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KRKO files License to Cover today---16 parties file Petitions & Objections!

Well, I thought the KRKO thing was pretty much of a done deal. Today KRKO filed their license to cover their construction permit. But not without a fight...again!

Here's the public notice: http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-290356A1.pdf
See page 6 of the notice. This came out today in the FCC's Daily Digest.

I am surprised that Snohomish County is still objecting. I thought they approved the permit! ???
 
FMSteve said:
Well, I thought the KRKO thing was pretty much of a done deal. Today KRKO filed their license to cover their construction permit. But not without a fight...again!

Here's the public notice: http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-290356A1.pdf
See page 6 of the notice. This came out today in the FCC's Daily Digest.

I am surprised that Snohomish County is still objecting. I thought they approved the permit! ???

Could it be for their 1520 facility?

My guess is the public can still object at any time even after the power increase. And 16 protesters from individuals to Snohomish County itself carries a lot of weight......

Why? Well interference and scenery issues aside, KRKO is just syndicated sports shows and not much else. If KRKO provided SIGNIFICANTLY more local content that Snohomish County NEEDS, I think fewer people would have a problem with it. A canned sports blabber station isn't exactly a NECESSITY in SnoCo.......
 
1520 doesn't seem like a wise choice to me. KGDD in Oregon City is totally dominant up here at nights (sometimes even in the daytime), as I'm sure it also is in the Everett area.
 
Dan said:
1520 doesn't seem like a wise choice to me. KGDD in Oregon City is totally dominant up here at nights (sometimes even in the daytime), as I'm sure it also is in the Everett area.

It is. KGDD would absolutely whip their butts on 1520......
 
Really doesn't matter if the complaints really have anything material to do with KRKO's license application. These complaints are done to delay and be expensive to KRKO. The FCC will continue to get onjections even after the license is granted. I bet the complaints and lawsuits will continue for years.

In Denver KOA was there first in Parker CO way back in '59. However, if they make even a small change to the way the property looks they get a rash of complaints from the neighbors and visits from the city.
 
It is a good thing that whomever owns that station is a private corporation because with the on-going investment to fight the NIMBY's combined with the apparent lackluster technical results, most board of directors would be looking for blood. Especially in this economy. And all this mess for what? A station that barely out-plays the original version and a AM to boot? Yikes!
 
It's not Snohomish County itself that filed an objection. Whoever's objection it was, it was cc'ed to the County, and whatever low-level employee at the FCC entered the filing into the computer typed in that it was from "The County of Snohomish".

Ditto with the objection from "Board of Commerissioners" (sic). The filing was addressed to the "Board of Commissioners of the FCC".
 
Dan said:
1520 doesn't seem like a wise choice to me. KGDD in Oregon City is totally dominant up here at nights (sometimes even in the daytime), as I'm sure it also is in the Everett area.

I have never understood why Skotdal needs the additional towers to put 1520 on the air from the new KRKO site. The requested 20-kW day facilities on 1520 are ND, so they definitely need no new towers. But it appears to me that the four towers already built for KRKO could synthesize almost the same night pattern as has been requested for 1520. Might turn out that 50-kW-N wouldn't quite work from the already built towers, but surely something close to 50 kW ought to work. I suspect that a lot of the complaints would just go away if Skotdal gave up trying to add still more towers.
 
The objections posted on the FCC website are related to the License to Cover application that is pending before the FCC for KRKO. A commission staffer simply misidentified a couple of the letters. For example, "THE COUNTY OF SNOHOMISH," is the beginning text of the second paragraph from a letter writer who lives near the site. Bryant - good for you for recognizing this. This group of 16 people is essentially the same core group of opponents who have fought the project since 2002. The arguments raised in the informal objections have already been heard and adjudicated - multiple times. They have a right to file informal objections. They've availed themselves of the opportunity. Their arguments will be heard again. We're prepared to address the merits when the time comes.

Boiseengineer isn't far from the truth, but in this case, some of the opponents really believe AM radio causes health problems. Science is not on their side. At least one opponent has political aspirations and is leveraging the exposure to further a future political career.

The post indicating the new 1380 signal has been lackluster must be basing that assumption on their own personal expectations of what the signal would be. The signal is exactly what we expected it to be, and slightly better at night than we thought it would be. It's vastly improved from the old transmitter site if you look at the field strength measurements. I should know. I made half of them. And, we still have a substantial amount of work left to do. Some of you may notice the signal sounds more quiet than others on the AM band. Our modulation is way down until we can get a better link to the transmitter site. Loudness will improve range and it's one of the things still on our "to-do" list. The station isn't owned by a corporation, though. Some of you already know the station is licensed to a local family - one of the only stations in Puget Sound that is still licensed to a family, and the only one with more than 5,000 watts to be licensed to a local family.

As for 1520 AM, we believe we'll be able to commence construction this summer. We won our appeal with the County. The opponents withdrew the majority of their superior court appeal last week after they realized they were going to lose on the merits. Their remaining appeal issue boils down to whether the FCC has sole jurisdiction to regulate all portions of the electromagnetic spectrum or whether every local city, county, parish, or state in America gets to reserve a portion of the regulation and make their own rules.

1520 AM will have a limited nighttime signal covering Snohomish, Lake Stevens, Mill Creek, Everett, and Mukilteo - about 160,000 people. The daytime signal will approximate the signal from 1380 and cover 1.5 - 2 million people. We have three or four potential scenarios for this radio station. We're evaluating all of them right now and will make a final decision at the time we receive Program Test Authorization from the FCC for this radio station. That may occur this fall. 1520 requires two additional antenna structures because the directional array is a four-element, in-line on a specific bearing whereas the 1380 directional array is a four-element parallelogram. The directional signals for 1380 and 1520 appear to point in the same direction, but they actually are centered on different bearings to the northwest, and the null portion of the signal is completely different for both stations. We looked at using the 1380 array for 1520. 1520 couldn't cover Snohomish two miles to the north in that configuration at night and there were engineering problems that couldn't be overcome. 1520 will be 50kW daytime and 50kW nighttime. Ironically, even though both stations are omni-directional daytime, they can't share the same daytime radiator because it creates problems that can't be fixed through engineering.

TVRadioGuru, to your point about the on-going "investment" to fight the NIMBY's, I tend to think of it as money out the window, for us and for the opponents. The opponents have expended or have exceeded $750,000 in fighting us since 2002 and they have very little to show for it. We made all the compromises they asked for in 2002 - self-supporting structures, height reductions, tree planting, lighting elimination, etc., but that wasn't really what they wanted - they wanted the project to go away. From our side, the permitting costs ran double the costs of construction. It's been a huge waste of time and money. There is no question that we could have made a better investment in something else if money was the only issue.

Many factors have contributed to our desire to pursue this project, but the most important one is that we believe in the merits of the project and the fact that regardless of the programming today, tomorrow, or yesterday, and regardless of how people perceive we've operated the radio station, the signal is an asset to the community by itself. It's more of an asset as a 50kW signal than it is as a 5kW signal, from building penetration, to reach, to emergency coverage. Opportunities to improve coverage in the over-crowded AM band are extremely rare. The old 5kW KRKO signal was designed to cover a population that existed in 1958 - before I-5 was completed, and the nighttime signal stopped dead two kilometers from the site in one direction. Rimshot directional 5kW signals are going dark around the country or converting to foreign music with no staff. They can't protect their programming from poaching (KRKO has been raided multiple times since 1993 and at least two times 90% of the programs were taken from KRKO in one shot), they can't keep a sales staff because good sales people move to stations with bigger signals so they can make more money, and they can't even get a shot at showing up in the ratings because their signals seldom make it beyond one county.

We have a strong local program that allows us to shift from sports to major topics of local importance when necessary, and we do that. The program has a large, responsive audience that shows up at station events. Do we want to do more? Sure, but the other part of the equation is that the station needs more revenue to do that, and one way to generate more revenue for better programming is to create a signal that allows you to call on five times more businesses than you could in the past.
 
Andrew Skotdal said:
We looked at using the 1380 array for 1520. 1520 couldn't cover Snohomish two miles to the north in that configuration at night and there were engineering problems that couldn't be overcome. 1520 will be 50kW daytime and 50kW nighttime. Ironically, even though both stations are omni-directional daytime, they can't share the same daytime radiator because it creates problems that can't be fixed through engineering.

I take it, then, that you plan to modify your application for 1520. The application that CDBS displays clearly shows 20 kW during non-critical daytime hours. The 50 kW daytime operation, using the night pattern. applies only during CH. As for your inability to share towers between 1380 and 1520, I am skeptical of that claim, unless there are economic factors that you consider insurmountable. The 140-kHz frequency difference is 9.2% of the higher frequency. I admit that's tight, but there are other high-power AM diplexes that are closer--1370 and 1500 in San Jose, for example. One of the oldest diplexes in radio history (no longer exists, but it worked way back in the 1930s) involved 560 and 610 in San Francisco. That spacing was only 8.2% of the higher frequency.

As for the pattern differences, 1520's CH/N pattern has a broad and deep minimum toward KOKC. It should be possible to replicate that with a parallelogram array. The interesting minimum (and it's the lowest minimum) is the very narrow one at 193 degrees. My assumption is that this minimum is intended to protect KFBK's 0.5 mV/m groundwave contour from your 25 microvolt/meter 10% skywave even though KFBK itself is at 177 degrees. If that protection is the reason for this very narrow minimum (it's only a few degrees wide) and the 193-degree minimum is not simply an accidental fallout of the design, well, you might have trouble protecting both KFBK and KOKC at the same time with a parallelogram design. I can't say; I'm not enough of an expert on DA design. But I suspect that such a narrow minimum will wind up being at least partially filled by a pattern augmentation. Four-tower in-lines don't have a wonderful reputation; many of them exhibit high RSS/RMS ratios, a predictor of unstable patterns. From what I've heard, four-tower parallelograms (and even six-tower parallelograms) are much more versatile and, in the end, easier to adjust.
 
I think Thomas Gorton and the rest @ Hatfield & Dawson have this figured out. If they say it won't work with a parallelogram, it wont.
 
boiseengineer said:
I think Thomas Gorton and the rest @ Hatfield & Dawson have this figured out. If they say it won't work with a parallelogram, it wont.
You'd think so, wouldn't you? But that's the easy answer. Take a look at the location of the towers. It sure looks as if they were placed with 1520 at least as much in mind as 1380. First off, although both Mr Skotdal and I have referred to the 1380 array as a parallelogram, that's not strictly true. Maybe trapezoid would be more accurate. The distance between towers 1 and 4 is greater than the distance between towers 2 and 3. The azimuths of both the 1-4 and 2-3 pairs lie at 195 degrees. The azimuth to KGDD is 193 degrees. Could be a coincidence, I guess; or is it? Now look at the azimuth to KOKC--116 degrees. It's not so easy to determine the azimuth of KRKO's 2-3 line but it's got to be darned close to 116 degrees. The 1-2 line is at 127 degrees. Now look at the height of the tall tower (#4): 181 degrees at 1520. Ideal for 1520--even though, according to the 1520 application at CDBS, 1520 will not use this tower either by day or by night. Why? Now take a look at the night array of WBBR in New York and at KRKO's night pattern. Hard (at least for me) to conclude that the WBBR array was not the prototype for the KRKO design. BUT now compare WBBR's tower heights and spacings with the KRKO towers operated at 1520. The 1520/1130 comparison is much closer than the 1380/1130 comparison. Also, remember that the WBBR array was designed to protect a pair of stations (CKWX and KWKH). True, those stations are closer together in azimuth (52 degrees) than the 77 degrees between KOKC and KGDD and WBBR doesn't protect either one to the degree that 1520 would have to protect its principal pair, but I find the parallels striking. Coincidental perhaps, but maybe not. Maybe Mr Gorton started with the idea of using all four towers for both stations and gave up for some reason. I'd be very interested to find out. If my scenario is correct, I think the reason for abandoning the idea of sharing all four KRKO towers is more likely financial than technical--maybe related to minimizing the cost of disrupting KRKO's operation during construction, although the cost of two additional towers can't be trifling either.
 
Hi Dan. I'll quote your comments, then respond:

>Dan Strassberg>"As for your inability to share towers between 1380 and 1520, I am skeptical of that claim, unless there are economic factors that you consider insurmountable."

A broader perspective is required here. First, KRKO has to be shut down for the 1520 implementation either way. Whether the two arrays share all, some, or none of the structures, the cost in downtime to KRKO is roughly the same. The cost of tuning units/traps/filters is also roughly the same since the arrays are in such close proximity to each other. On the other hand, we could have avoided a substantial amount of hearing and trial days (perhaps 20 or more) and shaved YEARS off the permitting if we could have shared the KRKO trapezoid for 1520. That’s a tremendous incentive to try to make a pure diplex work…land-use litigation costs excessively MORE than the construction. Nobody was more incentivized to do a pure diplex on the KRKO trapezoid than me. So, you're right in one sense, but the economic factors were IN FAVOR of diplexing on the KRKO trapezoid not against it. If you've ever hired a competent land-use attorney to prepare for just one hearing day, you'll recognize how staggering it is that we've been through 50 now with more to come. Four antenna elements versus eight on a site? That's a no brainer if it's an option.

>Dan Strassberg>"If my scenario is correct, I think the reason for abandoning the idea of sharing all four KRKO towers is more likely financial than technical--maybe related to minimizing the cost of disrupting KRKO's operation during construction"

The scenario is not correct. See my previous response.

>Dan Strassberg>"...you might have trouble protecting both KFBK and KOKC at the same time with a parallelogram design. I can't say; I'm not enough of an expert on DA design"

That's ok. We agree completely on this point. While we're at it, what about Class A 1510 KGA in Spokane (which you didn't mention) PLUS stations you did mention like Class A KFBK, Class A KOKC AND KGDD? How about the physical interactions between dissimilar radiators (as you know, the elements interact as they stand even without power applied to them)? What about current distribution and magnitude? What about bandwidth assumptions at the common point related to IBOC implementation? (Everybody save your breath on personal feelings regarding IBOC...I like it. It's working on our signal just fine. It won't work on many AM arrays, and there are a lot of people who try to make it work who don't know what they are doing while others want it to fail.) What about the fact that the radiators are elevated and all the steel platforms supporting the antenna elements and the tuning/filtering units interact with the array? (We're in a flood plain). We could REALLY get some Ph.Ds. excited at a kegger going into this.

>Boise Engineer>"I think Thomas Gorton and the rest @ Hatfield & Dawson have this figured out. If they say it won't work with a parallelogram, it wont."

Sometimes the answer IS that simple. Boise engineer is right, except he left out that James Banks (Kintronic), Bobby Cox (Kintronic), Tom King (Kintronic), Stephen Lockwood, Tom Gorton, James Hatfield, and Ben Dawson have this figured out. They ran and/or proofed MINNINEC models until their eyeballs fell out. Lockwood, by the way, is guided by inspired genius in directional antenna design. When his hand hits the mouse, it's like witnessing Michelangelo's Creation of Adam in the Sistine Chapel. Well, ok, maybe Scotty offering up the chemical architecture of plexiglas in Star Trek IV, The Voyage Home.

This discussion demonstrates perfectly one of the problems with local land use hearings. Intelligent people wade into areas where their expertise is limited and then believe they know enough to cry foul (or at least confuse a hearing examiner - which is all they need to do). Others assume the theories make sense because they have even less knowledge and pretty soon, 500 angry people show up in opposition at a hearing swearing it's the truth. Bear in mind, Dan, I'm not ascribing any of these motivations to you. I believe at the end of the day you looked into this because you are curious by nature, want to learn more, and that you DIDN'T mean to imply that my prior statements were less than forthcoming. We spent years having to explain in minute detail why each opponent theory ultimately falls apart. A little skepticism is healthy, though, and it's heartening to know someone other than an opponent is willing to spend so much time thinking about us without charging. Grab a copy of NEC or MINNINEC and start running the calculations and it will all make sense. The colorful tower geometry models can really knock the cash out of your wallet, but they are suitable for framing.
 
The radio business is better for having guys like Andy Skodahl around. There aren't many of them left. We should all admire his tenacity and committment ...and good sense of humor. To have gotten through all those hearings without being arrested for bodily assault on some of the 'concerned citizens' is amazing.
 
Jackson Dell Weaver said:
The radio business is better for having guys like Andy Skodahl around. There aren't many of them left. We should all admire his tenacity and committment ...and good sense of humor. To have gotten through all those hearings without being arrested for bodily assault on some of the 'concerned citizens' is amazing.

Agreed...Andy is one of the best men i've ever had the honor of working for....I wish KRKO the best of luck, and I really miss seeing them on a regular basis...

Andy knows radio and talent, that is for sure!!
 
It is my understanding that KGA will give up its Class A standing in order for a co-owned San Francisco Bay area station to improve its coverage area. I thought that was what encouraged this 1520 application in the first place.
 
All other parties outside of the KGA/KPIG applications have to wait until after KGA is issued their new class B license. Only then can they file any proposal that protects KGA as a class B station.
 
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