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.