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Montgomery, Alabama Economic Overview

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.- ~4aini5 & ~ltnnan, Qlqarterro OIOUltSem at Jjafn jiuite 240 1850 ~ Jitn.et, ~.~ ~asltinghm, Jfl.QI. 20036 (202) 293-0011 J\anm J- jilJmms Jlf'ax (202) 293~081O ®f QIouttGel [email protected] .e-mail: sqmmsp.eltmum@lli~plnfu com ~iUiam ~ Jflu~s, ill ~ Jj. Jcltmum [email protected] [email protected] ~m-~Uer [email protected] June 29, 2006 VIA ELECTRONIC FILING & HAND DELIVERY Ms. Marlene H. Dortch, Esq. Secretary Federal Communications Commission Portals II - 12th Street Lobby Filing Counter - TW-A325 445 12th Street, SW Washington, D.C. 20554 Re: WCOV-TV Facility ill No. 73642 Request for Waiver ofJuly 1, 2006 ReplicationlMaximization Deadline MB Docket No. 03-15 Dear Ms. Dortch: Woods Communications Corporation ("Woods"), permittee ofWCOV-DT, Montgomery, Alabama (the "Station"), by its attorneys, hereby respectfully requests a waiver ofthe Commission's July 1, 2006 replication/maximization interference protection deadline. In support, Woods respectfully submits the following: 1. WCOV-TV currently operates on NTSC Channel 20. Its current DTV channel is Channel 16 and its tentative DTV Channel Designation is Channel 16. See Tentative Digital · - Ms. Marlene H. Dortch, Esq. June 29,2006 Page 2 Channel Designationsfor Stations Participating in the First and Second Rounds ofthe DTV Channel Election Process, DA 06-1082, released May 23,2006 (Attachment A).\ 2. In its Second DTVPeriodic Review Report and Orde?, the Commission adopted a July 1,2006 replication/maximization interference protection deadline for all DTV licenses not subject to the July 1, 2005 deadline. The Commission stated that, in cases where a station was unable to meet the applicable deadline due to "circumstances beyond a station's control," it would "grant extensions ofthe applicable replication or maximization interference protection deadline on a six-month basis ifgood cause is shown.,,3 To receive such a waiver, broadcasters were required to make a showing "similar to that required to obtain a waiver ofthe DTV construction deadlines." See Report and Order, ~ 87. 3. In its June 14,2005 Public Notice, the Commission recognized that certain stations although unable to reach 100 percent maximization or replication, nevertheless would be able to come close to meeting the applicable coverage requirements. The Commission requested that stations submit the following information in conjunction with any request for waiver: "(1) how close to full replication/maximization the station will be as ofthe deadline; (2) the reason I Woods shall seek to amend that election to allow it to utilize Channel 20 for its ultimate DIV operation. 2 Second Periodic Review ofthe Commission's Rules and Policies Affecting the Conversion to Digital Television, Report and Order, 19 FCC Rcd 18279 (reI. September 7, 2004) ("Report and Order'). 3 Id. ~ 87. J:\# FCC\WCOV Request for Waiver Maximization Deadline doc .. - Ms. Marlene H. Dortch, Esq. June 29, 2006 Page 3 the station is unable to fully comply; (3) the cost to the station and the impact on viewers ifthe station were required to fully comply; (4) whether the station will be able to modify its operation to fully comply after analog operation terminates (e.g., relocate their DTV antenna to the top of the tower); and (5) any other relevant factors." Id. Background 4. By a November 20, 2002 filing, Woods requested Special Temporary Authority ("STA") to build a minimum digital facility (Attachment B). The Commission granted the STA (BDSTA-20021120ACR) and on October 6, 2003, Woods notified the Commission that it had commenced broadcast operations (Attachment C). At present, Woods has been operating pursuant to that STA. 5. On February 9, 2005, Woods, pursuant to FCC Form 382, elected to operate on Channel 16 for its post-transition DTV operation (Attachment D). In light ofeconomic factors, Woods intends to seek Commission consent to allow it to utilize Channel 20 for its post transition DTV channel. Woods intends to make such a request at the appropriate time. 1:\# FCCIWCOV Request for Waiver Maximization Deadline.doc Ms. Marlene H. Dortch, Esq. June 29, 2006 Page 4 Montgomery, Alabama Economic Overview 6. Station WCOV-TV is licensed to Montgomery, Alabama. The Montgomery- Selma, Alabama area DMA ranks 116 according to Nielsen Media Research (Attachment E). Nielsen also reports an estimate of245,090 homes with televisions in that market. Montgomery, Alabama households that subscribe to cable service as ofMay, 2006 is 78.6%. Households that subscribe to an Alternate Delivery System (ADS) are 22.3% (Attachment F). 7. The 2000 U. S. Census reports that Montgomery, Alabama is home to 223,510 people. The report also shows that the medium family income for residents ofMontgomery is approximately $44,669.00. In addition, the Census Bureau notes that 13% ofthe city's families and 17% ofthe city's individuals are below poverty level (Attachment G). A large portion ofthe city's income comes from its agricultural roots. Many ofthe residents of Montgomery, Alabama rely on jobs such as processing and shipping cotton, dairy and other farm products. They are construction workers and minors. They work on freight carriers and barges and in manufacturing plants. The average hourly wage earning for manufacturing jobs is around $13.56 (statewide). The average price of a single-family home in Montgomery is $241,263.00 (Attachment H). J:VI- FCC\WCOV Request for Waiver Maximization Deadline.doc · - Ms. Marlene H. Dortch, Esq. June 29, 2006 Page 5 8. In relation to these statistics, Montgomery, Alabama is on the lower end ofthe national levels. The 2000 Census Report shows that the national average yearly income for U.S. residents is $50,046.00. The national average for families below poverty level is 9.2%, while for individuals it is 12.4% (Attachment I). 9. In the wake ofthe digital television era, areas that report lower income levels and higher costs ofliving could be affected by the FCC's mandatory transition from analog to digital. Although approximately 67.5% ofthe country is already wired to receive digital transmission, statistics show most American families do not have a digital television set in their home (Attachment J). In fact, a survey listed on the National Association ofBroadcasters website reports that Nielsen Media Research estimated that, ofthe 110,200,000 U.S. TV households (2005-2006 TV season), only 5.9% ofthose households have digital television sets. In that same survey, Kagen research estimates that only 29 million households will have HDTV by the year 2008. Media Trends Track reiterates this estimated prediction in a report titled TV Basics on their website (Attachment K). 10. The expense and lack ofinformation regarding the conversion from analog to digital could be factors ofthe populations' lack ofinterest in purchasing digital televisions. The J:\# FCC\WCOV Request for Waiver Maximization Deadline.doc Ms. Marlene H. Dortch, Esq. June 29, 2006 Page 6 Federal Communications Commission has developed a DTV website where consumers can get the facts regarding the transition from analog to digital (Attachment L (general». The Consumer Electronics Association and the Consumer Electronics Retailers Coalition have created a DTV Tip Sheet for consumers to review before purchasing a digital television. Countless articles have been written in local communities and on the Internet to explain the new era in television. Yet, with all this information available, by the end of2005 only 5.9% ofU.S. Households had digital televisions in their homes (Attachment M and N). No figures are available as to the percentage ofhouseholds in Montgomery, Alabama which have digital television, but it is safe to assume that in light ofthe area's economic situation the percentage is less than the national percentage. 11. Costs and confusion on what to buy can be overwhelming to the public. A Standard-Definition Television retails at Circuit City for a little over $500.00. Prices at Best Buy linger around the same price range. Enhanced-Definition Televisions are a little higher in price while High Definition Televisions can cost over $2,000.00 (Attachment 0). The FCC Consumer Facts page advises that analog television sets will work with the "Plug-and-Play" method, but does not give consumers a projected cost estimate (Attachment P). J:\JI FCC\WCOV Request for Waiver Maximization Deadline.doc Ms. Marlene H. Dortch, Esq. June 29, 2006 Page 7 12. Consumers are already paying anywhere between $45.00-$65.00 per month for basic wired cable or alternate delivery service (Attachment Q). The additional costs of either set- top boxes or a new digital television set will undoubtedly have an adverse affect on the monthly budgets ofconsumers. These factors must be considered in the analysis ofthe cost ofa maximization build-out and the actual population which would benefit. Maximization Costs 13. The cost to build the maximized Channel 16 DTV facility for Woods is prohibitive. In this regard, the estimate to build the DTV facility is: (a) Tower (1800 feet) $ 2,500,000 (b) Antenna, Mountings, Elbows $ 200,000 (c) Transmission Line System $ 350,000 (d) Antenna and Transmission Line Installation $ 80,000 (e) DTV Transmitter and RF System (including installation) $ 900,000 (f) Transmitter Building $ 80,000 (g) Transmitter Building Electrical.. $ 50,000 (h) Microwave System, including antennas and transmission line .......$ 60,000 ]:\# FCC\WCOV Request for Waiver Maximization Deadline.doc Ms. Marlene H. Dortch, Esq. June 29,2006 Page 8 (i) Transmitter Building HVAC $ 15,000 Total $ 4,235,0004 In light of the scant population which has the capability to receive the WCOV DTV signal, it is not prudent to spend the required money. Obviously, Woods would not have the same argument in February, 2009, when all stations must broadcast in digital. Woods is taking steps to meet that deadline. WCOV-TV and WCOV-DT Coverage 14.
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