Cox Television Tulsa, LLC KMYT-TV, Tulsa, OK (Facility ID 54420)

WAIVER OF PHASE ASSIGNMENT, TESTNG PERIOD, AND PHASE COMPLETION DATE

Cox Television Tulsa, LLC (“Cox” or “Station”) seeks waiver of the post-Incentive

Auction Transition Phase assignment, and corresponding testing dates and construction

completion deadlines, for KMYT-TV Tulsa, OK (Facility ID 54420) (“Station”). Pursuant to the

Closing and Reassignment Public Notice, the Station has been assigned to Transition Phase 2, for

which the Phase Completion Date is 4/12/2019.1 Cox seeks to transition the Station early, with

expected transition completion on or before September 1, 2018, with a testing period to commence immediately preceding said date. Cox therefore requests a waiver to move to

Transition “Phase 0” which is before the start of the Transition Phase 1 testing date.

The FCC may grant a waiver for good cause shown.2 A waiver is appropriate where the

particular facts make strict compliance inconsistent with the public interest.3 In considering a

waiver, the FCC may take into account considerations of hardship, equity, or more effective

implementation of overall policy on an individual basis.4 Such a waiver is appropriate if

1 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) (Closing and Channel Reassignment Public Notice). 2 47 C.F.R. § 1.3. 3 Northeast Cellular Tel. Co. v. FCC, 897 F.2d 1164, 1166 (D.C. Cir. 1990). 4 WAIT Radio v. FCC, 418 F.2d 1153, 1159 (D.C. Cir. 1969), cert. denied, 409 U.S. 1027 (1972); Northeast Cellular, 897 F.2d at 1166.

178518191 v4 circumstances warrant a deviation from the general rule, and such deviation will serve the public interest.5

As demonstrated herein, good cause exists for waiver of the assigned Transition Phase and its attendant testing and completion dates. Grant of the waiver will serve the public interest by facilitating an orderly and efficient transition to more swiftly deliver new wireless broadband services to the public while minimizing impacts on broadcast television viewers and post-auction transition resources. KMYT-TV has partnered with T-Mobile to transition early to facilitate broadband service using the 600 MHz band in and around Tulsa, up to 7 months earlier than the scheduled transition for this market. The interplay amongst the four TV stations involved in this early transition is depicted in Table 1.

Table 1. Tulsa early transition move package.

Call Sign Channel New Ch Dependency LSS ISIX Case for T-Mobile

KOZJ 25 35 N/A 9 N/A

KXNW 34 25 KOZJ 9 N/A

KMYT 42 34 KXNW 9 Case 3

KGEB 49 12 N/A N/A Case 4

Background. KMYT-TV currently operates on Channel 42, which is in a portion of the

600 MHz band acquired by T-Mobile. To expedite the clearing of the 600 MHz band, two other stations, KXNW and KOZJ are both seeking to transition early and their applications are incorporated by reference to this waiver request.6 Because the three stations (KMYT-TV,

5 Northeast Cellular, 897 F.2d at 1166. 6 See also T-Mobile Letter in support of KMYT-TV early transition.

178518191 v4 KXNW and KOZJ) are linked, in order for KMYT-TV to move early, KXNW, and immediately

before it KOZJ, must and plan to transition at the same time to avoid impermissible interference.

A fourth station in the market, KGEB(DT), also plans to request permission to transition early

and on the same schedule, so as to minimize the number of rescans Tulsa area viewers will need

to make. Should the FCC grant the instant Phase Waiver request, Cox pledges to coordinate with

Tribune Broadcasting of Fort Smith License, LLC, licensee of KXNW(TV), Eureka Springs,

Arkansas; the Board of Governors of Missouri State University, licensee of KOZJ(TV), Joplin,

Missouri; and University Broadcasting, Inc., licensee of KGEB(DT), Tulsa, Oklahoma, to

minimize confusion among viewers in the DMA and ensure that viewers know of the intention of

all four stations to transition ahead of the overall Tulsa transition phase.

Interference. Attached hereto is an “Engineering Statement Supporting Request for

Waiver KMYT-TV,” prepared by duTreil, Lundin & Rackley, Inc

(“Engineering Statement”). As demonstrated in the Engineering Statement, the proposed early

transition will cause 0.99% new interference to Station KSJF-CD and 6.19% to KXNW. In the

Transition Scheduling PN, the Commission determined that allowing temporary pairwise

(station-to-station) interference of up to two percent (2%) during the transition is in the public

interest.7 The proposed new interference to KSJF-CD is under this allowable threshold and will

be temporary, as it will resolve upon the transition of Station KSJF-CD to its new channel on or

before April 12, 2019. Cox pledges to notify and work cooperatively with the licensee of Station

KSJF-CD to minimize actual interference, if possible.

7 Incentive Auction Task Force and Media Bureau Adopt A Post-Incentive Auction Transition Scheduling Plan, MB Docket No. 16-306 and GN Docket No. 12-268, 32 FCC Rcd 890, 913 ¶ 16 (MB 2017) (Transition Scheduling Adoption Public Notice), citing Incentive Auction Task Force and Media Bureau Seek Comment on Post-Incentive Auction Transition Scheduling Plan, Public Notice, 31 FCC Rcd 10802 (MB 2016) (Transition Scheduling Proposal Public Notice).

178518191 v4 In addition, as discussed above, the interference to KXNW will be resolved immediately when KXNW moves to channel 25, so no actual interference will occur. No other cases of incoming (received) interference exceeding the normal 0.5% rounding tolerance level to any other protected full-power or Class A television stations now operating will occur, and no new pairwise (station-to-station) interference will be created by the proposed early transition of

Station. No new linked station sets are created by the proposal.

Impacts to Transition Plan. The proposed transition will further the overall transition plan and will positive externalities by allowing the unlocking of a linked station set, thereby relieving numerous stations from burdens associated with coordination of resources and timing. Indeed, the transition of KXNW, KOZJ and KMYT-TV will remove three stations from linked station set 9. This will simplify the transition process for the last station, KNWA-TV, which currently operates at channel 50 and will transition to channel 33 in Phase 2.

This early out of phase move will also permit better utilization of resources by engaging vendors and service providers early in the process rather than have them potentially overloaded further in the transition. For KMYT-TV, the Station’s current tower will require significant renovations before the Station can replace its antenna and other equipment needed to move to its post-auction channel. Accordingly, KMYT-TV has planned to relocate to an interim tower site while construction on its primary tower takes place. KMYT-TV had planned to relocate to the interim tower site on its current channel. If, however, KMYT-TV is permitted to transition early,

KMYT-TV will move to its interim tower site on its post-auction channel. By allowing KMYT-

TV to move to its new channel on the interim tower site (instead of moving to the interim site on its current channel), grant of this Phase Waiver request will ease the potential strain on tower companies because KMYT-TV will no longer have a hard deadline by which it must complete

178518191 v4 construction on its current tower (since KMYT-TV will already be on its post-auction channel).

This will allow all parties more flexibility, and will ease the repack transition.

Furthermore, since KMYT-TV is currently in Phase 2 of the repack, it has already made

significant progress in obtaining the services and equipment it needs to transition to its post-

auction channel. For example, KMYT-TV has already purchased and received a broadband

antenna from its antenna supplier, Dielectric. While KMYT-TV had intended to use the antenna

on the interim tower on the Station’s current channel, the antenna can be configured for KMYT-

TV’s post-auction channel as well. KMYT-TV has also contacted its other vendors, including its

tower contractor for work on the interim tower, Stainless LLC, and Stainless has advised the

Station that Stainless can install the KMYT-TV antenna on the interim tower by September 1

without impacting other previously scheduled projects for other stations.8 KMYT-TV has also received confirmation from GatesAir that the Station’s transmission equipment can be delivered by August 1, thereby giving the Station plenty of time to install the new equipment.9

Attached is the “Current KMYT Repack Schedule” showing the station’s current repack plans. The station is using two different tower companies for the installation work on the interim

and main towers and Stainless is scheduled to begin work on the interim tower shortly. Cox

plans to stay with the current schedule if this waiver is granted, but grant of the waiver will give

Rio Steel, the tower company scheduled to work on the main tower, additional timing flexibility

should Rio need it for work for KMYT, for Cox, or for other broadcasters.

Impact on Viewers. Finally, Cox believes any disruption to viewers will be minimal. The

Station recognizes that its request for an early transition may increase the total number of times a

8 See attached letter from Stainless, LLC to Mr. Darin Hall, Tulsa, dated June 6, 2018. 9 See attached letter from GatesAir to Mr. Darin Hall, Cox Media Group Tulsa, dated June 6, 2018.

178518191 v4 viewer may need to rescan equipment in order to receive all reassigned stations in Tulsa from

two to three scans. Although this number exceeds the presumptive cap by one scan,10 a waiver can be justified as the Station will engage in a comprehensive consumer awareness campaign.

Cox pledges to act to mitigate further any viewer disruption by increasing outreach education beyond the required public service announcements and crawls to notify the Station audience of the proposed transition and provide detailed instructions on the rescanning process. Specifically,

for at least 30 days prior to ceasing operation on its pre-auction channel, the Station will devote

at least 90 seconds per day to a combination of viewer on-air education, PSAs, and

crawls. These efforts will be targeted to alert the public about the new channel and what actions

they will need to take, if any, to continue receiving KMYT-TV. The Station is also considering

using social media, on-air news stories, and other engagement events and interactions with the

public to ensure that the repack transition is widely publicized and that viewers in Tulsa will be

aware of the change. Finally, the Station will have technical personnel available to take calls

from the public to help with the rescanning process if needed, and additional staff members will

also be available as resources for viewers who call in with general questions.

Additionally, T-Mobile will undertake additional consumer outreach to ensure consumers

are informed about the transition as described in the attached letter.

Cox will coordinate with Missouri State University, licensee of KOZJ(TV), Joplin,

Missouri, Fort Smith License, LLC, licensee of KXNW(TV), Eureka

Springs, , and University Broadcasting, Inc., licensee of KGEB(DT), Tulsa, Oklahoma,

to minimize confusion among viewers in the DMA of the intention of all four stations to

transition ahead of the overall Tulsa transition phase.

10 See Transition Scheduling Adoption Public Notice at ¶¶ 20 and 21.

178518191 v4 MVPD Notification. Cox has already started to take the necessary actions to ensure all impacted MVPDs are notified of the impending channel change at least 90 days prior to actual change – on Saturday, June 2, 2018, transition letters were mailed to the MVPDs that carry the

Station.

The Transition Scheduling Adoption Public Notice permitted stations to propose

“alternative transition solutions that could create efficiencies,” and held that a request to modify a station’s transition deadline — including by moving to an earlier phase — would be viewed favorably if the request is “otherwise compliant with [FCC] rules and [has] little or no impact on the phase assignments or transition schedule.”11 As explained above, Cox’s instant request qualifies for such favorable treatment.

In sum, grant of this waiver will facilitate a more effective and efficient implementation of the overall policy goals of the Incentive Auction and post-auction transition, and thus is in the public interest.

11 Transition Scheduling Adoption Public Notice at ¶51.

178518191 v4 du Treil, Lundin & Rackley, Inc. Consulting Engineers

ENGINEERING STATEMENT SUPPORTING REQUEST FOR WAIVER TELEVISION STATION KMYT-TV (FACILITY ID NO. 54420) TULSA, OKLAHOMA CHANNEL 34

Background

This statement was prepared on behalf of Cox Television Tulsa, LLC, licensee of KMYT-TV, Tulsa, OK, in support of a request for waiver of the FCC’s Phase Assignment, Testing Period, and Phase Completion Date for television station KMYT-TV in the Tulsa DMA*. KMYT-TV is licensed for operation on RF Channel 42 with a non-directional (ERP) of 900 kW and an antenna height above average terrain (HAAT) of 381 m.†

As a result of the FCC’s Incentive Auction repack process, the KMYT-TV facility was reassigned to RF Channel 34. KMYT-TV has a construction permit (C.P.) for its post-transition operation on Channel 34 with a non-directional ERP of 770 kW and an antenna HAAT of 381 m.‡ An FCC engineering database summary sheet for the KXNW C.P. facility is attached hereto for reference.

In coordination with the wireless carrier T-Mobile, KMYT-TV seeks a waiver of the FCC’s Phase Assignment, Testing Period, and Phase Completion Date to allow KMYT-TV to make the transition to Channel 34 earlier than its given phase transition date. Specifically, the target date for KMYT-TV to begin operations on Channel 34 is September 1, 2018. This will facilitate the early deployment of new 600 MHz band wireless broadband services.

This statement demonstrates that KMYT-TV can transition to Channel 34 before its assigned phase date without any disruption to the FCC’s transition plans.

* Nielsen Designated Market Area abbreviated as DMA. † See FCC File No. BLCDT-20021112ABD. ‡ See FCC File No. 0000027114. du Treil, Lundin & Rackley, Inc.

Consulting Engineers Page 2

Assigned Phase

KMYT-TV was assigned to transition Phase 2, with a testing begin date of December 1, 2018. This is based on the latest FCC Phase Assignment spreadsheet dated May 30, 2018.

Linked Station Sets and Linked Station Neighbor Stations

An inspection of the latest FCC Linked Station Set (LSS) and Linked Station Neighbor (LSN) spreadsheet databases indicates that the KMYT-TV facility is part of the following LSSs and LSNs:

LSSs

Facility ID Phase LSS ID Linked Facility IDs

29557 51101 54420 81593 2 9 (KNWA-TV) (KOZJ) (KMYT-TV) (KXNW) 51101 29557 54420 81593 2 9 (KOZJ) (KNWA-TV) (KMYT-TV) (KXNW) 54420 29557 51101 81593 2 9 KMYT-TV (KNWA-TV) (KOZJ) (KXNW) 81593 29557 51101 54420 2 9 (KXNW) (KNWA-TV) (KOZJ) (KMYT-TV)

LSNs

Facility ID Phase LSS ID Up/Down Neighbor Facility ID 54420 81593 2 9 UPSTREAM (KMYT-TV) (KXNW)

These are based on the latest LSS and LSN spreadsheets available from the FCC, both dated May 30, 2018.

du Treil, Lundin & Rackley, Inc.

Consulting Engineers Page 3

The LSN with KMYT-TV involves one upstream case that is highlighted in the table above. This is the case of an interference conflict with KMYT-TV (Ch. 34 C.P.) into the licensed facility of KXNW, Eureka Springs, AR, on Ch. 34. KXNW is migrating from Channel 34 to Channel 25 as part of the Incentive Auction repack.

The licensee of KXNW has an Early Transition Agreement with T-Mobile with a target transition date of September 1, 2018. The licensees of KMYT-TV and KXNW will be working together to coordinate the transitions of KMYT-TV and KXNW on the same date. Therefore, the LSN for KMYT-TV upstream from KXNW will be coordinated between the two licensees to avoid an interference conflict.

Interference Caused Analysis Under Current Allocation Environment

An interference analysis was conducted for the KMYT-TV Channel 34 C.P. facility utilizing the latest version§ of the FCC’s TVStudy coverage and interference analysis prediction software. The report of the results is attached hereto entitled ‘Interference Caused Analysis for KMYT-TV Channel 34 C.P. Facility Under Current Allocation Environment.’ It is noted that a higher resolution terrain profile point spacing of 0.2 km is requested for this analysis.

The results of the analysis indicate that there are two cases of outgoing (caused) interference exceeding the normal 0.5% permissible rounding tolerance level to protected full-power or Class A television stations now operating. These are with respect to the KSJF-CD, Poteau, OK (Ch. 34) facility and the aforementioned, KXNW facility.

The predicted interference caused to the KSJF-CD facility is less than the FCC’s temporary 2% permissible interference level. Therefore, this does not create an interference conflict for the early transition of KMYT-TV.

The predicted interference with respect to KXNW is a conflict that will be resolved by coordinating the early transition of KMYT-TV with KXNW. As indicated above, the licensees of KMYT-TV and KXNW will be coordinating their respective early transition repack facilities to occur on the same target date so as to avoid an interference conflict.

§ TVStudy Version 2.2.5 du Treil, Lundin & Rackley, Inc.

Consulting Engineers Page 4

Interference Received Analysis Under Current Allocation Environment

An interference analysis specifically for the ‘received case’ of interference was conducted for the KMYT-TV Channel 34 C.P. facility utilizing the FCC’s aforementioned TVStudy prediction software. The report of the results is attached hereto entitled ‘Interference Received Analysis for KMYT-TV Channel 34 C.P. Facility Under Current Allocation Environment.’ The purpose of this study is to evaluate all current environment records in the received interference analysis. As above, it is noted that a higher resolution terrain profile point spacing of 0.2 km is requested for this analysis.

The results of the analysis indicate that there is one case of incoming (received) interference exceeding the normal 0.5% rounding tolerance level to the KMYT-TV Channel 34 C.P. facility. This case is with respect to the predicted interference received from the aforementioned KXNW facility. The predicted interference with respect to KXNW is an interference conflict that will be resolved by coordinating the early transition of KMYT-TV with KXNW to occur on the same target date as discussed above.

Effects on Linked Station Sets

The early transition of KMYT-TV in advance of its phase transition date will not create any new linked station sets. In fact, through the coordination of KMYT-TV and KXNW to make early transitions, the LSSs involving KMYT-TV and KXNW will be eliminated, which will simplify the Incentive Auction repack process.

Conclusion

It is concluded that the early transition of the KMYT-TV C.P. facility on Channel 34, as described herein, will not result in the creation of any linked station sets established in the Incentive Auction repack process. Furthermore, through the

du Treil, Lundin & Rackley, Innc.

Consulting Engineers Page 5

coordination of KMYT-TV and KXNW to make early transitions on their respective channels, the LSSs involving KMYT-TV and KXNW will be eliminated and it will simplify the repack process.

Louis R. du Treil, Jr., P.E.

du Treil, Lundin & Raackley, Inc. 3135 Southgate Circle Sarasota, Florida 34239

June 5, 2018

TV Inquiry du Treil, Lundin, & Rackley, Inc., Sarasota, Florida

Callsign: KMYT-TV Service: DT Status: CP App. Status: GRANT Border Code: Rec. Type: C

Channel: 34 Offset: Zone: 2 Docket Number: DTV Type: POSTTRAN

Fac. ID: 54420 Assoc. ID: Application File No.: BLANK-0000027114 DT Emission Mask:

City: TULSA State: OK Country: US CP Expiration Date:

Party Name: COX TELEVISION TULSA, LLC Last Change Date: 7/24/2017

Latitude (NAD 83): 36-01-36 Height AGL (m): 355.7 Polarization: H Longitude (NAD ): 095-40-45 Overall Height AGL (m): 386.5 83 Electrical Tilt (°): 0.75 ERP (kW): 770 Mechanical Tilt (°): Maximum ERP (kW): Mechanical Tilt Azimuth (°): Maximum ERP (dBk): 28.9 RCAMSL (m): 572.1 Degrees True (°): Maximum ERP at any Site Elevation AMSL (m): 216.4 Angle (kW): Antenna Make: HAAT (m): 381 Antenna Model: Maximum HAAT (m):

Antenna Type: N Antenna ID: 1001584 Rotation (°): 350 0 10 340 20 0° 1.000 90° 1.000 180° 1.000 270° 1.000 330 30 10° 1.000 100° 1.000 190° 1.000 280° 1.000 320 0.8 40 310 50 0.6 20° 1.000 110° 1.000 200° 1.000 290° 1.000 300 60 30° 1.000 120° 1.000 210° 1.000 300° 1.000 0.4 290 70 40° 130° 220° 310° 1.000 1.000 1.000 1.000 280 0.2 80

50° 1.000 140° 1.000 230° 1.000 320° 1.000 270 90

60° 1.000 150° 1.000 240° 1.000 330° 1.000 260 100

70° 1.000 160° 1.000 250° 1.000 340° 1.000 250 110 80° 1.000 170° 1.000 260° 1.000 350° 1.000 240 120

Standard Pattern: 230 130 220 140 Antenna Make: ERI 210 150 200 160 190 180 170 Antenna Model: ATW28H3-HSO-34H

Last Change Date: Note: Rotation or tilt is not applied to the pattern shown

Type: TOWER ASRN: 1048931 FAA Study No.: 2002-ASW-5969-OE Structure Height (m): 365.8 Structure Height (ft): 1200.1 Latitude (NAD 27): 036-01-35.6 Date Received: 03/19/2016 Longitude (NAD 27): 095-40-44.1 Date Entered: 03/19/2016 Ground Elevation (m): 216.4 Date Issued: Ground Elevation (ft): Latitude (NAD 83): 36-01-36.0 03/19/2016 710.0 Date Constructed: 03/28/2003 Longitude (NAD 83): 095-40-45.0 Overall Height AGL (m): 386.5 Date Dismantled: Overall Height AGL (ft): Struct. Address: 1268.0 9250 S. 273rd E. AVE. Overall Height AMSL (m): 602.9 BROKEN ARROW OK Overall Height AMSL (ft): 1978.0

Entity Name: IWG Towers Assets II, LLC INTERFERENCE CAUSED ANALYSIS FOR KMYT-TV CHANNEL 34 C.P. FACILITY UNDER CURRENT ALLOCATION ENVIRONMENT (0.2 KM TERRAIN PROFILE POINT SPACING)

tvstudy v2.2.5 (4uoc83) Database: localhost, Study: kmyt34e4, Model: Longley-Rice

Study build station data: LMS TV 2018-06-04 KMYT-TV is making an early transition to its assigned Incentive Auction repack channel (34) in coordination with station KXNW(TV), Proposal: KMYT34E4 D34 DT CP TULSA, OK Eureka Springs, AR with a target transition date of September 1, 2018. File number: kmyt34e4 Facility ID: 54420 Station data: User record Record ID: 2895 Country: U.S. Zone: II

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

Search options: All post-transition APP, CP, and baseline records excluded

Stations potentially affected by proposal:

IX Call Chan Svc Status City, State File Number Distance Yes KOCB D33 DT LIC , OK BLCDT20060615AAL 171.5 km Yes KXNW D34 DT LIC EUREKA SPRINGS, AR BMLCDT20140610AAT 160.5 No KMSS-TV D34 DT LIC SHREVEPORT, LA BLCDT20050705AAB 406.4 Yes WDAF-TV D34 DT LIC CITY, MO BLCDT20091008AAW 351.7 Yes KSJF-CD D34 DC CP POTEAU, OK BLANK0000032952 130.2 No KOMI-CD D34 DC LIC WOODWARD, OK BLANK0000014011 339.2 No KMTW D35 DT LIC HUTCHINSON, KS BLCDT20030117AAE 267.7

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: 36 1 36.00 N (NAD83) Longitude: 95 40 45.00 W Height AMSL: 572.1 m HAAT: 381.0 m Peak ERP: 770 kW Antenna: Omnidirectional Elev Pattrn: Generic Elec Tilt: 0.75

40.7 dBu contour: Azimuth ERP HAAT Distance 0.0 deg 770 kW 379.6 m 102.5 km 45.0 770 397.8 104.1 90.0 770 398.2 104.1 135.0 770 385.8 103.1 180.0 770 371.4 101.9 225.0 770 375.3 102.2 270.0 770 363.0 101.2 315.0 770 361.0 101.0

Database HAAT does not agree with computed HAAT Database HAAT: 381 m Computed HAAT: 379 m

Distance to Canadian border: 1266.6 km

Distance to Mexican border: 876.3 km

Conditions at FCC monitoring station: Grand Island NE Bearing: 337.1 degrees Distance: 594.4 km

Proposal is not within the West Virginia quiet zone area

Conditions at Table Mountain receiving zone: INTERFERENCE CAUSED ANALYSIS FOR KMYT-TV CHANNEL 34 C.P. FACILITY UNDER CURRENT ALLOCATION ENVIRONMENT (0.2 KM TERRAIN PROFILE POINT SPACING)

Bearing: 301.5 degrees Distance: 950.3 km

Study cell size: 2.00 km Profile point spacing: 0.20 km (Higher resolution terrain profile point spacing is requested.)

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

------Interference to BLCDT20060615AAL LIC scenario 1

Call Chan Svc Status City, State File Number Distance Desired: KOCB D33 DT LIC OKLAHOMA CITY, OK BLCDT20060615AAL

Undesireds: KMYT34E4 D34 DT CP TULSA, OK kmyt34e4 171.5 km

Service area Terrain-limited IX-free, before IX-free, after Percent New IX 38591.2 1,629,783 38223.3 1,628,236 38223.3 1,628,236 38179.1 1,627,816 0.12 0.03

Undesired Total IX Unique IX, before Unique IX, after KMYT34E4 D34 DT CP 44.2 420 44.2 420

------Interference to BMLCDT20140610AAT LIC scenario 1 KMYT-TV is coordinating its early transition with station **IX: 6.19% interference caused KXNW with a target transition date of September 1, 2018.

Call Chan Svc Status City, State File Number Distance Desired: KXNW D34 DT LIC EUREKA SPRINGS, AR BMLCDT20140610AAT

Undesireds: KMYT34E4 D34 DT CP TULSA, OK kmyt34e4 160.5 km WDAF-TV D34 DT LIC KANSAS CITY, MO BLCDT20091008AAW 301.1 KSJF-CD D34 DC CP POTEAU, OK BLANK0000032952 105.5 KRAH-CD D35 DC CP PARIS, AR BLANK0000035644 145.8

Service area Terrain-limited IX-free, before IX-free, after Percent New IX 13716.2 570,030 13292.2 562,625 13248.1 562,411 12182.1 527,580 8.05 6.19

Undesired Total IX Unique IX, before Unique IX, after KMYT34E4 D34 DT CP 1094.1 34,992 1065.9 34,831 WDAF-TV D34 DT LIC 8.0 46 8.0 46 4.0 29 KSJF-CD D34 DC CP 36.1 168 36.1 168 12.0 24

------Interference to BLCDT20091008AAW LIC scenario 1

Call Chan Svc Status City, State File Number Distance Desired: WDAF-TV D34 DT LIC KANSAS CITY, MO BLCDT20091008AAW

Undesireds: KMYT34E4 D34 DT CP TULSA, OK kmyt34e4 351.7 km WQEC D34 DT APP QUINCY, IL BLANK0000035763 299.2

Service area Terrain-limited IX-free, before IX-free, after Percent New IX 32826.7 2,539,581 32447.2 2,538,295 32391.3 2,538,168 32323.8 2,538,002 0.21 0.01

Undesired Total IX Unique IX, before Unique IX, after KMYT34E4 D34 DT CP 67.5 166 67.5 166 WQEC D34 DT APP 55.9 127 55.9 127 55.9 127

------

INTERFERENCE CAUSED ANALYSIS FOR KMYT-TV CHANNEL 34 C.P. FACILITY UNDER CURRENT ALLOCATION ENVIRONMENT (0.2 KM TERRAIN PROFILE POINT SPACING)

------Interference to BLANK0000032952 CP scenario 1 This predicted interference is within the FCC’s temporary 2% **IX: 0.99% interference caused permissible interference level.

Call Chan Svc Status City, State File Number Distance Desired: KSJF-CD D34 DC CP POTEAU, OK BLANK0000032952

Undesireds: KMYT34E4 D34 DT CP TULSA, OK kmyt34e4 130.2 km KRAH-CD D35 DC CP PARIS, AR BLANK0000035644 106.6

Service area Terrain-limited IX-free, before IX-free, after Percent New IX 5595.5 233,792 4977.3 218,770 4977.3 218,770 4751.9 216,615 4.53 0.99

Undesired Total IX Unique IX, before Unique IX, after KMYT34E4 D34 DT CP 225.4 2,155 225.4 2,155

------INTERFERENCE RECEIVED ANALYSIS FOR KMYT-TV CHANNEL 34 C.P. FACILITY UNDER CURRENT ALLOCATION ENVIRONMENT (0.2 KM TERRAIN PROFILE POINT SPACING)

tvstudy v2.2.5 (4uoc83)

Database: localhost Station Data: LMS TV 2018-05-03 Study: LMS180503 Model: Longley-Rice Scenario: kmyt34e4r

Desired station Service area Terrain-limited Interference-free

Undesired station Total interference Unique interference

KMYT34E4 D34 DT CP TULSA, OK 32998.9 1,314,238 32083.0 1,298,706 30818.0 1,263,833

KXNW D34 DT LIC EUREKA SPRINGS, AR 1095.5 32,951 995.0 31,265 (2.41%)* KRAH-CD D35 DC LIC PARIS, AR 0.0 0 0.0 0 KASN D34 DT CP PINE BLUFF, AR 40.3 686 8.1 42 (0.00%) KNWA-TV D33 DT CP ROGERS, AR 4.0 62 0.0 0 KOZJ D35 DT CP JOPLIN, MO 0.0 0 0.0 0 WDAF-TV D34 DT LIC KANSAS CITY, MO 28.0 778 0.0 0 KOCB D33 DT LIC OKLAHOMA CITY, OK 44.3 169 32.2 143 (0.01%) KSJF-CD D34 DC CP POTEAU, OK 181.7 2,526 117.1 1,174 (0.09%) KOMI-CD D34 DC LIC WOODWARD, OK 0.0 0 0.0 0

* Note: KMYT-TV is making an early transition to its assigned Incentive Auction repack channel (34) in coordination with station KXNW(TV), Eureka Springs, AR with a target transition date of September 1, 2018. KMYT-TV has no dependencies other than a upstream dependency with KXNW.

June 6, 2018

Mr. Darin Hall Cox Media Group Tulsa 2625 S Memorial Drive Tulsa, OK 74129

RE: KMYT Project

Mr. Hall,

At your request, we have evaluated our current and proposed field resource capabilities to include the KMYT-TV antenna installation project.

This earlier move project for KMYT will not impact our ability to deliver our previously scheduled projects and their Phase implementation.

We can meet the delivery date to allow KMYT to transition an assigned date earlier than Phase 2.

Please let me know if you have additional questions.

Regards,

Jon Marcusse National Sales Manager

Stainless - A Business of FDH Infrastructure Services, LLC 200 North Warner Road, Suite 215 King of Prussia, PA 19406

GatesAir 5300 Kings Island Drive, Suite 101 Mason, OH, USA, 45040 Telephone: 1 800-622-0022 Fax: 1 513-459-3796 www.gatesair.com

June 6th, 2018

Darin Hall | Chief Engineer Cox Media Group Tulsa KOKI/KMYT 2625 S Memorial Drive Tulsa, OK 74129

Dear Mr. Hall:

This letter is intended to confirm that GatesAir has the capacity to deliver transmission equipment for station KMYT to meet your 8/1/2018 date. This will not prevent GatesAir from fulfilling other orders or other customer commitments required for earlier Phases. In fact, it will allow GatesAir to more efficiently utilize our manufacturing capacity.

Should you have any question, please feel free to contact us for any further clarifications.

Best Regards,

Raymond Miklius Director, Television Transmission Product Line GatesAir, Inc. [email protected]

Current KMYT Repack Schedule 06-25-2018

4/16/2018 Interim Antenna/Line delivered 6/31/2018 Main Antenna/Line into Storage 7/6/2018 Interim Facility Construction complete 7/9/2018 Interim Transmitter delivery 7/16/2018 Interim Tower modification steel delivery 7/17/2018 Interim Tower work and installation begins 7/16/2018 Interim Transmitter installation 8/1/2018 Public Education rescan campaign begins 8/2/2018 Interim Transmitter installation complete 8/6/2018 Main Tower modification steel delivery 8/7/2018 Main Tower work and installation begins 8/13/2018 Interim Tower work and installation complete 8/20/2018 Main Antenna/Line Out of storage, Deliver to site 9/1/2018 Transition from Main site (RF CH. 42) to Interim Site (RF CH. 34) 9/17/2018 Main Transmitter delivery 10/8/2018 Main Transmitter installation 11/1/2018 Main Tower work and installation complete 12/3/2018 Transition from Interim site (RF CH. 34) to Main Site (RF CH. 34)

Darin Hall | Chief Engineer Cox Media Group Tulsa KOKI/KMYT 2625 S Memorial Drive Tulsa, OK 74129 918.388.5268 office | 918.706.7551 cell | [email protected]

KOKI-TV / KMYT-TV 2625 South Memorial Drive Tulsa, Oklahoma 74129 Phone: 918-388-5100 Fax: 918-491-6650 www.FOX23.com

June 6, 2018

Ms. Marlene H. Dortch Secretary, Federal Communications Commission 445 12th Street, S.W. Washington, DC 20554

Re: Application of Cox Television Tulsa, LLC, for Early Transition from the 600 MHz Spectrum KMYT-TV, Tulsa, Oklahoma (54420)

Dear Ms. Dortch,

T-Mobile is committed to assisting consumers in accessing local television stations that have changed channels as a result of the post-Incentive Auction repacking process. For this particular market, the proposed early transition of above-referenced station will increase the overall number of rescans in the market to more than the desired number of two rescans. As a beneficiary of the spectrum auction, T- Mobile is committed to educating consumers in the impacted market and will supplement the broadcaster’s outreach to consumers on the impending changes and the steps they will need to take to continuing receiving the station.

T-Mobile pledges to analyze the market utilizing our internal advertising team (or retain a third-party media strategy firm, as appropriate) to determine the best approaches to reach the impacted communities in a timely manner to minimize negative impacts and ensure continuity of over-the-air reception. T-Mobile pledges to undertake at its own expense one or more of the following methods, or such equivalent approaches as are appropriate, to reach consumers in the affected market:

• Bi-lingual public services announcements on radio and television stations in the market; • Bi-lingual advertisement in targeted newspaper, magazines, newsletters and/or websites; • MetroPCS and T-Mobile customer announcements via text message, direct mail and bill inserts; • Bilingual flyers in MetroPCS and T-Mobile stores; and • Bilingual posts on T-Mobile and MetroPCS social media.

If you have any questions. please feel free to contact me.

Respectfully submitted,

/s/ Steve B. Sharkey

Steve B. Sharkey Vice President, Government Affairs Technology and Engineering Policy T-Mobile USA, Inc. (202) 654-5900

T-Mobile USA, Inc. 601 Pennsylvania Avenue NW, North Building, Suite 800, Washington, DC 20004