ENGINEERING STATEMENT

IN SUPPORT OF

APPLICATION FOR MINOR CHANGE TO CONSTRUCTION PERMIT WHDT

STUART, FL

Background

Scripps Broadcasting Holdings LLC (Scripps) is the licensee of WHDT which has been authorized to operate its post-incentive auction facility on Ch. 34 (LMS File No. 0000071602) at Stuart, FL with an ERP of 621 kW at an HAAT of 384.0m. The tower is located at the following coordinates:

26 35’ 21.2’’ N (NAD 83) 80 12’ 42.8’’ W

Scripps took possession of the station in early 2019 and it had intended to build the maximized post-incentive auction facility at the tower site listed above; unfortunately, after further research (structural studies of the tower and vendor consultation), there is no way Scripps would be able to build the facility at the tower site prior to the expiration date of the construction permit (October 9, 2019). Therefore, Scripps is proposing to modify the construction permit to specify the site of its current STA facility (ASR#1028084) which is already operating on its post- auction channel and utilizes a broadband antenna. The proposed facility will have the following parameters:

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Coordinates: 26 34’ 30.7’’ N (NAD 83) 80 14’ 31.1’’ W ERP: 943.1 kW (DA) RCAMSL: 444.2m Antenna: Dielectric TUA-SP4-12/48H-1-S-R

The azimuth and elevation patterns for the proposed antenna have been attached to the application.

Coverage

The entire principal community of Stuart, FL is well within the predicted F(50,90) 48 dBu contour based on the proposed directional 943.1 kW ERP. The noise-limited contour of the proposed facility exceeds the noise-limited contour of the main facility which is considered a “maximization”; however, the Commission has lifted the “freeze” on applications that would maximize a station’s coverage if the station was reassigned to a new channel as part of the incentive auction and has not yet completed the transition to its post-auction channel. WHDT was reassigned to a new channel as part of the incentive auction, and it did transition to its new channel, but only under STA. The proposed change to the WHDT construction permit, while technically a “maximization”, meets the criteria the Commission identified in its July 22, 2010 Public Notice (DA 19-684) for lifting the “freeze”, as Scripps only seeks to change the facility in order to complete construction by the October 9, 2019 construction permit deadline.

Furthermore, WHDT had previously had a construction permit (LMS File No. 0000034671) for a “maximized” facility at the proposed site that specified an ERP of 1000 kW with the same antenna RCAMSL as the proposed facility. This previously authorized facility is larger than the proposed facility which will have an ERP of 943.1 kW.

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The proposed ERP and HAAT for WHDT (943.1 kW at an HAAT of 440.0m) exceeds the maximum allowed under Part 73.622(f)(8) of the FCC Rules; however, Part 73.622(f)(5) allows "Licensees and permittees...may request an increase in ERP in some azimuthal direction or antenna HAAT, or both, that exceed the initial technical facilities specified..., up to the maximum permissible limits on DTV power and antenna height set forth in paragraph (f)(6), (f)(7), or (f)(8) of this section, as appropriate, or 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."

In the West Palm Beach DMA, the station with the largest geographic coverage area is WPTV-TV (Ch. 12). The terrain-limited coverage areas of the licensed WPTV-TV facility and the proposed 943.1 kW WHDT facility were calculated using the FCC TVStudy software (Version 2.2.5). A selected portion of the output of the tvstudy.txt file generated by TVStudy for each station is included below:

tvstudy v2.2.5 (4uoc83) Database: localhost, Station Data: LMS TV 2019‐08‐09, Study: WPTV‐BLCDT20090619ACF, Model: Longley‐Rice Start: 2019.08.13 16:49:53

Scenario Desired station Service area Terrain‐limited Interference‐free

Coverage WPTV‐TV D12 DT LIC WEST PALM BEACH, FL 39600.6 5,840,102 39600.6 5,840,102 39600.6

tvstudy v2.2.5 (4uoc83) Database: localhost, Station Data: LMS TV 2019‐08‐09, Study: WDHT‐WFLXSite‐943k, Model: Longley‐Rice Start: 2019.08.13 16:09:24

Scenario Desired station Service area Terrain‐limited Interference‐free

Coverage WHDT D34 DT APP STUART, FL 29610.5 5,768,239 29610.5 5,768,239 29610.5

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As can be seen from the TVStudy information, the calculated terrain-limited coverage area of the licensed WPTV-TV facility is 39600.6 sq. km while the calculated terrain-limited coverage area of the proposed WHDT facility is 29610.5 sq. km. Since the calculated coverage area of the proposed WHDT facility will still be less than the coverage area of the largest station in the West Palm Beach market, WHDT should be allowed to exceed the maximum allowable ERP and HAAT.

Interference

An interference check study was run using the FCC TVStudy software (Version 2.2.5) for the proposed WHDT post-repack maximized facility parameters. The summary results of the study show that the proposed facility is not predicted to cause more than 0.5% new interference to any other surrounding co-channel or adjacent channel post-repack facilities (see attached study results).

Environmental/RFR

This report addresses only the conditions specified in 47CFR1.1307 that deal with Radio Frequency Radiation. Any other non-RFR conditions that might require the preparation of an EA are beyond the scope of this report; since the structure is existing and registered, such conditions should not be an issue requiring further consideration.

The location of the proposed post-incentive auction facility is a multi-user site and it is assumed that the site is currently “in compliance” with FCC guidelines for human exposure to RFR (as defined in OET-65). The worst case ground level RFR contributed to the site by this proposal in public areas is calculated to be 0.007336 mW/cm2, which is less than 5% of the MPE for public exposure (0.395333mW/cm2) at Ch. 34 (590-596 MHz). The contribution to the overall RFR from

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the proposed facility is negligible and, therefore, the site will remain “in compliance” with FCC guidelines.

Scripps agrees to comply with the Commission’s requirements regarding power adjustments or cessation of operation as may be necessary to ensure a compliant environment for worker access. Workers will be trained on RFR issues and encouraged to wear personal RFR monitors when on the structure. The tower base is enclosed by a locked security fence and appropriate signage warning of potential RFR hazards is posted.

Certification

I hereby certify that the foregoing report or statement was prepared by me but may include work performed by others under my supervision or direction. The statements of fact contained therein are believed to be true and correct based on personal knowledge, information and belief unless otherwise stated; with respect to facts not known of my own personal knowledge, I believe them to be true and correct based on their origin from sources known to me to be generally reliable and accurate. I have prepared this document with due care and in accordance with applicable standards of professional practice.

Benjamin L. Pidek, P.E. August 14, 2019

Attached: WHDT TVStudy Interference Results

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WHDT Maximization TVStudy Summary Results

Study created: 2019.08.13 16:09:24

Study build station data: LMS TV 2019‐08‐09

Proposal: WHDT D34 DT APP STUART, FL File number: WDHT‐WFLXSite‐943k Facility ID: 83929 Station data: User record Record ID: 1460 Country: U.S. Zone: III

Search options: Non‐U.S. records included

Stations potentially affected by proposal:

IX Call Chan Svc Status City, State File Number Distance No WJAN‐CD D33 DC LIC MIAMI, FL BLANK0000055082 117.2 km No WOFL D33 DT CP ORLANDO, FL BLANK0000034529 240.3 No WOFL D33 DT BL ORLANDO, FL DTVBL41225 240.3 Yes WWHB‐CD D33 DC LIC STUART, FL BLANK0000072131 50.5 No WRXY‐TV D33 DT CP TICE, FL BLANK0000035687 156.1 No WRXY‐TV D33 DT LIC TICE, FL BLCDT20060627ABA 156.1 Yes WFTX‐TV D34 DT CP CAPE CORAL, FL BLANK0000026821 156.8 Yes WFTX‐TV D34 DT BL CAPE CORAL, FL DTVBL70649 156.8 Yes WUCF‐TV D34 DT CP ORLANDO, FL BLANK0000027156 240.4 Yes WUCF‐TV D34 DT BL ORLANDO, FL DTVBL12855 240.4 No WFTV D35 DT CP ORLANDO, FL BLANK0000034714 235.6 No WFTV D35 DT BL ORLANDO, FL DTVBL72076 235.6 No WFLX D35 DT LIC WEST PALM BEACH, FL BLANK0000070400 0.0

No non‐directional AM stations found within 0.8 km

No directional AM stations found within 3.2 km

Record parameters as studied:

Channel: D34 Latitude: 26 34 30.70 N (NAD83) Longitude: 80 14 31.10 W Height AMSL: 444.2 m HAAT: 440.0 m Peak ERP: 943 kW Antenna: DIE‐TUA‐SP4‐12/48H‐1‐S‐R (ID 1004815) 0.0 deg Elev Pattrn: Generic Elec Tilt: 0.75

40.7 dBu contour: Azimuth ERP HAAT Distance 0.0 deg 943 kW 439.4 m 109.9 km 45.0 351 439.2 100.1 90.0 78.2 439.4 88.2 135.0 358 438.7 100.2 180.0 943 441.2 110.0 225.0 351 440.2 100.1 270.0 78.2 440.2 88.3

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315.0 358 440.2 100.3

ERP exceeds maximum ERP: 943 kW ERP maximum: 699 kW

Distance to Canadian border: 1690.0 km

Distance to Mexican border: 1662.8 km

Conditions at FCC monitoring station: Vero Beach FL Bearing: 341.4 degrees Distance: 121.0 km

Proposal is not within the West Virginia quiet zone area

Conditions at Table Mountain receiving zone: Bearing: 309.5 degrees Distance: 2750.1 km

Study cell size: 2.00 km Profile point spacing: 1.00 km

Maximum new IX to full‐service and Class A: 0.50% Maximum new IX to LPTV: 2.00%

No IX check failures found.

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CORPORATE OFFICE REGIONAL OFFICE 1475 NORTH 200 WEST 6197 MILLER RD. NEPHI, UT 84648 SWARTZ CREEK, MI 48473

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