Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of Future of Media and Information Needs GN Docket No. 10-25 of Communities in a Digital Age COMMENTS OF BELO CORP. Belo Corp. (“Belo” or “the Company”)1 hereby submits its Comments in response to the FCC’s Public Notice released on January 21, 2010 in the above-referenced proceeding, in order to assist the Commission in its assessment of Americans’ access to vibrant, diverse sources of news and information. As discussed in more detail below, Americans have access to a vast amount of diverse news and information content, thanks in no small part to the public service provided by Belo and other broadcasters. Moreover, although digital television is still in its infancy, it already has allowed Belo and other television broadcasters to implement innovative new services and pursue new opportunities to better serve their audiences. Television operators surely will continue to explore new ways to use DTV technology to enhance their roles as public servants. Most importantly, the Commission should recognize that Belo, like many other broadcasters, 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 12 Alfred I. duPont- Columbia University Silver Baton Awards; 11 George Foster Peabody Awards; and 26 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. provides exemplary pubic services not because of regulatory obligations, but because such service is at the core of the Company’s business model and defines its role in the community.2 Additional regulatory burdens in this regard, therefore, are not needed and would be counterproductive. Belo Stations Exemplify the Outstanding And Unique Public Services TV Broadcasters Across the Country Consistently Provide to Their Communities During Belo’s approximately 60 years as a television broadcaster, the Company’s television stations have upheld a tradition of journalistic excellence, providing their home communities with free local news, sports, and weather reports, up-to-the-minute emergency information, extensive coverage of local elections and politics, and community- oriented programming. Belo, like many television operators across the country, recognizes that broadcasters are an integral part of the communities they serve, and therefore are better-positioned than many of their competitors to provide such content. Three quarters of Belo’s full-power television stations produce original local newscasts, with most offering 30 hours or more per week of such programming on their primary channels alone. Not surprisingly, Belo stations routinely receive awards acknowledging the Company’s high journalistic standards and commitment to serving its stations’ local communities. For example, Belo station KHOU-TV, which serves Houston, TX, recently received a Peabody Award, a duPont-Columbia Award, the IRE Medal from Investigative Reporters and Editors, and a National Headliner Award for a two-year series of stories and 2 Belo has demonstrated to the Commission on many occasions that locally-oriented journalism and community service are at the core of the Company’s business. See, e.g., Comments of Belo Corp. in response to NBP Public Notice #26, GN Docket Nos. 09-47, 09-51, and 09-137 (Dec. 21, 2009) (“Belo NBP #26 Comments”); Comments of Belo Corp., MB Docket No. 04-233 (April 28, 2008) (“Belo Localism Comments”). -2- a documentary broadcast last summer about discrimination within the Texas National Guard. The series Under Fire: Discrimination and Corruption in the Texas National Guard detailed discrimination against female soldiers in the Texas National Guard and resulted in the appointment of a new commanding general and the dismissals of three Texas National Guard generals. Americans also have access to extensive free, up to date information during local emergencies, thanks to the efforts of Belo and other local broadcasters. Broadcast stations are by far the best mechanism for disseminating such information efficiently throughout communities, because broadcasters are part of those communities and because they employ a one-to-many distribution model, in contrast to the less-efficient one-to-one model employed by some of their competitors. Belo’s stations consistently provide emergency information to the communities they serve, and remain committed to doing so. For example, Belo station WWL-TV, New Orleans, Louisiana provided extensive emergency coverage of Hurricane Katrina in 2005. WWL was the only local television news outlet to remain on-the-air throughout the various stages of this devastating storm, providing emergency coverage for 15 straight days before resuming carriage of CBS network programming. The station’s coverage began three days before Katrina made landfall, ensuring that the community was aware of the impending danger, as well as critical evacuation and safety plans. WWL remained on the air throughout the crisis, broadcasting from its own transmitter facilities as well as temporary studios at Louisiana State University in Baton Rouge and the facilities of Louisiana Public Broadcasting. Cell phones and other communications devices were severely limited by the storm. As a result, WWL was the main source of ongoing information about the storm and its -3- impacts, as well as about how members of the community could get help or assist in relief efforts. Local government officials relied extensively on WWL to communicate information to the public, because, in many cases, local government could not do so itself. Belo and other communications entities took additional, creative steps to ensure that members of the community had access to WWL’s emergency content. For example, WWL’s coverage of Hurricane Katrina was carried throughout all of Louisiana and Mississippi on a network of digital channels, public television stations, and cable channels. Several radio stations simulcasted the audio portion of WWL’s feed, and Echostar retransmitted WWL’s signal to communities in Texas that were assisting in the evacuation efforts. WWL also streamed its broadcasts live on its Web site, experiencing unprecedented use by the public. In recognition of these extraordinary efforts, WWL became the first station ever to win the prestigious triple crown of news journalism – a duPont-Columbia award, a national Edward R. Murrow award, and a Peabody award – for coverage of the same event. KHOU-TV also is committed to keeping its community informed during local emergencies. In 2005, KHOU provided 60 hours of continuous, commercial-free coverage of Hurricane Rita. Similarly, the station provided 91 hours of uninterrupted coverage of Hurricane Ike in 2008.3 Because they are integral parts of the communities they serve, local television and radio stations also are in the best position to provide the communities they serve with extensive local and regional political coverage. Like many broadcasters, Belo takes its obligation to provide such programming seriously. For example, since 1996, Belo stations 3 See, e.g., Belo NBP #26 Comments at 5-6. -4- have offered vast amounts of free airtime to state and federal candidates. They also provide extensive political coverage in the weeks leading up to elections and often sponsor and air numerous candidate debates for both local and national races. Broadcasters enhance the community services of local non-profit organizations. Besides the millions of dollars raised year after year by broadcasters to support local non- profits, broadcasters are even more directly involved. When the Southern Arizona Big Brothers and Big Sisters organization had severe problems recruiting mentors for young men and women in Tucson, Arizona, Belo’s KMSB-TV took the media lead and dedicated public service announcements on air and numerous news stories during the campaign to recruit new mentors. The goal was to recruit 100 new mentors. When the campaign concluded a month later, over 400 new volunteers came forward and the number kept growing after the campaign ended. The station leveraged its services for one month and the local community will benefit for years to come. Belo and Other Television Broadcasters Are Using Digital Television Technology to Implement Innovative New Services and Pursue New Opportunities to Better Serve Their Local Communities Even though digital television is still in its infancy, and the DTV transition cost broadcasters an estimated one billion dollars, much of which was borne during the continuing economic downturn, Belo and other broadcasters are already using nascent DTV technology effectively to provide more content to the communities they service in new ways. In addition to HD programming, Belo stations are using DTV technology to provide multicast channels and other enhanced offerings to their local communities. Belo currently operates 17 multicast channels, with plans to launch several more by year’s end. Several Belo stations provide extensive local news programming – both time-shifted and -5- additional content – on their multicast channels, which makes local news and information content far