H:\Wp80\Ryan Felmlee\KSNT\Montecito

$H:\Wp80\Ryan Felmlee\KSNT\Montecito$ COHEN, DIPPELL AND EVERIST, P.C. Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of ) ) Third Periodic Review of the ) MB Docket No. 07-91 Commission’s Rules and Policies ) Affecting the Conversion ) To Digital Television ) COMMENTS OF MONTECITO TELEVISION LICENSE CORPORATION OF WICHITA The following comments are in response to the FCC Public Notice on comment period for the Third DTV Periodic Review Notice of Proposed Rulemaking (“NPRM”)1 and are submitted as joint comments on behalf of Montecito Television License Corporation of Wichita (“Montecito”), licensee of full-service television stations KSNC(TV), Great Bend, Kansas and KSNG(TV), Garden City, Kansas. Montecito has several concerns regarding the language proposed in the Third DTV Periodic Review NPRM relative to its full-service facilities, which shall be address herein. KSNC-DT The currently licensed analog operation of KSNC(TV) is on Channel 2 with 100 kW non-directional effective radiated power (“ERP”) and 296 meters antenna height above average terrain (“HAAT”). KSNC-DT has a DTV construction permit to operate on Channel 22 with 1000 kW non-directional ERP and 261.1 meters HAAT at the same site location as KSNC(TV). In its DTV Pre-Election Certification Form, KSNC-DT certified that it would operate its post-transition DTV station based on its allotted replication facilities2. KSNC-DT elected in the first round of DTV channel elections to operate its post-transition DTV station on Channel 22. Montecito has decided to operate its post-transition Channel 22 DTV station from the top- mounted location of the currently licensed analog antenna. Montecito would prefer to maintain operations of KSNC(TV) top-mounted analog operations until after the February 17, 2009 1Media Bureau Announces Comment and Reply Comment Dates for the Third DTV Periodic Review NPRM, MB Docket No. 07-91, Third Periodic Review of the Commission’s Rules and Policies Affecting the Conversion to Digital Television, MB Docket No. 07-91, Notice of Proposed Rulemaking, FCC 07-70 (rel. May 18, 2007) (“Third Periodic Review NPRM”). 2KSNC-DT filed an application for construction permit (FCC File No. BMPCDT20070511ABB) to operate its post-transition DTV facilities at 500kW ERP at 281.3 meters HAAT. COHEN, DIPPELL AND EVERIST, P.C. shut-off deadline. This process will require authority to operate the existing side-mounted KSNC-DT operation at reduced power until the replacement of the top-mounted low-band VHF antenna with the post-transition UHF channel 22 antenna can be completed. Montecito also notes that the climate of Great Bend, Kansas, during the month of February may create an obstacle for the process of the top-mounted antenna replacement which may require KSNC-DT to operate with the side-mounted DTV operation for an extended time period beyond the February 17, 2009 date. As an alternative to the above mentioned transition plan, KSNC-DT could also build out their top-mounted DTV facilities before the February deadline which would require the KSNC(TV) analog operations to operate at a reduced power. Montecito could relocate the analog operation to a side-mounted temporary antenna at a reduced power and replace the current top-mounted low-band VHF antenna with the post-transition DTV antenna simultaneously. Based on this approach of performing the KSNC-DT antenna replacement before the February 17, 2009 deadline, Montecito would require authority to operate its analog facilities at a lower height and reduced power. The KSNC(TV) and KSNC-DT facilities as listed in CDBS are as follows: KSNC(TV) License CH 2 100 kW ND 296 Meters HAAT North 38E 25' 54" Latitude West 98E 46' 18" Longitude NAD-27 KSNC-DT Construction Permit FCC File No BPCDT19990610KF CH 22 1000 kW ND 261.1 Meters HAAT North 38E 25' 54" Latitude West 98E 46' 18" Longitude NAD-27 KSNC-DT Application FCC File No BMPCDT20070511ABB CH 22 500 kW ND 284 Meters HAAT North 38E 25' 54" Latitude West 98E 46' 18" Longitude NAD-27 -2- COHEN, DIPPELL AND EVERIST, P.C. KSNG-DT The currently licensed analog operation of KSNG(TV) is on Channel 11 with 200 kW non-directional effective radiated power (“ERP”) and 244 meters antenna height above average terrain (“HAAT”). KSNG-DT has a DTV construction permit to operate on Channel 16 with 631 kW non-directional ERP and 217.6 meters HAAT at the same site location as KSNG(TV). In its DTV Pre-Election Certification Form, KSNG-DT certified that it would operate its post-transition DTV station based on its allotted replication facilities. KSNG-DT elected in the first round of DTV channel elections to operate its post-transition DTV station on Channel 11. Montecito has decided to operate its post-transition Channel 11 DTV station from its currently licensed top-mounted analog antenna at its current location. This process of employing the KSNG-DT post-transition operations through use of the existing top-mounted analog antenna will require a modification of the existing transmitter to accommodate digital operations on channel 11. To accomplish the transmitter modification, the KSNG(TV) analog operations will require approximately a 3dB (50%) reduction in power for the modification process to be completed. Therefore, the KSNG(TV) channel 11 analog operation will require authority to operate at a reduced power for the unspecified time period necessary to complete the transmitter modification for the post-transition digital operation. The KSNG(TV) and KSNG-DT facilities as listed in CDBS are as follows: KSNG(TV) License CH 11 200 kW ND 244 Meters HAAT North 37E 46' 40" Latitude West 100E 52' 08" Longitude NAD-27 KSNG-DT Construction Permit FCC File No. BPCDT19990709LG CH 16 631 kW ND 217.6 Meters HAAT North 37E 46' 40" Latitude West 100E 52' 08" Longitude NAD-27 KSNG-DT Final DTV Allotment CH 11 7.4 kW DA 244 Meters HAAT North 37E 46' 40" Latitude West 100E 52' 08" Longitude NAD-27 -3- COHEN, DIPPELL AND EVERIST, P.C. Respectfully submitted, ELL AND EVERIST, P.C. Ryan M. Felmlee . yens . strict ofColumbia Professional Engineer Registration No. 5714 -...L...L--~Y Subscribed and sworn to before me this of¥ 2007. -i f~olMy Public ission Expires: #"'Y -4-.

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