Before the Federal Communications Commission Washington, D.C

Before the Federal Communications Commission Washington, D.C. 20554

) In the Matter of ) ) Advanced Television Systems ) MB Docket No. 87-268 and Their Impact upon the ) Existing Television Broadcast ) Service ) )

To: The Commission

PETITION FOR RECONSIDERATION FOR TRIBUNE BROADCASTING COMPANY

Tribune Broadcasting Company (“Tribune”), by its undersigned attorney, hereby

submits this Petition for Reconsideration of the Seventh Report & Order in the above-referenced

proceeding.1 Specifically, Tribune requests that the Commission reconsider the allotment for

KCPQ-DT, Tacoma, Washington by allowing Tribune to amend KCPQ’s FCC Form 381, post-

transition service area certification to specify the replication of the station’s high-band, VHF

analog service area rather than its maximized UHF DTV service area.2 KCPQ is operating a 600 kW ERP DTV facility on channel 18 during the transition and elected to return to its high-band, analog VHF channel 13 for its post-transition operation.

To facilitate a smooth transition after February 17, 2009, KCPQ has decided to

use its analog channel 13 antenna for its post-transition DTV operation. By using the existing

analog antenna, KCPQ will provide more television service to viewers both before and after the

February 17, 2009 analog shut-down. KCPQ will avoid the inevitable analog service disruptions

1 See Advanced Television Systems and their Impact Upon the Existing Broadcast Service, Seventh Report & Order and Eighth Further Notice of Proposed Rulemaking, MB Docket No. 87-268, FCC 07-138, released August 6, 2007. 2 Tribune is the indirect, 100 percent owner of KCPQ. and coverage area losses that would result if its top-mounted analog antenna were removed and replaced prior to February 17, 2009. In addition, by using its analog antenna, KCPQ will require significantly less time before it can provide full power, post-transition DTV service because it will not be forced to endure the delays that many stations will face due to the shortages in antenna manufacturing capacity and related logistical support providers such as qualified tower riggers.

Unfortunately, without a change in KCPQ’s post-transition DTV allotment or the

Commission’s current proposals for post-transition service area changes, Tribune will be unable to provide post-transition DTV service to over 170,000 viewers who currently receive KCPQ’s

DTV service on its pre-transition channel 18 and over 30,000 viewers who currently receive

KCPQ’s analog service on channel 13.3 Like a number of other stations returning to their high- band VHF analog channels for post-transition digital operations, the problem faced by Tribune with KCPQ-DT is that there is a significant mis-match between KCPQ-DT’s theoretical antenna pattern in Appendix B and its existing analog antenna pattern.4 Because of this mis-match,

Tribune will be forced to reduce KCPQ’s post-transition ERP to 0.7 kW using its non-directional analog antenna to keep its post-transition operation entirely within the coverage footprint of its

Appendix B allotment.

3 These coverage statistics are the relevant population figures using 2000 Census data for Grade B/Noise-Limited service based on OET-69 studies considering terrain and predicted interference. 4 The Commission, in fact, recognized this phenomenon in the Third Periodic DTV NPRM when it noted that stations “may be unable to build precisely the facilities specified in the new DTV Table Appendix B (for example, if an antenna producing the exact antenna pattern described in Appendix B is not available).” Third Periodic Review of the Commission’s Rules & Policies Affecting the Conversion to Digital Television, Notice of Proposed Rulemaking, MB Docket No. 07-91, FCC 07-70, ¶ 93, released May 18, 2007.

2 To prevent coverage losses at the most crucial time of the transition, Tribune urges the FCC to grant the instant Petition, change KCPQ-DT’s certified, post-transition service area and recalculate KCPQ’s post-transition allotment on channel 13. Tribune has analyzed the replication facility that it expects the FCC’s table of allotment program to produce for KCPQ – a non-directional ERP of 22.7 kW and antenna radiation center height of 718 m AMSL -- and confirmed that the facility will comply with the 0.1 percent interference standard and that there are no interference areas of concern with Canada. By granting the Petition and changing KCPQ-

DT’s certification, the Commission will also significantly enhance the likelihood of indoor over- the-air reception as well as outdoor reception by viewers with sub-standard equipment. This increased reception is due to the enormous difference in ERP between what KCPQ will be forced to operate at using its analog antenna if its current Appendix B allotment does not change (0.7 kW, non-directional) and the replication facility likely to be generated by the FCC’s table of allotment program (22.7 kW, non-directional).

Given the enormous importance of improving and maximizing DTV service on and around February 17, 2009, Tribune submits that a grant of the instant Petition is decidedly in the public interest.

Respectfully submitted,

TRIBUNE BROADCASTING COMPANY

/s/ Thomas P. Van Wazer /s/ Thomas P. Van Wazer Sidley Austin LLP 1501 K Street, N.W. Washington, D.C. 20005 (202) 736-8119

Its Attorney

Dated: October 10, 2007