Analysis of Potential Repacking Issues Affecting KSAT Channel 12 San Antonio, TX January 18, 2013

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Analysis of Potential Repacking Issues Affecting KSAT Channel 12 San Antonio, TX January 18, 2013 KSAT San Antonio, TX (facility ID 53118) currently operates on channel 12 with an effective radiated

1 Analysis of Potential Repacking Issues Affecting KSAT Channel 12 San Antonio, TX January 18, 2013 KSAT San Antonio, TX (facility ID 53118) currently operates on channel 12 with an effective radiated power (ERP) of 65 kw using a directional antenna with a radiation center above mean sea level (RCAMSL) of 607 meters. The license authorizing this operation (BLCDT ABH) was granted on December 18, The construction permit (BPCDT AAL) for this facility was granted on September 10, 2012 in response to an application that was accepted for filing on February 28, 2011 and was to replaced the then existing license BLCDT AED that authorized and ERP of 22.2 kw. Although the construction permit application had no domestic conflicts the grant was delayed due to the need for Mexican coordination. During the delay, the Federal Communications Commission (FCC) staff suggested that KSAT apply for a Special Temporary Authority (STA) for 37 kw ERP since that level of power was previously approved by Mexico and therefore the STA could be granted without further Mexican approval. The STA application for 37 kw was accepted for filing on July 9, 2012, was granted (BDSTA AAK ) on August 2, 2012 and KSAT commenced operation at 37 kw. P. O. Box 907 Warrenton, VA Phone Fax

2 Included with the STA application was a study prepared by Meintel, Sgrignoli & Wallace (MSW) that indicated the 65 kw facility proposed by KSAT would not cause any interference to any known existing station or planned Mexican stations. Although KSAT is currently licensed for 65 kw, a concern has been raised that this facility might not be fully protected in a spectrum repacking that could arise from the Notice of Proposed Rulemaking (Expanding the Economic and Innovation Opportunities of Spectrum Through Incentive Auctions) FCC Docket No (NPRM). This NPRM is the result of an Act of Congress Middle Class Tax Relief and Job Creation Act of 2012 (Act) that granted the FCC authority to auction broadcast spectrum that may become available from broadcasters who voluntarily give up their spectrum 1 in return for some level of compensation. The returned spectrum will then be auctioned for flexible use (assumed to be wireless broadband). In that the desired spectrum is the upper portion of the UHF broadcast band, stations that do not participate in the auction or those who select the possible option of moving from UHF to VHF spectrum will need to change channel, commonly referred to as repacking. The concern for KSAT is that the Act states that in making any reassignments or reallocations the Commission shall make all reasonable efforts to preserve, as of the date of the enactment of this Act, the coverage area and population served of each broadcast television 1 There are various proposed options, in addition to just relinquishing there channel, that could be available to broadcasters who desire to participate in the auction including moving from UHF to VHF or sharing a channel with another station. P. O. Box 907 Warrenton, VA Phone Fax

3 licensee, as determined using the methodology described in OET Bulletin 69 of the Office of Engineering and Technology of the Commission. As of the date when the Act was enacted, KSAT had a license to operate at an ERP of 22.2 kw (BLCDT AED), but it was operating at 37 kw pursuant to STA (BDSTA AEJ) at that time (and not the thenlicensed 22.2 kw). In view of this concern a study was undertaken to determine the impact on KSAT if the currently licensed service is not protected. The primary reason for increasing the power from 22.2 kw to 65 kw was to mitigate service problems that surfaced after KSAT made the transition to digital. KSAT had previously operated analog on channel 12 and transitioned its digital operation from UHF channel 48 to its former analog channel. After the transition the station begin receiving complaints of poor service on digital channel 12. Although the power increase expanded the service contour of KSAT it did not significantly change the service population (see attached service comparisons and plots) since the majority of the population is near to the transmitter. The power increase did however significantly improve the service margin within the service area and consequently greatly improved the reception potential. The service margin is the measure of how much the signal level exceeds the service threshold (the point at which service just becomes available). It is noted that the increase in power necessitated the use of a directional antenna; however, most areas receive P. O. Box 907 Warrenton, VA Phone Fax

4 a much higher level of signal and even in the modest null of the antenna most of it is offset by the higher level of input power. The study that was conducted evaluated the service using the FCC OET Bulletin 69 methodology 2 on a cell-by-cell basis using 0.5 km cells. This entailed evaluating more than 150,000 cells and the results indicated that approximately 90% of the population within the KSAT service area would receive an improved level of service with the new antenna at the power increased to 65 kw. It was also determined that a similar percentage of improvement would also be realized with the STA power of 37 kw but obviously with a smaller improvement in the service margin. In view of the above it would negate the service improvement for KSAT viewers that has been accomplished by the new antenna and accompanying power increase if the current licensed facility is not fully protected in any repacking. The above was prepared by: William R. Meintel Partner, Meintel, Sgrignoli & Wallace 2 The FCC OET Bulletin 69 methodology evaluates service by dividing the service area into a grid of essentially square cells and then computing the service for each cell. P. O. Box 907 Warrenton, VA Phone Fax

5 Predicted Service Comparsion for KSAT Channel 12 San Antonio, TX Predicted Service Predicted Service Service kw 65 kw vs 22.2 kw State County Population Households Population Households Population Households TEXAS ATASCOSA 38,628 12,816 38,628 12, TEXAS BANDERA 13,864 5,459 13,027 5, TEXAS BASTROP 0 0 1, , TEXAS BEE 28,091 7,515 16,705 5,010-11,386-2,505 TEXAS BEXAR 1,392, ,942 1,392, , TEXAS BLANCO 3,602 1,393 3,143 1, TEXAS CALDWELL 30,833 10,386 31,727 10, TEXAS COMAL 77,961 29,041 77,931 29, TEXAS DEWITT 12,476 4,325 16,911 6,018 4,435 1,693 TEXAS FRIO 16,209 4,726 14,370 4,624-1, TEXAS GILLESPIE TEXAS GOLIAD 1, , TEXAS GONZALES 17,380 6,315 18,499 6,733 1, TEXAS GUADALUPE 89,023 30,900 89,023 30, TEXAS HAYS 81,744 27,939 81,376 27, TEXAS KARNES 15,446 4,454 15,446 4, TEXAS KENDALL 22,463 8,119 20,784 7,579-1, TEXAS KERR 6,127 2,433 1, ,799-1,922 TEXAS LA SALLE TEXAS LAVACA ,961 2,784 6,852 2,738 TEXAS LIVE OAK 9,894 3,162 9,286 2, TEXAS MCMULLEN TEXAS MEDINA 39,220 12,847 39,121 12, TEXAS TRAVIS 5,141 1,779 8,360 3,084 3,219 1,305 TEXAS UVALDE 1, , TEXAS WILSON 32,408 11,038 32,408 11, Total 1,937, ,211 1,931, ,520-5,

6 Predicted Service Comparsion for KSAT Channel 12 San Antonio, TX Predicted Service Predicted Service Service Gain / kw 37 kw vs 22.2 kw State County Population Households Population Households Population Households TEXAS ATASCOSA 38,628 12,816 38,628 12, TEXAS BANDERA 13,498 5,306 13,027 5, TEXAS BASTROP 0 0 1, , TEXAS BEE 16,973 5,115 16,705 5, TEXAS BEXAR 1,392, ,942 1,392, , TEXAS BLANCO 3,222 1,247 3,143 1, TEXAS CALDWELL 29,103 9,763 31,727 10,677 2, TEXAS COMAL 77,758 28,948 77,931 29, TEXAS DEWITT 6,136 2,446 16,911 6,018 10,775 3,572 TEXAS FRIO 16,132 4,694 14,370 4,624-1, TEXAS GILLESPIE TEXAS GOLIAD 1, , TEXAS GONZALES 16,996 6,151 18,499 6,733 1, TEXAS GUADALUPE 89,023 30,900 89,023 30, TEXAS HAYS 77,323 26,427 81,376 27,811 4,053 1,384 TEXAS KARNES 15,446 4,454 15,446 4, TEXAS KENDALL 21,408 7,761 20,784 7, TEXAS KERR 1, , TEXAS LA SALLE TEXAS LAVACA 0 0 6,961 2,784 6,961 2,784 TEXAS LIVE OAK 9,391 2,965 9,286 2, TEXAS MCMULLEN TEXAS MEDINA 39,134 12,807 39,121 12, TEXAS TRAVIS ,360 3,084 8,240 3,040 TEXAS UVALDE TEXAS WILSON 32,408 11,038 32,408 11, Total 1,899, ,323 1,931, ,520 32,516 12,197

7 Predicted Service Comparsion for KSAT Channel 12 San Antonio, TX Predicted Service Predicted Service Service kw 65 kw vs 37 kw State County Population Households Population Households Population Households TEXAS ATASCOSA 38,628 12,816 38,628 12, TEXAS BANDERA 13,864 5,459 13,498 5, TEXAS BASTROP TEXAS BEE 28,091 7,515 16,973 5,115-11,118-2,400 TEXAS BEXAR 1,392, ,942 1,392, , TEXAS BLANCO 3,602 1,393 3,222 1, TEXAS CALDWELL 30,833 10,386 29,103 9,763-1, TEXAS COMAL 77,961 29,041 77,758 28, TEXAS DEWITT 12,476 4,325 6,136 2,446-6,340-1,879 TEXAS FRIO 16,209 4,726 16,132 4, TEXAS GILLESPIE TEXAS GOLIAD 1, , TEXAS GONZALES 17,380 6,315 16,996 6, TEXAS GUADALUPE 89,023 30,900 89,023 30, TEXAS HAYS 81,744 27,939 77,323 26,427-4,421-1,512 TEXAS KARNES 15,446 4,454 15,446 4, TEXAS KENDALL 22,463 8,119 21,408 7,761-1, TEXAS KERR 6,127 2,433 1, ,492-1,795 TEXAS LA SALLE TEXAS LAVACA TEXAS LIVE OAK 9,894 3,162 9,391 2, TEXAS MCMULLEN TEXAS MEDINA 39,220 12,847 39,134 12, TEXAS TRAVIS 5,141 1, ,021-1,735 TEXAS UVALDE 1, , TEXAS WILSON 32,408 11,038 32,408 11, Total 1,937, ,211 1,899, ,323-38,278-11,888

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 In the Matter of ) ) Expanding the Economic and Innovation ) GN Docket No. 12-268 Opportunities of Spectrum Through Incentive ) Auctions