Request for Extension of KALO STA As KALO Has Previously Reported To
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Request for Extension of KALO STA As KALO has previously reported to the Commission, the current repack construction permit for KALO, File No. 0000034872, granted January 4, 2018, specifies a transmitter site that was planned to be shared with KKAI, Facility ID Number 83180, Kailua, Hawaii, pursuant to a Memorandum of Understanding between the parties, which was submitted to the Commission. Pursuant to that agreement, KKAI’s licensee was the party responsible for organizing and accomplishing the construction of the monopole support for the antenna on Mauna Kapu, as well as the antenna, feedline, and combiner acquisition and installation. As reported in a prior tolling request filed December 11, 2019, at that time, KALO’s partner KKAI had been unable to make any substantial progress toward completion of these items and had requested and been granted tolling of its own repack construction permit (File No. 0000086047). As a result of KKAI’S difficulties, KALO had not been able to move forward with its own construction. In late January of 2020, however, KKAI notified KALO that it had decided to abandon both the Mauna Kapu site and the Memorandum of Understanding between the parties, so that KALO now would need to build its own, single station facilities to complete the repack process. In connection with this decision, KKAI’s licensee made available to KALO two existing monopole supports that KALO could use for mounting its antennas, together with an antenna, microwave equipment, and the rights to obtain electrical power through an existing meter connection at the site. Agreements for obtaining access to these items was negotiated over a period of approximately two months, until the last part of March 2020. Additionally, KALO negotiated a modified lease for the transmitter room vacated by KKAI. These acquisitions all moved forward the construction of the final facilities for KALO and promised to result in significant savings in time, as there no longer was the need to construct a new tower or a new power source, and the antenna had already been delivered to Hawaii. By that time, however, all of the United States, and especially Hawaii, had been locked down due to the COVID-19 pandemic. As a result, both the shipment and delivery of goods and the travel of personnel to work on the installation of broadcast facilities have been severely impacted. As an initial matter, the number of flights to Hawaii has been significantly decreased. Further, all travelers to Hawaii are required to remain in quarantine for a period of fourteen days upon their arrival and are required to check in daily with the Hawaiian government from their place of quarantine, with their location monitored. While some exemptions are available to essential workers, travel around the island is still quite restricted. As a result, obtaining the necessary personnel to undertake the construction final of the permanent KALO facilities has not been possible to date. Likewise, the ability to obtain transmission line and other items necessary for construction has been severely delayed due to manufacturing and shipping delays caused by the response to the pandemic. Furthermore, following the change in plans, KALO determined that the existing support poles were in a very slightly different location and at a different elevation from the previously planned new monopole, and that a modification of the construction permit for the final facilities would therefore be required. An application for modification for construction permit has been prepared and is being filed concurrently herewith. As a result of these prior and ongoing problems and of the need to meet a Phase 2 transition deadline, later adjusted to Phase 3, KALO sought and was granted Special Temporary Authority (File No. 0000066951) to install an antenna for operation on its new channel at its current transmitter site as a workaround, and it completed facilities on the new channel and is operating with those facilities on an interim basis until permanent facilities can be constructed. KALO herein seeks an extension of that STA to be able to continue operating pending construction of its permanent facilities. Attached hereto is the engineering exhibit from the initial STA request for KALO. Nothing has changed with regard to the technical operation. {01437049‐1 } SMITH AND FISHER EXHIBIT A ENGINEERING STATEMENT The engineering data contained herein have been prepared on behalf of KALO TV, INC., licensee of full-power digital television station KALO-DT, Channel 38 in Honolulu, Hawaii, in support of its Request for Special Temporary Authority to operate with an interim facility on its post-repack channel, Channel 18, until such time as the station can construct the facility authorized in Construction Permit 0000034872. It is proposed to mount a Scala/Kathrein directional horizontally-polarized panel antenna at the 20-meter level of the existing 60.6-meter tower on which the present KALO-DT Channel 38 (pre-repack) antenna is mounted. The proposed effective radiated power for the facility is 74.0 kW. Exhibit B is a map upon which the predicted service contours are plotted. As shown, the community of Honolulu is completely encompassed by the proposed 48 dBu city- grade service contour. It is important to note that the predicted service contour does not extend beyond that of the KALO-DT facility authorized in Construction Permit 0000034872 at any azimuth, as shown in Exhibit C. Antenna azimuth pattern data for the un-rotated antenna is provided in Exhibit D. The antenna will be oriented at an azimuth of 110 degrees true. Since the service contour of the facility proposed herein lies completely within that authorized to the repack facility of KALO-DT, no interference study is included herein. A power density calculation is provided in Exhibit E. Since no change in the overall height or location of the existing KALO-DT tower is proposed herein, the Federal Aviation Administration has not been notified of this application. In addition, the Federal Communications Commission issued Antenna Structure Registration Number 1218023 to this tower. SMITH AND FISHER EXHIBIT A I declare under penalty of perjury that the foregoing statements and the attached exhibits, which were prepared by me or under my immediate supervision, are true and correct to the best of my knowledge and belief. KEVIN T. FISHER December 5, 2018 CONTOUR POPULATION 2015 U.S. CENSUS DATA CITY-GRADE : 996,040 (342,653 HH) NOISE-LIMITED : 999,456 (344,879 HH) FCC NOISE-LIMITED SERVICE CONTOUR Laie Hauula Waialua FCC CITY-GRADE Kaaawa CONTOUR WahiawaH-2 Waikane Mililani Town WaianaeKALO-DTKALO-DTKALO-DTKALO-DTKALO-DTKALO-DT Ahuimanu H-1 H-3 Kailua Nanakuli Waipahu Makakilo City Waimanalo Honolulu Kualapuu Kaunakak L EXHIBIT B PREDICTED SERVICE CONTOURS Scale 1:900,000 mi PROPOSED KALO-DT INTERIM FACILITY 0 6 12 18 CHANNEL 18 - HONOLULU, HAWAII V-Soft Communications LLC ® © AUTHORIZED KALO-DT FCC NOISE-LIMITED SERVICE CONTOUR Kilauea Anahola Kapaa Lihue PROPOSED KALO-DT INTERIM FACILITY o N/L SERVICE CONTOUR ipu Laie Waialua Kaaawa H-2 MakahaKALO-DTKALO-DTKALO-DTKALO-DTKALO-DTKALO-DT MililaniH-1 Town H-3 Waipahu Kailua Honolulu Kalawao Kualapuu Kaunakakai Ka L Lanai City EXHIBIT C CONTOUR COMPARISON Scale 1:1,300,000 mi PROPOSED KALO-DT INTERIM FACILITY 0 6 12 18 CHANNEL 18 - HONOLULU, HAWAII V-Soft Communications LLC ® © Antenna Pattern Rotation Angle = 0 Pre-Rotation Antenna Pattern.... Azimuth (deg) Relative Field 0.0 1.0 10.0 0.96 20.0 0.86 30.0 0.7 40.0 0.54 50.0 0.4 60.0 0.27 70.0 0.16 80.0 0.08 90.0 0.02 100.0 0.03 110.0 0.05 120.0 0.06 130.0 0.06 140.0 0.05 150.0 0.02 160.0 0.05 170.0 0.08 180.0 0.09 190.0 0.08 200.0 0.05 210.0 0.02 220.0 0.05 230.0 0.06 240.0 0.06 250.0 0.05 260.0 0.03 270.0 0.02 280.0 0.08 290.0 0.16 300.0 0.27 310.0 0.4 320.0 0.54 330.0 0.7 340.0 0.86 350.0 0.96 SMITH AND FISHER EXHIBIT E POWER DENSITY CALCULATION PROPOSED KALO-DT INTERIM FACILITY CHANNEL 18 – HONOLULU, HAWAII Since the FCC considers the possible biological effects of RF transmissions in its environmental determinations, we have studied the matter with respect to this Honolulu facility. Employing the methods set forth in OET Bulletin No. 65 and considering a main-lobe effective radiated power of 74.0 kW, an antenna radiation center 20 meters above ground, and assuming a vertical relative field value of 20 percent at the steeper elevation angles for the proposed Scala/Kathrein antenna, maximum power density two meters above ground of 0.31 mW/cm2 is calculated to occur in the vicinity of the base of the tower. Since this value is only 18.5 percent of the 1.65 mW/cm2 reference for controlled environments (areas without public access) surrounding a facility operating on Channel 18 (494-500 MHz), and since the site is inaccessible to the public, a grant of this proposal may be considered a minor environmental action with respect to public and occupational exposure to non-ionizing electromagnetic radiation. In addition, once the new KALO-DT antenna is installed, a power density survey of the tower site will be conducted in order to ensure compliance with the Commission’s RF human exposure standards. Further, the station owner will take whatever precautionary steps are necessary, such as reducing power or leaving the air temporarily, to ensure that workers operating in the vicinity of the antenna are not exposed to excessive non-ionizing radiation.