Technical Summary

WEPX-TV Greenville, North Carolina Channel 36 850 kW 275 (HAAT)

ION Media Greenville License, Inc. (“ION”) licensee of television station WEPX-TV, Facility ID 81508, Greenville, North Carolina (the “Station”) hereby submits this Construction Permit Modification application seeking authority to relocate its transmitter from the currently authorized site to a site that will accommodate post-repack operations (FCC LMS File No. 0000034893).

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 WEPX-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 Greenville market. In the immediate vicinity of the current tower site, ION’s market analysis found no alternatives that would provide equivalent interference-free coverage as compared to the Station’s pre-auction or authorized post-auction facilities. However, ION was able to identify an alternative tower providing superior height and coverage performance to the southeast of the current authorized site.

The new tower is located approximately 32 kilometers to the southeast of the current site. Accordingly, the Station’s proposed noise limited service contour (“NLSC”) will shift to the southeast, resulting 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 WEPX-TV loss area would be 88,556 persons over an area of 1,303 sq. km. WEPX-TV also would have a gain area of 193,945 persons and 7,482.1 sq. km. Thus, under the Commission’s traditional counter prediction methodology, WEPX-TV would have a net gain area of 105,389 persons and 6,179.1 sq. km. WEPX-TV currently provides an over-the-air signal to 846,508 persons in its service area, so the predicted service gain using 50/90 curves would represent approximately 12.5% of WEPX- TV’s service population. Figure 1 also demonstrates that the Commission’s 50/90 curves predict that all of the loss area would remain well served by 5 or more over-the-air full-power television stations. The proposed site relocation would not, of course, create any television coverage “white area.”

The Commission’s 50/90 curves also predict that, within the gain area, following construction of all repack facilities in this market, 2,662 persons would receive only 4 services. See Figure 2. If this application is approved, WEPX-TV would add an additional service in this area. As a result, all of the loss area would be well-served by 5 or more full-power television stations following WEPX-TV’s move to the proposed site. See Figure 3.

ION has reviewed the impact of this application on low power and Class A television stations in the Greenville 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 WEPX-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 36. 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, the requested tower site change is necessary for WEPX-TV to continue serving the vast majority of its viewers in the Greenville market. Importantly, WEPX-TV would add a fifth service to 2,662 persons in the post-repack gain area. Third, as a practical matter, very few viewers are likely to lose access to the programming available on WEPX-TV. ION network programming will remain available on area cable and satellite providers throughout the loss area, and approximately 79% of the viewers in the loss area subscribe to one of such services.

For the foregoing reasons, WEPX-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 36 operations before the close of Phase 5 will be jeopardized. Figure 1

Tabulation of other NLSC Services Considered

Call Sign Channel Community of License State

WAVY-TV 31 Portsmouth VA WBTW-D 13 Florence SC WCTI-TV 12 New Bern NC WCVE-TV 42 Richmond VA WCVW-D 44 Richmond VA WECT-D 44 Wilmington NC WFMY-TV 51 Greensboro NC WFXB-D 18 Myrtle Beach SC WGHP-D 35 High Point NC WGNT-D 50 Portsmouth VA WGPX-TV 14 Burlington NC WHMC-D 9 Conway SC WHRO-TV 16 Hampton-Norfolk VA WITN-TV 32 Washington NC WJPM-TV 45 Florence SC WLFL-D 27 Raleigh NC WMBF-TV 32 Myrtle Beach SC WMYV-D 33 Greensboro NC WNCN-D 17 Goldsboro NC WNCT-TV 10 Greenville NC WPDE-TV 16 Florence SC WPXU-TV 34 Jacksonville NC WPXV-TV 46 Norfolk VA WRAL-TV 48 Raleigh NC WRAZ-D 49 Raleigh NC WRDC-D 28 Durham NC WRIC-TV 22 Petersburg VA WRLH-TV 26 Richmond VA WRPX-TV 15 Rocky Mount NC WSET-TV 13 Lynchburg VA WSFX-TV 30 Wilmington NC WSKY-TV 9 Manteo NC WTKR-D 40 Norfolk VA WTPC-TV 7 Virginia Beach VA WTVD-D 11 Durham NC WTVI-D 11 Charlotte NC WTVR-TV 25 Richmond VA WTVZ-TV 33 Norfolk VA WUNC-TV 25 Chapel Hill NC WUND-TV 20 Edenton NC WUNG-TV 44 Concord NC WUNJ-TV 29 Wilmington NC WUNK-TV 23 Greenville NC WUNL-TV 32 Winston-Salem NC

WUNM-TV 19 Jacksonville NC WUNP-TV 36 Roanoke Rapids NC WUNU-D 31 Lumberton NC WUPV-D 47 Ashland VA WUVC-DT 38 Fayetteville NC WVBT-D 29 Virginia Beach VA WVEC-D 13 Hampton VA WWAY-D 46 Wilmington NC WWBT-D 12 Richmond VA WWCW-D 20 Lynchburg VA WWMB-D 21 Florence SC WXII-TV 31 Winston-Salem NC WXLV-TV 29 Winston-Salem NC WYDO-D 47 Greenville NC

*Licensed Authorization

Figure 2

Figure 3

Tabulation of other NLSC Services Considered

Call Sign Channel Community of License State

WAVY-TV.C 19 Portsmouth VA WBTW-A 13 Florence SC WCTI-TV.C 10 New Bern NC WCVE-TV.C 22 Richmond VA WCVW-D.C 29 Richmond VA WECT-D.C 23 Wilmington NC WFMY-TV.C 35 Greensboro NC WFXB-D.C 36 Myrtle Beach SC WGHP-D.C 31 High Point NC WGNT-D.C 20 Portsmouth VA WGPX-TV.C 26 Burlington NC WHMC-D.C 28 Conway SC WHRO-TV.C 31 Hampton-Norfolk VA WITN-TV.C 34 Washington NC WJPM-TV.C 16 Florence SC WLFL-D.C 18 Raleigh NC WMBF-TV-A 32 Myrtle Beach SC WMYV-D.C 28 Greensboro NC WNCN-D.C 8 Goldsboro NC WNCT-TV.C 12 Greenville NC WPDE-TV.C 27 Florence SC WPXU-TV.C 16 Jacksonville NC WPXV-TV.C 32 Norfolk VA WRAL-TV.C 17 Raleigh NC WRAZ-D.C 15 Raleigh NC WRDC-D.C 14 Durham NC WRIC-TV.C 28 Petersburg VA WRLH-TV.C 24 Richmond VA WRPX-TV.C 32 Rocky Mount NC WSET-TV.C 7 Lynchburg VA WSFX-TV.C 29 Wilmington NC WSKY-TV.C 13 Manteo NC WTKR-D.C 16 Norfolk VA WTPC-TV-A 7 Virginia Beach VA WTVD-D.C 9 Durham NC WTVI-D.C 9 Charlotte NC WTVR-TV.C 23 Richmond VA WTVZ-TV-A 33 Norfolk VA WUNC-TV.C 20 Chapel Hill NC WUND-TV.C 29 Edenton NC WUNG-TV.C 21 Concord NC WUNJ-TV.C 21 Wilmington NC WUNK-TV.C 25 Greenville NC WUNL-TV.C 33 Winston-Salem NC

WUNM-TV.C 28 Jacksonville NC WUNP-TV.C 27 Roanoke Rapids NC WUNU-D.C 30 Lumberton NC WUPV-D.C 8 Ashland VA WUVC-DT.C 22 Fayetteville NC WVBT-D.C 21 Virginia Beach VA WVEC-D.C 11 Hampton VA WWAY-D.C 24 Wilmington NC WWBT-D.C 10 Richmond VA WWCW-D.C 21 Lynchburg VA WWMB-D.C 26 Florence SC WXII-TV.C 16 Winston-Salem NC WXLV-TV-A 29 Winston-Salem NC WYDO-D.C 19 Greenville NC

*Post Auction Authorization