HATFIELD & DAWSON THOMAS M. E CKELS, PE CONSULTING ELECTRICAL ENGINEERS TELEPHONE (206) 783-9151 STEPHEN S. L OCKWOOD, PE 9500 G REENWOOD AVE. N. FACSIMILE (206) 789-9834 DAVID J. P INION, PE SEATTLE, WASHINGTON 98103 E-MAIL [email protected] ERIK C. S WANSON , PE MAURY L. H ATFIELD , PE THOMAS S. G ORTON, PE (1942-2009) MICHAEL H. M EHIGAN , PE PAUL W. LEONARD , PE (1925-2011) JAMES B. H ATFIELD, PE BENJAMIN F. D AWSON III, PE CONSULTANTS

Engineering Statement Minor Modification of KSCI Channel 18 at Long Beach, November 2017

Expansion Application This Engineering Statement has been prepared on behalf of NRJ TV LA License Co, LLC, licensee of digital KSCI at Long Beach, California. This application specifies a minor modification of the licensed KSCI facility, including a transmitter site change to a tower on Mount Wilson.

KSCI is entering into a channel sharing arrangement with KOCE-TV. The initial channel sharing application by KOCE-TV is currently pending, with channel sharing to commence on the current KSCI Ch18 facility at Mount Harvard. FCC staff has advised that in this situation, a minor modification application for contour expansion (filed during the November 28 to December 7 window) should be filed only by KSCI, with a follow-on application to include KOCE-TV to be filed after the channel sharing has been implemented and licensed.

Compliance with §73.622(f) DTV maximum power and antenna heights Processing is requested pursuant to the provisions of §73.622(f)(5), which allows for technical facilities up to those needed to provide the same geographic coverage as the largest station within the market. The table below demonstrates that the geographic coverage of the proposed noise limited contour will not exceed that of the largest station within the DMA.

Geographic Coverage (km 2)

KSCI 800 kW at 943m HAAT (Ch18 proposed) 41,337.3

KTTV 115 kW at 903m HAAT (Ch11 License) 55,607.8 KSCI Long Beach (November 2017) Page 2

Interference Study An interference study has been conducted using the Commission’s TVStudy software. The results of the study demonstrate that this proposal will have no additional interference impact on other stations (licenses, permits, and applications) beyond the nominal 0.5% value as permitted by the FCC Rules.

This study has been conducted using a grid cell size of 1.0 kilometers, and a terrain extraction increment of 0.5 kilometers.

While the study results indicate an MX (mutually-exclusive) situation with expansion applications filed by the following repacked stations: • KNSD Ch17 San Diego (File No. 34867) • KPSP-CD Ch18 Cathedral City (File No. 34073) ...in connection with the second expansion window, in all scenarios the interference is received by the proposed KSCI-TV facility . No interference in excess of 0.5% is caused to the pending KNSD and KPSP-CD application facilities, and therefore these MX “hits” would not be considered an impediment to grant of the instant application.

Hatfield & Dawson Consulting Engineers KSCI Long Beach (November 2017) Page 3

Study created: 2017.11.24 10:54:51

Study build station data: LMS TV 2017-11-22 (76)

Proposal: KSCI D18 DT LIC LONG BEACH, CA File number: KSCI-T3-ATW26C2-1MBT-800KW Facility ID: 35608 Station data: User record Record ID: 386 Country: U.S. Zone: II

Stations affected by proposal:

Call Chan Svc Status City, State File Number Distance KNSD D17 DT CP SAN DIEGO, CA BLANK0000027747 199.8 km KNSD D17 DT APP SAN DIEGO, CA BLANK0000034867 199.8 KNSD D17 DT BL SAN DIEGO, CA DTVBL35277 199.8 KPSP-CD D18 DC CP CATHEDRAL CITY, CA BLANK0000024532 155.6 KPSP-CD D18 DC APP CATHEDRAL CITY, CA BLANK0000034073 155.5 KPSP-CD D18 DC BL CATHEDRAL CITY, CA DTVBL10535 155.6 KUSI-TV D18 DT LIC SAN DIEGO, CA BLANK0000005158 199.7 KPBS D19 DT CP SAN DIEGO, CA BLANK0000027963 199.7 KPBS D19 DT BL SAN DIEGO, CA DTVBL6124 199.7

No non-directional AM stations found within 0.8 km

No directional AM stations found within 3.2 km

Record parameters as studied:

Channel: D18 Latitude: 34 13 35.70 N (NAD83) Longitude: 118 3 59.50 W Height AMSL: 1833.5 m HAAT: 899.0 m Peak ERP: 800 kW Antenna: AND-ATWC2 190.0 deg Elev Pattrn: ERI-ATW26-2MBT-SMOOTH Tilts: elec 2.0, mech 1.0 @ 190.0 deg

39.1 dBu contour: Azimuth ERP HAAT Distance 0.0 deg 67.3 kW 390.3 m 87.0 km 45.0 31.2 397.0 82.2 90.0 216 680.3 113.9 135.0 165 1411.3 136.0 180.0 42.5 1528.7 123.8 225.0 85.1 1488.3 130.5 270.0 236 1013.1 126.7 315.0 116 633.1 106.4

Database HAAT does not agree with computed HAAT Database HAAT: 899 m Computed HAAT: 943 m

ERP exceeds maximum ERP: 800 kW ERP maximum: 150 kW

**Proposal service area extends beyond baseline plus 1.0% Proposal service area population is more than 95.0% of baseline

Hatfield & Dawson Consulting Engineers KSCI Long Beach (November 2017) Page 4

Distance to Canadian border: 1620.4 km

**Proposal is within coordination distance of Mexican border Distance to Mexican border: 190.3 km

Conditions at FCC monitoring station: Livermore CA Bearing: 320.6 degrees Distance: 511.0 km

Proposal is not within the West Virginia quiet zone area

Conditions at Table Mountain receiving zone: Bearing: 56.2 degrees Distance: 1308.3 km

No land mobile station failures found

Study cell size: 1.00 km Profile point spacing: 0.50 km

Maximum new IX to full-service and Class A: 0.50% Maximum new IX to LPTV: 2.00%

Proposal receives 2.28% interference from scenario 1 **MX with BLANK0000034867 APP, 2.28% interference, scenario 2 Proposal receives 2.28% interference from scenario 3 Proposal receives 2.28% interference from scenario 4 **MX with BLANK0000034867 APP, 2.28% interference, scenario 5 Proposal receives 2.28% interference from scenario 6 **MX with BLANK0000034073 APP, 2.31% interference, scenario 7 Proposal receives 2.28% interference from scenario 8 **MX with scenario 9, receives 2.31% interference **MX with BLANK0000034073 APP, 2.31% interference, scenario 10 **MX with BLANK0000034867 APP, 2.28% interference, scenario 11 Proposal receives 2.28% interference from scenario 12 **MX with BLANK0000034073 APP, 2.31% interference, scenario 13 Proposal receives 2.28% interference from scenario 14 **MX with scenario 15, receives 2.31% interference **MX with BLANK0000034073 APP, 2.31% interference, scenario 16 **MX with BLANK0000034867 APP, 2.28% interference, scenario 17 Proposal receives 2.28% interference from scenario 18

Hatfield & Dawson Consulting Engineers KSCI Long Beach (November 2017) Page 5

Facilities Proposed The proposed operation will be on Channel 18 with a maximum lobe effective radiated power of 800 kilowatts (H pol) and 464 kilowatts (V pol), using an antenna with 2 degrees of electrical beam tilt, and 1 degree of mechanical beam tilt. Operation is proposed with an ERI model ATW26HS8- ETC2-18H antenna, which will be top-mounted on an existing tower at the Mount Wilson transmitter site. The FCC Antenna Structure Registration Number is 1013889.

The KSCI Ch18 antenna will replace the existing KAZA Ch47 antenna which is top-mounted on this tower. Because the KSCI antenna will be slightly taller than the KAZA antenna the FCC ASR record will need to be modified by the tower owner after FAA clearance has been obtained. Since this is by no means the tallest tower at Mount Wilson, FAA clearance is not anticipated to be a problem.

RF Exposure Calculations OET Bulletin 65 Evaluating Compliance with FCC Guidelines for Human Exposure to Radiofrequency Electromagnetic Fields (Edition 97-01) states in part that: When performing an evaluation for compliance with the FCC's RF guidelines all significant contributors to the ambient RF environment should be considered. . .For purposes of such consideration, significance can be taken to mean any transmitter producing more than 5% of the applicable exposure limit (in terms of power density or the square of the electric or magnetic field strength) at accessible locations.

As will be demonstrated below, the proposed operation will produce less than 5% of the applicable exposure limit for both controlled and uncontrolled environments. Thus, the proposed facility is categorically excluded from the requirement of further study. Therefore, pursuant to §1.1307(b)(3) of the Commission's Rules no calculations are required for the other FM and TV facilities in the vicinity, and precise calculations are made only with regard to the levels from this proposal.

The power density calculations shown below were made using the techniques outlined in OET Bulletin No. 65. "Ground level" calculations in this report have been made at a reference height of 2 meters above ground to provide a worst-case estimate of exposure for persons standing on the ground in the vicinity of the tower. The equation shown below was used to calculate the ground level power density figures from each antenna.

Hatfield & Dawson Consulting Engineers KSCI Long Beach (November 2017) Page 6

2 3340981.()× AdjERP Watts S(/)µ W cm = D2 Where: AdjERP(Watts) is the maximum lobe effective radiated power times the element pattern factor times the array pattern factor.

D is the distance in meters from the center of radiation to the calculation point.

Power density levels produced by the proposed facility were calculated for an elevation of 2 meters above ground (90 meters below the antenna radiation center). The worst case power density levels occur at depression angles between 45 and 90 degrees below the horizontal. The calculations in this report assume a worst-case relative field value of 0.032 at these angles, based on the manufacturer’s vertical plane pattern for the ERI model ATW26HS8-ETC2-18H antenna proposed in this application. This relative field value yields a worst-case adjusted average effective radiated power of 1294.3 watts at depression angles between 45 and 90 degrees below the horizontal. Assuming this power and the shortest distance between the antenna radiation center and 2 meters above ground level (i.e. straight down), the highest calculated power density from the proposed antenna alone occurs at the base of the antenna support structure. At this point the power density is calculated to be 5.3 µW/cm², which is 1.6% of 329.3 µW/cm² (the FCC maximum for uncontrolled environments at the Channel 18 frequency).

These calculations show that the maximum calculated power density produced at two meters above ground level by the proposed operation alone is less than 5% of the applicable FCC exposure limit at all locations between 1 and 500 meters from the base of the antenna support structure. Section 1.1307(b)(3) of the Commission's Rules excludes applications for new facilities or modifications to existing facilities from the requirement of preparing an environmental assessment when the calculated emissions from the applicants proposed facility are predicted to be less than 5% of the applicable FCC exposure limit. Therefore, the proposed facility is in compliance with Section 1.1301 et seq and no further analysis of RF exposure at this site is required in this application.

Pursuant to OET Bulletin No. 65, all station personnel and contractors are required to follow appropriate safety procedures before any work is commenced on the antenna tower, including

Hatfield & Dawson Consulting Engineers KSCI Long Beach (November 2017) Page 7 reduction in power or discontinuance of operation before any maintenance work is undertaken. The permittee/licensee in coordination with other users of the site must reduce power or cease operation as necessary to protect persons having access to the site, tower or antenna from radiofrequency exposure in excess of FCC guidelines.

Hatfield & Dawson Consulting Engineers