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.

BEDSTA - 20091028ACN
Section I - General Information
1. Legal Name of the Applicant
BELO KENTUCKY, INC.
Mailing Address
400 SOUTH RECORD STREET

City
DALLAS
State or Country (if foreign address)
TX
Zip Code
75202 -
Telephone Number (include area code)
2149776606
E-Mail Address (if available)
FCC Registration No
0003595253
Call Sign
WHAS-TV
Facility ID Number
32327
2. Contact Representative (if other than licensee/permittee)
JOHN BURGETT
Firm or Company Name
WILEY REIN LLP
Mailing Address
WILEY REIN LLP
1776 K STREET, NW

City
WASHINGTON
State or Country (if foreign address)
DC
ZIP Code
20006 -
Telephone Number (include area code)
2027197000

E-Mail Address (if available)
JBURGETT@WILEYREIN.COM
3. Purpose:
Engineering STA
Extension of Existing Engineering STA         File Number: BDSTA - 20091014AAM
Legal STA
Extension of Existing Legal STA         
4. Service: DS 
5. Community of License:
City: LOUISVILLE     State: KY
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.
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 36]
8.
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
GUY KERR
Typed or Printed Title of Person Signing
SECRETARY
Signature
Date (mm/dd/yyyy)
10/28/2009

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 36
Description:
EXHIBIT

ON OCTOBER 19, 2009, THE FCC GRANTED WHAS-TV SPECIAL TEMPORARY AUTHORITY TO OPERATE AT 16.4 KW (THE STA). THIS WAS NECESSARY TO PERMIT BELO TO DETERMINE IF SUCH A POWER INCREASE WOULD RESOLVE INDOOR RECEPTION ISSUES ASSOCIATED WITH WHAS-TVS SWITCH FROM ANALOG TO A HIGH-BAND VHF DIGITAL CHANNEL. AS NOTED IN THE ORIGINAL REQUEST FOR THE STA, THE OPERATION OF WHAS-TV AT 16.4 KW IS PREDICTED TO CAUSE SOME NEW INTERFERENCE ABOVE THE 0.5 PERCENT LIMIT TO WLFI-TV, LAFAYETTE, INDIANA, WHICH IS LICENSED TO PRIMELAND TELEVISION, INC. (PRIMELAND). THUS, BELO ENTERED INTO AN AGREEMENT WITH PRIMELAND WHEREBY PRIMELAND GRANTED BELO PERMISSION TO CONDUCT TESTING OF WHAS-TV AT 16.4 KW UNTIL OCTOBER 28, 2009.

BELO, THROUGH AN INDEPENDENT CONSULTING ENGINEER APPROVED BY PRIMELAND, PERFORMED SUCH TESTING AND THE PRELIMINARY RESULTS REVEAL THAT WHAS-TV, OPERATING AT 16.4 KW WITH THE PARAMETERS SPECIFIED IN THE STA, DOES NOT CAUSE ANY ADDITIONAL INTERFERENCE TO WLFI-TV. THESE RESULTS ARE ONLY PRELIMINARY AND BELO WOULD LIKE TO CONTINUE OPERATION AT 16.4 KW FOR A LONGER PERIOD OF TIME TO CONFIRM THE LONG-TERM ACCURACY OF THE TESTS. THUS, BELO RESPECTFULLY REQUESTS AN EXTENSION OF THE STA FOR AN ADDITIONAL 90 DAYS, UNTIL JANUARY 26, 2009. PRIMELAND HAS VERBALLY CONSENTED TO SUCH EXTENSION AND THE PARTIES ARE FINALIZING A FORMAL AGREEMENT. BELO WILL PROVIDE THE FCC WITH A COPY OF THIS AGREEMENT ONCE IT IS COMPLETED. THIS ADDITIONAL TIME WILL ALSO PERMIT BELO TO BETTER DETERMINE IF OPERATING AT A HIGHER POWER RESOLVES WHAS-TVS INDOOR RECEPTION ISSUES. WHILE BELO HAS ANECDOTAL EVIDENCE THAT THE POWER INCREASE HELPS WHAS-TVS INDOOR SIGNAL STRENGTH, IT NEEDS ADDITIONAL TIME TO CONFIRM THIS.


Attachment 36