ENGINEERING EXHIBIT Incentive Auction Channel Reassignment
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ENGINEERING EXHIBIT Incentive Auction Channel Reassignment Application for Modification of Digital Television Station Construction Permit prepared for Hearst Properties Inc. WPXT(DT) Portland, ME Facility ID 53065 Ch. 34 500 kW 590 m Hearst Properties Inc. (“Hearst”) is the licensee of digital television station WPXT(DT), Channel 43, Facility ID 53065, Portland, ME. Reassignment of WPXT from Channel 43 to Channel 34 was specified in the Incentive Auction Closing and Channel Reassignment Public Notice (“CCRPN”, DA 17-317, released April 13, 2017). Hearst herein proposes modification of the WPXT Channel 34 Construction Permit (“CP”, file# 0000034514). The CP authorizes operation at 190 kW effective radiated power (“ERP”) nondirectional at 267 meters antenna height above average terrain (“HAAT”). Hearst proposes herein to relocate WPXT 34.9 km from the currently authorized site and operate with an ERP of 500 kW directional and 590 meters antenna HAAT. The proposed WPXT operation will employ a new antenna system to be side-mounted on an existing tower structure associated with FCC Antenna Structure Registration (“ASR”) number 1045602. No change to the overall structure height will result. The proposed antenna is an elliptically polarized directional Dielectric model TFU- 16DSB/VP-F OS (25 percent vertical polarization). The maximum horizontally polarized ERP is 500 kW and the maximum vertically polarized ERP is 125 kW. The vertically polarized component will not exceed the horizontally polarized component at any azimuth. The directional antenna’s azimuthal patterns are depicted in Figures 1 and 1A, and the elevation pattern is provided in Figure 2. Engineering Exhibit Hearst Properties Inc. (WPXT) (page 2 of 5) Figure 3 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. Interference study per FCC OET Bulletin 691 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. FCC processing of this proposal is requested using a 2 km cell size and 0.2 km terrain profile increment. The interference study output report is provided as Table 1. Additional interference analysis shows that the proposed WPXT facility will not result in the displacement of any authorized or proposed Low Power Television or Television Translator facility, including any authorizations or pending applications that arose during the Special Displacement Window.2 The site location is 142.5 km to the U.S. – Canada border, within the international coordination zone. According to “TVStudy” analysis including non-US records from current FCC LMS data, no Canadian station would receive any new interference from the proposed WPXT facility. The proposed 500 kW ERP exceeds the maximum permitted by §73.622(f)(8)(i) for the proposed antenna HAAT of 590 meters. 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 within the same market. As demonstrated in Figure 4, the total area within the proposed WPXT noise limited service contour (“NLSC”) is 24,630 square kilometers, which does not exceed the NLSC area of WMTW(DT) (47,552 sq. km, Ch. 8, Poland Spring ME, BLCDT-20090622ACH). Thus, the 500 kW ERP specified herein complies with §73.622(f)(5). 1FCC 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 0.2 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. 2“Incentive Auction Task Force and Media Bureau Announce Post-Incentive Auction Special Displacement Window April 10, 2018, through May 15, 2018, and Make Location and Channel Data Available,” Public Notice, DA 18-124, released February 9, 2018. Engineering Exhibit Hearst Properties Inc. (WPXT) (page 3 of 5) Owing to the 34.9 km relocation distance, the proposed WPXT NLSC will extend beyond that of the existing CP in many directions. A coverage contour comparison map, Figure 5, shows the NLSC gain and loss areas. Although the FCC’s NLSC expansion “freeze” Public Notice 3 of April 5, 2013 (DA 13-618) should not be applicable to reassigned stations such as WPXT, if a waiver of the freeze is necessary then one is requested on behalf of Hearst . The applicant is supplying a separate statement that provides justification for the change in transmitting site location and corresponding NLSC extension. The change in site location would co-locate WPXT with Hearst’s station WMTW. The WPXT antenna will be side-mounted on the WMTW tower structure, which is owned by Hearst . The tower structure specified in the WPXT CP is owned by another party and would require ongoing rental payment for antenna and equipment space. The antenna’s directional pattern is a custom configuration that was developed to match the existing NLSC area to the extent possible. The main directional lobe is oriented at 95° True North, towards the most distant point of the authorized NLSC as well as the principal community of Portland. The power on the backside of the pattern (to the west) is suppressed considerably in order to minimize contour extension in that direction, and the pattern shape on the sides (north and south) is reduced also to minimize contour extension there (see the pattern azimuthal plot in Figure 1). Even with the manufacturer’s best efforts, practical limitations in antenna design result in unavoidable contour extensions on the sides and rear of the pattern due to the 34.9 km change in site location. While an ERP of 700 kW would be needed in the main lobe for the proposed NLSC to reach all of the authorized NLSC to the east, the proposed ERP was set to 500 kW to help reduce the amount of contour extension elsewhere. The proposed ERP of 500 kW results in a minor loss area along the eastern portion of the authorized NLSC. The proposed WPXT facility’s NLSC encompasses 24,629.6 sq. km (18,359.1 sq. km land area) and 991,112 persons (2010 Census). This is an increase over the authorized WPXT 3“Media Bureau Announces Limitations on the Filing and Processing of Full Power and Class A Television Station Modification Applications, Effective Immediately, and Reminds Stations of Spectrum Act Preservation Mandate,” DA 13-618, Public Notice, released April 5, 2013. Engineering Exhibit Hearst Properties Inc. (WPXT) (page 4 of 5) NLSC, which encompasses 19,856.1 sq. km (14,512.6 sq. km land area) and 421,678 persons. The authorized post-repack NLSC of nearby stations which overlap that of the authorized and proposed WPXT are provided on Figure 5 to demonstrate the availability of other services. The area of WPXT’s NLSC loss consists of 199.8 sq. km of land area containing a population of 5,937 persons (0.60% of the total population within the proposed NLSC), and is within the NLSC of seven or more post-repack facilities. WPXT is an affiliate of the CW network. Overlapping same-network (CW) station coverage contours are supplied on Figure 6. All of the loss area is within the NLSC of another CW network station. The proposed WPXT facility would provide new CW service to an area of 3,195.7 sq km containing 130,668 persons. 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 20 percent antenna relative field in downward elevations (pattern data shows less than 20 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 3.7 µW/cm 2, which is 0.9 percent of the general population/uncontrolled maximum permitted exposure limit. This is 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 Hearst Properties Inc. (WPXT) (page 5 of 5) List of Attachments Figure 1, 1A Antenna Azimuthal Pattern Figure 2 Antenna Elevation Pattern Figure 3 Proposed Coverage Contours Figure 4 Maximum ERP per §73.622(f) Figure 5 Coverage Contour Comparison – Loss Area Alternate Services Figure 6 Coverage Contour Comparison – CW Network Gain Area 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. November 21, 2018 207 Old Dominion Road Yorktown, VA 23692 703-650-9600 0 330 30 1.0 AZIMUTH PATTERN 0.9 Horizontal Polarization 0.8 In Free Space 0.7 Proposal No.