Via GCKey June 26th, 2013 Mr. John Traversys Secretary General Canadian Radio-television and Telecommunications Commission Ottawa, Ontario K1A 0N2 Dear Mr. Traversys : Re: Part I application for a technical amendment to the broadcasting licence of CFHK-FM St. Thomas The present constitutes an application by Corus Radio Company, a wholly owned subsidiary of Corus Entertainment Inc. (Corus), to change the authorized contours of CFHK-FM Collingn wood by: (i) relocatingn the transmitter site; (ii) increasing the average effective radiated power (ERP) from 16,700 watts to 22,000 watts; and (iii) inncreasing the effective height of the antenna above average terrain (EHAAT) from 150 metres to 179.6 metres. Corus is filing the following documents with this covering letter: • Application form (on-line Form 303); • Appendix 1 – Supplementary brief • Appendix 2 – Engineering brief • Appendix A – Proof of filing with Industry Canada • Appendix B – Coveraga e maps • Appendix C – Availability of the transmitter site • Appendix D – Documentation supporting technical issues Corus trusts that the application is in proper forrm; however, should you have anny questions please contact the undersigned. 2 Thank you for yoour attention to this matter. Sincerely, Sylvie Courtemanche Vice President, Government Relations Corus Entertainment Inc. ***End of document*** Appendix 1 – Supplementary Brief Technical Amendment – CFHK-FM St. Thomas Overview of application 1. This is an application by Corus Radio Company, a wholly owned subsidiary of Corus Entertainment Inc. (Corus), to amend the licence of CFHK-FM St. Thomas, Ontario. Corus proposes to change the authorized contours of CFHK-FM by: (i) relocating the transmitter site; (ii) increasing the average effective radiated power (ERP) from 16,700 watts to 22,000 watts; and (iii) increasing the effective height of the antenna above average terrain (EHAAT) from 150 metres to 179.6 metres. 2. The purpose of this technical amendment is to overcome fourth adjacent channel interference to CFHK-FM’s signal caused by CHST-FM London, which is operated by Rogers Broadcasting Limited (RBL). CHST-FM transmits on the frequency 102.3 MHz which is the fourth adjacent channel to CFHK-FM on 103.1 MHz. 3. Corus proposes to relocate CFHK-FM’s transmitter to CHST-FM’s transmitter site, consistent with Industry Canada guidelines for addressing such issues. Co-location with CHST-FM will allow us to better equalize the signal strength of the two stations, thereby eliminating fourth adjacent channel interference. 4. This application is intended solely to correct CFHK-FM’s technical reception problems. It will not impact any other station in the market. Current reception issues 5. CFHK-FM operates on 101.3 MHz with an average ERP of 16,700 watts. From its current transmitter location approximately 10 miles north-east of St. Thomas, it serves the communities of St. Thomas and London and the surrounding primarily rural areas. Based on Statistics Canada 2011 census data, CFHK-FM’s 3 mV/m contour encompasses a population of just over 450,000 persons. 6. The RBL-owned station CHST-FM London broadcasts from a transmitter location in London, at a site owned by Bell Media Inc., on 102.3 MHz. CHST-FM’s FM channel is therefore fourth adjacent to that of CFHK-FM. 7. In Broadcasting Decision CRTC 2012-490 the Commission approved an application by RBL to increase the average ERP of CHST-FM from 5,840 watts to 20,400 watts, and the maximum ERP from 12,100 watts to 100,000 watts. 8. The purpose of the power increase was to improve CHST-FM’s reception within its authorized contours; however, it also had the effect of significantly increasing the strength of the CHST-FM signal relative to that of the Corus-owned station CFHK-FM. 9. Because of the fourth adjacent channel frequency relationship, the result was to create technical interference to the reception of CFHK-FM, particularly in the vicinity of 2 the CHST-FM transmitter site where the signal strength disparity between the two stations is most pronounced. Corus became aware of this particular interference issue shortly following the implementation of the power increase of CHST-FM to its maximum ERP of 100 kW. 10. Earlier this year Corus conducted an on-line survey in which listeners were invited to respond to six questions concerning the technical quality of their reception of CFHK-FM. The survey garnered responses from 604 listeners and, of this number, 190 (31.5%) reported reception/interference problems, the majority of them clustered in areas close to the CHST-FM transmitter site in London. This is the usual result of fourth adjacent channel interference, which typically occurs close to the transmitter site of the interfering station where its signal strength is significantly higher than that of the station receiving the interference. 11. Appendix D includes a map of the London/St. Thomas area with the locations of listener reports of signal reception issues linked to Forward Sortation Area (FSA) postal codes. This graphical representation clearly demonstrates the high incidence of reception problems in the vicinity of the CHST-FM transmitter site in London, in the N6A FSA postal code. 12. London is an important part of CFHK-FM’s market area and as such, it is important that we maintain a signal of as high a technical quality as possible in the area. The presence of fourth adjacent interference from CHST-FM significantly limits our ability to properly serve our listeners in the London area. A relocation of the transmitter site to CHST-FM’s site is the optimum solution 13. Corus retained engineering consultants D.E.M. Allen & Associates Ltd. (DEMA) to investigate the fourth adjacent channel interference problems being experienced by CFHK-FM and to recommend a solution to these problems. The DEMA report is also included in Appendix D. 14. As detailed in the report, DEMA estimated the signal levels of CFHK-FM and CHST-FM at six specific locations where listeners had complained of fourth adjacent channel interference. DEMA concluded that the differences in signals levels between the two stations at those locations are sufficient to cause fourth adjacent channel interference on many receivers. 15. In such cases, Industry Canada’s rules strongly recommend that fourth adjacent channel stations be co-located if possible to avoid such interference. DEMA agrees that this is the appropriate solution to resolve the interference problem. At the proposed technical parameters, DEMA states that “[c]o-siting CFHK-FM at the CHST-FM site will equalize the field strengths of CHST-FM and CFHK-FM in the problem areas and will substantially diminish, if not eliminate any instances of fourth adjacent interference.” 16. The CHST-FM site is owned by Bell Media Inc. It is located just south of London, approximately 15 km north-west of CFHK-FM’s existing site. Corus has secured an 3 agreement with Bell Media Inc. to lease space on their tower to mount the new antenna for CFHK-FM. A copy of this agreement has been provided as Appendix C to this application. 17. The location of available space on the Bell Media Inc. tower has determined the new EHAAT of 179.6 m, a slight increase from the 150 m EHAAT at CFHK-FM’s existing location. DEMA has selected an antenna design and ERP that will roughly equalize signal strengths between CHST-FM and CFHK-FM, maintain an excellent signal in St. Thomas, and closely duplicate the population covered by the proposed 3 mV/m contour as compared to the existing 3 mV/m contour. 18. Based on Statistics Canada 2011 census data, CFHK-FM’s proposed 3 mV/m contour will encompasses a population of 455,096 persons, an increase of less than 1% from the number of persons covered by the existing 3 mV/m contour. 19. With regard to the impact on CFHK-FM’s signal quality in St. Thomas, the DEMA report notes that the new transmitter site maintains a clear path into St. Thomas. The proposed 3 mV/m contour continues to fully enclose St. Thomas, meeting the requirements of Industry Canada respecting the provision of satisfactory service to principal target centres. In addition, DEMA calculated field strengths at several locations in St. Thomas using Predict software, and confirmed that the estimated field strengths at those locations would be well above the desired 3 mV/m for a principal target centre. 20. Co-siting with CHST-FM is the optimum technical solution and is consistent with the strong recommendations of Industry Canada respecting the solution to instances of fourth adjacent channel interference. Moreover, space is available on the tower used by CHST-FM and Corus has been successful in securing an agreement with the owner of the tower to lease space for CFHK-FM’s antenna. 21. In these circumstances, Corus has not pursued alternate solutions in addressing the current reception difficulties. Given the specific technical issue to be addressed, Corus submits that there is no other technical solution that can effectively address fourth adjacent channel interference problems. The proposed amendment will have no impact on other stations in the market 22. As noted above, CFHK-FM serves the communities of St. Thomas and London. The other English-language commercial radio broadcasters serving these markets are as follows: • Astral Media Radio G.P. – CJBK, CKSL-FM, CJBX-FM and CIQM-FM London • Blackburn Radio Inc. – CKLO-FM London • My Broadcasting Corporation – CKZM-FM St. Thomas • Rogers Broadcasting Limited – CHST-FM London 23. The proposed technical amendment is based solely in the need to correct fourth adjacent channel interference problems. Other than a relocation of the transmitter site 4 approximately 15 km to the north-west, CFHK-FM’s proposed technical parameters are very comparable to its current parameters and the total population enclosed within the 3 mV/m contour will change by less than 1%.