Federal Communications Commission 
Washington, D.C. 20554
DA 07-4980
Released: December 14, 2007
Sunflower Broadcasting, Inc.
c/o Jack N. Goodman, Esq.
Wilmer Cutler Pickering Hale and Dorr LLP
1875 Pennsylvania Avenue, N.W.
Washington, DC  20006
Re:     Petition for Waiver of Main Studio Rule  
KBSL-TV, Goodland, Kansas
Fac. ID 66416
Dear Mr. Goodman:
This is in reference to the Petition for Waiver of Main Studio Rule filed by Sunflower 
Broadcasting, Inc. (“Sunflower”) on June 15, 2007.  The petition is unopposed.  The petition 
requests a waiver of the main studio rule, Section 73.1125 of the Commission’s Rules,1 with 
respect to KBSL-TV, Goodland, Kansas.  We will grant the request for a main studio waiver, but 
only on a temporary basis.
Section 73.1125(a) requires that each broadcast station operate a main studio within either the 
principal community contour of any station, of any service, licensed to its community of license 
or within 25 miles of the reference coordinates of the center of its community of license, 
whichever it chooses.2 KBSL was previously authorized to operate as a satellite of KWCH-TV, 
Hutchinson, Kansas.   KBSL's Grade B contour does not overlap that of KCWH and, therefore, 
Commission rules no longer require approval for KBSL to operate as a satellite.  However,
because KBSL will not maintain its own studio, Sunflower requests a waiver of Section 73.1125, 
the Commission’s main studio rule.3
  
1 47 C.F.R. §73.1125.
2  See Review of the Commission's Rules Regarding the Main Studio and Local Public Inspection Files of Broadcast 
Television and Radio Stations, 13 FCC Rcd 15691 (1998).   
3 47 C.F.R. §73.1125.
Sunflower reports that KBSL has had a studio in space that it rented from a Goodland radio 
station.  However, that station is in bankruptcy and has been sold.  Thus, the continuing 
availability of the space is in question.  Sunflower has searched for suitable alternative locations 
to no avail.  Moreover, Sunflower indicates that it has ceased operations at the Goodland studio 
as a result of the resignation of the two persons who operated KBSL.
Moreover, according to Sunflower, economic challenges have rendered the maintenance of a 
main studio for KBSL infeasible.  There are no other commercial television stations licensed to 
Goodland, which had a population in 2006 of 5,981.  The median household income in 2004 for 
the county was $30,402, only 72.9 percent of the statewide average for Kansas.  According to 
Sunflower, from 2000 to 2004, private non-farm employment in the county declined 11.6 
percent.  
Sunflower states that, because of the small population, recruiting and retaining qualified staff has 
been difficult.  Furthermore, there have been declines in over-the-air viewing.  While some local 
cable systems carry the KBSL signal, the two satellite systems carry only the signal from 
KBSL’s parent, KWCH.  Thus, Sunflower maintains, Goodland is not capable of economically 
supporting a full-service station, including a local main studio.
Sunflower states that, as required, it has established a toll-free telephone number for Goodland 
residents to reach KWCH.  Sunflower pledges telephonic access to the public inspection file.  
KBSL also has a website enabling viewers to receive information about KBSL and its 
programming and this website gives users a direct e-mail link to contact KWCH.
We do not believe that Sunflower’s request for a main studio waiver for KBSL is warranted.  We 
are concerned that a distant Hutchinson studio may not be sufficiently accessible to residents of 
Goodland.  Moreover, Sunflower's request does not claim that it has lost its studio space, only 
that continued availability is not certain.  Indeed, Sunflower has apparently voluntarily closed the 
studio because of its loss of staff.
At the same time, we recognize that changed circumstances may warrant temporary relief until 
such time as KBSL can obtain operating staff and/or new studio space, if needed.  Thus, we will 
grant a temporary waiver to permit Sunflower to operate KBSL without a main studio for a 
period not to exceed one year from the date of this letter.
ACCORDINGLY, a waiver of Section 73.1125 of the Commission’s Rules with respect to 
KBSL’s main studio, IS GRANTED for a period not to exceed twelve (12) months from the date 
of this letter.
FURTHERMORE, Sunflower’s petition for a waiver of Section 73.1125 of the Commission’s 
Rules with respect to KBSL’s main studio, IS GRANTED to the extent indicated, and otherwise 
DENIED.
Sincerely, 
Barbara A. Kreisman
Chief, Video Division
Media Bureau