ENGINEERING EXHIBIT Modification of a Licensed Facility for LPTV

ENGINEERING EXHIBIT

Modification of a Licensed Facility for LPTV Station Application

prepared for

United Communications Corporation K38MY-D St. James, Minnesota Facility ID 183814 Ch. 13 (Digital) 3 kW-Max DA

Table of Contents

FCC Form 2100, Schedule C – Engineering Data (Digital)

Statement A Comprehensive Engineering Statement Attachment TV_Study Interference Report

This material supplies a “hard copy” of the engineering portions of this application as entered April 20, 2018 for filing electronically. Since the FCC’s electronic filing system may be accessed by anyone with the applicant’s name and password, and electronic data may otherwise be altered in an unauthorized fashion, we cannot be responsible for changes made subsequent to our entry of this data and related attachments. Statement A COMPREHENSIVE ENGINEERING STATEMENT prepared for United Communications Corporation K38MY-D St. James, Minnesota Facility ID 183814 Ch. 13 (Digital) 3 kW-Max DA

United Communications Corporation (“UCC”) is the licensee of low power television station K38MY-D, Channel 38, St. James, Minnesota, Facility ID 183814 (File No. BLDTT- 20120326AKE). UCC also holds an FCC “Silent” STA for K3MY-D under LMS File No. 0000036887, as the station lost the lease on the tower in December of 2017. K38MY-D is displaced because, on Channel 38, they are currently “out of core” as a result of the TV Band Repack. Under the provisions of the FCC’s Special Displacement Filing Window for low power television stations and television translators, UCC requests a displacement channel change to Channel 13.

Nature of the Proposal The antenna system for the proposed K38MY-D operation is a directional antenna model Dielectric DLP-8MR (Antenna ID 117144) oriented at 75°T North which will be side-mounted on the tower bearing ASR number 1025277 at 595.4 meters AMSL. No change in structure overall height is necessary to carry out this proposal. Since no change to the structure’s overall height is proposed, no change to structure marking/lighting requirements set forth in the aeronautical study will result.

The proposed digital facility will operate on Channel 13 using a “full service” out of channel emission mask, a maximum effective radiated power of 3 kW, and an antenna height of 595.4 meters AMSL. Schedule C - Figure 1 depicts the 51 and 48 dBμ F(50,90) coverage contours of the authorized and proposed facilities. As demonstrated on the provided map, the service area overlap shown demonstrates compliance with §74.787(b)(1)(ii). The proposed site is located 24.5 km from the licensed (File No. BLDTT-20120326AKE) coordinates, thus complying with §74.787(a)(4) of the Rules for a displaced translator.

Cavell, Mertz & Associates, Inc. Schedule C - Statement A COMPREHENSIVE ENGINEERING STATEMENT (Page 2 of 5)

Allocation Considerations The instant proposal complies with the Commission’s interference protection requirements toward all DTV, television translator, LPTV, and Class A stations. A detailed interference study was conducted using the FCC’s TV Study program version 2.2.5. The interference study results are provided as an attachment to this Engineering Statement and show that any new interference does not exceed the Commission’s interference limits (0.5 percent to full service and Class A stations, and 2.0 percent to secondary stations). Accordingly, the instant proposal complies with §74.793 regarding interference protection to analog and digital television, low power television, television translator, and Class A television facilities for both pre and post transition.

International Coordination The proposed transmitter site is located 501 km from the U.S.-Canadian border, which is greater than the 100 km required coordination distance specified for digital low power television stations in the Letter of Understanding1 and is greater than the 400 km distance required for full-service facilities. Thus, it is believed that international coordination will not be necessary for the instant proposal.

Other Allocation Considerations The nearest FCC monitoring station is at Grand Island, NE, at a distance of 470 km from the proposed site. This exceeds by a great margin the threshold minimum distance specified in §73.1030(c)(3) that would suggest consideration of the monitoring station. The proposed site is also located outside the areas specified in §73.1030(a)(1) and §73.1030(b). Thus, notification of the instant proposal to the National Radio Astronomy Observatory at Green Bank, West Virginia, or the Table Mountain Radio Receiving Zone in Boulder County, Colorado is not required. There are no AM broadcast stations located within 3.2 km (2 miles) of the proposed site, according to information extracted from the Commission’s engineering database.

1 The Letter of Understanding Between the Federal Communications Commission of the United States of America and Industry Canada Related to the Use of the 54-72 MHz, 76-88 MHz, 174-216 MHz and 470-806 MHz Bands for the Digital Television Broadcasting Service Along the Common Border, September 29, 2000, paragraph 12.

Cavell, Mertz & Associates, Inc.

Schedule C - Statement A COMPREHENSIVE ENGINEERING STATEMENT (Page 3 of 5)

Environmental Considerations The instant proposal is not believed to have a significant environmental impact as defined under §1.1306 of the Commission’s Rules. Consequently, preparation of an Environmental Assessment is not required. UCC herein proposes to construct the proposed facility on an existing tower with ASR Number 1025277, co-located with UCC’s KEYC-TV.

The use of existing antenna support structures has been characterized as being environmentally preferable by the Commission, according to Note 1 of §1.1306 of the FCC Rules. No change in structure height is proposed, thus no change in current structure marking and lighting requirements is anticipated. Therefore, it is believed that this application may be categorically excluded from environmental processing pursuant to §1.1306 of the Commission’s rules.

Human Exposure to Radiofrequency Electromagnetic Field The proposed operation was evaluated for human exposure to radiofrequency electromagnetic field using the procedures outlined in the Commission’s OET Bulletin 65 (“OET 65”). OET 65 describes a means of determining whether a proposed facility exceeds the radiofrequency exposure guidelines adopted in §1.1310. Under present Commission policy, a facility may be presumed to comply with the limits specified in §1.1310 if it satisfies the exposure criteria set forth in OET 65. Based upon that methodology, and as demonstrated in the following, the proposed transmitting system will comply with the cited adopted guidelines.

The proposed K38MY-D Channel 13 antenna center of radiation will be 275 meters above ground level. An effective radiated power of 3 kilowatts, horizontally polarized, will be employed utilizing a Dielectric DLP-8MR directional antenna. A “worst-case” relative field value of 20 percent (from 15° to 90° below the horizontal) is assumed for purposes of the calculation. The “uncontrolled/general population” limit specified in §1.1310 for Channel 13 (center frequency 213 MHz) is 200 μW/cm2.

Cavell, Mertz & Associates, Inc.

Schedule C - Statement A COMPREHENSIVE ENGINEERING STATEMENT (Page 4 of 5)

OET 65’s formula for television transmitting antennas is based on the NTSC transmission standards, where the average power is normally much less than the peak power. For the DTV facility in the instant proposal, the peak-to-average ratio is different than the NTSC ratio. The DTV ERP figure herein refers to the average power level. The formula used for calculating DTV signal density in this analysis is essentially the same as equation (10) in OET 65. S = (33.4098) (F2) (ERP) / D2 Where: S = power density in microwatts/cm2 ERP = total (average) ERP in Watts F = relative field factor D = distance in meters

Using this formula and the above assumptions, the proposed facility would contribute a power density of 0.05 µW/cm² at two meters above ground level near the antenna support structure, or 0.01 percent of the general population/uncontrolled limit.

§1.1307(b)(3) states that facilities are categorically excluded from responsibility for taking any corrective action in the areas where their contribution is less than five percent of the exposure limit. Since the instant situation meets the five percent exclusion test at all ground level areas, the impact of any other facilities near this site may be considered independently from this proposal. Accordingly, it is believed that the impact of the proposed operation should not be considered to be a factor at or near ground level as defined under §1.1307(b).

Safety of Tower Workers and the General Public As demonstrated herein, excessive levels of RF energy attributable to the proposal will not be caused at publicly accessible areas at ground level or near the base of the antenna supporting structure. Consequently, members of the general public will not be exposed to RF levels in excess of the Commission’s guidelines. Nevertheless, site access will continue to be restricted and controlled through the use of a locked fence. Additionally, appropriate RF exposure warning signs will continue to be posted.

Cavell, Mertz & Associates, Inc.

Schedule C - Statement A COMPREHENSIVE ENGINEERING STATEMENT (Page 5 of 5)

With respect to worker safety, it is believed that based on the preceding analysis, excessive exposure would not occur in areas at ground level or at the base of the top mounted tower structure. A site exposure policy will be employed protecting maintenance workers from excessive exposure when work must be performed on the tower or in areas where high RF levels may be present. Such protective measures may include, but will not be limited to, restriction of access to areas where levels in excess of the guidelines may be expected, power reduction, or the complete shutdown of facilities when work or inspections must be performed in areas where the exposure guidelines would otherwise be exceeded. On-site RF exposure measurements may also be undertaken to establish the bounds of safe working areas. The applicant will coordinate exposure procedures with all pertinent stations.

Conclusion Based on the preceding, it is believed that the instant proposal complies with all Commission Rules and policies.

Cavell, Mertz & Associates, Inc.

Mound Saint Paul Minnetonka Hutchinson Edina South Saint Paul Chanhassen Rive Bloomington Cottage Grove Chaska Burnsville Hastings Prior Lake Lakeville BLDTT-20120326AKE 51 dB F(50,90) Contour

Marshall Northfield

New Ulm Faribault

Mankato

Owatonna

Austin Fairmont Albert Lea Worthington

S C - F 1 Proposed Ch 13 Facility A P F 48 dB F(50,90) Contour C C

prepared May 2018 for United Communications Corporation K38MY-D St. James, Minnesota Facility ID 183814 Ch. 13 (Digital) 3 kW-Max DA Scale 1:1,000,000 Cavell, Mertz & Associates, Inc. km Manassas, Virginia 0 10Mason 20 City 30 Spencer V-Soft Communications LLC ® © TV_Study Interference Report United Communications Corporation K38MY-D St. James, Minnesota Facility ID 183814 Ch. 13 (Digital) 3 kW-Max DA

K38MY-D Pre-Transition Study – channel 13

tvstudy v2.2.5 (V9lR41) Database: localhost, Study: K38MY_ch13_pre, Model: Longley-Rice Start: 2018.05.02 18:21:10

Study created: 2018.05.02 18:21:10

Study build station data: LMS TV 2018-05-01

Proposal: K38MY-D D13 LD LIC ST. JAMES, MN File number: BLDTT20120326AKE Facility ID: 183814 Station data: User record Record ID: 631 Country: U.S.

Build options: Protect pre-transition records not on baseline channel Protect baseline records from LPTV

Stations potentially affected by proposal:

IX Call Chan Svc Status City, State File Number Distance No KEYC-TV D12 DT LIC MANKATO, MN BLCDT20120918AFE 0.0 km Yes WHO-DT D13 DT LIC DES MOINES, IA BLCDT20090410ASQ 245.2 No WREX D13 DT LIC ROCKFORD, IL BLANK0000005114 457.4 No WREX D13 DT APP ROCKFORD, IL BLANK0000035733 457.4 No WIRT-DT D13 DT LIC HIBBING, MN BLCDT20090417ABE 399.2 No WCMN-LP N13+ TX LIC ST. CLOUD-SARTELL, MN BLTVL20021031ABS 179.7 No KFME D13 DT LIC FARGO, ND BLEDT20090818ABM 404.8 No KPLO-TV D13 DT LIC RELIANCE, SD BLCDT20131113AIL 423.1 Yes KSFY-TV D13 DT LIC SIOUX FALLS, SD BLCDT20090223ABE 176.8

No non-directional AM stations found within 0.8 km

No directional AM stations found within 3.2 km

Record parameters as studied:

Channel: D13 Mask: Full Service Latitude: 43 56 13.00 N (NAD83) Longitude: 94 24 39.00 W Height AMSL: 595.0 m HAAT: 0.0 m Peak ERP: 3.00 kW Antenna: DIE DLP-8MR 75.0 deg Elev Pattrn: Generic

48.0 dBu contour: Azimuth ERP HAAT Distance 0.0 deg 2.17 kW 282.7 m 58.7 km 45.0 3.00 286.4 61.2 90.0 3.00 284.3 61.1 135.0 2.68 273.6 59.7 180.0 0.997 261.7 52.0 225.0 0.013 258.8 23.5 270.0 0.026 267.9 27.2 315.0 0.550 275.7 48.6

Database HAAT does not agree with computed HAAT Database HAAT: 0 m Computed HAAT: 274 m

Distance to Canadian border: 501.4 km

Distance to Mexican border: 1691.1 km

Conditions at FCC monitoring station: Grand Island NE Bearing: 225.9 degrees Distance: 469.9 km

Proposal is not within the West Virginia quiet zone area

Conditions at Table Mountain receiving zone: Bearing: 248.5 degrees Distance: 985.7 km

Study cell size: 0.50 km Profile point spacing: 0.10 km

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

------Interference to BLCDT20090410ASQ LIC scenario 1

Call Chan Svc Status City, State File Number Distance Desired: WHO-DT D13 DT LIC DES MOINES, IA BLCDT20090410ASQ

Undesireds: K38MY-D D13 LD LIC ST. JAMES, MN BLDTT20120326AKE 245.2 km KIIN D12 DT LIC IOWA CITY, IA BLEDT20091229ABP 188.7 WREX D13 DT LIC ROCKFORD, IL BLANK0000005114 365.1 WIBW-TV D13 DT APP TOPEKA, KS BLANK0000035760 373.5 KSFY-TV D13 DT LIC SIOUX FALLS, SD BLCDT20090223ABE 305.0

Service area Terrain-limited IX-free, before IX-free, after Percent New IX 49120.5 1,152,553 48051.6 1,132,716 47689.7 1,126,532 47670.4 1,126,430 0.04 0.01

Undesired Total IX Unique IX, before Unique IX, after K38MY-D D13 LD LIC 51.7 526 19.2 102 KIIN D12 DT LIC 40.1 166 36.1 160 36.1 160 WREX D13 DT LIC 22.9 1,715 18.9 1,709 18.6 1,380 WIBW-TV D13 DT APP 159.9 850 141.0 790 141.0 790 KSFY-TV D13 DT LIC 162.0 3,519 143.2 3,459 111.0 3,364

------Interference to BLCDT20090410ASQ LIC scenario 2

Call Chan Svc Status City, State File Number Distance Desired: WHO-DT D13 DT LIC DES MOINES, IA BLCDT20090410ASQ

Undesireds: K38MY-D D13 LD LIC ST. JAMES, MN BLDTT20120326AKE 245.2 km KIIN D12 DT LIC IOWA CITY, IA BLEDT20091229ABP 188.7 WREX D13 DT LIC ROCKFORD, IL BLANK0000005114 365.1 WIBW-TV D13 DT LIC TOPEKA, KS BLCDT20110111ABO 373.5 KSFY-TV D13 DT LIC SIOUX FALLS, SD BLCDT20090223ABE 305.0

Service area Terrain-limited IX-free, before IX-free, after Percent New IX 49120.5 1,152,553 48051.6 1,132,716 47744.0 1,126,728 47724.8 1,126,626 0.04 0.01

Undesired Total IX Unique IX, before Unique IX, after K38MY-D D13 LD LIC 51.7 526 19.2 102 KIIN D12 DT LIC 40.1 166 36.1 160 36.1 160 WREX D13 DT LIC 22.9 1,715 18.9 1,709 18.6 1,380 WIBW-TV D13 DT LIC 103.3 639 86.7 594 86.7 594 KSFY-TV D13 DT LIC 162.0 3,519 145.4 3,474 113.2 3,379

------Interference to BLCDT20090410ASQ LIC scenario 3

Call Chan Svc Status City, State File Number Distance Desired: WHO-DT D13 DT LIC DES MOINES, IA BLCDT20090410ASQ

Undesireds: K38MY-D D13 LD LIC ST. JAMES, MN BLDTT20120326AKE 245.2 km KIIN D12 DT LIC IOWA CITY, IA BLEDT20091229ABP 188.7 WREX D13 DT APP ROCKFORD, IL BLANK0000035733 365.1 WIBW-TV D13 DT APP TOPEKA, KS BLANK0000035760 373.5 KSFY-TV D13 DT LIC SIOUX FALLS, SD BLCDT20090223ABE 305.0

Service area Terrain-limited IX-free, before IX-free, after Percent New IX 49120.5 1,152,553 48051.6 1,132,716 47662.1 1,122,862 47643.6 1,122,766 0.04 0.01

Undesired Total IX Unique IX, before Unique IX, after K38MY-D D13 LD LIC 51.7 526 18.5 96 KIIN D12 DT LIC 40.1 166 31.8 149 31.8 149 WREX D13 DT APP 54.7 5,396 46.4 5,379 45.4 5,044 WIBW-TV D13 DT APP 159.9 850 141.0 790 141.0 790 KSFY-TV D13 DT LIC 162.0 3,519 143.2 3,459 111.0 3,364

------Interference to BLCDT20090410ASQ LIC scenario 4

Call Chan Svc Status City, State File Number Distance Desired: WHO-DT D13 DT LIC DES MOINES, IA BLCDT20090410ASQ

Undesireds: K38MY-D D13 LD LIC ST. JAMES, MN BLDTT20120326AKE 245.2 km KIIN D12 DT LIC IOWA CITY, IA BLEDT20091229ABP 188.7 WREX D13 DT APP ROCKFORD, IL BLANK0000035733 365.1 WIBW-TV D13 DT LIC TOPEKA, KS BLCDT20110111ABO 373.5 KSFY-TV D13 DT LIC SIOUX FALLS, SD BLCDT20090223ABE 305.0

Service area Terrain-limited IX-free, before IX-free, after Percent New IX 49120.5 1,152,553 48051.6 1,132,716 47716.4 1,123,058 47697.9 1,122,962 0.04 0.01

Undesired Total IX Unique IX, before Unique IX, after K38MY-D D13 LD LIC 51.7 526 18.5 96 KIIN D12 DT LIC 40.1 166 31.8 149 31.8 149 WREX D13 DT APP 54.7 5,396 46.4 5,379 45.4 5,044 WIBW-TV D13 DT LIC 103.3 639 86.7 594 86.7 594 KSFY-TV D13 DT LIC 162.0 3,519 145.4 3,474 113.2 3,379

------Interference to BLCDT20090223ABE LIC scenario 1

Call Chan Svc Status City, State File Number Distance Desired: KSFY-TV D13 DT LIC SIOUX FALLS, SD BLCDT20090223ABE

Undesireds: K38MY-D D13 LD LIC ST. JAMES, MN BLDTT20120326AKE 176.8 km KEYC-TV D12 DT LIC MANKATO, MN BLCDT20120918AFE 176.8 KTTM D12 DT LIC HURON, SD BLCDT20081204AFD 161.4 WHO-DT D13 DT LIC DES MOINES, IA BLCDT20090410ASQ 305.0 KFME D13 DT LIC FARGO, ND BLEDT20090818ABM 391.8 KHGI-TV D13 DT LIC KEARNEY, NE BLANK0000001675 371.6 KPLO-TV D13 DT LIC RELIANCE, SD BLCDT20131113AIL 257.6

Service area Terrain-limited IX-free, before IX-free, after Percent New IX 45529.4 667,975 43571.6 614,149 41349.3 585,669 41306.0 584,557 0.10 0.19

Undesired Total IX Unique IX, before Unique IX, after K38MY-D D13 LD LIC 94.1 1,339 43.3 1,112 KEYC-TV D12 DT LIC 5.4 15 1.2 7 0.0 0 KTTM D12 DT LIC 146.5 114 0.0 0 0.0 0 WHO-DT D13 DT LIC 713.3 24,633 704.5 22,582 659.1 22,370 KFME D13 DT LIC 101.1 416 50.8 283 50.8 283 KHGI-TV D13 DT LIC 10.9 2,082 0.7 0 0.7 0 KPLO-TV D13 DT LIC 1458.7 3,557 1252.7 3,271 1252.7 3,271

------Interference to BLCDT20090223ABE LIC scenario 2

Call Chan Svc Status City, State File Number Distance Desired: KSFY-TV D13 DT LIC SIOUX FALLS, SD BLCDT20090223ABE

Undesireds: K38MY-D D13 LD LIC ST. JAMES, MN BLDTT20120326AKE 176.8 km KEYC-TV D12 DT LIC MANKATO, MN BLCDT20120918AFE 176.8 KTTM D12 DT LIC HURON, SD BLCDT20081204AFD 161.4 WHO-DT D13 DT LIC DES MOINES, IA BLCDT20090410ASQ 305.0 KFME D13 DT LIC FARGO, ND BLEDT20090818ABM 391.8 KHGI-TV D13 DT APP KEARNEY, NE BLANK0000035802 371.6 KPLO-TV D13 DT LIC RELIANCE, SD BLCDT20131113AIL 257.6

Service area Terrain-limited IX-free, before IX-free, after Percent New IX 45529.4 667,975 43571.6 614,149 41339.2 583,220 41295.8 582,108 0.10 0.19

Undesired Total IX Unique IX, before Unique IX, after K38MY-D D13 LD LIC 94.1 1,339 43.3 1,112 KEYC-TV D12 DT LIC 5.4 15 1.2 7 0.0 0 KTTM D12 DT LIC 146.5 114 0.0 0 0.0 0 WHO-DT D13 DT LIC 713.3 24,633 696.0 19,039 650.7 18,827 KFME D13 DT LIC 101.1 416 50.8 283 50.8 283 KHGI-TV D13 DT APP 49.1 8,094 10.9 2,449 10.9 2,449 KPLO-TV D13 DT LIC 1458.7 3,557 1233.3 3,251 1233.3 3,251

------Interference to proposal scenario 1 4.51% interference received

Call Chan Svc Status City, State File Number Distance Desired: K38MY-D D13 LD LIC ST. JAMES, MN BLDTT20120326AKE

Undesireds: KEYC-TV D12 DT LIC MANKATO, MN BLCDT20120918AFE 0.0 km KSFY-TV D13 DT LIC SIOUX FALLS, SD BLCDT20090223ABE 176.8

Service area Terrain-limited IX-free Percent IX 8262.2 164,608 8249.4 161,112 7612.5 153,839 7.72 4.51

Undesired Total IX Unique IX Prcnt Unique IX KEYC-TV D12 DT LIC 635.9 7,273 635.9 7,273 7.71 4.51 KSFY-TV D13 DT LIC 1.0 0 1.0 0 0.01 0.00

TV_Study Interference Report United Communications Corporation K38MY-D St. James, Minnesota Facility ID 183814 Ch. 13 (Digital) 3 kW-Max DA

K38MY-D Post-Transition Study – Channel 13 tvstudy v2.2.5 (V9lR41) Database: localhost, Study: K38MY_ch13, Model: Longley-Rice Start: 2018.05.02 17:15:58

Study created: 2018.05.02 17:15:58

Study build station data: LMS TV 2018-05-01

Proposal: K38MY-D D13 LD LIC ST. JAMES, MN File number: BLDTT20120326AKE Facility ID: 183814 Station data: User record Record ID: 628 Country: U.S.

Build options: Protect baseline records from LPTV

Search options: Baseline record excluded if station has CP