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 KCBD(TV), Lubbock, ) Rulemaking No. _____ (Facility 27507) )

To: Office of the Secretary, Federal Communications Commission Attn: Chief, Media Bureau

PETITION FOR RULEMAKING

Gray Television Licensee, LLC (“Gray”), licensee of full power commercial KCBD(TV) (“KCBD”), Lubbock, Texas, 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 Gray requests that the Commission amend the DTV Table to substitute UHF Channel 36 for VHF Channel 11 with the technical parameters as set forth in the attached Engineering Statement. As set forth herein, grant of this Petition will a preferential 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.”2 In considering channel substitution requests, the Commission considers the

1 See 47 C.F.R. §§ 1.401, 1.420, 73.622(i). 2 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 petitioner’s public interest justification and whether the proposal would comply with the

principal community coverage requirements of Section 73.625(a).3

This channel substitution serves the public interest because it will resolve

significant over-the-air (“OTA”) reception problems in KCBD’s existing service area.4

With viewers increasingly reliant on OTA signals to receive the most valued video content,5 providing a strong broadcast signal is more 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

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). 3 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). 4 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”). 5 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 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).

2 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.”6 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.”7

Attached is an Engineering Statement of Chesapeake RF Consultants, LLC,8 which sets forth in detail the proposed KCBD Channel 36 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 36 facilities will provide full principal community coverage to Lubbock, Texas.

As further demonstrated by the attached Engineering Statement, when compared to KCBD’s existing Channel 11 DTV allotment, the proposed Channel 36 facilities will create only a de minimis loss area. Although the proposed Channel 36 facilities at the maximum 1,000 kW ERP will result in a slight theoretical reduction in KCBD’s predicted coverage and population served using standard FCC contours, an analysis using the terrain-limited coverage predictions reveals a loss population of just 350 persons, or

6 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.”) 7 Id. ¶ 44. 8 See Exhibit 1 (“Engineering Statement”). 3 0.08% of KCBD’s service population.9 And both the standard and terrain-limited contour predictions almost certainly overstate the actual loss area given the specific VHF propagation challenges KCBD faces. In practice, Gray expects few if any persons who are currently able to receive KCBD’s OTA signal on Channel 11 would no longer be able to receive KCBD’s OTA signal as a result of the transition to Channel 36.

For the foregoing reasons, Gray respectfully requests that the Commission grant this Petition and immediately commence a rulemaking proceeding to change the digital allotment for KCBD from Channel 11 to Channel 36 as proposed herein.

Respectfully submitted,

GRAY TELEVISION LICENSEE, LLC

By: _/s/ Ari Meltzer______Ari Meltzer Joan Stewart Wiley Rein LLP 1776 K Street NW Washington DC 20006 202.719.7467 [email protected] [email protected]

Dated: February 10, 2021

9 See WSET, Inc., 80 FCC 2d 233, 246 (1980) (finding loss area of population of 500 de minimis).

4 Exhibit 1

Engineering Statement prepared for Gray Television Licensee, LLC KCBD(DT) Lubbock, TX Facility ID 27507 Ch. 36 1000 kW 282 m

This engineering statement has been prepared on behalf of Gray Television Licensee, LLC (“Gray”) , licensee of KCBD (Facility ID 27507, Lubbock TX) in support of a Petition for Rulemaking to amend §73.622(i) 1 by changing KCBD’s digital television channel assignment. KCBD is licensed to operate on Channel 11 (File# 0000010766). As described herein, Gray requests substitution of Channel 36 in lieu of Channel 11 for KCBD.

The KCBD Channel 11 facility is in the VHF spectrum and has proven to be ineffective for satisfactory viewer reception as discussed herein and elsewhere in the petition. The use of Channel 36 would place KCBD in the UHF spectrum which is known to provide robust signal levels for home reception.

Gray has determined that many viewers experience significant difficulty in receiving KCBD’s signal. Problems with digital VHF reception by stations in many markets were widely publicized since the 2009 digital transition date. It has been established that indoor reception is difficult for digital VHF stations such as KCBD due to the longer wavelength signal’s inability to readily pass through buildings (the windows are smaller than the wavelength size), the ineffectiveness of many indoor antennas many of which were designed to emphasize the shorter wavelengths for UHF reception, and high levels of manmade and environmental noise.

1The post-incentive auction transition period ended on July 13, 2020, pursuant to the Incentive Auction Closing and Channel Reassignment Public Notice (DA 17-317, released April 13, 2017). The FCC’s rules have not yet been amended to reflect all new full power channel assignments in a revised Table of Allotments. Because the Table has not yet been amended, it is understood that FCC’s Media Bureau will continue to refer to the Post-Transition Table of DTV Allotments, 47 CFR § 73.622(i) (2018), for the purpose of post-auction channel change rulemaking proceedings.

Engineering Statement Gray Television Licensee, LLC (KCBD) Page 2 of 5

The proposed KCBD Channel 36 facility will utilize a different transmitting location which is 5.5 km distant from the licensed KCBD Channel 11 site. The proposed Channel 36 operation will employ the existing UHF broadband directional antenna that is top-mounted on the tower structure associated with FCC Antenna Structure Registration number 1248244. Gray owns the broadband antenna, which is currently shared by KJTV (Ch. 35, Fac ID 55031, Lubbock TX) and Gray’s station KLCW-TV (Ch. 23, Fac ID 77719, Wolfforth TX). No change to the overall structure height will result.

The licensed KCBD Channel 11 facility operates with 41 kW (“ERP”) nondirectional at 234 meters antenna height above average terrain (“HAAT”). Gray proposes herein to utilize 1000 kW ERP directional on Channel 36 at 282 meters antenna HAAT.

A summary of the licensed Channel 11 and proposed Channel 36 technical parameters is provided in the following.

Licensed Channel 11 Parameters (file# 0000010766) FacID Call Ch City St Lat Lon RCAMSL HAAT ERP DA 27507 KCBD 11 LUBBOCK TX 333229.9 1015013.6 1208.2 234 41 ND

Proposed Channel 36 Parameters FacID Call Ch City St Lat Lon RCAMSL HAAT ERP DA 27507 KCBD 36 LUBBOCK TX 333008.3 1015221.3 1263.7 282.1 1000 DA

The proposed directional antenna azimuthal pattern is plotted in Figure 1. A map is supplied as Figure 2, which depicts the standard predicted coverage contours. As demonstrated thereon, the proposed facility complies with §73.625(a)(1) as the entire community of Lubbock will be encompassed by the 48 dBµ contour.

Interference study per FCC OET Bulletin 69 2 shows that the proposal complies with the 0.5 percent limit of new interference caused to pertinent nearby full service and Class A television

2FCC Office of Engineering and Technology Bulletin number 69, Longley-Rice Methodology for Evaluating TV Coverage and Interference , February 6, 2004 (“OET-69”). This analysis employed the FCC’s current “TVStudy” software with the default application processing template settings, 2 km cell size, and 1 km terrain increment. Engineering Statement Gray Television Licensee, LLC (KCBD) Page 3 of 5

stations and reassignments as required by §73.616. The interference study output report is provided as Table 1. No predicted interference is caused to any other relevant facility.

Figure 3 shows that the proposed Channel 36 noise limited service contour (“NLSC”) will fall short of matching that of the licensed Channel 11 facility. The proposed Channel 36 facility will operate at 1000 kW ERP, the maximum permissible power for a UHF digital television station, and at an antenna HAAT that is increased by 48.1 meters beyond that of the licensed facility. The existing top-mounted UHF broadband antenna is directional, having a wide cardioid pattern oriented to the west. However, even a theoretical operation with a nondirectional pattern at 1000 kW ERP would also result in an NLSC that insufficiently matches that of the licensed Channel 11 KCBD.

The proposed KCBD Channel 36 NLSC loss areas are depicted in Figure 3 along with the NLSC of overlapping alternative authorized television services. The stations providing the alternative services are listed in Table 2. The areas on Figure 3 that are tinted yellow, nearly all of the loss area, represent locations where there are less than 5 other TV services remaining in the loss area. A summary of the number of alternative services for the loss area is provided on the map and in the following table. Loss Area Analysis – Standard FCC Contours KCBD Population Within NLSC (2010 census) Licensed Ch. 11 Total: 414,829 Proposed Ch. 36 Total: 406,628 Gain Area Population: 0 Loss Area Population: 8,201 Common Area Population: 406,628 Number of Other Services Loss Pop 0 2,929 1 1,814 2 432 3 2,707 4 276 5 or more 43 Total Change 8,201 Total less than 5 services 8,158 Total less than 5 (percentage) 1.97%

Comparisons of various results of this computer program (run on a Mac processor) to the FCCs implementation of TVStudy show excellent correlation. Engineering Statement Gray Television Licensee, LLC (KCBD) Page 4 of 5

The licensed Channel 11 facility’s NLSC encompasses 414,829 persons and the proposed Channel 36 facility’s NLSC would encompass 406,628 persons. The resulting NLSC loss population is 8,201 persons, of which 8,158 persons would have less than five other services representing 1.97 percent of the total population within the licensed KCBD Channel 11 NLSC.

The results of additional loss area analysis are provided in Figure 4, now to consider terrain- limited coverage predictions of the licensed Channel 11 facility and the proposed Channel 36 operation. Here, the FCC’s TVStudy computer program was used to determine terrain-limited coverage predictions at locations beyond the proposed Channel 36 NLSC. The study area was set using the “fixed geography” option to match the KCBD licensed Channel 11 NLSC. Default cell size and profile step settings were employed. The analysis included examination of each cell that is located beyond the Channel 36 NLSC and beyond the NLSC of at least five other stations (the same, yellow-tinted area as Figure 3) as bounded by the existing Channel 11 facility’s NLSC. Cells in this region were counted as lost service if they are predicted to have terrain-limited service from the licensed Channel 11 facility and not from the proposed Channel 36. The results regarding the number of alternative services for the loss area is provided on Figure 4 and in the following table. Loss Area Analysis – Terrain-Limited KCBD Terrain-Limited Population TVStudy at Fixed Geography Area (2010 census) Licensed Ch. 11 Total 414,091 Number of Other Services Loss Pop 0 326 1 5 2 18 3 1 4 0 5 or more 0 Total Loss 350 Total less than 5 services 350 Total less than 5 (percentage) 0.08%

This analysis shows that nearly all of the terrain-limited service population achieved by the licensed KCBD within its NLSC will receive terrain-limited service from the proposed Channel 36. Here, the count of other services where terrain-limited service is lost provides the number of other stations that provide NLSC coverage to each cell. The determination of terrain- Engineering Statement Gray Television Licensee, LLC (KCBD) Page 5 of 5

limited service loss considers each cell that is located within the existing Channel 11 facility’s NLSC, beyond the Channel 36 NLSC, and beyond the NLSC of at least five other stations (the yellow tinted area on Figure 4). This analysis shows that the terrain-limited loss population is only 350 persons, all having less than five other services and representing 0.08 percent of the total terrain-limited population within the licensed KCBD Channel 11 NLSC. The FCC has previously found that population loss of less than 500 persons is de minimis, 3 and the predicted population loss in this case is only 350 persons who would not otherwise be well-served.

Conclusion The proposed channel substitution complies with the FCC’s principal community coverage requirements of §73.625 and the interference protection requirements of §73.616. The population that is predicted to lose service is considered as de minimis .

List of Attachments Figure 1 Antenna Azimuthal Pattern Figure 2 Proposed Coverage Contours Figure 3 Coverage Contour Comparison; Loss Area Analysis – Standard FCC Contours Figure 4 Loss Area Analysis – Terrain-Limited Method Table 1 TVStudy Analysis of Proposal Table 2 Overlapping Authorized Alternate Television Services

Chesapeake RF Consultants, LLC Joseph M. Davis, P.E. February 8, 2021 207 Old Dominion Road Yorktown, VA 23692 703-650-9600

3See WSET, Inc ., 80 FCC 2d 233, 246 (1980). Rotate Pattern 270 Degrees

Figure 1 Antenna Azimuthal Pattern KCBD(DT) Lubbock, TX

\ 0 \0 0\0\\0\ 0\0\\0\0\\

\00\\0\0\0\0 Facility ID 27507 \\00\\0\0\\0\

\00\\00\00\\0\ \\0\00\\0\\00\\ Chesapeake RF Consultants, LLC \\0\00\\0\\00\\ \00\\00\00\\0\ Radiofrequency Consulting Engineers Ch. 36 1000 kW 282 m \\00\\0\0\\0\\ \00\\0\0\0\0 0\0\\0\0\\ Digital Television and Radio 0\0\\0\0 \ 0\0 prepared for Gray Television Licensee, LLC

February, 2021 Collingsworth Deaf Smith RandallCanyon Armstrong Donley

Clarendon

Wellington

\ 0 \0 0\0\\0\

0\0\\0\0\\

\00\\0\0\0\0

Hereford \\00\\0\0\\0\

\00\\00\00\\0\ \\0\00\\0\\00\\ Chesapeake RF Consultants, LLC \\0\00\\0\\00\\ \00\\00\00\\0\ Radiofrequency Consulting Engineers Figure 2 \\00\\0\0\\0\\ \00\\0\0\0\0 Memphis 0\0\\0\0\\ Digital Television and Radio 0\0\\0\0 Hollis Proposed Coverage Contours \ 0\0 Friona KCBD(DT) Lubbock,Curry TX Facility ID 27507 Hall Childress Parmer DimmittCastro SwisherTulia Briscoe Bovina Fort Sumner Ch. 36 1000 kW 282 m 0° Childress Clovis prepared for Farwell Hart Gray Television Licensee, LLC

Muleshoe Earth February, 2021Portales 315° Olton Plainview 45° Lockney Bailey Lamb Hale Floyd Motley Cottle Hale Center Paducah Roosevelt Floydada Littlefield Petersburg Abernathy Anton Proposed KCBD 48 dBµ Morton (Principal Community) Shallowater 40.86 dBµ Lubbock, TX Idalou Lorenzo Ralls Crosbyton King (Noise Limited Service Contour) Cochran Hockley Lubbock Crosby Dickens Levelland 270° Lubbock 90° Wolfforth Spur Sundown Slaton Knox City

Stonewall YoakumPlains Terry Lynn PostGarza Kent Brownfield Tahoka Hagerman Aspermont

Denver City O'Donnell Stamford Lovington Seagraves Hamlin 225° 135° Rotan Lea Gaines Dawson Borden Scurry Fisher Anson Lamesa Seminole Snyder Hobbs

Area Population Proposed Digital Coverage (sq. km) (2010 Census) 180° Within Noise Limited Service Contour 24,805.7 406,628 Scale 1:1,500,000 OET Bulletin 69: TVStudy Sweetwater Merkel Tye Carlsbad Within noise limited contour 24,612.4Eunice 406,239 km Not affected by terrain losses 24,388.2 406,216 Colorado City0 15 30 45 Lost to all interference 0.0 0 V-Soft Communications LLC ® © Net Interference-Free Service 24,388.2 406,216 AndrewsAndrews Martin Howard Mitchell Nolan Loving Coahoma Big Spring

Jal Stanton Collingsworth Deaf Smith RandallCanyon Armstrong Donley

\ 0 \0 0\0\\0\

0\0\\0\0\\

\00\\0\0\0\0

Hereford \\00\\0\0\\0\

\00\\00\00\\0\ \\0\00\\0\\00\\ Chesapeake RF Consultants, LLC \\0\00\\0\\00\\ \00\\00\00\\0\ Radiofrequency Consulting Engineers Figure 3 \\00\\0\0\\0\\ \00\\0\0\0\0 0\0\\0\0\\ Digital Television and Radio 0\0\\0\0 Coverage Contour Comparison \ 0\0 Gain-Loss Area AnalysisCurry Standard FCC Contours Parmer Castro Swisher Briscoe Hall Childress Alternate TV Services 555555 KCBD(DT) Lubbock, TX 444444 Clovis 333333 Facility ID 27507 333333 111111 Ch. 36 1000 kW 282 m 222222 11111 111111 11111 KCBD Licensed Ch. 11 File# 0000010766 prepared for Portales Plainview 36 dBµ Contour (NLSC) 222222 Gray Television Licensee, LLC 31,272.8 sq. km Bailey Lamb Hale Floyd Motley Cottle

February, 2021 Roosevelt Proposed KCBD Ch. 36 40.86 dBµ Contour (NLSC) 24,805.7 sq. km 333333 000000 444444 111111 222222 333333 Dickens King Cochran Hockley Lubbock Licensed Ch. 11 CrosbySite Levelland Lubbock

Proposed Ch. 36 Site

222222 Garza Kent Stonewall Yoakum333333 Terry Lynn 111111

222222 KCBD Population Within NLSC (2010 census) Licensed Ch. 11 Total: 414,829 111111 Proposed Ch. 36 Total: 406,628 Gain Area Population: 0 Loss Area Population: 8,201 000000 Lea 333333 Common Area Population: 406,628 Gaines Dawson Borden Scurry Fisher Number of Other Services Loss Pop 444444 Lamesa Snyder Hobbs 555555 111111 0 2,929 1 1,814 2 432 3 2,707 4 276 5 or more 43 Scale 1:1,500,000Sweetwater Carlsbad Total Change 8,201 km Contours plotted per FCC TVStudy default Total less than 5 services 8,158 0 20 40 60 method using 8-radial HAAT and for UHF V-Soft Communications LLC ® © Total less than 5 (percentage) 1.97% stations are adjusted with dipole factor. AndrewsAndrews Martin Howard Mitchell Nolan

Big Spring KCBD Terrain-Limited Population TVStudy at Fixed Geography Area (2010 census) Licensed Ch. 11 Total 414,091 Number of Other Services Loss Pop 0 326 1 5 2 18 3 1 4 0 5 or more 0 Total Loss 350 Total less than 5 services 350 Total less than 5 (percentage) 0.08% Collingsworth Deaf Smith RandallCanyon Armstrong Donley

\ 0 \0 0\0\\0\

0\0\\0\0\\

\00\\0\0\0\0

Hereford \\00\\0\0\\0\

\00\\00\00\\0\ \\0\00\\0\\00\\ Chesapeake RF Consultants, LLC \\0\00\\0\\00\\ \00\\00\00\\0\ Radiofrequency Consulting Engineers Figure 4 \\00\\0\0\\0\\ \00\\0\0\0\0 0\0\\0\0\\ Digital Television and Radio 0\0\\0\0 Loss Area Analysis \ 0\0 Terrain-Limited MethodCurry KCBD(DT) Lubbock, TX Parmer Castro Swisher Briscoe Hall Childress Facility ID 27507 Ch. 36 1000 kW 282 m Clovis

prepared for Gray Television Licensee, LLC KCBD Licensed Ch. 11 File# 0000010766 Portales Plainview 36 dBµ Contour (NLSC) February, 2021 31,272.8 sq. km Bailey Lamb Hale Floyd Motley Cottle

Roosevelt Proposed KCBD Ch. 36 40.86 dBµ Contour (NLSC) KCBD Population Within NLSC (2010 census) 24,805.7 sq. km Licensed Ch. 11 Total: 414,829 Proposed Ch. 36 Total: 406,628 Gain Area Population: 0 Loss Area Population: 8,201 Common Area Population: 406,628 King Number of Other Services Loss Pop Cochran Hockley Lubbock Crosby Dickens 0 2,929 Levelland 1 1,814 Lubbock 2 432 3 2,707 4 276 5 or more 43 Total Change 8,201 Total less than 5 services 8,158 Total less than 5 (percentage) 1.97% Yoakum Terry Lynn Garza Kent Stonewall

KCBD Terrain-Limited Population TVStudy at Fixed Geography Area (2010 census) Licensed Ch. 11 Total 414,091 Number of Other Services Loss Pop 0 326 1 5 2 18 3 Lea 1 4 0 Gaines Dawson Borden Scurry Fisher 5 or more 0 Lamesa Snyder Total Loss 350Hobbs Total less than 5 services 350 Total less than 5 (percentage) 0.08% FCC "TVStudy" Analysis (default settings) Terrain-Limited Results

Cells Having Terrain-Limited Service From Licensed Ch. 11 Scale 1:1,500,000Sweetwater No Loss Carlsbad Terrain-Limited Service Is Provided for Proposed Ch. 23 km Contours plotted per FCC TVStudy default Cells Having Terrain-Limited Service From Licensed Ch. 11 0 20 40 60 method using 8-radial HAAT and for UHF Loss Terrain-Limited Service Is Lost for Proposed Ch. 23 V-Soft Communications LLC ® © stations are adjusted with dipole factor. AndrewsAndrews Martin Howard Mitchell Nolan

Big Spring Table 1 KCBD TVStudy Analysis of Proposal (page 1 of 2) tvstudy v2.2.5 (4uoc83) Database: localhost, Study: KCBD 36prop, Model: Longley-Rice Start: 2021.02.05 10:45:33

Study created: 2021.02.05 10:45:33

Study build station data: LMS TV 2021-02-05

Proposal: KCBD D36 DT APP Lubbock, TX File number: KCBD 36prop Facility ID: 27507 Station data: User record Record ID: 3465 Country: U.S. Zone: II

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 KJTV-TV D35 DT LIC LUBBOCK, TX BLANK0000074582 0.0 km No KASY-TV D36 DT LIC ALBUQUERQUE, NM BLANK0000074897 461.1 No KASY-TV D36 DT APP ALBUQUERQUE, NM BLANK0000134573 461.1 No KXTX-TV D36 DT LIC DALLAS, TX BLANK0000074968 468.1

No non-directional AM stations found within 0.8 km

No directional AM stations found within 3.2 km

Record parameters as studied:

Channel: D36 Latitude: 33 30 8.30 N (NAD83) Longitude: 101 52 21.30 W Height AMSL: 1263.7 m HAAT: 282.1 m Peak ERP: 1000 kW Antenna: RFS PHPR64U3313 Ch36 0.0 deg Elev Pattrn: Generic Elec Tilt: 0.70

40.9 dBu contour: Azimuth ERP HAAT Distance 0.0 deg 990 kW 282.3 m 94.7 km 45.0 475 295.1 89.5 90.0 228 300.8 84.2 135.0 464 298.4 89.8 180.0 976 283.8 94.8 225.0 924 268.6 91.9 270.0 899 261.9 90.4 315.0 895 265.8 91.1

Distance to Canadian border: 1722.5 km

Distance to Mexican border: 404.8 km

Conditions at FCC monitoring station: Douglas AZ Bearing: 255.2 degrees Distance: 762.4 km

Proposal is not within the West Virginia quiet zone area

Conditions at Table Mountain receiving zone: Bearing: 338.9 degrees Distance: 793.4 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%

Table 1 KCBD TVStudy Analysis of Proposal (page 2 of 2)

------Interference to proposal scenario 1

Call Chan Svc Status City, State File Number Distance Desired: KCBD D36 DT APP Lubbock, TX KCBD 36prop

Service area Terrain-limited IX-free Percent IX 24612.4 406,239 24388.2 406,216 24388.2 406,216 0.00 0.00

Table 2 Overlapping Authorized Alternate Television Services prepared for Gray Television Licensee, LLC KCBD Lubbock, TX

Call Sign Ch. Facility ID Status File Number Community KOSA-TV 7 6865 CP 0000036068 Odessa, TX KVII-TV 7 40446 CP 0000035799 Amarillo, TX KOBR 8 62272 Lic BLCDT-20090619AAX Roswell, NM KACV-TV 9 1236 Lic BLEDT-20111222AXJ Amarillo, TX KWES-TV 9 42007 Lic BLCDT-20121210ACW Odessa, TX KBIM-TV 10 48556 Lic 0000067866 Roswell, NM KFDA-TV 10 51466 Lic BLCDT-20111114BLB Amarillo, TX KVIH-TV 12 40450 Lic 0000035800 Clovis, NM KCIT 15 33722 Lic 4834 Amarillo, TX KMLM-DT 15 53541 Lic 0000064406 Odessa, TX KXVA 15 62293 Lic BLCDT-20110520ADO Abilene, TX KPTB-DT 16 53544 Lic BLCDT-20090210AFA Lubbock, TX KSAN-TV 16 307 Lic 0000004868 San Angelo, TX KPCB-DT 17 77452 Lic BLCDT-20090210AFB Snyder, TX KPTF-DT 18 81445 Lic BLCDT-20090612AEB Farwell, TX KUPB 18 86263 Lic BLCDT-20090615ABW Midland, TX KAMR-TV 19 8523 Lic BLCDT-20080519ACZ Amarillo, TX KIDY 19 58560 Lic BLCDT-20110520ADN San Angelo, TX KTXS-TV 20 308 CP 0000035779 Sweetwater, TX KRWB-TV 21 84157 Lic BLCDT-20090619ABH Roswell, NM KLCW-TV 23 77719 Lic 0000074584 Wolfforth, TX KPEJ-TV 23 12524 Lic BLCDT-20060629AGO Odessa, TX KTEL-TV 25 83707 Lic BLCDT-20081125ADK Carlsbad, NM KTTZ-TV 25 65355 Lic 0000063358 Lubbock, TX KMID 26 35131 Lic BLCDT-20110218AAS Midland, TX KAMC 27 40820 CP 0000052586 Lubbock, TX KRPV-DT 27 53539 Lic BLCDT-20090211ABQ Roswell, NM KPBT-TV 28 50044 Lic 0000063946 Odessa, TX KRBC-TV 29 306 Lic BLCDT-20070831AAK Abilene, TX KUPT 29 27431 Lic BLCDT-20081125ADR Hobbs, NM KTAB-TV 30 59988 CP 0000029890 Abilene, TX KWWT 30 84410 CP 0000036063 Odessa, TX KEYU 31 83715 Lic BLCDT-20130815AAW Borger, TX KLBK-TV 31 3660 Lic 0000078650 Lubbock, TX KENW 32 18338 Lic BLEDT-20030219ADP Portales, NM KCWO-TV 33 42008 Lic BLCDT-20090818AAN Big Spring, TX