D:\KPTZ\KPTZ 220A Mod Engineering Dec 2020.Wpd

$D:\KPTZ\KPTZ 220A Mod Engineering Dec 2020.Wpd$

December 2020 KPTZ(FM) Channel 220A Port Townsend, Washington Allocation Study

Background The instant application proposes a site change for FM station KPTZ, which operates on Channel 220A in the reserved band.

Spacing Study The attached spacing study shows the co-channel and adjacent channel spacing between stations and demonstrates that the proposed operation meets the adjacent channel spacing requirements to existing domestic stations on IF channels and on Channels 221 to 223 as prescribed in §73.207 of the Commission's Rules

The attached allocation study map exhibits demonstrate requisite contour protection for the following domestic stations per §73.509 of the Commission’s Rules: First-adjacent: KSVR 219A Mount Vernon KYFQ 219C1 Tacoma

Second-adjacent: KSQM 218A Sequim

CBU-FM-1 221C Victoria, British Columbia The proposed operation is short-spaced to Canadian station CBU-FM-1 which operates on Channel 221C at Victoria, British Columbia. Under the terms of the Working Arrangement for the Allotment and Assignment of FM Broadcasting Channels Under the Agreement Between the Government of Canada and the Government of the United States of America Relating to the FM Broadcasting Service , as amended in 1997 (" Working Arrangement "), the required first-adjacent-channel Class A to Class C spacing is 182 kilometers, whereas the distance between the proposed KPTZ site and the CBU-FM-1 site is 87 kilometers. The attached allocation study map demonstrates that the proposed KPTZ 48 dBu F(50,10) contour will not overlap any Canadian land areas. Therefore, this proposal satisfies the requirements of the Working Arrangement with respect to CBU-FM-1.

Hatfield & Dawson Consulting Engineers CKAY-FM 219C1 Gibsons, British Columbia The proposed operation is short-spaced to Canadian station CKAY-FM which operates on Channel 219C1 at Gibsons, British Columbia. Under the terms of the Working Arrangement , the required first-adjacent-channel Class A to Class C spacing is 168 kilometers, whereas the distance between the proposed KPTZ site and the CKAY-FM site is 145 kilometers. The attached allocation study map demonstrates that the proposed KPTZ 48 dBu F(50,10) contour will not overlap any Canadian land areas. Therefore, this proposal satisfies the requirements of the Working Arrangement with respect to CKAY-FM.

CJZN-FM 217C Victoria, British Columbia The proposed operation is short-spaced to Canadian station CJZN-FM which operates on Channel 217C at Victoria, British Columbia. Under the terms of the Working Arrangement , the required third-adjacent-channel Class A to Class C spacing is 101 kilometers, whereas the distance between the proposed KPTZ site and the CJZN-FM site is 74 kilometers. The attached allocation study map demonstrates that the proposed KPTZ 220A 94 dBu F(50,10) contour will not overlap any Canadian land areas. Therefore, this proposal satisfies the requirements of the Working Arrangement with respect to CJZN-FM.

Waiver Requested re Overlap Received From CBU-FM-1 The proposed KPTZ facility will receive overlap from the CBU-FM-1 54 dBu F(50,10) contour, amounting to 100% of the proposed KPTZ 60 dBu F(50,50) contour land area.

Because the received overlap in this case is not from a domestic station or allotment, the received overlap prohibitions of §73.509 are not strictly applicable to the overlap received by KPTZ from CBU-FM-1. Application of §73.509 is limited to “overlap of signal strength contours with any other station licensed by the Commission and operating in the reserved band...” (emphasis added). Therefore, waiver of the received overlap prohibitions of §73.509 is not believed to be an absolute requirement. However, if the staff determines that a waiver of the applicable portions of §73.509 is required, it is explicitly requested for the contour overlap which would be received by the proposed KPTZ facility.

Hatfield & Dawson Consulting Engineers The predicted interference received from CBU-FM-1 would limit modified non-commercial service which the applicant proposes, but not eliminate it. Much of the KPTZ coverage area would be preserved despite the predicted interference (much of which would in any case occur over water areas of Puget Sound and the Strait of Juan de Fuca).

In Northern Sound Public Radio , 4 FCC Rcd 5495 (1989), the Commission permitted the creation of a new non-commercial educational FM station, receiving interference from an operating Canadian station, despite 100% overlap from a Canadian station’s interfering contour. The 100% overlap sought herein is substantially identical to the 100% waiver granted in Northern Sound Public Radio .

Similar waivers in the Puget Sound area have been subsequently granted to KBCS 217C3 Bellevue for co-channel interference (see BPED-19880712MW, BPED-19960520MA, BPED-20000721ABJ, BMPED-20010119AFC, and BPED-20020816AAM), to KSER 214A for first-adjacent-channel interference (see BPED-19970515MB), and to KEXP 212C3 for first-adjacent-channel interference (see BPED-20011016AAR and BPED-20050331BCK). Indeed, the current KPTZ facility operates under such a waiver. The instant application seeks to modify the KPTZ tower location, ERP, and antenna pattern, and so presents a simple case for continued waiver.

Based on the foregoing, grant of the waiver requested in this application would be consistent with precedent established in the Northern Sound Public Radio , KBCS, KSER, and KEXP cases, and should be granted for precisely the same reasons that the previous waivers were granted. Therefore, the applicant respectfully requests waiver, if required, of the received interference provisions of §73.509 of the Commission’s Rules with respect to CBU-FM-1 Channel 221C Victoria.

TV Channel 6 Section 73.525 of the Commission’s Rules specifies a threshold distance of 154 kilometers for FM stations operating on Channel 220. There are no domestic TV Channel 6 stations located within this threshold distance.

Hatfield & Dawson Consulting Engineers FMSTUDY.EXE Copyright 2020, Hatfield & Dawson, LLC Version 5.00 ======SEARCH PARAMETERS Channel: 220A 91.9 MHz Page 1 Latitude: 48 7 57.1 (NAD83) Longitude: 122 49 31.4 Safety Zone: 50 km Job Title: KPTZ 220A PORT TOWNSEND

Call City Channel ERP(kW) Latitude Bearing Dist Req Status St FCC File No. Freq. HAAT(m) Longitude deg-True (km) (km) ======VICTORIA 217C 0.000 48 35 40.3 314.3 74.04 101 CP BC 91.3 0.0 123 32 41.7 -26.96 SHORT

VICTORIA 217C 0.000 48 35 40.3 314.3 74.04 101 CP BC 91.3 0.0 123 32 41.7 -26.96 SHORT

KBCS BELLEVUE 217C2 1.800 DA 47 32 38.4 140.5 84.59 55 LIC WA BLED-20130307ABN 91.3 389.0 122 6 33.4 29.59 CLEAR

NEW VICTORIA 217C 3.500 48 35 40.3 314.3 74.04 101 LIC BC 91.3 494.0 123 32 41.7 -26.96 SHORT

KQXI GRANITE FALLS 218A 1.600 DA 48 5 10.4 94.3 64.27 31 LIC WA BMLED-20150608AA 91.5 -92.0 121 57 54.5 33.27 CLEAR

KSQM SEQUIM 218A 2.050 DA 48 5 0.3 260.7 33.35 31 LIC WA BLED-20151112XON 91.5 -62.0 123 16 1.6 2.35 CLOSE

GIBSONS-SECHELT 219C1 0.000 49 9 1.3 322.0 144.76 168 ALC BC 91.7 0.0 124 2 59.8 -23.24 SHORT

KSVR MOUNT VERNON 219A 0.170 DA 48 23 48.3 52.3 48.33 72 LIC WA BLED-20021112AAQ 91.7 204.0 122 18 30.5 -23.67 SHORT

CBYFFM CHILLIWACK 219A 0.500 49 6 35.5 33.1 130.42 98 LIC BC 91.7 202.0 121 50 51.5 32.42 CLEAR

KZAZ BELLINGHAM 219A 0.120 DA 48 48 3.3 19.7 79.02 72 LIC WA BLED-19910828KA 91.7 102.0 122 27 44.6 7.02 CLOSE

KYFQ TACOMA 219C1 4.300 DA 47 32 52.3 178.8 65.02 133 LIC WA BLED-20130222ACV 91.7 582.0 122 48 26.5 -67.98 SHORT

KPTZ PORT TOWNSEND 220A 2.200 DA 48 7 41.3 207.3 0.55 115 LIC WA BLED-20130510ACX 91.9 102.0 122 49 43.6 -114.45 SHORT

KPBW BREWSTER 220C2 1.000 48 2 13.5 91.8 211.78 166 LIC WA BLED-20120521AAL 91.9 755.2 119 59 11.2 45.78 CLEAR

KDNA YAKIMA 220C1 18.500 46 31 41.4 134.9 249.43 200 LIC WA BMLED-20060906AB 91.9 280.0 120 31 7.2 49.43 CLEAR

Hatfield & Dawson Consulting Engineers FMSTUDY.EXE Copyright 2020, Hatfield & Dawson, LLC Version 5.00 ======SEARCH PARAMETERS Channel: 220A 91.9 MHz Page 2 Latitude: 48 7 57.1 (NAD83) Longitude: 122 49 31.4 Safety Zone: 50 km Job Title: KPTZ 220A PORT TOWNSEND

Call City Channel ERP(kW) Latitude Bearing Dist Req Status St FCC File No. Freq. HAAT(m) Longitude deg-True (km) (km) ======K221GR LACEY 221D 0.099 DA 47 3 42.3 180.2 119.05 0 CP WA BNPFT-20180418AB 92.1 0.0 122 49 48.5 0.00 TRANS

NEW VICTORIA 221C 0.000 48 45 55.3 324.5 86.82 182 CP BC 92.1 0.0 123 30 45.7 -95.18 SHORT

VICTORIA 221C 0.000 48 30 19.3 311.1 63.53 182 CP BC 92.1 0.0 123 28 27.7 -118.47 SHORT

K221FJ TACOMA 221D 0.150 DA 47 14 31.4 164.7 102.60 0 LIC WA BLFT-20100202ABK 92.1 0.0 122 28 1.4 0.00 TRANS

CJRQFM VICTORIA 221C 0.000 48 24 59.3 308.4 51.18 182 ALC BC 92.1 0.0 123 22 4.7 -130.82 SHORT

CJRQFM VICTORIA 221C 87.000 48 45 12.3 324.8 84.83 182 LIC BC 92.1 636.0 123 29 29.7 -97.17 SHORT

K221DV KAMILCHE 221D 0.019 47 8 19.3 192.2 113.01 0 LIC WA BLFT-20141008AAW 92.1 0.0 123 8 27.5 0.00 TRANS

K221FR WEST SEATTLE, ETC. 221D 0.250 DA 47 28 49.4 163.2 75.72 0 LIC WA BLFT-20151201AKW 92.1 0.0 122 32 2.5 0.00 TRANS

NEW VANCOUVER 222C1 0.000 49 21 11.4 356.0 136.08 99 ALC BC 92.3 0.0 122 57 22.7 37.08 CLEAR

KQMV BELLEVUE 223C 60.000 47 30 16.7 137.2 94.81 95 LICAPP WA 0000120175 92.5 698.0 121 58 7.8 SS -0.19 SHORT

KQMV BELLEVUE 223C 60.000 47 30 16.7 137.2 94.81 95 LIC WA BLH-20060824AEA 92.5 698.0 121 58 7.8 SS -0.19 SHORT

VICTORIA 274D 0.000 48 27 38.3 313.8 53.00 10 ALC BC 102.7 0.0 123 20 36.7 43.00 CLEAR

44444 END OF FM SPACING STUDY FOR CHANNEL 220 44444

Hatfield & Dawson Consulting Engineers KSVR 219A Mount Vernon 60 dBu F(50,50) 54 dBu F(50,10)

SAN JUAN

A D A C A N

ISLAND

KPTZ 220A Port Townsend 60 dBu F(50,50) 54 dBu F(50,10)

JEFFERSON

KYFQ 219C1 Tacoma 60 dBu F(50,50) KITSAP 54 dBu F(50,10)

KPTZ 220A 1Adj Study Map 0 102030 Kilometers MASON Hatfield & Dawson 12/2020 KSVR 219A Mount Vernon 54 dBu F(50,10)

Overlap over water area only

ISLAND

KPTZ 220A Port Townsend 60 dBu F(50,50)

KPTZ 220A 1Adj Study Map Detail 03.36.710 Kilometers Hatfield & Dawson 12/2020 SAN JUAN

A D A N A

ISLAND

KSQM 218A Sequim 60 dBu F(50,50) 100 dBu F(50,10)

KPTZ 220A Port Townsend 60 dBu F(50,50) 100 dBu F(50,10)

JEFFERSON

KPTZ 220AKITSAP 2Adj Study Map 0 5 10 15 Kilometers Hatfield & Dawson 12/2020 Neither the first-adjacent 48 dBu interfering contour nor the third-adjacent 94 dBu interfering contour from the proposed facility overlaps any Canadian land areas. Therefore, full protection is provided to Canadian stations CJZN-FM 217C Victoria, CBU-FM-1 221C Victoria, and CKAY-FM 219C1 Gibsons.

SAN JUAN

A C D A N A

ISLAND

KPTZ 220A Port Townsend 94 dBu F(50,10) 48 dBu F(50,10)

JEFFERSON

KITSAP

KPTZ 220A Canada Allocation Study Map 0 204060 Kilometers Hatfield & Dawson 12/2020 December 2020 KPTZ(FM) Channel 220A Port Townsend, Washington RF Exposure Study

Facilities Proposed The proposed operation will be on Channel 220A (91.9 MHz) with a maximum lobe effective radiated power of 1.95 kilowatts. Operation is proposed with a circularly-polarized directional antenna which will be side-mounted on a new tower to be constructed in Port Townsend.

The proposed antenna support structure will not exceed 60.96 meters (200 feet) above ground and does not require notification to the Federal Aviation Administration. Therefore, this structure does not require an Antenna Structure Registration Number.

RF Exposure Calculations The power density calculations shown below were made using the techniques outlined in OET Bulletin No. 65. "Ground level" calculations in this report have been made at a reference height of 2 meters above ground to provide a worst-case estimate of exposure for persons standing on the ground in the vicinity of the tower. The equation shown below was used to calculate the ground level power density figures from each antenna.

Hatfield & Dawson Consulting Engineers 2 3340981.()× AdjERP Watts S(/)µ W cm = D2 Where: AdjERP(Watts) is the maximum lobe effective radiated power times the element pattern factor times the array pattern factor.

D is the distance in meters from the center of radiation to the calculation point.

Ground level power densities have been calculated for locations extending from the base of the tower to a distance of 500 meters. Values past this point are increasingly negligible.

Calculations of the power density produced by the proposed antenna system assume a Type 2 element pattern, which is the element pattern used by the Commission’s FMModel software for the PSI model PSIFM-2-DA antenna to be used. The highest calculated ground level power density occurs at a distance of 28 meters from the base of the antenna support structure. At this point the power density is calculated to be 9.8 µW/cm², which is 4.9% of 200 µW/cm 2 (the FCC standard for uncontrolled environments, i.e. those areas accessible to the general population).

The permittee/licensee in coordination with other users of the site must reduce power or cease operation as necessary to protect persons having access to the site, tower or antenna from radiofrequency exposure in excess of FCC guidelines.

Hatfield & Dawson Consulting Engineers Ground-Level RF Exposure OET FMModel

KPTZ 220A Port Townsend Antenna Type: PSIFM-2-DA (Type 2) No. of Elements: 2 Element Spacing: 1.0 wavelength

Distance: 500 meters Horizontal ERP: 1.95 kW Vertical ERP: 1.95 kW

Antenna Height: 52 meters AGL

Maximum Calculated Power Density is 9.8 µW/cm 2 at 28 meters from the antenna structure.

Hatfield & Dawson Consulting Engineers WHIDBEY ISLAND STATION

ISLAND

OAK HARBOR

60 dBu

COUPEVILLE 20

JAMESTOWN PORT TOWNSEND

CARLSBORG SEQUIM

RIVER ROAD 525 BELL HILL MARROWSTONE

101 PORT HADLOCK-IRONDALE

116 BLYN FREELAND CLALLAM

104

PORT LUDLOW HANSVILLE

PORT GAMBLE TRIBAL COMUNITY JEFFERSON

QUILCENE

KPTZLOFALL 220A Contour Map KITSAP 03.36.710KINGSTON