Engineering Statement W269DO Paducah, Kentucky (Facility ID # 201099) Permitee - Bristol Broadcasting Company, Inc. Application to Modify Construction Permit

By this Application, the Permitee (Bristol Broadcasting Company, Inc.) seeks authority to modify the authorized facilities of FM Translator Station W269DO including changing the antenna/transmitter site, antenna height, and effective radiated power.

Engineering Discussion - Rules Compliance

W269DO will rebroadcast station WPAD(AM) at Paducah, Kentucky (Facility ID # 54720) as a “fill-in” translator. The service contour of Translator Station W269DO with the proposed facilities will not extend outside a circle with a 25-mile radius centered at the WPAD(AM) transmitter site. See Figure 1 “Primary Station Data/Rules Compliance Showing” attached herewith.

As is also shown on Figure 1, the predicted 60 dBu contour of the proposed facility will overlap the 60 dBu contour of the W269DO facilities authorized by construction permit as is required for the filing of a “minor change” application.

The W269DO antenna will be mounted on an existing work platform atop a grain elevator and will require no significant modification to the existing structure.

Contour Overlap Analysis

An analysis of contour overlap to co-channel, adjacent channel, and IF channel facilities created by the instant proposal to operate W269DO on channel 269D (101.7 mHz) was completed. This analysis (see Figure 2) demonstrated that there will be no prohibited contour overlap to any present or proposed facilities with only one exception:

That potential for interference is vis-a-vis WLLE(FM) at Mayfield, Kentucky, operating on the second upper adjacent channel. Second adjacent channel interference is presumed to be caused within a +40 db undesired/desired F(50,10) contour overlap. The WLLE(FM) signal strength at the proposed W269DO tower site was calculated to be 84.0 dBu. Therefore, the W269DO interfering contour would be the 124.0 dbu F(50,10) contour which would extend less than 0.1 kilometer from the antenna and would reach no population. Accordingly, this potential interference area should be waived pursuant to established commission policies.

Based on the foregoing, the instant application complies with all applicable FCC rules regarding interference to other existing or proposed facilities.

Radiofrequency Radiation Exposure and Environmental Considerations

The RF contribution from the proposed 0.250 kW facility with the center of radiation at 15 meters above ground level was evaluated using the Commission's FM Model Program and assuming a “worst case” single bay circularly polarized antenna. The maximum RF contribution of the facility at a height of 2 meters above ground was calculated to be 59.487 µW/cm² at a horizontal distance of 3.48 meters from the tower base. There are no other AM, FM or TV broadcast antennas located in close enough proximity to the proposed site to warrant consideration for RF contribution. The 59.487 µW/cm² RF exposure level is well below the maximum permissible of 200 µW/cm² for general public exposure and the limit of 100 µW/cm² for “controlled” areas, and, therefore, the proposed facility will be in full compliance with the FCC-specified guidelines for human exposure to radiofrequency radiation in both the “controlled” and “un-controlled” environments.

The proposed W269DO antenna will be mounted on an existing structure (grain elevator) with no structural modification necessary and will create no significant visual impact to the grain elevator.

The area at the base of the grain elevator will be secured to prevent unauthorized or accidental access to the area. Signs will be posted warning of potential RF danger. Additionally, the licensee will reduce operating power or cease transmissions entirely to comply with ANSI guidelines whenever persons require access to the area for maintenance or other purposes.

In light of the foregoing, it is clear that the proposed facility will have no significant impact on the environment.

No Concerns About Two Translator Stations Serving Substantially The Same Area While Retransmitting The Signal of The Same Primary Station.

W269DO will retransmit AM Station WPAD at Paducah, Kentucky. FM Translator Station W258AN (Facility ID # 145480) also retransmits WPAD(AM). However, Figure 1 illustrates that with the facilities proposed hereby there would be far less than 50 percent overlap of the predicted 60 dBu contours of W269DO and W258AN. Thus, any concerns about two translator stations serving substantially the same area while retransmitting the signal of the same primary station are eliminated. Since W269DO will be serving a substantial population not served by W258AN, a public interest benefit for W269DO to rebroadcast WPAD(AM) is clearly demonstrated.

-89-15 Cypress -89-00 -88-45 -88-30 -88-15 -88-00 32 Mill Creek Belknap

Karnak 24 Ullin 37-15 Tamms 16 Pulaski Joppa Fredonia Olmsted Qmount Vernon Dycusburg Metropolis Hamletsburg Smithland 8 Brookport Mounds Princeton Kevil La Center 0 W269DO Barlow W258AN Calvert City

37-00 Grand Rivers 8 Fillmore

Wilson City Charleston 16 Wyatt W269DO - Proposed Bardwell Cadiz 24 Benton Anniston

East Prairie 32 Hardin 36-45 Mayfield km 70 60 50 40 30 20 10 0 10 20 30 40 50 60 70 30 -89-15 -89-00 -88-45 -88-30 -88-15 -88-00 Brookport Hamletsburg Smithland

25 Mounds W266CO Prin W266COW266CO Kevil La Center 20 W269DO Barlow W269DOW269DO 15 Calvert City 37-00 Grand Rivers 10 Alfalfa Center Fillmore Birds Point

Wilson City 5 Winford Wyatt 0 W269DO - Proposed Bardwell Laketon 5 Henson Benton Deventer Crosno Berkley 10 Arlington Thirtyfour Corner WLLE Columbus WLLEWLLE Hardin 15 36-45 Wolf Island South Columbus Mayfield 20

Hailwell 25 Clinton 30 km 60 50 40 30 20 10 0 10 20 30 40 50 60

Callsign City State Freq Channel ERP Class Status Distance Clr Watts Kilometer W269DO PADUCAH KY 101.7 269 250 D CP 18.97 -34.80 dB WLLE MAYFIELD KY 102.1 271 50000 C2 LIC 15.39 -25.17 dB WTPR-FM MCKINNON TN 101.7 269 1800 A LIC 74.36 8.93 dB WCMT-FM SOUTH FULTON TN 101.3 267 22000 C3 LIC 56.85 10.20 dB K269GZ SIKESTON MO 101.7 269 250 D LIC 88.2 13.42 dB W269CD PROVIDENCE KY 101.7 269 38 D LIC 91.3 15.96 dB WCIL-FM CARBONDALE IL 101.5 268 28500 B LIC 115.93 16.28 dB W269CE DYERSBURG TN 101.7 269 250 D LIC 117.8 19.98 dB W266CO PADUCAH KY 101.1 266 100 D LIC 24.48 20.27 dB WCMT-FM MARTIN TN 101.3 267 2400 C3 LIC 63.53 21.97 dB