DRT) Station Prepared For

TECHNICAL EXHIBIT Displacement Application for Modification of Digital Television Replacement Translator (DRT) Station prepared for Rocky Mountain Public Media, Inc. DRT for KRMA-TV, Fort Collins, Colorado Facility ID 14040 Rocky Mountain Public Media, Inc (formerly Rocky Mountain Public Broadcasting, Inc) is the licensee of a digital television replacement translator (DRT) station for KRMA-TV on Channel 47, Fort Collins, Colorado, File BLEDT-20090824ACJ (covering the permit in File BDRTET-20090107AIL), Facility ID 14040. The DRT (D47) is being displaced and is hereby applying during the Special Displacement Window for a new DRT channel (D19). As proposed herein the DRT will operate at its existing antenna location, but on Channel 19. The current antenna is a Scala CL-1469 UHF directional antenna that does not need to be replaced to operate on the new channel. Contour Overlap The antenna location, pattern and orientation on the new channel will remain unchanged, thereby insuring that there will be contour overlap with the displaced facility. Interference Analysis, International Coordination, etc. The results of evaluating the proposed facility for interference using the FCC TV Study program indicate that the station will cause 5.75% interference to station KTVD, channel D19, File BLCDT20090218ABY. However this station will be moving to channel D31 as part of the current TV band repack. KRMA-TV therefore proposes to move to channel D19 only after KTVD completes its transition to its post-repack channel. The station will cause no other interference. KRMA-TV seeks a contingent waiver elsewhere in this application. The results of TV Study also indicate that the DRT on channel 19 will receive 16.99% interference. KRMA-TV hereby states that it wishes to accept this interference for the following reasons. The Fort Collins DRT for KRMA-TV has been providing service to an area that stretches from Fort Collins, CO through Windsor, CO to Greeley, CO that receives inadequate service from the primary station KRMA-TV, Denver on Channel 18 (moving to 33 during repack) because of partial terrain shielding. The attached coverage and interference map for the KRMA-TV DRT on CH 19 (Figure 1) shows that this area will be interference free. In areas where the KRMA-TV DRT on CH 19 will suffer interference, the main KRMA-TV signal coverage on channel 33 will be more than adequate. RMPM selected channel 19 for the displaced Channel 47 DRT only after studying all other UHF channels. Channel 19 is the only identified translator channel that does not cause outgoing interference. The TV Study results indicate that the station complies with the FCC’s requirements for international coordination, FCC monitoring station protection, and AM transmitter protection. At 47 km distance the proposed facility is well outside the range for coordination with the NTIA regarding the Table Mountain Quiet Zone (16 km for power levels between 1 and 25 kW). The TV Study results are attached to this exhibit. Environmental Considerations The proposed facility was evaluated for human exposure to RF energy using the procedures described in FCC OET Bulletin Number 65. Based on OET-65 equations and using .05 as the relative field strength in a downward direction1, the calculated signal density near the tower at two meters above ground level attributable to the proposed facility is 1.24 uW/cm2, which is 0.37% of the general population/uncontrolled maximum permitted exposure limit. Thus, the public will not be exposed to RF levels attributable to the proposed facility in excess of the FCC’s guidelines. The applicant will reduce power or cease operation to protect workers having access to the tower. There will be no change in overall structure height. Thus the proposed facility is categorically excluded from environmental processing. Exhibit prepared by: J.B. Schoedler Associates, LLC Denver, Colorado 303-725-9043 [email protected] 1 The elevation pattern for a Scala CL-1469 antenna shows <=.05 relative field value from 30 to 90 degrees below horizontal. Figure 1: Coverage and Interference Map for KRMA TV CH 19 Study created: 2018.04.27 11:22:38 Study build station data: LMS TV 2018-04-19 Proposal: KRMA-TV D19 (D47) LD LIC DENVER, CO File number: BLEDT20090824ACJ Facility ID: 14040 Station data: LMS TV 2018-04-19 Record ID: f2bbeb37d173422f9c57cf6212b6c0ea Country: U.S. Build options: Protect pre-transition records not on baseline channel Stations potentially affected by proposal: IX Call Chan Svc Status City, State File Number Distance Yes KPXC-TV D18 DT CP DENVER, CO BLANK0000027023 56.0 km Yes KRMA-TV D18 DT LIC DENVER, CO BLEDT20100312ABH 97.3 No K18FN-D D18 LD LIC PEETZ, CO BLDTT20110928AKM 170.2 No K19FH-D D19 LD LIC ASPEN, CO BLDTT20121119AGZ 202.6 No K19DY D19 LD CP CANON CITY, CO BDFCDTT20100111AEX 236.1 No K19DY N19 TX LIC CANON CITY, CO BLTT20001027AAF 236.1 Yes KSBS-CD D19 DC CP DENVER, CO BLANK0000034533 90.9 Yes KTVD D19 DT LIC DENVER, CO BLCDT20090218ABY 90.7 No K19KN-D D19 LD LIC EADS, ETC., CO BLANK0000001775 306.6 No K19EG-D D19 LD LIC HOLYOKE, CO BLDTT20110613AAO 239.9 No K45KB-D D19 LD APP LAKE GEORGE, CO BLANK0000052545 173.7 No K19CE N19z TX LIC MONTROSE, CO BLTT20040602ABQ 322.6 No K19HG-D D19 LD LIC REDSTONE, CO BLDTT20091221ABC 225.3 No K39ED-D D19 LD APP ROCKY FORD, CO BLANK0000052167 303.7 No KWKS D19 DT LIC COLBY, KS BLEDT20070601ATA 357.9 No K19DV N19 TX LIC MANILA-DUTCH JOHN, UT BLTT19940907IB 358.1 No K19FX-D D19 LD LIC LARAMIE, WY BLDTT20111129FFV 84.7 No K19JG-D D19 LD CP MIDWEST, WY BNPDTL20100510ACO 347.3 No K19JH-D D19 LD CP WHEATLAND, WY BNPDTL20100510AEL 200.5 No KRMT D20 DT CP DENVER, CO BLANK0000034798 105.2 Yes K20KE-D D20 LD LIC FORT MORGAN, CO BLDTL20150115AAB 91.3 No K20FS-D D20 LD LIC PEETZ, CO BLDTT20110114AAR 170.2 No KFNB D20 DT LIC CASPER, WY BLCDT20090225AAN 262.3 No K27CB N27+ TX LIC FRASER, ETC., CO BLTT19890609IM 90.3 No non-directional AM stations found within 0.8 km No directional AM stations found within 3.2 km Record parameters as studied: Channel: D19 Mask: Stringent Latitude: 40 32 46.90 N (NAD83) Longitude: 105 11 54.90 W Height AMSL: 2201.0 m HAAT: 0.0 m Peak ERP: 5.62 kW Antenna: (replication) 0.0 deg Elev Pattrn: Generic 49.3 dBu contour: Azimuth ERP HAAT Distance 0.0 deg 0.000 kW 488.8 m 10.5 km 45.0 0.000 633.6 11.6 90.0 4.34 653.9 63.2 135.0 2.17 596.6 57.5 180.0 0.000 561.8 11.2 225.0 0.000 199.8 7.3 270.0 0.000 13.1 2.9 315.0 0.000 101.3 5.3 Database HAAT does not agree with computed HAAT Database HAAT: 0 m Computed HAAT: 406 m Distance to Canadian border: 939.5 km Distance to Mexican border: 981.2 km Conditions at FCC monitoring station: Grand Island NE Bearing: 83.6 degrees Distance: 571.6 km Proposal is not within the West Virginia quiet zone area Conditions at Table Mountain receiving zone: Bearing: 182.7 degrees Distance: 47.7 km ERP: 0.000562 kW Field strength: 31.8 dBu, 0.0 mV/m No land mobile station failures found Study cell size: 1.00 km Profile point spacing: 1.00 km Maximum new IX to full-service and Class A: 0.50% Maximum new IX to LPTV: 2.00% **IX check failure to BLCDT20090218ABY LIC scenario 1, 5.75% interference caused ---- Below is IX received by proposal BLEDT20090824ACJ ---- Proposal receives 16.99% interference from scenario 1.

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