Federal Communications Commission
Washington, D.C. 20554
Approved by OMB
3060-0386 (July 2002)
FOR FCC USE ONLY
 
Extension of Existing Engineering STA

Read Instructions/FAQ before filling out form

FOR COMMISSION USE ONLY
FILE NO.

BESTA - 20160316AAK
Section I - General Information
1. Legal Name of the Applicant
KPHP RADIO, INC.
Mailing Address
P.O. BOX 3003

City
BLUE BELL
State or Country (if foreign address)
PA
Zip Code
19422 -
Telephone Number (include area code)
2156283500
E-Mail Address (if available)
CRISA@CRAWFORDBROADCASTING.COM
FCC Registration No
0003253150
Call Sign
KKPZ
Facility ID Number
4113
2. Contact Representative (if other than licensee/permittee)
JOHN S. NEELY, ESQ.
Firm or Company Name
MILLER AND NEELY, P.C.
Mailing Address
SUITE 203
3750 UNIVERSITY BLVD., WEST

City
KENSINGTON
State or Country (if foreign address)
MD
ZIP Code
20895 -
Telephone Number (include area code)
3019336304

E-Mail Address (if available)
JOHNSNEELY@YAHOO.COM
3. Purpose:
Engineering STA
Extension of Existing Engineering STA         File Number: BSTA - 20030915AHO
Legal STA
Extension of Existing Legal STA         
4. Service: AM 
5. Community of License:
City: PORTLAND     State: OR
6. If this application has been submitted without a fee, indicate reason for fee exemption (see 47 C.F.R. Section 1.1114):
Governmental Entity Noncommercial Educational Licensee/Permittee Other
N/A (Fee Required)
7. 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 33]

8.
Please explain in detail the "extraordinary circumstances" which warrant temporary operations at variance from the Commission's Rules. In addition, please specify 1)the specific rules and/or policies from which the applicant seeks temporary relief; 2) how the public interest will be furthered by grant; and 3) the expected duration of the STA and the licensee's plan for restoration of licensed operation. If requesting variance with other than authorized technical facilities, please specify the exact facilities sought.
[Exhibit 34]
9.
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

I hereby 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.

Typed or Printed Name of Person Signing
JOHN NEELY, ESQ
Typed or Printed Title of Person Signing
COUNSEL
Signature
Date (mm/dd/yyyy)
03/16/2016

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 34
Description:
DISCUSSION

THE CURRENT STA EXPIRES MARCH 22, 2016.

THIS STA IS REQUIRED DUE TO PATTERN DISTORTION CAUSED TO KKPZ BY MISADJUSTED DETUNED TOWER STRUCTURES IN CLOSE PROXIMITY TO THE LICENSED KKPZ ANTENNA TOWER.

FOR GREATER THAN TEN YEARS KKPZ HAS OPERATED WITH AN STA DUE TO AN UNDETUNED PART 90 TOWER OWNED BY TRI-METROPOLITAN TRANSPORTATION DISTRICT ('TRI-MET') FOR ITS PART 90 STATION OPERATIONS.

FOR NEARLY AS LONG, KKPZ SOUGHT FCC INVOLVEMENT IN REQUIRING TRI-MET TO DETUNE ITS TOWER.     BY LETTER DATED JULY 23, 2014, THE FCC'S WIRELESS TELECOMMUNICATIONS BUREAU FOUND THAT THE UNDETUNED TRI-MET TOWER WAS DISTURBING THE KKPZ RADIATION PATTERN IN VIOLATION OF FCC RULES.

BY LETTER DATED AUGUST 19, 2014, TRI-MET RESPONDED TO THE FCC THAT TRI-MET WILL DETUNE ITS TOWER WITH DESIGN WORK ANTICIPATED TO BE COMPLETED BY EARLY 2015 AND TOWER WORK ANTICIPATED IN SPRING 2015.

BY LETTER DATED JULY 20, 2015, KKPZ FILED A FURTHER COMPLAINT WITH THE WIRELESS TELECOMMUNICATIONS BUREAU ADVISING THAT TRI-MET HAD YET TO COMPLY WITH FCC'S DETUNING ORDER.

BY LETTER DATED SEPTEMBER 18, 2015, THE WIRELESS TELECOMMUNICATIONS BUREAU ASKED TRI-MET TO FILE A STATUS REPORT WITHIN 30-DAYS AND COMPLETE DETUNING BEFORE DECEMBER 31, 2015. HOWEVER, THAT LETTER WAS RETURNED TO THE FCC AS MISADDRESSED AND UNDELIVERABLE.

BY FOLLOWUP LETTER DATED NOVEMBER 19, 2015, THE WIRELESS TELECOMMUNICATIONS BUREAU ASKED TRI-MET TO FILE A STATUS REPORT WITHIN 30 DAYS AND COMPLETE DETUNING BEFORE MARCH 1, 2016.

BY LETTER DATED DECEMBER 7, 2016, (SEE ATTACHMENT 34) TRI-MET RESPONDED THAT IT EXPECTED DETUNING TO BE COMPLETED 'BY THE END OF JANUARY 2016.'

KKPZ REPORTS THAT TRI-MET DID NOT MEET ITS JANUARY ESTIMATE BUT DOES, AT LEAST INITIALLY, APPEAR TO HAVE LARGELY COMPLETED DETUNING BY MARCH 1, 2016.

HOWEVER, THE TRI-MET TOWER IS AMONG A FIVE TOWER FARM WITH THE TRI-MET TOWER BEING THE NEAREST OF THE FIVE TO THE KKPZ TOWER. NOW THAT THE TRI-MET TOWER IS LARGELY DETUNED, IT APPEARS THAT THE UN-DETUNED TRI-MET TOWER WAS EFFECTIVELY MASKING RE-RADIATING EFFECTS OF OTHER TOWERS AT THE FARM.       THE TOWER FARM IS WITHIN KKPZ'S MAIN SIGNAL LOBE.

KKPZ IS NOW ATTEMPTING WORK WITH AND COORDINATE ALL OF THE TOWER OWNERS TO ADJUST AND FINALIZE DETUNING OF THE 5 TOWERS AS A GROUP. THE TIME REQUIRED TO ADJUST EQUIPMENT AND RECEIVE THE FULL COOPERATION OF THE TOWER OWNERS IS BEYOND KKPZ'S CONTROL.

THE STA EXTENSION IS NEEDED IN ORDER THAT KKPZ MAY CONTINUE OPERATION WITH PARAMETERS AT VARIANCE.

KKPZ RECEIVED NO INTERFERENCE COMPLAINTS DURING THE CURRENT STA PERIOD. AS THE STATION DESIRES TO CONTINUE TO PROVIDE THE PUBLIC WITH A BROADCAST SERVICE DURING THIS PERIOD, IT IS WITHIN THE PUBLIC INTEREST TO GRANT THIS STA TO OPERATE WITH PARAMETERS AT VARIANCE UNTIL THE PROJECT IS COMPLETED AND OPERATION MAY RESUME AT LICENSED VALUES.


Attachment 34
Description
Tri-Met Letter