Before the FEDERAL COMMUNICATIONS COMMISSION Washington DC 20554
In the Matter of ) ) Amendment of Section 73.622, ) MB Docket No. _____ Digital Television Table of Allotments ) For WVPT(TV), Staunton, VA ) Rulemaking No. _____ (Facility 60111) )
To: Office of the Secretary, Federal Communications Commission Attn: Chief, Media Bureau
PETITION FOR RULEMAKING
VPM Media Corporation (“VPM”), licensee of noncommercial educational television station WVPT(TV) (“WVPT” or “the Station”), Staunton, Virginia, hereby requests that the Commission institute a rulemaking proceeding for the purpose of amending the DTV Table of Allotments (the “DTV Table”) contained in Section
73.622(i) of the Commission’s rules.1 VPM requests that the Commission amend the
DTV Table to substitute UHF Channel 15 (reserved educational) for VHF Channel 11
(reserved educational)2 with the technical parameters set forth in the attached
Engineering Statement. As set forth herein, grant of this Petition will create a preferential
1 See 47 C.F.R. §§ 1.401, 1.420, 73.622(i). 2 In the Closing and Channel Reassignment Public Notice, the FCC assigned WVPT to transition from channel 11 to channel 12. See Incentive Auction Closing and Channel Reassignment Public Notice: The Broadcast Television Incentive Auction Closes; Reverse Auction and Forward Auction Results Announced; Final Television Band Channel Assignments Announced; Post-Auction Deadlines Announced, Public Notice, 32 FCC Red 2786 (WTB & MB 2017). VPM has a pending construction permit to relocate WVPT to channel 12, on which it is operating pursuant to special temporary authorization, but the Station is still licensed to operate on channel 11. See File Nos. 0000028448 (construction permit); 0000129932 (tolling); BLEDT-20130214ACP (license). arrangement of allotments by expanding the availability of free over-the-air television
service in this market.
The FCC has described the goal of the DTV Table as ensuring the provision of
digital television service “to the American people in an expeditious and efficient
manner.”3 In considering channel substitution requests, the Commission considers the
petitioner’s public interest justification and whether the proposal would comply with the
principal community coverage requirements of Section 73.625(a).4
This channel substitution serves the public interest in at least two ways.
First, it will resolve significant over-the-air (“OTA”) reception problems in
WVPT’s existing service area.5 With viewers increasingly reliant on OTA signals to receive the most valued video content,6 providing a strong broadcast signal is more
3 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 (2004); In the Matter of Amendment of Section 73.622(B), Table of Allotments, Digital Television Broadcast Stations (In the Matter of Amendment of Section 73.622(B), Table of Allotments, Digital Television Broadcast Stations (Albany, New York), 19 FCC Rcd. 4279, 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). 4 See, e.g., 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) (“Mesa NPRM”); 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 Broad. Stations, Moscow, Idaho, Notice of Proposed Rulemaking, 17 FCC Rcd. 19447 (2002). 5 See Mesa NPRM ¶ 6 (recognizing effect of “VHF propagation challenges”); In Re Amendment of Section 73.622(b), Table of Allotments, Digital Television Broadcast Stations, Missoula, Mt, Notice of Proposed Rulemaking, 16 FCC Rcd. 2227 (2001) (finding that proposal to substitute channels to improve signal coverage and eliminate interference “warrants consideration”). 6 See, e.g., Parks Associates, TV Antenna Usage in US Broadband Households Jumped to 25% in 2019 and Is Expected to Grow More as COVID-19 Keeps Consumers 2 important than it has been in decades. Yet, the challenges with digital reception of VHF
signals are well-documented. Ten years ago, the Commission recognized the deleterious
effects manmade noise has on the reception of VHF signals, finding that “the propagation
characteristics of these channels allow undesired signals and noise to be receivable at
relatively farther distances, nearby electrical devices tends to emit noise in this band that
can cause interference, and reception of VHF signals requires physically larger antennas
… relative to UHF channels.”7 The Commission also observed the “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.”8
These observations are consistent with WVPT’s real-world experience. WVPT
routinely receives calls from viewers with two different reception issues based on
WVPT’s VHF channel. In the first instance, viewers located within WVPT’s predicted
coverage area are unable to receive an OTA signal due to a deficient antenna system that
can receive the UHF channels in the market, but not WVPT. The consumer confusion is
magnified because WVPT’s virtual (PSIP) channel suggests that it should be a UHF
at Home (Mar. 26, 2020), http://www.parksassociates.com/blog/article/pr-02762020 (finding that OTA viewing increased from 15% in 2018 to 25% in 2019); Phil Kurz, New Research Reveals Resurgence in OTA Antenna Viewing, TVTechnology (Apr. 29, 2019), available at https://www.tvtechnology.com/news/new-research-reveals-resurgence-in- ota-antenna-viewing (finding that viewers consume 19% of viewing time over the air); The Evolving Over-the-Air Home, Nielsen Local Watch Report (Jan. 14, 2019), available at https://www.nielsen.com/wp-content/uploads/sites/3/2019/04/q2-2018-local-watch- report.pdf (finding that more than 14% of TV households lack cable or satellite service). 7 See Matter of Innovation in the Broadcast Television Bands: Allocations, Channel Sharing and Improvements to VHF, Notice of Proposed Rulemaking, 25 FCC Rcd. 16498 ¶ 42 (2010) (recognizing that “VHF channels have certain characteristics that have posed challenges for their use in providing digital television service.”). 8 Id. ¶ 44. 3 station, not a VHF station. In the second instance, viewers who previously received
WVPT’s OTA signal either intermittently or permanently lose the signal due to
interference from sources including LED lighting, CF lighting, electric motors, electric
dryers, solar panels, kitchen appliances, a bird bath heater, Christmas lights, phone
chargers, pool pumps, a wood stove blower, and electric utility pole insulator failure.
Although some of these cases can be resolved, other times the sources of interference are
outside the viewer’s control. Furthermore, when there is lightning activity in the area, the
VHF signal can be virtually unwatchable for hours at a time. Moving WVPT from
channel 11/12 to channel 15 will solve the problems associated with VHF reception that
make it difficult for viewers to receive WVPT’s noncommercial educational programming without a subscription service.
Second, the proposed channel substitution will allow for a more efficient construction of WVPT’s post-incentive auction facilities. VPM initially planned to retune
WVPT’s existing distributed transmission system (“DTS”) transmitters from channel 11 to channel 12. After VPM placed its orders, however, the transmitter manufacturer declared bankruptcy and neither the transmitter manufacturer nor the antenna manufacturer were able to support the planned retuning effort. Meanwhile, in February
2020, the manufacturer of the existing tower, Valmont, performed a structural analysis
which revealed that the existing tower at Elliott Knob cannot support a replacement
antenna on channel 12.9 Not only is UHF equipment more readily available, but UHF
antennas are lighter than VHF antennas. As a result, transitioning to channel 15 should
9 For a more detailed description of VPM’s efforts, see VPM’s Request for Tolling Waiver, File No. 0000129932.
4 obviate the need for VPM to construct a new tower for WVPT—saving both time and money.
Attached is an Engineering Statement of Doug Vernier Telecommunications
Consultants,10 which sets forth in detail the proposed WVPT Channel 15 DTV Table specifications. 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. The proposed Channel
15 facilities will provide full principal community coverage to Staunton, Virginia.
As further demonstrated by the attached Engineering Statement, when compared to WVPT’s existing service, the proposed Channel 15 facilities will cover 1,025,057 people, a net gain of 56,813 people. Although there is a small loss area that covers 27,033 people, as demonstrated by Exhibit 2 to the Engineering Statement, most of the loss area is at the southwest portion of WVPT’s contour, where 7-10 services will remain, including service from noncommercial educational television station WBRA-TV.11 As demonstrated by Exhibit 4 to the Engineering Statement, the only areas that will receive fewer than five stations as a result of the proposed channel change do not receive noise-
10 See Attachment 1 (“Engineering Statement”). 11 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).
5 limited coverage from WVPT today.12 In practice, VPM expects few if any persons who are currently able to receive WVPT’s OTA signal on Channel 12 would no longer be able to receive WVPT’s OTA signal as a result of the transition to Channel 15. Meanwhile, any losses are offset by WVPT’s increased coverage to the north, providing a second, third, fourth, and fifth service, and a first noncommercial educational service, to many viewers.
For the foregoing reasons, VPM respectfully requests that the Commission grant this Petition and immediately commence a rulemaking proceeding to change the digital allotment for WVPT from Channel 11 to Channel 15 as proposed herein.
Respectfully submitted,
VPM MEDIA CORPORATION
By: _/s/ Ari Meltzer______Ari Meltzer Wiley Rein LLP 1776 K Street NW Washington DC 20006 202.719.7467 [email protected]
Dated: May 27, 2021
12 See WSET, Inc.,80 FCC 2d 233, 246 (1980) (finding loss area population of 500 de minimis).
6 Attachment 1
May 24, 2021
Engineering Statement in Support of Petition to Amend
the Television Table of Assignments
The applicant, VPM Media Corporation, operators of WVPT-TV, Staunton, Virginia, a full-service public TV facility, proposes to substitute its licensed VHF channel 111 with UHF channel 15. The station has experienced a substantial loss of viewers within its prescribed coverage area due to the poor propagation characteristics of the VHF channel, made worse by the area’s rugged terrain and the fact the other licensed stations in the area are nearly all UHF. The applicant proposes that the channel be defined as “educational” and the asterisk seen in the table of assignments would be changed to channel 15*, while the existing channel 11 educational, or 12, set-aside will be removed from the table.
We have performed a channel study using the Commission’s procedures, set forth in OET Bulletin No. 69, “Longley-Rice Methodology for Evaluating TV Coverage and Interference”. We find that the proposed facility2 will not cause interference, of more than 0.5%, to any other full-service licensed facility. No interference will be caused to land mobile installations, when operating on channel 15. Attached, as Exhibit #1, is the full print-out from the Commission’s own TVStudy computer program. The proposal will meet the principal city requirements of Sec. 73.625 (a).
Proposed coordinates: 38-09-54.4 N, 79-18-50.1 W.
Any adjustment of the proposed transmission site from that proposed will not be more than 0.1 km from the current licensed coordinates of the WVPT-1 main transmission site coordinates. The antenna will have a deep null to the west to protect Green Bank observatory. The noise-limited-service contour of the new antenna pattern will cover a population of 1,025,057 people for an area of 29,405.9 sq kmi This is 104.9 percent of the currently served population:
Population Gained: 83,846, Area Gained: 5,562.4 sq km
Population lost: 27,033, Area lost 3,104.9 sq km
Exhibit #2 is a comparative map of the noise limited coverage of the current VHF facilities compared to the coverage when on channel 15 UHF.
A study of TV stations servicing the lost area, based on their FCC noise-limited-service contours, finds that there are three small contiguous areas where the service count drops below 5. The map shown in Exhibit #3 is based on channel 15 transmission. The loss area between the existing channel 12 N.L. contour and the proposed channel 15 N.L. contour has been identified. The map defines the service counts in this area to be 2, 3 and 4 services. Exhibit #4 is a service count map of WVPT when on channel 12. Exhibit #5 Is a zoomed in scale map of the channel 15 noise-limited-service coverage within the areas as defined above. This map shows that the area is not served with either channel 15 or channel 12,
1 WVPT-TV operates with an STA on channel 12 2 The OET 69 analysis was done for a 263-kW facility at the licensed antenna height. therefore no loss of viewers will occur. All the rest of the loss area is supplied service of at least five full- time TV stations or more. In fact, the proposal will also increase the number of available services to the north of WVPT where, based on the current channel 12 facilities, some areas have only a very few channels including one area with only one service. (See Exhibit #4) It should be noted that TVStudy predicts the incoming interference to the proposed four-transmitter DTS system be 14.07 percent, while V-Soft Communication’s Probe 5 (in daily use at the FCC, and Industry Canada, Department of Innovation, Science and Economic Development Canada) shows the interference to be well less at 8.5%. The petitioner is very willing to accept this level of predicted interference, as it is comparable to the interference it has received on its licensed channel and the interference can be ameliorated by using the proposed UHF frequency.
Based on the excellent past experiences of numerous TV stations, throughout the country, that made the change to UHF, we are confident that the move to channel 15 will be an excellent improvement for WVPT-TV’s currently poor viewership coverage.
Exhibit #6 is documentation of my qualifications to prepare this engineering statement.
Petition Proposal: Substitute channel 15* for channel 11 (keep as educational)
Remove channel 11* from the table of assignments.
i 2010 U.S. Census (At this time the 2020 census was not yet available.) tvstudy v2.2.5 (4uoc83) Database: 127.0.0.1, Study: BLANK0000055362 #133, Model: Longley-Rice Start: 2021.05.14 13:13:26
Study created: 2021.05.14 13:13:26
Study build station data: LMS TV 2021-05-10
Proposal: WVPT D15 DD LIC STAUNTON, VA File number: BLANK0000055362 Facility ID: 60111 Station data: User record Record ID: 136 Country: U.S. Zone: I Ref. lat.: 38 09 54.40 N Ref. long.: 79 18 50.10 W # DTS sites: 4
Search options: Baseline record excluded if station has CP
Stations potentially affected by proposal:
IX Call Chan Svc Status City, State File Number Distance No WXIX-TV D15 DT LIC NEWPORT, KY BLANK0000087069 466.6 km No W15EB-D D15 DC CP CHARLOTTE, NC BLANK0000127538 357.9 No W15EB-D D15 DC LIC CHARLOTTE, NC BLANK0000083736 357.9 Yes WRAZ D15 DT LIC RALEIGH, NC BLANK0000143683 285.5 No WEWS-TV D15 DT LIC CLEVELAND, OH BLCDT20091211ACS 411.5 Yes WQCW D15 DT LIC PORTSMOUTH, OH BLANK0000100248 256.2 No WPSU-TV D15 DD LIC CLEARFIELD, PA BLEDT20130614ACC 337.1 No WLTX D15 DT LIC COLUMBIA, SC BLANK0000082085 470.5 No WTNZ D15 DT LIC KNOXVILLE, TN BLANK0000081278 477.0 Yes WFDC-DT D15 DT LIC ARLINGTON, VA BLANK0000041206 212.3 No WXII-TV D16 DT LIC WINSTON-SALEM, NC BLANK0000081027 219.9 No WINP-TV D16 DT LIC PITTSBURGH, PA BLANK0000098050 259.6
No non-directional AM stations found within 0.8 km
5/14/2021 1:19:08 PM Page 1 No directional AM stations found within 3.2 km
Record parameters as studied, DTS site # 1:
Channel: D15 Latitude: 38 9 54.40 N (NAD83) Longitude: 79 18 50.10 W Height AMSL: 1333.0 m HAAT: 689.0 m Peak ERP: 263 kW Antenna: TUL-BP2-6-12M-1 112.0 deg Elev Pattrn: TUL-BP2-6-12M-1 Elec Tilt: 2.00
38.8 dBu contour: Azimuth ERP HAAT Distance 0.0 deg 2.79 kW 680.7 m 77.4 km 45.0 0.001 664.5 25.8 90.0 4.24 779.1 83.2 135.0 171 711.3 113.8 180.0 232 726.4 117.4 225.0 114 615.3 106.1 270.0 239 655.4 114.4 315.0 160 604.2 108.6
Database HAAT does not agree with computed HAAT Database HAAT: 689 m Computed HAAT: 680 m
ERP exceeds maximum ERP: 263 kW ERP maximum: 263 kW
Record parameters as studied, DTS site # 2:
Channel: D15 Latitude: 37 59 0.00 N (NAD83) Longitude: 78 29 1.00 W Height AMSL: 495.1 m HAAT: 333.0 m
5/14/2021 1:19:08 PM Page 2 Peak ERP: 1.00 kW Antenna: TUL-2BP(SP)-15.AZ 0.0 deg Elev Pattrn: TUL-2BP(SP)-15.AZ
38.8 dBu contour: Azimuth ERP HAAT Distance 0.0 deg 0.998 kW 354.2 m 58.7 km 45.0 0.279 266.9 47.3 90.0 0.008 379.1 31.6 135.0 0.003 366.8 27.0 180.0 0.371 359.0 53.7 225.0 0.962 323.8 57.0 270.0 0.136 278.0 44.1 315.0 0.173 320.1 47.5
Database HAAT does not agree with computed HAAT Database HAAT: 333 m Computed HAAT: 331 m
Record parameters as studied, DTS site # 3:
Channel: D15 Latitude: 38 20 39.40 N (NAD83) Longitude: 79 35 46.10 W Height AMSL: 1338.0 m HAAT: 470.0 m Peak ERP: 0.010 kW Antenna: SCA CL-1469 0.0 deg Elev Pattrn: SCA CL-1469
38.8 dBu contour: Azimuth ERP HAAT Distance 0.0 deg 0.010 kW 404.7 m 34.0 km 45.0 0.000 260.2 14.3 90.0 0.000 573.6 0.4 135.0 0.000 654.3 0.4 180.0 0.000 577.0 0.4 225.0 0.000 489.5 0.4 270.0 0.000 372.5 0.4 315.0 0.000 316.1 15.5
5/14/2021 1:19:08 PM Page 3 Database HAAT does not agree with computed HAAT Database HAAT: 470 m Computed HAAT: 456 m
Record parameters as studied, DTS site # 4:
Channel: D15 Latitude: 38 36 3.90 N (NAD83) Longitude: 78 37 56.80 W Height AMSL: 962.0 m HAAT: 0.0 m Peak ERP: 0.025 kW Antenna: TUL-C2SP-15 COS 66_33.AZ 230.0 deg Elev Pattrn: TUL-C2SP-15 COS 66_33.AZ
38.8 dBu contour: Azimuth ERP HAAT Distance 0.0 deg 0.011 kW 652.6 m 40.0 km 45.0 0.003 641.1 31.4 90.0 0.024 667.1 44.8 135.0 0.013 500.3 38.2 180.0 0.000 655.1 3.7 225.0 0.000 540.3 0.1 270.0 0.000 619.0 0.1 315.0 0.002 621.3 28.2
Database HAAT does not agree with computed HAAT Database HAAT: 0 m Computed HAAT: 612 m
**DTS proposal has coverage outside reference facility and distance limit
Distance to Canadian border: 438.9 km
Distance to Mexican border: 2126.1 km
Conditions at FCC monitoring station: Laurel MD DTS site # 1 Bearing: 62.0 degrees Distance: 243.2 km DTS site # 2 Bearing: 47.2 degrees Distance: 195.3 km DTS site # 3 Bearing: 68.4 degrees Distance: 257.2 km
5/14/2021 1:19:08 PM Page 4 DTS site # 4 Bearing: 67.6 degrees Distance: 168.8 km
**Proposal is within the West Virginia quiet zone area
Conditions at Table Mountain receiving zone: DTS site # 1 Bearing: 283.8 degrees Distance: 2236.1 km DTS site # 2 Bearing: 284.4 degrees Distance: 2311.5 km DTS site # 3 Bearing: 283.3 degrees Distance: 2207.5 km DTS site # 4 Bearing: 282.8 degrees Distance: 2282.8 km
No land mobile station failures found
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%
------Interference to BLANK0000143683 LIC scenario 1
Call Chan Svc Status City, State File Number Distance Desired: WRAZ D15 DT LIC RALEIGH, NC BLANK0000143683
Undesireds: WVPT D15 DD LIC STAUNTON, VA BLANK0000055362 285.5 km WRDC D14 DT LIC DURHAM, NC BLANK0000125503 0.0 W15EB-D D15 DC CP CHARLOTTE, NC BLANK0000127538 219.2 WLTX D15 DT LIC COLUMBIA, SC BLANK0000082085 268.9 WFDC-DT D15 DT LIC ARLINGTON, VA BLANK0000041206 384.8 WPXU-TV D16 DT LIC JACKSONVILLE, NC BLANK0000129487 161.6 WXII-TV D16 DT LIC WINSTON-SALEM, NC BLANK0000081027 183.3
Service area Terrain-limited IX-free, before IX-free, after Percent New IX 48202.4 3,800,594 48030.7 3,797,515 47458.9 3,733,396 46985.3 3,723,765 1.00 0.26
Undesired Total IX Unique IX, before Unique IX, after WVPT D15 DD LIC 545.4 12,558 473.6 9,631
5/14/2021 1:19:08 PM Page 5 WRDC D14 DT LIC 4.0 208 4.0 208 4.0 208 W15EB-D D15 DC CP 84.5 3,613 32.1 1,110 28.1 1,062 WLTX D15 DT LIC 60.2 1,385 23.9 660 19.9 448 WFDC-DT D15 DT LIC 31.8 718 31.8 718 8.0 88 WPXU-TV D16 DT LIC 107.2 1,304 107.2 1,304 107.2 1,304 WXII-TV D16 DT LIC 340.5 59,632 320.4 57,616 288.5 55,941
------Interference to BLANK0000143683 LIC scenario 2
Call Chan Svc Status City, State File Number Distance Desired: WRAZ D15 DT LIC RALEIGH, NC BLANK0000143683
Undesireds: WVPT D15 DD LIC STAUNTON, VA BLANK0000055362 285.5 km WRDC D14 DT LIC DURHAM, NC BLANK0000125503 0.0 W15EB-D D15 DC LIC CHARLOTTE, NC BLANK0000083736 219.2 WLTX D15 DT LIC COLUMBIA, SC BLANK0000082085 268.9 WFDC-DT D15 DT LIC ARLINGTON, VA BLANK0000041206 384.8 WPXU-TV D16 DT LIC JACKSONVILLE, NC BLANK0000129487 161.6 WXII-TV D16 DT LIC WINSTON-SALEM, NC BLANK0000081027 183.3
Service area Terrain-limited IX-free, before IX-free, after Percent New IX 48202.4 3,800,594 48030.7 3,797,515 47482.9 3,734,433 47009.3 3,724,802 1.00 0.26
Undesired Total IX Unique IX, before Unique IX, after WVPT D15 DD LIC 545.4 12,558 473.6 9,631 WRDC D14 DT LIC 4.0 208 4.0 208 4.0 208 W15EB-D D15 DC LIC 40.2 2,498 8.0 73 4.0 25 WLTX D15 DT LIC 60.2 1,385 44.1 738 40.1 526 WFDC-DT D15 DT LIC 31.8 718 31.8 718 8.0 88 WPXU-TV D16 DT LIC 107.2 1,304 107.2 1,304 107.2 1,304 WXII-TV D16 DT LIC 340.5 59,632 320.4 57,616 288.5 55,941
------Interference to BLANK0000100248 LIC scenario 1
Call Chan Svc Status City, State File Number Distance Desired: WQCW D15 DT LIC PORTSMOUTH, OH BLANK0000100248
5/14/2021 1:19:08 PM Page 6 Undesireds: WVPT D15 DD LIC STAUNTON, VA BLANK0000055362 256.2 km WLFG D14 DD LIC GRUNDY, VA BLANK0000071597 187.2 WTTK D15 DT LIC KOKOMO, IN BLANK0000093987 375.7 WXIX-TV D15 DT LIC NEWPORT, KY BLANK0000087069 212.8 W15EB-D D15 DC CP CHARLOTTE, NC BLANK0000127538 386.9 WEWS-TV D15 DT LIC CLEVELAND, OH BLCDT20091211ACS 321.2 WOHL-CD D15 DC LIC LIMA, OH BLANK0000140190 299.8 WTNZ D15 DT LIC KNOXVILLE, TN BLANK0000081278 318.9
Service area Terrain-limited IX-free, before IX-free, after Percent New IX 37994.3 1,307,345 35904.9 1,236,020 35435.2 1,214,030 35351.3 1,211,597 0.24 0.20
Undesired Total IX Unique IX, before Unique IX, after WVPT D15 DD LIC 103.7 2,658 83.8 2,433 WLFG D14 DD LIC 15.9 639 11.9 639 11.9 639 WTTK D15 DT LIC 12.0 76 8.0 71 8.0 71 WXIX-TV D15 DT LIC 242.9 3,797 191.2 3,123 183.3 3,088 WEWS-TV D15 DT LIC 199.1 17,019 167.2 16,436 163.2 16,349 WOHL-CD D15 DC LIC 4.0 19 0.0 0 0.0 0 WTNZ D15 DT LIC 55.5 1,133 35.7 1,047 27.8 944
------Interference to BLANK0000041206 LIC scenario 1
Call Chan Svc Status City, State File Number Distance Desired: WFDC-DT D15 DT LIC ARLINGTON, VA BLANK0000041206
Undesireds: WVPT D15 DD LIC STAUNTON, VA BLANK0000055362 212.3 km WPSU-TV D15 DD LIC CLEARFIELD, PA BLEDT20130614ACC 268.8 WCPB D16 DT CP SALISBURY, MD BLANK0000143851 143.2
Service area Terrain-limited IX-free, before IX-free, after Percent New IX 24894.9 8,155,998 24166.4 8,114,847 23748.8 8,078,686 23664.7 8,077,290 0.35 0.02
Undesired Total IX Unique IX, before Unique IX, after WVPT D15 DD LIC 191.8 4,591 84.1 1,396 WPSU-TV D15 DD LIC 417.6 36,161 417.6 36,161 309.9 32,966
------
5/14/2021 1:19:08 PM Page 7 Interference to proposal scenario 1 14.07% interference received
Call Chan Svc Status City, State File Number Distance Desired: WVPT D15 DD LIC STAUNTON, VA BLANK0000055362
Undesireds: W15EB-D D15 DC CP CHARLOTTE, NC BLANK0000127538 357.9 km WRAZ D15 DT LIC RALEIGH, NC BLANK0000143683 285.5 WQCW D15 DT LIC PORTSMOUTH, OH BLANK0000100248 256.2 WPSU-TV D15 DD LIC CLEARFIELD, PA BLEDT20130614ACC 337.1 WFDC-DT D15 DT LIC ARLINGTON, VA BLANK0000041206 212.3
Service area Terrain-limited IX-free Percent IX 32774.3 827,141 27538.2 714,292 23981.4 613,761 12.92 14.07
Undesired Total IX Unique IX Prcnt Unique IX WRAZ D15 DT LIC 1646.1 60,183 1016.4 30,775 3.69 4.31 WQCW D15 DT LIC 475.5 936 395.5 890 1.44 0.12 WPSU-TV D15 DD LIC 88.2 52 32.1 31 0.12 0.00 WFDC-DT D15 DT LIC 2088.8 68,835 1386.9 39,360 5.04 5.51
5/14/2021 1:19:08 PM Page 8 WNPB-TV WWPB-D WDVM-TV
Frederick WGPT-D WVFX-D WGPT-D Parkersburg WBOY-TV Noise-Limited DTV Full-Service Station Count Map - Channel 15 695 WDTV-D WWPX-TV WDTV-D Germantown Dashed-lines Rockville Reference N.L. 19 97 6 5 Silver Spring Reston REF 79 4 66 WUSA-D WJAL-D 522 Chantilly WVPT1-D-15 7 Washington WVPT2-D-15 WJLA-TV Green Bank 3 BurkeAlexandria WVPT3-D-15 5 2 3 WVPT4-D -15 3 211 Mount Vernon Dale City WVPT4-D -15
2 Harrisonburg Charleston 4 WVPT3-D-15 WVPT1-12 8 WVPT1-D-15 7 9 10 64W 8 WHSV-TV 340 WSWP-TV 9 Charlottesville WVPT2-D-15 WCAV-D 12 60 WVIR-TV WHTJ-D 250 64 WNVC-D WNVC-D 895 WVNS-TV 11 295 WUPV-D 10 288 501 WRLH-TV RichmondWTVR-TV 581 WCVE-TV WCVW-D 9 WRIC-TV Lynchburg 12 WNVT-D WWBT-D WWCW-D Roanoke WWCW-D Blacksburg460 WSET-TV Scale 1:1,500,000 Petersburg 11 WDBJ-D 11 km WSLS-TV WFXR-D WPXR-TV 0 20 40 60 WBRA-TV WFFP-TV/WZBJ 15 V-Soft Communications LLC ® © 29 81 360
220
85
WCWG-DWXII-TV Morgantown Hagerstown
WDTV-D WVFX-D WBOY-TV WVFX-D Frederick Channel 12 Service Area Count Map Parkersburg REF Reference DTS 50 WWPX-TV WVPT1-D.C Noise Limited Reference - Dashed WWPX-TV Germantown WVPT2-D.C Rockville Contours are Noise-Limited WVPT3-D.C 19 2 Silver Spring 1 Reston 79 66 Proposed 522 Chantilly Washington 3 Washington BurkeAlexandria 2 211 Mount Vernon Dale City 3 3 3 3 3 Harrisonburg Charleston 5 WVPT3-D.C 8 WVPT1-D-15 10 WVPT1-D.C 9 11 95 WHSV-TV 10 64W 340 CharlottesvilleWNVC-D WOAY-TV WVPT2-D.C WCAV-D 250 WOAY-TV 11 WVIR-TV WHTJ-D 64 WHTJ-D 60 220
WSWP-TV WVNS-TV 295 WVNS-TV WUPV-D 12 288 WRIC-TV 501 WRIC-TV 11 WNVT-D 460 Richmond 581 WTVR-TV WWBT-DWCVW-D 15 WRLH-TV Lynchburg WCVE-TV Scale 1:1,500,000 WWCW-D km Roanoke WVVA-D Blacksburg WBRA-TV WSET-TV 0 20 40 60 Petersburg 11 WDBJ-D WSLS-TV WDBJ-D WFXR-DWSLS-TV 29 V-Soft Communications LLC ® © 85 81 WPXR-TV WFFP-TV/WZBJ 360
WCWG-DWXII-TVWUNL-TV WNPB-TV
WWPB-D WDVM-TV
WGPT-D
WVFX-D
WDTV-DWBOY-TV 695 WWPX-TV
97
WUSA-D WJAL-D WJLA-TV
Beverly
Longley-Rice, Noise-Limited, DTV Full-Service Station - For Existing CH 12
Dashed-lines Note: The contour method predicts channel 15 loss within 2, 3 and 4 service count areas. However, these areas show virtually no Longley-Rice Reference N.L. Mill Creek N.L coverage for the same areas under channel 12 operation. REF Huttonsville WVPT1-D-15 WVPT2-D-15 WVPT3-D-15 WVPT4-D -15 Franklin
WVPT4-D -15
Durbin
3 2 Green Bank
Monterey 3
4 WVPT3-D-15 WVPT3-D.C 4
5
Scale 1:400,000 km Marlinton 0 5 10 15 V-Soft WVPT1-12Communications LLC ® © WVPT1-D-15 64W WHSV-TVWVPT1-D.C Staunton Hillsboro
Jolivue
WCAV-D WVPT2-D-15 WVIR-TVWHTJ-D WNVC-D WSWP-TV WNVC-D
60 250
64
WVNS-TV 895 WUPV-D
295
WRLH-TV WTVR-TV WCVE-TV WCVW-D WCVE-TV WRIC-TV WNVT-D WWBT-D
581
WWCW-D WSET-TV
WDBJ-D WSLS-TVWDBJ-D WPXR-TV WFXR-D WPXR-TV WBRA-TV WFFP-TV/WZBJ
81
220
85
WCWG-DWXII-TV Exhibit #5
Declaration:
I, Douglas L. Vernier, declare that I have received training as an engineer from the University of Michigan, School of Engineering. That, I have received degrees from the University in the field of Broadcast Telecommunications. That, I have been active in broadcast consulting for over 40 years.
That, I have held a Federal Communications Commission First Class Radiotelephone License continually since 1964. In 1985, this license was reissued by the Commission as a lifetime General Radiotelephone license no. PG-16-16464.
That, I am certified as a Professional Broadcast Engineer (#50258) by the Society of Broadcast Engineers, Indianapolis, Indiana. (Life-time Certification received in 2010).
That, my qualifications are a matter of record with the Federal Communications Commission.
That, I have been retained by the VPM Media Corporation to prepare the engineering showings appended hereto.
That, I have prepared these broadcast engineering showings, the technical information contained in same and the facts stated within are true of my knowledge.
That, under penalty of perjury, I declare that the foregoing is correct.
Douglas L. Vernier
Executed on May 24, 2021