1 Before the FEDERAL COMMUNICATIONS COMMISSION
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Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) MB Docket No. 13-249 Revitalization of the AM Radio Service ) REPLY COMMENTS OF BONNEVILLE INTERNATIONAL CORPORATION Bonneville International Corporation (“Bonneville”), licensee of KSL(AM), Salt Lake City, UT, and KIRO(AM), Seattle, WA, hereby submits its reply to comments in the above- referenced proceeding. Bonneville’s KSL and KIRO are Class A radio stations that have served their audiences since the earliest days of radio broadcasting, including nighttime service to regions extending well beyond their immediate communities of license. Bonneville is a signatory to the AM Radio Preservation Alliance (“Alliance”) submissions in this proceeding and endorses the legal and technical information presented in them.1 These comments supplement those submissions by providing the Commission with a comprehensive picture of the service that KSL and KIRO provide to their listeners near and far – which would be compromised by an FCC decision to eliminate the protections afforded to Class A stations. KSL(AM), Salt Lake City, UT The radio station now operating under call sign KSL originally signed on the air in 1922.2 It began serving a wide swath of the western United States in 1932 when it added a 50,000-watt transmitter, and in the eight decades since then the station has become a news and information 1 Comments of the AM Radio Preservation Alliance, MB Docket No. 13-249 (Mar. 21, 2016). 2 The station acquired the KSL call sign in 1925. 1 source available to 59.5 million people across 14 states, encompassing many sparsely-populated rural counties and Native American tribal areas.3 KSL today broadcasts locally produced news and news/talk programming Monday through Friday from 5 AM to midnight, and the overnight hours’ network programming is augmented with regular local breaks for news, weather, and traffic information. The KSL newsroom, providing service to our audiences across all of our platforms – radio, television, and websites – has dozens of reporters, editors, and producers; 16 full-time employees are focused on radio. We estimate that approximately 70 to 80 percent of our news broadcasts appeal to regional interests and concerns, including reports that address land and water conservation issues, Ute and Navajo tribal matters, search and rescue efforts, national parks, and U.S. Bureau of Land Management issues. The Ute Tribe’s Uintah and Ouray Reservation in Eastern Utah falls within KSL’s .1mV/m contour and the Navajo Nation’s reservation falls within the nighttime .5 mV/m 50% skywave protected area. KSL’s Traffic Center is manned with three full-time and several part-time traffic reporters, most of whom provide traffic reports for radio. The station provides local and regional traffic reports, including conditions on Interstates 70, 80, 84, 15, and 215. In association with our sister TV station we have access to a helicopter for reporting serious traffic tie-up situations. The helicopter is also available for covering regional news in outlying areas. KSL News has its own weather center with state-of-the-art forecasting equipment. We employ three full-time meteorologists, shared among radio, television, and out websites, who 3 This information comes from a study conducted in March 2016 by Hatfield & Dawson Consulting Engineers, Seattle, WA, for the Bonneville stations, which draws the population numbers from the 2010 U.S. Census. According to that data, KSL’s signal more than 29 million minority citizens, including 765,000 Native Americans. KSL has one of the largest “white area” coverages – meaning locations not served by any other radio station -- of any Class A station in the United States. 2 deliver on-air weather reports several times each hour all day and evening long. In addition to providing sophisticated forecasts and warnings to our audiences, our technology allows us to pinpoint conditions in a specific area and broadcast geo-targeted information for listeners. The station serves a critical public-safety role for our area as the regional Primary Entry Point (“PEP”) station housing FEMA-supplied equipment.4 KSL also is the LP1 EAS station for the Salt Lake Regional Operational Areas, which includes – by its request – Uinta County, WY. We work with the National Oceanic and Atmospheric Administration (“NOAA”) and the Utah Broadcasters Association to assure that EAS alerts that run on KSL also are forwarded by the NOAA Radio system. KSL’s role as a leading source of public safety information is not limited to weather emergencies. An “Amber Alert” incident in 2009 illustrates the value of the “critical hours” protection for Class A stations’ nighttime signals: Shortly after midnight on January 17, 2009, a father reported to authorities that his young daughter was missing from the family home in Ogden, UT, about 35 miles north of Salt Lake City. 5 Authorities issued an Amber Alert, which KSL broadcast around 6:00 AM that morning – and a truck driver more than 300 miles away, in Washington County, UT, heard the broadcast. Shortly thereafter, the trucker spotted the girl and her abductor and immediately called 911. Local police made an arrest by 7:30 AM, and the girl 4 The argument that Class A skywave protection must be eliminated so that local stations can provide emergency service lacks seriousness. In local emergency situations, FCC rules already allow daytime stations to operate 24/7 and also permit a reduced-power station to use their full daytime facilities. See 47 C.F.R. § 73.1250(f). Such stations do not need to seek prior FCC permission in these circumstances; they need only file post-emergency reports to keep the Commission apprised. Id.; 47 C.F.R. § 73.1250(e). 5 See Andrew Adams and Mary Richards, Missing girl found safe in southern Utah, ksl.com (Jan. 17, 2009), available at http://www.ksl.com/?nid=148&sid=5330683; Ben Winslow, Teen safe, found in Washington Co. after Ogden Amber Alert,DESERET NEWS (Jan. 17, 2009), available at http://www.deseretnews.com/article/705278041/Teen-safe-found-in-Washington-Co-after-Ogden-Amber- Alert.html?pg=all. Details in this paragraph concerning the incident are drawn from one or both news reports. 3 was returned to her family. The KSL broadcast plainly made a difference, and it was possible only because the broadcast fell within the critical hours period for protected skywave service. Beyond providing important news, weather, traffic, and public safety information, KSL serves other needs and interests of its audience. For instance, the station is the voice of BYU sports. Listeners all over the West, especially those driving long distances without streaming capability, tune in to KSL to follow BYU in football and basketball. The station also covers other college, high school, and professional sports teams around the state and the region. In addition, KSL is the home of cultural fare, producing such as programming as the Peabody Award-winning “Music and the Spoken Word” – first aired in 1929 and now carried by radio stations across the country. Finally, KSL is dedicated to its public service mission, which is reflected in many endeavors on and off the air; one of the most notable is the station’s on-air fundraising for Primary Children’s Hospital of Salt Lake City. The largest child-focused health- care facility between Denver and the West Coast, Primary Children’s serves many families well beyond the Salt Lake City metro area. KSL Newsradio is frequently recognized for journalistic excellence. The radio operations won a national Edward R. Murrow award for best newscast in 2015, and it took the Breaking News honor in 2014. KIRO(AM), Seattle, WA The station now operating under the KIRO call sign first went on the air in 1927, and it became a 50,000-watt station in 1941. It serves a wide section of the Pacific Northwest, including nighttime listeners north of the U.S./Canada border in and around Vancouver and Calgary, who are not reflected in U.S. census-based listener data. In 1974, KIRO became the Pacific Northwest’s first all-news station. More recently it launched an all-sports format, but it continues to operate a shared newsroom with a co-owned 4 FM station. The shared newsroom employs more than 25 people covering and delivering news reports, which are almost exclusively focused on state/regional issues. KIRO is the is the radio flagship of the Seattle Seahawks and Seattle Mariners,6 and provides live and local sports coverage Monday through Friday from 7 AM to 7 PM, along with six hours or more of local coverage on weekends. KIRO also broadcasts Washington State University football and basketball. During most evening and weekend hours, the station serves the Pacific Northwest with live play-by-play sports coverage. Like KSL in its area, KIRO serves as the FEMA/EAS PEP for the Pacific Northwest region. KIRO is also the Seattle LP-1 EAS station. During major news and weather emergencies, local news coverage is simulcast on KIRO and its sister FM station. Consistent areas of focus include floods, windstorms, landslides, earthquakes, and major forest fires. The Pacific Northwest has grappled with numerous storm-related and fire-related emergencies in the region over the past three years. The shared newsroom treats emergencies as a major focus for its reporting and dispatches its journalists throughout the state of Washington as storms and other emergencies arise. *** This overview of KSL’s and KIRO’s service to their regions epitomizes precisely the type of service that the Commission envisioned that Class A stations would provide nightly across wide areas of the United States. The stations continue to provide news, entertainment, and emergency information that many listeners well beyond Salt Lake City or Seattle value – particularly in places that receive little or no service from other stations.