ENGINEERING EXHIBIT
Application for Digital Television Station Construction Permit prepared for
Ramar Communications, Inc. KJTV-TV Lubbock, TX Facility ID 55031 Ch. 35 1000 kW 282 m
Ramar Communications, Inc. (“Ramar”) is the licensee of digital television station KJTV-TV, Channel 35, Facility ID 55031, Lubbock TX. KJTV-TV is licensed (file# BLCDT- 20070201BKH) to operate with 1000 kW effective radiated power (“ERP”) at 274 meters antenna height above average terrain (“HAAT”). In connection with the replacement of the main antenna, Ramar proposes herein to increase KJTV-TV’s HAAT to 272 meters and change to directional operation.
KJTV-TV shares its main antenna with Ramar’s KLCW-TV (Facility ID 77719, Wolfforth TX) which has been reassigned from Channel 43 to Channel 23 as specified in the Incentive Auction Closing and Channel Reassignment Public Notice (“CCRPN”, DA 17-317, released April 13, 2017). Although KJTV-TV will remain on Channel 35 post-repack, the reassignment of KLCW-TV requires that the shared antenna be replaced, as KLCW-TV’s Channel 23 reassignment is beyond the frequency range of the existing broadband antenna. Ramar’s Class A television station KXTQ-CD (Facility ID 55055, Lubbock TX), co-located with KJTV-TV, has been reassigned from Channel 46 to Channel 24 and will also require a separate replacement antenna.
Reconfiguration of the top of the tower will be necessary to accommodate the channel reassignments, involving the two replacement antennas, removal of the topmost lattice sections of the tower (to change the KJTV-TV/KLCW-TV antenna from a side-mount to a top-mount), replacement of transmission line, and replacement of two levels of guy wire. The final configuration will be a top-mount broadband antenna for the full-service stations (KJTV-TV and KLCW-TV) and, immediately below that, a side-mounted broadband antenna for KJTV-CD
Engineering Exhibit Ramar Communications, Inc. (KJTV-TV) (page 2 of 5)
which will be shared with KJTV-CD (Ch. 33, Facility ID 168090, Wolfforth TX,) KLBB-LD (Ch. 19, Facility ID 192484, Lubbock TX), KMYL-LD (Ch. 22, Facility ID 168087, Lubbock TX), and K31MX-D (Lic Ch. 31, CP Ch. 15, Facility ID 55054, Lubbock TX).
Therefore, the proposed KJTV-TV operation will employ a new directional broadband antenna system to be top-mounted on the tower that will also be shared with KLCW-TV. The antenna’s center of radiation height above ground will increase by 4.3 meters.
The existing tower structure corresponds to FCC Antenna Structure Registration (“ASR”) number 1248244. The reconfiguration of the top of the tower will result in an increase of the structure’s overall height by 7.6 meters to 297.2 meters above ground level. The FAA has issued a Determination of No Hazard for the height increase (2017-ASW-7973-OE) and the ASR has been modified to specify the increased overall height above ground.
The proposed antenna is a horizontally polarized directional RFS model PHPR64U3313. The directional antenna’s azimuthal pattern is supplied in Figure 1 and the elevation pattern is depicted in Figure 2.
Figure 3 supplies a map that demonstrates compliance with §73.625(a)(1) regarding coverage of the entire principal community. The proposed facility’s predicted population exceeds 95 percent of the CCRPN baseline facility’s population.
Gain – Loss Analysis As a result of incentive auction channel reassignment, KJTV-TV’s antenna must be replaced in order to accommodate KLCW-TV’s new channel. KJTV-TV’s licensed transmitter power output (“TPO”) is 26.84 kW (see BLCDT-20070201BKH) and the equipment’s maximum TPO capacity is 27.0 kW (see Schedule 381 at LMS file# 0000004070). According to the manufacturer, a similar model to the existing antenna system (RFS RD32OM series) having the same gain and pattern response cannot be fabricated for shared use by KJTV-TV and KLCW-TV due to the frequency spread between the post-repack channels (23 and 35). In order for KJTV-TV to continue to use its existing transmitter and achieve the maximum ERP of
Engineering Exhibit Ramar Communications, Inc. (KJTV-TV) (page 3 of 5)
1000 kW in a shared configuration with KLCW-TV’s new channel, the replacement antenna must be a high-gain directional panel system. Practical options for nondirectional operation would require KJTV-TV to acquire a replacement transmitter having more power capacity than the existing equipment.
Owing to the change to directional operation, and despite the increase in antenna height, there will be some areas of service loss. A coverage contour comparison map, Figure 4, shows scattered loss areas attributable to the proposed panel antenna’s directional pattern. The authorized post-repack noise limited service contours (“NLSC”) of nearby stations which overlap that of the licensed KJTV-TV are provided on the map to demonstrate the availability of other services. There is at least one other service available in all of the loss areas, with some of the loss area having 3, 4, and 5 other services available.
The proposed KJTV-TV facility’s NLSC encompasses 406,245 persons and the licensed KJTV-TV NLSC encompasses 409,612 persons (2010 Census). A minor area of contour extension (gain area) exists containing 4 persons, and the population within the loss area is 3,371 persons. The loss area’s population density is low and the loss population represents 0.8 percent of the total population within the licensed KJTV-TV NLSC.
Contour Extension – Waiver Request The FCC’s Public Notice 1 of April 5, 2013 (DA 13-618) imposed limitations on the filing and processing of full power station applications that propose an increase in their authorized NLSC. As proposed herein, the KJTV-TV NLSC will be extended slightly beyond the currently authorized contour location over two small arcs as shown in Figure 4.
DA 13-618 contemplates waiver of the contour extension limitation for certain cases by stating: The Bureau will consider, on a case-by-case basis, requests for waiver of the filing limitation imposed by this Public Notice when a modification application is necessary or otherwise in the
1“Media Bureau Announces Limitations on the Filing and Processing of Full Power and Class A Television Station Modification Applications, Effective Immediately, and Reminds Stations of Spectrum Act Preservation Mandate,” DA 13-618, Public Notice, released April 5, 2013.
Engineering Exhibit Ramar Communications, Inc. (KJTV-TV) (page 4 of 5)
public interest for technical or other reasons to maintain quality service to the public, such as when zoning restrictions preclude tower construction at a particular site or when unforeseen events, such as extreme weather events or other extraordinary circumstances, require relocation to a new tower site.
For the case at hand, replacement of the shared antenna utilized by KJTV-TV is necessary as discussed earlier due to the reassignment of KLCW to Channel 23. While the proposed ERP could be reduced to eliminate the contour extension, that would increase the area of loss commensurately. The contour extension occurs at the proposed directional antenna’s major lobes, due to the 4.3 meter increase in antenna height above ground. The total area of contour extension is 7.5 square km and encompasses a population of 4 persons. This is 0.03 percent of the total area and 0.001 percent of the total population within the licensed KJTV-TV NLSC and can be considered as de minimis . A waiver of the DA 13-618 contour extension limitations is justified in this case for the reasons stated above.
Interference and Allocation The proposed facility expands the KJTV-TV service contour beyond that established by the CCRPN . Interference study per FCC OET Bulletin 69 2 shows that the proposal complies with the 0.5 percent limit of new interference caused to pertinent nearby post-auction full service and Class A television stations and reassignments as required by §73.616. The interference study output report is provided as Table 1.
The nearest FCC monitoring station is 764 km distant at Douglas, AZ. This exceeds by a large margin the threshold minimum distance specified in §73.1030(c)(3) that would suggest consideration of the monitoring station. The site is not located within the areas requiring coordination with “quiet” zones specified in §73.1030(a) and (b). The site location is beyond the border areas requiring international coordination. There are no authorized AM stations within 3 kilometers of the site.
2FCC Office of Engineering and Technology Bulletin number 69, Longley-Rice Methodology for Evaluating TV Coverage and Interference , February 6, 2004 (“OET-69”). This analysis employed the FCC’s current “TVStudy” software with the default application processing template settings, 2 km cell size, and 1 km terrain increment. Comparisons of various results of this computer program (run on a Mac processor) to the FCCs implementation of TVStudy show excellent correlation.
Engineering Exhibit Ramar Communications, Inc. (KJTV-TV) (page 5 of 5)
Human Exposure to Radiofrequency Electromagnetic Field (Environmental) The proposed operation was evaluated for human exposure to RF energy using the procedures outlined in the FCC’s OET Bulletin Number 65. Based on OET-65 equation (10), and considering 15 percent antenna relative field in downward elevations (pattern data shows less than 15 percent relative field at angles 10 to 90 degrees below the antenna), the calculated signal density near the tower at two meters above ground level attributable to the proposed facility is 9.3 µW/cm 2, which is 2.3 percent of the general population/uncontrolled maximum permitted exposure limit. This is well below the five percent threshold limit described in §1.1307(b) regarding sites with multiple emitters, categorically excluding the applicant from responsibility for taking any corrective action in the areas where the proposal’s contribution is less than five percent.
The general public will not be exposed to RF levels attributable to the proposal in excess of the FCC’s guidelines. RF exposure warning signs will continue to be posted. With respect to worker safety, the applicant will coordinate exposure procedures with all pertinent stations and will reduce power or cease operation as necessary to protect persons having access to the site, tower, or antenna from RF electromagnetic field exposure in excess of FCC guidelines. This exhibit is limited to the evaluation of exposure to RF electromagnetic field.
List of Attachments Figure 1 Antenna Azimuthal Pattern Figure 2 Antenna Elevation Pattern Figure 3 Proposed Coverage Contours Figure 4 Coverage Contour Comparison – Gain/Loss Analysis Table 1 TVStudy Analysis of Proposal Form 2100 Saved Version of Engineering Sections from FCC Form at Time of Upload
Chesapeake RF Consultants, LLC Joseph M. Davis, P.E. August 31, 2018 207 Old Dominion Road Yorktown, VA 23692 703-650-9600
Azimuth Pattern - Relative Field (True North) 0
330 30 1.0
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300 0.6 60
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270 0.0 90
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Figure 1 Antenna Azimuthal Pattern KJTV-TV Lubbock, TX
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\00\\00\00\\0\ \\0\00\\0\\00\\ Chesapeake RF Consultants, LLC \\0\00\\0\\00\\ \00\\00\00\\0\ Radiofrequency Consulting Engineers Ch. 35 1000 kW 282 m \\00\\0\0\\0\\ \00\\0\0\0\0 0\0\\0\0\\ Digital Television and Radio 0\0\\0\0 \ 0\0 prepared for Ramar Communications, Inc.
August, 2018
E / Emax Vertical Radiation Pattern
1.0 Date : 29/06/2017 Station : Lubbock 0.9 Model : PHP64U3313 0.8 Frequency (MHz) : 602.00 Directivity : 15.35 dBd 0.7 Tilt : 0.7 degrees Azimuth Angle : 267 degrees 0.6 Vertical Unit Pattern : PHP4S-602.vup 0.5
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Figure 2 Antenna Elevation Pattern KJTV-TV Lubbock, TX
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\00\\00\00\\0\ \\0\00\\0\\00\\ Chesapeake RF Consultants, LLC \\0\00\\0\\00\\ \00\\00\00\\0\ Radiofrequency Consulting Engineers Ch. 35 1000 kW 282 m \\00\\0\0\\0\\ \00\\0\0\0\0 0\0\\0\0\\ Digital Television and Radio 0\0\\0\0 \ 0\0 prepared for Ramar Communications, Inc.
August, 2018
TV & RADIO | IN-BUILDING | WIRELESS | IN-TUNNEL | HF & DEFENSE | MICROWAVE | MOBILE RADIO www.rfsworld.com Commercial in Confidence Page 10 Deaf Smith Randall Armstrong Donley
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\\0\00\\0\\00\\ Chesapeake RF Consultants, LLC Harmon \\0\00\\0\\00\\ \00\\00\00\\0\ Radiofrequency Consulting Engineers Figure 3 \\00\\0\0\\0\\ \00\\0\0\0\0 0\0\\0\0\\ Digital Television and Radio 0\0\\0\0 \ 0\0 Proposed Coverage Contours Curry KJTV-TV Lubbock, TX Parmer Hall Childress Castro Swisher Briscoe Facility ID 55031 0° Ch. 35 1000 kW 282 m prepared for Ramar Communications, Inc.Hardeman
315° 45° August, 2018 Bailey Lamb Hale Floyd Motley Cottle Proposed KJTV-TV 48 dBµ Foard Roosevelt (Principal Community) 41 dBµ (Noise Limited Service Contour)
Lubbock, TX Cochran Hockley Lubbock Crosby Dickens King Knox 270° 90°
Haskell Yoakum Terry Lynn Garza Kent Stonewall
225° 135° Lea Gaines Dawson Borden Scurry Fisher Jones
Area Population 180° Proposed Digital Coverage (sq. km) (2010 Census) Within Noise Limited Service Contour 24,690.5 406,245 Scale 1:1,500,000 OET Bulletin 69: TVStudy Within noise limited contour 24,728.6 406,283 km Not affected by terrain losses 24,512.3 406,260 0 15 30 45 Lost to all interference 0.0 0 V-Soft Communications LLC ® © Andrews Martin Howard Mitchell Nolan Taylor Net Interference-Free Service 24,512.3 406,260
Deaf Smith Randall Armstrong Donley
\ 0 \0 0\ 0\0\\
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\00\\00\00\\0\ \\0\00\\0\\00\\ Chesapeake RF Consultants, LLC Harmon \\0\00\\0\\00\\ \00\\00\00\\0\ Radiofrequency Consulting Engineers Figure 4 \\00\\0\0\\0\\ \00\\0\0\0\0 0\0\\0\0\\ Digital Television and Radio 0\0\\0\0 \ 0\0 Coverage Contour Comparison Curry Gain-Loss Analysis Contour Extension Parmer Castro (GainSwisher Area) Briscoe HallKJTV-TV Lubbock,Childress TX Facility ID 55031 Ch. 35 1000 kW 282 m
prepared for Hardeman Ramar Communications, Inc. August, 2018 Bailey Lamb Hale Floyd Motley Cottle
Foard Roosevelt
Proposed KJTV-TV 1000 kW 282 m Directional 41 dBµ (NLSC) Area: 24,690.5 sq. km Population: 406,245 Cochran Hockley Lubbock Crosby Dickens King Knox
Lic KJTV-TV BLCDT-20070201BKH 1000 kW 274 m Nondirectional 41 dBµ (NLSC) Area: 27,749.2 sq. km Population: 409,612 Haskell Yoakum Terry Lynn Garza Kent Stonewall Alternative Services Depicted Authorized Post-Repack Facilities Noise Limited Service Contours Call Sign Ch. Community KOSA-TV 7 Odessa, TX KOBR 8 Roswell, NM KWES-TV 9 Odessa, TX KBIM-TV 10 Roswell, NM KFDA-TV 10Lea Amarillo, TX KCBD 11 Lubbock, TX Gaines Dawson Borden Scurry Fisher Jones KVIH-TV 12 Clovis, NM KPTB-DT 16 Lubbock, TX KPCB-DT 17 Snyder, TX KLCW-TV CP 23 Wolfforth, TX KPEJ-TV 23 Odessa, TX KTTZ-TV CP 25 Lubbock, TX KMID-D 26 Midland, TX Contour Extension (Gain Area) KAMC-D 27 Lubbock, TX Scale 1:1,500,000 KPBT-TV CP 28 Odessa, TX KJTV-TV Gain Area km KUPT 29 Hobbs, NM 0 15 30 45 KLBK-TV CP 31 Lubbock, TX KJTV-TV Loss Area NolanV-Soft Communications LLCTaylor ® © KENW 32 Portales, NM Andrews Martin Howard Mitchell Table 1 KJTV-TV TVStudy Analysis of Proposal (page 1 of 2) tvstudy v2.2.5 (4uoc83) Database: localhost, Study: KJTV-TV PHP_1000kW, Model: Longley-Rice Start: 2018.08.30 11:54:30
Study created: 2018.08.30 11:54:30
Study build station data: LMS TV 2018-08-27
Proposal: KJTV-TV D35 DT APP Lubbock, TX File number: KJTV-TV PHP 1000kW Facility ID: 55031 Station data: User record Record ID: 2265 Country: U.S. Zone: II
Build options: Protect pre-transition records not on baseline channel
Search options: Baseline record excluded if station has CP
Stations potentially affected by proposal:
IX Call Chan Svc Status City, State File Number Distance No KNME-TV D35 DT LIC ALBUQUERQUE, NM BLEDT20030218BNH 461.1 km No KUOK D35 DT LIC WOODWARD, OK BLANK0000004509 379.2 No KDFW D35 DT LIC DALLAS, TX BLCDT20090508AAB 467.2
No non-directional AM stations found within 0.8 km
No directional AM stations found within 3.2 km
Record parameters as studied:
Channel: D35 Latitude: 33 30 8.30 N (NAD83) Longitude: 101 52 21.30 W Height AMSL: 1263.7 m HAAT: 282.1 m Peak ERP: 1000 kW Antenna: RFS PHPR64U3313 Ch35 0.0 deg Elev Pattrn: Generic Elec Tilt: 0.70
40.8 dBu contour: Azimuth ERP HAAT Distance 0.0 deg 990 kW 282.3 m 94.9 km 45.0 478 295.1 89.8 90.0 227 300.8 84.3 135.0 468 298.4 90.1 180.0 976 283.8 95.0 225.0 929 268.6 92.2 270.0 903 261.9 90.7 315.0 914 265.8 91.5
Distance to Canadian border: 1722.5 km
Distance to Mexican border: 404.8 km
Conditions at FCC monitoring station: Douglas AZ Bearing: 255.2 degrees Distance: 762.4 km
Proposal is not within the West Virginia quiet zone area
Conditions at Table Mountain receiving zone: Bearing: 338.9 degrees Distance: 793.4 km
Table 1 KJTV-TV TVStudy Analysis of Proposal (page 2 of 2)
Study cell size: 2.00 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%
------Interference to proposal scenario 1
Call Chan Svc Status City, State File Number Distance Desired: KJTV-TV D35 DT APP Lubbock, TX KJTV-TV PHP 1000kW
Service area Terrain-limited IX-free Percent IX 24728.6 406,283 24512.3 406,260 24512.3 406,260 0.00 0.00