Alejandro Luciano PE Consulting Engineer

Engineering Statement Application for Construction Permit Minor Change Caguas Educational TV. W251DA CH. 251D 98.1 Mhz Vega Baja,

I. Introduction

This engineering exhibit is prepared in support of a minor modification to the authorized construction permit of FM Fill-in translator W251DA Vega Baja, Puerto Rico. It is proposed to modify the present construction permit to, relocate the W251DA antenna, change antenna location above ground, and antenna pattern. The proposed W251DA facility is compliant with all interference protection requirements except to WNVM-FM Ch. 249A, it will be shown that the interference produced by the proposed operation of W251DA fall in a small uninhabited area close to the proposed antenna location.

II. Protection to FCC Monitoring Station and Arecibo Observatory

The proposed W251DA facility is located 35.11 Km from the FCC monitoring station at Santa Isabel, Puerto Rico, because of the low ERP of the proposed W251DA facility towards the monitoring station and the intervening terrain, no adverse effect to the monitoring station is expected. Pursuant to Section 73.1030 of the FCC Rules, concurrently with the filling of this application the Arecibo Observatory is being notified of the proposed facility.

III. Environmental Considerations.

The proposed W251DA antenna will operate at a radiation center of 22.86 meters above ground, at an ERP of 0.25kW. The proposed modification was evaluated for potential radiofrequency exposure to workers and the general public. Based on a radiation center at 22.86 meters above ground, a relative antenna field factor of 0.618 at 45 degrees depression from horizontal and a total ERP of 0.25kW, the calculated RF exposure at two meters above ground will not exceed 3.123μw/cm² or 1.56% of the 200 µw/cm² general population uncontrolled limit applicable to the FM band. The transmitter site is restricted from access. The tower is not located in a flood plain, a wilderness area, or in a wildlife preserve that might affect threatened and endangered species or their habitat, it is not located in an Indian religious and/or cultural site. No significant changes in surface features will take place.

IV. Exhibits Discussion

Exhibit 1: Exhibit 1, shows the allocation compliance consideration for the proposed W251DA transmitters site, it shows that the proposed antenna location is within the 25-mile radius permitted by the rules.

Exhibit 2: Exhibit 2, shows minor change compliance, it shows that the present W251DA construction permit 60 dBu contour is totally encompassed by the proposed W251DA minor change.

Exhibit 3: Exhibit 3, shows the 1st adjacent allocation compliance for the proposed W251DA operation. It shows that there is no prohibited overlap between the proposed operation and the present authorized and construction permit of 1st adjacent stations protected contours.

Exhibit 4: Exhibit 4, shows the co-channel allocation compliance. It shows no prohibited overlap between the proposed W521DA operation and the WXHD-FM Ch. 251A present and construction permit protected contours.

Exhibit 5: Exhibit 5, shows the 3rd adjacent allocation compliance consideration, it shows no prohibited overlap between the proposed W251DA and 3rd adjacent WIOB-FM Ch. 248B Mayaguez, PR and WUKQ-FM Ch. 254B Mayaguez, PR. protected contours.

Exhibit 6: Exhibit 6, shows the 2nd adjacent allocation clearance to W253DB CH. 253D Barranquitas, PR.

Exhibit 7: Exhibit 7, shows the 2nd adjacent allocation clearance to WNVM CH. 249A Cidra, P R. The initial study indicates that interference is created to 2nd adjacent WNVM, as per 74.1204(d) it will be shown that no interference will occur due to lack of population. WNVM-FM places 75.3 dBu at the proposed W251DA site, adding 40 dBu to the U/D ratio produces an interference contour of 115.3 dBu. The Exhibit shows January 2020 dated “Google Earth” satellite picture with the superimposed W251DA 115.3 dBu proposed contour, it was determined that the 115.3 dBu interfering contour touches the ground along the antenna main beam at a distance of 74 to 165 meters from the tower base. The satellite picture shows that the interference area is uninhabited. A recent visit to the site shows that the area remains uninhabited. There are two uninhabited shelters nearby, that are used as hen shelters.

Exhibit 8: Exhibit 8 shows the FM station search used for the proposed W251DA minor change.

Alejandro Luciano PE Consulting Engineer PO Box 194528 San Juan, Puerto Rico 00919-4528 (787)717-6984

25 Miles Radius from Proposed W251DA-D WBYM 60dBu Contour WBYM-AM EXHIBIT 1 AM FILL-IN TRANSLATOR ALLOCATION CONSIDERATION PROPOSED MINOR CHANGE W251DA CH. 251 98.1 MHZ) - 0.250 KW DA VEGA BAJA, PUERTO RICO

Alejandro Luciano PE September 2020 W251DA CP 60 dBu Proposed W251DA-D Contour 60dBu Contour WBYM-AM EXHIBIT 2 MINOR CHANGE ALLOCATION CONSIDERATION PROPOSED MINOR CHANGE W251DA CH. 251 98.1 MHZ) - 0.250 KW DA VEGA BAJA, PUERTO RICO

Alejandro Luciano PE September 2020 Proposed W251DA 50/10 54 dBu

W250CF - CP 60 dBu W250CF - LIC 60 dBu

W252EG 60 dBu

WZOL-FM 3 60 dBu

WZOL FM 60 dBu

EXHIBIT 3 FIRST ADJACENT ALLOCATION CONSIDERATION PROPOSED MINOR CHANGE W251DA CH. 251 98.1 MHZ 0.25KW DA VEGA BAJA, PR

Alejandro Luciano PE September 2020 Proposed W251DA 40 dBu 50/10

WXHD-FM CP 60 dBu

WXHD-FM LIC. 60 dBu

EXHIBIT 4 CO-CHANNEL ALLOCATION CONSIDERATION PROPOSED MINOR CHANGE W251DA CH. 251 98.1 MHZ 0.25KW DA VEGA BAJA, PR

Alejandro Luciano PE September 2020 Proposed W251DA 94 dBu 50/10 Contour

WUKQ-FM LIC. WIOB-FM LIC. 54 dBu Contour 54 dBu Contour

EXHIBIT 5 THIRD ADJACENT ALLOCATION CONSIDERATION PROPOSED MINOR CHANGE W251DA CH. 251 98.1 MHZ 0.25KW DA VEGA BAJA, PR

Alejandro Luciano PE September 2020 Proposed W251DA 100 dBu Contour Transmitter Shelter

Hen Shelter

Uninhabited Area of interference to WNVM-FM

W253DB-CP 60dBu Protected Contour

EXHIBIT 6 SECOND ADJACENT, W253DB, ALLOCATION CLEARANCE PROPOSED MINOR CHANGE W251DA CH. 251 98.1 MHZ 0.25KW DA VEGA BAJA, PR

Alejandro Luciano PE September 2020 Proposed W251DA 115.3 dBu Contour Interference to WNVM-FM ends

Interference to WNVM-FM begins

Area of interference to WNVM-FM

WUKQ-FM LIC. Transmitter Shelter WIOB-FM LIC. 54 dBu Contour Hen Shelter 54 dBu Contour

EXHIBIT 7 SECOND ADJACENT WNVM-FM ALLOCATION CONSIDERATION PROPOSED MINOR CHANGE W251DA CH. 251 98.1 MHZ 0.25KW DA VEGA BAJA, PR

Alejandro Luciano PE September 2020 EXHIBIT 8

FM SEARCH FROM PROPOSED W251DA 18 - 18 - 21.8 North Latitude, 66 - 16 - 29.6 West Longitude CH. 251D - 98.1MHZ, 0.25kW DA, RC = 439.8 Meters AMSL Freq. ERP HAAT Distance Distance Call Channel Service Status City State Country File Number Facility ID Azimuth Licensee/Permittee MHZ (kW) (Meters) (KM) (Miles) WIOB 248 B FM 97.5 LIC MAYAGUEZ PR US BLH-19951020KC 8153 50 302 94.64 58.8 271.34 SPANISH BROADCASTING SYSTEM HOLDING COMPANY INC. WIOB-FM1 248 D FB 97.5 LIC SAN GERMAN PR US BLFTB-19861003TG 8154 0.92 0 77.42 48.11 257.16 SPANISH BROADCASTING SYSTEM HOLDING COMPANY INC. WNVM-FM1 249 D FB 97.7 LIC CAYEY PR US BLFTB-20101004AAE 183917 0.021 0 26.65 16.56 160.78 NEW LIFE BROADCASTING INC. WNVM-FM1 249 D FB 97.7 APP CAYEY/AIBONITO PR US 118123 183917 0.1 0 26.65 16.56 160.78 NEW LIFE BROADCASTING INC. WNVM 249 A FM 97.7 LIC CIDRA PR US 106819 1891 3.1 336 17.86 11.1 100.11 NEW LIFE BROADCASTING INC. WNVM 249 A FM 97.7 LIC CIDRA PR US BMPH-20180618ABE 1891 3.1 336 17.86 11.1 100.11 NEW LIFE BROADCASTING INC. WNVM 249 A FM 97.7 LIC CIDRA PR US BMLH-20120710ACQ 1891 3 333 17.76 11.04 99.97 NEW LIFE BROADCASTING INC. WNVM 249 A FS 97.7 LIC CIDRA PR US BXLH-20110322ABR 1891 3 324 17.76 11.04 99.97 NEW LIFE BROADCASTING INC. W250CF 250 D FX 97.9 LIC ARECIBO PR US BLFT-20161121ADT 26656 0.23 0 48.76 30.3 286.2 AURIO A MATOS BARRETO WXHD 251 A FM 98.1 CP SANTA ISABEL PR US BPH-20180904ABO 77881 6 153 32.16 19.98 195.84 AMOR RADIO GROUP CORP. WXHD 251 A FM 98.1 LIC SANTA ISABEL PR US BLH-20140806AAW 77881 6 133 32.15 19.98 196.16 AMOR RADIO GROUP CORP. W250CF 252 D FX 98.3 CP ARECIBO PR US BPFT-20180110AAW 26656 0.125 0 63.25 39.3 287.12 AURIO A MATOS BARRETO WZOL-FM3 252 D FB 98.3 LIC FAJARDO PR US BLFTB-20131231AEN 191171 0.166 0 62.28 38.7 87.28 WZOL INC. WZOL 252 A FM 98.3 LIC LAS PIEDRAS PR US BLH-20120514ADR 8898 0.83 574 44.69 27.77 93.94 WZOL INC. W252EG 252 D FX 98.3 CP UTUADO PR US BNPFT-20181009AAP 203235 0.1 0 46.15 28.68 264.49 CENTRAL BROADCASTING CORPORATION W253DB 253 D FX 98.5 CP BARRANQUITAS PR US BNPFT-20181010AAL 202068 0.022 0 14.17 8.8 193.48 RADIO PROCER IN C. WUKQ-FM 254 B FM 98.7 LIC MAYAGUEZ PR US BLH-20130104ABI 54818 25 601 77.42 48.1 257.09 WLII/WSUR LICENSE PARTNERSHIP G.P. WUKQ-FM1 254 D FB 98.7 LIC PONCE PR US BLFTB-20130325AML 127832 3.8 -28 50.78 31.55 226.29 WLII/WSUR LICENSE PARTNERSHIP G.P. Alejandro Luciano PE Consulting Engineer

October 5, 2020

Angel M. Vazquez Spectrum Manager Arecibo Observatory HC3 Box 53995 Arecibo, PR 00612

On behalf of Caguas Educational TV Inc. licensee of fill-in translator W251DA Facility ID: 202075 and in accordance with section 73.1030 of the FCC Rules, we hereby notify of the proposed modified facility

The particulars of the proposal are as follow:

Proposed W251DA:

Frequency: 98.1 MHz NAD 83 geographical coordinates of antenna location: 18-18’-21.8” N+ 66-16’-29.6” W- EIRP Power: 0.25 kW Horizontal Polarized. Antenna orientation: 320 degrees True. Emission: F3E

Should you have any questions or need additional information, please contact the undersigned at your convenience.

Alejandro Luciano PE Consulting Engineer PO Box 194528 San Juan, Puerto Rico 00919-4528 [email protected] (787)717-6984 Sent via email to [email protected]