BROADCAST TECHNICAL CONSULTANTS
ENGINEERING STATEMENT
IN SUPPORT OF A
COUNTERPROPOSAL
MM DOCKET 00-148, DA 00-1905 RM-9939
First Broadcasting Company, LP Next Media Licensing, Inc. Capstar TX Limited Partnership Rawhide Radio, LLC Clear Channel Broadcasting Licenses, Inc.
Prepared by:
Reynolds Technical Associates 2421 Presidents Drive, Suite B-23 Montgomery, Alabama 36116 (334) 323-3620
October, 2000
2421 Presidents Drive, Suite B-23 • Montgomery, AL 36116' (334) 323-3620· Fax: (334) 323-3623 Engineering Statement In Support of a Counterproposal MM Docket 00-148 The Joint Petitioners
CONTENTS
FOR ENGINEERING EXHIBITS
1. statement of Engineers 1-26
2. Table 1 Summary of communities and channels
3. Exhibit E, Figure 1 Allocation study for channel 248C, KLAK.P, Keller, Texas
4. Exhibit E, Figure 2 KLAK.P 70 dBu contour map
5. Exhibit E, Figure 3 KLAK.P 70 dBu contour map (zoomed view)
6. Exhibit E, Figure 4 TIGER map of Keller, Texas
7. Exhibit E, Figure 5 KLAK.P gain and loss area map
8. Exhibit E, Figure 6 Map of remaining services for KLAK.P
9. Exhibit E, Figure 7 Facilities in remaining services study
10. Exhibit E, Figure 8 Allocation study for channel 230Cl, AL230C1 Archer City, Texas
II. Exhibit E, Figure 9 Allocation study for channel 222C2, KSEY.A channel 230C2, Seymour, Texas
12. Exhibit E, Figure 10 Channel 222C2 70 dBu contour map, Seymour, Texas
13. Exhibit E, Figure 11 Channel 222C2/channel 230C2 gain and loss area map, Seymour, Texas
14. Exhibit E, Figure 12 Allocation study for channel 298C2, Channel 222C2, Seymour, Texas
15. Exhibit E, Figure 13 Allocation study for channel 257A, Channel 297A, Knox City, Texas
16. Exhibit E, Figure 14 Allocation study for channel 296C3, Channel 298C3, Wellington, Texas
17. Exhibit E, Figure 15 Allocation study for channel 232C2 KZCD.P Lawton, OK
Continued on next page
i Continued from previous page
CONTENTS FOR ENGINEERING EXHIBITS
18. Exhibit E, Figure 16 KZCD.P 70 dBu contour map
19. Exhibit E, Figure 17 KZCD.P/KZCD.L gain and loss map
20. Exhibit E, Figure 18 Allocation study for channel 233C2 KXOO.L, Elk City, Oklahoma
2l. Exhibit E, Figure 19 Allocation study for channel 255C3 AD 233C3 Quanah, Texas
22. Exhibit E, Figure 20 Allocation study for channel 249A KGOK.P, Purcell, Oklahoma
23. Exhibit E, Figure 21 KGOK.P 70 dBu contour map
24. Exhibit E, Figure 22 KGOK.P/KGOK.C gain and loss area map
25. Exhibit E, Figure 23 Map of remaining services for KGOK
26. Exhibit E, Figure 24 Facilities in KGOK remaining services study
27. Exhibit E, Figure 25 Allocation study for channel 239Cl KKAJ.P, Healdton, Oklahoma
28. Exhibit E, Figure 26 KKAJ.P 70 dBu contour map
29. Exhibit E, Figure 27 KKAJ.P/KKAJ.L gain and loss area map
30. Exhibit E, Figure 28 Map of remaining services for KKAJ
3l. Exhibit E, Figure 29 Facilities in Ardmore remaining services study
EXHIBIT E, FIGURES 30 - 36 ARE FOR OPTION II ONLY
32. Exhibit E, Figure 30 Allocation study for channel 225C2 KWTX.P Waco, Texas
33. Exhibit E, Figure 31 KWTX (Ch 225C2) 70 dBu contour map
34. Exhibit E, Figure 32 KWTX (Ch 225C2) gain and loss area map
35. Exhibit E, Figure 33 Remaining services study
36. Exhibit E, Figure 34 Facilities in KWTX (Ch 225C2) remaining services study
ii CONTENTS
FOR ENGINEERING EXHIBITS
37. Exhibit E, Figure 35 Allocation study for channel 248C2, KLRK.P, Marlin, Texas
38. Exhibit E, Figure 35(a) KLRK hypothetical 70 dBu Contour Map
39. Exhibit E, Figure 36 Gain/Loss Study for KLRK
40. Exhibit E, Figure 37 Allocation study for channel 247Cl, KWTX. P, Lakeway, Texas
4l. Exhibit E, Figure 38 KWTX.P 70 dBu contour map
42. Exhibit E, Figure 39 KWTX.P gain and loss area map
43. Exhibit E, Figure 40 Map of remaining services for KWTX
44. Exhibit E, Figure 41 Facilities in Lakeway, TX remaining Services study
45. Exhibit E, Figure 42 Allocation study for channel 245Cl KAJA. P, San Antonio, Texas
46. Exhibit E, Figure 43 KAJA.P 70 dBu contour map
47. Exhibit E, Figure 44 KAJA.P/KAJA.L gain and loss area map
48. Exhibit E, Figure 45 KAJA Maximum Cl Interference Contour, 54 dBu F(50,10) to Mexican Border Map
49. Exhibit E, Figure 46 Allocation study for channel 243C2, KHFI. P, Lago Vista, Texas
50. Exhibit E, Figure 47 KHFI.P 70 dBu contour map
5l. Exhibit E, Figure 48 KHFI.P gain and loss area map
52. Exhibit E, Figure 49 Map of remaining services for KHFI
53. Exhibit E, Figure 50 Facilities in Lago Vista, TX remaining Services study
54. Exhibit E, Figure 51 Allocation Study for channel 297A, KBAE, Llano, Texas
55. Exhibit E, Figure 52 AL297A 70 dBu contour map
56. Exhibit E, Figure 53 AL297A/AP242A gain and loss area map
57. Exhibit E, Figure 54 Allocation Study for channel 249A, KLFX, channel 297A, Nolanville, Texas
iii CONTENTS
FOR ENGINEERING EXHIBITS
58. Exhibit E, Figure 55 Allocation study for channel 249Cl, KVCQ.P, Converse, Texas
59. Exhibit E, Figure 56 KVCQ.P 70 dBu contour map
60. Exhibit E, Figure 57 KVCQ.P gain and loss area map
61. Exhibit E, Figure 58 Map of remaining services for KVCQ
62. Exhibit E, Figure 59 Facilities in Converse remaining Services study
63. Exhibit E, Figure 60 KVCQ Maximum C1 Interference Contour, 54 dBu F(50,lO) to Mexican Border Map
64. Exhibit E, Figure 60A Allocation study for channel 249C1, KVCQ.P, Mcqueeney, Texas
65. Exhibit E, Figure 60B KVCQ.P 70 dBu contour map (Mcqueeney)
66. Exhibit E, Figure 60C KVCQ.P 70 dBu contour map (Mcqueeney) Zoomed View
67. Exhibit E, Figure 60D TIGER map of Mcqueeney, Texas
64. Exhibit E, Figure 61 Allocation study for channel 256A, AD 243A, Ingram, Texas
65. Exhibit E, Figure 62 Cumulative gain/loss study
iv Engineering Statement
In Support of a
Counterproposal MM Docket 00-148 First Broadcasting Company, L.P. Next Media Licensing, Inc. Capstar TX Limited Partnership Rawhide Radio, LLC Clear Channel Broadcasting Licenses, Inc.
General
The instant counterproposal was prepared for First Broadcasting Company, L.P. ("First") and Next Media Licensing, Inc. ("Next"), licensee of KLAK, channel 248C2, Durant,
Oklahoma, Capstar TX Limited Partnership, licensee of various stations in the counterproposal, Rawhide Radio, LLC, licensee of KVCQ, channel 249C I, Mcqueeney,
Texas, and Clear Channel Broadcasting Licenses, Inc., licensee ofKAlA, channel 247C,
San Antonio, Texas. The above named petitioners are referred herein as The Joint
Petitioners. It is prepared and submitted in response to an NPRM for MM Docket 00-148
(see DAOO-1905). The Joint Petitioners propose to delete channel 248C2 at Durant and subsequently allocate channel 248C at Keller, Texas. They propose that the license of
KLAK be modified accordingly. Various other channel changes, upgrades, site modifications and changes in communities of license are possible as the result of the instant counterproposal.
The counterproposal is submitted to the Commission in two options. Option I seeks the adoption ofthe entire counterproposal as presented. Option II provides for the adoption ofone portion ofthe counterproposal iffor some reason, presently unknown to The Joint Petitioners, only one portion can be adopted. This provision is also discussed in the legal section ofthe counterproposal.
The instant counterproposal is mutually exclusive (MX) with the NPRM in its proposed use of channel 233C3 at Quanah, Texas. However, a substitute channel, 255C3, is available for use at Quanah. Therefore, if the Commission adopts The Joint Petitioners counterproposal as submitted, it can use a proposed substitute channel of 255C3 at
Quanah as a third local service.
Methods
The Joint Petitioners' counterproposal is presented in sections, in with each channel or licensed facility where a change is proposed discussed individually. All sections begin with an allocation or channel spacing study. Additional exhibits then support the proposed modification's technical compliance.
All searches were performed on a V-Soft SearchFM program and verified with the EDX
FMSR search program. The FCC F(50,50) contours were calculated using SoftWright's
Terrain Analysis Package (TAP) Version 4.1.586. The studies were based on the latest technical data from the Commission's databases. Mapping, population counts, and gain/loss areas were conducted using a professional mapping program from MapInfo
Corporation, Version 5.5. The program contains the exact community boundaries of the relevant cities. In pertinent cases where community boundaries were critical, the boundaries were cross-checked with the U.S. Census Bureau's TIGER maps.
All modifications that require a class change or antenna site modification have a gain/1oss study for population and square kilometers. The five facilities that require community of
2 license changes include a remaining services study that demonstrates at least five (5) remaining services in the loss areas.
Nature ofThe Joint Petitioners Counterproposal
A summary of all communities and their related channels (present and proposed) is included in Table 1 for reference. The Joint Petitioners propose to delete channel 248C2 at Durant and substitute channel 248C at Keller, Texas for use by KLAK. In order to accomplish this, various channels and licensed facilities need to be modified in order to create compliance with §73.207. The counterproposal provides for first local services at
Keller, Converse, Lakeway, and Lago Vista, all Texas; and Purcell, Oklahoma. It creates a large increase in square kilometers covered. This is demonstrated by the large increase in the number ofpersons served within the new 60-dBu contour.
Option I and Option II
The composition of The Joint Petitioners' counterproposal can be described as having two basic components. For presentation simplicity the components are labeled North
Division and South Division. The North Division consists of all stations north of Waco,
Texas, and the South Division ofall stations south ofWaco. The pivot station joining the
North and South division is KWTX, channel 248C, Waco, Texas. KLAK (North
Division) cannot upgrade without a modification to KWTX. The North Division goal is to achieve the upgrade of KLAK and its subsequent change in community of license to
Keller, Texas. The South Division goal is to accommodate the KiAK upgrade and in turn allow for various channel changes, license modifications and changes in communities oflicense. In option I, The Joint Petitioners propose to delete channel 248C
3 at Waco and allocate KWTX (on a mutually exclusive basis) to channel 247Cl at
Lakeway, Texas, as that community's first local service. This reassignment of KWTX, move south ofits present location, and the combination ofa channel change-downgrade, give full spacing to KLAK as a class C at Keller.
Option II would be the grant of either the Northern Division or the Southern Division separately. If the Southern Division cannot be adopted, the North Division can be adopted separately by using an alternate modification of KWTX. In adopting the North
Division only, the prohibited short space between KLAK at Keller and KWTX at Waco can be eliminated by substituting channel 225C2 for channel 248C at Waco (a sub change at Marlin, Texas is necessary to make this substitution). Conversely, if the North
Division cannot be adopted, the South Division can be adopted separately by following the proposal to delete channel 248C at Waco and allocating channel 247CI to Lakeway for use by KWTX. All ofthe sub changes for the KWTX allotment at Lakeway proposed in option I would also be required in option II, ifthe South Division only were adopted.
The use ofoption II is to be used only ifThe Joint Petitioners counterproposal cannot he adopted in totality as presented in option L
The allotment ofchannel 248C at Keller requires the following modifications:
I). KRZB.A - channel 248CI (AL248CI, Archer City, Texas), Archer City, Texas.
Previously in MM Docket 97-225 channel 248C2 was deleted at Olney, Texas with
channel 282C2 being substituted. As a result, channel 248C2 was allotted to Archer
City for use by KRZB. In a subsequent rule making, channel 248C2 was deleted and
channel 248CI allotted. The permittee ofKRZB (and petitioner for channel 248CI at
Archer City) agreed to a change in the allotment reference coordinates for KRZB on
4 channel 248Cl. However, the corrected allotment coordinates do not appear in the
most current Commission database. The Joint Petitioners' instant counterproposal
uses the corrected allotment which appears in the final Report and Order in MM
Docket 99-23 (DA 99-2698). The use of these coordinates was necessary to avoid
short spacing to KICM channel 229C2 that recently received a construction permit for
that channel at Krum, Texas.
The allotment of channel 248C at Keller creates a short-space to the channel 248Cl allocation at Archer City (using the correct allotment reference coordinates) of 140.55 kilometers (it appears that at this point no Form 301 has been filed for KRZB on channel
248Cl). In order to eliminate this short-spacing, The Joint Petitioners propose to substitute channel 230Cl at the correct allotment reference site (NL: 33-36-58, WL: 98
51-42). The substitution ofchannel 230C1 for channel 248C1 at Archer City will require no modification to the allotment reference if certain additional changes are made in the spectrum. To accomplish this substitution, the following additional facility changes must occur.
A). ALOPEN -channel 230C2, Seymour, Texas. Presently KSEY, licensed to
Seymour, Texas, operates on channel 232A with an allocation of channel 230C2
for a MX upgrade. In addition, the KSEY licensee has an application (Form 301)
on file for channel 230C2. The substitution ofchannel 230Cl for channel 248Cl
at Archer City creates a short-spacing to the allotment of channel 230C2 at
Seymour of 186.92 kilometers, and 184.91 kilometers to the KSEY pending
channel 230C2 application. There is a short-spacing to the licensed site ofKSEY
as a class A on channel 232 of36.27 kilometers. In order to eliminate these short-
5 spacings, The Joint Petitioners propose to delete channel 230C2 at Seymour by substituting channel 222C2 (or channel 222A) with no site change for the licensed class A KSEY site, and a change for the KSEY pending application for a class
C2, if the licensee so desires. Additional spectrum changes are required to substitute channel 222C2 (or 222A) for channel 230C2 (or 230A) at Seymour.
Channel 222C2 is currently allotted to Seymour, but no applications are pending.
In order to use channel 222C2 for this substitution, The Joint Petitioners propose the substitution of channel 298C2 for channel 222C2 at Seymour at the channel
222C2 allotment reference coordinates. The substitution of channel 298C2 for channel 222C2 is possible since channel 299A (and 299C3) at Jacksboro was deleted in favor of channel 238A in MM Docket 98-198. However, two additional substitutions of vacant channels at Knox City and Wellington, both
Texas, are required.
I). AVAC - channel 297A, Knox City, Texas. The substitution ofchannel
298C2 for channel 222C2 at Seymour, Texas creates a short space of67.10
kilometers to the vacant channel 297A at Knox City, Texas. Channel257A
can be allocated at the channel 297A allotment coordinates at Knox City
without any additional spectrum changes. The substitution ofchannel 257A
for channel 297A eliminates all known short spacing.
2). AVAC - channel 298C3, Wellington, Texas. The substitution ofchannel
298C2 for channel 230C2 at Seymour creates ashort spacing of 14.30
kilometers to the allotted but vacant channel 298C3 at Wellington, Texas.
Channel 296C3 can be substituted for channel 298C3 at the channel 298C3
6 allotment coordinates without any additional spectrum changes. The channel
study lists short spacing to channel 295CI at Clinton, Oklahoma. However,
channel 295Cl was deleted at Clinton and allotted to channel 294C2 at
Okarche, Oklahoma in MM Docket 98-70. Therefore, the substitution of
channel 296C3 for channel 298C3 at Wellington eliminates all known short
spacing.
B). AD230 - channel 230C3, Windthorst, Texas. Currently a proposed add for
channel 230C3 appears in the Commission's Database. The impact of this
proposal is discussed in the legal section of the instant counterproposal. This
proposed allotment is short spaced to the allotment of channel 230CI at Archer
City by 172.27 kilometers. There are no substitute channels for channel 230C3 at
Windthorst. This proposed allotment is also short spaced to a pending application
of KICM for channel 229Cl at Krum, Texas. Therefore, the instant
counterproposal is MX with this proposed allotment, ifthe Windthorst petition is
accepted for filing. If it is accepted, the channel 230C3 allotment at Windthorst
must be compared on a priority basis with Keller, Texas.
It should also be noted that the proposed allotment ofchannel 230C3 is short
spaced to the unused allotment ofchannel 230C2 at Seymour. The petitioner for
channel 230C3 at Windthorst did not offer a replacement channel for channel
230C2, or a willingness to reimburse the KSEY licensee for expenses (including
agreements to relocate signed by the KSEY licensee). See legal section
discussion.
7 C) KZCD.L - channel 231 C2, Lawton, Oklahoma. The substitution of channel
230Cl for channel 248Cl at the correct allotment reference at Archer City creates
a short-space to the licensed site of KZCD, Lawton, Oklahoma of 50.21
kilometers. The Joint Petitioners propose to eliminate this short-space by
substituting channel 232C2 for channel 231 C2 with a change in reference
coordinates at Lawton. The license of KZCD will be modified accordingly. In
order to use channel 232C2 as a substitute for channel 231 C2 with the modified
site, two additional spectrum changes must be made.
1) KXOO - channel 232C3, Elk City, Oklahoma. Presently KXOO operates on
channel 232C3. The substitution ofchannel 232C2 at Lawton creates a short
space of 54.10 kilometers between KXOO and KZCD. The Joint Petitioners
propose to eliminate this short spacing by substituting channel 233C3 for
channel 232C3 at the licensed site of KXOO. However, the substitution of
channel 233C3 at KXOO creates a short space to the proposed allotment of
channel 233C3 at Quanah, Texas by 22.61 kilometers. This is the MX point
(or The Joint Petitioners counterproposal with the instant PRM. The Joint
Petitioners counterproposal does not seek to deny Quanah its Third local aural
service. Therefore, a substitute of255C3 is proposed at Quanah in lieu ofthe
NPRM channel 233C3. Both proposed allotments (233C3 and 255C3) use the
community of Quanah's reference coordinates for these allotments (i.e., no
site restriction).
2) KSEY - channel 232A, Seymour, Texas. Presently KSEY operates on
channel 232A and, as discussed earlier, has an allotment for an upgrade to
8 channel 230C2. The allotment of channel 230C2 does not conflict with the
substitution of channel 232C2 at Lawton, but it does conflict with the
substitution of channel 230Cl for channel 248CI at Archer City. In addition,
the licensed facility of KSEY on channel 232A is short-spaced to the
allotment of channel 232C2 at Lawton by 29.35 kilometers. The previously
discussed substitution of channel 222C2 and/or channel 222A at Seymour
eliminates this short-spacing.
D) KICM - channel 229Cl, Krum, Texas. Presently KICM operates on channel
229C2 at Healdton, Oklahoma. The licensee ofKICM has been granted a change
in community oflicense from Healdton, Oklahoma, to Krum, Texas. The original
allotment was for channel 229C3. The licensee subsequently filed for (and was
approved) a one-step upgrade to channel 229C2 at Krum. The database currently
shows an additional one-step upgrade on the part ofthe KICM licensee to channel
229CI. The substitution of channel 230CI at Archer City and the allotment of
channel 229Cl at Krum creates a short spacing of 25.32 kilometers. However,
this short spacing is of no concern due to the expectation that the application for
channel 229C I at Krum will be dismissed.
II). KRZB.C - channel 248C2, Olney, Texas. Previously channel 248C2 was deleted
from Olney and allotted to Archer City as that community's first local service in MM
Docket 97-225. The Report and Order was adopted September 23, 1998, was
released October 2, 1998, and became final November 17, 1998. Therefore, channel
248C2 does not exist at Olney, since MM Docket 97-225 is final with channel
248CI now allocated at Archer City. Due to the finality of this MM Docket, no
9 consideration is given to a substitute for channel 248C2 at Olney, since the channel
no longer exists.
III). AD249C3 - channel 249C3, Healdton, Oklahoma. The licensee of KOOK, channel
249C3 at Pauls Valley, Oklahoma, has been granted a petition for rule making
seeking the deletion of channel 249C3 at Pauls Valley and its subsequent allotment
at Healdton. A CP has been granted to modify the license ofKOOK. The allotment
ofchannel 248C at Keller will create a short space to channel 249C3 at Healdton of
74.70 kilometers. In The Joint Petitioners' counterproposal, the licensee of KOOK
is consenting to have its license modified to seek the deletion of channel 249C3 at
Healdton and allotted to Purcell, Oklahoma on channel 249A as a first local service.
Therefore, the short-spacing between channel 249C3 at Healdton and the allotment
ofchannel 248C at Keller will not exist, since channel 249A at Purcell and channel
248C at Keller are fully spaced.
A). KKAJ - channel 239Cl, Ardmore, Oklahoma. Currently KKAJ operates on
channel 239Cl licensed to Ardmore, Oklahoma. KKAJ is not MX with any ofthe
participants in The Joint Petitioners counterproposal. However, KKAJ is
modifying its license to specify Healdton, Oklahoma as its new community of
license to replace the service vacated by KOOK. The reference coordinates used
for KKAJ in the instant counterproposal are the same as those recently adopted in
MM Docket 98-198. No additional spectrum changes are required for the
allotment ofchannel 239Cl for channel 249C3 at Healdton.
IV-A).KWTX - channel 248C, Waco, Texas. Presently KWTX operates on channel
248C licensed to Waco, Texas. The allotment of channel 248C at Keller creates a
10 short-space to the licensed site of KWTX of 56.64 kilometers. The Joint Petitioners propose to eliminate this short-spacing by modifying the facilities of KWTX to operate on channel 225C2 with a change in reference coordinates. This substitution of channel 225C2 for channel 248C at Waco is a component only in Option II of the instant counterproposal and is to be considered if one ofthe elements can be granted while another element cannot. For a complete discussion of the relationships in
Option II, see the legal section of the instant counterproposal. In order to change from channel 248C to channel 225C2, the following spectrum change must occur.
A). KLRK -channel 225C2, Marlin, Texas. Presently KLRK, licensed to Marlin,
Texas, operates on channel 225A with a CP for channel 225C2 at a different site
from its licensed facility. The substitution ofchannel 225C2 for channel 248C at
Waco creates a short spacing to the CP site of KLRK at Marlin of 178.63
kilometers and a short-space to KLRK.L of 131.73 kilometers. The Joint
Petitioners propose to eliminate this short-space by substituting channel 248C2 at
the licensed site ofKLRK. This substitution is possible only ifKWTX substitutes
channel 225C2 for channel 248C. In addition, the allotment of channel 248C2 at
the licensed site of KLRK gives clear spacing to the proposed allotment site of
KLAK on channel 248C at Keller of5.65 kilometers. This substitution is directly
connected to the substitution ofchannel 225C2 for channel 248C at Waco. It also
is proposed only in Option II. All of the following components are to be
considered in Option I. The remaining facilities could be adopted independently
of the previously discussed upgrade scenario of KLAK and, vice-versa, KLAK
can be considered without the Option I elements.
II IV-B).KWTX - channel 248C, Waco, Texas. As discussed previously, the allotment of
channel 248C at Keller, Texas creates a short spacing of KWTX on channel 248C
of 56.64 kilometers. In order to eliminate this short space, the Joint Petitioners
propose the deletion ofchannel 248C at Waco and the allotment ofchannel 247Cl
at Lakeway, Texas as that community's first local service. This substitution gives
clearance to KLAK on channel 248C at Keller of 139.11 kilometers. The spacing
between the licensed facility of KWTX on channel 248C and the proposed
allotment ofchannel 247Cl at Lakeway is 120.89 kilometers. This creates a short
spacing of 88.11 kilometers that demonstrates the Joint Petitioners' allotment
proposal for KWTX is MX. However, in order to allocate channel 247Cl to
Lakeway for use by KWTX, additional changes must be made in the spectrum as
follows:
A). KAJA - channel 247C, San Antonio, Texas. Presently KAlA operates on channel
247C licensed to San Antonio, Texas. The allotment of channel 247Cl at
Lakeway creates a short spacing to KAJA of 144.05 kilometers. ·The Joint
Petitioners propose to eliminate this short spacing by substituting channel 245C1
for channel 247C at San Antonio for use by KAJA. This substitution also
requires a minor site modification.
1). KHFI - channel 244Cl, Georgetown, Texas. Presently KHFI operates on
channel 244C1. The substitution ofchannel 245C1 for channel 247C1 at San
Antonio creates a short spacing to KHFI of45.81 kilometers. In addition, the
proposed allotment of channel 247CI at Lakeway creates a short spacing to
KHFI on channel 244Cl of 79.37 kilometers. Deleting channel 244CI at
12 Georgetown and substituting channel 243C2 at Lago Vista, Texas (as that community's first local service) can eliminate both of these short spacings.
The substitution of channel 243C2 gives clearance to KAlA on channel
245Cl by 57.48 kilometers, while channel 243C2 is a fourth-adjacent to the proposed allotment of KWTX on channel 247CI at Lakeway, Texas.
Therefore, it is ofno concern. a). KBAE.C - channel 242A, Llano, Texas. Presently KBAE has a
construction permit on channel 242A licensed to Llano, Texas. The
substitution of channel 243C2 for channel 244Cl (KHFI) creates a short
spacing to Llano of 19.08 kilometers. This short spacing can be
eliminated by the substitution ofchannel 297A for channel 242A at Llano.
The substitution requires a minor site modification. This substitution
requires some additional subchanges.
i). KLFX - channel 297A, Nolanville, Texas. Presently KLFX operates
on channel 297A at Nolanville. It has an application on file for a 1.75
kilometers site change. If channel 297A is substituted for channel
242A at Llano, it creates a short spacing to Nolanville of 10.15
kilometers (8.40 kilometers if application site is used). This short
spacing can be eliminated by substituting channel 249A for channel
297A at either the licensed site or the application site of KLFX.
Channel 249A is available for substitution at Nolanville only after
channel 248C is deleted at Waco and allocated to Lakeway on channel
247Cl. The apparent short spacings to channel 249C2 at Mason are of
13 no concern, since this channel was deleted in MM Docket 99-357.
However, there is one subchange required for this allotment.
*). KVCQ - channel 249Cl, Mcqueeney, Texas. Previously channel
249C3 was deleted at Cuero, Texas and channel 249C1 was
allotted to Mcqueeney, Texas. At this point, KVCQ has not begun
broadcast operations at Mcqueeney on channel 249C1. If channel
249A is substituted for channel 297A at Nolanville, there is a short
spacing to Mcqueeney of 7.26 kilometers. This short spacing can
be eliminated by deleting channel 249C1 at Mcqueeney and
substituting channel 249Cl at Converse, Texas as that
community's first local service. This community oflicense change
will give clear spacing to Nolanville of 5.04 kilometers. Channel
249Cl at Converse can occur only after channel 247C is modified
to channel 245C1 at San Antonio. The distance between channel
249Cl at Mcqueeney and channel 249C1 at Converse is 79.95
kilometers, thereby creating a short spacing of 165.05 kilometers.
This is a an MX community oflicense change. b). RADD - channel 243A, Ingram, Texas. Currently channel 243A has been
allocated to Ingram, Texas. The substitution of channel 243C2 at Lago
Vista for channel 244C1 at Georgetown creates a short spacing to Ingram
of 29.35 kilometers. Substituting channel 256A for channel 243A at the
channel 243A allotment reference coordinates can eliminate this short
14
------_..__ .. _-_._------spacmg. Channel 256A is available for allotment at Ingram, since channel
256A was deleted at Camp Wood, Texas in MM Docket 99-214.
This completes the Table of Allotments' modifications required for the allocation of channel 248C at Keller.
EXHIBITS EXPLAINED
KLAK
Exhibit E, Figure 1 is an allocation study depicting the spacing to all known FM facilities that are affected by the allotment ofchannel 248C at Keller. The study depicts all ofthe major on-channel and adjacent channel modifications required, but not the subchanges.
Exhibit E, Figure 2 is a map generated using the programs and techniques in the Methods section of the instant counterproposal. This study depicts the KLAK channel 248C allotment coordinates, a maximum class C 70 dBu contour, and the community boundaries ofKeller. It demonstrates full compliance with §73.315 ofthe Rules. Exhibit
E, Figure 3 is a zoomed view of Exhibit E, Figure 2, showing the hypothetical 70 dBu contour and the city boundaries of Keller. Exhibit E, Figure 4 is a portion of the US
Census Bureau' TIGER map of the city boundaries of Keller. Exhibit E, Figure 5 is a map demonstrating the gain and loss area of the respective 60 dBu contours for KLAK.
Exhibit E, Figure 6 is a map depicting the remaining services in the loss area after KLAK is deleted at Durant and allocated to Keller. Exhibit E, Figure 7 is a list of the facilities included in Exhibit E, Figure 6. The numbers shown for the contours in Exhibit E,
Figure 6 correspond to the facilities in Exhibit E, Figure 7.
15 KRZB (AL248Cl)
Exhibit E, Figure 8 is an allocation study depicting the spacing to all known FM facilities
that are affected by the substitution ofchannel 230C1 for channel 248C1 at the allocation
coordinates ofKRZB, Archer City, Texas. The study depicts all ofthe major on-channel
and adjacent channel modifications required, but not the subchanges. Each change
required is discussed in the allocation study, as is the method The Joint Petitioners
propose to eliminate conflicts. The only potential conflict with the substitution of
channel 230Cl for channel 248Cl at Archer City is a possible PRM for channel 230C3 at
Windthorst, Texas.
KSEY (AL230C2 and AP230C2)
Exhibit E, Figure 9 is an allocation study depicting the spacing to all known FM facilities
that are affected by the substitution of channel 222C2 at Seymour, Texas with a site
restriction of4.84 kilometers. Exhibit E, Figure lOis a map showing the 70 dBu contour
for channel 222C2 and the community boundaries of Seymour. It verifies compliance
with §73.315 ofthe Commission's Rules and Regulations. Exhibit E, Figure 11 is a map
gain/loss study map, comparing the F(50,50) 60 dBu contour for channel 230C2 and the
hypothetical 60 dBu contour for the allotment ofchannel 222C2. Exhibit E, Figure 12 is
an allocation study for the substitution of channel 298C2 for channel 222C2 at the
allocated reference coordinates for channel 222C2. Exhibit E, Figure 13 is an allocation
study for the substitution of channel 257A for channel 297A at Knox City, Texas.
Exhibit E, Figure 14 is an allocation study for the substitution of channel 296C3 for channel 298C3 at Wellington, Texas.
16 KZCD
Exhibit E, Figure 15 is an allocation study depicting the spacing to all known FM facilities that are affected by the substitution of channel 232C2 for channel 231 C2 at
Lawton, Oklahoma. Presently KZCD operates on channel 231 C2. The proposed channel substitution requires a site change of 9.69 kilometers from its licensed site. This gives it a site restriction of 10.57 kilometers to the city ofLawton. Exhibit E, Figure 16 is a map showing the hypothetical 70 dBu contour for the proposed channel 232C2 substitution and the Lawton community boundaries. It demonstrates full compliance with §73.315 of the Rules. Exhibit E, Figure 17 is a map demonstrating the gain and loss area of the respective 60 dBu contours for KZCD.
KXOO
Exhibit E, Figure 18 is an allocation study depicting the spacing to all known FM facilities that are affected by the substitution ofchannel 233C3 for channel 232C3 at the licensed site of KXOO, Elk City, Oklahoma. The study shows that this proposed substitution is short spaced to the proposed allotment ofchannel 233C3 at Quanah, Texas by 22.61 kilometers. Therefore, this substitution is MX with the instant NPRM.
AD255C3
Exhibit E, Figure 19 is an allocation study showing the spacing of all pertinent FM facilities for the allotment of channel 255C3 in lieu of the NPRM channel of 233C3 at
Quanah, Texas. If channel 255C3 is used in lieu of channel 233C3, the second FM allotment at Quanah can be accommodated, while the MX between channel 233C3 at
Quanah and channel 233C3 at Elk City is eliminated. Both channel 233C3 and The Joint
17 Petitioners substitution of channel 255C3 used the community of Quanah's reference coordinates for the allotment.
KGOK
Exhibit E, Figure 20 is an allocation study for the substitution ofchannel 249A at Purcell,
Oklahoma after channel 249C3 is deleted at Healdton, Oklahoma. The allotment of channel 249A at Purcell is short spaced to channel 249C3 at Healdton by 76.22 kilometers. Therefore, The Joint Petitioners request for the allotment ofchannel 249A at
Purcell is MX with channel 249C3 at Healdton and is an MX community of license change. The study also includes the proposed allotment ofchannel 248C at Keller, Texas and demonstrates the two proposals are fully spaced by 1.76 kilometers.
Exhibit E, Figure 21 is a map showing the maximum class A hypothetical 70-dBu contour over the city oflicense (Purcell, Oklahoma). It shows the compliance ofchannel
249A at Purcell with §73.315 of the Commission's Rules. Exhibit E, Figure 22 is gain/loss study map for the licensed facility's F(50,50) 60 dBu contour and the proposed hypothetical 60 dBu contour. Exhibit E, Figure 23 is a map showing the remaining services that are provided to the loss area ofKGOK. Exhibit E, Figure 24 is a description ofthe facilities whose contours are shown in Exhibit E, Figure 23.
KKAJ
Exhibit E, Figure 25 is an allocation study for the allotment of KKAJ from Ardmore to
Healdton, Oklahoma as a replacement service, since the deletion of channel 249C3 at
Healdton (and its subsequent allotment to Purcell) would leave Healdton without a local service. Exhibit E, Figure 26 is a hypothetical 70 dBu contour map showing KKAJ's compliance with §73.315 of the Commission's rules as it pertains to the proposed
18 allotment to Healdton. Exhibit E, Figure 27 is a gain/loss study comparing the licensed
KKAJ 60 dBu contour to the proposed hypothetical class C2 60 dBu at Healdton. Exhibit
E, Figure 28 is a remaining services study showing that at least 5 services cover all points in the KKAJ loss area. Exhibit E, Figure 29 is a list of the stations in the remaining services study shown in Exhibit E, Figure 28.
KWTX COption II)
Exhibit E, Figure 30 is an allocation study showing all the spacings for the substitution of channel 225C2 for channel 248C at Waco, Texas (KWTX). It demonstrates that only one spectrum change is required for this substitution. Exhibit E, Figure 31 is a 70 dBu contour map, demonstrating that channel 225C2 at Waco complies with §73.315 of the
Rules. Exhibit E, Figure 32 is gain/loss study map for the licensed class C facility's
F(50,50) 60 dBu contour and the proposed hypothetical 60 dBu contour. Exhibit E,
Figure 33 is a remaining services study for the loss area ofKWTX. Exhibit E, Figure 34 is a list ofthe facilities used in the KWTX remaining services study.
KLRK
Exhibit E, Figure 35 is an allocation study for the substitution of channel 248C2 for channel 225C2 at Marlin, Texas. The study demonstrates that no additional changes are required for this substitution after KWTX moves from channel 248C to channel 225C2.
It demonstrates full spacing requirements to the allotment ofchannel 248C at Keller and gives 3.33 kilometers clearance. Exhibit E, Figure 35(a) is a map demonstrating a maximum class C3 70-dBu contour to the community boundaries ofMarlin. It shows full compliance with §73.315 of the Commission's Rules. Exhibit E, Figure 36 is gain/loss
19 study map for the CP facility's F(50,50) 60 dBu contour and the proposed hypothetical 60 dBu contour.
KWTX (Option 1)
Exhibit E, Figure 37 is an allocation study showing all the spacings for the substitution of channel 247Cl at Lakeway, Texas for channel 248C at Waco, Texas (KWTX). It demonstrates that only two spectrum changes are required for this substitution. However, it does not depict the subchanges required. Exhibit E, Figure 38 is a 70 dBu contour map, demonstrating that channel 247Cl at Lakeway complies with §73.3l5 of the Rules.
Exhibit E, Figure 39 is gain/loss study map for the licensed class C facility's F(50,50) 60 dBu contour and the proposed hypothetical 60 dBu contour. Exhibit E, Figure 40 is a remaining services study for the loss area ofKWTX. Exhibit E, Figure 41 is a list ofthe facilities used in the KWTX remaining services study.
KAJA
Exhibit E, Figure 42 is an allocation study showing all the spacings for the substitution of channel 245Cl for channel 247C at San Antonio, Texas (KAJA). It demonstrates that only one spectrum change is required for this substitution. However, it does not depict the subchanges required. Exhibit E, Figure 43 is a 70 dBu contour map, demonstrating that channel 247Cl at Lakeway complies with §73.3l5 of the Rules. Exhibit E, Figure
44 is gain/loss study map for the licensed class C facility's F(50,50) 60 dBu contour and the proposed hypothetical 60 dBu contour. Since KAJA is a minimal class C (100 kW at
300 meters HAAT) and a maximum class CI is being proposed, no gain/loss study is included. Exhibit E, Figure 45 is a maximum class Cl F(50,1O) 54 dBu contour map.
20 This exhibit shows that the proposed allocation of channel 245Cl does not produce prohibitive overlap with the Mexican border.
KHFI
Exhibit E, Figure 46 is an allocation study showing all the spacings for the substitution of channel 243C2 at Lago Vista, Texas for channel 244Cl at Georgetown, Texas (KHFI). It demonstrates that only two spectrum changes are required for this substitution. However, it does not depict the subchanges required. Exhibit E, Figure 47 is a 70 dBu contour map, demonstrating that channel 243C2 at Lago Vista complies with §73.3l5 of the Rules.
Exhibit E, Figure 48 is gain/loss study map for the licensed class Cl facility's F(50,50) 60 dBu contour and the proposed hypothetical 60 dBu contour. Exhibit E, Figure 49 is a remaining services study for the loss area of KHFI. Exhibit E, Figure 50 is a list of the facilities used in the KHFI remaining services study.
KBAE
Exhibit E, Figure 51 is an allocation study showing all the spacings for the substitution of channel 297A at Llano, Texas for channel 242A at Llano, Texas (KBAE). It demonstrates that only one spectrum change is required for this substitution. However, it does not depict the subchange required. Exhibit E, Figure 52 is a 70 dBu contour map, demonstrating that channel 297A at Llano complies with §73.315 of the Rules. Exhibit
E, Figure 53 is gain/loss study map for the CP class A facility's F(50,50) 60 dBu contour and the proposed hypothetical 60 dBu contour.
21 KLFX
Exhibit E, Figure 54 is an allocation study showing all the spacings for the substitution of channel 249A for channel 297A at Nolanville, Texas (KLFX). It demonstrates that only one spectrum change is required for this substitution.
KVCQ
Exhibit E, Figure 55 is an allocation study showing all the spacings for the substitution of channel 249Cl at Converse, Texas for channel 249Cl at Mcqueeney, Texas (KVCQ). It demonstrates that the spectrum changes required for this substitution have been effectuated by the previous changes of KAJA. Exhibit E, Figure 56 is a 70 dBu contour map, demonstrating that channel 249Cl at Converse complies with §73.3l5 ofthe Rules.
Exhibit E, Figure 57 is gain/loss study map for the licensed class C facility's F(50,50) 60 dBu contour and the proposed hypothetical 60 dBu contour. Exhibit E, Figure 58 is a remaining services study for the loss area of KVCQ. Exhibit E, Figure 59 is a list ofthe facilities used in the KVCQ remaining services study. Exhibit E, Figure 60 is a map demonstrating that the proposed F(50,1O) 54 dBu contour does not overlap the Mexican border, in compliance with international agreements.
The Joint Petitioners realize that precedent establishes the fact that a service removed from a community, and that service has never begun operations, it is not considered a loss of service to the community. This is the case with KVCQ at Mcqueeney. Channel
249Cl was placed at Mcqueeney in MM Docket 99-357, after it was deleted at Cuero.
An application for KVCQ compliance to the Report and Order in MM Docket 99-357 is currently being prepared. However, it will be several months before broadcast operations
22 can began at Mcqueeney. A final resolution in MM Docket 00-148 is expected before any deadlines for beginning operations at Mcqueeney.
However, if the Commission does determine that The Joint Petitioners cannot leave
Mcqueeney without service, the modification required of KVCQ in order to substitute channel 249A for channel 297A at Nolanville can be accomplished by modifying the reference coordinates for channel 249C 1. This modification would use the same reference as those proposed for channel 249Cl at Converse. KVCQ provides the required 70 dBu contour service to 100% of Mcqueeney from those reference coordinates. If channel 249C1 remains allotted to Mcqueeney and uses the same allotment reference coordinates as those proposed in the instant counterproposal, the map depicting the 54 dBu F(50,10) contour's relationship to the Mexican Border remains the same as that shown in Figure 60. Exhibit E, Figure 60A is an allocation study depicting clear spacing for channel 249C1 at Mcqueeney using the same reference as the study for the allotment ofchannel 249C1 to Converse. Exhibit E, Figure 60B is a 70 dBu contour map using the F(50,50) method ofpredicting the 70 dBu for a maximum class C1. This map depicts compliance with §73.315 ofthe Commission's Rules. Exhibit E, Figure 60C is a zoomed view of the KVCQ 70 dBu and the Mcqueeney community boundaries.
Exhibit E, Figure 60D is a tiger map of the Mcqueeney boundaries. As with option II,
The Joint Petitioners request that KVCQ remain allotted to Mcqueeney only if it cannot be allotted to Converse.
23
._ __..,._._-_. <'--'_ -- AD243
Exhibit E, Figure 61 is an allocation study showing all the spacings for the substitution of channel 256A for channel 243A at Ingram, Texas (AD243A). It demonstrates that no spectrum changes are required for this substitution.
The Joint Petitioners Counterproposal Gain-Loss Area
Exhibit E, Figure 62 is a tabulation ofthe gain/loss areas for each facility that requires an antenna location or class change. Stations that are proposed to have only their present channel substituted at their licensed site and require no class changes are omitted in this study. It is assumed that the service they would provide with a channel change would not deviate from their current coverage. In addition, the gain/loss totals are included according to the two divisions ofthe instant counterproposal discussed earlier.
The study includes ten facilities that have a deviation in their coverage area proposed by the instant counterproposal. Listed in the study is each station's loss and gain area in square kilometers and the population gains and losses in number ofpersons according to the U.S. Census Bureau's estimated 1999 population figures. It depicts a cumulative total loss area of 56,195 square kilometers and a gain area of 59,122 square kilometers. The
Joint Petitioners counterproposal has a net area gain of2,927 square kilometers.
The population loss has a cumulative loss of 1,076,211 persons, while the population gain is 5,446,202 persons. Therefore, the net population gain of The Joint Petitioners counterproposal is 4,369,991 persons.
Proposed Elimination ofShort-Space
The Joint Petitioners counterproposal, if adopted, will eliminate the following existing short-spaces between various stations:
24 1) KZCD.L to AL230C2, Seymour, TX 4.42km
2) KBAE.C to KXXM, San Antonio, TX 16.lOkm
3) KLFX.L to KWBU, Waco, TX 7.25km
Conclusion
The Joint Petitioners' counterproposal has demonstrated that it is in technical compliance with the present Commission Rules concerning such actions. The counterproposal produces five new first local services: Keller, Texas, a community of 13,683 persons,
Purcell, Oklahoma, a community of 4,784 persons; Lakeway, Texas, a community of
4,044 persons; Lago Vista, Texas, a community of2,199 persons; and Converse, Texas, a community of 8,887 persons, (all according to the 1990 US Census Bureau), and an upgrade ofKLAK to a full class C. In addition, the residents ofHealdton, Oklahoma will continue to be served by a local service (KKAJ), while Ardmore, Oklahoma will continue to receive local service from four local services. The counterproposal creates a net increase in new 60-dBu service to 2,927 square kilometers and 4,369,991 persons while eliminating three existing short spacings.
25 Statement ofthe Consultants
The instant engineering portion ofa counterproposal was prepared· for First Broadcasting
Co" L.P.; Next Media Licensing, Inc.; Capstar TX Limited P.artnership; Rawhide Radio,
LLC; and Clear Channel Broadcasting Licenses, Inc. ('The Joint Petitioners") and supports a counterproposal to MM Docket 00-148, RM-9939. It was developed by
Reynolds Technical Associates (RTA) and may not be used for purposes other than submission to th~ Commission by The Joint Petitjoners.
It may not be reproduced in its entirety, or in part, by anyone (other than from the
Commission) without the written consent ofRTA.
The information in this application is compiled from the most recent Commission and
outside data. RTA is not responsible for errors resulting from incorrect data or
unpublished rule and procedure changes.
For Reynolds Technical Associates: -v£:! .~I\f ~ Lee S. Reynolds
October ?!. 2000 2421- Presidents Drive, Suite B-23 Montgomery, Alabama 361.16 (334) 323·3620
••0/lOC,.., nc""lC.-.l COtltUlT"'lllS .
26 ENGINEERING STATEMENT In Support of a Counterproposal MM Docket 00-148
The Joint Petitioners
Summary of Channel Assignments
(Depicting all communities, channels, and modifications)
COMMUNITY PRESENT PROPOSED COMMENTS Keller, TX --- 248C Delete channel 248C2 at Durant, OK and change community of license to Keller, TX on Ch 248C as a first local service Durant, OK 248C2, 296A 296A Delete channel 248C2 at Durant, OK and Change community of license to Keller, TX on Ch. 248C Archer City TX 248C1 230C1 Delete Ch 248C1 and substitute Ch 230C1 at the current allotment site Seymour, TX 230C2 222C2 Delete Ch 230C2 and substitute Ch 222C2 at a new antenna site Seymour, TX 222C2 298C2 Delete Ch 222C2 and substitute Ch 298C2 at Ch 222C2 allotment coordinates Knox City, TX 297A 257A Delete Ch 297A and substitute Ch 257A at Ch 297A allotment coordinates. Wellington, TX 298C3 296C3 Delete Ch 298C3 and substitute Ch 296C3 at Ch 298C3 allotment coordinates. Lawton, OK 231C2, 237C3, 251C1, 258C3, 268C1, 232C2, 237C3, 251C1, 258C3, 268C1, Delete Ch 231C2 and substitute Ch 232C2 297C2 297C2 at a new antenna site Elk City, OK 232C3, 243C1, 253C 233C3, 243C1, 253C Delete Ch 232C3 and substitute Ch 233C3 at the current licensed site Quanah, TX 233C3, 265C2 255C3, 265C2 Substitute Ch 233C3 with Ch 255C3 at the same Reference Coordinates Healdton, OK U9C3 239C1 Delete Ch 249C3 and substitute Ch 239C1 at a new antenna site Purcell, OK -- 249A Delete Ch 249C3 at Healdton, OK and Change community of license to Purcell, OK on Ch 249A as a first local service Ardmore, OK 239C1,253C3 253C3 Delete Ch 239C1 at Ardmore, OK and Change community of license to Healdton, OK on 239C1
Continued on the next page
~ Table 1 fit. !~S~NI~REYNOLDS I I IIOADCAST TECHNICAL C;ONSULTANTS COMMUNITY PRESENT PROPOSED COMMENTS Waco, TX 233A, 239C2, 248C, 260C, 277A 225C2**, 233A, 239C2, 260C, 277A Delete Ch 248C and substitute Ch 225C2 'Ootion 2 only) 233A, 239C2, 260C, 277A** at a new antenna site for Option 2. Marlin, TX 225C2 248C2** Delete Ch 225C2 and substitute Ch 248C2 'Ootion 2 only) at a new antenna site (Option 2). Lakeway, TX ...... ----- 247C1* Delete Ch 248C at Waco, TX & allocate Ch 247C1 at Lakeway, TX as a first local service. San Antonio, TX 225C1,241C1,247C,258C, 262C, 225C1, 241C1, 245C1*, 258C, 262C, Substitute Ch 245C1 for Ch 247C at San 270C1,274C1,283C1,298C 270C1,274C1,283C1,298C Antonio with an antenna site chanoe. Georgetown, TX 244C1, 299C3 299C3 Delete Ch 244C1 at Georgetown and allocate Ch 243C2 at Lago Vista, TX as a first local service. Lago Vista, TX -----_.. 243C2* Delete Ch 244C1 at Georgetown and allocate Ch 243C2 at Lago Vista, TX as a first local service. Llano, TX 242A, 275A, 293C3 297A*, 275A,296C3 Delete Ch 242A and substitute Ch 297A at Llano with an antenna site chanoe. Nolanville, TX 297A 249A* Delete Ch 297A and substitute Ch 249A at Nolanville at both the application and the licensed site for Ch 297A. Mcqueeney, TX 249C1 .--* Delete Ch 249C1 at McQueeney. Because Ch 249C1 at McQueeney is an unused allotment for KVCQ, it can be deleted and reallocated without the need for a substitute channel at McQueenev. Live Oak, TX --- 249C1* Delete Ch 249C1 at McQueeney and allocate Ch 249C1 at Live Oak as a first local service. Ingram, TX 243A 256A* Substitute Ch 256A for Ch 243A at the allocation site of Ch 243A at Inoram, TX. Flatonia, TX 232A* Allocate Ch 232A to alleviate possible gray --- area issues with the deletion of Ch 249C1 at Mcaueeney.
* These changes to the Table ofAllotments are proposed only in Option 1. ** These changes to the Table of Allotments are proposed only in Option 2. Engineering Statement In Support of a Counterproposa1 MM Docket 00-148 The Joint Petitioners
Allocation Study - ch 248C Keller, TX (KLAK) [Depicting spectrum changes required to create clear spacing for Ch 248C] (Using proposed Ch 248C allotment coordinates as reference)
33 26 13 N. Class C Search Date 97 29 05 W. Current rules spacings 09-30-00 Channel 248 97.5 MHz ------Call Ch# City State Bear' Dist' R'qrd Margin
Community of Keller TX 156.8 61.15 Reference Coordinates: North Latitude: 32-55-49 West Longitude: 97-29-05 KLAK 248C2 Durant OK 73.7 100.75 249.0 -148.25 * Of No Concern: Licensed facility of KLAK RAnD 248C1 Archer City TX 278.9 128.84 270.0 -141.16 * Of Concern: Incorrect reference coordinates For allotment of Ch 248Cl at Archer City RAnD 248Cl Archer City TX 278.8 129.45 270.0 -140.55 * Of Concern: Correct allotment reference. Substitution of Ch 230C1 proposed at site. NL: 33-36-58, WL: 98-51-42 KRZB.C 248C2 Olney TX 293.6 117.70 249.0 -131.30 * Of No Concern: Previous allotment of Ch 248C2 before allotment to Archer City KGOKFM 249C3 Healdton OK 1.3 101.30 176.0 -74.70 * Of Concern: Deletion of Ch 249C3 at Healdton and allotment of Ch 249A at Purcell, OK proposed for KGOK. See Purcell below. RDEL 251A Bridgeport TX 231.0 37.46 95.0 -57.54 * Of No Concern: Incorrect database entry. Correct channel Allotment at Bridgeport is Ch 252A. KWTXFM 248C Waco TX 176.0 233.36 290.0 -56.64 * KWTXFM 248C Waco TX 176.1 235.07 290.0 -54.93 * Of Concern: Substitution of Ch 225C2 proposed with change in reference site. RAnD 248C1 Archer City TX 274.5 220.90 270.0 -49.10 * Of No Concern: Incorrect data base entry. Listed 0 0 As 99 longitude is lieu of 98 •
Continued on next page
I Exhibit E, Figure 1 Continued from previous page
Allocation Study - Ch 248C Keller, TX (KLAK) [Depicting spectrum changes required to create clear spacing for Ch 248C] (Using proposed Ch 248C allotment coordinates as reference)
33 26 13 N. Class C Search Date 97 29 05 W. Current rules spacings 09-30-00 Channel 248 97.5 MHz ------Call Ch# City State Bear' Dist' R'qrd Margin
KGOKFM 249C3 Pauls Valley OK 8.3 142.02 176.0 -33.98 * Of Note: Previous licensed facility of KGOK before allotment to Healdton. KEGL 246C Fort Worth TX 152.8 105.75 105.0 0.75 * KBFB 250C Dallas TX 152.8 105.93 105.0 0.93 * KGOK.P 249A Purcell OK 4.2 166.76 165.0 1.76 * Of Note: Proposed allotment of channel 249A in lieu of channel 249C3 at Healdton, OK Reference Coordinates: NL: 34-56-11, WL: 97-21-12 KATX.A 249A Eastland TX 226.3 166.91 165.0 1.91 * KATX 249A Eastland TX 226.3 166.91 165.0 1.91 * KWTX.P 248C2 Marlin TX 173.0 254.65 249.0 5.65 * Of Note: Substitution of Ch 248C2 for Ch 225C2 Marlin, TX in Option II at NL: 31-09-27, WL: 97-09-22 KDDQ 246A Comanche OK 340.3 117.75 95.0 22.75 RAnD 246A Duncan OK 339.5 127.33 95.0 32.33
KLFX.P 249A Nolanville TX 182.0 259.97 165.0 94.97 Of Note: Substitution of Ch 249A for Ch 297A KLFX proposed in instant Counterproposal. KLFX.A as reference KWTX.P 247Cl Lakeway TX 202.6 320.7 209.0 111.07 Of Note: Allotment to Lakeway proposed in Option I of instant counterproposal at, NL: 30-18-27, NL: 97-46-46
I Exhibit E, Figure 1 I @) REYNOLDS ~ TECHNiCAl-_-_0. __ - C' 0' ,{,
.....~
\,. AD248C (KLAK.P) Keller, TX 70 dBu Contour ~ The Joint Petitioners i~i;lj """F~;'" ._•..•_ i;J '; ,.".,"-.~'"'' ( _ I·_t··, . i I '\ T\ _.- t7 . \ 1\ "". I
\ ... Clay I. I \ "'. I Cooke .L"::;; \ ~\ Montague 'Q···k ~. ." ~'I "~"', \ I ...•.....0.--._ . e,.fl" ~ ." ' , ' . l" [ : HypotheticalConto~------.:. 70 dBu ------\\ L \ I ''\ r--- ~~ I \ \ \ \ (AP248C) \" \ 33-26-13 ''\ wi':' \ 97-29-05 ~ i 1\1 !g I "" Jl~,...... \~ _.~._ -"-,,_ i ""', ',...... I .. - __ _.. __ e9 1 . '\ ' ..8' ------.- '---"-"""'" .•~I{)J}:( .\ X...... _4 -, ....",." . \ '.,'- , 'i;jf' i ~ I Wise tI ~,~ ~Iert ~ l '\ F"1 (" City.. tt ~ U4~ ill .-LImits T ; __ J-- -- _~1l~ I -~ () ~ 1iQ. ~= PaloPituo N 1:=:=1 ,--_"". ~ REYNOLDS I o 15 30 TECHNICAL \ ASSOC'ATES Kilometen I UOAOCA$T TfCHNICA\ CO'-'5UlTANTS ) AD248C (KLAK.P) Keller, TX 70 dBu Contour (Zoomed) ~ The Joint Petitioners
• I I J
,.tr:l ~ ~ ri ~ ~ REYNOLDS TECHNICAL ASSOC'ATIS "OAOCAST T1ECHNICAl CO"lSUlTANTS