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 - 20210216AAJ
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
Typed or Printed Title of Person Signing
COUNSEL
Signature
Date (mm/dd/yyyy)
02/12/2021

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 FEBRUARY 23, 2021.

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

FOR GREATER THAN TEN YEARS KKPZ OPERATED WITH AN STA DUE PRIMARILY TO A COMPLETELY UNDETUNED TOWER STRUCTURE OWNED BY TRI-METROPOLITAN TRANSPORTATION DISTRICT ('TRI-MET') FOR ITS LICENSED PART 90 STATION OPERATIONS. TRI-MET APPEARS TO HAVE DETUNED ITS TOWER IN 2016 PURSUANT TO COMMISSION ORDER.   KKPZ ENGINEERS ANTICIPATED THAT RELATED SIGNAL DISTORTION ISSUES WOULD BE RESOLVED AND KKPZ COULD RESUME OPERATIONS AT LICENSED VALUES AFTER THE TRI-MET TOWER WAS PROPERLY DETUNED.

THE KKPZ TOWER IS LOCATED NEAR A MULTI-TOWER ANTENNA FARM AND THE TRI-MET TOWER DETUNING HAS STARKLY REVEALED WHAT IS OCCURRING WITH OTHER TOWERS IN THE ANTENNA FARM.

INTERMITTENTLY EVERY FEW WEEKS OR MONTHS ONE OR ANOTHER NEARBY TOWER OR TOWERS, INCLUDING TRI-MET, WILL ADD, REMOVE OR CHANGE MOUNTED ANTENNAS.       MORE OFTEN THAN NOT, THE RESPONSIBLE PARTY DOES NOT COMPLY WITH SECTION 1.30002 NOTIFICATION REQUIREMENTS TO KKPZ. IF KKPZ DOES NOT PER CHANCE NOTICE A CREW WORKING ON A NEARBY TOWER, THE KKPZ DETUNING GOES OUT OF ADJUSTMENT WITHOUT OUR ADVANCE KNOWLEDGE.

AFTER WORK ON THE NEARBY TOWER IS COMPLETED AND DISCOVERED BY KKPZ, THEN KKPZ COMMENCES MAKING ITS OWN DETUNING ADJUSTMENTS AS NEEDED. IT IS A HUGE TIME COMMITMENT TO MONITOR AND ADDRESS THE SITUATION AND KKPZ DOES NOT CONTROL WHEN OR HOW OFTEN CHANGES OCCUR ON OTHER TOWERS WITHOUT RECEIVING PRIOR NOTIFICATION AS REQUIRED BY FCC RULES. THESE FACTORS HAVE MADE IT CHALLENGING TO COMPLETE THE KKPZ MEASUREMENTS REQUIRED TO PREPARE FORM 302.

KKPZ CONTINUES IN ITS EFFORTS TO WORK WITH AND COORDINATE ALL OF THE TOWER OWNERS TO DEVELOP SENSIBLE PROTOCOLS. FOR EXAMPLE, KKPZ, OTHER TOWER OWNERS AND SITE MANAGERS HAVE POSTED SIGNAGE INDICATING THE NEED FOR PRIOR COORDINATION PER RULE SECTION 1.30002. IN PRACTICE, HOWEVER, THESE SIGNS HAVE BEEN LARGELY IGNORED BY CONTRACTORS COMMISSIONED TO WORK ON THE TOWERS, WHO APPEAR TO BE FOCUSED ON COMPLETING THE ASSIGNED WORK AND ARE NOT CONCERNED WITH THE NOTIFICATION RESPONSIBILITIES UNDER 1.30002. THE PROMPT AND FULL COOPERATION FROM THE VARIOUS TOWER OWNERS, THEIR WORKERS AND CONTRACTORS IS BEYOND KKPZ'S REASONABLE CONTROL.

GIVEN THE HISTORY OF EVENTS ON TOWER STRUCTURES WHICH KKPZ DOES NOT CONTROL, IT IS ANTICIPATED THAT THE RECENT PATTERN OF DETUNING ADJUSTMENTS WILL CONTINUE FOR THE FORESEEABLE FUTURE.

THE STA EXTENSION IS NEEDED IN ORDER THAT KKPZ MAY CONTINUE OPERATION AND BROADCAST SERVICE TO ITS LISTENING AUDIENCE 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