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

Read Instructions/FAQ before filling out form

FOR COMMISSION USE ONLY
FILE NO.

BSTA - 20090406AAI
Section I - General Information
1. Legal Name of the Applicant
MT. WILSON FM BROADCASTERS, INC.
Mailing Address
1500 COTNER AVENUE

City
LOS ANGELES
State or Country (if foreign address)
CA
Zip Code
90025 -
Telephone Number (include area code)
3104785540
E-Mail Address (if available)
FCC Registration No
0001530187
Call Sign
KKGO
Facility ID Number
43939
2. Contact Representative (if other than licensee/permittee)
ROBERT B. JACOBI, ESQ.
Firm or Company Name
COHN AND MARKS LLP
Mailing Address
1920 N STREET, N.W.
SUITE 300

City
WASHINGTON
State or Country (if foreign address)
DC
ZIP Code
20036 - 1622
Telephone Number (include area code)
2024524810

E-Mail Address (if available)
RBJ@COHNMARKS.COM
3. Purpose:
Engineering STA
Extension of Existing Engineering STA
Legal STA
Extension of Existing Legal STA         
4. Service: FM 
5. Community of License:
City: LOS ANGELES     State: CA
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)
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
7.0. STA is requested for use of
Licensed Antenna system with:
       Reduced power
       Reduced hours of operation
       Required equipment out of service
       Other variance             [Exhibit 1]

Antenna system authorized by Construction Permit:               - 
      Describe requested modes of operation              [Exhibit 2]

Other antenna system: (Complete Items 7.1 - 7.11)
7.1. Channel Number:
7.2. Antenna Location Coordinates: (NAD 27)

Latitude:    
Degrees Minutes Seconds     North     South


Longitude: 
Degrees Minutes Seconds     West     East

7.3. Antenna Structure Registration Number:   
Not Applicable Notification filed with FAA
7.4. Overall Tower Height Above Ground Level: meters
7.5. Height of Radiation Center Above Mean Sea Level: meters(H) meters(V)
7.6. Height of Radiation Center Above Ground Level: meters(H) meters(V)
7.7. Height of Radiation Center Above Average Terrain: meters(H) meters(V)
7.8. Effective Radiated Power: kW(H) kW(V)
7.9. Maximum Effective Radiated Power: Not Applicable
(Beam-Tilt Antenna ONLY)
kW(H) kW(V)
7.10.
Directional Antenna Relative Field Values: Not applicable (Nondirectional)
Rotation (Degrees): No Rotation
Degrees Value Degrees Value Degrees Value Degrees Value Degrees Value Degrees Value    
0 10 20 30 40 50
60 70 80 90 100 110
120 130 140 150 160 170
180 190 200 210 220 230
240 250 260 270 280 290
300 310 320 330 340 350
Additional 
Azimuths

7.11. 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 3]
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 4]
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 certify that I have prepared 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
JOHN J. DAVIS
Relationship to Applicant (e.g., Consulting Engineer)
CONSULTING ENGINEER
Signature
Date (mm/dd/yyyy)
04/03/2009
Mailing Address
PO BOX 128
City
SIERRA MADRE
State or Country (if foreign address)
CA
Zip Code
91025 -0128
Telephone Number (No dashes or parentheses, include area code)
6263556909
E-Mail Address (if available)
JOHNJDAVIS@ROADRUNNER.COM

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
SAUL LEVINE
Typed or Printed Title of Person Signing
SAUL LEVINE
Signature
Date (mm/dd/yyyy)
04/03/2009

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:
REQUEST TO INCREASE IBOC DIGITAL SIDEBAND POWER

1.   INTRODUCTION:   SINCE 2005, FM STATION KKGO HAS BEEN BROADCASTING DIGITAL CARRIERS BASED UPON THE IBOC SYSTEM (COMMONLY REFERRED TO AS HD RADIO) WITH A POWER LEVEL OF 180 WATTS ERP [1% (-20 DB) OF THE LICENSED 18 KW ERP MAIN ANALOG CHANNEL] IN ACCORDANCE WITH THE FCCS REQUIREMENTS FOR SUCH BROADCASTING.

CURRENTLY, THE COMMISSION HAS ALLOWED A FEW STATIONS TO BROADCAST WITH DIGITAL SIDEBAND POWERS OF 10% (-10 DB) OF THE MAIN ANALOG CARRIER IN ORDER TO DETERMINE THE HARMFUL EFFECTS, IF ANY, OF SUCH A POWER INCREASE UPON THE STATIONS ANALOG CARRIER, AND TO CO-CHANNEL AND FIRST ADJACENT CHANNEL STATIONS.

2.   SPECIAL TEMPORARY AUTHORIZATION REQUEST: MT. WILSON FM BROADCASTERS, INC.(MT. WILSON), LICENSEE OF FM STATION KKGO, HEREBY REQUESTS PERMISSION TO TEST A SLIGHTLY HIGHER POWER LEVEL THAN IS CURRENTLY AUTHORIZED. MT. WILSON IS CONCERNED, BASED UPON EXTENSIVE TESTING BY NPR LABORATORIES, AND OTHERS, THAT DAMAGING INTERFERENCE TO KKGOS MAIN ANALOG SIGNAL WILL RESULT IF THE COMMISSION AUTHORIZES AN INCREASE TO 10% OF THE ANALOG CARRIER. MT. WILSON RECOGNIZES THAT SOME DIGITAL POWER INCREASE WILL BE BENEFICIAL TO MORE CLOSELY MATCH THE DIGITAL AND ANALOG COVERAGE AREAS, BUT WITHOUT CREATING HARMFUL INTERFERENCE TO ITS ANALOG SIGNAL OR TO THE SIGNAL OF ANY FIRST ADJACENT CHANNEL STATION.

THE PROPOSED TEST WOULD INCREASE THE KKGO DIGITAL SIDEBAND POWER LEVELS BY 27%, FROM THE PRESENTLY AUTHORIZED 180 WATTS ERP (440 WATTS TPO) TO 229 WATTS ERP (560 WATTS TPO), WHICH IS THE MAXIMUM DIGITAL POWER OUTPUT CAPABILITY OF THE BROADCAST ELECTRONICS FMI-106 FM TRANSMITTER, OPERATING IN THE IBOC ONLY, MODE USED AT KKGO. MT. WILSON REQUESTS A TEST PERIOD OF 90 DAYS TO DETERMINE WHETHER A SMALL POWER INCREASE WILL PROVIDE ANY SIGNIFICANT IMPROVEMENT IN THE DIGITAL SIGNAL COVERAGE AREA, AND IN BUILDING PENETRATION.

IT IS HOPED THAT THE TESTS WILL FIND THAT A DIGITAL POWER LEVEL LESS THAN THE CURRENTLY PROPOSED 10% OF THE ANALOG POWER WILL PROVIDE THE DESIRED IMPROVEMENT IN COVERAGE WITHOUT THE HARMFUL SIDE EFFECTS.


Attachment 1


Exhibit 4
Description:
PUBLIC INTEREST BENEFIT

THERE HAVE BEEN VARIOUS STUDIES OF THE EFFECTS OF AN INCREASE IN THE HD RADIO DIGITAL CARRIER POWER LEVELS. STUDIES DONE BY NPR LABORATORIES AND IBIQUITY HAVE REACHED DIFFERENT CONCLUSIONS AS TO WHETHER THE INCREASE IS BENEFICIAL OR DETRIMENTAL. THERE IS NO MAGIC IN A POWER LEVEL OF 10% OF THE ANALOG CARRIER, ESPECIALLY CONSIDERING THAT THE NPR LABORATORIES STUDY SHOWS SIGNIFICANT REDUCTION WILL RESULT IN ANALOG COVERAGE IF SUCH AN INCREASE IN THE DIGITAL SIDEBANDS IS PERMITTED. THE RESULTS OF THE FIRST STUDY HAVE PROMPTED NPR LABORATORIES TO DO FURTHER TESTING AT VARIOUS POWER LEVELS BETWEEN 1% AND 10% OF THE ANALOG CARRIER.

WHAT MT. WILSON IS PROPOSING IS A TEST TO INCREASE KKGOS DIGITAL CARRIER FROM 1% TO 1.27% OF THE ANALOG CARRIER IN THE HOPE THAT, EVEN AT THIS SLIGHTLY HIGHER DIGITAL POWER LEVEL, THERE WILL BE AN IMPROVEMENT IN THE DIGITAL SIGNAL COVERAGE AREA, WITH NO RESULTING LOSS IN ANALOG COVERAGE AREA DUE TO INTERFERENCE FROM THE DIGITAL CARRIERS. THE PUBLIC WOULD CERTAINLY BENEFIT FROM SUCH A STUDY.


Attachment 4