Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) Spectrum for Broadband ) GN Docket Nos. 09-47, 09-137 ) A National Broadband Plan for Our Future ) GN Docket No. 09-51 COMMENTS—NBP PUBLIC NOTICE #26 BELO CORP. 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 (214) 977-6606 December 21, 2009 TABLE OF CONTENTS Page QUESTION C WHAT ARE THE BENEFITS OF FREE, OVER-THE- AIR TELEVISION BROADCASTING IN PARTICULAR WITH RESPECT TO PUBLIC AWARENESS OF EMERGENCY INFORMATION, LOCAL NEWS, POLITICAL DISCOURSE, AND EDUCATION?....................... 2 QUESTION A4/A5: HOW DO TELEVISION BROADCASTERS USE THE CAPABILITIES OF DIGITAL TELEVISION TODAY? HOW DO BROADCASTERS PLAN TO USE LICENSED SPECTRUM IN THE FUTURE? .................................................. 8 -i- Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) Spectrum for Broadband ) GN Docket Nos. 09-47, 09-137 ) A National Broadband Plan for Our Future ) GN Docket No. 09-51 COMMENTS—NBP PUBLIC NOTICE #26 BELO CORP. Introduction and Summary Belo Corp. (“Belo” or “the Company”) hereby submits its Comments in response to the FCC’s Public Notice released on December 2, 2009 in the above-referenced proceedings seeking data on the use of spectrum currently licensed to broadcast television stations.1 Belo appreciates the opportunity to contribute to the critically important questions under consideration in this proceeding about the ways in which television broadcasters serve the public interest as well as their current use of, and future plans for, their licensed spectrum. As described herein, Belo’s television stations have a long history of journalistic excellence and provide crucial services to their home communities every day in the form of free local news, sports, and weather reports, up-to-the-minute emergency information, extensive coverage of local elections and politics, and 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 nine Alfred I. duPont-Columbia University Silver Baton Awards; nine George Foster Peabody Awards; and 19 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. community awareness that otherwise would not be available to millions of consumers. Like many other broadcasters across the country in this early stage following the national transition to digital television, Belo already is putting its digital capacity to use in a variety of ways that further these important objectives, and the Company is developing additional innovative uses for this spectrum. In examining the record in this proceeding, Belo urges the FCC to consider the extensive public interest benefits that television broadcasters have provided for more than half a century, the enormous investment that broadcasters and consumers have made to upgrade to digital service, and the real potential that broadcasters have to further improve their program offerings and public service in the digital era. Question C: What are the benefits of free, over-the-air television broadcasting in particular with respect to public awareness of emergency information, local news, political discourse, and education? Throughout the transition to digital television and thereafter, the Commission repeatedly has recognized the vital importance of broadcast television. As the agency stated at the outset of the digital transition: As the next generation of television—digital television— moves from the drawing board into American homes, we reaffirm . our intention to preserve and promote universal, free, over-the-air television. Broadcast television has become an important part of the fabric of our society by making available to every American a vast array of programming, including news, public affairs, educational, and entertainment programming.2 Now that broadcasters and the public have successfully made the transition to digital service, the Commission continues to recognize the unique public interest benefits 2 Advanced Television Systems and Their Impact Upon the Existing Television Broadcast Service, Fourth Further Notice of Proposed Rulemaking and Third Notice of Inquiry, 10 FCC Rcd 10540, 10543, ¶ 22 (1995). -2- provided by over-the-air broadcasting. FCC Chairman Genachowski recently remarked, for example, that “broadcast television remains a unique medium, the exclusive source of video programming relied upon by millions of households, and a very significant source for millions of others.”3 In testifying before Congress in September, Commissioner Michael Copps similarly stated that “[w]e rely on our broadcast media for so much of the news we must have, for emergency and public safety information, for public affairs programming essential to our civic dialogue, and for programming that supports the health and welfare of our children and reflects the social and cultural diversity that comprises the great tapestry that is America.”4 Broadcasting since the 1950s, Belo takes great pride in serving its local communities in ways that fulfill each of these fundamental objectives. As Belo has demonstrated to the Commission on many occasions, locally-oriented journalism and community service are at the core of Belo’s business.5 Provided below are a few illustrative examples of how Belo serves its communities on a daily basis with emergency information, local news and information, and election and political coverage. 3 Statement of Julius Genachowski, Chairman, Federal Communications Commission before the United States Senate Committee on Commerce, Science and Transportation Hearing on “Rethinking the Children’s Television Act for a Digital Media Age,” July 22, 2009, available at http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-292170A1.pdf. 4 Testimony of FCC Commissioner Michael J. Copps, U.S. House Committee on Energy and Commerce, Subcommittee on Communications, Technology and the Internet, “Oversight of the Federal Communications Commission,” 2009 FCC Lexis 4925 (September 17, 2009). See also FCC News Release, 30 Days and Counting to DTV Transition: FCC Concentrates on Preparing Consumers for June 12 Deadline, 2009 FCC LEXIS 2205 (May 13, 2009) (“Television is a primary source for news, weather and public safety information for many Americans so the FCC is working overtime to reach those remaining viewers who still have not taken the necessary action to continue to receive television programming after June 12.”). 5 See, e.g., Comments of Belo Corp., MB Docket No. 04-233 (April 28, 2008). -3- Local News: Like many television broadcasters across the country, Belo is highly focused on serving its local communities with high quality local news and information. Broadcasters are often the best positioned among their many competitors to provide superior coverage of breaking stories, local issues, and community activities. Because these objectives are at the heart of the Company’s business model, Belo consistently has invested in the resources necessary to provide extensive local news, public affairs, and community-oriented coverage with the aim of developing its stations into durable news and information franchises. Of Belo’s 20 full-power stations, 15 produce original local newscasts, and most of these stations regularly offer 30 hours or more per week of local news programming on their primary channels alone. While there are many examples of Belo’s dedication to superior local news programming, the outstanding coverage provided by Houston station KHOU-TV is particularly noteworthy. Each weekday, KHOU produces and airs “Great Day Houston,” an hour-long local news/talk program which provides extensive local coverage and often serves as an outlet for various local public service and non-profit groups. The station also is highly committed to investigative reporting. To note just one example, KHOU recently produced a series of 10 reports about the effect of the government’s current healthcare reform proposals on Houstonians. The in-depth reports, which focused on the uninsured, small businesses, self-employed individuals, emergency rooms, and insurance companies, among other highly important topics, aired each weekday over a two-week period last August. KHOU also recently expanded its extensive news schedule through the addition of a 4:30 a.m. newscast in September in order to better serve viewers who are commuters, shift workers, or early risers with important breaking news and overnight -4- developments. The station’s high journalistic standards and commitment to local service have earned it dozens of journalism awards in recent years. In 2009 alone, KHOU was honored with one national and six regional Edward R. Murrow Awards, 12 regional Emmy Awards, and one award from the National Academy of Television Arts and Sciences. Belo’s Dallas-Fort Worth station, WFAA-TV, also has earned many awards over the years for its journalism and community service, but this year it was the recipient of a particularly notable honor. In January 2009, the station received