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L.A. SOCIAL JUSTICE RADIO PROJECT 844.REC.LPFM/202.621.2355 BLL-20190620AAP Recnet.Com

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L.A. SOCIAL JUSTICE RADIO PROJECT 844.REC.LPFM/202.621.2355 BLL-20190620AAP Recnet.Com REC Networks Minor modification for KSXS-LP 11541 Riverton Wharf Rd. LOS ANGELES (CHATSWORTH), CA Mardela Springs, MD 21837 L.A. SOCIAL JUSTICE RADIO PROJECT 844.REC.LPFM/202.621.2355 BLL-20190620AAP recnet.com PROPOSED 60dBu F(50,50) SERVICE CONTOUR LOS ANGELES, CA – Channel 300L1 (107.9 MHz) ~ ERP 0.002 kW Elev: 689 meters ~ RCAGL: 7 meters ~ RCAMSL: 696 meters ~ HAAT: 280 meters (GLOBE) Overall tower height: 8 meters – ASR: No nearby airports NAD83 Latitude: 34° 15’ 24.1” NL – Longitude: 118° 38’ 26.8” WL NAD27 Latitude: 34° 15’ 24.1” NL – Longitude: 118° 38’ 23.5” WL No AM stations within 3 km of proposed site. WAIVER REQUEST – Contingent on concurrent grant of modification for KNJR-LP R E C NETWORKS CHANNEL REPORT NAD27 LATITUDE: 34 - 15' 24.1" - LONGITUDE: 118 - 38' 23.5" CHANNEL: 300 - CLASS: LP100 CHAN FREQ CALL LOCATION CLS DIST REQ CLEAR BEAR ----------------------------------------------------------------------------------- 297 107.3 TIJUANA BN C1 255.6 73.0 182.6 140.3 : ----------------------------------------------------------------------------------- 297 107.3 XHFG-FM TIJUANA BN C1 255.7 73.0 182.7 140.3 : ----------------------------------------------------------------------------------- 298 107.5 KLVE LOS ANGELES CA B 52.8 67.0 -14.2 93.2 : UNIVISION RADIO STATIONS GROUP, INC. : See second-adjacent channel waiver request. ----------------------------------------------------------------------------------- 298 107.5 KLVE-FM1 SANTA CLARITA CA D 9.0 6.0 3.0 24.7 : UNIVISION RADIO STATIONS GROUP, INC. ----------------------------------------------------------------------------------- 299 107.7 KIST-FM CARPINTERIA CA B1 114.5 74.0 40.5 284.1 : RINCON BROADCASTING LS LLC ----------------------------------------------------------------------------------- 300 107.9 KNJR-LP THOUSAND OAKS CA L1 21.2 24.0 -2.8 259.4 : CONEJO RADIO MINISTRIES : This facility will be abandoned by the instant application for KNJR-LP filed in : conjunction with the instant application for KSXS-LP. ----------------------------------------------------------------------------------- 300 107.9 KSXS-LP LOS ANGELES CA L1 3.5 24.0 -20.5 126.5 : THE LOS ANGELES SOCIAL JUSTICE RADIO PROJECT : KSXS-LP currently authorized facility. ----------------------------------------------------------------------------------- 300 107.9 KWVE-FM SAN CLEMENTE CA B 118.9 112.0 6.9 120.4 : CALVARY CHAPEL OF COSTA MESA ----------------------------------------------------------------------------------- 300 107.9 KNJR-LP THOUSAND OAKS CA L1 20.4 24.0 -3.6 247.0 : CONEJO RADIO MINISTRIES : Proposed facility and waiver request. Mutual short-spacing with KSXS-LP. ----------------------------------------------------------------------------------- 300 107.9 KUZZ-FM BAKERSFIELD CA B 131.4 112.0 19.4 356.0 : BUCK OWENS PRODUCTION COMPANY, INCORPORATED ----------------------------------------------------------------------------------- 300 107.9 KOXC-LP OXNARD CA L1 46.7 24.0 22.7 260.5 : CENTRO EVANGELICO EMMANUEL, INC. ----------------------------------------------------------------------------------- 300 107.9 KQRU-LP SANTA CLARITA CA L1 23.9 24.0 -0.1 35.3 : SANTA CLARITA ORGANIZATION FOR PLANNING THE ENVIRONMENT ----------------------------------------------------------------------------------- JOINT REQUESTS FOR WAIVERS OF §73.807(a) and §73.816 KSXS-LP Los Angeles, CA Channel 300L1 (107.9 MHz) For KSXS-LP, the proposed modification will extend the distance from second-adjacent channel short-spaced station KLVE, Los Angeles, CA. The proposed modification will also create a new mutual co-channel short-spacing under §73.807(a) between cooperating LPFM stations, KNJR-LP, Thousand Oaks and KSXS-LP, Los Angeles. We will address each short-spacing herein. In respect to KLVE (KSXS-LP application only) KLVE operates on Channel 298B with 29.5 kW at 914 meters above average terrain into a non- directional antenna. KLVE places a 74.5 dBu protected contour at the proposed KSXS-LP site. Using the U/D method1, the proposed LPFM station is predicted to produce an undesired interference overlap in respect to KLVE to the proposed LPFM station’s 114.5 dBu interfering contour (“overlap zone”). At 2 watts ERP, the overlap zone extends to 19 meters from the radiation center. The proposed location is a major transmission site for land mobile radio, FM booster stations KWSV-LP-FM1 and KMRO-FM3 as well as international broadcast station KVOH. The only “structures” within 19 meters of the antenna is transmission equipment cabinets. The nearest occupied structure is 136 meters away at an elevation of 60 meters lower. Based on these findings, the proposed modified LPFM station will continue to not create any interference with KLVE. Los Angeles Social Justice Radio Project (SJRP) is requesting a waiver of §73.807(a) in respect to second-adjacent channel short-spaced station KLVE, Los Angeles, California. In respect to short-spacing between KNJR-LP and KSXS-LP Both KSXS-LP and KNJR-LP operate on Channel 300L1. Currently, these stations meet the minimum distance separations required between two LPFM stations in accordance with §73.807(a) of the Commission’s Rules. In the instant applications, both KSXS-LP and KNJR- LP wish to simultaneously make moves to locations that would not meet the minimum distance separations between two LPFM stations. 1 - See Living Way Ministries, Inc. Memorandum Opinion and Order, 17 FCC Rcd 17054, 17056 (2002) at 5. Recon denied 23 FCC Rcd 15070 (2008). In the instant case, both KSXS-LP and KNJR-LP are both facing site availability issues meaning their needs to relocate is eminent. In the case of KSXS-LP, despite an original finding of approved zoning and use, the authority to operate from this site has been revoked by the City of Los Angeles. In the case of KNJR-LP, the need to move from the current site as caused by a private dispute between the licensee and the property owner. Therefore, both stations have an immediate need to relocate. We also note that KNJR-LP has been licensed since 2007 and with the exception of the entire year 2018, has been operating continuously ever since. KSXS-LP is a newly licensed station. The station did complete construction and then faced subsequent opposition from the City of Los Angeles, spurred by the influence of an adjacent property owner. In the wake of the pressure from the City of Los Angeles, SJRP, in coordination with REC Networks (REC) has been searching for alternate sites that could be used to maintain the radio service. The site that was originally chosen by SJRP was a very unique site where there were no occupied structures within close distance to the east and south. This made it a good candidate site, that, in a normally densely populated part of the San Fernando Valley, it would allow the station to properly protect short-spaced second adjacent channel station KLVE. Due to the dense population and multi-story structures in the west San Fernando Valley compounded by the field strength of KLVE at potential sites, the ability to find another viable site within the area that would otherwise meet all §73.807(a) co-channel and first-adjacent channel minimum spacing has proven to be fruitless. To address this issue, REC reached out to Strategic Communications Group, owner of the transmission site at Chatsworth Peak. As a result, REC was able to obtain site assurance for SJRP to be able to move KSXS-LP to this site if a waiver can be obtained from the Commission to allow for the short-spacing of two LPFM stations. CRM has received assurance at their proposed site on their own without interaction with REC. In studies conducted by REC, it has been determined that because of intervening terrain, the operation of KSXS-LP at its proposed waiver site would not cause significant interference with KNJR-LP within their service contour and vice versa. Interference can be further reduced through the utilization of Nicom BKG-series antenna, which based on manufacturer’s specifications has a directional characteristic. By orienting a proposed KSXS-LP BKG antenna at 95 degrees and a similar antenna at KNJR-LP at a rotation of 260 degrees, not only will it reduce interference but it would also eliminate contour overlap between the two short-spaced stations. If KSXS-LP and KNJR-LP were FM translators, this specific arrangement would be allowed. In 2000, Making Appropriations for the Government of the District of Columbia for 2001 also known as the Radio Broadcast Protection Act was signed into law.2 In Section 632(a)(1)(A), the RBPA directs the Commission to prescribe minimum distance separations for third-adjacent channels (as well as for co-channels, and first- and second-adjacent channels).3 In the LPFM 2 - Pub L. No. 106-553, 114 Stat 2762 (2000) (“RBPA”). 3 - See RBPA at §632(a)(1)(A). Second Report and Order that implemented this statute, the Commission added required third- adjacent channel distance separation towards full-power (full-service) FM and FM translator stations but did not implement any required second- or third- adjacent channel protections towards other LPFM stations thus implying an interpretation that the RBPA did not apply to LPFM to LPFM protection relationships.4 Later, in 2011, when the Local Community Radio Act of 20105 was enacted, the Section 632 language was changed to prescribe protection for co- channels and first- and second- adjacent channels.6 Further, the requirement for the use of minimum distance separation was clarified to state that co-channel, first- and second-adjacent channel distance separations
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