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. 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 i 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 United States. 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