Engineering Statement CONFLICT RESOLUTION KLFY-DT LAFAYETTE, LOUISIANA WAFB-DT BATON ROUGE, LOUISIANA prepared for KLFY, L.P. This statement has been prepared to provide certain “public interest” data on behalf of KLFY, L.P. KLFY, L.P. is the licensee of television station KLFY-TV, Facility ID 35059, Lafayette, LA. KLFY-TV operates on NTSC (analog) Channel 10 and digital (DTV) Channel 56. In its first- round channel election filing (BFRECT-20050210AAY), KLFY, L.P. elected KLFY-TV’s NTSC Channel 10 for final DTV operation. A letter from the Commission June 7, 2005 advised that the election of Channel 10 would cause interference in excess of 0.1 percent to the election by WAFB(TV) (Baton Rouge, LA) of its NTSC Channel 9. The Commission’s analysis indicates that 3.4 percent additional interference would be caused to WAFB’s elected Channel 9. Additionally, the WAFB election of its NTSC Channel 9 would cause 8.8 percent interference to the KLFY-TV Channel 10 election, thus generating a conflict letter to WAFB as well. An interference acceptance agreement has been developed between these stations in order for the conflicted elections of KLFY-TV and WAFB to proceed. This statement provides public interest data regarding the acceptance of interference for each station. A recent FCC Public Notice1 listed various factors which should be addressed concerning public interest matters. The resulting situation for KLFY-TV and WAFB’s proposed operation on their NTSC channels is summarized in the following. KLFY-TV and WAFB are addressed in separate sections. 1 “DTV Channel Election: First Round Conflict Decision Extension and Guidelines for Interference Conflict Analysis, Public Notice, DA 05-2233, August 2, 2005. Cavell, Mertz & Davis, Inc. Engineering Statement CONFLICT RESOLUTION KLFY-DT LAFAYETTE, LOUISIANA WAFB-DT BATON ROUGE, LOUISIANA (page 2 of 6) Section One --- KLFY-DT The amount that the proposal exceeds the 0.1% interference level (KLFY-DT): The proposed WAFB-DT facility as elected will create additional interference to KLFY-DT affecting a population of 100,656 persons, which is 8.83 percent of the KLFY-DT baseline population of 1,139,772 according to OET Bulletin 69 analysis2. The remaining interference-free service population is 1,039,116 persons. This determination is pursuant to the FCC’s channel election conflict method, which considers interference from existing NTSC stations regardless of whether the NTSC station will vacate its channel post-transition. The cumulative level of interference that would be received by the affected station (KLFY-DT): No other additional interference is contemplated under the agreement with any other station, beyond the 8.83 percent as proposed in the agreement. Considering only the incoming interference from nearby stations based on current channel election results (omitting all NTSC station interference), the KLFY-DT interference-free population is 1,049,077. This is 92.04 percent of the KLFY-DT baseline population of 1,139,772 which implies a cumulative interference level of 7.96 percent. The OET Bulletin 69 results are summarized in the following, including a list of the interfering DTV facilities (only WAFB-DT is predicted to cause interference to KLFY-DT). 2 FCC Office of Engineering and Technology Bulletin number 69, Longley-Rice Methodology for Evaluating TV Coverage and Interference, February 6, 2004 (“OET-69”). The implementation of OET-69 for this study followed the guidelines of OET-69 as specified therein. A standard cell size of 2 km was employed with 2000 Census data. Comparisons of various results of this computer program (run on a Sun processor) to the Commission’s implementation of OET-69 show excellent correlation. Cavell, Mertz & Davis, Inc. Engineering Statement CONFLICT RESOLUTION KLFY-DT LAFAYETTE, LOUISIANA WAFB-DT BATON ROUGE, LOUISIANA (page 3 of 6) Results for: 10A LA LAFAYETTE USERRECORD01 APP HAAT 506.0 m, ATV ERP 17.2 kW POPULATION AREA (sq km) within Noise Limited Contour 1189526 39365.1 not affected by terrain losses 1189311 39349.0 lost to NTSC IX 0 0.0 lost to additional IX by ATV 140234 264.8 lost to ATV IX only 140234 264.8 lost to all IX 140234 264.8 Potential Interfering Stations Included in above Scenario 1 9A LA BATON ROUGE USERRECORD02 APP The availability of an in-core digital channel that the licensee could use for digital operations in lieu of its NTSC channel (KLFY-DT): KLFY-TV’s DTV Channel 56 is NOT within the core. The proposed use of KLFY-TV’s NTSC Channel 10 would permit KLFY-DT to employ the transmitting facilities associated with its long-established NTSC Channel 10. Where the interference occurs (e.g., whether it is outside the affected station’s DMA) (KLFY-DT): The attached Figure 1 depicts the location of the proposed additional interference to KLFY-DT Channel 10 attributable to WAFB-DT Channel 9. None of the interference occurs over Lafayette, KLFY-DT’s principal community. All of the interference is beyond KLFY-DT’s DMA (Lafayette, LA) and within that of an adjacent market (Baton Rouge, LA DMA). The area of predicted interference is fairly small and located along the edge of KLFY-DT’s service contour in a densely populated area where the service contour skims over the city of Baton Rouge. Since the FCC’s interference limit is based upon population, the 0.1% limit is quickly exceeded in such a case. The number of remaining services to the population in the loss area (KLFY-DT): Figure 1 also depicts the alternate station service contours which overlap the area subject to interference. As shown thereon, at least 6 other digital television stations will provide service to all of the KLFY-DT interference area, with portions of the area within 9 station contours. KLFY-TV and WAFB are both CBS network affiliates, and WAFB-DT will provide CBS network service to Cavell, Mertz & Davis, Inc. Engineering Statement CONFLICT RESOLUTION KLFY-DT LAFAYETTE, LOUISIANA WAFB-DT BATON ROUGE, LOUISIANA (page 4 of 6) the KLFY-DT interference area. The contours are based on the facilities as “certified” by each station on FCC Form 381. Any other relevant public interest considerations (KLFY-DT): The proposed KLFY-DT Channel 10 service population (considering WAFB-DT’s additional interference) of 1,039,116 exceeds the present interference-free service population achieved by the existing analog KLFY-TV Channel 12 facility. The present analog KLFY-TV facility’s interference- free service population is 862,014. Even with interference from WAFB-DT Channel 9, the proposed KLFY-DT Channel 10 service population is an increase of 20.6 percent over the present analog facility population (i.e., a 120.6 percent match of the present analog Channel 10 operation). Section Two --- WAFB-DT The amount that the proposal exceeds the 0.1% interference level (WAFB-DT): The proposed KLFY-DT facility as elected will create additional interference to WAFB-DT affecting a population of 28,772 persons, which is 3.37 percent of the WAFB-DT baseline population of 854,752 according to OET Bulletin 69 analysis. The remaining interference-free service population is 825,980 persons. This determination is pursuant to the FCC’s channel election conflict method, which considers interference from existing NTSC stations regardless of whether the NTSC station will vacate its channel post-transition. The cumulative level of interference that would be received by the affected station (WAFB-DT): No other additional interference is contemplated under the agreement with any other station, beyond the 3.37 percent as proposed in the agreement. Considering only the incoming interference from nearby stations based on current channel election results (omitting all NTSC station interference), the interference-free population is 826,224. This is 96.66 percent of the WAFB-DT Cavell, Mertz & Davis, Inc. Engineering Statement CONFLICT RESOLUTION KLFY-DT LAFAYETTE, LOUISIANA WAFB-DT BATON ROUGE, LOUISIANA (page 5 of 6) baseline population of 854,752 which implies a cumulative interference level of 3.34 percent. The OET Bulletin 69 results are summarized below, including a list of the interfering DTV facilities. Results for: 9A LA BATON ROUGE USERRECORD02 APP HAAT 145.0 m, ATV ERP 3.2 kW POPULATION AREA (sq km) within Noise Limited Contour 859169 16287.3 not affected by terrain losses 859139 16235.2 lost to NTSC IX 0 0.0 lost to additional IX by ATV 32915 633.1 lost to ATV IX only 32915 633.1 lost to all IX 32915 633.1 Potential Interfering Stations Included in above Scenario 1 9A AL MOBILE BMPCDT 20041026ADT CP 10A LA LAFAYETTE USERRECORD01 APP The availability of an in-core digital channel that the licensee could use for digital operations in lieu of its NTSC channel (WAFB-DT): WAFB’s DTV Channel 46 is within the core. The proposed use of WAFB’s NTSC Channel 9 would make Channel 46 available in the region for another station’s subsequent election or future use by new entrants, while permitting WAFB to employ the transmitting facilities associated with its long-established NTSC Channel 9. Where the interference occurs (e.g., whether it is outside the affected station’s DMA) (WAFB-DT): The attached Figure 2 depicts the location of the proposed additional interference to WAFB-DT Channel 9 attributable to KLFY-DT Channel 10. None of the interference occurs over Baton Rouge, WAFB-DT’s principal community. All of the interference is beyond WAFB-DT’s DMA (Baton Rouge, LA) and within that of an adjacent market (Lafayette, LA DMA). The area of predicted interference is located along the edge of WAFB-DT’s service contour. The number of remaining services to the population in the loss area (WAFB-DT): Figure 2 also depicts the alternate station service contours which overlap the area subject to interference.