Federal Communications Commission
Washington, D.C. 20554
Approved by OMB
3060-0027 (July 2011)
FCC 301
FOR FCC USE ONLY
 
APPLICATION FOR CONSTRUCTION PERMIT FOR COMMERCIAL BROADCAST STATION

Read INSTRUCTIONS Before Filling Out Form

FOR COMMISSION USE ONLY
FILE NO.

BP - 20131021AFX
Section I - General Information
1. Legal Name of the Applicant
RADIO FIESTA NETWORK, LLC
Mailing Address
4887 MELROSE AVENUE

City
LOS ANGELES
State or Country (if foreign address)
CA
ZIP Code
90029 -
Telephone Number (include area code)
3234620903
E-Mail Address (if available) 
ASTALIS@AOL.COM
FCC Registration Number:
0016101958
Call Sign 
KFIR
Facility ID Number
23024
2. Contact Representative (if other than Applicant)
J. DOMINIC MONAHAN
Firm or Company Name
LUVAAS COBB
Mailing Address
POST OFFICE BOX 10747

City
EUGENE
State or Country (if foreign address)
OR
ZIP Code
97440 - 2747
Telephone Number (include area code)
5414849292
E-Mail Address (if available)
DMONAHAN@LUVAASCOBB.COM
3. If this application has been submitted without a fee, indicate reason for fee exemption (see 47 C.F.R. Section 1.1114):
Governmental Entity Other AMENDMENT
N/A (Fee Required)
4.
Application Purpose
New station New Station with Petition for Rulemaking or Counterproposal to Amend FM Table of Allotments
Major Modification of construction permit Major Change in licensed facility
Minor Modification of construction permit Minor Change in licensed facility
Major Amendment to pending application Minor Amendment to pending application
(a) 
File number of original construction permit:

BP-20131021AFX NA
(b) 
Service Type:

AM FM
(c) Community of License:
City: SWEET HOME

State: OR

 (d) Facility Type

Main Auxiliary
If an amendment, submit as an Exhibit a listing by Section and Question Number the portions of the pending application that are being revised. [Exhibit 1]



NOTE: In addition to the information called for in this section, an explanatory exhibit providing full particulars must be submitted for each question for which a "No" response is provided.

Section II - Legal

1. Certification.  Applicant certifies that it has answered each question in this application based on its review of the application instructions and worksheets. Applicant further certifies that where it has made an affirmative certification below, this certification constitutes its representation that the application satisfies each of the pertinent standards and criteria set forth in the application instructions and worksheets. Yes No
2. Parties to the Application.
a. List the applicant, and, if other than a natural person, its officers, directors, stockholders with attributable interests, non-insulated partners and/or members. If a corporation or partnership holds an attributable interest in the applicant, list separately its officers, directors, stockholders with attributable interests, non-insulated partners and/or members. Create a separate row for each individual or entity. Attach additional pages if necessary.

(1)   Name and address of the applicant and each party to the application holding an attributable interest (if other than individual also show name, address and citizenship of natural person authorized to vote the stock or holding the attributable interest). List the applicant first, officers next, then directors and, thereafter, remaining stockholders and other entities with attributable interests, and partners. (2)   Citizenship.
(3)   Positional Interest: Officer, director, general partner, limited partner, LLC member, investor/creditor attributable under the Commission's equity/debt plus standard, etc.
(4)   Percentage of votes.
(5)   Percentage of total assets (equity plus debt).

[Enter Parties/Owners Information]


Parties to the Application

List the applicant, and, if other than a natural person, its officers, directors, stockholders with attributable interests, non-insulated partners and/or members. If a corporation or partnership holds an attributable interest in the applicant, list separately its officers, directors, stockholders with attributable interests, non-insulated partners and/or members. Create a separate row for each individual or entity. Attach additional pages if necessary.
(1) Name and address of the applicant and each party to the application holding an attributable interest (if other than individual also show name, address and citizenship of natural person authorized to vote the stock or holding the attributable interest). List the applicant first, officers next, then directors and, thereafter, remaining stockholders and other entities with attributable interests, and partners.
(2) Citizenship.
(3)
Positional Interest: Officer, director, general partner, limited partner, LLC member, investor/creditor attributable under the Commission's equity/debt plus standard, etc.
(4) Percentage of votes.
(5)
Percentage of total assets (equity plus debt).

(1) Name and Address (2) Citizenship (3) Positional Interest (4) Percentage of Votes (5) Percentage of Assets
RADIO FIESTA NETWORK, LLC, 4887 MELROSE AVENUE, LOS ANGELES, CA 90029
US
LICENSEE
0
0

(1) Name and Address (2) Citizenship (3) Positional Interest (4) Percentage of Votes (5) Percentage of Assets
MICHAEL ASTALIS, 4887 MELROSE AVENUE, LOS ANGELES, CA 90029
US
LC/LLC/PLLC MEMBER
100
100



b. Applicant certifies that equity and financial interests not set forth above are non-attributable.
Yes No
N/A
See Explanation in
[Exhibit 2]
3. Other Authorizations. List call signs, locations, and facility identifiers of all other broadcast stations in which applicant or any party to the application has an attributable interest. N/A

[Exhibit 3]

4. Multiple Ownership.
a. Is the applicant or any party to the application the holder of an attributable radio joint sales agreement or an attributable radio or television time brokerage agreement in the same market as the station subject to this application?

If "YES," radio applicants must submit as an Exhibit a copy of each such agreement for radio stations.

Yes No

[Exhibit 4]

b. Applicant certifies that the proposed facility complies with the Commission's multiple ownership rules and cross-ownership rules.

Radio applicants only: If "Yes," submit an Exhibit providing information regarding the market, broadcast station(s), and other information necessary to demonstrate compliance with 47 C.F.R. § 73.3555(a).

All Applicants: If "No," submit as an Exhibit a detailed explanation in support of an exemption from, or waiver of, 47 C.F.R. § 73.3555.

Yes No


[Exhibit 5]

c. Applicant certifies that the proposed facility:
(1) does not present an issue under the Commission's policies relating to media interests of immediate family members;
(2)  complies with the Commission's policies relating to future ownership interests; and
(3)  complies with the Commission's restrictions relating to the insulation and non-participation of non-party investors and creditors.

Yes No
See Explanation in
[Exhibit 6]

d.
Does the Applicant claim status as an "eligible entity," that is, an entity that qualifies as a small business under the Small Business Administration's size standards for its industry grouping (as set forth in 13 C.F.R. § 121-201), and holds:
(1)  30 percent or more of the stock or partnership interests and more than 50 percent of the voting power of the corporation or partnership that will own the media outlet; or
(2)  15 percent or more of the stock or partnership interests and more than 50 percent of the voting power of the corporation or partnership that will own the media outlet, provided that no other person or entity owns or controls more than 25 percent of the outstanding stock or partnership interests; or
(3) more than 50 percent of the voting power of the corporation that will own the media outlet (if such corporation is a publicly traded company)?
All applicants: If "Yes," submit as an Exhibit a detailed showing demonstrating proof of status as an eligible entity.

Yes No
See Explanation in
[Exhibit 7]

5. Character Issues. Applicant certifies that neither applicant nor any party to the application has or has had any interest in or connection with:
a. any broadcast application in any proceeding where character issues were left unresolved or were resolved adversely against the applicant or party to the application; or
b. any pending broadcast application in which character issues have been raised.
Yes No

See Explanation in
[Exhibit 8]
6. Adverse Findings. Applicant certifies that, with respect to the applicant and any party to the application, no adverse finding has been made, nor has an adverse final action been taken by any court or administrative body in a civil or criminal proceeding brought under the provisions of any law related to any of the following: any felony; mass media-related antitrust or unfair competition; fraudulent statements to another government unit; or discrimination. Yes No

See Explanation in
[Exhibit 9]

7. Alien Ownership and Control. Applicant certifies that it complies with the provisions of Section 310 of the Communications Act of 1934, as amended, relating to interests of aliens and foreign governments. Yes No

See Explanation in
[Exhibit 10]

8. Program Service Certification. Applicant certifies that it is cognizant of and will comply with its obligations as a commission licensee to present a program service responsive to the issues of public concern facing the station's community of license and service area. Yes No
9. Local Public Notice. Applicant certifies that it has or will comply with the public notice requirements of 47 C.F.R. Section 73.3580. Yes No
10. Auction Authorization. If the application is being submitted to obtain a construction permit for which the applicant was the winning bidder in an auction, then the applicant certifies, pursuant to 47 C.F.R. Section 73.5005(a), that it has attached an exhibit containing the information required by 47 C.F.R. Sections 1.2107(d), 1.2110(i), 1.2112(a) and 1.2112(b), if applicable.

An exhibit is required unless this question is inapplicable.

Yes No
N/A

[Exhibit 11]

11. Anti-Drug Abuse Act Certification. Applicant certifies that neither applicant nor any party to the application is subject to denial of federal benefits pursuant to Section 5301 of the Anti-Drug Abuse Act of 1988, 21 U.S.C. Section 862. Yes No
12. Equal Employment Opportunity (EEO). If the applicant proposes to employ five or more full-time employees, applicant certifies that it is filing simultaneously with this application a Model EEO Program Report on FCC Form 396-A. Yes No
N/A
13. Petition for Rulemaking/Counterproposal to Add New FM Channel to FM Table of Allotments. If the application is being submitted concurrently with a Petition for Rulemaking or Counterproposal to Amend the FM Table of Allotments (47 C.F.R. section 73.202) to add a new FM channel allotment, petitioner/counter-proponent certifies that, if the FM channel allotment requested is allotted, petitioner/counter-proponent will apply to participate in the auction of the channel allotment requested and specified in this application. Yes No
N/A
14. Tribal Priority - Threshold Qualifications. Is the Applicant applying for an FM allotment set forth in a Public Notice announcing a Tribal Threshold Qualifications window? An Applicant answering "Yes" must provide an Exhibit demonstrating that it would have been qualified to add the allotment for which it is applying using the Tribal Priority. Yes No
N/A

[Exhibit 12]

I certify that the statements in this application are true, complete, and correct to the best of my knowledge and belief, and are made in good faith. I acknowledge that all certifications and attached Exhibits are considered material representations. I hereby waive any claim to the use of any particular frequency as against the regulatory power of the United States because of the previous use of the same, whether by license or otherwise, and request an authorization in accordance with this application. (See Section 304 of the Communications Act of 1934, as amended.)

Typed or Printed Name of Person Signing
MICHAEL ASTALIS
Typed or Printed Title of Person Signing
MEMBER
Signature
Date
03/07/2014

WILLFUL FALSE STATEMENTS ON THIS FORM ARE PUNISHABLE BY FINE AND/OR IMPRISONMENT (U.S. CODE, TITLE 18, SECTION 1001), AND/OR REVOCATION OF ANY STATION LICENSE OR CONSTRUCTION PERMIT (U.S. CODE, TITLE 47, SECTION 312(a)(1)), AND/OR FORFEITURE (U.S. CODE, TITLE 47, SECTION 503).



SECTION III-A - AM Engineering

TECHNICAL SPECIFICATIONS
Ensure that the specifications below are accurate. Contradicting data found elsewhere in this application will be disregarded. All items must be completed. The response "on file" is not acceptable.
TECH BOX
1. Frequency: 720  kHz
2. Class (select one):
A B C D
3. Hours of Operation:
Unlimited Limited Daytime Share Time Specified Hours:
4. Daytime: Yes No
[Daytime Operation]

4. Daytime Operation

a. Power: 10 kW

b. Antenna Location Coordinates: (NAD 27)

Latitude:
Degrees 44 Minutes 35 Seconds 43 North South

Longitude:
Degrees 123 Minutes 7 Seconds 34 West East

c. and d.

Complete the appropriate following items. If additional space is needed, please provide the information requested below in an Exhibit.

[Exhibit 24]

Nondirectional Directional

Theoretical RMS: 277.68  mV/m per kW at 1 km (Nondirectional)
 mV/m at 1 km (Directional)
   

Standard RMS:     

 mV/m at 1 km (Directional Only)


[Nondirectional Tower Subform]

4c. Nondirectional Tower:

Tower Number
Overall height above ground
(include obstruction lighting)
(meters)
84.7  
Antenna structure registration Number: 1034993
Notification filed with FAA
Not Applicable
Is this tower: (a) Top-loaded
(b) Sectionalized
(c) Neither

Height of radiator above
base insulator, or above base,
if grounded (meters)

82.8  

Electrical height of radiator (degrees)

71.6  

Top-Loaded/Sectionalized
apparent height (degrees)

 

A

 

B

 

C

 

D

 

         or

[Directional Towers Subform]



Augmented: Yes No

If "yes," complete the following:

Augmented RMS: mV/m at 1 km

[Augmentations Subform]




5. Nighttime: Yes No
[Nighttime Operation]

5. Nighttime Operation

a. Power: 0.146  kW

b. Antenna Location Coordinates: (NAD 27)

Latitude:
Degrees 44 Minutes 35 Seconds 43     North South

Longitude:
Degrees 123 Minutes 7 Seconds 34     West East

c. and d.

Complete the appropriate following items. If additional space is needed, please provide the information requested below in an Exhibit.

[Exhibit 25]

Nondirectional Directional

Theoretical RMS: 277.68  mV/m per kW at 1 km (Nondirectional)
 mV/m at 1 km (Directional)
   

Standard RMS:     

 mV/m at 1 km (Directional Only)


[Nondirectional Tower Subform]

5c. Nondirectional Tower:

Tower Number
Overall height above ground
(include obstruction lighting)
(meters)
84.7  
Antenna structure registration Number: 1034993
Notification filed with FAA
Not Applicable
Is this tower: (a) Top-loaded
(b) Sectionalized
(c) Neither

Height of radiator above
base insulator, or above base,
if grounded (meters)

82.8  

Electrical height of radiator (degrees)

71.6  

Top-Loaded/Sectionalized
apparent height (degrees)

 

A

 

B

 

C

 

D

 

         or

[Directional Towers Subform]



Augmented: Yes No

If "yes," complete the following:

Augmented RMS:  mV/m at 1 km

[Augmentations Subform]




6. Critical Hours Operation: Yes No
[Critical Hours Operation]


 
NOTE: In addition to the information called for in this section, an explanatory exhibit providing full particulars must be submitted for each question for which a "No" response is provided.
CERTIFICATION
7. Broadcast Facility.    The proposed facility complies with the engineering standards and assignment requirements of requirements of 47 C.F.R. Sections 73.24(e), 73.24(g), 73.33, 73.45, 73.150, 73.152, 73.160, 73.182(a)-(i), 73.186, 73.189, 73.1650. Exhibit Required

Yes No


See Explanation in
[Exhibit 13]

8. Community Coverage.    The proposed facility complies with community coverage requirements of 47 C.F.R. Section 73.24(i).

Yes No


See Explanation in
[Exhibit 14]

9. Main Studio Location.    The proposed main studio location complies with requirements of 47 C.F.R. Section 73.1125.

Yes No


See Explanation in
[Exhibit 15]

10. Interference.    The proposed facility complies with all of the following applicable rule sections. Check all those that apply. An exhibit is required for each applicable section. Yes No


See Explanation in
[Exhibit 16]

Groundwave.
a.)      47 C.F.R. Section 73.37.

[Exhibit 17]
Skywave.
b.)      47 C.F.R. Section 73.182.

[Exhibit 18]
Critical Hours.
c.)      47 C.F.R. Section 73.187.

[Exhibit 19]
 
11. Environmental Protection Act.    The proposed facility is excluded from environmental processing under 47. C.F.R. Section 1.1306 (i.e., The facility will not have a significant environmental impact and complies with the maximum permissible radiofrequency electromagnetic exposure limits for controlled and uncontrolled environments). Unless the applicant can determine compliance through the use of the RF worksheets in Appendix A, an Exhibit is required.

By checking "Yes" above, the applicant also certifies that it, in coordination with other users of the site, will reduce power or cease operation as necessary to protect persons having access to the site, tower or antenna from radiofrequency electromagnetic exposure in excess of FCC guidelines.
Yes No


See Explanation in
[Exhibit 20]

12. Community of License Change - Section 307(b). If the application is being submitted to change the facility's community of license, then the applicant certifies that it has attached an exhibit containing information demonstrating that the proposed community of license change constitutes a preferential arrangement of station assignments under Section 307(b) of the Communications Act of 1934, as amended (47 U.S.C. Section 307(b)).

An exhibit is required unless this question is not applicable.

Yes No
N/A

[Exhibit 21]
13.
Dispositive Section 307(b) Preference.
  a. Was the AM facility that is the subject of this application awarded on the basis of a dispositive Section 307(b) preference? Yes No
b. If yes to 13(a), applicant certifies that: (i) the community of license proposed in the subject application is the same as that on which the Section 307(b) preference was based, or (ii) as shown in the attached Exhibit, the service area proposed in the subject application is substantially equivalent to the service area on which the Section 307(b) preference was based. Yes No
N/A

See Explanation in
[Exhibit 22]

c. If yes to 13(a) and no to 13(b), applicant certifies that, although in the subject application it proposes to: (i) change the community of license, or (ii) modify service to the area on which the Section 307(b) preference was based, it has for a period of four years of on-air operations: (1) served the community of license, or (2) provided full service to the area on which the Section 307(b) preference was based. Yes No

See Explanation in
[Exhibit 23]

PREPARERS CERTIFICATION ON PAGE 3 MUST BE COMPLETED AND SIGNED.



SECTION III - PREPARER'S CERTIFICATION

I certify that I have prepared Section III (Engineering Data) on behalf of the applicant, and that after such preparation, I have examined and found it to be accurate and true to the best of my knowledge and belief.

Name
WAYNE S. REESE
Relationship to Applicant (e.g., Consulting Engineer)
CONSULTING ENGINEER
Signature
Date
03/07/2014
Mailing Address
MUNN-REESE, INC.
P. O. BOX 220
City
COLDWATER
State or Country (if foreign address)
MI
Zip Code
49036 -0220
Telephone Number (include area code)
5172787339
E-Mail Address (if available)
WAYNE@MUNN-REESE.COM

WILLFUL FALSE STATEMENTS ON THIS FORM ARE PUNISHABLE BY FINE AND/OR IMPRISONMENT (U.S. CODE, TITLE 18, SECTION 1001), AND/OR REVOCATION OF ANY STATION LICENSE OR CONSTRUCTION PERMIT (U.S. CODE, TITLE 47, SECTION 312(a)(1)), AND/OR FORFEITURE (U.S. CODE, TITLE 47, SECTION 503).



Exhibits
Exhibit 1
Description:
AMENDMENT CHANGES

THIS AMENDMENT IS BEING FILED TO ANSWER THE FCC LETTER OF JANUARY 8, 2014 THAT A PRELIMINARY REVIEW OF THE APPLICATION REVEALED THAT THE PROPOSED 0.25 MV/M 10% SKYWAVE CONTOUR OF KFIR OVERLAPS THE 0.5 MV/M GROUNDWAVE CONTOUR OF FIRST ADJACENT CHANNEL CLASS A STATION KIRO(AM), SEATTLE, WA. THE PROPOSED CHANGE IS TO REDUCE THE NIGHTTIME POWER FROM 225 WATTS TO 146 WATTS. WITH THIS CHANGE, THE FOLLOWING CHANGES HAVE BEEN MADE.

SECTION III-A TECH BOX QUESTION 5(A)---0.146 KW
SECTION III-A TECH BOX QUESTION 7 - CHECKED BOX 'NO', WAIVER REQUEST
DISCUSSION OF ENGINEERING EXHIBITS AND EXHIBITS 13.4 AND 13.6
SECTION III-A TECH BOX QUESTION 10(B) --- EXHIBITS 18.1-18.2 AND ADDITION OF EXHIBIT 18.3
SECTION III-A TECH BOX QUESTION 11 - EXHIBIT 20.1

Attachment 1


Exhibit 5
Description:
MULTIPLE OWNERSHIP SHOWING

STATION KFIR(AM) IS THE ONLY BROADCAST STATION OWNED BY RADIO FIESTA AND ITS PRINCIPALS. THUS THIS APPLICATION IS FULLY COMPLIANT WITH THE FCCS MULTIPLE OWNERSHIP RULES.

Attachment 5


Exhibit 13
Description:
DISCUSSION OF ENGINEERING EXHIBITS

THE BROADCAST FACILITY REMAINS IN COMPLIANCE WITH ALL APPLICABLE RULES CONTAINED IN C.F.R. CHAPTER 47, PART 73, SUBPART A. AS STATED BEFORE, KFIR PROPOSES TO CO-LOCATE WITH KTHH. DAYTIME POWER WILL BE 10.0 KW. NIGHTTIME POWER WILL ALSO BE 0.146 KW. DETAILS OF THE PROPOSED ANTENNA SYSTEM ARE LOCATED IN EXHIBIT(S) 13.1-4. EXHIBIT 13.1 IS A COPY OF ASR #1034993 FOR THE TOWER TO BE UTILIZED. AS THE TOWER IS EXISTING AND NO CHANGES ARE PROPOSED, NO FILING WITH THE FAA WAS NECESSARY. A MAP DEPICTING THE PRESENT AND PROPOSED DAYTIME SERVICE CONTOURS HAS BEEN INCLUDED AS EXHIBIT 13.5. THE PRESENT AND
PROPOSED NIGHTTIME SERVICE CONTOURS HAVE BEEN INCLUDED IN EXHIBIT 13.6. THE PRESENT AND PROPOSED 1.0 V/M BLANKET INTERFERENCE CONTOURS FOR THE DAYTIME AND NIGHTTIME OPERATIONS HAVE BEEN INCLUDED IN EXHIBIT 13.7.

THIS APPLICATION REQUESTS A WAIVER OF 73.189(B)(2)(II) REGARDING THE MINIMUM EFFECTIVE FIELD STRENGTH OF 282 MV/M FOR 1 KW. DUE TO A REDUCED AVERAGE RADIAL LENGTH FOR THE GROUND SYSTEM, THE ACTUAL EFFECTIVE FIELD STRENGTH OF THE PROPOSED ANTENNA SYSTEM WILL BE 277.68 MV/M FOR 1 KW. HOWEVER, THIS IS 1.5% BELOW THE MINIMUM
SPECIFIED 282 MV/M FOR 1 KW. THE COMMISSION HAS SAID IT WILL WAIVER SUCH A DEFICIENCY UP TO 2%.

Attachment 13
Description
Discussion of Engineering Exhibits As Amended
Exhibits 13.1 - 13.7 As Amended


Exhibit 17
Description:
GROUNDWAVE EXHIBITS

THE PROPOSED ALLOCATION REMAINS IN COMPLIANCE WITH THE REQUIREMENTS OF 73.37. EXHIBIT(S) 17.1-2 ARE RELEVANT MAP M-3 ALLOCATION STUDIES FOR THE PROPOSED OPERATION. NO PROHIBITED CONTOUR OVERLAP IS PREDICTED TO OCCUR TO ANY DOMESTIC FACILITY AS NOTED IN THE SUPPLIED EXHIBITS. THE PROPOSED ALLOCATION USES EXISTING FIELD STRENGTH MEASUREMENTS ON TAKEN ON KIRO SEATTLE, WA IN AN APPLICATION, BP 20071119AEZ. A COPY OF THE MEASUREMENT DATA IS INCLUDED IN EXHIBIT 17.3.

Attachment 17
Description
Exhibits 17.1 - 17.3


Exhibit 18
Description:
SKYWAVE EXHIBITS

THE PROPOSED ALLOCATION WILL COMPLY WITH THE REQUIREMENTS OF 73.182. EXHIBIT 18.1 IS A NIGHTTIME ALLOCATION STUDY FOR THE PROPOSED KFIR(AM) OPERATION. IN RESPONSE TO FCC ATTEMPTS TO STREAMLINE THE APPLICATION PROCESS, NIGHTTIME PROTECTIONS IN WHICH THE PROPOSED OPERATION WILL HAVE A NEGLIGIBLE EFFECT HAVE BEEN OMITTED TO REDUCE PAPERWORK. A COMPLETE LIST OF ALL PROTECTIONS WILL BE SUPPLIED UPON REQUEST. ANALYSIS OF THE COMPLETE STUDY HAS CONCLUDED THE PROPOSED OPERATION WILL NOT INTERFERE WITH ANY PROTECTED OPERATION, HOWEVER INDIVIDUAL STUDIES WILL BE SUPPLIED FOR ANY STATION UPON REQUEST. A TABULATION OF THE PRESENT AND PROPOSED RSS LIMITATIONS HAS BEEN SUPPLIED AS EXHIBIT 18.2. EXHIBIT 18.3 IS A MAP SHOWING THE PROTECTION TO FIRST ADJACENT CHANNEL, CLASS A STATION, KIRO, SEATTLE, WA. THE MAP SHOWS THAT THE PROPOSED KFIR 0.25 MV/M 10% SKYWAVE CONTOUR WILL NOT OVERLAP THE GROUNDWAVE 0.5 MV/M CONTOUR OF KIRO.

Attachment 18
Description
Exhibits 18.1 - 18.3 As Amended


Exhibit 19
Description:
CRITICAL HOURS EXHIBITS

THE PROPOSED ALLOCATION IS IN COMPLIANCE WITH THE REQUIREMENTS OF 73.187. THE PRESENT FREQUENCY OF 720 KHZ IS A CLASS A FREQUENCY WHICH DOES REQUIRE CRITICAL HOURS OPERATION OR PROTECTION. EXHIBIT 19.1 DEMONSTRATES THAT FULL PROTECTION WILL BE AFFORDED WGN CHICAGO, IL AND KOTZ KOTZEBUE, AK DURING CRITICAL HOURS.

Attachment 19
Description
Exhibit 19.1


Exhibit 20
Description:
ENVIRONMENTAL COMPLIANCE

APPLICANT CERTIFIES RF COMPLIANCE WITH THE ATTACHED STUDY.

REGARDING COMPLIANCE WITH THE NEPA, NATIONWIDE PROGRAMMATIC AGREEMENT AND NHPA SECTION 106 FOR TOWER CO-LOCATION, COMPLIANCE WITH THE AGREEMENT IS NOT REQUIRED WHERE NO NEW TOWER CONSTRUCTION IS BEING PROPOSED AND THE TOWER IS NOT BEING SUBSTANTIALLY ALTERED. SPECIFICALLY, COMPLIANCE IS NOT NECESSARY WHERE ONLY AN AM SIGNAL IS BEING DIPLEXED INTO AN EXISTING AM ANTENNA WITH NO PHYSICAL CHANGE TO THE EXISTING STRUCTURE, AS HERE. HOWEVER, SHOULD THE COMMISSION DETERMINE THAT COMPLIANCE IS NECESSARY, UPON NOTIFICATION TO THE APPLICANT, THE APPLICANT WILL FILE FCC FORM 621.


Attachment 20
Description
Exhibit 20.1 - RF Radiation Study As Amended