ENGINEERING EXHIBIT Incentive Auction Channel Reassignment
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ENGINEERING EXHIBIT Incentive Auction Channel Reassignment Priority Station Application for Modification of Digital Television Station Construction Permit prepared for Sacramento Television Stations, Inc. KMAX-TV Sacramento, CA Facility ID 51499 Ch. 24 1000 kW 591 m Sacramento Television Stations, Inc. (“STSI”) is the licensee of digital television station KMAX-TV, Channel 21, Facility ID 51499, Sacramento CA. Reassignment of KMAX-TV from Channel 21 to Channel 24 was specified in the Incentive Auction Closing and Channel Reassignment Public Notice (“CCRPN” , DA 17-317, released April 13, 2017). A Construction Permit (“CP” file# 0000029627) authorizes KMAX-TV to operate on Channel 24 at 1000 kW effective radiated power (“ERP”) with a nondirectional antenna at 613 meters height above average terrain (“HAAT”). STSI proposes herein a minor modification of the reassignment CP to reduce the antenna HAAT to 591 m and to utilize a different nondirectional antenna. No other changes are sought. The CP specifies a new antenna system to be top-mounted on the candelabra tower structure associated with FCC Antenna Structure Registration number 1011404. As presently authorized, the KMAX-TV Channel 24 facility would utilize the upper antenna of a stacked antenna system. Now, plans for implementing the reassignment have been finalized and the proposed KMAX-TV Channel 24’s antenna will be the bottom antenna of a stacked system, beneath a new antenna for STSI’s KOVR Channel 25 facility (Facility ID 56550, Stockton CA).1 Thus, KMAX-TV’s Channel 24 operation would utilize the bottom-of-stack location, decreasing 1The existing candelabra antenna stack utilized by KOVR consists of the licensed KOVR Channel 25 antenna beneath KOVR’s former analog Channel 13 antenna, which is no longer in use. Contemporaneously, STSI will submit a separate minor modification application to specify a corresponding increase in antenna height of the KOVR Channel 25 facility. Engineering Exhibit Sacramento Television Stations, Inc. (KMAX-TV) (page 2 of 4) the antenna height by 21.8 meters to 591 meters HAAT. No change to the overall structure height will result. The proposed antenna is an elliptically polarized nondirectional Dielectric model TFU- 29JSC/VP-R O4 (24 percent vertical polarization). The horizontally polarized ERP is 1000 kW and the vertically polarized ERP is 240 kW. Figure 1 supplies a map that demonstrates compliance with §73.625(a)(1) regarding coverage of the entire principal community. The proposed facility’s predicted population exceeds 95 percent of the CCRPN baseline facility’s population. At 1000 kW ERP and 613 m HAAT, the presently authorized KMAX-TV noise limited service contour (“NLSC”) extends beyond that of the CCRPN facility and resulted from a minor modification application filed during the priority filing window. 2 The modification sought herein to reduce antenna HAAT to 591 meters provides an NLSC which also exceeds that of the CCRPN facility (910 kW ERP at 581 m HAAT) but is within that of the present authorization. Interference study per FCC OET Bulletin 69 3 shows that the proposal complies with the 0.5 percent limit of new interference caused to pertinent nearby post-auction full service and Class A television stations and reassignments as required by §73.616. The interference study output report is provided as Table 1. The proposed 1000 kW ERP exceeds the maximum allowed for the proposed antenna HAAT of 591 meters permitted by §73.622(f)(8)(i). Section 73.622(f)(5) permits the maximum ERP to be exceeded in order to provide the same geographic coverage area as the largest station 2“Incentive Auction Task Force and Media Bureau Announce the Opening of the First Priority Filing Window for Eligible Full Power and Class A Television Stations from August 9 through September 8, 2017” Public Notice, DA 17-724, released July 31, 2017. 3FCC Office of Engineering and Technology Bulletin number 69, Longley-Rice Methodology for Evaluating TV Coverage and Interference , February 6, 2004 (“OET-69”). This analysis employed the FCC’s current “TVStudy” software with the default application processing template settings, 2 km cell size, and 1 km terrain profile increment. Comparisons of various results of this computer program (run on a Mac processor) to the FCCs implementation of TVStudy show excellent correlation. Engineering Exhibit Sacramento Television Stations, Inc. (KMAX-TV) (page 3 of 4) within the same market. As demonstrated in Figure 2, the total area within the proposed KMAX-TV NLSC is 45,435 square kilometers, which does not exceed the 47,544 sq. km NLSC area of KXTV (Ch. 10, Sacramento CA, BLCDT-20120201AAM). Thus, the 1000 kW ERP specified herein is in compliance with §73.622(f)(5). The nearest FCC monitoring station is 61 km distant at Livermore, CA. Using the FCC propagation curves, the proposed F(50,90) signal level at the monitoring station is 4.6 mV/m, which is below the 10 mV/m threshold of §73.1030(c) for further analysis. The site is not located within the areas requiring coordination with “quiet” zones specified in §73.1030(a) and (b). The site location is beyond the border areas requiring international coordination. There are no authorized AM stations within 3 kilometers of the site. Human Exposure to Radiofrequency Electromagnetic Field (Environmental) The proposed operation was evaluated for human exposure to RF energy using the procedures outlined in the FCC’s OET Bulletin Number 65. Based on OET-65 equation (10), and considering 10 percent antenna relative field in downward elevations (pattern data shows less than 10 percent relative field at angles 10 to 90 degrees below the antenna), the calculated signal density near the tower at two meters above ground level attributable to the proposed facility is 1.2 µW/cm 2, which is 0.3 percent of the general population/uncontrolled maximum permitted exposure limit. This is well below the five percent threshold limit described in §1.1307(b) regarding sites with multiple emitters, categorically excluding the applicant from responsibility for taking any corrective action in the areas where the proposal’s contribution is less than five percent. The general public will not be exposed to RF levels attributable to the proposal in excess of the FCC’s guidelines. RF exposure warning signs will continue to be posted. With respect to worker safety, the applicant will coordinate exposure procedures with all pertinent stations and will reduce power or cease operation as necessary to protect persons having access to the site, tower, or antenna from RF electromagnetic field exposure in excess of FCC guidelines. This exhibit is limited to the evaluation of exposure to RF electromagnetic field. No increase in structure height is proposed. Engineering Exhibit Sacramento Television Stations, Inc. (KMAX-TV) (page 4 of 4) List of Attachments Figure 1 Proposed Coverage Contours Figure 2 Maximum ERP power §73.622(f) Table 1 TVStudy Analysis of Proposal Form 2100 Saved Version of Engineering Sections from FCC Form at Time of Upload Chesapeake RF Consultants, LLC Joseph M. Davis, P.E. January 10, 2019 207 Old Dominion Road Yorktown, VA 23692 703-650-9600 \ 0 \0 0\ 0\0\\ 0\0\\0\0\\ \00\\0\0\0\0 \\0\ \\00\\0\0 \00\\00\00\\0\ Butte \\0\00\\0\\00\\ Chesapeake RF Consultants, LLC \\0\00\\0\\00\\ \00\\00\00\\0\ Radiofrequency Consulting Engineers Figure 1 \\00\\0\0\\0\\ Glenn \00\\0\0\0\0 Sierra 0\0\\0\0\\ Digital Television and Radio 0\0\\0\0 \ 0\0 Proposed Coverage Contours KMAX-TV Sacramento, CA 0° Storey Mendocino Nevada Facility ID 51499 Ch. 24 1000 kW 591 m Colusa Sutter Lake Carson City prepared for 315° Yuba Placer45° Sacramento TelevisionLyon Stations, Inc. Douglas Proposed KMAX-TV 48 dBµ January, 2019 (Principal Community) 41 dBµ (Noise Limited Service Contour) El Dorado Sacramento,Yolo CA Alpine Sonoma Napa Sacramento Amador Solano 270° 90° Marin Calaveras Tuolumne San Joaquin Contra Costa Mono San Francisco Stanislaus Alameda San Mateo Mariposa 225° 135° Merced Santa Clara Area PopulationSanta Cruz Madera Proposed Digital Coverage (sq. km) (2010 Census) 180° Within Noise Limited Service Contour 45,435.4 10,707,241 OET Bulletin 69: TVStudy Scale 1:1,750,000 Within noise limited contour 47,465.2 10,767,605 km Not affected by terrain losses 40,624.7 7,132,240 0 20 40 60 Lost to all interference 251.3 10,264 V-Soft Communications LLC ® © Net Interference-Free Service 40,373.4 7,121,976 Fresno \ 0 \0 0\ 0\0\\ 0\0\\0\0\\ \00\\0\0\0\0 \\0\ \\00\\0\0 \00\\00\00\\0\ Butte \\0\00\\0\\00\\ Chesapeake RF Consultants, LLC \\0\00\\0\\00\\ \00\\00\00\\0\ Radiofrequency Consulting Engineers Figure 2 \\00\\0\0\\0\\ Glenn \00\\0\0\0\0 Sierra 0\0\\0\0\\ Digital Television and Radio 0\0\\0\0 \ 0\0 Maximum ERP per §73.622(f) KMAX-TVStorey Sacramento, CA Mendocino Nevada Facility ID 51499 Ch. 24 1000 kW 591 m KXTV Ch. 10 Sacramento, CA BLCDT-20120201AAM Colusa Sutter 36 dBµ ContourLake (NLSC) Carson City prepared for Area: 47,544 sq. km Yuba Placer Sacramento TelevisionLyon Stations, Inc. Douglas Proposed KMAX-TV January, 2019 41 dBµ Contour (NLSC) Area: 45,435 sq. km El Dorado Yolo Alpine Sonoma Napa Sacramento Amador Solano Marin Calaveras Tuolumne San Joaquin Contra Costa Mono San Francisco Stanislaus Alameda San Mateo Mariposa Merced Santa Clara Santa Cruz Madera Scale 1:1,750,000 km 0 20 40 60 V-Soft Communications LLC ® © Fresno Table 1 KMAX-TV TVStudy Analysis of Proposal (page 1 of 4) tvstudy v2.2.5 (4uoc83) Database: localhost, Study: KMAX-TV Bottom-1000kW, Model: Longley-Rice Start: 2019.01.09 15:36:35 Study created: 2019.01.09 15:36:35 Study build station data: LMS TV 2019-01-09 Proposal: KMAX-TV D24 DT APP SACRAMENTO, CA File number: KMAX-TV Bottom-1000kW Facility ID: 51499 Station data: User record Record ID: 2455 Country: U.S.