FINAL KCTS-TV Channel Substitution Rulemaking Petition.Pdf

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

In the Matter of: ) ) Amendment of Section 73.622(i), ) MB Docket No. the Table of Allotments for ) Digital Television Stations, ) Rulemaking No. For KCTS-TV, Seattle, Washington ) (Facility ID No. 33749) )

To: Office of the Secretary, Federal Communications Commission

Attn: Chief, Mass Media Bureau

PETITION FOR RULEMAKING

CASCADE PUBLIC MEDIA (“Cascade”), licensee of non-commercial educational television station KCTS-TV, Facility ID No. 33749, Seattle, Washington (“KCTS” or the

“Station”), by counsel, hereby respectfully petitions the Commission to institute a rulemaking proceeding pursuant to Section 1.401 of the Commission’s Rules1 for the purpose of amending the digital television Table of Allotments set forth in Section 73.622(i) of the Rules (“DTV

Table”)2. Cascade requests that the Commission amend the DTV Table to substitute UHF

Channel 17 for Seattle, Washington, in lieu of VHF Channel 9 (on which the Station is currently operated), in accordance with the technical parameters set forth in the Engineering Statement attached hereto as Exhibit 1.3 As demonstrated below, the proposed substitution meets the

1 47 C.F.R. § 1.401

2 47 C.F.R. § 73.622(i)

3 See Engineering Statement of Don Everist, Cohen, Dippell and Everist, P.C., in Support of Petition to Amend the Table of Allotments for KCTS-TV, Seattle Washington, dated December 2020 (“Engineering Statement”) (attached as Exhibit 1 hereto).

applicable technical requirements set forth in Rules 616, 623 and 625(a) for post-transition DTV channel changes, 4 and would serve the public interest by: addressing ongoing reception complaints KCTS has received from viewers since commencing operations on Channel 9; optimizing Seattle, Washington DTV allotments by improving the Station’s OTA reception within its community of license and core service area, allowing it to better compete for viewers with other full-power television stations in the Seattle-Tacoma market; and enabling the Station to better serve the Seattle community by substantially improving viewer access to its non- commercial educational and public affairs programming, in both “over-the-air” (“OTA”), and in the forthcoming ATSC 3.0 mobile device, environments.

KCTS is licensed to Seattle, Washington, and transmits on VHF Channel 9, at 21.7 kW

ERP. It is one of two full-power non-commercial educational digital television stations serving the Seattle-Tacoma DMA, and, of those, the only NCE DTV station operating on a VHF channel.5 In the DTV “repack,” KCTS was originally allotted digital Channel 41. KCTS is a

PBS affiliate, and many residents of Seattle and KCTS’ core viewing area depend on the

Station’s OTA transmissions in order to receive PBS’ outstanding educational, cultural and public affairs programming. Apart from KCTS, only two of the 15 other full-power television stations in the Seattle-Tacoma DMA operate on VHF channels, and no other television station in the DMA operates on a VHF channel as low as KCTS’ Channel 9.6 As set forth below and in

Cascade’s Vice President of Engineering and Technologies’ declaration attached as Exhibit 2,

4 47 C.F.R. §§ 73.616, 73.623, and 73.625(a).

5 https://www.stationindex.com/tv/markets/seattle-tacoma

6 See supra, n.5. 2

since the digital transition and commencement of DTV operations on VHF Channel 9 in 2009,

KCTS has consistently received viewer complaints of poor reception and interference, many of

whom complain that Channel 9 is the only station they cannot receive reliably over the air.7

These persistent VHF reception issues put KCTS at a severe disadvantage in reaching viewers,

compared with most other full power DTV stations in the Seattle market which now operate on

UHF channels. Moreover, KCTS’ high-VHF band channel allotment will effectively preclude the Station and its core viewers from realizing the full benefits of the ATSC 3.0 transition, because VHF frequencies are unsuitable for mobile devices with onboard antennas.

Generally, the Commission will grant a proposed reallotment when the change will result in a “preferential arrangement of allotments.”8 The Commission will consider a proposal to

change the DTV Table to be in the public interest if it satisfies one of the Commission’s five

allotment priorities.9 The Commission’s stated objective of the post-transition DTV Table is

ensuring the provision of digital television service “to the American people in an expeditious and

efficient manner.”10 The Commission has recognized repeatedly that substitution of UHF

7 Statement of Jabran Soubeih, Cascade Public Media Vice President of Engineering & Technology (“Soubeih Statement”), attached hereto as Exhibit 2.

8 See generally Amendment of Section 3.606 of the Commission's Rules and Regulations, Sixth Report and Order, 41 F.C.C. 148, 167-173 (1952). 9 Id. The five allotment priorities are: (1) to provide at least one television service to all parts of the United States; (2) to provide each community with at least one television broadcast station; (3) to provide a choice of at least two television services to all parts of the United States; (4) to provide each community with at least two television broadcast stations; and (5) to assign any remaining channels to communities based on population, geographic location, and the number of television services available to the community from stations located in other communities. Id.

10 See, e.g., In the Matter of Amendment of Section 73.622(B), Table of Allotments, Digital Television Broadcast Stations (Nampa, Idaho), Report and Order, 19 FCC Rcd. 4491, 4493 3

channels for VHF channels under parameters meeting applicable technical requirements may serve the public interest and the Commission’s DTV Table priorities, where the channel change would address viewer reception and interference issues caused by the relatively poor signal propagation characteristics of DTV VHF operations.11

Reliable high-quality reception of free DTV programming over the air has become even

more important than ever, as more people rely increasingly on OTA reception in this era of pandemic-induced economic uncertainty and “cord cutting.”12 Yet, since at least 2010, the

Commission has recognized that “VHF channels have certain technical characteristics that have

posed challenges for their use in providing digital television service,” including “propagation

characteristics of these channels [that] allow undesired signals and noise to be receivable at

relatively farther distances,” the tendency of “nearby electrical devices … to emit noise in this

(2004); In the Matter of Amendment of Section 73.622(B), Table of Allotments, Digital Television Broadcast Stations (In the Matter of Amendment of Section73.622(B), Table of Allotments, Digital Television Broadcast Stations (Albany, New York), 19 FCC Rcd. 4329, 4331 (2004); see also In the Matter of Advanced Television Systems & Their Impact Upon the Existing Television Broadcast Service, 12 FCC Rcd. 14588 ¶ 76 (1997). 11 See, e.g., In Re Amendment of Section 73.622(i), ) Post-Transition Table of DTV Allotments, Television Broadcast Stations, (Portland, Oregon), Notice of Proposed Rulemaking, MB Docket No. 20-334, RM-11864 (rel. Oct. 13, 2020); In Re Amendment of Section 73.622(i), Post- Transition Table of DTV Allotments, Television Broadcast Stations (Mesa, Arizona), Notice of Proposed Rulemaking, MB Docket No. 20-331, RM-11863, DA-20-1192 (rel. Oct. 13, 2020); In Re Amendment of Section 73.622(b), Table of Allotments, Digital Television Broad. Stations, Ontario, CA, Notice of Proposed Rulemaking, 16 FCC Rcd. 2276 (2001); In Re Amendment of Section 73.606(b), Table of Allotments, Television Broadcast Stations, Moscow, Idaho, Notice of Proposed Rulemaking, 17 FCC Rcd. 19447 (2002). 12 See, e.g., Jon Lafayette, “Cord-Cutting Hit Record Levels in First Quarter,” Broadcasting + Cable, https://www.broadcastingcable.com/news/cord-cutting-hit-record-levels-in-first-quarter (May 8, 2020); Aaron Pressman, “Cord cutting is speeding up as the coronavirus pandemic squeezes consumers,” Fortune, https://fortune.com/2020/05/05/cord-cutting-coronavirus-cable- satellite-tv-comcast-verizon-charter-altice-att-dish/ (May 5, 2020).

band that can cause interference,” and the fact that “reception of VHF signals requires physically

larger antennas that are generally not well suited to the mobile applications expected under

flexible use, relative to UHF channels.”13 The Commission further noted that independent studies

by a private engineering firm and the Commission’s own staff both found “large variability in the performance (especially intrinsic gain) of indoor antennas available to consumers, with most antennas receiving fairly well at UHF and the substantial majority not so well to very poor at high-VHF” and that it is expected “that the reception capabilities of an indoor antenna at low-

VHF will generally to be less than at high VHF.”14 The Commission continues to recognize that, although VHF reception issues are not universal, “environmental noise blockages affecting

[VHF] signal strength and reception exist” and “[vary] widely from service area to service area.”15

KCTS’ real-world experience since the DTV transition to Channel 9 has been consistent

with the Commission’s observations: in fact, the reception of KCTS on its high-VHF Channel 9

experienced by a large number of viewers in its community of license and core service area

13 Innovation in the Broadcast Television Bands: Allocations, Channel Sharing and Improvements to VHF, Notice of Proposed Rulemaking, 25 FCC Rcd. 16498, 16511 ¶ 42 (2010) (“VHF Improvements NPRM”).

14 Id. at 16512 ¶ 44. See also Amendment of Parts 73 and 74 of the Commission’s Rules to Establish Rules for Digital Low Power Television, Television Translator, and Television Booster Stations and to Amend Rules for Digital Class A Television Stations, Second Report and Order, 26 FCC Rcd. 10732, 10750 ¶ 37 (2011) (“As a result of the full power digital television transition, some full power stations on VHF channels have experienced reception problems and such problems have not been alleviated even by allowing these stations to operate with the maximum power permitted under the full power television rules.”).

15 Assessment and Collection of Regulatory Fees for Fiscal Year 2020, MD Docket No. 20-105, FCC 20-64, at ¶ 52 (rel. May 13, 2020).

ranges from “not so well to very poor.” As set forth in the Soubeih Statement, attached hereto as

Exhibit 2, since KCTS began full power DTV operations from VHF channel 9, the Station consistently has received large numbers of complaints of poor reception and interference from

OTA viewers. Soubeih Statement, at ¶¶ 4-5. Between 2012 (when the Station instituted a new tracking system) and 2020, the Station has logged over 1,000 such complaints. Id. at ¶ 5. A sampling of typical reports include: “weak signal;” “consistent reception problems;” “I can’t get you,” “[a]ll channels but 9 are consistent, Channel 9 reception fades to color blocks evenings and weekends;” “[a]ll the commercial broadcast stations come in clear, but the auto scan shows NO sign of KCTS. Antenna is an RCA Amplified flat panel antenna. Signal on KOMO is 8/9

(Strong);” “[f]or the last week I have been unable to access PBS/channel 9 on either television, no matter what changes I make . . . .;” “I thought that since I am able to receive Channel 11 very

well, that I would also get Channel 9. Please help, we love PBS . . . .” Id.

KCTS’ DTV OTA reception problems are well-known and notorious in the community.

In June 2009, after the transition, the Seattle Times published an article about KCTS’ reception issues. Id. at ¶ 4. https://www.seattletimes.com/business/digital-pioneer-kcts-gets-static-over-

switch-comcast-update/. Continuing reception problems were the subject of a May-June 2019

West Seattle Blog user forum discussion. https://westseattleblog.com/forums-2/topic/kcts-hd-

antenna-reception/

These continuing propagation problems put KCTS at a severe competitive disadvantage

compared to other full-power DTV stations broadcasting in the DMA, all but two of which

operate on a UHF channel. KCTS’ coverage area population count is predicated on unobstructed

reception by a theoretical outdoor antenna placed at 30 feet. That notional configuration does

not conform to the real world experiences of the Station’s viewers as described in the Soubeih 6

Statement, many of whom simply do not possess or use such an outdoor antenna, and/or cannot

in fact reliably receive the Station over-the-air on Channel 9 using the OTA reception hardware

they have. See Soubeih Statement, at ¶ 6.16

Moreover, the propagation characteristics of high-band VHF and reception issues (as

documented in the Soubeih Statement) make it very likely that viewers will be unable to receive

reliably KCTS’s VHF signal on digital mobile devices with integral “onboard” antennas, as the

industry transitions to ATSC 3.0. Id. at ¶ 7.17 That means that, absent the requested reallocation

to UHF Channel 17, KCTS and its viewers will be unable to realize the vast potential benefits of

the forthcoming ATSC 3.0 operating environment. Id. In sum, the technical limitations of VHF

Channel 9 for DTV use in the Seattle viewing area are manifestly inconsistent with the DTV

Table’s public interest objective of delivering the full benefits of DTV service to the American

public, efficiently and expeditiously.

Attached hereto as Exhibit 1 is the Engineering Statement of Don Everist, which sets

forth in detail the proposed Channel 17 DTV Table specifications and technical parameters, to be

16 Indoor antennas suitable for VHF reception are often too large and unwieldy for many consumers. E.g., https://store.antennasdirect.com/ClearStream-FUSION-Amplified-UHF-VHF- Indoor-Outdoor-HDTV-Antenna.html

17 See Dru Sefton, “Prompted by auction sales, moves to low VHF bring both challenges and advantages,” Current, https://current.org/2017/04/prompted-by-auction-sales-moves-to-low-vhf- bring-both-challenges-and-advantages/; See also National Association of Broadcasters, Next Generation Television (ATSC 3.0) Station Transition Guide, at 8 (April 2019), https://nabpilot.org/wp-content/uploads/2019/04/NAB-ATSC-3.0-Guide_Final.pdf (“Performance of VHF channels 7 through 13 is better than low-band VHF, but the longer wavelength of VHF reduces the chances of successful reception for many portable use cases, due to utilization of built-in antennas in these devices,” while “[d]ue to the short wavelengths and resulting reception advantages in this part of the TV spectrum, UHF is suitable for all anticipated ATSC 3.0 service models.”).

used in the construction permit application for the proposed Channel 17 facilities. This proposal is in compliance with all relevant technical requirements for amendment of the post-transition

DTV Table, including the interference protection requirements of 47 C.F.R. §73.616 and the

0.5% de minimis interference standard with respect to all allotments and assignments, existing and proposed. As further reflected in the Engineering Statement, the proposed Channel 17 facility will provide full principal community coverage to Seattle, Washington.

Engineering analysis using the Commission’s TVStudy tool indicates that, compared to current KCTS-TV Channel 9 operations, the Channel 17 facilities and operating parameters

KCTS proposes would create a predicted interference-free coverage loss area of 3,449.6 square kilometers or 13.3%, equating to a population loss of about 93,121 persons, when compared with the current predicted coverage area of VHF Channel 9.18 The loss area is mainly at the Northern boundary of the predicted proposed Channel 17 coverage area, due to the necessity of using a directional signal to protect a Canadian booster operated on Channel 17.19

However, as the Engineering Statement notes, the “proposed 1000 kW directional

Channel 17 operation is larger in terms of area and population served than the previous Channel

41 KCTS-DT operation.”20 As shown by Exhibit E-7 to the Engineering Statement, the contour of the Channel 41 allotment previously approved by the Commission is almost entirely encompassed within the predicted proposed Channel 17 contour, and the proposal would create only de minimis “white” or “gray” areas when compared to KCTS’ original Channel 41

18 Engineering Statement, at 5, Tables II, III, & IV, & Exhibit E-6.

19 Id., at 2.

20 Id., at Table II.

allotment.21 Also, as the Engineering Statement notes, portions of the predicted “loss area” lie within public lands comprising Olympic National Forest, Mt. Rainier National Park, Wenatchee

National Forest, and Mt. Baker National Forest; relatively sparsely populated areas.22

Moreover, even when compared with the current theoretical coverage area of Channel 9, the loss of coverage would not result in a substantial number of persons in the predicted loss area not being “well served” by other DTV stations.23 No viewer in the loss area would not continue to be served by at least two full-power DTV stations.24 Further, fully 99.07 percent (99.07%) of the population within the loss area would continue to be served by at least five (5) full-power

DTV stations, including at least one major network station.25 In real-world operating conditions,

Cascade expects that few (if any) persons currently able to receive KCTS’ VHF Channel 9 signal

OTA would no longer be able to receive on Channel 17.

21 See Engineering Statement, at 5 & Exhibit E-7. In light of the fact that the Commission previously determined that any service loss associated with operating at Channel 41 was acceptable when assigning KCTS to that channel in the DTV transition, the Channel 41 contour is an appropriate benchmark to analyze service loss here. See Advanced Television Systems and Their Impact Upon the Existing Television Broadcast Service, Sixth Report and Order, 12 FCC Rcd. 14588, 14606 ¶ 30 (1997) (recognizing that service replication may “prove[] difficult for existing VHF stations operating on UHF channels . . .”).

22 Engineering Statement, Table II.

23 See Third Periodic Review of the Commission’s Rules and Policies Affecting the Conversion to Digital Television, Notice of Proposed Rulemaking, 22 FCC Rcd. 9478, 9493, ¶ 38 (2007) (“The Commission is generally most concerned where there is a loss of an area’s only network or NCE TV service, or where the loss area results in an area becoming less than well-served, i.e., served by fewer than five full-power over-the-air signals.”) (footnotes and citations omitted); In Re Amendment of Sections 73.606(b) & 73.622(b), Report and Order, 18 FCC Rcd. 15577, 15580 (2003) (explaining that areas that receive at least five other existing full power services are considered well-served).

24 Engineering Statement, Table III & Exhibit E-6.

25 Engineering Statement, Table III, Table IV & Exhibit E-6. 9

EXHIBIT 1

ENGINEERING STATEMENT OF DON EVERIST, COHEN, DIPPELL AND EVERIST, P.C., IN SUPPORT OF PETITION OF CASCADE PUBLIC MEDIA TO AMEND THE TABLE OF ALLOTMENTS FOR KCTS-TV, SEATTLE WASHINGTON

EXHIBIT 1

ENGINEERING REPORT PETITION FOR RULE MAKING TO AMEND SECTION 73.622(2)(i) OF THE FCC RULES BY SUBSTITUTING UHF-TV CHANNEL 17* FOR VHF CHANNEL 9* FOR KCTS-TV, SEATTLE, WASHINGTON

DECEMBER 2020

COHEN, DIPPELL AND EVERIST, P.C. CONSULTING ENGINEERS RADIO AND TELEVISION WASHINGTON, D.C. COHEN, DIPPELL AND EVERIST, P.C.

KCTS-TV, SEATTLE, WASHINGTON PAGE 1

This engineering statement has been prepared on behalf of Cascade Public Media, licensee of non-commercial educational television station KCTS-TV on Channel 9* at Seattle, Washington in support of its petition for rule making to amend Section 73.622 of the FCC Rules and Regulations to specify Channel 17*. KCTS-TV has received a number of reception complaints from off-the-air viewers and seeks to improve its service to the public by adapting its signal so that it will be more easily received. Accordingly Cascade Public Media proposes to amend FCC Rule Section

73.622(2)(i) to specify Channel 17* in order to address those off-the-air viewer reception complaints.

Section 73.622(2)(i) for DTV VHF Channel 9* Substitute DTV UHF Channel 17*

North Latitude: 47° 36' 58" West Longitude: 122° 18' 28" NAD-27

North Latitude: 47° 36' 57" West Longitude: 122° 18' 32" NAD-83

Seattle, Washington, Allocation Situation

The UHF spectrum was examined using TVStudy 2.2 for KCTS-TV from the KCTS-TV tower. Only one channel was deemed to have sufficient allocation potential to be a good candidate for domestic consideration and further investigation. Therefore, it is proposed to operate UHF

Channel 17* with a maximum directional ERP of 1000 kW with a radiation center of 284.9 meters

AMSL as a substitute for VHF Channel 9*.

*Indicates Educational Channel COHEN, DIPPELL AND EVERIST, P.C.

KCTS-TV, SEATTLE, WASHINGTON PAGE 2

Domestically, based on TVStudy, Channel 17* from the KCTS-TV transmitter site with a center of radiation of 159.9 meters above ground has no domestic allocation constraints. However, the KCTS-TV site is separated 102 km from the common United States-Canadian Border. Based on TVStudy, there is a Canadian operation, CIVI-DT-2 located at a distance of 191.1 km.

Canadian

As noted above, Channel 17* was the only available domestic channel. However, the

Canadian operation on Channel 17 is an allocation consideration as it operates at 35 kW directional.

The proposed KCTS-TV operation with a directional antenna is designed to protect the CIVI-DT service area. Therefore, coordination of the proposed Channel 17* operation with the Canadian administration is requested.

Tower

Exhibit E-1 provides a sketch of the existing tower.

Interference Analysis

Exhibit E-2 provides a full allocation study of predicted or absence of interference caused by the proposed KCTS-TV operation. The Channel 17 digital operation has been performed utilizing the FCC’s TVStudy 2.2 evaluation program, for which the source and data has been posted by the

Commission on its website at http://www.fcc.gov/oet/tvstudy. The model employs the Longley-Rice propagation methodology and evaluates in grid cells of approximately 2 sq. km and using one-second terrain data sampled approximately every 1.0 km at one-degree azimuth intervals with 2010 census centroids. All studies are based upon data in the Commission’s current Licensing and Management COHEN, DIPPELL AND EVERIST, P.C.

KCTS-TV, SEATTLE, WASHINGTON PAGE 3

System (“LMS”) database update of the FCC's engineering database. Exhibit E-2 provides the allocation analysis results.

Antenna Pattern

Exhibit E-3 provides the proposed Ch. 17 directional radiation and anticipated elevation patterns.

Elevation Data

Overall height above ground of the 181.1 meters existing antenna structure 594.1 feet (including beacon and lightning rod)

Center of radiation of the proposed Channel 17 159.9 meters antenna above ground 524.6 feet

Elevation of site above mean sea level 125.0 meters 410.1 feet

Center of radiation of the proposed Channel 17 284.9 meters antenna above mean sea level 934.7 feet

Overall height above mean sea level 306.1 meters of existing tower structure 1004.2 feet (including antenna and beacon)

Antenna height above average terrain 249 meters1 816.9 feet

Antenna Registration Number: 1032916

Note: Slight height differences may result due to conversion to metric.

1The licensed value is specified. COHEN, DIPPELL AND EVERIST, P.C.

KCTS-TV, SEATTLE, WASHINGTON PAGE 4

Coverage

For the existing site, the average elevation data for 3.2 to 16.1 km along each radial are based upon the one-second NGDC profile data and conforms very closely to the terrain information of that determined and on file at the Commission and has been previously established. For this filing, the one second terrain data and prediction of coverage contours are based solely on TVStudy 2.2.

Table I provides the F(50,90) DTV coverage contours that have been computed every ten degrees in azimuth from the reference azimuth. The DTV coverage contour calculations are based on TVStudy 2.2 which represents the propagation data for Channels 14-69, as published by the FCC in Figure 10b and Figure 10c, Section 73.699 of the FCC Rules and Regulations.

Utilizing the formula in Section 73.625(b)(2) of the Rules for the effective heights, it is found

that the depression angle, Ah, varies from 0.389 to 0.465 degrees. Since the relative vertical field is greater than 90% of the maximum at these depression angles, the maximum power was used in determining the distance to the DTV contour.

Table I includes the distances to the 48 and 41 dBu F(50,90) coverage contours, the average elevation 3.2 to 16.1 km, and the antenna height above average terrain for each of the ten degree spaced radials. Exhibit E-4 provides the 48 and 41 dBu F(50,90) coverage contours and demonstrates that the community of license is covered by the F(50,90) 48 dBu contour.

Exhibit E-5 provides a comparison of the predicted licensed Channel 9 36 dBu service in relation to the proposed Channel 17, 39.044 dBu noise-limited contour. COHEN, DIPPELL AND EVERIST, P.C.

KCTS-TV, SEATTLE, WASHINGTON PAGE 5

Exhibit E-6 provides the predicted contours for other televised services within the current

KCTS-TV licensed Channel 9 service area. Table III shows the licensed parameters for the television stations that are predicted to serve the various KCTS-TV, Channel 17 loss area pockets.

Table IV provides the loss area, populations and percentages.

Exhibit E-7 provides a comparison of the formerly licensed DTV served by Channel 41 in relation to the current licensed Channel 9 and the proposed replacement Channel 17.

Total Radiofrequency Field Levels at the Existing Tower Site

The total contribution by the proposed KCTS-TV broadcast facilities and the addition of the

2 existing FM operations at 2 meters above ground level is less than 15 percent of the current FCC guidelines for uncontrolled/general population exposure.

The RFF contribution of each station will be calculated using the following formula:

S = 33.4(F²) Total ERP R² where: S = power density in µW/cm² F = relative field factor Total ERP = ERP Horizontal Polarization + ERP Vertical Polarization R = RCAGL - 2 meters

ERP = RMS ERP in watts for FM and DTV Stations

KUOW-FM License Facility

Channel 235 Freq: 94.9 MHz range ERP = 200,000 watts (H) + 100,000 watts (V) Polarization = circular RCAGL -2 meters = 135 meters COHEN, DIPPELL AND EVERIST, P.C.

KCTS-TV, SEATTLE, WASHINGTON PAGE 6

KUOW-FM is using a Shively, Type 6014-5/3 antenna with 0° electrical beam tilt. The field factor will be less than 0.25 at any angle greater than 20 degrees below the horizon. A value of 0.25 will be used in the calculation.

S = 33.4 (F²) Tot ERP Tot ERP = 200,000 watts (H&V) R² R = 135 meters F = 0.25 (field factor)

S = 22.9 µW/cm²

KUOW-FM contributes 22.9 µW/cm² at 2 meters above ground. The limit for an uncontrolled environment is 200 µW/cm² for station broadcasting on 94.9 MHz.

200 µW/cm² is the RFF limit for the FM band.

Therefore:

KUOW-FM contributes less than 12% RFF for an uncontrolled environment two meters above ground at tower site.

KEXP-FM Facility

Channel 212 Freq: 90.3 MHz range ERP = 9400 watts (H&V) Polarization = circular RCAGL -2 meters = 120 meters

KEXP-FM utilizes Jampro, Type JMPC-3 with 0.5 wavelength bay spacing antenna with 0° electrical beam tilt. The field factor will be less than 0.12 at any angle greater than 40 degrees below the horizon. A value of 0.12 will be used in the calculation.

S = 33.4 (F²) Tot ERP Tot ERP = 9400 watts (H&V) R² R = 120 meters F = 0.12 (field factor)

S = 0.32 µW/cm²

KEXP-FM contributes 0.32 µW/cm² at 2 meters above ground. The limit for an uncontrolled environment is 200 µW/cm² for station broadcasting on 90.3 MHz. COHEN, DIPPELL AND EVERIST, P.C.

KCTS-TV, SEATTLE, WASHINGTON PAGE 7

200 µW/cm² is the RFF limit for the FM band.

Therefore:

KEXP-FM contributes less than 1% RFF for an uncontrolled environment two meters above ground at tower site.

Proposed KCTS-TV Facility

Channel 17 Freq: 488-491 MHz range Max. ERP = 1,200,000 watts Polarization = Elliptical RCAGL -2 meters = 150.9 meters

KCTS-TV proposed to utilize Dielectric similar to Type TFU-20ETT/VP-R CT140 antenna with 1° electrical beam tilt. The manufacturer’s vertical plane pattern for this antenna is included as Exhibit E-3. Based on this plot, the field factor will be less than 0.05 at any angle greater than 40 degrees below the horizon. A value of 0.05 will be used in the calculation.

S = 33.4 (F²) Tot ERP Tot ERP = 1,200,000 watts (H&V) R² R = 150.9 meters F = 0.05 (field factor)

S = 4.0 µW/cm²

The proposed KCTS-TV facility contributes 4 µW/cm² at 2 meters above ground. The limit for an uncontrolled environment is [f/1500] for station broadcasting on 488-494 MHz.

(491 MHz)/1500 = 327.3 µW/cm² is the RFF limit for KCTS-TV.

Therefore:

The proposed KCTS-TV DTV facility contributes less than 1% RFF for an uncontrolled environment two meters above ground at tower site. COHEN, DIPPELL AND EVERIST, P.C.

KCTS-TV, SEATTLE, WASHINGTON PAGE 8

Total RFF at Site

The total RFF contribution for all transmitters can now be calculated:

Total RFF = KUOW-FM RFF + KEXP-FM (RFF) + KCTS-TV RFF

Total RFF = <12% + <1% + <1% Total RFF <15%

The total contribution by the existing 2 FM (KUOW-FM and KEXP-FM broadcast facilities and the addition of the proposed operation of KCTS-TV at 2 meters above ground level is less than

15 percent of the current FCC guidelines for uncontrolled/general population exposure.

Authorized personnel and rigging contractors will be alerted to the potential zone of high field levels on the tower, and if necessary, the station will operate with reduced power or terminate the operation of the transmitter as appropriate when it is necessary for authorized personnel or contractors to perform work on the tower. Workers and the general public, therefore, will not be subjected to RFF levels in excess of the current FCC guidelines.

Environmental Assessment

The existing tower will not require any significant modification and has all the necessary approvals including FCC antenna structure registration number 1032916. ABOVE GROUND ABOVE MEAN SEA LEVEL

181.1 METERS (594.1') (1004.2') 306.1 METERS 179.9 METERS (590.1') (1000.1') 304.8 METERS

CHANNEL 17 C/R 159.9 METERS 284.9 METERS C/R CHANNEL 17

152.4 METERS

C/R 137.0 METERS

KUOW-FM

C/R 122.0 METERS

KEXP-FM

PAINTING AND LIGHTING ARE IN ACCORDANCE WITH F.C.C. RULES AND REGULATIONS ASRN 1032916

EXISTING SELF-SUPPORTING TOWER

NOT TO SCALE

0.0 METERS (0') (410.1') 125.0 METERS

EXHIBIT E-1 VERTICAL SKETCH KCTS-TV TELEVISION DECEMBER 2020

COHEN, DIPPELL AND EVERIST, P.C. Consulting Engineers Washington, D.C. COHEN, DIPPELL AND EVERIST, P.C.

EXHIBIT E-2

ALLOCATION STUDY

TVSTUDY 2.2 tvstudy v2.2.5 (4uoc83) Database: localhost, Study: KCTS-Ch17-Envelope-IX, Model: Longley-Rice Start: 2020.12.14 12:57:38

Study created: 2020.12.14 12:57:38

Study build station data: LMS TV 2020-12-14

Proposal: KCTS-TV D17 DT LIC SEATTLE, WA File number: Ch17-Envelope Facility ID: 33749 Station data: User record Record ID: 116 Country: U.S. Zone: II

Search options: Non-U.S. records included Baseline record excluded if station has CP

Stations potentially affected by proposal:

IX Call Chan Svc Status City, State File Number Distance Yes KFFV D16 DT LIC SEATTLE, WA BLANK0000087122 0.1 km No KNDO D16 DT LIC YAKIMA, WA BLCDT20090217ACI 181.8 No KABH-CD D17 DC LIC BEND, OR BLDTA20131029ABN 400.8 No KMTR D17 DT LIC EUGENE, OR BLCDT20030618AAY 392.7 No KMTR D17 DT CP EUGENE, OR BLANK0000035793 406.5 No CHEK-DT D16 DT LIC VICTORIA, BC BLANKCANADA105 143.7 No CH4388 D17 DC LIC BECHER BAY, BC BLANKCANLP30 125.7 No CH2517-DT D17 DC LIC LOGAN LAKE, BC BLANKCANLP203 338.6 No CH4555 D17 DC LIC PEMBERTON, BC BLANKCANLP266 302.9 Yes CIVI-DT-2 D17 DT LIC VANCOUVER, BC BLANKCANADA92 199.1

No non-directional AM stations found within 0.8 km

No directional AM stations found within 3.2 km

Record parameters as studied:

Channel: D17 Page 1 Latitude: 47 36 57.00 N (NAD83) Longitude: 122 18 32.00 W Height AMSL: 284.9 m HAAT: 249.0 m Peak ERP: 1000 kW Antenna: DIE-TFU-32DSB-R DC-S 250.0 deg Elev Pattrn: Generic Elec Tilt: 0.80

39.0 dBu contour: Azimuth ERP HAAT Distance 0.0 deg 372 kW 197.3 m 79.8 km 45.0 837 254.5 93.1 90.0 922 232.7 90.7 135.0 965 240.3 92.5 180.0 960 222.0 89.7 225.0 766 266.2 94.0 270.0 202 282.2 83.9 315.0 226 270.7 83.2

Database HAAT does not agree with computed HAAT Database HAAT: 249 m Computed HAAT: 246 m

**Proposal is within coordination distance of Canadian border Distance to Canadian border: 102.0 km

Distance to Mexican border: 1719.3 km

Conditions at FCC monitoring station: Ferndale WA Bearing: 353.1 degrees Distance: 150.0 km

Proposal is not within the West Virginia quiet zone area

Conditions at Table Mountain receiving zone: Bearing: 115.1 degrees Distance: 1593.2 km

No land mobile station failures found

Study cell size: 2.00 km Profile point spacing: 1.00 km Page 2 Maximum new IX to full-service and Class A: 0.50% Maximum new IX to LPTV: 2.00%

------Interference to BLANK0000087122 LIC scenario 1

Call Chan Svc Status City, State File Number Distance Desired: KFFV D16 DT LIC SEATTLE, WA BLANK0000087122

Undesireds: KCTS-TV D17 DT LIC SEATTLE, WA Ch17-Envelope 0.1 km KNDO D16 DT LIC YAKIMA, WA BLCDT20090217ACI 181.8 CHEK-DT D16 DT LIC VICTORIA, BC BLANKCANADA105 143.7

Service area Terrain-limited IX-free, before IX-free, after Percent New IX 17338.7 4,020,926 16372.1 3,987,153 15941.2 3,959,906 15901.0 3,954,016 0.25 0.15

Undesired Total IX Unique IX, before Unique IX, after KCTS-TV D17 DT LIC 40.2 5,890 40.2 5,890 KNDO D16 DT LIC 28.0 454 11.9 454 11.9 454 CHEK-DT D16 DT LIC 419.0 26,793 402.9 26,793 402.9 26,793

------Interference to BLANKCANADA92 LIC scenario 1

Call Chan Svc Status City, State File Number Distance Desired: CIVI-DT-2 D17 DT LIC VANCOUVER, BC BLANKCANADA92

Undesireds: KCTS-TV D17 DT LIC SEATTLE, WA Ch17-Envelope 199.1 km CHEK-DT D16 DT LIC VICTORIA, BC BLANKCANADA105 66.3 CH4388 D17 DC LIC BECHER BAY, BC BLANKCANLP30 121.3

Service area Terrain-limited IX-free, before IX-free, after Percent New IX 4961.3 235,725 4488.0 228,256 4319.2 227,355 4130.4 223,799 4.37 1.56 (in U.S.) 17926.2 2,878,875 14894.9 2,744,073 14597.8 2,729,103 14444.7 2,724,321 1.05 0.18

Undesired Total IX Unique IX, before Unique IX, after KCTS-TV D17 DT LIC 257.3 4,022 188.8 3,556 (in U.S.) KCTS-TV D17 DT LIC 249.6 4,782 153.1 4,782 CHEK-DT D16 DT LIC 112.4 279 108.4 173 84.3 106 (in U.S.) Page 3 CHEK-DT D16 DT LIC 293.1 14,970 289.1 14,970 196.6 14,970 CH4388 D17 DC LIC 60.4 728 56.4 622 16.1 329 (in U.S.) CH4388 D17 DC LIC 8.1 0 4.0 0 0.0 0

------Interference to proposal scenario 1 0.53% interference received

Call Chan Svc Status City, State File Number Distance Desired: KCTS-TV D17 DT LIC SEATTLE, WA Ch17-Envelope

Undesireds: KFFV D16 DT LIC SEATTLE, WA BLANK0000087122 0.1 km CH4388 D17 DC LIC BECHER BAY, BC BLANKCANLP30 125.7 CIVI-DT-2 D17 DT LIC VANCOUVER, BC BLANKCANADA92 199.1

Service area Terrain-limited IX-free Percent IX 24657.6 4,073,831 22829.0 4,043,814 22345.9 4,022,482 2.12 0.53

Undesired Total IX Unique IX Prcnt Unique IX KFFV D16 DT LIC 8.1 0 4.0 0 0.02 0.00 CH4388 D17 DC LIC 108.8 209 40.4 0 0.18 0.00 CIVI-DT-2 D17 DT LIC 438.7 21,332 366.1 21,123 1.60 0.52

Page 4 COHEN, DIPPELL AND EVERIST, P.C.

EXHIBIT E-3

DIRECTIONAL ANTENNA Relative Azimuth Field 0 0.610 10 0.790 20 0.880 30 0.900 40 0.910 50 0.920 60 0.930 70 0.940 80 0.950 90 0.960 100 0.970 110 0.975 120 0.980 130 0.980 140 0.985 150 1.000 160 0.985 170 0.980 180 0.980 190 0.980 200 0.980 210 0.980 220 0.920 230 0.830 240 0.720 250 0.600 260 0.480 EXHIBIT E-3 270 0.450 CHANNEL 17 280 0.550 PROPOSED DIRECTIONAL PATTERN 290 0.640 KCTS-TV, SEATTLE, WASHINGTON 300 0.640 DECEMBER 2020 310 0.550 320 0.400 330 0.280 340 0.305 350 0.420

ELEVATION PATTERN Proposal No. C-71656-1 Date 16-Dec-20 Call Letters KCTS Channel 17 Frequency 491 MHz Antenna Type TFU-20ETT/VP-R CT140 RMS Directivity at Main Lobe 18.6 ( 12.69 dB ) Beam Tilt 1.00 deg RMS Directivity at Horizontal 12.6 ( 11.00 dB ) Pattern Number 20E186100 Calculated 1 1

0.9 0.9

0.8 0.8

0.7 0.7

0.6 0.6

0.5 0.5

0.4 0.4

0.3 0.3 0.9 0.2 0.2

0.1 0.1

0 0 -3 -2 -1 0 1 2 3 4 5 6 7 8 9 10 11 -10 0 10 20 30 40 50 60 70 80 90 Degrees Below Horizontal Degrees Below Horizontal

Angle Field Angle Field Angle Field Angle Field Angle Field -10.0 0.075 10.0 0.125 30.0 0.043 50.0 0.011 70.0 0.031 -9.0 0.137 11.0 0.116 31.0 0.014 51.0 0.026 71.0 0.030 -8.0 0.079 12.0 0.054 32.0 0.053 52.0 0.040 72.0 0.026 -7.0 0.093 13.0 0.093 33.0 0.055 53.0 0.038 73.0 0.020 -6.0 0.164 14.0 0.089 34.0 0.019 54.0 0.023 74.0 0.013 -5.0 0.101 15.0 0.042 35.0 0.033 55.0 0.013 75.0 0.007 -4.0 0.190 16.0 0.084 36.0 0.055 56.0 0.029 76.0 0.006 -3.0 0.278 17.0 0.078 37.0 0.038 57.0 0.040 77.0 0.009 -2.0 0.119 18.0 0.026 38.0 0.010 58.0 0.038 78.0 0.011 -1.0 0.381 19.0 0.070 39.0 0.043 59.0 0.027 79.0 0.013 0.0 0.823 20.0 0.071 40.0 0.052 60.0 0.013 80.0 0.013 1.0 1.000 21.0 0.024 41.0 0.030 61.0 0.017 81.0 0.013 2.0 0.828 22.0 0.061 42.0 0.014 62.0 0.028 82.0 0.011 3.0 0.515 23.0 0.068 43.0 0.042 63.0 0.033 83.0 0.010 4.0 0.375 24.0 0.022 44.0 0.046 64.0 0.031 84.0 0.008 5.0 0.309 25.0 0.048 45.0 0.026 65.0 0.024 85.0 0.006 6.0 0.169 26.0 0.067 46.0 0.014 66.0 0.016 86.0 0.004 7.0 0.150 27.0 0.033 47.0 0.039 67.0 0.016 87.0 0.002 8.0 0.154 28.0 0.032 48.0 0.047 68.0 0.023 88.0 0.001 9.0 0.096 29.0 0.062 49.0 0.033 69.0 0.028 89.0 0.000 90.0 0.000

This document contains proprietary and confidential information of Dielectric. It is to be used solely for the purpose for which it is provided. No disclosure, reproduction, or use of this document or any part of it may be made without the written permission of Dielectric. COHEN, DIPPELL AND EVERIST, P.C.

FM ANTENNA MANUFACTURER ELEVATION PATTERNS Antenna Mfg.: Shively Labs Date: 6/28/2006 Antenna Type: 6014-5/3 Station: KUOW Beam Tilt 0 Frequency: 94.9 Gain (Max) 2.754 4.399 dB Channel #: 235 Gain (Horizon) 2.754 4.399 dB Figure: 3

0.9

0.8

0.7

0.6

0.5 Normalizedl Field

0.4

0.3

0.2

0.1

0 -60 -50 -40 -30 -20 -10 0 10 20 30 40 50 60 70 80 90 Elevation Angle (Deg) Antenna Mfg.: Shively Labs Date: 6/28/2006 Antenna Type: 6014-5/3 Station: KUOW Beam Tilt 0 Frequency: 94.9 Gain (Max) 2.754 4.399 dB Channel #: 235 Gain (Horizon) 2.754 4.399 dB Figure: 3 Angle of Angle of Angle of Angle of Depression Relative Depression Relative Depression Relative Depression Relative (Deg) Field (Deg) Field (Deg) Field (Deg) Field -90 0.000 -44 0.152 0 1.000 46 0.172 -89 0.020 -43 0.133 1 0.989 47 0.174 -88 0.038 -42 0.110 2 0.955 48 0.171 -87 0.056 -41 0.083 3 0.901 49 0.162 -86 0.073 -40 0.052 4 0.828 50 0.149 -85 0.090 -39 0.022 5 0.740 51 0.132 -84 0.107 -38 0.023 6 0.639 52 0.111 -83 0.123 -37 0.054 7 0.530 53 0.088 -82 0.139 -36 0.086 8 0.417 54 0.063 -81 0.154 -35 0.116 9 0.304 55 0.040 -80 0.169 -34 0.141 10 0.196 56 0.027 -79 0.182 -33 0.160 11 0.100 57 0.039 -78 0.195 -32 0.172 12 0.047 58 0.062 -77 0.206 -31 0.176 13 0.094 59 0.088 -76 0.217 -30 0.172 14 0.152 60 0.113 -75 0.226 -29 0.159 15 0.197 61 0.136 -74 0.233 -28 0.137 16 0.227 62 0.158 -73 0.239 -27 0.107 17 0.240 63 0.178 -72 0.244 -26 0.070 18 0.238 64 0.195 -71 0.246 -25 0.030 19 0.223 65 0.210 -70 0.246 -24 0.027 20 0.196 66 0.222 -69 0.244 -23 0.071 21 0.159 67 0.232 -68 0.239 -22 0.117 22 0.117 68 0.239 -67 0.232 -21 0.159 23 0.071 69 0.244 -66 0.222 -20 0.196 24 0.027 70 0.246 -65 0.210 -19 0.223 25 0.030 71 0.246 -64 0.195 -18 0.238 26 0.070 72 0.244 -63 0.178 -17 0.240 27 0.107 73 0.239 -62 0.158 -16 0.227 28 0.137 74 0.233 -61 0.136 -15 0.197 29 0.159 75 0.226 -60 0.113 -14 0.152 30 0.172 76 0.217 -59 0.088 -13 0.094 31 0.176 77 0.206 -58 0.062 -12 0.047 32 0.172 78 0.195 -57 0.039 -11 0.100 33 0.160 79 0.182 -56 0.027 -10 0.196 34 0.141 80 0.169 -55 0.040 -9 0.304 35 0.116 81 0.154 -54 0.063 -8 0.417 36 0.086 82 0.139 -53 0.088 -7 0.530 37 0.054 83 0.123 -52 0.111 -6 0.639 38 0.023 84 0.107 -51 0.132 -5 0.740 39 0.022 85 0.090 -50 0.149 -4 0.828 40 0.052 86 0.073 -49 0.162 -3 0.901 41 0.083 87 0.056 -48 0.171 -2 0.955 42 0.110 88 0.038 -47 0.174 -1 0.989 43 0.133 89 0.020 -46 0.172 0 1.000 44 0.152 90 0.000 -45 0.165 45 0.165

COHEN, DIPPELL, AND EVERIST, P.C.

TABLE I COMPUTED COVERAGE DATA FOR THE PROPOSED DTV OPERATION OF KCTS-TV, SEATTLE, WASHINGTON CHANNEL 17 1000 KW ERP 249 METERS HAAT DECEMBER 2020

Average* Effective Radial Elevation Effective Depression Radiated Distance to Contour Bearing 3.2 to 16.1 km Height Angle Power 48 dBu 41 dBu (N ° E, T) meters meters degrees kW km km 0 153.3 197.3 0.389 372.1 68.9 77.2 10 140.6 210.0 0.401 624.2 72.5 81.2 20 127.8 222.8 0.413 774.5 74.5 83.6 30 115.1 235.5 0.425 810.0 75.7 85.2 40 102.4 248.2 0.436 828.1 76.7 87.0 50 98.5 252.1 0.44 846.4 77.1 87.8 60 103.3 247.3 0.436 865.0 76.9 87.3 70 108.2 242.4 0.431 883.7 76.7 86.8 80 113.0 237.6 0.427 902.4 76.4 86.4 90 117.9 232.7 0.423 921.5 76.2 86.0 100 116.2 234.4 0.424 940.8 76.4 86.4 110 114.5 236.1 0.426 950.6 76.6 86.7 120 112.8 237.8 0.427 960.5 76.8 87.0 130 111.1 239.5 0.429 960.5 76.9 87.2 140 112.3 238.3 0.428 970.3 76.9 87.2 150 116.4 234.2 0.424 1000.0 76.7 87.0 160 120.5 230.1 0.42 970.3 76.3 86.2 170 124.5 226.1 0.416 960.5 75.9 85.7 180 128.6 222.0 0.413 960.5 75.6 85.3 190 118.8 231.8 0.422 960.5 76.3 86.3 200 109.0 241.6 0.431 960.5 77.0 87.5 210 99.1 251.4 0.439 960.5 77.8 89.0 220 89.3 261.3 0.448 846.4 77.9 89.3 230 82.6 267.9 0.453 689.0 77.3 88.3 240 79.1 271.5 0.456 518.4 76.1 86.3 250 75.5 275.1 0.459 360.0 74.4 83.9 260 72.0 278.6 0.462 230.4 72.3 81.3 270 68.4 282.2 0.465 202.5 71.8 80.9 280 71.0 279.6 0.463 302.5 73.8 83.2 COHEN, DIPPELL, AND EVERIST, P.C.

TABLE I COMPUTED COVERAGE DATA FOR THE PROPOSED DTV OPERATION OF KCTS-TV, SEATTLE, WASHINGTON CHANNEL 17 1000 KW ERP 249 METERS HAAT DECEMBER 2020

Average* Effective Radial Elevation Effective Depression Radiated Distance to Contour Bearing 3.2 to 16.1 km Height Angle Power 48 dBu 41 dBu (N ° E, T) meters meters degrees kW km km 290 73.5 277.1 0.461 409.6 75.2 85.2 300 76.0 274.6 0.459 409.6 75.0 84.8 310 78.6 272.0 0.457 302.5 73.2 82.3 320 88.0 262.6 0.449 160.0 69.2 77.7 330 104.3 246.3 0.435 78.4 64.5 72.7 340 120.6 229.9 0.42 93.0 64.3 72.5 350 137.0 213.6 0.405 176.4 66.4 74.5

*Based on data from FCC one-second data base.

COHEN, DIPPELL AND EVERIST, P.C.

TABLE II POPULATION AND AREA DATA KCTS-TV, SEATTLE, WASHINGTON LICENSED, CHANNEL 9, 21.7 KW ND, 249 METERS HAAT PROPOSED, CHANNEL 17, 1000 KW MAX DA, 249 METERS HAAT DECEMBER 2020

FCC Rule Section 73.622(f)(5)

The technical parameters cited herein finds the current licensed KCTS-TV, Channel 9, 36 dBu contour fully encompasses the 1000 kW directional Channel 17 proposed operation. Further the proposed 1000 kW directional Channel 17 operation is larger in terms of area and population served than the previous Channel 41 DTV KCTS-TV operation. However, the proposed 1000 kW, Channel 17 KCTS-TV operation will only cover 85.8% of the current licensed KCTS-TV, Channel 9 operation. It is noted that within that percentage shortfall are the public lands comprising Olympic National Forest, Mt. Rainier National Park, Wenatchee National Forest, and Mount Baker National Forest. A part of the coverage shortfall is due to the protection to the Canadian booster station CIVI-DT.

KCTS-TV as shown below is the largest in the market. Call Population Area 2010 sq. km KCTS-TV 4,177,824 28,773.8 KZJO 4,147,016 28,472.6 KOMO-TV 4,132,260 25,837.5 KIRO-TV 4,058,101 21,492.7 The above numbers are within service area, not interference-free.

Call Population Area 2010 sq. km

KCTS-TV 4,115,603 25,795.5 KZJO 4,097,776 25,508.1 KOMO-TV 4,083,986 23,466.7 KIRO-TV 4,029,240 20,180.8 The above numbers are interference-free.

COHEN, DIPPELL AND EVERIST, P.C.

TABLE III OTHER FULL-SERVICE DTV STATIONS PREDICTED TO SERVE THE LOSS AREA DECEMBER 2020

Two Services

Station Channel ERP/kW HAAT/Meters KWDK 34 123 695 KWPX-TV 33 400 716

Three Services

KWDK 34 123 695 KWPX-TV 33 400 716 KZJO 36 1000 287

Four Services East

KWDK 34 123 695 KWPX-TV 33 400 716 KZJO 36 1000 287

South

KCPQ 13 30 610 KWDK 34 123 695 KWPX-TV 33 400 716

-1- COHEN, DIPPELL AND EVERIST, P.C.

TABLE III OTHER FULL-SERVICE DTV STATIONS PREDICTED TO SERVE THE LOSS AREA DECEMBER 2020 (continued)

South

Station Channel ERP/kW HAAT/Meters KCPQ 13 30 610 KWDK 34 123 695 KWPX-TV 33 400 716 KZJO 36 1000 287

West

KCPQ 13 30 610 KWDK 34 123 695 KWPX-TV 33 400 716 KZJO 36 1000 287 KSTW 11 100 275.7

West

KCPQ 13 30 610 KZJO 36 1000 287 KOMO-TV 30 95 259

-2- COHEN, DIPPELL AND EVERIST, P.C.

TABLE III OTHER FULL-SERVICE DTV STATIONS PREDICTED TO SERVE THE LOSS AREA DECEMBER 2020 (continued)

Station Channel ERP/kW HAAT/Meters KCPQ 13 30 610 KZJO 36 1000 287 KOMO-TV 30 915 259 KSTW 11 100 275.1

Station Channel ERP/kW HAAT/Meters KCPQ 13 30 610 KZJO 36 1000 287 KOMO-TV 30 915 259 KVOS-TV 14 535 799

-3- COHEN, DIPPELL AND EVERIST, P.C.

TABLE III OTHER FULL-SERVICE DTV STATIONS PREDICTED TO SERVE THE LOSS AREA DECEMBER 2020 (continued)

North

Station Channel ERP/kW HAAT/Meters KBCB 19 165 757 KCPQ 13 30 610 KVOS-TV 14 535 799 KSTW 11 100 275.7

5+ Services

North

Station Channel ERP/kW HAAT/Meters KBCB 19 165 757 KCPQ 13 30 610 KVOS-TV 14 535 799 KWDK 34 123 695 KWPX-TV 33 400 716 KZJO 36 1000 287 KSTW 11 100 275.7 KOMO-TV 30 95 259 KIRO-TV 23 715 257

-4- COHEN, DIPPELL AND EVERIST, P.C.

TABLE III OTHER FULL-SERVICE DTV STATIONS PREDICTED TO SERVE THE LOSS AREA DECEMBER 2020 (continued)

South

Station Channel ERP/kW HAAT/Meters KCPQ 13 30 610 KWDK 34 123 695 KWPX-TV 33 400 716 KZJO 36 1000 287 KBTC-TV 27 100 220 KCKA 19 187 347 KSTW 11 100 275.7 KOMO-TV 30 915 259

-5-

COHEN, DIPPELL AND EVERIST, P.C.

TABLE IV DETAIL OF SERVICE COVERAGER DECEMBER 2020

2010* Population Population Percentage Losing KCTS-TV Service** 100,414 -- 2 Service 7 0.01% 3 Service 0 0% 4 Service 930 0.93% 5+ Service 99,477 99.07%

*TVStudy 2.2 interference-free population.

**Number reflects individuals who will lose KCTS-TV service. Loss is greater than shown in Table II because Table II population loss is offset by individuals who will gain KCTS-TV service.

EXHIBIT 2

STATEMENT OF JABRAN SOUBEIH, CASCADE PUBLIC MEDIA VICE PRESIDENT OF ENGINEERING & TECHNOLOGY IN SUPPORT OF PETITION OF CASCADE PUBLIC MEDIA TO AMEND THE TABLE OF ALLOTMENTS FOR KCTS-TV, SEATTLE WASHINGTON

EXHIBIT 2

1. My name is Jabran Soubeih. I make this statement, on the basis of my own personal knowledge, in support of the Petition of Cascade Public Media (“CPM”), licensee of digital television station KCTS-TV, Seattle, Washington, to Amend the Table of Allotments to substitute UHF Channel 17 in lieu of VHF Channel 9.

2. I am CPM’s Vice President of Engineering & Technology. I have served in that position since November 2016, and previously was employed by CPM as Executive Director of Engineering and Technical Planning since July 2008. In those positions, my responsibilities included tracking and attempting to resolve viewer complaints of poor reception and interference. Responsibilities also included implementing the FCC-ordered “repacking” of the television band and transition to DTV service for KCTS-TV.

3. Prior to the “repack” and DTV transition, KCTS operated in analog mode on VHF Channel 9. KCTS was assigned a pre-transition DTV channel on UHF channel 41 by the FCC. KCTS-DT went on the air in 1999 with a DTV UHF transmitter operating at 427kW, and, until the analog shutoff deadline, simulcast on both UHF Channel 41 and VHF Channel 9. KCTS was given the option to continue operating DTV on UHF channel 41 or relocate DTV transmission to VHF channel 9 after analog shutoff. Seeking to derive efficiencies from operating a more durable solid-state transmitter at the lower DTV power levels enabled by VHF, KCTS elected to operate in digital mode on VHF Channel 9. KCTS received a construction permit and authorization allowing KCTS DTV to operate at 21.7kW on VHF Channel 9, where it has operated since June 12, 2009.

4. Since KCTS began full power DTV operations from VHF channel 9, it has consistently received large numbers of complaints of poor reception and interference from OTA viewers. Here is a link to a Seattle Times article which appeared on June 22, 2009 describing the issues viewers were having: https://www.seattletimes.com/business/digital-pioneer-kcts-gets- static-over-switch-comcast-update/

5. Between 2012 (when KCTS instituted a new tracking system) and 2020, KCTS has logged over 1,000 such complaints. I reviewed and compiled records of over 300 such complaints to prepare this statement, and the following is a representative sampling of the nature and substance of viewer complaints received from throughout the KCTS service area between 2012 and 2020:

 “weak signal”

 “consistent reception problems”

 “I can’t get you”

 “[a]ll channels but 9 are consistent, Channel 9 reception fades to color blocks evenings and weekends.”

 “Just installed an antennas direct DB4 multi directional antenna. Channel 9 is the only channel we wanted and one of the only ones we don't receive. Do we need a vhf antenna instead. Any help you can provide will be much appreciated.”

 “Channel 9 on air has been fading out about 9pm recently, last several days.”

 “did the rescan after your conversion to VHF and was never able to restore channel 9. I purchased what I was told was the strongest indoor antenna available and still no channel 9. I had perfect reception when it was broadcasted over UHF. Is there any hope for service restoration--five years later?”

 All the commercial broadcast stations come in clear, but the auto scan shows NO sign of KCTS. Antenna is an RCA Amplified flat panel antenna. Signal on KOMO is 8/9 (Strong).”

 “I support Channel 9 but am not able to watch it due to poor reception. I have only received channel 9 once or twice. When I had my antenna installed I could get it, but it has disappeared except for one or two days over the last 5 months. Most disheartening!”

 “Looking at the towers in the area, I'm receiving everything but PBS. We've been here for about a week, & I was able to receive signal the first few days with the current antenna. I've added an amplifier for the signal which helped for a few channels, but I've not been able to rescan and receive for 9.1-etc with a full rescan. Is this a tower change? If not, we may just be having issues on the first floor of our apartment. Thank you!”

 “always gotten Channel 9, 9.2, and 9.3 since I've had this TV so this is very confusing and frustrating. Any other advice? Thank you!”

 “have an old tv with a rca converter box. That does not get 9 very often.”

 “For the last week I have been unable to access PBS/channel 9 on either television, no matter what changes I make. The app is on my phone, and I can see videos on there. I am very disappointed I missed the new seasonal start of CALL THE MIDWIFE. Please assist.”

 “I'm using an RCA ANT1500 digital flat antenna. When I do a channel scan, 9-1, 9-2, and 9-3 are found but there is little signal strength when I go to those channels. Has anyone near me been successful? What antenna do they use and how is it positioned?”

 “I thought that since I am able to receive Channel 11 very well, that I would also get Channel 9. Please help, we love PBS? My amp has an FM trap that is switched ON to assist VHF reception.”

 “Ever since getting the antenna and giving up cable I have not been able to get channel 9. I want to, and would support it if I could. Please tell me how. Thank you!”

 “Our antenna is located inside our attic. We can get channel 9 on one tv but not the other. Both tv's are digital. We used to be able to get channel 9 on this tv but have not been able to for some months even with repeated attempts to re-scan.” 6. In assisting viewers with rescan and other instructions, I found that many had purchased indoor OTA antennas sold as suitable for both UHF/VHF use, which simply did not receive our VHF DTV signal well. Some indoor UHF antennas have built-in amplifiers to improve UHF reception, these amplifiers also increase the noise floor causing potential problems for VHF signals, https://www.tvtechnology.com/opinions/solving-vhf-dtv-reception-problems. Certainly, their performance was far inferior compared to the notional outdoor antenna placed at 30 feet above ground used by the Commission to predict KCTS’ coverage area. 7. Many viewers tie their financial support of KCTS, an NCE station which depends on donations and support from viewers, to their ability to receive our programming OTA. The poor propagation and reception characteristics of our high-band VHF signal are placing us at a severe disadvantage compared to other full power DTV stations in our market, the vast majority of which operate on UHF frequencies. Moreover, because mobile “digital broadcast” devices are expected to use compact onboard antennas more suitable for UHF reception, I do not believe such devices will be able to reliably receive a quality VHF Channel 9 signal from KCTS in the forthcoming ATSC 3.0 operating environment, placing us at a further disadvantage in realizing the promise of the next generation of DTV services. I hereby certify under penalties of perjury that the foregoing statements are true and correct to the best of my knowledge, and made in good faith.

Dated: 1/6/2021 Jabran Soubeih, Vice President of Engineering & Technology Cascade Public Media