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Technical Summary WUPX-TV Richmond, Kentucky Channel 25

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Technical Summary WUPX-TV Richmond, Kentucky Channel 25 Technical Summary WUPX-TV Richmond, Kentucky Channel 25 465 kW 354.11 (HAAT) ION Media Lexington License, Inc. (“ION”) licensee of television station WUPX-TV, Facility ID 23128, Richmond, Kentucky (the “Station”) hereby amends its pending construction permit application seeking authority to relocate its transmitter from the currently authorized site to a site that will accommodate post-repack operations (FCC LMS File No. 0000064267). This application is necessary because ION does not have access to its current tower for post-repack operations. Following the Commission’s assignment of post-repack facilities to WUPX-TV, ION was unable to reach accommodation with the tower landlord that would permit the station to continue operating from its current site. This forced ION to identify a new site for the station’s post-repack operations. Before selecting the proposed tower location, ION performed an analysis of available tower sites in the Lexington market. In the immediate vicinity of the current tower site, ION’s market analysis found no alternatives that would provide equivalent interference-free coverage as compared to the Station’s pre-auction or authorized post-auction facilities. A number of sites were rejected due to interference issues. ION has, however, acquired an acceptable tower site to the southeast of the city of Lexington which would allow ION to achieve acceptable coverage with minimal or no interference to other broadcast stations. The new tower is located 93.3 kilometers to the southwest of the current site. Accordingly, the Station’s proposed noise limited service contour (“NLSC”) will shift to the southwest, resulting in some areas of service gain and loss. Figure 1 shows the loss area and the stations predicted to serve the loss areas using the Commission’s standard prediction methodology. Under this analysis, the total size of the WUPX-TV loss area would be 383,833 persons over an area of 19,512.2 sq. km. WUPX-TV also would have a gain area of 330,444 persons and 10,679.9 sq. km. Thus, under the Commission’s traditional counter prediction methodology, WUPX-TV would have a net loss area of 54,819 persons and 8,832.3 sq. km. WUPX-TV currently provides an over-the-air signal to 1,156,822 persons in its service area, so the predicted service loss using 50/90 curves would represent approximately 4.7% of WUPX- TV’s service population. Figure 1 also demonstrates that the Commission’s 50/90 curves predict that the majority of the loss area would remain well served by 5 or more over-the-air full-power television stations with some areas served by between 1 and 4 stations, as shown in Figure 1. However, the move would not create any television coverage “white area,” as there is at least one other over-the-air television signal throughout the WUPX-TV loss area. Where there are less than 3 services available, the loss of over-the-air service amounts to approximately 2,938 persons (.25% of WUPX-TV’s total service population). ION also analyzed the authorized post-repack NLSC construction permit authorizations of nearby full power television stations which overlap that of the proposed WUPX-TV facilities. As depicted by Figure 2, this analysis indicates that, once the permitted stations are operating, the WUPX-TV loss area would continue to have areas served by between 1 and 4 stations. It would also continue to be the case that, after the permitted stations are operational, no television coverage “white area” would exist in the WUPX-TV loss area. However, where there are less than 3 services, the loss of over-the-air service in the WUPX-TV loss area would be reduced to 1,440 persons (.12% of WUPX-TV’s total service population) after the permitted stations become operational. Importantly, the Commission’s 50/90 curves also predict that, within the gain area, following construction of all repack facilities in this market, 13,827 persons would receive only 1 or 2 services. See Figure 3. If this application is approved, WUPX-TV would add an additional service for persons in these areas. Figure 4 indicates the number of services that would be available in the gain area following WUPX-TV’s move to the proposed site. ION has reviewed the impact of this application on low power and Class A television stations in the Lexington DMA. The application does not create harmful interference to any low- power television station that participated in the post-auction displacement window that occurred in 2018. ION’s proposed relocation of WUPX-TV is in the public interest and should be granted. First, ION’s pre-repack tower site is unavailable for post-repack operations, and the current proposal is ION’s best solution to implementing its reassignment to Channel 25. Given the loss of its current tower site, grant of authority to construct at the proposed location is necessary to ensure that ION can timely complete construction of the station’s facilities by the June 21, 2019 Phase 3 transition deadline. Second, WUPX-TV would add a second or third available service to a large number of persons (13,827) in the gain area; far more than would see their available services reduced to 1 or 2 in the loss area (1,440 persons). Third, the requested tower site change is necessary for WUPX-TV to continue serving the vast majority of its viewers in the Lexington market. Fourth, as a practical matter, very few viewers are likely to lose access to the programming available on WUPX-TV. ION network programming will remain available on area cable and satellite providers throughout the loss area, and approximately 80% of the viewers in the loss area subscribe to one of such services. For the foregoing reasons, WUPX-TV requests that the staff promptly grant this Construction Permit Modification, as herby amended. If the application is not granted, ION’s ability to complete its transition to Channel 25 operations before the close of Phase 3 will be jeopardized. Figure 1 Tabulation of other NLSC Services Available to WUPX-TV Loss Areas Call Sign Channel Community of License ST WATE‐TV 26 Knoxville TN WAVE‐D 47 Louisville KY WBIR‐TV 10 Knoxville TN WBKI‐D 51 Salem IN WBKO‐D 13 Bowling Green KY WBNA‐D 8 Louisville KY WBNS‐TV 21 Columbus OH WBXX‐TV 20 Crossville TN WCET‐D 34 Cincinnati OH WCHS‐TV 29 Charleston WV WCMH‐TV 14 Columbus OH WCPO‐TV 22 Cincinnati OH WCTE‐D 22 Cookeville TN WCVN‐TV 24 Covington KY WCYB‐TV 5 Bristol VA WDKY‐TV 31 Danville KY WDRB‐D 49 Louisville KY WDTN‐D 50 Dayton OH WEMT‐D 38 Greeneville TN WETP‐TV 41 Sneedville TN WHAS‐TV 11 Louisville KY WHIO‐TV 41 Dayton OH WHIZ‐TV 40 Zanesville OH WIPB‐D 23 Muncie IN WIPX‐TV 27 Bloomington IN WJHL‐TV 11 Johnson City TN WKAS‐D 26 Ashland KY WKEF‐D 18 Dayton OH WKGB‐TV 48 Bowling Green KY WKHA‐D 16 Hazard KY WKLE‐D 42 Lexington KY WKMJ‐TV 38 Louisville KY WKMR‐D 15 Morehead KY WKNX‐TV 7 Knoxville TN WKON‐D 44 Owenton KY WKOP‐TV 17 Knoxville TN WKPC‐TV 17 Louisville KY WKPI‐TV 24 Pikeville KY WKPT‐TV 27 Kingsport TN WKRC‐TV 12 Cincinnati OH WKSO‐TV 14 Somerset KY WKYT‐TV 36 Lexington KY WKYU‐TV 18 Bowling Green KY WKZT‐TV 43 Elizabethtown KY WLEX‐TV 39 Lexington KY WLFB‐D 40 Bluefield WV WLJC‐TV 7 Beattyville KY WLKY‐D 26 Louisville KY WLOS‐D 13 Asheville NC WLPX‐TV 39 Charleston WV WLWT‐D 35 Cincinnati OH WNKY‐D 16 Bowling Green KY WOAY‐TV 50 Oak Hill WV WOSU‐TV 38 Columbus OH WOUB‐TV 27 Athens OH WOWK‐TV 13 Huntington WV WPTD‐D 16 Dayton OH WPTO‐D 28 Oxford OH WPXK‐TV 23 Jellico TN WQCW‐D 17 Portsmouth OH WRGT‐TV 30 Dayton OH WSAZ‐TV 23 Huntington WV WSTR‐TV 33 Cincinnati OH WSWP‐TV 10 Grandview WV WSYX‐D 48 Columbus OH WTAP‐TV 49 Parkersburg WV WTIU‐D 14 Bloomington IN WTNZ‐D 34 Knoxville TN WTSF‐D 44 Ashland KY WTTE‐D 36 Columbus OH WTTV‐D 48 Bloomington IN WTVQ‐DT 40 Lexington KY WUNE‐TV 17 Linville NC WUNW‐D 27 Canton NC WVAH‐TV 19 Charleston WV WVLR‐D 48 Tazewell TN WVLT‐TV 30 Knoxville TN WVNS‐TV 8 Lewisburg WV WVPB‐TV 34 Huntington WV WVVA‐D 46 Bluefield WV WWHO‐D 46 Chillicothe OH WXIX‐TV 29 Newport KY WYMT‐TV 12 Hazard KY *Licensed Authorization Figure 2 Tabulation of other NLSC Services Available to WUPX-TV Loss Areas Call Sign Channel Community of License ST WATE-TV 26 Knoxville TN WAVE-D.C 36 Louisville KY WBIR-TV 10 Knoxville TN WBKI-D.C 16 Salem IN WBKO-D 13 Bowling Green KY WBNA-D 8 Louisville KY WBNS-TV 21 Columbus OH WBXX-TV.C 31 Crossville TN WCET-D.C 17 Cincinnati OH WCHS-TV 29 Charleston WV WCMH-TV 14 Columbus OH WCPO-TV.C 26 Cincinnati OH WCTE-D 22 Cookeville TN WCVN-TV.C 22 Covington KY WCYB-TV 5 Bristol VA WDKY-TV.C 19 Danville KY WDRB-D.C 32 Louisville KY WDTN-D.C 31 Dayton OH WEMT-D.C 28 Greeneville TN WETP-TV.C 24 Sneedville TN WHAS-TV 11 Louisville KY WHIO-TV.C 33 Dayton OH WHIZ-TV.C 30 Zanesville OH WIPB-D.C 19 Muncie IN WIPX-TV.C 28 Bloomington IN WJHL-TV.C 9 Johnson City TN WKAS-D.C 36 Ashland KY WKEF-D.C 34 Dayton OH WKGB-TV.C 29 Bowling Green KY WKHA-D.C 33 Hazard KY WKLE-D.C 35 Lexington KY WKMJ-TV.C 34 Louisville KY WKMR-D.C 30 Morehead KY WKNX-TV 7 Knoxville TN WKON-D.C 24 Owenton KY WKOP-TV.C 29 Knoxville TN WKPC-TV.C 30 Louisville KY WKPI-TV.C 23 Pikeville KY WKPT-TV.C 32 Kingsport TN WKRC-TV 12 Cincinnati OH WKSO-TV.C 17 Somerset KY WKYT-TV.C 21 Lexington KY WKYU-TV 18 Bowling Green KY WKZT-TV.C 23 Elizabethtown KY WLEX-TV.C 28 Lexington KY WLFB-D.C 25 Bluefield WV WLJC-TV 7 Beattyville KY WLKY-D.C 14 Louisville KY WLOS-D 13 Asheville NC WLPX-TV.C 18 Charleston WV WLWT-D.C 20 Cincinnati OH WNKY-D.C 24 Bowling Green KY WOAY-TV.C 31 Oak Hill WV WOSU-TV.C 16 Columbus OH WOUB-TV.C 32 Athens OH WOWK-TV.C 10 Huntington WV WPTD-D.C 35 Dayton OH WPTO-D.C 29 Oxford OH WPXK-TV.C 18 Jellico TN WQCW-D.C 15 Portsmouth OH WRGT-TV.C 36 Dayton OH WSAZ-TV.C 22 Huntington WV WSTR-TV.C 18 Cincinnati OH WSWP-TV.C 8 Grandview WV WSYX-D.C 28 Columbus OH WTAP-TV.C 35 Parkersburg WV WTIU-D.C 33 Bloomington IN WTNZ-D.C 15 Knoxville TN WTSF-D.C 13 Ashland KY WTTE-D.C 27 Columbus OH WTTV-D.C 27 Bloomington IN WTVQ-DT.C 27 Lexington KY WUNE-TV.C 36 Linville NC WUNW-D.C 27 Canton NC WVAH-TV.C 24 Charleston WV WVLR-D.C 36 Tazewell TN WVLT-TV.C 34 Knoxville TN WVNS-TV.C 11 Lewisburg WV WVPB-TV.C 9 Huntington WV WVVA-D.C 17 Bluefield WV WWHO-D.C 23 Chillicothe OH WXIX-TV.C 15 Newport KY WYMT-TV 12 Hazard KY *Post Auction Authorization Figure 3 Figure 4 .
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