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.

BMPCDT - 20040112ABL
Section I - General Information
1. Legal Name of the Applicant
KJLA, LLC
Mailing Address
2323 CORINTH AVENUE

City
WEST LOS ANGELES
State or Country (if foreign address)
CA
ZIP Code
90064 -
Telephone Number (include area code)
3109435288
E-Mail Address (if available) 
FCC Registration Number:
0008195455
Call Sign 
KJLA-DT
Facility ID Number
14000
2. Contact Representative (if other than Applicant)
BARRY A. FRIEDMAN
Firm or Company Name
THOMPSON HINE LLP
Mailing Address
SUITE 800
1920 N STREET, NW

City
WASHINGTON
State or Country (if foreign address)
DC
ZIP Code
20036 -
Telephone Number (include area code)
2023318800
E-Mail Address (if available)
BARRY.FRIEDMAN@THOMPSONHINE.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
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:

BPCDT-19991101AFT NA
(b) 
Service Type:

AM FM
(c) Community of License:
City: VENTURA

State: CA

 (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]




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
FRANCIS X. WILKINSON
Typed or Printed Title of Person Signing
VICE PRESIDENT
Signature
Date
01/12/2004

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-D - DTV Engineering
Complete Questions 1-5, and provide all data and information for the proposed facility, as requested in Technical Specifications, Items 1-13.

Pre-Transition Certification Checklist: An application concerning a pre-transition channel must complete questions 1(a)-(c), and 2-5. A correct answer of "Yes" to all of the questions will ensure an expeditious grant of a construction permit application to change pre-transition facilities. However, if the proposed facility is located within the Canadian or Mexican borders, coordination of the proposal under the appropriate treaties may be required prior to grant of the application. An answer of "No" will require additional evaluation of the applicable information in this form before a construction permit can be granted.

Post-Transition Expedited Processing. An application concerning a post-transition channel must complete questions 1(a), (d)-(e), and 2-5. A station applying for a construction permit to build its post-transition channel will receive expedited processing if its application (1) does not seek to expand the noise-limited service contour in any direction beyond that established by Appendix B of the Seventh Report and Order in MB Docket No. 87-268 establishing the new DTV Table of Allotments in 47 C.F.R. § 73.622(i) ("new DTV Table Appendix B"); (2) specifies facilities that match or closely approximate those defined in the new DTV Table Appendix B facilities; and (3) is filed within 45 days of the effective date of Section 73.616 of the rules adopted in the Report and Order in the Third DTV Periodic Review proceeding, MB Docket No. 07-91.

1. The proposed DTV facility complies with 47 C.F.R. Section 73.622 in the following respects:
 
(a) It will operate on the DTV channel for this station as established in 47 C.F.R. Section 73.622.
Yes No
(b) It will operate a pre-transition facility from a transmitting antenna located within 5.0 km (3.1 miles) of the DTV reference site for this station as established in 47 C.F.R. Section 73.622.
Yes No
(c) It will operate a pre-transition facility with an effective radiated power (ERP) and antenna height above average terrain (HAAT) that do not exceed the DTV reference ERP and HAAT for this station as established in 47 C.F.R. Section 73.622.
Yes No
(d) It will operate at post-transition facilities that do not expand the noise-limited service contour in any direction beyond that established by Appendix B of the Seventh Report and Order in MB Docket No. 87-268 establishing the new DTV Table of Allotments in 47 C.F.R. § 73.622(i) ("new DTV Table Appendix B").
Yes No
N/A
(e) It will operate at post-transition facilities that match or reduce by no more than five percent with respect to predicted population from those defined in the new DTV Table Appendix B.
Yes No
N/A
2. The proposed facility will not have a significant environmental impact, including exposure of workers or the general public to levels of RF radiation exceeding the applicable health and safety guidelines, and therefore will not come within 47 C.F.R. Section 1.1307.
Applicant must submit the Exhibit called for in Item 13.
Yes No
3. Pursuant to 47 C.F.R. Section 73.625, the DTV coverage contour of the proposed facility will encompass the allotted principal community. Yes No
4. The requirements of 47 C.F.R. Section 73.1030 regarding notification to radio astronomy installations, radio receiving installations and FCC monitoring stations have either been satisfied or are not applicable. Yes No
5. The antenna structure to be used by this facility has been registered by the Commission and will not require registration to support the proposed antenna, OR the FAA has previously determined that the proposed structure will not adversely effect safety in air navigation and this structure qualifies for later registration under the Commission's phased registration plan, OR the proposed installation on this structure does not require notification to the FAA pursuant to 47 C.F.R. Section 17.7. Yes No




SECTION III-D - DTV 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. Channel Number:

DTV   49      Analog TV, if any   57
2. Zone:
I     II      III
3. Antenna Location Coordinates: (NAD 27)
Latitude:    
Degrees 34 Minutes 13 Seconds 35.3     North     South


Longitude: 
Degrees 118 Minutes 3 Seconds 57.7     West     East
4. Antenna Structure Registration Number: 1221073
Not Applicable Notification filed with FAA
5.
Antenna Location Site Elevation Above Mean Sea Level: 1739.8  meters
6.
Overall Tower Height Above Ground Level: 122  meters
7.
Height of Radiation Center Above Ground Level: 86.2  meters
8.
Height of Radiation Center Above Average Terrain : 937  meters
9.
Maximum Effective Radiated Power (average power): 1000  kW     
10. Antenna Specifications:

a.  Manufacturer RFS     Model PHP30CA-CH49

b.  Electrical Beam Tilt:
1.4 degrees    Not Applicable

c.   Mechanical Beam Tilt:
degrees toward azimuth
degrees True    Not Applicable
Attach as an Exhibit all data specified in 47 C.F.R. Section 73.625(c).
[Exhibit 46]

d.  Polorization:
Horizontal    Circular    Elliptical

e.  Directional Antenna Relative Field Values:    Not applicable (Nondirectional)

[For a composite directional (not off-the-shelf) antenna, press the following button to fill in the relative field values subform.]
[Relative Field Values]


10e. Directional Antenna Relative Field Values

[Fill in this subform for a composite directional (not off-the-shelf) antenna, only.]

e.  Directional Antenna Relative Field Values:
Rotation (Degrees): 0 No Rotation
Degrees Value Degrees Value Degrees Value Degrees Value Degrees Value Degrees Value    
0 0.056 10 0.117 20 0.187 30 0.075 40 0.162 50 0.186
60 0.134 70 0.373 80 0.74 90 0.942 100 0.957 110 0.895
120 0.758 130 0.572 140 0.583 150 0.67 160 0.653 170 0.763
180 0.964 190 0.947 200 0.766 210 0.648 220 0.599 230 0.59
240 0.524 250 0.489 260 0.824 270 0.993 280 0.969 290 0.905
300 0.831 310 0.583 320 0.422 330 0.259 340 0.115 350 0.189
Additional 
Azimuths

134

0.543

156

0.643

184

0.991

247

0.441

272

1

If a directional antenna is proposed, the requirements of 47 C.F.R. Sections 73.625(c) must be satisfied. Exhibit required.
[Exhibit 47]

11.
Does the proposed facility satisfy the pre-transition interference protection provisions of 47 C.F.R. Section 73.623(a) (Applicable only if Certification Checklist Items 1(a), (b), or (c) are answered "No.") and/or the post-transition interference protection provisions of 47 C.F.R. Section 73.616?

If "No," attach as an Exhibit justification therefor, including a summary of any related previously granted waivers.

Yes No

[Exhibit 48]

12.
If the proposed facility will not satisfy the coverage requirement of 47 C.F.R. Section 73.625, attach as an Exhibit justification therefore. (Applicable only if Certification Checklist item 3 is answered "No.")
[Exhibit 49]
13.
Environmental Protection Act. Submit in an Exhibit the following:
[Exhibit 50]
If Certification Checklist Item 2 is answered "Yes," a brief explanation of why an Environmental Assessment is not required. Also describe in the Exhibit the steps that will be taken to limit RF radiation exposure to the public and to persons authorized access to the tower site.

By checking "Yes" to Certification Checklist Item 2, 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.

If Certification Checklist Item 2 is answered "No," an Environmental Assessment as required by 47 C.F.R Section 1.1311.


PREPARERS CERTIFICATION ON SECTION III 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
S. MERRILL WEISS
Relationship to Applicant (e.g., Consulting Engineer)
TECHNICAL CONSULTANT
Signature
Date
01/09/2004
Mailing Address
227 CENTRAL AVENUE
City
METUCHEN
State or Country (if foreign address)
NJ
Zip Code
08840 -1242
Telephone Number (include area code)
7324946400
E-Mail Address (if available)
MERRILL@MWGRP.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 47
Description:
DIRECTIONAL ANTENNA DATA

(EXTRACT FROM TECHNICAL STATEMENT ATTACHED TO THIS EXHIBIT 40.)

THE FACILITIES REQUESTED IN THIS APPLICATION INCLUDE OPERATION AT 1000 KW ERP AT A HEIGHT ABOVE AVERAGE TERRAIN OF 937 METERS (A REDUCTION OF 12 METERS FROM THE OUTSTANDING CONSTRUCTION PERMIT). THESE VALUES EXCEED THE POWER LEVEL VS. ELEVATION RELATIONSHIP PROVIDED IN THE FORMULA CONTAINED IN 73.622(F)(8)(II) OF THE COMMISSIONS RULES. AUTHORIZATION FOR THIS EXCEPTION IS PROVIDED IN 73.622(F)(5), HOWEVER, WHICH STATES THAT STATIONS ARE TO BE PERMITTED DTV POWER UP TO THAT NEEDED TO PROVIDE THE SAME GEOGRAPHIC COVERAGE AREA AS THE LARGEST STATION WITHIN THEIR MARKET. THE JUSTIFICATION FOR THESE FACILITIES REMAINS THE SAME AS IT WAS IN THE TECHNICAL STATEMENT THAT ACCOMPANIED THE APPLICATION FOR THE PREVIOUSLY-APPROVED CONSTRUCTION PERMIT.

THE ANTENNA PROPOSED FOR USE BY KJLA-DT IS A DIRECTIONAL PANEL ARRAY HAVING A SCULPTURED PATTERN ORIENTED TO HAVE ITS THREE MAJOR LOBES EXTENDING FROM APPROXIMATELY 80 THROUGH 305 DEGREES TRUE (AT THE HALF-POWER POINTS). THE RESULTING FIELD PLACES MAXIMUM SIGNAL IN THE DIRECTION OF VENTURA, KJLA-DTS CITY OF LICENSE, WITH 1 MW EFFECTIVE RADIATED POWER (ERP) AT THE PEAK OF THE BEAM. IN ORDER TO PROTECT MEXICAN STATION XHUPN, ON CHANNEL 49 IN TECATE, BCN, AS AGREED TO BY THE MEXICAN SCT, POWER IS REDUCED TO 200 KW IN THE DIRECTION OF THE BORDER SECTION ENCOMPASSED WITHIN THE MEXICAN STATIONS 64 DBU CONTOUR. THE RELEVANT PORTION OF THE BORDER EXTENDS FROM APPROXIMATELY 129 DEGREES TO 155 DEGREES, AS SEEN FROM MT WILSON. THE CORRESPONDING DEPRESSION ANGLES RANGE FROM 1.1 TO 1.3 DEGREES BELOW HORIZONTAL. THE CONSIDERATIONS INVOLVED IN PROVIDING PROTECTION TO XHUPN WERE DETAILED IN THE SECTION ON PROTECTION TO MEXICAN STATIONS CONTAINED WITHIN THE LAST TECHNICAL STATEMENT FILED IN SUPPORT OF THE APPLICATION FOR THE CURRENTLY OUTSTANDING CONSTRUCTION PERMIT. THEY REMAIN UNCHANGED, AND THERE IS NO NEED TO SECURE CONSENT OF THE MEXICAN SCT FOR THE PROCESSING OF THIS APPLICATION.

TO ACHIEVE THE DESIGNED POWER REDUCTION TOWARD THE MEXICAN BORDER WHILE MINIMIZING SERVICE LOSSES IN THE LOS ANGELES AREA, DIFFERENT BEAM TILT VALUES ARE USED ON EACH OF THE ANTENNA FACES. THREE MAJOR LOBES ARE OBTAINED, HAVING PEAK VALUES LOCATED AT 96 DEGREES, 184 DEGREES, AND 272 DEGREES TRUE. THE CORRESPONDING ELECTRICAL BEAM TILT VALUES ARE 2.4 DEGREES, 2.4 DEGREES, AND 1.4 DEGREES, RESPECTIVELY. OTHER TECHNIQUES ARE ALSO APPLIED TO SCULPT THE PATTERN IN THE DESIRED MANNER. POWER GAIN OF THE ANTENNA IS 44.67 (16.50 DB) AT THE LOBE MAXIMUM TOWARD 272 DEGREES AND A DEPRESSION ANGLE OF 1.4 DEGREES.

A PLOT OF THE RELATIVE FIELD AZIMUTHAL RADIATION PATTERN AT THE DEPRESSION ANGLES HAVING MAXIMUM RADIATION IN EACH DIRECTION IS PROVIDED AS FIGURE 4A. (FOOTNOTE OMITTED.) SHOWN IN FIGURE 4B IS THE RELATIVE FIELD AZIMUTHAL RADIATION PATTERN AT THE DEPRESSION ANGLES TO THE RADIO HORIZON IN EACH DIRECTION. PLOTTED IN FIGURE 4C IS THE NORMALIZED, RELATIVE FIELD, AZIMUTHAL RADIATION PATTERN IN THE HORIZONTAL PLANE. THE AZIMUTHAL RADIATION PATTERN AT THE DEPRESSION ANGLES HAVING MAXIMUM RADIATION IN EACH AZIMUTHAL DIRECTION, EXPRESSED IN DECIBELS RELATIVE TO 1 KW (DBK), IS PLOTTED IN FIGURE 5A. FIGURE 5B SHOWS THE AZIMUTHAL RADIATION PATTERN AT THE DEPRESSION ANGLES TO THE RADIO HORIZON IN EACH DIRECTION IN DBK. FIGURE 5C IS A PLOT OF THE HORIZONTAL PLANE RADIATION PATTERN IN DBK. THE TABULATED AZIMUTHAL FIELD AND POWER VALUES USED IN THE DERIVATION OF FIGURES 4A, 4B, AND 4C AND FIGURES 5A, 5B, AND 5C APPEAR IN FIGURE 6.

BECAUSE OF THE USE OF DIFFERENT ELECTRICAL BEAM TILT VALUES IN THE THREE MAIN LOBES, THREE ELEVATION RADIATION PATTERNS IN RELATIVE FIELD VALUES ARE INCLUDED AS FIGURES 7A, 7B, AND 7C, FOR THE 96-, 184-, AND 272-DEGREE AZIMUTHS, RESPECTIVELY. THE CORRESPONDING ELEVATION POWER PATTERNS EXPRESSED IN DBK ARE PLOTTED IN FIGURES 8A, 8B, AND 8C. THE RELATED TABULATED ELEVATION FIELD AND POWER VALUES ARE GIVEN IN FIGURE 9.

FIGURE 10 GIVES THE TABULATED VALUES OF AVERAGE ELEVATIONS AND CONTOUR DISTANCES FOR THE NINE REQUIRED RADIAL DIRECTIONS, CALCULATED AS PRESCRIBED IN 73.625(B)(1, 2, AND 4). FIGURE 11 SHOWS THE CITY GRADE (48 DBU) AND NOISE LIMITED (41 DBU) CONTOURS ON A MAP OF THE COVERAGE AREA AS PRESCRIBED BY 73.625(B)(3). THE LOCATION OF THE PRINCIPAL COMMUNITY (CITY GRADE) (48 DBU) CONTOUR IS POSITIONED BEYOND VENTURA, AS REQUIRED BY 73.625(A)(1). FOR COMPARISON PURPOSES, FIGURE 12 SHOWS THE LOCATIONS OF THE CONTOURS OF THE CURRENTLY PROPOSED FACILITIES AND OF THE FACILITIES APPROVED IN CONJUNCTION WITH THE OUTSTANDING CONSTRUCTION PERMIT. (THE DIFFERENCE IS QUITE SMALL, AND CONSEQUENTLY THE CONTOURS OVERLAY ONE ANOTHER IN MOST DIRECTIONS.)

KJLA-DT WILL USE A TYPE VERIFIED TRANSMITTER AS PER SECTION 73.1660 OF THE COMMISSIONS RULES. INSTALLATION OF THE RF SYSTEM THAT CONNECTS THE TRANSMITTER TO THE POWER COMBINER USED FOR SHARING OF THE ANTENNA BY MULTIPLE STATIONS, OF THE POWER COMBINER AND TRANSMISSION LINES, AND OF THE ANTENNA ITSELF HAS BEEN COMPLETED. MEASUREMENTS OF THE VARIOUS SYSTEM LOSSES HAVE BEEN MADE AND THE REQUIRED TRANSMITTER POWER HAS BEEN CALCULATED. THE EXACT TRANSMITTER POWER TO BE USED HAS BEEN DETERMINED BASED UPON THE RESULTS OF THESE MEASUREMENTS OF END-TO-END LOSSES.

TWO ANTENNA ARRAYS, TWO SETS OF TRANSMISSION LINES, AND TWO POWER COMBINERS WILL BE SHARED AMONG THE STATIONS PARTICIPATING IN THE COMMON OPERATION IN ORDER TO PROVIDE HIGHER PERFORMANCE THAN COULD BE ACHIEVED WITH A SINGLE SET OF EQUIPMENT FOR THE FOUR ADJACENT CHANNELS INVOLVED IN THE OPERATION. IN ADDITION, THE MULTIPLE ARRAYS ALLOW FOR CONTROL OF RADIATION PATTERNS FOR SOME STATIONS TO MEET INTERFERENCE PROTECTION REQUIREMENTS, AND THEY PROVIDE REDUNDANCY TO HELP ASSURE RELIABLE OPERATION OF THE OVERALL FACILITY. THE TWO ANTENNA ARRAYS ARE STACKED ONE ABOVE THE OTHER, AS SHOWN IN THE DRAWING OF FIGURE 3.


Attachment 47
Description
Complete Technical Statement including Figures & Tables


Exhibit 48
Description:
INTERFERENCE ANALYSIS

(EXTRACT FROM COMPLETE TECHNICAL STATEMENT ATTACHED AT EXHIBIT 40.)

EVEN THOUGH THE CHANGE IN FACILITIES REQUESTED IS MINOR AND THE REDUCTION IN ANTENNA HEIGHT WOULD TEND TO REDUCE INTERFERENCE, NEW INTERFERENCE STUDIES WERE CONDUCTED TO CONFIRM THAT NO ADDITIONAL INTERFERENCE IS PREDICTED TO BE CAUSED BY THE CURRENT PROPOSAL. DOING SO IS APPROPRIATE BECAUSE OF ADOPTION IN THIS APPLICATION OF THE MORE CONSERVATIVE ADMINISTRATIVE APPROACH OF USING THE MAXIMUM RADIATION AT ANY DEPRESSION ANGLE AT EACH AZIMUTH VALUE TO REPRESENT THE ANTENNA PATTERN IN THE COMMISSION'S DATABASE. (FOOTNOTE OMITTED.) A VERSION OF THE COMMISSION'S TV_PROCESS PROGRAM WAS USED TO PERFORM THOSE STUDIES. A SUMMARY OF THE STUDIES IS SHOWN IN TABLE 1 (IN THE FILE ATTACHED AT EXHIBIT 40). IN THE TABLE, THE CHANNEL, CALL SIGN, CITY OF LICENSE, AND APPLICATION RECORD NUMBER OF EACH STATION STUDIED ARE GIVEN IN THE LEFT FOUR COLUMNS. THESE ARE FOLLOWED BY THE DTV BASELINE OR GRADE B CONTOUR POPULATION IN THE FIFTH COLUMN, THE TOTAL POPULATION PREDICTED TO BE IMPACTED BY ADDITIONAL ATV (DTV) INTERFERENCE WITH KJLA-DT ASSUMED TO BE LOCATED AT THE SOUTH MOUNTAIN SITE INCLUDED IN THE COMMISSION'S ORIGINAL DTV PLAN IN THE SIXTH COLUMN, AND THE NUMBER OF SCENARIOS STUDIED FOR EACH STATION IN THE SEVENTH COLUMN. IN THE TWO COLUMNS ON THE RIGHT, THE POPULATIONS PREDICTED TO BE IMPACTED BY ADDITIONAL ATV (DTV) INTERFERENCE WITH USE OF THE PLANNED MODIFIED FACILITIES AT MT WILSON ARE SHOWN ALONGSIDE THE PERCENT CHANGES IN TOTAL POPULATION FROM THE DTV PLAN VALUES. THE DASHES SHOWN ON SOME ROWS INDICATE INSTANCES IN WHICH THE TV_PROCESS PROGRAM REPORTED THAT 'THE PROPOSAL CAUSES NO INTERFERENCE,' MEANING THAT THERE WERE NO CELLS IN ITS INITIAL CULLING STUDY THAT INDICATED INTERFERENCE. THUS, IN THESE CASES, NO FURTHER EXAMINATION WAS REQUIRED, AND THE NUMBER OF SCENARIOS STUDIED WAS ZERO. WHEN MULTIPLE SCENARIOS EXISTED AND TV_PROCESS STUDIED THEM, THE WORST-CASE POPULATION IMPACT WAS SELECTED FOR PRESENTATION IN THE TABLE.

TABLE 1 SUMMARIZES TWELVE CASES IMPLICATED IN THE MOVE OF KJLA-DT FROM SOUTH MOUNTAIN TO MT WILSON USING THE PROPOSED NEW FACILITIES AND THEREFORE REQUIRING ANALYSIS. SIX OF THESE SHOW THAT ANALYSIS BEYOND THE INITIAL CULLING STUDY WAS UNNECESSARY. OF THE REMAINING SIX, ONE SHOWS NO PREDICTED CHANGE IN INTERFERENCE, AND ONE SHOWS A VERY SLIGHT DECREASE. THE LAST FOUR CASES ARE ALL SHADED IN TABLE 1 AND RELATE TO KOCE-DT AND KOCE-TV -- BOTH OF WHICH ARE PARTICIPANTS IN THE MT WILSON JOINT OPERATION IN WHICH KJLA-DT IS ALSO A PARTICIPANT.

OF THE FOUR SHADED CASES IN TABLE 1, THE TWO THAT ARE HEAVILY SHADED REPRESENT THE DTV FACILITIES ON CHANNEL 48 THAT WERE PROJECTED IN THE FCC'S DTV PLAN AT KOCE'S CURRENT SITE AT LA HABRA HEIGHTS AND THE CURRENT OPERATION ON CHANNEL 50 OF KOCE-TV AT THE SAME SITE. WITH RESPECT TO THE PREDICTED INTERFERENCE TO KOCE-DT ON CHANNEL 48 AT LA HABRA HEIGHTS, KJLA AND KOCE MUTUALLY RELINQUISHED PROTECTION FROM EACH TO THE OTHER'S DTV PLAN FACILITIES AT THE START OF DEVELOPMENT OF THE MT WILSON JOINT OPERATION, AS NEITHER COULD MOVE THERE WITHOUT COLLOCATING WITH THE OTHER. IN FACT, THE KOCE-DT MT WILSON FACILITIES ARE REPRESENTED BY THE LIGHTLY SHADED LINE JUST ABOVE THE UPPER OF THE TWO HEAVILY SHADED LINES. AS CAN BE SEEN, THE KOCE-DT MT WILSON FACILITIES ARE AIDED BY THE MOVE OF KJLA-DT TO MT WILSON IN THAT THERE IS A RESULTING REDUCTION IN PREDICTED INTERFERENCE POPULATION OF 1.7 PERCENT. MOREOVER, THE KOCE-DT FACILITIES ALREADY ARE FULLY CONSTRUCTED AND READY TO OPERATE AS SOON AS THE COMMISSION COMPLETES PROCESSING OF A CONSTRUCTION PERMIT MODIFICATION APPLICATION COMPLEMENTARY TO THIS ONE, FILED DECEMBER 22, 2003 (IN FILE NUMBER BMPEDT-20031222ABT).

REGARDING THE PREDICTED INTERFERENCE TO KOCE-TV ON CHANNEL 50, THE COMMISSION HAS ON FILE A LETTER BETWEEN THE ATTORNEYS FOR THE LICENSEES OF KJLA AND KOCE ((A COPY OF WHICH IS CONTAINED IN THE FILE ATTACHED TO EXHIBIT 40) IN WHICH KOCE AGREED TO ACCEPT INTERFERENCE FROM KJLA-DT TO GREATER THAN THE DE MINIMIS LIMIT OF INTERFERENCE POPULATION -- SPECIFICALLY TO 2.5 PERCENT INTERFERENCE POPULATION. ALTHOUGH THE ACTUAL ANTENNA PATTERN HAS NOT CHANGED, BECAUSE OF THE COMPLEXITY OF THE PATTERN, THE WAY IN WHICH THE PATTERN IS REPRESENTED FOR ADMINISTRATIVE PURPOSES HAS BEEN CHANGED TO A MORE CONSERVATIVE APPROACH, USING THE MAXIMUM RADIATION AT ANY DEPRESSION ANGLE AT EACH AZIMUTH VALUE TO CHARACTERIZE THE FIELD IN THAT DIRECTION. THE RESULT IS A CALCULATION OF 3.9 PERCENT INTERFERENCE TO KOCE-TV INSTEAD OF 2.5 PERCENT, EVEN THOUGH THE SAME ACTUAL PATTERN IS INVOLVED. SINCE KOCE-TV NOW HAS A CONSTRUCTION PERMIT TO COLLOCATE ITS TRANSMITTER AT MT WILSON AS PART OF THE JOINT OPERATION THERE, IT IS EXPECTED THAT ANY INTERFERENCE ACTUALLY CAUSED WILL BE SHORT LIVED. AS SHOWN ON THE LIGHTLY SHADED LINE BELOW THE LOWER OF THE TWO HEAVILY SHADED LINES IN TABLE 1, THE SITUATION WITH RESPECT TO INTERFERENCE TO KOCE-TV WILL DRAMATICALLY IMPROVE ONCE KOCE MOVES TO MT WILSON. KOCE-TV IS CURRENTLY ON A CONSTRUCTION SCHEDULE THAT CALLS FOR COMPLETION OF THE MT WILSON FACILITIES IN MARCH, 2004. EVEN IF THERE IS SOME SLIPPAGE IN THAT SCHEDULE, THE DE MINIMIS LIMIT WILL BE EXCEEDED FOR ONLY A FEW MONTHS. AS INDICATED BY A NEW LETTER (A COPY OF WHICH IS CONTAINED IN THE FILE ATTACHED TO EXHIBIT 40), THE LICENSEE OF KOCE IS WILLING TO ACCEPT THE LEVEL OF INTERFERENCE THAT WILL RESULT FROM THE OPERATION OF KJLA-DT AT FULL FACILITIES DURING THE CONSTRUCTION OF KOCE-TV. THUS, WITH RESPECT TO INTERFERENCE TO KOCE, THERE IS NO REASON FOR THE COMMISSION NOT TO PROCEED TO GRANT OF THE CONSTRUCTION PERMIT MODIFICATION CURRENTLY SOUGHT.


Attachment 48


Exhibit 49
Description:
PRINCIPAL COMMUNITY COVERAGE

(EXTRACT FROM COMPLETE TECHNICAL STATEMENT ATTACHED AT EXHIBIT 40.)

AS REQUIRED BY SECTION 73.625(A)(1), THE DTV TRANSMITTER LOCATION MUST BE CHOSEN SO AS TO PUT A MINIMUM F(50,90) FIELD STRENGTH OF 48 DBU OVER THE ENTIRE PRINCIPAL COMMUNITY TO BE SERVED. (FOOTNOTE OMITTED.) SECTION 73.625(A)(2) FURTHER REQUIRES THAT THE LOCATION OF THE ANTENNA MUST BE SO CHOSEN THAT THERE IS NOT A MAJOR OBSTRUCTION IN THE PATH OVER THE PRINCIPAL COMMUNITY TO BE SERVED. AS DEMONSTRATED BY THE 48 DBU CONTOUR ON THE COVERAGE MAP OF FIGURE 11, (IN THE FILE ATTACHED AT EXHIBIT 40) TAKEN ALONE, THE TRANSMITTER LOCATION CHOSEN, COMBINED WITH THE OTHER CHARACTERISTICS OF THE TRANSMISSION SYSTEM, DOES DELIVER THE MINIMUM REQUIRED FIELD STRENGTH OVER THE ENTIRE PRINCIPAL COMMUNITY TO BE SERVED. CHECKLIST QUESTION NUMBER 3, WHICH ASKS IF THE DTV COVERAGE CONTOUR OF THE PROPOSED FACILITY WILL ENCOMPASS THE ALLOTTED PRINCIPAL COMMUNITY, THEREFORE IS CORRECTLY ANSWERED YES. BUT IT HAS BEEN ANSWERED NO IN THIS INSTANCE IN AN ABUNDANCE OF CAUTION WITH RESPECT TO OBSTRUCTIONS IN THE PATH THAT OCCUR WITHIN THE PRINCIPAL COMMUNITY.

AS HAS BEEN POINTED OUT IN ALL OF THE KJLA-DT APPLICATIONS HERETOFORE FILED, SEPARATE STUDIES USING SHADOWING TECHNIQUES DEMONSTRATE, THAT THERE IS A CERTAIN AMOUNT OF BLOCKAGE OF SOME PORTIONS OF VENTURA WHEN SERVED FROM MT. WILSON. TO PUT THE AMOUNT OF BLOCKAGE IN CONTEXT, SIMILAR STUDIES WERE CONDUCTED USING THE REFERENCE SITE INCLUDED IN THE FCC PLAN. THE RESULTS SHOW A VERY SMALL INCREASE IN THE BLOCKAGE WHEN MOVING FROM SOUTH MOUNTAIN TO MT. WILSON. THE DIFFERENCE IS MINIMAL, AMOUNTING TO A DIFFERENCE OF ABOUT 1,500 HOUSEHOLDS BETWEEN THE TWO SITES A DIFFERENCE OF ONLY ABOUT 4 PERCENT OF THE TOTAL NUMBER OF HOUSEHOLDS SERVED IN VENTURA. SHADOW STUDIES ARE BASED PURELY UPON LINE-OF-SIGHT AND DO NOT ACCOUNT FOR REFLECTIONS AND DIFFRACTION THAT WILL CAUSE SIGNALS TO REACH PLACES BEYOND LINE-OF-SIGHT. WITH ANALOG TRANSMISSION, SUCH SIGNALS WERE GENERALLY UNUSABLE BECAUSE OF THE ECHOES (GHOSTS) CREATED BY THE REFLECTIONS. DIGITAL RECEIVERS, ON THE OTHER HAND, WILL BE ABLE TO MAKE USE OF SUCH SIGNALS AS MANUFACTURERS INCLUDE HIGH PERFORMANCE ADAPTIVE EQUALIZERS IN THEIR RECEIVER DESIGNS. SO, IT CAN BE EXPECTED THAT THE NUMBER OF HOUSEHOLDS REACHED FROM MT. WILSON WILL INCREASE WITH TIME AS THE TECHNOLOGY IMPROVES.

STUDIES OF THE TERRAIN IN THE AREA SHOW THAT THERE ARE NO PRACTICAL LOCATIONS FROM WHICH IT MIGHT BE POSSIBLE TO PROVIDE SERVICE TO ALL OF VENTURA WITHOUT SOME AMOUNT OF BLOCKAGE. IT IS WELL KNOWN THAT IT IS NOT POSSIBLE TO CONSTRUCT ANY ANTENNA SUPPORTING STRUCTURES IN THE LOS ANGELES AREA EXCEPT AT THE FEW EXISTING ANTENNA FARMS, OF WHICH MT. WILSON IS THE PRINCIPAL ONE. GIVEN THAT THE CURRENT SITE USED BY KJLA WILL NOT BE AVAILABLE TO KJLA-DT (AS PREVIOUSLY EXPLAINED), THAT THERE ARE NUMEROUS BENEFITS TO THE PUBLIC IN IMPROVING THE COVERAGE ACHIEVED BOTH BY KJLA-DT AND BY KOCE-DT, (FOOTNOTE OMITTED.) AND THE COMMISSIONS ACKNOWLEDGEMENT OF THE BENEFITS OF COMMON FACILITIES, ESPECIALLY FOR NEW DIGITAL STATIONS AND IN THE LOS ANGELES AREA, IT IS SUBMITTED THAT THE AMOUNT OF OBSTRUCTION INVOLVED IS SUFFICIENTLY SMALL SO THAT COMPLIANCE IS ACHIEVED WITH SECTION 73.625(A)(2). SHOULD THE COMMISSION REACH A DIFFERENT CONCLUSION, THEN A WAIVER OF THE OBSTRUCTION REQUIREMENT IS HEREBY REQUESTED. (FOOTNOTE OMITTED.)

Attachment 49


Exhibit 50
Description:
ENVIRONMENTAL IMPACT / RADIO FREQUENCY RADIATION

(EXTRACT FROM COMPLETE TECHNICAL STATEMENT ATTACHED AT EXHIBIT 40.)

NONE OF THE CONDITIONS SPECIFIED IN SECTION 1.1307 THAT WOULD REQUIRE THE PREPARATION OF AN ENVIRONMENTAL ASSESSMENT PERTAIN WITH RESPECT TO THE PROPOSED FACILITY AT MT. WILSON. IN PARTICULAR, BECAUSE IT WILL BE PART OF AN ESTABLISHED ANTENNA FARM, THE NEW OPERATION DOES NOT IMPLICATE MANY OF THE CAUSES FOR FURTHER INVESTIGATION AND PREPARATION OF FURTHER REPORTS.

WITH RESPECT TO RADIO FREQUENCY RADIATION EXPOSURE, OET BULLETIN 65 PROVIDES METHODS FOR EVALUATING THE LEVEL OF EXPOSURE FOR BOTH EMPLOYEES (OCCUPATIONAL/CONTROLLED SITUATIONS) AND NON-EMPLOYEES (GENERAL POPULATION/UNCONTROLLED SITUATIONS). THE COMBINATION OF THE ANTENNA RADIATION PATTERN, AS PROVIDED IN THE MANUFACTURERS TECHNICAL SPECIFICATIONS, WITH THE ANTENNA HEIGHT ABOVE GROUND LEVEL AND THE OPERATING POWER LEVEL INDICATE THAT THE POTENTIAL EXPOSURE WOULD BE LESS THAN 5 PERCENT OF THE MAXIMUM PERMISSIBLE EXPOSURE (MPE) LIMIT FOR GENERAL POPULATION / UNCONTROLLED SITUATIONS. SPECIFICALLY, APPLICATION OF THE FORMULAS PROVIDED IN OET 65 YIELDS A VALUE OF LESS THAN ONE PERCENT OF THE MPE. THUS THE PROPOSED OPERATION IS CATEGORICALLY EXCLUDED FROM HAVING TO SUBMIT A DETAILED RF EXPOSURE ANALYSIS OF THE SITE.

NOTWITHSTANDING THE FOREGOING, KJLA, LLC RECOGNIZES ITS RESPONSIBILITY FOR THE SAFETY AND HEALTH OF EMPLOYEES AND CONTRACTORS WHEN EXPOSED TO RF RADIATION CONDITIONS. IT WILL WORK COOPERATIVELY WITH OTHER BROADCASTERS SHARING THE MT. WILSON ANTENNA FARM TO COORDINATE ACTIVITIES SO AS TO MAINTAIN A SAFE ENVIRONMENT UNDER ALL CONDITIONS.


Attachment 50