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REQUEST TO MODIFY REPACK TRANSITION SCHEDULE

NBC License LLC (“NBCTLL”), the licensee of digital full power TV station KSTS, San Jose, (FIN 64987), hereby respectfully requests that the Commission modify the transition schedule to allow KSTS to test and transition to its post- auction channel facility in transition phase 9 instead transition phase 8.

The FCC assigned KSTS to be repacked from channel 49 to channel 19 in transition phase 8, with a testing start date of January 18, 2020 and a phase completion date of March 13, 2020. KSTS is co-located with digital full power TV station KDTV-DT, San Francisco, California (FIN 33778)1 licensed to KDTV License Partnership, G.P. (“”) on a tower located on Mount Allison that is owned by a parent company of Univision.2 The FCC assigned KDTV-DT to be repacked from channel 51 to channel 20 in transition phase 9, with a testing start date of March 14, 2020 and a phase completion date of May 1, 2020. KDTV-DT’s transition to its repack channel is linked upstream to KMAX-TV, Sacramento, California (FIN 51499).3

Given that KSTS and KDTV-DT are co-located, NBCTLL has been coordinating closely with Univision about work being done on the Mount Allison tower and determined that it makes the most sense for the two stations to transition to their repack channel facilities in the same phase.

In the Transition Scheduling PN, the Media Bureau stated that it would evaluate requests for modification of a transition deadline on a case-by-case basis to assess the impact on the transition schedule.4 The Bureau also acknowledged that alternative transition solutions “may reduce reimbursement costs or implement a market-wide transition plan that could allow stations to more efficiently utilize limited resources, facilitate coordination, or reduce the impact of the transition on viewers.”5 Further, the Bureau said “viewers will benefit from stations in a given DMA transitioning together. Not only does this limit the total number of channel rescans for viewers, but multiple stations’ communications with the public about the timing of a rescan supports education efforts.”6

In the case of KSTS, there will be no negative impact on the overall transition schedule. First, KSTS’s repack channel assignment in phase 8 is not part of any linked-station set, and thus KSTS will not cause prohibited interference to any station by transitioning in phase 9. Second,

1 KDTV-DT channel shares with digital full-power TV sharee station KTSF, San Francisco, California (FIN 37511), licensed to Lincoln Broadcasting Company, A California Limited Partnership. 2 See ASR No. 1044718, registered to Univision Television Group, Inc.; see also File No. 0000034597 (repack channel CP for KSTS) and File No. 0000034452 (repack channel CP for KDTV-DT). 3 KMAX-TV is licensed to Lincoln Broadcasting Company, A California Limited Partnership. 4 See Incentive Auction Task Force and Media Bureau Adopt Post-Incentive Auction Transition Scheduling Plan, Public Notice, 32 FCC Rcd 890, 913 ¶ 490 (MB 2017) (“Transition Scheduling PN”). 5 Transition Scheduling PN at ¶ 50. 6 Transition Scheduling PN at ¶ 52. because KSTS and KDTV-DT are co-located on the same tower, allowing KSTS to transition in the same phase with KDTV-DT will result in utilizing limited resources more efficiently (e.g., tower crew would be needed once in phase 9 instead of twice in phases 8 and 9). (Because KDTV-TV is linked upstream to KMAX-TV, KDTV-TV would not be able to transition early in the same phase as KSTS.)

To reduce viewer confusion, KSTS will establish a “KSTS Rescan Viewer Communications Plan” that will be implemented 30 days prior to the phase 9 transition date. This plan is designed to reach Spanish language over-the-air viewers across the entire San Francisco-, California market with targeted, high-frequency messaging on multiple platforms. The KSTS Rescan Viewer Communications Plan will include the following components:

• On each of the thirty days leading up to the phase 9 transition date, KSTS will over- deliver on the required 30 days of 60-seconds of PSA/crawls by guaranteeing a minimum of 120-seconds worth of on-air content in Spanish on both TELEMUNDO (48.1) and TeleXitos (48.2). In the weeks leading up to the transition, KSTS newscasts also will include explainer stories about the frequency change and what viewers can expect. Additionally, announcements will be included “ticker” that crawls across the lower-third of the screen during 2.5 hours of morning news, Monday-Sunday.

• In the seven days prior to the transition, KSTS plans to air numerous “Countdown-to- Rescan IDs,” which will count down the days until the transition in conjunction with the airing of KSTS’s legal station ID throughout the broadcast day.

• TelemundoAreaDeLaBahia.com (KSTS’s website) will include explainer stories in Spanish on the transition and a “How-To” video in Spanish on rescanning. Supplementing the video will be multiple slide shows consisting of screen grabs of the rescan menus from various brands of (e.g., Samsung, Vizio, LG, etc.). The website will be referenced as a source of detailed information in all communications, including Facebook posts, announcements and the Telemundo Area de la Bahia Instagram site, which originate 24/7 from the station.

• A formal station press release in Spanish will be distributed throughout the market, and our newspaper and radio media partners will report the transition.

• A “Rescan Hotline” phone line and “Rescan Email Address” will be established to field viewer inquiries. KSTS plans to personally respond to each inquiry and anticipates establishing a staffed Spanish speaking phone bank to answer calls from early morning into on the day of the transition and on subsequent days, as warranted.

Accordingly, the grant of this waiver request will serve the public interest by facilitating a more effective and efficient implementation of the overall policy goals of Auction and post-auction transition.