KXLK-CD License Certification Exhibit.Pdf
Total Page:16
File Type:pdf, Size:1020Kb
License Certification Exhibit prepared 6/18/2020 for Univision Local Media, Inc. KXLK-CD Austin, TX Channel 14 15 kW-DA 295m HAAT Univision Local Media, Inc., licensee of KXLK-CD, Austin, Texas, (“KXLK-CD”) provides notices that it has completed construction of the KXLK-CD post-auction facility pursuant to construction permit file number 0000115517. The stations construction permit included two special conditions; the notification of health care facilities potentially affected by DTV operations, and conducting equipment tests to identify and substantially eliminate objectional interference, along with documentation that objectional interference to existing land mobile radio facilities in the 460 MHz to 470 MHz band will not be caused. Pursuant to § 73.1610 of the Commission’s rules, KXLK-CD has conducted equipment tests commencing June 1, 2020. These equipment tests consisted of 5 days of operation for 4 - 8 hours per day and subsequent to June 5, 2020, continuous operation. Equipment test included station’s legal ID and contact information for any inquiries or reports. Subsequently the station requested and received program test authority, and on June 16th, 2020 the station commenced program tests. Multiple inquiries were received during the ongoing tests and no reports of interference to land mobile radio licensees were received. In addition, KXLK-CD conducted extensive efforts to notify any land mobile radio licensees within and well beyond the KXLK-CD contour. Multiple responses to these notifications were received, and each inquiring licensee was again notified upon the commencement of equipment tests with instructions to report any evidence of interference. This information and the following attachments are submitted as evidence that no objectionable interference to protected land mobile radio licensees is occurring and to document compliance with the stations construction permit special conditions. List of Attachments: 1. LMR Interference Protection Engineering Report 2. Protected LMR Licensee Notification Letter 3. LMR Licensee Notification List 4. DTV Medical Notification Package Attachment 1 Land Mobile Radio Interference Analysis Report for Univision Local Media, Inc. Television Station KXLK-CD, Channel 14 Austin, TX Regarding Potential Out of Band Emissions and Signal Overload into Land Mobile Operations below Channel 14 and around the Austin, Texas, area Rev. 01 May 20, 2020 Prepared by: Joseph L. Snelson, Jr CPBE Meintel, Sgrignoli, & Wallace, LLC 1282 Smallwood Drive Suite 372 Waldorf, Maryland 20603 (202) 251-7589 INTRODUCTION and BACKGROUND This revised report has been prepared for Univision Local Media, Inc., licensee of Class A television station KXLK-CD ("KXLK"), licensed to serve Austin, Texas. KXLK holds a Construction Permit, FCC File Number 0000107928, to construct its post-auction facility on channel 14. Pertinent authorized technical parameters can be found in Table 1 of this report. As stated in the Construction Permit the following condition must be met: During equipment tests, authorized by Section 73.1610 of the Commissions Rules, the permittee shall take adequate measures to identify and substantially eliminate objectionable interference which may be caused to existing land mobile radio facilities in the 460 to 470 MHz band. Documentation that objectionable interference will not be caused to existing land mobile radio facilities shall be submitted along with the request for Program Test Authority. Program tests shall not be commenced under Section 73.1620(a) of the Commissions Rules and may only be started after specific authority is granted by the Commission. An application for a license must be filed within 10 days after the start of program tests. MSW prepared a report dated February 11, 2019 evaluating the potential impact that KXLK operations may have on any active authorized Land Mobile ("LM") operations below channel 14. This report reflects a revision of the initial report. Revisions include a change in the location of KXLK's channel 14 transmitter site and a change in antenna height. This study also utilized measurement data taken at the time the proof-of-performance was performed on the transmitter. Specifically, the measured Out-Of-Band-Emissions ("OOBE") response for the transmitter and post-transmitter filter were used in this study for determining potential interference and signal overload into Land Mobile operations below cannel 14. Similar to the initial study that was performed, this study also focused on a circular area with a radius of 176 km and a center point being the transmitter site coordinates as stated in KXLK's Construction Permit. There were 8,974 authorized LM facilities identified inside this circular area and studied. EXECUTIVE SUMMARY MSW studied the predicted KXLK OOBE interference into authorized LM stations operating below TV channel 14. The potential impact that KXLK might have on LM receiver overload were also studied. Based on the results of the study the following conclusions were reached. 1. Utilization of a 12-Section post-transmitter filter, as installed, will be effective in significantly reducing OOBE and protecting current LM operations. 2. There were no cases of OOBE interference into Land Mobile operations reported. 1 3. There were only three cases of potential LM receiver signal overload reported. The frequencies of the reported cases are between 461.0500 and 463.9250 MHz. The amount of overload margin is greater than -1 dB. Additionally, with there being over 6 MHz of spacing from the band edge of TV channel 14 (470 MHz) overload is unlikely. In the event, however, any overload issues are reported, overload should be able to be remediated with the use of TV channel 14 pre-filtering between the LM antenna and receiver. 4. Based on the above, KXLK should be able to operate on channel 14 and provide sufficient OOBE interference and signal overload protection to authorized LM facilities. 5. This report serves as a documented showing of the measures taken to identify and eliminate objectionable interference and overload into existing LM facilities in the 460 to 470 MHz band and satisfies the requirement under the Special/Waiver Condition section of the Construction Permit. SCOPE OF STUDY AND METHODOLOGY The scope of this study consists of two parts with each part analyzing the impact of potential KXLK OOBE interference into an LM receiver and LM receiver desensitization ("overload") due to a television station operating in the adjacent band at a power level significantly higher than that of LM base or mobile stations. The first part is a general study that is theoretical in nature and based on a single LM station, both fixed and mobile, operating on a frequency close to the channel 14 band edge with default operating parameters (i.e. antenna height, bandwidth, etc.). This serves as a worse case condition and serves as an indicator of the effectiveness of post-transmitter filtering and antenna radiation characteristics in protecting current and possible future LM operations. The parameters used for the television station are found in Table 1 and the generic parameters used for both fixed and mobile LM operations are found in Table 2 of this report. An interference study was performed using the Longley-Rice Irregular Terrain Model “”to predict interference caused by OOBE from the television station into both fixed and mobile LM operations using the generic parameters. The study focused on a circular area with a radius of 176 km from a center point with coordinates of the television station transmitter site. The circular area was divided into cells with a size of approximately 1 km per side. The assumed LM receiver location was considered to be at the geographic center of the cell. A path profile was created between the television transmitter site and the cell center followed by the ITM analysis. The loss from the OOBE post-transmitter filter, at the LM station frequency, was added to the coupling factor, calculated from the bandwidth of the LM station and the 500 kHz measurement bandwidth used for digital television stations, to the received field strength. LM antenna gain and line loss were then added to the field strength. 2 Overload calculations were performed by using the free space loss from the television transmit antenna to the cell center point. The received power level in the direction of the cell included losses due to terrain, calculated antenna azimuth and elevation discrimination, cross polarization, and coupling losses based on the bandwidth of the LM station and the 3dB half- power bandwidth of the television station (approximately 5.38 MHz). LM antenna gain and assumed transmission line loss for fixed base stations was also considered. The second part of the study consisted of analyzing interference and overload into currently authorized fixed and mobile LM facilities. A list of potentially impacted LM facilities was created from the FCC's Universal Licensing System ("ULS") database by searching for all active and licensed LM facilities within a culling distance of 176 km from the television station. The area studied is shown in Appendix 1 of this report. Interference and overload calculations were performed similar to the cell analysis described for the first part except the authorized LM facilities (e.g. frequency, antenna height, etc.) were utilized. Other study parameters utilized in the study, including ITM parameters, are shown in Table 3. Tables 4 and 5 are example calculations for both the interference and overload for one of the fixed base stations studied. The purpose of these examples is to show how the study calculations were performed. For authorized mobile LM operations a study was conducted similar to the general cell area study discussed above. A circular area was defined using the radius of operation for the mobile LM facility as authorized. If no radius was defined a default radius of 48 km was used. The center point used was the coordinates of the mobile LM operation as authorized. The circular area was divided into 1 km/side cells and calculations were made at the geographic center of each cell.