Technical Summary

WPXK-TV Jellico, Channel 18 1000 kW 512.5 (HAAT)

ION Media Knoxville License, Inc. (“ION”) licensee of WPXK-TV, Facility ID 52628, Jellico, Tennessee (the “Station”) submits this Construction Permit Modification application to allow it to relocate its transmitter from the currently authorized site (FCC LMS File No. 0000026977) to a site that will accommodate post-repack operations.

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 WPXK-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 a comprehensive analysis of available tower sites in the Jellico and nearby Knoxville markets. Fortunately, ION was able to identify an acceptable tower site in the immediate vicinity of the current authorized site.

The new tower is located less than half a kilometer from the current site. Notwithstanding the close proximity of the transmitter sites, the Station’s proposed noise limited service contour (“NLSC”) results 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 WPXK-TV loss area would be 105,686 persons over an area of 4,312.8 sq. km. WPXK-TV also would have a gain area of 344 persons and 9.75 sq. km. Thus, under the Commission’s traditional counter prediction methodology, WPXK-TV would have a net loss area of 105,342 persons and 4,303.05 sq. km. WPXK-TV currently provides an over-the-air signal to 1,907,744 persons in its service area, so the predicted service loss using 50/90 curves would represent approximately 5.52% of WPXK-TV’s service population.

Figure 1 also demonstrates that the Commission’s 50/90 curves predict that the vast 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 3 and 4 stations, as shown in Figure 1. The move would not any television coverage “white area,” as there are at least 3 other over-the-air television signals throughout the WPXK-TV loss area. Where there are less than 5 services available, the loss of over-the-air service amounts to approximately 2,480 persons (.13% of WPXK-TV’s total service population).

ION has reviewed the impact of this application on low power and Class A television stations in the Knoxville 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 WPXK-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 18. 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 September 6, 2019 Phase 5 transition deadline. Second, WPXK-TV’s proposes technical facilities will lead to a service area loss that, standing alone, is only about half a percentage point larger than the 5% service loss the Commission permitted when it approved initial post-repack operations that did not expand service in any direction.1 Third, the requested tower site change is necessary for WPXK-TV to continue serving the vast majority of its viewers in the Knoxville market. Fourth, as a practical matter, very few viewers are likely to lose access to the programming available on WPXK-TV. ION network programming will remain available on area cable and satellite providers throughout the loss area, and approximately 85% of the viewers in the loss area subscribe to one of such services.

For the foregoing reasons, WPXK-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 18 operations before the close of Phase 5 will be jeopardized.

1 See Incentive Auction Task Force and Media Bureau Announce Procedures for the Post-Incentive Auction Broadcast Transition, Public Notice, 32 FCC Rcd 858 (2017); 47 CFR § 73.3700(b)(1)(v)(A)-(C). Expanding the Economic and Innovation Opportunities of Spectrum Through Incentive Auctions, Report and Order, 29 FCC Rcd 6567, 6792 para. 551 (2014), aff'd, Nat’l Assoc. of Broadcasters, et al v. FCC, 789 F.3d 165 (D.C. Cir. 2015). Although the requested tower change would increase WPXK-TV’s service contour in one direction, its impact would so slight as to be statistically insignificant (less than .02%). Figure 1

Tabulation of other NLSC Services Considered

Call Sign Channel Community of License State WAAY-TV 32 Huntsville AL WAFF-D 48 Huntsville AL WAGA-TV 27 Atlanta GA WATC-DT 41 Atlanta GA WATE-TV 26 Knoxville TN WATL-D 25 Atlanta GA WBIR-TV 10 Knoxville TN WBKO-D 13 Bowling Green KY WBNA-D 8 Louisville KY WBTV-D 23 Charlotte NC WBXX-TV 20 Crossville TN WCNC-TV 22 Charlotte NC WCTE-D 22 Cookeville TN WCYB-TV 5 Bristol VA WDEF-TV 12 Chattanooga TN WDKY-TV 31 Danville KY WDSI-TV 14 Chattanooga TN WELF-TV 16 Dalton GA WEMT-D 38 Greeneville TN WETP-TV 41 Sneedville TN WFLI-TV 42 Cleveland TN WGCL-TV 19 Atlanta GA WGGS-TV 16 Greenville SC WGTA-D 24 Toccoa GA WGTV-D 8 Athens GA WHIQ-D 24 Huntsville AL WHNS-D 21 Greenville SC WHNT-TV 19 Huntsville AL WHSG-TV 44 Monroe GA WHTN-D 38 Murfreesboro TN WJFB-D 44 Lebanon TN WJHL-TV 11 Johnson City TN WJZY-D 47 Belmont NC WKAS-D 26 Ashland KY WKGB-TV 48 Bowling Green KY WKHA-D 16 Hazard KY WKLE-D 42 Lexington KY WKMR-D 15 Morehead KY WKNX-TV 7 Knoxville TN WKON-D 44 Owenton KY WKOP-TV 17 Knoxville TN WKPI-TV 24 Pikeville KY WKPT-TV 27 Kingsport TN WKRN-TV 27 Nashville TN

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 WLOS-D 13 Asheville NC WMYA-TV 14 Anderson SC WNAB-D 23 Nashville TN WNEH-D 18 Greenwood SC WNGH-TV 33 Chatsworth GA WNKY-D 16 Bowling Green KY WNPT-D 8 Nashville TN WNPX-TV 36 Cookeville TN WNSC-TV 15 Rock Hill SC WNTV-D 9 Greenville SC WPBA-D 21 Atlanta GA WPCH-TV 20 Atlanta GA WPGD-TV 33 Hendersonville TN WPXA-TV 31 Rome GA WRCB-D 13 Chattanooga TN WSB-TV 39 Atlanta GA WSMV-TV 10 Nashville TN WSPA-TV 7 Spartanburg SC WTCI-D 29 Chattanooga TN WTNZ-D 34 Knoxville TN WTVC-D 9 Chattanooga TN WTVF-D 25 Nashville TN WTVQ-DT 40 Lexington KY WUNE-TV 17 Linville NC WUNW-D 27 Canton NC WUPA-D 43 Atlanta GA WUPX-TV 21 Richmond KY WUVG-DT 48 Athens GA WUXP-TV 21 Nashville TN WVLR-D 48 Tazewell TN WVLT-TV 30 Knoxville TN WVVA-D 46 Bluefield WV WXIA-TV 10 Atlanta GA WYFF-D 36 Greenville SC WYMT-TV 12 Hazard KY WZDX-D 41 Huntsville AL WZTV-D 15 Nashville TN

*Licensed Authorization