KSFW/2 RELOCATION APP

[Bob E. Nelson]

For we (the few, the proud) geeks who care about this stuff, HCCN's KSFW/2 has filed an application to relocate from the Collinsville tower (200 watts) to the Bank of America Building in downtown Dallas with a full 300 watts, the maximum for a low-power digital on VHF:

http://licensing.fcc.gov/cgi-bin/ws...973&Service=LD&Form_id=346&Facility_id=130934

This application is interesting (at least to OTA nerds) in a few respects:

1). It comes just weeks after KSFW/2 fired up the facility in Collinsville.

2). How will channel mapping on PSIP be done? Since the new facility will be in the Dallas DMA, will it have to use 43, the RF channel for KDTN/2?

3). Of course, whether it even gets approved is an open question. Since the proposed RF-2 facility is adjacent to KHPK on RF-3, does the downtown Dallas site meet the interference criteria?

4). Could this be an incremental move to eventually get the plant ultimately located out in Cedar Hill? As I understand it (mostly from Trip in Va), a low power facility need not provide a service contour over the city of license (Gainesville in this case). Please correct me if I've botched that matter.

 

[jd]

4). As I understand it (mostly from Trip in Va), a low power facility need not provide a service contour over the city of license (Gainesville in this case). Please correct me if I've botched that matter.

Several years ago there was a discussion about the LP licensed to Corsicana (K25FW) moving to Cedar Hill and using a directional antenna to target Dallas, with virtually nothing sent back toward their COL. Someone explained that portion of the rules on this board, and although I've always thought I was pretty quick on the uptake, I just don't understand. Why even bother licensing stations to a specific community of license? Duh, it beats me.

I think your interpretation of the COL coverage rule is correct. But when you're talking about something that defies logic you must equate that with a description of the FCC's control of the airwaves, that being "if it fits, license it. And if it doesn't fit, deregulate it so it will."

 

[JHBrandt]

3). Of course, whether it even gets approved is an open question. Since the proposed RF-2 facility is adjacent to KHPK on RF-3, does the downtown Dallas site meet the interference criteria?

On 2/1 the FCC sent HCCN a letter saying it didn't: http://licensing.fcc.gov/cgi-bin/prod/cdbs/forms/prod/getimportletter_exh.cgi?import_letter_id=16831

HCCN's application included an interference study that showed KHPK losing under 1500 potential viewers (<.05%) to interference from KSFW's new proposal: https://licensing.fcc.gov/cdbs/CDBS...?appn=101350973&qnum=5100&copynum=1&exhcnum=1

Does the FCC have a de minimus exception to the interference rules? It would seem rather extreme to deny an application based on very minor interference, but I don't know what the FCC would consider "very minor."

 

[jd]

/getattachment.jsp?appn=101350973&qnum=5100&copynum=1&exhcnum=1
It would seem rather extreme to deny an application based on very minor interference, but I don't know what the FCC would consider "very minor."

As I understand it the de minimis interference level between DTV's is 0.5%, but for some reason I can't call up the specific rule right now. Anything less than that, one could assume, would be "very minor" or, if you prefer, insignificant.

In the case of the pending WFAA application the interference to the "service population" of KLTV in Tyler would be around 3.0%, hence they filed an interference agreement along with the application. I expect that application to be approved, and I certainly don't see why KSFW couldn't do something similar. Then again, maybe they'll be able to make adjustments in their pattern or power level to bring the interference level down.

 

[tripinva]

It's 0.5% for full-service stations, but 2% for low-powered stations. So KSFW should be able to cause 2% interference to KHPK.

- Trip

 

[jd]

I don't know if was me or the database, but thanks for clearing it up, trip. I didn't remember it being different for LPTV's and that's really quite a margin.

 

[Bob E. Nelson]

Does the FCC have a de minimus exception to the interference rules? It would seem rather extreme to deny an application based on very minor interference, but I don't know what the FCC would consider "very minor."

Another factor that may come into play regarding KSFW's intentions to move from Collinsville to the Bank of America Tower in downtown Dallas is the distance. I'll defer to Trip Ericson's knowledge of the rules to confirm (or deny) what I've been told. In short, a move of that magnitude (more than 30 miles) in a single step is too large without a waiver.

 

[JHBrandt]

It's 0.5% for full-service stations, but 2% for low-powered stations. So KSFW should be able to cause 2% interference to KHPK.

- Trip

So the FCC is in error unless they've conducted their own analysis and found much greater interference than KSFW's analysis showed. It'll be interesting to see how KSFW responds. I understand they have 30 days, which would be until March 3.

 

[JHBrandt]

Another factor that may come into play regarding KSFW's intentions to move from Collinsville to the Bank of America Tower in downtown Dallas is the distance. I'll defer to Trip Ericson's knowledge of the rules to confirm (or deny) what I've been told. In short, a move of that magnitude (more than 30 miles) in a single step is too large without a waiver.

The FCC took that position with another station (KHFD) which is also trying to move to Cedar Hill. KHFD's response was that the 30-mile limit only applied to channel displacement applications. I don't know who's correct, but if KHFD is, the 30-mile limit wouldn't apply to KSFW's application either, since neither station is filing for a displacement.

 

[tripinva]

My understanding of the interference rules is that LPTV stations are protected after 2% and full-service stations are 0.5%. For example, say a low-powered station was filing for channel 49 in Dallas. They could cause 2.0% interference to KATA-CD (I don't know what the rules are for Class A, but I'm assuming it's like an LP) but only 0.5% to KSTR. Now, of course, if the interference is over a heavily populated area of the Dallas area, getting above 2% for a station like KSFW could be pretty easy.

I also am under the impression that an LPTV station needs only to show their old and new contours overlap to be considered a "minor modification."

- Trip

 

[Bob E. Nelson]

The KSFW/2 story continues to unfold with an amended application filed for 130 watts:

https://licensing.fcc.gov/cgi-bin/w...t=25&appn=101357785&formid=346&fac_num=130934

The directional pattern is sharply away from Cedar Hill (and KHPK/3):

http://www.fcc.gov/fcc-bin/FMTV-service-area?x=LD1357785.html

 

[JHBrandt]

And now HCCN is trying something similar with their sister station, KQFW/7. They filed a displacement application seeking to move to out-of-core channel 56, and they want to move KQFW's tower from Collinsville to Garland. I'm guessing they're still trying to find a way to cover most of Dallas without relying on a station owned by someone else, like KPFW.

I don't think the FCC will let them get away with the move on a displacement app since it's over 30 miles.

 

[JHBrandt]

The FCC has granted KSFW/2 a construction permit. Still no correspondence on KQFW/7, though.

 

[JHBrandt]

And now HCCN is trying something similar with their sister station, KQFW/7. They filed a displacement application seeking to move to out-of-core channel 56, and they want to move KQFW's tower from Collinsville to Garland. I'm guessing they're still trying to find a way to cover most of Dallas without relying on a station owned by someone else, like KPFW.

I don't think the FCC will let them get away with the move on a displacement app since it's over 30 miles.

Correction: HCCN sold KQFW/7 to another Godcaster called LMO Christian Media. HCCN still owns KSFW/2 and KHFW/29; I guess they finally figured out they didn't actually need three TV stations to serve their north Texas viewers.

 

[JHBrandt]

Another factor that may come into play regarding KSFW's intentions to move from Collinsville to the Bank of America Tower in downtown Dallas is the distance. I'll defer to Trip Ericson's knowledge of the rules to confirm (or deny) what I've been told. In short, a move of that magnitude (more than 30 miles) in a single step is too large without a waiver.

The FCC took that position with another station (KHFD) which is also trying to move to Cedar Hill. KHFD's response was that the 30-mile limit only applied to channel displacement applications. I don't know who's correct, but if KHFD is, the 30-mile limit wouldn't apply to KSFW's application either, since neither station is filing for a displacement.

OK, I'm bumping this old thread. Our story so far: KSFW/2 had applied to move from Collinsville to downtown Dallas. At that time KHPK was on RF 3, so to avoid interference KSFW/2 amended their application with a directional antenna pointing north. This let their new coverage overlap their old without interfering excessively with KHPK/3. And because this was not a channel displacement, the 30-mile rule did not apply and the FCC granted KSFW/2 a construction permit.

Now, back to present day: KHPK has displaced to RF 28, so interference is no longer an issue. Thus KSFW applied to modify their construction permit. Now they want to broadcast from downtown Ft. Worth with a non-directional antenna.

The FCC has just denied this modification on two grounds. One, astonishingly, is the 30-mile rule! Apparently the FCC's own employees don't agree on the meaning of their own rules. If it applied, it should have also blocked KSFW's previous CP as well as KHFD's move to Cedar Hill.

The other issue makes more sense. The FCC is claiming "our ASR registration search using the antenna registration number 1050709 as provided in the proposed construction permit reveals the tower status as terminated."

 

[tripinva]

In the R&O that established the transition date for LPTV stations, they stated the 30-mile rule now applies to modifications as well as displacements. Prior to that R&O, it only applied to displacements.

- Trip

 

[JHBrandt]

In the R&O that established the transition date for LPTV stations, they stated the 30-mile rule now applies to modifications as well as displacements. Prior to that R&O, it only applied to displacements.

- Trip

Ah, so the rules have changed. I see.

I guess KSFW's stuck in downtown Dallas. They could still modify to 3 kW and an omni, though, given that KHPK/3 is long gone.