Modification to a Licensed Television Broadcast Station Mesa, AZ TABLE of CONTENTS
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Prepared For: Multimedia Holdings Corporation a subsidiary of TEGNA Inc. 8350 Broad Street, Suite 2000 Tysons, VA 22102 MODIFICATION TO A LICENSED Prepared By: Ryan Wilhour TELEVISION BROADCAST Consulting Engineer Kessler and Gehman Associates STATION 507 NW 60th Street, Suite D Gainesville, FL 32607-2055 352-332-3157 Extension 3 [email protected] www.kesslerandgehman.com CALL SIGN: KPNX-TV FACILITY ID: 35486 FCC FILE NO.: 20090618AAM LOCATION: MESA, AZ June 18, 2020 KPNX-TV – Modification to a Licensed Television Broadcast Station Mesa, AZ TABLE OF CONTENTS 1.0 CHANNEL MODIFICATION APPLICATION .......................................................... 2 2.0 ALLOCATION ANALYSIS ..................................................................................... 2 3.0 SECTION 73.622(f)(5) - LARGEST STATION IN THE MARKET ANALYSIS ....... 2 4.0 § 73.625 COMMUNITY OF LICENSE COMPLIANCE........................................... 3 5.0 NOISE LIMITED CONTOUR AND POPULATION LOSS ANALYSIS ................... 3 6.0 RADIO FREQUENCY RADIATION COMPLIANCE............................................... 5 7.0 CERTIFICATION ................................................................................................... 6 APPENDIX A – Proposed TVStudy V2.2.5 Allocation Analysis ....................................... 7 APPENDIX B – Licensed TVStudy V2.2.5 Allocation Analysis ........................................ 9 APPENDIX C – § 73.625 Predicted Community of License Contours ........................... 11 APPENDIX D – Population Loss for Underserved Areas .............................................. 12 APPENDIX E – Population Loss for Gray and Underserved Areas ............................... 13 APPENDIX F – Population Loss for White Space Served Areas .................................. 14 APPENDIX G – Far Field Exposure to RF Emissions ................................................... 15 APPENDIX H – Antenna Azimuth Pattern ..................................................................... 16 Page 1 KPNX-TV – Modification to a Licensed Television Broadcast Station Mesa, AZ 1.0 CHANNEL MODIFICATION APPLICATION Multimedia Holdings Corporation (MHC) is the licensee of a television broadcast station having call sign KPNX-TV facility ID 35486. It is herein proposed to • Change the channel from VHF 12 to UHF 18, • Increase the ERP from 39kW to 1MW, • Change the antenna azimuth pattern from non-direction to directional as demonstrated in Appendix H. 2.0 ALLOCATION ANALYSIS KPNX-TV operating on channel 18 with 1000kW through a non-directional antenna would cause 1.82% prohibited interference to KFTU-CD. A Dielectric C170 azimuth pattern was chosen to allow KPNX-TV to operate at 1000kW and simultaneously protect KFTU-CD from prohibited interference. Appendix A is a TVStudy V2.2.5 study which demonstrates that there are no interference failures or other allocation issues for the proposed facility. 3.0 SECTION 73.622(f)(5) - LARGEST STATION IN THE MARKET ANALYSIS Appendix A indicates that the proposed 1000kW ERP exceeds the 392kW maximum allowable ERP threshold. Section 73.622(f)(5) of the FCC rules indicate that licensees and permittees may request an increase in either ERP in some azimuthal direction or antenna HAAT, or both, up to that needed to provide the same geographic coverage area as the largest station within their market, whichever would allow the largest service area. A TVStudy V2.2.5 noise limited contour analysis of the proposed and licensed KPNX-TV facilities determine that they have a geographical coverage area of 40,279.7 km² and 47,062.6 km² as shown in Appendix A and B, respectively. As such, the licensed facility is larger than the proposed facility; thus, the proposed Page 2 KPNX-TV – Modification to a Licensed Television Broadcast Station Mesa, AZ facility is compliant with Section 73.622(f)(5) of the rules and may exceed the otherwise applicable 392kW ERP limitation. 4.0 § 73.625 COMMUNITY OF LICENSE COMPLIANCE Appendix C illustrates the § 73.625 F(50,90) 48 dBµV/m and 43 dBµV/m principal community of license proposed and licensed contours respectively. As demonstrated the 48 dBµV/m proposed contour completely subsumes the principal community of license as required. The Appendix C predicted coverage contours were generated using V-Soft Probe-31 software in accordance with § 73.625(b) methodology using F(50,90) propagation curves. The average terrain was extracted from three arc second terrain along eight equally spaced cardinal radials from 3 kilometers to 16 kilometers from the site and beginning from true north. 5.0 NOISE LIMITED CONTOUR AND POPULATION LOSS ANALYSIS Appendix A and B are long form allocation study results generated by TVStudy V2.2.5 for the proposed and licensed facilities which determines that 4,120,968 and 4,184,138 people respectively are predicted to receive a nominal signal after interference and terrain limitations are considered. When considering the results of TVStudy, the population is reduced by 63,170 people which is a 1.53% population reduction. The FCC weighs the public interest when a television broadcast facility proposes a service area contraction. The FCC defines “white area” as locations where the population does not receive any over-the-air television service, “gray area” as locations where the population receives only one over-the-air television service2 and “underserved area” where the population receives less than five other 1 Version 3.101 2 See Apogee, Inc., 99 FCC 2d 979, ¶ 7 (1985). Page 3 KPNX-TV – Modification to a Licensed Television Broadcast Station Mesa, AZ existing services.3 Appendix D, E, and F are contour density maps for illustrating underserved, gray, and white areas as it relates to the terrain limited population loss regions that exist between the licensed and proposed noise limited contours. Appendix D, E, and F were generated using PROGIRA Plan Version 7.1.0 to predicted coverage contours and Longley-Rice terrain limited coverage area and corresponding populations in accordance with § 73.625(b) methodology using F(50,90) propagation curves and OET Bulletin Number 69 settings along with 2010 Census and 3 arc second terrain data. The terrain limited 36dBµV/m baseline population within the contour is 4,184,025 people according to PROGIRA plan and 4,184,428 people according to TVStudy V2.2.5 and is due to rounding and computing differences between the two platforms and introduces an 0.0096% error between the two figures. In order to provide consistency the PROGRIA plan baseline figure of 4,184,025 people will be used to serve as the baseline for the denominator for the percent reduction percentage calculated from Appendix D, E, and F. The results of the three appendices are as follows: • Appendix D - Underserved populations: 219 people or a 0.005% loss • Appendix E - Gray and Underserved populations: 26 people or a 0.0006% loss • Appendix F – White populations: 0 people or a 0.0% loss As illustrated when considering underserved, gray and white contour overlap methodology, the population loss is insignificant. Many Over-The-Air (OTA) receivers in the Phoenix DMA use indoor rabbit ear style antennas. It is well documented that indoor digital VHF reception is substandard when compared to UHF reception even when the stations have a similar geographical size and transmitter location. Although insignificant contour population loss is demonstrated above, grant of the requested channel 3 See Cambridge and St. Michaels, Maryland, 19 FCC Rcd 2592 (AD 2004). Page 4 KPNX-TV – Modification to a Licensed Television Broadcast Station Mesa, AZ substitution serves the public interest since it would allow KPNX-TV to broadcast on a channel capable of providing much improved in-home OTA reception. 6.0 RADIO FREQUENCY RADIATION COMPLIANCE A theoretical analysis has been conducted of the human exposure to radio frequency radiation (“RFR”) using the calculation methodology described in OET Bulletin 65, Edition 97-01. The RFR analysis is conducted pursuant to the following methodology: Terrain4 extraction is compiled from the proposed tower site to radial lengths of 0.25 miles in 0.001 mile increments for 360 radials. The power density is calculated for each terrain point at 6 feet above ground level using the elevation and azimuth pattern of the proposed broadcast antenna. The power density calculations are conducted using the lower edge of the proposed channel frequency. To account for ground reflections, a coefficient of 1.6 was included in the calculation. The resulting cylindrical polar analysis is then summarized into a coordinate plane graph using the following methodology: Starting from the origin the maximum calculated RFR value is determined among the 360-degree radials for each 0.001 mile increment, the value is then converted into a percentage of the maximum allowable general population or uncontrolled exposure and plotted as a function of perpendicular distance from the tower. The resulting RFR study in Appendix G demonstrates that the peak exposure is 1.70% of the most restrictive permissible exposure threshold. Pursuant to OET Bulletin 65 concerning multiple-user transmitter sites only those licensees whose 4 Terrain extraction is based upon a 3 arc second point spacing terrain database. Page 5 KPNX-TV – Modification to a Licensed Television Broadcast Station Mesa, AZ transmitters produce power density levels greater than 5.0% of the exposure limit are considered significant contributors to RFR. Since the proposed operation is within 5% of the most permissible