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Engineering Statement Channel Change Application WYES-TV , LA Proposed New Channel 28 April 9, 2021

In this application, the licensee of WYES-TV (WYES) proposes to change from it licensed High-VHF channel 11 to UHF channel 28. WYES is the only station in the New Orleans, LA Market that is not on a UHF channel. This puts WYES at a significant disadvantage with regard to over-the-air reception in that antennas designed for UHF reception are very inefficient at VHF and viewers are not likely to be motivated to acquire a VHF compatible antenna for a single station. In addition, it has been well documented that indoor reception of VHF signals is more difficult than UHF and therefore might require an outdoor antenna for reception of that single channel. In view of this and to improve service availability, WYES proposes to move to UHF channel 28.

The power and antenna pattern proposed here for channel 28 seeks to provide the maximum service while providing the required protection to other stations. The facility is to be located at the same site and height as the current WYES channel 11 facility and will operate with an (ERP) of 1,000 kW into a directional antenna. The proposed directional antenna pattern is somewhat broader than the current channel 11 pattern in an effort to reduce service loss due to the 1,000 kW ERP power cap for UHF stations. An interference study using the FCC’s TVStudy software with the default settings shows the proposed facility would not cause any non-de minimis interference to other stations requiring protection. A copy of the TVStudy interference analysis is provided in Appendix A.

A comparison of the standard predicted service contours shows both areas where the proposed new contour exceeds that of the current licensed facility as well as areas where the opposite is true. As discussed above this is due to the attempt to maximize the service and the limitations posed by the UHF power cap. It however is also known the actual service does not necessarily stop at the arbitrary boundary imposed by the traditionally computed service contours. Therefore, a further analysis was performed using the FCC’s TVStudy software to determine the predicted service provided by the proposed channel 28 facility within the traditional noise-limited-service contour (NLC) of the licensed channel 11 facility. The result of that study, as depicted in the coverage map provided below, shows the predicted service of the proposed UHF facility slightly equals that of the VHF facility. The plot shows that there is only 1-cell (population 0) where the VHF facility provides service that is not covered by the proposed UHF facility. A further analysis also indicated there are 5-cells (population 56) where the UHF facility provides service that is not covered by the licensed VHF facility. Therefore, the proposed facility is capable of providing sufficient field strength for service in the areas where its traditionally computed NLC does not reach as far as the licensed VHF facility.

In view of the above and the supporting information provided in the appendices, it is believed that WYES is justified in requesting this change and that it would be in the public interest to grant its request.

William R. Meintel Senior Partner Meintel, Sgrignoli & Wallace LLC

Appendix A

TVStudy Interference Analysis Results for proposed channel change of station WYES-TV channel 11 New Orleans, LA to channel 28. tvstudy v2.2.5 (4uoc83) Database: localhost, Study: 00824_01302021_WYES_25090, Model: Longley-Rice Start: 2021.01.30 11:30:54

Study created: 2021.01.30 11:30:54

Study build station data: LMS TV 2021-01-30

Proposal: WYES-TV D28 DT APP NEW ORLEANS, LA File number: 00673_11302020_WYES_25090 Facility ID: 25090 Station data: User record Record ID: 1157 Country: U.S. Zone: III

Search options: Non-U.S. records included Baseline record excluded if station has CP

Stations potentially affected by proposal:

IX Call Chan Svc Status City, State File Number Distance No WFNA D27 DT LIC GULF SHORES, AL BLANK0000120977 219.1 km Yes WWL-TV D27 DT LIC NEW ORLEANS, LA BLANK0000109373 10.2 No WMCF-TV D28 DT LIC MONTGOMERY, AL BLANK0000107502 448.8 No WFSG D28 DT LIC PANAMA CITY, FL BLANK0000064507 389.5 Yes KATC D28 DT LIC LAFAYETTE, LA BLCDT20071109AAV 228.7 Yes WMAW-TV D28 DT LIC MERIDIAN, MS BLANK0000106235 256.1 No WVUE-DT D29 DT APP NEW ORLEANS, LA BLANK0000127677 0.0 No WVUE-DT D29 DT LIC NEW ORLEANS, LA BLCDT20110502AEC 0.0

No non-directional AM stations found within 0.8 km

Directional AM stations within 3.2 km: WQNO 690 L DAN D NEW ORLEANS, LA BMML20170703AFC WQNO 690 L DAN N NEW ORLEANS, LA BMML20170703AFC

Record parameters as studied:

Channel: D28 Latitude: 29 57 14.00 N (NAD83) Longitude: 89 56 58.00 W Height AMSL: 306.5 m HAAT: 306.0 m Peak ERP: 1000 kW Antenna: ERI ATW_WC_EBSP_00440592553_horizontal_a 165.0 deg Elev Pattrn: ERI ATW_WC_EBSP_00440592553_horizontal_e Elec Tilt: 0.75

40.1 dBu contour: Azimuth ERP HAAT Distance 0.0 deg 268 kW 307.5 m 87.7 km 45.0 671 306.5 95.8 90.0 1000 306.4 99.3 135.0 845 306.2 97.8 180.0 810 306.3 97.4 225.0 968 306.8 99.1 270.0 840 305.2 97.7 315.0 350 306.5 89.8

Distance to Canadian border: 1457.1 km

Distance to Mexican border: 814.8 km

Conditions at FCC monitoring station: Powder Springs GA Bearing: 47.3 degrees Distance: 656.9 km

Proposal is not within the West Virginia quiet zone area

Conditions at Table Mountain receiving zone: Bearing: 313.3 degrees Distance: 1786.8 km

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 BLANK0000109373 LIC scenario 1

Call Chan Svc Status City, State File Number Distance Desired: WWL-TV D27 DT LIC NEW ORLEANS, LA BLANK0000109373

Undesireds: WYES-TV D28 DT APP NEW ORLEANS, LA 00673_11302020_WYES_25 10.2 km WGNO D26 DT LIC NEW ORLEANS, LA BLCDT20121019AAK 9.2 WFNA D27 DT LIC GULF SHORES, AL BLANK0000120977 229.1

Service area Terrain-limited IX-free, before IX-free, after Percent New IX 31548.0 1,788,624 31548.0 1,788,624 31118.9 1,771,607 31110.9 1,771,373 0.03 0.01

Undesired Total IX Unique IX, before Unique IX, after WYES-TV D28 DT APP 16.0 239 8.0 234 WGNO D26 DT LIC 4.0 5 0.0 0 0.0 0 WFNA D27 DT LIC 429.1 17,017 425.1 17,012 421.1 17,012

------Interference to BLCDT20071109AAV LIC scenario 1

Call Chan Svc Status City, State File Number Distance Desired: KATC D28 DT LIC LAFAYETTE, LA BLCDT20071109AAV

Undesireds: WYES-TV D28 DT APP NEW ORLEANS, LA 00673_11302020_WYES_25 228.7 km KBTV-TV D27 DT LIC PORT ARTHUR, TX BLANK0000063140 163.9 KTBS-TV D28 DT LIC SHREVEPORT, LA BLANK0000053971 305.2 KUGB-CD D28 DC CP , TX BLANK0000127537 321.2 KCEB D28 DT LIC LONGVIEW, TX BLANK0000080719 305.2 KITU-TV D29 DT LIC BEAUMONT, TX BLANK0000063643 156.1

Service area Terrain-limited IX-free, before IX-free, after Percent New IX 42336.9 1,348,897 42333.0 1,348,897 41892.4 1,344,016 41647.4 1,338,214 0.58 0.43

Undesired Total IX Unique IX, before Unique IX, after WYES-TV D28 DT APP 245.1 5,802 245.1 5,802 KBTV-TV D27 DT LIC 28.1 13 0.0 0 0.0 0 KTBS-TV D28 DT LIC 135.1 2,388 0.0 0 0.0 0 KCEB D28 DT LIC 135.1 2,388 0.0 0 0.0 0 KITU-TV D29 DT LIC 305.4 2,493 277.3 2,480 277.3 2,480

------Interference to BLANK0000106235 LIC scenario 1

Call Chan Svc Status City, State File Number Distance Desired: WMAW-TV D28 DT LIC MERIDIAN, MS BLANK0000106235

Undesireds: WYES-TV D28 DT APP NEW ORLEANS, LA 00673_11302020_WYES_25 256.1 km WCBI-TV D27 DT LIC COLUMBUS, MS BLANK0000059851 180.4 WMCF-TV D28 DT LIC MONTGOMERY, AL BLANK0000107502 273.8 KATC D28 DT LIC LAFAYETTE, LA BLCDT20071109AAV 364.7 WREG-TV D28 DT LIC MEMPHIS, TN BLCDT20050513AAE 345.0

Service area Terrain-limited IX-free, before IX-free, after Percent New IX 32611.9 726,173 32350.7 715,450 31718.5 711,353 31583.4 709,918 0.43 0.20

Undesired Total IX Unique IX, before Unique IX, after WYES-TV D28 DT APP 175.1 3,974 135.1 1,435 WCBI-TV D27 DT LIC 52.0 314 16.0 30 16.0 30 WMCF-TV D28 DT LIC 512.0 1,131 484.0 1,129 476.0 1,105 KATC D28 DT LIC 52.1 2,580 52.1 2,580 20.1 65 WREG-TV D28 DT LIC 72.1 356 36.0 74 36.0 74

------Interference to proposal scenario 1 0.68% interference received

Call Chan Svc Status City, State File Number Distance Desired: WYES-TV D28 DT APP NEW ORLEANS, LA 00673_11302020_WYES_25

Undesireds: WWL-TV D27 DT LIC NEW ORLEANS, LA BLANK0000109373 10.2 km KATC D28 DT LIC LAFAYETTE, LA BLCDT20071109AAV 228.7 WMAW-TV D28 DT LIC MERIDIAN, MS BLANK0000106235 256.1 WVUE-DT D29 DT APP NEW ORLEANS, LA BLANK0000127677 0.0

Service area Terrain-limited IX-free Percent IX 28786.6 1,674,833 28782.6 1,674,703 28501.4 1,663,320 0.98 0.68

Undesired Total IX Unique IX Prcnt Unique IX WWL-TV D27 DT LIC 8.0 175 4.0 113 0.01 0.01 KATC D28 DT LIC 233.2 10,709 225.2 10,709 0.78 0.64 WMAW-TV D28 DT LIC 52.0 561 40.0 499 0.14 0.03

Appendix B

As discussed above, the apparent loss area created by moving WYES from VHF channel 11 to UHF channel 28 is in a large part due to limiting the predicted service computation to the area defined by the traditionally computed extent of its noise limited contour (NLC). In view of this, the FCC’s TVStudy software was utilized to perform a study of the predicted service provided by the proposed channel 28 facility within the noise limited contour of the licensed channel 11 facility. The result of that study shows the proposed channel 28 facility provides a service level signal over the entire area now served by the licensed channel 11 facility, with the exception of one cell at the edge of the contour that contains zero population. Below is a map showing in GREEN the points within the VHF channel 11 NLC where the channel 28 facility would provide service and in RED the single point that would not be served.

Appendix C

As a further justification to granting the proposed facility, the following page provides a map showing the areas of apparent service loss, as discussed above, that receive service from one or more other stations in either the New Orleans, LA market or the adjacent markets. The extent of the noise limited contour for each of the other stations providing service is shown with color coding to identify those stations.

Stations Providing Service in the Apparent Loss Area

CALL CITY STATE CHANNEL SERVICE TYPE WAFB Baton Rouge LA 9 Full Service WBRZ-TV Baton Rouge LA 13 Full Service WGMB-TV Baton Rouge LA 24 Full Service WLPB-TV Baton Rouge LA 25 Full Service WVLA-TV Baton Rouge LA 34 Full Service KGLA-DT Hammond LA 35 Full Service KFOL-CD Houma LA 30 Class A KWBJ-CD Morgan City LA 22 Class A WNOL-TV New Orleans LA 15 Full Service WDSU New Orleans LA 19 Full Service WGNO New Orleans LA 26 Full Service WWL-TV New Orleans LA 27 Full Service WVUE-DT New Orleans LA 29 Full Service WPXL-TV New Orleans LA 33 Full Service WUPL Slidell LA 17 Full Service WMAH-TV Biloxi MS 16 Full Service WLOX Biloxi MS 32 Full Service WXXV-TV Gulfport MS 25 Full Service