TECHNICAL EXHIBIT PETITION FOR RULE MAKING TO AMEND THE FM TABLE OF ALLOTMENTS HATTIESBURG, MISSISSIPPI WESTWEGO, LOUISIANA HOUMA, LOUISIANA GONZALES, LOUISIANA Technical Narrative This technical narrative and accompanying Figures have been prepared on behalf of stations WUSW (FM) , Hattiesburg, Mississippi, and KFXN (FM) , Houma, Louisiana, in support of a Petition for Rule Making to amend 47 C.F.R. Section 73.202(b) to reallot channel 279 C at Hattiesburg, Mississippi to channel 279 CO at Westwego, Louisiana; and to reallot channel 281C at Houma, Louisiana to channel 281CO at Gonzales, Louisiana. As the requested changes are mutually exclusive with each channel's current allotment, Petitioner invokes the provisions of Section 1.420(i). The following is a summary of the merits of this reallotment proposal: • The community of Westwego, Louisiana (2000 Census population 10,763 persons) will be provided with its first local aural transmission service . • The community of Hattiesburg, Mississippi (2000 Census population 44,779 persons) will continue to have local aural service from FM radio stations WAIl, WJMG, WUSM and WXRR; and AM stations WBKH, WFOR and WORV. • The community of Gonzales, Louisiana (2000 Census population 8,156 persons) will be provided with its first local aural transmission service. • The community of Houma, Louisiana (2000 Census population 32,393 persons) will continue to have local Hattiesburg, Mississippi and Westwego, Louisiana Page 2 aural service from FM radio station KCIL and AM station KFXY. • The proposed channel 279CO allotment site at Westwego, Louisiana satisfies the Commission's allocations spaclng.ru 1es. 1 • The proposed channel 281CO allotment site at Gonzales, Louisiana satisfies the Commission's allocations spaclng.ru 1es. 2 • The 60 dbu gain area associated with the proposed reallotment of channel 279C to 279CO will encompass 1,514,562 persons, while the 60 dbu loss area will encompass 258,159 persons, for a net gain of 1,087,051 additional persons served within the WUSW 60 dbu 3 service contour • • The channel 279C 60 dbu loss area is well served by a number of radio services'. • The 60 dbu gain area associated with the proposed reallotment of channel 281C to 281CO will encompass 18,665 persons, while the 60 dbu loss area will encompass 655,290 persons, for a net loss of 636,625 persons'; however the aggregate of the two proposals is a total net GAIN of 548,681 persons served within the 60 dbu contours of WUSW and KFXN as a result of this proposal. • The channel 281C 60 dbu loss area is well served by a 6 number of radio services . 1 Proposed allotment coordinates are 29' 54' 52" North, 89' 54' 34" West. See this Exhibit under the heading "Compliance With FCC Rules" for details on allocations considerations with respect to this site. Also see Figure 1 accompanying this Exhibit for the allocations spacing study. 2 Proposed allotment coordinates are 29' 52' 55" North, 90' 56' 07" West. See this Exhibit under the heading "Compliance With FCC Rules" for details on allocations considerations with respect to this site. Also see Figure 2 accompanying this Exhibit for the ailocations spacing study. 3 See Figure 3. 4 See Figures 5 and 6. 5 See Figure 4. 6 See Figures 8 and 9. Hattiesburg, Mississippi and Westwego, Louisiana Page 3 Table of Figures Accompanying this Exhibit Figure 1 WUSW (FM) Channel 279CO Allocations Spacing Study Figure 2 KFXN (FM) Channel 281CO Allocations Spacing Study Figure 3 WUSW (FM) Channel 279C/279CO 60 dbu Gain and Loss Areas Figure 4 KFXN (FM) Channel 281C/281CO 60 dbu Gain and Loss Areas Figure 5 Depiction of Services to WUSW 60 dbu loss area Figure 6 Tabulation of Services to WUSW 60 dbu loss area Figure 7 WUSW 279CO 70 dbu Service to Westwego, LA. Figure 8 Depiction of Services to KFXN 60 dbu loss area Figure 9 Tabulation of Services to KFXN 60 dbu loss area Figure 10 KFXN 281CO 70 dbu Service to Gonzales, LA and outline of Baton Rouge Urbanized Area. Hattiesburg, Mississippi and Westwego, Louisiana Page 4 Proposed Change in the FM Table of Allotments Hattiesburg is located in Forrest County, Mississippi, and has a 2000 U.S. Census population of 44,779 persons. Under this proposal, Hattiesburg will continue to receive local aural radio service from the following stations: FM Radio WAIl WJMG WUSM WXRR AM Radio WBKH WFOR WORV Westwego, Louisiana is located in Jefferson Parrish, Louisiana, and has a 2000 U.S. Census population of 10,763 persons. westwego has no local FM or AM aural broadcast service and, therefore, Petitioner's proposal would bring a first local aural broadcast service to Westwego. Houma is located in Terrebonne Parrish, Louisiana, and has a 2000 U.S. Census population of 32,393 persons. Under this proposal, Houma will continue to receive local aural radio service from the following stations: FM Radio KCIL AM Radio KFXY Gonzales, Louisiana is located in Ascension Parrish, Louisiana, and has a 2000 U.S. Census population of 8,156 persons. Gonzales has no local FM or AM aural broadcast service and, therefore, Petitioner's proposal would bring a first local aural broadcast service to Gonzales. Hattiesburg, Mississippi and Westwego, Louisiana Page 5 Accordingly, Petitioner requests modification of the FM allocation table as follows: City Present Proposed Hattiesburg, MS 221A, 226A, 279C, 221A, 226A, 283C1 283C1 Westwego, LA 279CO Houma, LA 281CO Gonzales, LA 281C, 298C1 298C1 Compliance with FCC Rules The attached Figure 1 is a tabulation of required separations pertinent to use of channel 279CO at westwego, Louisiana. The reference site complies with the Commission's minimum distance separations contained in Section 73.207 of the FCC's rules to all existing, authorized and proposed stations and allotments, except for: a) The existing channel 279C allotment at Hattiesburg, Mississippi, for which this proposal is a mutually exclusive substitute, and b) Channel 281C, Houma, Louisiana, to which this proposal would be short spaced. This spacing deficiency is addressed in this instant application (the reallotment of channel 281 at Houma) . Operation from the channel 279CO reference site will provide the requisite city grade (70 dbu) signal to all of Westwego. 7 Figure 7 is a map which was developed using the 2000 U.S. Census Topologically Integrated Geographic Encoding and Referencing (TIGER) Line files which depicts the city grade coverage (70 dbu) contours based on class CO facilities (ERP 100 kW/HAAT 450 meters) at the proposed allotment site. As shown, all (100%) of Westwego is located well within the 70 dBu City Grade contour. Westwego is located 26 kilometers from the proposed WUSW channel 279CO allotment site. The attached Figure 2 is a tabulation of required separations pertinent to use of channel 281CO at Gonzales, 7 See Figure 7 herein. Hattiesburg, Mississippi and Westwego, Louisiana Page 6 Louisiana. The reference site complies with the Commission's minimum distance separations contained in Section 73.207 of the FCC's rules to all existing, authorized and proposed stations and allotments, except for the existing channel 281C allotment at Houma, Louisiana, for which this proposal is a mutually exclusive substitute. Operation from the channel 281CO reference site will provide the requisite city grade (70 dbu) signal to all of Gonzales. s Figure 10 is a map which was developed using the 2000 U.S. Census Topologically Integrated Geographic Encoding and Referencing (TIGER) Line files which depicts the city grade coverage (70 dbu) contours based on class CO facilities (ERP 100 kW/HAAT 450 meters) at the proposed allotment site. As shown, all (100%) of Gonzales is located well within the 70 dBu City Grade contour. Gonzales is located 39.8 kilometers from the proposed KFXN channel 281CO allotment site. Urbanized Area Considerations The WUSW (FM) 279C 70 dbu contour currently encompasses none of the New Orleans Urbanized Area. Under this proposal, the WUSW (FM) 70 dbu contour will encompass 9 100% of that Urbanized Area . The KFXN (FM) 281C 70 dbu contour currently encompasses 91% of the New Orleans Urbanized Area. The 70 dbu contour of the proposed 281CO facility will encompass 2% of the Baton Rouge Urbanized Area and none of the New Orleans Urbanized Area. 60 dbu Gain and Loss Areas There are currently 427,511 persons residing within the WUSW (FM) channel 279C 60 dbu contour. There will be 1,514,562 persons residing within the proposed WUSW 279CO 60 dbu contour. All 427,511 persons residing within the current WUSW 60 dbu contour will lose that service. 1,514,562 persons will gain service within the proposed 8 See Figure 10 herein. 9 See Figure 7. Hattiesburg, Mississippi and Westwego, Louisiana Page 7 WUSW 60 dbu contour as a result of the proposed 279CO operation at Westwego. See Figure 3. The 60 dbu loss area related to the reallotment of channel 279C is well served by many aural services. See Figures 5 and 6. There are currently 2,225,921 persons residing within the KFXN (FM) channel 281C 60 dbu contour. There will be 1,589,296 persons residing within the proposed KFXN 281CO 60 dbu contour. 655,290 persons residing within the current KFXN 60 dbu contour will lose that service. 18,665 persons not currently within the KFXN 60 dbu contour will gain this new service. This will result in a net loss of KFXN 60 dbu service to 636,625 persons. See Figure 4. The two proposals presented herein will result in an aggregate gain in 60 dbu service to 548,681 persons. The 60 dbu loss area related to the reallotment of channel 281C is well served by many aural services. See Figures 8 and 9.