborhood” series that stations in at least two Raycom markets have aired. The series reports on neglected neighborhoods and what local government is doing to address the neglect and related community problems. The problems that these stations focus on are largely identified through information received from the community. Moreover, these series highlight another role for broadcast journalism: helping people solve problems, such as community neglect. In one community in which a “Take Back the Neighborhood” series aired, city officials told an individual complaining about a problem property that she might be better off contacting her local broadcast station than going directly to the city for assistance. Similarly, broadcast coverage can put pressure on local law enforcement and other officials to provide information to the public that they might otherwise withhold. In some instances, government officials will schedule and hold their first press conference on an issue hours before a local station plans to run a special on the subject.

Digital technology also has changed the way stations gather news and produce live television. At a number of stations, reporters can publish content to

11 Web sites and mobile sites from a laptop on the road, so long as they have access to the Internet, or access to a Skype or WiFi connection. They can now perform live remote broadcasts for newscasts without expensive and cumbersome satellite equipment by using video-over-Internet products. Several years ago, it would not have been possible for many local stations to send reporters overseas or across the country for stories. Internet-based equipment makes it possible to deliver content and video back home at the cost of access to the Internet. While more expensive and, in many respects, more sophisticated, newer cameras are also much easier to use and more accessible. Reporters can often capture footage with cell phones and other small devices that record video.

New technologies have improved journalism by making more people — both within and outside the newsroom — part of the news process. Certainly, the variety of ways in which viewers can contribute content and drive the direction of news coverage enfranchises those viewers in the newsgathering and reporting process. Most stations and many individual reporters have Facebook pages and

Twitter accounts that allow them to interact directly with their communities. The intimate connection between viewers and newscasters is, in many ways, a unique relationship.

In virtually all cases, of course, local broadcast organizations are unable to hire additional staff to deploy all of these new digital and Internet technologies — the meaning of the expression “to do more with less” has never been more applicable than it is today. Broadcasters are exploring innovative means to

12 realize efficiencies in newsgathering while maintaining their longstanding

commitment to their local markets.

For example, news organizations that own multiple stations in

different markets once provided largely independent coverage of news events.

These organizations are finding new ways to share content among different stations, so that, for example, multiple sports departments do not write stories

about the same event but can deploy those resources to provide a greater variety of

coverage. Coordinating coverage conserves resources that local stations can then

use to provide coverage uniquely important to their communities. Some

organizations have consolidated other functions to both economize and enhance

their product. One news organization has centralized its high-end graphics in one

location, while providing Internet-based software that can be used by reporters to

generate standard graphics. Previously, each location had its own graphics

department, and stations in smaller markets did not have access to high-end

graphics and maps. By centralizing the graphics function, the station has improved

its product in smaller markets and saved money that can be invested in other

functions.

News organizations also are finding ways to share expenses with other

broadcasters in the same community. In some markets, stations are entering into

arrangements with other stations to pool certain resources for commodity events

such as press conferences and court hearings. In other markets, news stations may

share the expense of a helicopter for footage that would be largely identical if shot

13 from separate aircraft. Other more enduring arrangements may involve the

sharing of back-office and other expenses. The common element in all of these

arrangements is that they provide creative mechanisms for broadcasters to redeploy journalistic resources in the most effective manner possible for service to their local communities.

* * *

There is little doubt that broadcasters are subject to additional content

and advertising competition from a variety of new-media sources, and that this

competition has transformed our markets. This new competition, and the current

downturn, have increased the overall challenges facing television broadcasters in

local markets. Yet, our central role in our communities remains as important today

as ever, and we appreciate the Commission’s focus on these essential issues.

Respectfully submitted,

BARRINGTON BROADCASTING GROUP, LLC BELO CORP. DISPATCH BROADCAST GROUP FREEDOM BROADCASTING, INC. GANNETT CO., INC. POST-NEWSWEEK STATIONS, INC. RAYCOM MEDIA, INC.

By: ______Kurt Wimmer Elizabeth Canter COVINGTON & BURLING, LLP 1201 Pennsylvania Avenue, N.W. Washington, D.C. 20004-2401 (202) 662-6000

May 7, 2010

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