Before the Federal Communications Commission Washington, D.C

Before the Federal Communications Commission Washington, D.C. 20554 ) In the Matter of ) ) Advanced Television Systems ) MB Docket No. 87-268 and Their Impact upon the ) Existing Television Broadcast ) Service ) ) To: The Commission COMMENTS OF TRIBUNE BROADCASTING COMPANY Tribune Broadcasting Company (“Tribune”), by its undersigned attorney, hereby submits its comments in response to the FCC’s Eighth Further Notice of Proposed Rule Making (“8th FNPRM”) in the above-referenced proceeding.1 Tribune is the indirect, 100 percent owner of WGNO-DT and WNOL-DT, two stations licensed to New Orleans, Louisiana. Tribune supports the Commission’s proposal in the 8th FNPRM to (i) modify the technical parameters for WGNO and WNOL in the DTV Table and Appendix B to specify the parameters for a shared antenna Tribune plans to use for both stations at the transmitter site of WDSU in New Orleans, and (ii) waive the freeze to allow the authorized service area of WGNO and WNOL in the post- transition DTV table to exceed the currently authorized contours of both stations.2 As indicated in Tribune’s earlier comments and ex parte submissions in this proceeding, the analog and digital transmitting facilities of WGNO and WNOL were completely destroyed by Hurricane Katrina. The parameters in the post transition table adopted in the 7th Report and Order reflect DTV operations for WGNO and WNOL from the old transmitter site 1 See Advanced Television Systems and their Impact Upon the Existing Broadcast Service, Seventh Report & Order and Eighth Further Notice of Proposed Rule Making, MB Docket No. 87-268, FCC 07-138, released August 6, 2007. 2 See 8th FNPRM ¶¶ 155-156. destroyed by Katrina. While Tribune has restored and improved the analog service of WGNO and WNOL, neither station is on the air with a digital signal. In its comments filed in response the 7th FNPRM, Tribune indicated that it was in the final stages of selecting a new DTV transmitter site and that, once the site selection was finalized, Tribune expected to file a follow- up request to change the WGNO and WNOL allotments to reflect operations from the new site. In or around July of this year, Tribune finalized an agreement to relocate the DTV facilities of WGNO and WNOL to the WDSU transmitter site, which is approximately 3.7 km from the old WGNO/WNOL transmission site. Shortly after reaching this agreement, Tribune submitted an ex parte request in this proceeding to change the WGNO-DT and WNOL-DT allotments to specify operations from the WDSU site using a shared antenna. Tribune submits that modifying the DTV allotments for both WGNO and WNOL to specify operations from the WDSU site with the actual antenna pattern as proposed is clearly in the public interest because it will make it much easier for both stations to provide DTV service after the transition ends. By conforming the allotments to the expected operating parameters of the stations, Tribune will be freed up to provide new DTV service to the New Orleans market without the need for new interference studies, negotiations or Commission interaction. Respectfully submitted, TRIBUNE BROADCASTING COMPANY /s/ Thomas P. Van Wazer /s/ Thomas P. Van Wazer Sidley Austin LLP 1501 K Street, N.W. Washington, D.C. 20005 (202) 736-8119 Its Attorney Dated: October 10, 2007 2 .

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