WNEU Request for Engineering STA

WNEU Request for Engineering STA Circumstances Warranting Operation at Variance from Authorized Height and Power NBC Telemundo License LLC (“NBCU”), the licensee of WNEU, Merrimack, New Hampshire (FIN 51864), hereby respectfully requests Special Temporary Authority (STA) to operate WNEU at variance from the height and effective radiated power (ERP) specified in WNEU’s post-auction repack channel 29 construction permit (File No. 0000034700) (“Repack Channel CP”). This STA is required to allow WNEU to transition to its new channel before the August 2, 2019 Phase 4 deadline and to minimize the loss of service to viewers during the temporary operation. WNEU operating on its repack channel with its antenna at a lower height and higher ERP not impact other stations because WNEU will be terminating operations on its pre-auction channel by August 2. The tower for WNEU's repack channel facility (ASR No. 1003433) is owned by American Towers LLC (“American Tower”). Because American Tower needs to complete additional work on top of the tower, including the removal of existing double-stacked broadband antennas and building a top-mount UHF broadband antenna as well as associated work for other area TV stations, the new repack channel antenna for WNEU has been installed on the tower at a lower radiation center height of 314.25 meters AGL rather than the 370.1 meters AGL height authorized by WNEU’s Repack Channel CP so that WNEU may commence operations on its repack channel by August 2. The additional work to be performed on top of the tower by American Tower is anticipated to be completed by the end of 2019. Thereafter, WNEU’s new repack channel antenna will be moved to its final position authorized by the Repack Channel CP and ERP reduced to 540 kW as authorized in the Repack Channel CP. This project will be managed by American Tower. Description of Requested Facility Operation at the temporary location on the authorized tower will use the same antenna, the same antenna pattern, the same antenna orientation, and the same mechanical and electrical beam tilt as specified in the WNEU Repack Channel CP. An increase in ERP to 700 kW is requested to minimize the loss of service to the height reduction. An interference study using TVStudy 2.2.5 and the same 0.5 km cell size and 1 km terrain profile interval used for the WNEU Repack Channel CP application analysis showed that with the increase in ERP the reduction in interference free population served at the WNEU post-auction temporary antenna location is limited to 1.73 percent. As shown on the attached map, the service area contour of the temporary operation does not exceed the contour authorized in the WNEU Repack Channel CP and the community grade contour continues to encompass Merrimack, NH, WNEU’s community of license. Note the question “Does the proposed antenna propose elevation radiation patterns that vary with azimuth for reasons other than the use of mechanical beam tilt?” was checked “Yes” solely to indicate the presence of an attached xmil file with elevation pattern data to allow accurate analysis of the antenna with mechanical tilt included. Environmental Statement The RF exposure study for the temporary WNEU post-repack facility was updated to reflect the lower antenna height and increased ERP. RF power density from the facility using a combined horizontal and vertically polarized ERP of 1,050 kW was calculated using the procedures described in FCC Office of Engineering and Technology Bulletin 65. Although the antenna is directional, a worst case relative field of 1.0 was used for all azimuth with mechanical down-tilt added at all azimuths. The results provided here, which assume a non- directional azimuth pattern, are worst case for public RF exposure on the ground from the actual antenna. The maximum power density at the site, allowing for 2 meter person height and an additional 20 meter of height to allow for terrain variation and building height is calculated to be 0.0045 mW/cm2 or 1.20% of the FCC maximum permissible exposure level of 0.375 mW/cm2 at 563 MHz for an uncontrolled environment. The tower is secured with a fence and locked gate with required signage. At full power in the main beam, RF power density on towers greater than 137 meters from this facility is calculated to be below occupational exposure levels. There are no towers less than 137 meters from the proposed tower with heights that would put them in the main beam of the antenna. WNEU will coordinate with other users at the site and reduce power or shut down as required to protect workers on this tower from RF exposure above the limits specified in Section1.1310 of the FCC's Rules. Doug Lung June 20, 2019 Page 1 Exhibit prepared by Doug Lung, June 20, 2019 WNEU Request for Engineering STA (continued) Page 2 Exhibit prepared by Doug Lung, June 20, 2019.

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