BEFORE THE
FEDERAL COMMUNICATIONS COMMISSION
WASHINGTON, D.C. 20554
In the Matter of )
)
Innovation in the Broadcast Television
Bands: Allocations, Channel Sharing and
Improvements to VHF
)
)
)
ET Docket No. 10-235
REPLY COMMENTS OF LOCAL TELEVISION BROADCASTERS
Local Television Broadcasters,1 by their attorneys and pursuant to 47 C.F.R. § 1.415(c),
hereby reply to the initial comments filed in the above-captioned proceeding.2 The comments
confirm Local Television Broadcasters? contention that the proposals outlined in the NPRM represent
the wrong plan at the wrong time. Pursuing them now would be arbitrary, capricious, and contrary to
the public interest because the NPRM?s proposals lack any showing that they can be accomplished
without service loss and the creation of interference, either of which will cause certain and
irreparable harm to television broadcasters and viewers. The ensuing reallocation and repack are
highly disruptive mechanisms, involving excessive government intervention that is an unnecessary
solution to a spectrum ?crisis? that does not exist.3 Instead, the FCC should consider the numerous
alternatives to the NPRM?s arbitrary blueprint that are set forth in various broadcasters? comments as
the foundation for more productive TV spectrum reform.
1 Local Television Broadcasters includes numerous television broadcasters that collectively own
230 television stations operating diverse markets throughout the country, from New York (DMA #1)
to St. Joseph, Missouri (DMA #200), as identified in Attachment A.
2 Innovation in the Broad. Television Bands: Allocations, Channel Sharing and Improvements to
VHF, Notice of Proposed Rulemaking, 25 FCC Rcd 16498 (2010) (?NPRM?).
3 Although the FCC has not yet proposed repacking the broadcast spectrum in any public
proceeding, Chairman Genachowski made clear in remarks before the National Association of
Broadcasters (?NAB?) conference earlier this month that the FCC intends to pursue repack. See
Prepared Remarks at NAB Show 2011, April 12, 2011, at 8, available at http://www.fcc.gov/ Daily_
Releases/Daily_Business/2011/db0412/DOC-305708A1.pdf (?Now, this brings me to an important
issue that merits working together on a productive path ? repacking, or what some are increasingly
calling realignment.?) (?Genachowski NAB Speech?).
2
I. Providing Broadcasters with Increased Flexibility To Meet Mobile Wireless
Demand Is a Superior Approach for Addressing Wireless Broadband Needs.
The comments filed to date in this docket provide the FCC with several alternatives that
would more effectively address mobile broadband needs as they emerge across the country than the
measures proposed in the NPRM. In addition to Local Television Broadcasters, many other groups ?
Public Broadcasters, Capitol Broadcasting Company, Cox Media Group, ION Media Networks, LIN
Television Corporation, NAB/MSTV, and Sinclair Broadcast Group, Inc. ? suggested alternative
plans.4 The key feature of these plans is that they would provide individual broadcasters with the
regulatory flexibility to respond to actual wireless broadband demands at the local and regional level,
rather than imposing a nationally uniform approach on every market irrespective of actual need.
Such market-based, locally-oriented approaches are superior to the centrally planned model
envisioned by the NPRM and its proponents. First, the alternative plans would maintain the
historical local focus of the TV spectrum bands. Creating a regulatory environment that permits
broadcasters to adopt local and regional responses to wireless broadband demands is an approach that
most directly addresses the purported spectrum ?crisis? because even proponents of repack recognize
that their alleged ?crisis? affects, at most, the nation?s 30 largest markets.5 Second, each alternative
plan would avoid the years of uncertainty inherent in seeking and obtaining Congressional
authorization, conducting incentive auctions, and overseeing wireless operators? build out of the
4 Comments of Local Television Broadcasters, ET Docket No. 10-235 (filed Mar. 18, 2011)
(?LTB Comments?) at 28-31; Comments of Ass?n of Pub. Television Stations, et al., ET Docket No.
10-235 (filed Mar. 18, 2011) at 17-18; Comments of Capitol Broad. Co., ET Docket No. 10-235
(filed Mar. 18, 2011) at 22-25; Comments of Cox Media Grp., Inc., ET Docket No. 10-235 (filed
Mar. 18, 2011) at 21-23 (?CMG Comments?); Comments of ION Media Networks, ET Docket No.
10-235 (filed Mar. 18, 2011) at 8; Comments of LIN Television Corp., ET Docket No. 10-235 (filed
Mar. 18, 2011) (?LIN Comments?) at 5-7; Comments of NAB and Ass?n for Maximum Serv.
Television, Inc., ET Docket No. 10-235 (filed Mar. 18, 2011) (?NAB/MSTV Comments?) at 9-19;
Comments of Sinclair Broad. Grp., Inc., ET Docket No. 10-235 (filed Mar. 18, 2011) (?Sinclair
Comments?) at 13.
5 See, e.g., CEA & CTIA, Broadcast Spectrum Incentive Auctions White Paper (Feb. 15, 2011) at
2, http://files.ctia.org/pdf/CTIA_CEA_TV_Spectrum_Whitepaper.pdf.
3
reallocated spectrum.6 Instead, the FCC could implement these plans immediately. Third, the
alternative plans would avoid saddling broadcasters with the costs or viewers with the accompanying
service degradation, of a second DTV transition in less than a decade.7 Fourth, unlike the NPRM?s
proposals, the alternative plans would not hamper broadcasters? provision of HDTV and multicasting
or interfere with innovative new digital services like Mobile DTV. Fifth, unlike the one-time
revenue boost from incentive auctions, allowing the flexible use outlined in broadcasters? proposals
could create an ongoing government revenue stream through ancillary services fees.8
These alternative plans would require market-based cooperation among broadcasters and
wireless providers to meet the potential future demands of carriers and consumers. Broadcasters are
very willing ? starting today ? to begin working with wireless operators to address emerging
spectrum demands. CTIA has publicly endorsed using private agreements to clear spectrum for
wireless broadband use in the context of its recently filed Channel 51 Petition, and the same logic
supports private negotiations for flexible use of the broadcast bands as well.9 As long as the FCC
focuses only on spectrum reallocation, however, wireless carriers will have no incentive to work with
broadcasters. The FCC should encourage this necessary cooperation by granting broadcasters
flexibility to meet market demands and by withdrawing its proposal to reclaim broadcast spectrum
for new licensees.
6 See, e.g., David Lieberman, AT&T CEO Talks Optimistically About T-Mobile Deal, USATODAY
(Apr. 3, 2011), http://www.usatoday.com/money/industries/telecom/ 2011-04-03-att-ceo-randall-
stephenson.htm (AT&T CEO Randall Stephenson: ?it takes a decade? to build out new spectrum.).
7 In his recent remarks before the NAB, Chairman Genachowski sketched out a few principles he
expects to govern the process of reclaiming and repacking broadcast spectrum, including
compensation to broadcasters for the costs of channel changes and maintaining the voluntary nature
of every step of the process. See Genachowski NAB Speech at 8-9. The Chairman?s comments are
no substitute for a notice and comment rulemaking that fully explores the harms that repack would
cause and the rules that would govern any repack.
8 See LTB Comments at 28-31.
9 See Petition for Rulemaking and Request for Licensing Freezes by CTIA ? the Wireless
Association® and Rural Cellular Association, RM-11626, filed Mar. 15, 2011, at 19-22 (?Channel 51
Petition?).
4
II. Adopting the NPRM?s Proposals Would Be Arbitrary, Capricious, and Contrary to
the Public Interest.
The availability and superiority of market-based alternatives ? and the FCC?s duty to
consider them ? demonstrate that adopting the NPRM proposals at this time would be arbitrary,
capricious, and contrary to the public interest. The FCC is required to give serious consideration to
alternatives to its proposals and to adopt the choices that best serve the public interest.10 That duty is
particularly strong in this case because, as Local Television Broadcasters explained in their
comments, the NPRM lacks the legal and factual predicates required for reallocation of the TV
spectrum, a course that would cause irreparable harm to both broadcasters and viewers.11
The NPRM and the comments favoring it supply no record evidence that any of the proposed
changes is technically feasible. Instead, the record demonstrates that the NPRM?s proposals are
likely to create interference and significant service losses, which will affect primarily vulnerable
populations that depend on over-the-air television.12 These predictable results will lead to viewer,
advertiser, and revenue declines for broadcasters, crippling their ability to provide the high-quality
local news and information services on which viewers currently depend and eviscerating their ability
to roll out new services like Mobile DTV.13 Moreover, these public interest harms can not be
justified by any corresponding need because the record neither demonstrates nor proves that a
?looming spectrum crisis? exists ? the articulated premise for any spectrum reallocation and repack.
To the contrary, the record demonstrates that the FCC has ample time to implement less harmful and
10 City of Brookings Mun. Tel. Co. v. FCC, 822 F. 2d 1153, 1169 (D.C. Cir. 1987) (citing
Farmers Union Cent. Exch., Inc. v. FERC, 734 F.2d 1486, 1511 (D.C. Cir. 1984)). See also
Cincinnati Bell Tel. Co. v. FCC, 69 F.3d 752, 761 (6th Cir. 1995).
11 See LTB Comments at 2-18.
12 See id. at 5-7, 12, 20; CMG Comments at 16-19. See also Comments of Univision
Commc?ns., Inc., ET Docket No. 10-235 (filed Mar. 18, 2011) at 1-5 (describing continuing
importance of over-the-air television for Hispanic viewers). CMG?s preliminary engineering
analyses estimate that its stations? coverage areas could shrink by as much as 15%, affecting
primarily rural viewers who can less likely obtain substitute video services. CMG Comments at 17.
13 See id. at 12, 22, 23; Comments of Belo Corp., ET Docket No. 10-235 (filed Mar. 18, 2011) at
12; LIN Comments at 12-13; CMG Comments at 16-19; Pearl Mobile DTV Comments, ET Docket
No. 10-235 (filed Mar. 18, 2011) at 10 (?Pearl Comments?).
5
less drastic solutions like those described above, without in any manner compromising consumer
access to mobile broadband services.
A. Proponents of the NPRM Fail To Establish That the FCC?s Proposals Are
Legally Permissible or Technically Feasible.
Proponents of the NPRM?s proposals proffer scant legal or technical support for them. The
support that they do put forth is largely erroneous and exacerbates the formidable legal and technical
hurdles Local Television Broadcasters and other commenting parties have identified.
Incentive Auctions. T-Mobile raises the issue of incentive auctions (on which the NPRM did
not seek comment), suggesting that the FCC commence a proceeding to implement incentive auction
legislation that has not yet been passed.14 T-Mobile does not indicate which of the many incentive
auction bills it would have the FCC implement, but regardless, absent statutory changes, the FCC has
no authority to conduct such a proceeding.15 Ultra vires action wastes both agency and private
parties? resources. T-Mobile?s suggested approach not only puts the cart before horse, it completely
uncouples the cart from the horse.
Co-Primary Designation. The advocates of the co-primary proposal provide no technical
evidence supporting its feasibility, and each leaves unopposed the significant evidence of
infeasibility.16 Moreover, CTIA has alleged in its Channel 51 Petition that adjacent operations of
14 Comments of T-Mobile, ET Docket No. 10-235 (filed Mar. 18, 2011) (?T-Mobile Comments?)
at 8-9.
15 See LTB Comments at n. 8 (listing five different incentive auction bills). None of the pending
bills has achieved consensus support in Congress, and the most recent congressional hearings on
spectrum revealed significant concerns that must be addressed, presumably before any bill can
advance. See Using Spectrum To Advance Public Safety, Promote Broadband, Create Jobs, And
Reduce The Deficit: Hearing Before the Commc?ns and Tech. Subcomm. Of the H. Energy and
Commerce Comm., 112th Cong. at 32 (Rep. Ed Markey (D, MA): ?obviously, the broadcasters are a
big part of our safety response capacity, because people turn to radios, people turn to television to get
their information. So we want to make sure that those local broadcasters are there.?), 43-46 (Rep.
John Dingell (D-MI): (due to the unresolved problems that incentive auctions and spectrum repack
create in Canadian and Mexican border areas, ?it looks to me here a little like we?re buying a pig in a
poke where the commissions come up here and they are going to do all these wonderful things and
we don?t know exactly what they?re going to do.?).
16 See, e.g., LTB Comments at Attachment B, Technical Statement in Support of Comments.
6
broadcast and mobile wireless services create technical challenges that require special Commission
attention.17 In the face of such allegations, the Commission cannot move forward without first
resolving ?the science? ? interference issues raised by the laws of physics. The FCC?s core
obligation to maintain the integrity of the spectrum dictates that the agency must closely examine the
co-primary proposal and resolve any interference issues before adopting rules affecting broadcasters?
primary status. See 47 U.S.C. §§ 151, 303(f), 303(y). Principles of administrative law prohibit the
Commission from avoiding such crucial questions while moving forward on a piecemeal basis.18
CEA erroneously asserts that the co-primary proposal is consistent with the FCC?s decision
in the lower 700 MHz reallocation proceeding.19 In that case, the FCC in fact held that co-primary
operation of full-power broadcasting and mobile wireless could not coexist.20 That precedent is a
significant obstacle to adoption of the co-primary proposal in this docket, not supportive precedent.
CTIA disingenuously claims that the co-primary proposal ?is consistent with [the FCC?s]
policy of deploying spectrum with flexible service rules.?21 The FCC?s publicly proclaimed repack
plan would not lead to flexibility, but rather to a portion of the bands being used exclusively by
wireless operators and the remainder exclusively by broadcasters.22 The only proposals in this
proceeding consistent with flexible use policies are those raised by broadcasters.
Channel Sharing. Unless and until the substantial legal and technical problems cited in the
broadcasters? comments are solved ? assuming they can be ? broadcasters are unlikely to participate
in channel sharing arrangements.23 AT&T admits in its comments that broadcasters ?committed to
17 See Channel 51 Petition at 4-7, 12-13, 19-22.
18 See National Association of Broadcasters v. FCC, 740 F.3d 1190, 1211 (D.C. Cir. 1984);
Neighborhood TV Company, Inc. v. FCC, 742 F.2d 629, 642 (D.C. Cir. 1984).
19 Comments of the Consumer Elecs. Ass?n, ET Docket 10-235 (filed Mar. 18, 2011) (?CEA
Comments?) at 12.
20 See Reallocation and Service Rules for the 698-746 MHz Spectrum Band (Television
Channels 52-59), Notice of Proposed Rulemaking, 16 FCC Rcd 7278 (2001).
21 CTIA Comments, ET Docket. No. 10-235 (filed Mar. 18, 2011) at 12.
22 See, e.g., CEA Comments at 9. Moreover, the NPRM does not even address service rules for
the reallocated spectrum. See NPRM, 25 FCC Rcd at 16504.
23 See LTB Comments at 18-25.
7
the highest quality high definition signal . . . cannot share channels,?24 and it should be obvious that
broadcasters have no interest in offering low-quality service.
T-Mobile and CTIA advocate granting ?full must carry rights? to channel-sharing
broadcasters but do not address whether such action comports with the Communications Act.25
Under Section 614, broadcasters enjoy mandatory carriage rights because they operate ?local
commercial television stations.? See 47 U.S.C. § 534(a). Courts, however, will be unlikely to
consider multiple programming streams on one 6 MHz ATSC channel to be individual ?signals?
entitled to carriage.26 Faced with an inability to offer high-quality services and uncertain mandatory
carriage rights, broadcasters will find little reason to embrace channel sharing arrangements.
VHF. Several parties disingenuously support the NPRM?s VHF proposals as a means of
encouraging relocation of TV channels to the VHF band, while at the same time freely admitting that
digital services cannot effectively operate on that spectrum.27 AT&T argues that ?the Commission
should focus on the UHF bands only? when permitting mobile use of the TV spectrum because VHF
frequencies are ?not ideal? for such use.28 As AT&T explains, ?the form factor of a VHF antenna
would render a mobile device untenable.?29
As broadcasters have noted, mobile is an extremely important part of their future.30 Forcing
broadcasters to use VHF channels would be tantamount to sabotaging that future and picking certain
?winners? over other ?losers.? Moreover, while the issue is worthy of study, broadcasters generally
agree that material improvements to VHF band utility are unlikely.31
24 AT&T Comments, ET Docket 10-235 (filed Mar. 18, 2011) at 5.
25 See CTIA Comments at 14; T-Mobile Comments at 10-14.
26 See LTB Comments at 20-22.
27 See AT&T Comments at 6-7. See also CTIA Comments at 15-16.
28 AT&T Comments at 5.
29 Id. at 6.
30 See, e.g., Pearl Comments at 3-8; Comments of Open Mobile Video Coalition, ET Docket No.
10-235 (filed Mar. 18, 2011) at 4-12.
31 See, e.g., NAB/MSTV Comments at 19-23, Sinclair Comments at 9.
8
B. The Record Does Not Establish a Spectrum ?Crisis.?
The companies supporting the NPRM?s proposals assume that a real and immediate spectrum
shortage exists but provide no evidence of one.32 The public statements of these companies? own
executives contradict the spectrum ?crisis? claim. For example, following the announcement of its
planned acquisition of T-Mobile, AT&T Mobility CEO Ralph de la Vega stated that the deal will
?resolve[] the pending spectrum challenges that we?re facing in major cities,?33 and that, ??with this
deal, we?re set? for both the short and long haul.?34 Verizon Wireless executives also have
disavowed any need for TV spectrum.35 Sprint likewise has noted that broadcast spectrum
reallocation is not necessary to address immediate spectrum needs.36
A late-filed presentation by Mobile Future, an AT&T-affiliated industry organization, seeks
to counteract these public statements by claiming that if current usage trends continue, demand for
wireless broadband will exceed capacity within the next four years.37 The presentation is not
persuasive, however, because the report lacks any hard data supporting its calculations of growth in
wireless capacity or demand. In fact, two of the report?s flawed presumptions demonstrate why it is
far too speculative to justify any FCC reliance on its dire predictions.
32 E.g., T-Mobile Comments at 6-7.
33 James Rogers, AT&T CEO: T-Mobile Solves Spectrum Crunch, THE STREET (Mar. 22, 2011),
http://www.thestreet.com/story/11055239/1/att-ceo-t-mobile-solves-spectrum-crunch.html.
34 Mark Milian, AT&T Exec Says Problems Soon Without T-Mobile Merger, CNN (Mar. 22,
2011), http://articles.cnn.com/2011-03-22/tech/verizon.att.spectrum_1_aloha-partners-spectrum-at-t-
executive.
35 See id. (quoting CTO David Small); see also Verizon Not Seeking Television Spectrum, RADIO
AND TELEVISION BUSINESS REPORT (Apr. 8, 2010), www.rbr.com/tv-cable/23161.html (quoting CEO
Ivan Seidenberg).
36 See Sprint Nextel Corp. Comments, GN Docket No. 09-51 (filed Oct. 23, 2009) at 2; see also
Yu-Ting Wang, FCC Eyes Spectrum Harmonization and Sharing, Milkman Says, COMMUNICATIONS
DAILY at 9-11 (Apr. 7, 2011).
37 See Letter from Jonathan Spalter, Chairman, to Marlene H. Dortch, Secretary, FCC, dated
April 5, 2011 (attaching Rysavy Research and Mobile Future, The Spectrum Imperative: Mobile
Broadband Spectrum and Its Impacts for U.S. Consumers and the Economy, An Engineering
Analysis, Mar. 16, 2011, at 17 (?MF Report?)).
9
First, the report presumes that technological improvements will not expand capacity
sufficiently to meet increasing demands.38 Rapid and continuing technological developments
undercut this presumption. Earlier this year, for instance, Alcatel Lucent unveiled the LightRadio
Cube, which compresses the elements of a cell tower into a 2.3 inch cube that can operate on existing
wireless frequencies. This new technology promises to double available bandwidth while reducing
cost-per-bit and operational costs.39 If just this one innovation is able to double bandwidth in densely
populated areas, it and similar innovations will expand capacity far more than any reallocation of
broadcast spectrum. Mobile Future?s presumption that technological advances will be insufficient is
simply inconsistent with this real world evidence.
Second, the report rests on the mistaken premise that the only way to meet projected future
wireless broadband needs is to use today?s one-to-one wireless network architecture.40 Local
Television Broadcasters agree that wireless video programming will drive consumer demand, but as
demonstrated by the record in this docket, the one-to-many architecture of Mobile DTV provides a
far more efficient way to deliver high-value, high-demand video programming than current wireless
networks.41 Fostering Mobile DTV will save spectrum by allowing broadcasters to efficiently
deliver mobile video, whereas reallocation and spectrum sharing would make broadcasters? mobile
video plans impossible to execute.42
While continuing to disparage broadcast TV as a supposedly inefficient use of spectrum,
wireless carriers have publicly stated that they will increase efficiency by making broadcasting part
38 See id. at 15.
39 See Alcatel Lucent, LightRadio: Evolve your wireless broadband network for the new
generation of applications and users, http://www.alcatel-lucent.com/features/light_radio/index.html
(last visited Apr. 25, 2011); Charles Babcock, Alcatel Lucent Shrinks Cell Phone Towers,
INFORMATIONWEEK (Feb. 7, 2011), http://www.informationweek.com/news/telecom/business/
229201232.
40 See MF Report at 9-11, 13-14.
41 See, e.g., Pearl Comments at 7.
42 See, e.g., LTB Comments at 22-25; CMG Comments at 9-11.
10
of their future network designs.43 The MF Report does not account for such integration of broadcast
capability into wireless broadband networks or the potential spectrum savings realized by broadcast
distribution of video programming via Mobile DTV.
Due to all these oversights, the MF Report cannot be considered credible evidence of a
current or future spectrum shortage. Given the lack of any reliable evidence of a looming spectrum
?crisis,? administrative law principles prohibit the FCC from moving forward with the NPRM?s
proposals based on the presumption that one exists.44
CONCLUSION
For the foregoing reasons as well as those set forth in their initial comments, Local
Television Broadcasters request that the FCC terminate this proceeding and move forward with
providing current TV licensees with the flexibility to meet market demands for wireless broadband
services as they evolve.
Respectfully submitted,
LOCAL TELEVISION BROADCASTERS
By: /s/
John R. Feore, Jr.
Kevin P. Latek
Derek Teslik
DOW LOHNES PLLC
1200 New Hampshire Avenue, NW
Suite 800
Washington, DC 20036
April 25, 2011 (202) 776-2000
43 See Stephen Lawson, ?Verizon Looks to Video Broadcasting on LTE,? PCWorld Business
Center (November 8, 2010), http://www.pcworld.com/businesscenter/article/210063/
verizon_looks_to_video_broadcasting_on_lte.html (Verizon Wireless expects to use broadcasting to
deliver live video as part of efforts to deal with heavy demand for capacity); Doug Lung, Is LTE in
Broadcast?s Future, Television Broadcast.com (Mar.1, 2011), http://www.televisionbroadcast.com/
article/114486 (discussing Verizon and AT&T plans for broadcast component of LTE networks).
44 See, e.g., Portland Cement Ass?n v. Ruckelshaus, 486 F. 2d 375, 393 (D.C. Cir. 1973) (?It is
not consonant with the purpose of a rule-making proceeding to promulgate rules on the basis of
inadequate data . . .?).
ATTACHMENT A
LOCAL TELEVISION BROADCASTERS
Owner DMA Station
Birmingham WCFT-TV, Tuscaloosa, AL
Birmingham WJSU-TV, Anniston, AL
Charleston WCIV(TV), Charleston, SC
Harrisburg-Lancaster WHTM-TV, Harrisburg, PA
Little Rock-Pine Bluff KATV(TV), Little Rock, AR
Roanoke-Lynchburg WSET-TV, Lynchburg, VA
Tulsa KTUL(TV), Tulsa, OK
Allbritton
Communications Company
and WCIV, LLC
Washington, DC WJLA-TV, Washington, DC
Charlotte WCCB(TV), Charlotte, NC
Columbia, SC WOLO-TV, Columbia, SC
Jackson, TN WBBJ-TV, Jackson, TN
Montgomery-Selma WAKA(TV), Selma, AL
Bahakel Communications
Ltd.
Myrtle Beach-Florence WFXB(TV), Myrtle Beach, SC
Alexandria, LA WNTZ-TV, Natchez, MS
Baton Rouge WGMB-TV, Baton Rouge, LA
El Paso KTSM-TV, El Paso, TX
Evansville WEVV-TV, Evansville, IN
Harlingen-Weslaco KVEO-TV, Brownsville, TX
Lafayette KADN-TV, Lafayette, LA
Odessa-Midland KPEJ-TV, Odessa, TX
Shreveport KMSS-TV, Shreveport, LA
Tyler-Longview KETK-TV, Jacksonville, TX
Waco-Temple KWKT-TV, Waco, TX
Communications
Corporation of America
Waco-Temple KYLE-TV, Bryan, TX
Billings KTVQ(TV), Billings, MT
Butte-Bozeman KBZK-TV, Bozeman, MT
Butte-Bozeman KXLF-TV, Butte, MT
Colorado Springs-Pueblo KOAA-TV, Pueblo, CO
Corpus Christi KRIS-TV, Corpus Christi, TX
Great Falls KRTV(TV), Great Falls, MT
Lafayette KATC(TV), Lafayette, LA
Lexington WLEX-TV, Lexington, KY
Missoula KPAX-TV, Missoula, MT
Santa Barbara-Santa Maria KSBY(TV), San Luis Obispo, CA
Cordillera
Communications, Inc.
Tucson KVOA(TV), Tucson, AZ
Cleveland-Akron WJW(TV), Cleveland, OH
Denver KDVR(TV), Denver, CO
Denver KFCT(TV), Ft. Collins, CO
Greensboro-High Point WGHP(TV), High Point, NC
Kansas City WDAF-TV, Kansas City, MO
Milwaukee WITI(TV), Milwaukee, WI
FoxCo Acquisition, LLC
Richmond-Petersburg WTVR-TV, Richmond, VA
2
Owner DMA Station
Salt Lake City KSTU(TV), Salt Lake City, UT
St. Louis KTVI(TV), St. Louis, MO
Binghamton WBNG-TV, Binghamton, NY
Buffalo WKBW-TV, Buffalo, NY
Detroit WMYD(TV), Detroit, MI
Duluth-Superior, MN/WI KBJR-TV, Superior, WI
Duluth-Superior, MN/WI KRII(TV), Chisholm, MN
Fresno-Visalia KSEE(TV), Fresno, CA
Ft. Wayne WISE-TV, Fort Wayne, IN
Peoria-Bloomington, IL WEEK-TV, Peoria, IL
San Francisco-Oakland KOFY-TV, San Francisco, CA
Granite Broadcasting
Corporation
Syracuse WTVH(TV), Syracuse, NY
Albany, GA WSWG(TV), Valdosta, GA
Augusta WRDW-TV, Augusta, GA
Bowling Green WBKO(TV), Bowling Green, KY
Charleston-Huntington WSAZ-TV, Huntington, WV
Charlottesville WCAV(TV), Charlottesville, VA
Colorado Springs-Pueblo KKTV(TV), Colorado Springs, CO
Dothan WTVY(TV), Dothan, AL
Grand Junction-Montrose KKCO(TV), Grand Junction, CO
Greenville WITN-TV, Washington, NC
Harrisonburg WHSV-TV, Harrisonburg, VA
Knoxville WVLT-TV, Knoxville, TN
La Crosse-Eau Claire WEAU-TV, Eau Claire, WI
Lansing WILX-TV, Onandaga, MI
Lexington WKYT-TV, Lexington, KY
Lexington WYMT-TV, Hazard, KY
Lincoln & Hastings KGIN(TV), Grand Island, NE
Lincoln & Hastings KOLN(TV), Lincoln, NE
Madison WMTV(TV), Madison, WI
Meridian WTOK-TV, Meridian, MS
Omaha WOWT-TV, Omaha, NE
Panama City WJHG-TV, Panama City, FL
Parkersburg WTAP-TV, Parkersburg, WV
Reno KOLO-TV, Reno, NV
Rockford WIFR(TV), Freeport, IL
Sherman, TX-Ada, OK KXII(TV), Sherman, TX
South Bend-Elkhart WNDU-TV, South Bend, IN
Tallahassee-Thomasville, FL/GA WCTV(TV), Thomasville, GA
Topeka WIBW-TV, Topeka, KS
Waco-Temple KBTX-TV, Bryan, TX
Waco-Temple KWTX-TV, Waco, TX
Wausau-Rhinelander WSAW-TV, Wausau, WI
Wichita-Hutchinson KAKE-TV, Wichita, KS
Wichita-Hutchinson KLBY(TV), Colby, KS
Gray Television, Inc.
Wichita-Hutchinson KUPK(TV), Garden City, KS
Idaho Independent Boise KTRV-TV, Nampa, ID
3
Owner DMA Station
Television, Inc.
Louisville WDRB(TV), Louisville, KY Independence Television
Company Louisville WMYO(TV), Salem, IN
Lima Communications
Corporation
Lima, OH WLIO(TV), Lima, OH
Davenport-Rock Island, IA/IL WQAD-TV, Moline, IL
Des Moines WHO-DT, Des Moines, IA
Ft. Smith-Fayetteville KFSM-TV, Fort Smith, AR
Huntsville-Decatur WHNT-TV, Huntsville, AL
Memphis WREG-TV, Memphis, TN
Norfolk-Portsmouth WGNT(TV), Portsmouth, VA
Norfolk-Portsmouth WTKR-TV, Norfolk, VA
Oklahoma City KAUT-TV, Oklahoma City, OK
Oklahoma City KFOR-TV, Oklahoma City, OK
Local TV, LLC
Wilkes Barre-Scranton WNEP-TV, Scranton, PA
Duluth-Superior, MN/WI KDLH(TV), Duluth, MN Malara Broadcast Group,
Inc. Ft. Wayne WPTA(TV), Fort Wayne, IN
Bakersfield KERO-TV, Bakersfield, CA
Denver KMGH-TV, Denver, CO
Indianapolis WRTV(TV), Indianapolis, IN
McGraw-Hill Broadcasting
Company, Inc.
San Diego KGTV(TV), San Diego, CA
Augusta WJBF(TV), Augusta, GA
Birmingham WVTM-TV, Birmingham, AL
Charleston WCBD-TV, Charleston, SC
Columbus, GA WRBL(TV), Columbus, GA
Columbus, OH WCMH-TV, Columbus, OH
Greenville WNCT-TV, Greenville, NC
Greenville-Spartanburg, NC/SC WSPA-TV, Spartanburg, SC
Greenville-Spartanburg, NC/SC WYCW(TV), Asheville, NC
Hattiesburg-Laurel WHLT(TV), Hattiesburg, MS
Jackson, MS WJTV(TV), Jackson, MS
Mobile, AL-Pensacola, FL WKRG-TV, Mobile, AL
Myrtle Beach-Florence WBTW(TV), Florence, SC
Providence-New Bedford, RI/MA WJAR(TV), Providence, RI
Raleigh-Durham WNCN(TV), Goldsboro, NC
Roanoke-Lynchburg WSLS-TV, Roanoke, VA
Savannah WSAV-TV, Savannah, GA
Tampa-St. Petersburg WFLA-TV, Tampa, FL
Media General, Inc.
Tri-Cities, TN-VA WJHL-TV, Johnson City, TN
Atlanta WGCL-TV, Atlanta, GA
Flint-Saginaw WNEM-TV, Bay City, MI
Greenville-Spartanburg, NC/SC WHNS(TV), Greenville, SC
Hartford & New Haven WFSB(TV), Hartford, CT
Kansas City KCTV(TV), Kansas City, MO
Kansas City KSMO-TV, Kansas City, MO
Las Vegas KVVU-TV, Henderson, NV
Meredith Corporation and
KVVU Broadcasting Corp.
Nashville WSMV-TV, Nashville, TN
4
Owner DMA Station
Phoenix KPHO-TV, Phoenix, AZ
Portland KPDX(TV), Vancouver, WA
Portland KPTV(TV), Portland, OR
Midwest Television, Inc. San Diego KFMB(TV), San Diego, CA
Abilene - Sweetwater KRBC-TV, Abilene, TX
Amarillo KCIT(TV), Amarillo, TX
Billings KHMT(TV), Hardin, MT
Erie WFXP(TV), Erie, PA
Joplin - Pittsburg, MO/KS KODE-TV, Joplin, MO
Lubbock KAMC(TV), Lubbock, TX
Monroe - El Dorado, LA/AR KTVE(TV), El Dorado, AR
Rockford WTVO(TV), Rockford, IL
San Angelo KSAN-TV, San Angelo, TX
Springfield, MO KOLR(TV), Springfield, MO
Terre Haute WFXW(TV), Terre Haute, IN
Utica WUTR(TV), Utica, NY
Wichita Falls - Lawton, TX/OK KJTL(TV), Wichita Falls, TX
Mission Broadcasting, Inc.
Wilkes Barre-Scranton WYOU(TV), Scranton, PA
Chattanooga WFLI-TV, Chattanooga, TN
Gainesville WNBW-DT, Gainesville, FL
Portland, ME WPME(TV), Lewiston, ME
Tallahassee-Thomasville, FL/GA WTLF(TV), Tallahassee, FL
MPS Media
Wilkes Barre-Scranton WSWB(TV), Scranton, PA
Chattanooga WDSI-TV, Chattanooga, TN
Gainesville WGFL(TV), High Springs, FL
Portland, ME WPXT(TV), Portland, ME
Tallahassee-Thomasville, FL/GA WTLH(TV), Tallahassee, FL
Wilkes Barre-Scranton WOLF-TV, Scranton, PA
New Age Media
Broadcasting Group
Wilkes Barre-Scranton WQMY(TV), Williamsport, PA
Abilene - Sweetwater KTAB-TV, Abilene, TX
Amarillo KAMR-TV, Amarillo, TX
Beaumont ? Port Arthur KBTV-TV, Port Arthur, TX
Billings KSVI(TV), Billings, MT
Champaign&Springfield-Decatur WCIA(TV), Champaign, IL
Champaign&Springfield-Decatur WCFN(TV), Springfield, IL
Dothan WDHN(TV), Dothan, AL
Erie WJET-TV, Erie, PA
Evansville WTVW(TV), Evansville, IN
Ft. Smith-Fayetteville KFTA-TV, Ft. Smith, AR
Ft. Smith-Fayetteville KNWA-TV, Rogers, AR
Ft. Wayne WFFT-TV, Ft. Wayne, IN
Harrisburg-Lancaster WLYH-TV, Lancaster, PA
Jacksonville WCWJ(TV), Jacksonville, FL
Johnstown - Altoona WTAJ-TV, Altoona, PA
Joplin - Pittsburg, MO/KS KSNF(TV), Joplin, MO
Little Rock-Pine Bluff KARK-TV, Little Rock, AR
Nexstar Broadcasting
Group
Little Rock-Pine Bluff KARZ-TV, Little Rock, AR
5
Owner DMA Station
Lubbock KLBK-TV, Lubbock, TX
Monroe - El Dorado, LA/AR KARD-TV, West Monroe, LA
Odessa-Midland KMID(TV), Midland, TX
Peoria-Bloomington, IL WMBD-TV, Peoria, IL
Rochester WROC-TV, Rochester, NY
Rockford WQRF-TV, Rockford, IL
San Angelo KLST(TV), San Angelo, TX
Shreveport KTAL-TV, Texarkana, TX
Springfield, MO KSFX-TV, Springfield, MO
St. Joseph, MO KQTV(TV), St. Joseph, MO
Terre Haute WTWO(TV), Terre Haute, IN
Utica WFXV(TV), Utica, NY
Washington, DC WHAG-TV, Hagerstown, MD
Wichita Falls - Lawton, TX/OK KFDX-TV, Wichita Falls, TX
Wilkes Barre-Scranton WBRE-TV, Wilkes-Barre, PA
Oxford Media Group Chicago WJYS(TV), Hammond, IN
SCTV, Inc. Los Angeles KAZA-TV, Avalon, CA
Burlington-Plattsburgh, VT/NY WFFF-TV, Burlington, VT
Santa Barbara-Santa Maria KEYT-TV, Santa Barbara, CA
Smith Media, L.L.C.
Utica WKTV(TV), Utica, NY
Chicago WGN-TV, Chicago, IL
Dallas-Ft. Worth KDAF(TV), Dallas, TX
Denver KWGN-TV, Denver, CO
Grand Rapids-Kalamazoo WXMI(TV), Grand Rapids, MI
Harrisburg-Lancaster WPMT(TV), York, PA
Hartford-New Haven WTIC-TV, Hartford, CT
Hartford-New Haven WCCT-TV, Waterbury, CT
Houston KIAH(TV), Houston, TX
Indianapolis WXIN(TV), Indianapolis, IN
Indianapolis WTTV(TV), Bloomington, IN
Indianapolis WTTK(TV), Kokomo, IN
Los Angeles KTLA-TV, Los Angeles, CA
Miami-Ft. Lauderdale WSFL-TV, Miami, FL
New Orleans WGNO(TV), New Orleans, LA
New Orleans WNOL-TV, New Orleans, LA
New York, NY WPIX(TV), New York, NY
Philadelphia WPHL-TV, Philadelphia, PA
Portland KRCW-TV, Salem, OR
Sacramento-Stockton KTXL(TV), Sacramento, CA
San Diego KSWB-TV, San Diego, CA
Seattle-Tacoma KZJO(TV), Seattle, WA
Seattle-Tacoma KCPQ(TV), Tacoma, WA
St. Louis, MO KPLR-TV, St. Louis, MO
Tribune Broadcasting
Company
Washington, DC WDCW(TV), Washington, DC
WAND(TV) Partnership Champaign & Springfield-Decatur WAND(TV), Decatur, IL
Baton Rouge WVLA-TV, Baton Rouge, LA White Knight
Broadcasting, Inc. Shreveport KSHV-TV, Shreveport, LA
6
Owner DMA Station
Tyler-Longview KFXK-TV, Longview, TX
WNAC, LLC Providence-New Bedford, RI/MA WNAC-TV, Providence, RI