HomeMy WebLinkAbout20061274.tiff Hardy, Carey, Chautin & Balkin, LLP
ATTORNEYS AT LAW
110 Veterans Memorial Boulevard,Suite 300
Metairie,Louisiana 70005
Telephone 504.830.4646
Facsimile 504.830.4659
www.hardycarey.com
May 3, 2006 Joseph Chautin, III
jchautin(rihardycarev_com
Direct Dial: 504.830.4643
2317.107
Via Hand Delivery
Ms. Marlene Dortch, Secretary
Federal Communications Commission
445 12' Street, SW
Washington, DC 20554
Re: CSR-7004-M
LeSEA Broadcasting of Denver,Inc. v. Comcast of Colorado I, LLC, et al
Petitioner's Reply to Respondent's Opposition
Dear Ms. Dortch:
Please find enclosed an original and four (4) copies of the above referenced pleading
that we are filing on behalf of LeSEA Broadcasting of Denver, Inc., the Petitioner in this
proceeding. If you have any questions, please do not hesitate to contact me.
Kindest Regards,
—s--
�se. C. Chautin, III
JCC,III:ems
Encl.
cc: Service List
Peter Sumrall
Stephen Broeckaert (via hand delivery)
(10141,A 0S k G 0O 0290
Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC 20554
In re: )
)
LeSEA Broadcasting of Denver, Inc. ) CSR-7004-M
)
v. )
)
Comcast of Colorado I, LLC and, )
Comcast of Colorado II, LLC and, )
Comcast of Colorado III, LLC and, )
Comcast of Colorado IV, LLC and, )
Comcast of California/Colorado, LLC and, )
Comcast of California/Colorado/Texas/Washington, Inc. )
)
Request for Mandatory Carriage )
for KWHD(TV) )
in All Communities Served by Comcast in )
Larimer and Weld Counties, Colorado' )
)
To: Chief, Media Bureau
Reply to Opposition to Must Carry Complaint
Pursuant to Section 76.7(c) of the Commission's rules, LeSEA Broadcasting of Denver,
Inc. ("LeSEA")hereby files this reply to the opposition filed by Comcast of Colorado I, LLC et
al ("Comcast"). Comcast has alleged that KWHD is not eligible for carriage on its systems
serving Weld and Larimer Counties because KWHD does not deliver a good quality signal to
Comcast's headends at Fort Collins and Greeley, Colorado. LeSEA disputes the accuracy and
technical sufficiency of these tests and requests that the Bureau grant carriage of KWHD on these
systems.
' See Exhibit A in original complaint for complete listing of communities.
I. Comcast's tests of KWHD's signal are technically insufficient and inaccurate
and cannot be relied upon to determine KWHD's must-carry rights on these
systems.
The Commission places the initial burden on Comcast to show, through signal strength
tests,that KWHD's signal is inadequate for purposes of must-carry. Hope Television, Inc. v.
Friendship Cable of Arkansas, Inc., 13 FCC Rcd 13454 (1998); Corridor Television, LLP v.
Bluebonnet Electric Coop, Inc. d/b/a BRDC Cablevision, 16 FCC Red 13825, 13827 at¶ 7
(2001). Comcast must use sound engineering practices when conducting the tests to meet its
initial burden and to be able to rely on the tests to determine KWHD's must-carry eligibility. At
a minimum, for the tests to be considered to have been conducted using sound engineering
practices, the reported results must include,
"1) specific make and model numbers of the equipment used, as well as its age and
most recent date(s) of calibration; 2) description(s) of the characteristics of the
equipment used, such as antenna ranges and radiation patterns; 3) height of the
antenna above ground level and whether the antenna was properly oriented; and 4)
weather conditions and time of day when tests were done."
Complaint of Larry L. Schrecongost, 12 FCC Rcd 13194 at¶ 16;Must Carry Order, 8 FCC Rcd
2965, 2990 at¶ 103 (1993), and Clarification Order, 8 FCC Rcd 4142 at¶ 5 (1993).
Moreover,with respect to the antenna used, Comcast must "take measurements with
`generally accepted equipment that is currently used to receive signals of similar frequency range,
type or distance from the principal headend.""Hope Television, 13 FCC Rcd at¶ 6 (citing
Clarification Order, 8 FCC Red at 4143); Citrus County Association for Retarded Citizens v.
Mickelson Media, Inc. d/b/a Century Cable, 16 FCC Rcd 20713 (FCC 2001). Comcast must also
test KWHD's signal at the same height that it receives the signals of other broadcasters that it
currently carries. Suburban Cable TV Co., Inc., 16 FCC Rcd 10790, 10800-01 at¶32 (2001)
-2-
(citing Clarification Order, 8 FCC Rcd at 4143). Finally, conducting a test when a station is
operating at reduced power will yield invalid results that do not give a(literally) clear picture of
the station's signal strength. See KM Television of El Dorado, LLC v. Friendship Cable of
Arkansas, 19 FCC Rcd 8534 (2004); Folse Communications, LLC v. Allen's TV Cable Service,
Inc., 18 FCC Rcd 11304 (2003); R y F Broadcasting v. Cable TV of Greater San Juan, 14 FCC
Rcd 6821 (1999).
Here, Comcast inadequately and improperly tested KWHD's signal at the Fort Collins
and Greeley headends. The lack of use of sound engineering practices when performing the tests
vitiated the results as well as Comcast's subsequent denial of carriage.2 Comcast committed four
fatal errors in testing KWHD signal, any of which alone would invalidate the results,but when
taken together make it impossible to rely on the results to determine KWHD's must carry status.
First, Comcast conducted the tests when KWHD was operating at reduced power, a fact
which Comcast knew at the time it conducted the tests. Second, Comcast used an antenna that
was inferior to the types that it uses to receive other broadcasters' signals off-air. Third, Comcast
tested the signal at a height of only 31 feet,which is not the height that it receives the signals of
other broadcast signals that it carries. And, finally, Comcast improperly oriented the antenna in
2 Part of the problem with the tests was that they were conducted in a hurry, even though
Comcast had more than six months to test KWHD's signal from the time LeSEA made its first
election for carriage of KWHD. Indeed, Comcast's own engineer, Bob McQuitty, admitted to
KWHD's chief engineer that he had only two days to conduct the tests. Exhibit A (Affidavit of
Ron Vincent). Placing the completion of the testing under such a deadline - especially when the
tests could have been properly done at any point in the last six months - increased the chances
that the test would be performed in a sloppy manner and without attention to detail and
procedure. The consequence of this hurried and poor testing is that the test results are so flawed
they cannot be relied upon to give an accurate picture of KWHD's signal strength at either
headend and thus, cannot form the basis for a denial of carriage on these systems.
-3-
both tests such that it could not properly measure KWHD's signal. These four critical mistakes
establish that Comcast failed to use sound engineering practices in the KWHD tests.
Consequently, the tests cannot form the basis for Comcast's denial of carriage of KWHD.3
A. Comcast improperly tested KWHD's signal when the station was
operating at reduced power.
On April 11, 2006, LeSEA began having problems with the air conditioning unit in
KWHD's transmitter building. The unit failed and as the temperature rose in the building, the
power to the transmitter was reduced, resulting in a decrease of KWHD's signal strength by 26%.
KWHD operated with only 74%power from April 11, 2006 until April 12, 2006. At
approximately 3 pm on April 12, 2006, the technicians were able to fix the air conditioner and
normal power operation was restored. However, LeSEA's Chief Engineer,Ron Vincent,
discovered on April 16, 2006, that the air conditioner developed a second leak and failed again.
At that point, the power was again reduced and KWHD operated at 71% of its normal power.
See Exhibit A (Affidavit of Ron Vincent). The station is still operating at this power level.
LeSEA notified the Commission of the reduced power operation on April 26, 2006. See Exhibit
B (Reduced Power Notification)4.
3 These gross errors in Comcast's tests make it impossible for LeSEA to reach an
informed decision as to whether LeSEA must commit to provide additional equipment at its own
cost in order to qualify for carriage. As the Bureau will readily recognize, making such a
commitment under these circumstances would be premature and unnecessary, given that Comcast
has not carried its burden. In the event the Bureau directs Comcast to re-test the signal using
sound engineering practices, LeSEA respectfully requests that such order direct Comcast to
coordinate with LeSEA on the timing of the test so that LeSEA personnel can be present. Only if
such properly conducted tests confirmed a lack of signal strength would LeSEA be in a position
to make any commitment to provide equipment at its own cost.
In the footnote of the Notification, LeSEA indicated that normal power was restored on
April 13, 2006. LeSEA's Chief Engineer later clarified that normal power was restored at
-4-
•
Given KWHD's situation, any tests that Comcast conducted of KWHD's signal on April
11 and April 12 are invalid since they were conducted when KWHD was not operating at full-
power. See KM Television of El Dorado, LLC v. Friendship Cable of Arkansas, 19 FCC Rcd
8534, 8536 at¶ 8 (2004). What is more disturbing, however, is that Comcast's engineer, Bob
McQuitty, who performed the test of KWHD's signal at Greeley,knew of KWHD's power
troubles when he was testing the signal. On April 11, 2006, Mr. McQuitty called Ron Vincent,
LeSEA's chief engineer at KWHD, and, when they spoke, Mr. McQuitty informed Mr. Vincent
that he was conducting tests of KWHD's signal for Comcast. Mr. McQuitty inquired whether the
station was having power problems because he noticed a drop in the signal strength from early
morning to approximately noon. Mr. Vincent confirmed for Mr. McQuitty that KWHD was
operating at reduced power and informed him of the reason. See Exhibit A(Affidavit of Ron
Vincent). Despite having this information when he was testing the signal, however, Mr.
McQuitty did not stop the test or reschedule it, or even note the reduced power in the test results;
nor did he stop the April 12, 2006 test of KWHD's signal at Fort Collins.
Comcast's submission of these test results despite its knowledge of the station's reduced
power is not only disingenuous,but irresponsible. The Bureau should completely reject the test
results on this basis alone.
B. Comcast's test results are also invalid because it used an amateur, low
gain antenna with a 35-mile range to pick up KWHD's signal.
According to Comcast's test specifications, the engineers used two separate RCA 3036X
antennas to test KWHD's signal. This $59.95 rooftop antenna is typically used by residential
approximately 3 pm on April 12, 2006.
-5-
consumers to enhance their analog off-air reception at their homes; it is not a professional
antenna used to receive a signal for purposes of must-carry. Comcast's own documentation
shows that this antenna,unlike professional antennas which are channel-specific, is designed to
receive a wide range of both UHF and VHF channels. Moreover, the stated range of the antenna,
an underwhelming 35 miles for UHF, leaves no doubt as to its amateur use and complete
inadequacy for determining must-carry eligibility. Since KWHD's tower is located more than 35
miles from both the Fort Collins and Greeley testing sites, this low gain antenna had no chance of
adequately testing KWHD's signal.
Moreover, the antenna cannot be the same as what Comcast currently uses "to receive
signals of similar frequency range, type or distance from the principal headend." Clarification
Order, 8 FCC Rcd at 4143. On both its Fort Collins and Greeley systems, Comcast carries
several full power UHF stations that are licensed to Denver, some fifty-five miles away from Fort
Collins.' The use of this low-gain, short range antenna appears to have been calculated to trigger
a poor signal test, and violates LeSEA's right to have the signal tested using equipment that
Comcast uses"to receive signals of a similar ... type and distance from the principal headend."
Id.
Indeed, at the Greeley headend, Comcast uses high-gain professional antennas to receive
broadcast signals. KWHD's Chief Engineer, Ron Vincent, observed a communications tower at
the Greeley headend with multiple high-gain antennas hanging on it. See Exhibit A (Affidavit of
' These stations include KTVD (Channel 20), KDVR(Channel 31), KCEC (Channel 50),
and KPXC-TV (Channel 59). Comcast carries another UHF station, KMAS-TV (Channel 24),
licensed to Steamboat Springs, which is also more than 35 miles away from Fort Collins. This
station is only carried on the Fort Collins system.
-6-
Ron Vincent, Exhibits 1-6). This alone supports the conclusion that Comcast cannot receive
signals from Denver using the short-range antenna employed for the KWHD signal test. Further,
it strongly suggests, if not confirms, that Comcast intentionally chose to use an inadequate
antenna for the KWHD signal tests.
C. Comcast's test results are also unreliable because it tested KWHD's
signal at the paltry height of 31 feet when it receives other broadcast
signals at double that height.
Much like it violated the Commission's edict requiring testing of signals employing
comparable antennas used to receive other signals, Comcast also failed to follow the FCC's
requirement that it test KWITD's signal at the same height which it receives other broadcast
signals that it is currently carrying. Since the beginning of must-carry in 1993, the Commission
has strictly enforced the cable operator's mandated obligation to test signals at the same height
that it receives other broadcast signals. For example, in Suburban Cable TV Co., Inc., 16 FCC
Rcd 10790, 10800-01 at¶32 (2001), the Commission held that a test of the station's signal at 30
feet was blatantly invalid because Suburban was receiving other broadcast signals at a height of
approximately 350 feet.
Similarly, Comcast violated the FCC's mandate by not testing KWHD at the height
which it receives other broadcast signals. In both tests of KWHD's signal, Comcast mounted the
inadequate antenna on a pole on the roofs of its headend buildings at the equally inadequate
heights of 31 feet (Fort Collins) and 31 feet 2 inches (Greeley). At the Greeley headend, it is
clear that Comcast is receiving other broadcast signals at heights of at least 60 feet on its
communications tower. Yet, Comcast only tested KWHD on a makeshift pole at a height of 31
feet two inches, affixed to the top of the headend building- directly adjacent to the
-7-
communications tower- in violation of the Commission's requirements. See Exhibit A
(Affidavit of Ron Vincent and Exhibits 1-6). Comcast must test KWHD's signal at the same
height that it receives other broadcast signals for purposes of determining the station's must-carry
eligibility or else the results will be an invalid picture of KWHD's true signal strength and cannot
be used to determine its must-carry status.
D. Comcast ensured that the tests would fail by improperly orienting the
antenna.
In addition to using an inadequate antenna mounted at only 31 feet, Comcast improperly
oriented the antenna on both tests. This improper orientation added to the almost certainty that
Comcast would not receive an adequate signal from KWHD. According to Comcast's diagrams,
it oriented the antenna at 130° for the Fort Collins test and at 265° for the Greeley test. Both
orientations were incorrect. For the test at Fort Collins, Comcast should have oriented the
antenna at the 153° mark. See Exhibit A(Affidavit of Ron Vincent). The orientation mistake
was even worse on the Greeley test. On that test, Comcast oriented the antenna at the 265° mark,
over 100° from where KWHD's tower is located, which is at the 167°mark.6 Once Comcast
improperly oriented the antenna, the legitimacy of the tests was permanently compromised and
the validity of the tests was negated. See e.g. KM Television of El Dorado, LLC v. Classic Cable
6 Comcast has no excuse for this error since LeSEA's chief engineer, Ron Vincent, called
Bob McQuitty, Comcast's engineer on April 12, 2006, to make sure that Comcast was properly
orienting the antenna for the test. Mr. Vincent told Mr. McQuitty that many times, an antenna is
improperly oriented toward Golden, Colorado while KWHD's tower is located halfway between
Parker and Elizabeth, Colorado. Mr. McQuitty assured him that Comcast had the correct
orientation. See Exhibit A(Affidavit of Ron Vincent). Mr. Vincent's information also did not
make it to Michael Agnew, the Comcast engineer who tested KWHD's signal at Greeley. Both
engineers could have easily determined the location of KWHD's tower by simply searching in
the Commission's CDBS database.
-8-
of Louisiana, LLC, 19 FCC Rcd 12845 (2004). Thus, neither Comcast nor the Bureau can rely
upon Comcast's tests to determine KWHD's must-carry eligibility.
Conclusion
Comcast has failed to carry its burden of showing that its tests of KWHD's signal at the
headends at Fort Collins and Greeley meet the Commission's requirements of sound engineering
practices. The tests were irrevocably flawed because Comcast conducted them when KWHD
was operating at low power,which Comcast knew at the time, and used a woefully inadequate
and improperly oriented antenna mounted at a bare 31 feet. These flaws doomed the tests from
the outset and invalidated any use of the tests to deny KWHD carriage on Comcast's systems
serving Weld and Larimer Counties. LeSEA respectfully requests that the Bureau find the tests
unreliable and order Comcast to carry KWHD's signal.
Respectfully submitted:
Jose C Chautin, III
Eli Stubbe
Hari Carey, Chautin &Balkin, LLP
110 Veterans Blvd., Suite 300
Metairie, LA 70005
Tel: (504) 830-4646
Fax: (504) 830-4659
Attorneys for
LeSEA Broadcasting of Denver, Inc.
Dated: May 3, 2006
-9-
CERTIFICATE OF SERVICE
I, Joseph C. Chautin, III do hereby certify that a copy of the foregoing must-carry
complaint was mailed on this 3r°day of May, 2006 via first-class mail, postage pre-paid
to the following:
Scott Binder The Hon. Doug Hutchinson
Senior VP - Comcast Cable Mayor, Fort Collins, CO
8000 E. Iliff Avenue 1315 Whedbee Street
Denver, CO 80231 Fort Collins, CO 80524
Doug Gaston, Esq. Frank Lancaster
Senior VP & General Counsel Larimer County Manager
Comcast Cable 200 W. Oak Street
1500 Market Street P.O. Box 1190
Philadelphia, PA 19102 Fort Collins, CO 80522-1190
Weld County Commissioners Roy Otto, City Manager
Weld County, Colorado City of Greeley, CO
915 Tenth Street 1000 10th Street
P.O. Box 758 Greeley, CO 80631
Greeley, CO 80632
Frederick W. Giroux, Esq.
Cole, Raywid &Braverman, LLP
1919 Pennsylvania Avenue,NW
Suite 200
Washington, DC 20006 �6
Josep . autin, III
-10-
County of Douglas )
State of Colorado )
AFFIDAVIT OF RON VINCENT
BEFORE ME,the undesigned Notary, personally came and appeared:
RON VINCENT
who after being duly sworn did depose and state as follows:
I.Ron Vincent, am a citizen of the United States of America and resident of the County
of Douglas, State of Colorado.
1) I am employed by LeSEA Broadcasting of Denver,Inc.,the licensee of TV station
KWHD, as the chief engineer. I have been in this position for 8 years and have worked for
LeSEA Broadcasting Corporation since 1979. I have been a broadcast engineer for 26 years and
am certified by the Society of Broadcast Engineers.
2) On April 11, 2006, I went out to KWHD's transmitter building on a routine visit and
discovered that the air conditioning unit had failed. Due to the heat in the building the detuning
was altered and the power was reduced. At that point, KWHD was operating at 74% of its
normal power. Air conditioner technicians were able to fix the unit on April 12,2006 and the
normal power was restored at approximately 3 pm that afternoon. On April 16, 2006, I
discovered that the air conditioning unit had developed a second leak and the power was again
reduced. From that point on,the station was operating at 71%.
3) On April 11, 2006, after I determined that KWHD was operating at reduced power, I
received a call from Bob McQuitty of Comcast. He left a message and I returned his call.
During our call, Mr. McQuitty stated that he was testing KWHD's signal for Comcast. He told
me that he had two days to test the signal.
4) He asked me if KWHD was having problems because he noticed a drop in the signal
from early morning until approximately noon. I informed him that KWHD was having problems
and was operating at 74% of its normal power due to the failure of the air conditioner in the
transmitter building. I told him that in approximately another day the signal should be back up
to full power. In speaking with him,I had the impression that he had to finish the tests and could
not wait.
5) On April 12, 2006,I called Bob McQuitty to make sure that Comcast was properly
orienting the antenna toward KWHD's tower since many people assume that the tower is near
Golden, Colorado. I informed him that the tower was actually located half way between Parker
and Elizabeth, Colorado. Mr. McQuitty assured me that he oriented the antenna correctly.
6) After reviewing Comcast's test results filed in response to LeSEA's carnage complaint, I
EXHIBIT
A
observed that the antenna orientation specified on both the Greeley and Ft. Collins tests
conducted by Comcast was inaccurate. Based upon the location of the test sites specified by
Comcast and the location of the KWHD tower at 39°25' 57" N, 104°39' 18" W, the proper
antenna orientation for the Greeley test would have been 167° degrees, and the proper antenna
orientation for the Ft. Collins test would have been 153° degrees.
7) On the afternoon of April 28,2006, I traveled to the address at 3737 W. 10th Street,
Greeley, Colorado, which is listed as the address of Comcast's Greeley headend provided in
Comcast's test results. I took a GPS reading of the coordinates at the site which were: 40°
25.412'N, 104°44.447'. While present, I noted a communications tower located on the property
directly adjacent to the headend building. The tower was substantially higher than the headend
building and had multiple antennas appended to it, many of which appeared to be high gain
television reception antennas or cut-to-channel antennas. I estimate the height of the tower to be
approximately 60 feet with the high gain professional antennas mounted at a height of between
45 and 60 feet. I did not observe the RCA antenna that was used in the Greeley test either on the
tower or on the roof of the headend building. 1 took several pictures of the site, including the
communications tower and the antennas. They are attached to this affidavit as Exhibits 1-6.
6 CCt1 k.A14\6. C
Ron Vincent, Chief Engineer for KWHD(TV)
LeSEA Broadcasting of Denver, Inc. County of Arapahoe,State of Colorado
The foregoing instrument was subscribed and aired
before me this.../day of Ana c�OG
Sworn to and Subscribed before me by >�o n 1l n 0€. Ala
Witness my hand and official seal.
This 1 `day of May,2006 C)O at,B .
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Affidavit of Ron Vincent
May 1, 2006
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Hardy, Carey, Chautin. & Balkin, LE p
A T T O R N E Y S AT LAW
110 veterans Memorial Boulevard,Suite 300
Metairie,Louisiana 70005
Telephone 504.830.4646
Facsimile 504.830.4659
�w✓whardycarey.com
April 26, 2006 Elise M. Stubbe; Esq.
estubbe(dihardvcarev.corn
Direct Dial: 504.830.4641
fi L 2317.107
Via Hand Delivery Y,? ct t a
t:
Ms.Marlene Dortch, Secrreta1 w 0 k e �° " I= v
Federal Conunulucatipf iiEsiou . ?
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445 12th Street, SW # i .gt'- l"..e"cirr e& `^ iir
Washington, DC 205541a �" E F° '
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Re: KWHD(TV) � � " F $
Fat. Id. 37101 �ECEIvED
Castle Rock, CO
FRN: 0011-6662-60 APR 2 6 2006
Notice of Operation at Reduced Power
Fa�AmimmunicatonsCommisslor,
Mice of Secrty
Dear Ms. Dortch:
We are filing this letter on behalf of LeSEA Broadcasting of Denver, Inc., the licensee of
KWHD(TV) and pursuant to Section 73.1560(d)to notify the Commission that KWEID(TV) has
been operating at reduced power since April 16, 2006.1
If you have any questions,please do not hesitate to contact me.
Sincerely,
Elise M. Stubbe
EMS:dbg
cc: Pete Sim-mall (public file)
Tony Hale
Wes Hylton
'The station started operating at reduced power on April 11, 2006, but resumed normal
power operations on April 13, 2006. On April 16, 2006, the station was again forced to begin
operating at reduced power and has been doing so since that date.
EXHIBIT
T:12317.1071 FCC 060425 ems(KWHD low power notice).wpd
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