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December 1, 2010
The Honorable Julius Genachowski
Chairman
Federal Communications Commission
445 12
th
Street, SW
Washington, D.C. 20554
Dear Chairman Genachowski,
In the matter ofthe Federal Communications Commission (FCC) Notice ofProposed
Rulemaking (NPRM) to implement Section 203 and 304 ofthe Satellite Television Extension
and Localism Act of201 (STELA), we write to voice our concern for the households in
Wyoming that do not have access to Wyoming-based television programming. As you consider
a rule to implement STELA, we urge you to consider the needs ofthese "orphan" counties.
The issue oforphan counties - counties that are considered part ofthe local market ofa
neighboring state - is a national issue that affects satellite viewers from New Jersey to Oregon.
However, it has long been widely acknowledged that Wyoming is the poster childJor everything
that is wrong with the current system ofDesignated Local Market Areas (DMA). There are
seven DMAs within Wyoming's boundaries, five ofwhich do not originate within the state.
Owing to the so-called localism rules, 16 ofWyoming's 23 counties are orphaned. Put another
way, nearly 55% ofall Wyoming television households cannot receive Wyoming-based news,
weather, sports, or emergency alerts from their satellite subscription.
The sheer size and remote nature ofWyoming lend itselftoward satellite television service, but
the lack ofany truly local access is cause for great frustration in our state. For example,
residents ofone northern Wyoming county is still considered part ofDenver, Colorado's local
market area - an absurdity when you consider that Denver is nearly 400 miles away, and the in 
state market area originates from the next county.
We recognize that wholesale reform ofthe DMA system was regrettably not contemplated
during consideration ofSTELA. However, we do not believe that precludes the FCC from
taking a targeted approach to solving what is a very real issue for Wyoming. We urge you to
carefully consider taking appropriate steps to ensure that residents in orphan counties have the
option ofviewing in-state programming. Thank you for your attention to this important matter.
Sincerely,
1862