DOCKET FILE COPY ORIGINAL Before the Washington, D.C. 20554 FEDERAL COMMUNICATIONS COMMISSION RECEIVED SEP 26 2002 ) -~ncw6cowrrswm In the Matter of Amendment of Section 73.202 ) MB Docket No. Table of Allotments, ) FM Broadcast Stations. ) RM No. (Toledo, Ohio, Oak Harbor, Ohio ) and Genoa, Ohio) ) ) -wIwEs&IETuw To: Assistant Chief, Audio Division, Media Bureau JOINT PETITION FOR RULEMAKING Rasp Broadcasting Enterprises, Inc. (“Rasp”),licensee of WJZE(FM), Channel 247A, Oak Harbor, Ohio (Facility ID No. 55183), and Citicasters Licenses, Inc. (“Citicasters”), licensee of WRVF(FM), Channel 268B, Toledo, Ohio (Facihty ID No. 62188), by their respective attorneys, hereby jointly petition the Commission for the following four modifications (collectively, the “Proposal”): modification of the Commission’s Table of Allotments for FM Broadcast Stations (Section 73.202 of the Commission’s Rules) to: (i) delete Channel 247A from Oak Harbor, Ohio, and (ii) add Channel 247A to Genoa, Ohio; contingent on Commission approval of the above change in the Table of Allotments, modification of the Commission’s Table of Allotments for FM Broadcast Stations (Section 73.202 of the Commission’s Rules) to: (i) delete Channel 268B from Toledo, Ohio, and (ii) add Channel 268B to Oak Harbor, Ohio; and modification of the license of WJZE to specify operations on Channel 247A in Genoa, Ohio, in lieu of operation on Channel 247A in Oak Harbor, Ohio, and \\\DC ~ 58176/0217 - 1616128 “2
Transcript
DOCKET FILE COPY ORIGINAL
Before the
Washington DC 20554 FEDERAL COMMUNICATIONS COMMISSION RECEIVED
SEP 26 2002 ) - ~ n c w 6 c o w r r s w m In the Matter of
Amendment of Section 73202 ) MB Docket No Table of Allotments ) FM Broadcast Stations ) RM No (Toledo Ohio Oak Harbor Ohio ) and Genoa Ohio) )
) -wIwEsampIETuw
To Assistant Chief Audio Division Media Bureau
JOINT PETITION FOR RULEMAKING
Rasp Broadcasting Enterprises Inc (ldquoRasprdquo) licensee of WJZE(FM)
Channel 247A Oak Harbor Ohio (Facility ID No 55183) and Citicasters
Licenses Inc (ldquoCiticastersrdquo) licensee of WRVF(FM) Channel 268B Toledo Ohio
(Facihty ID No 62188) by their respective attorneys hereby jointly petition the
Commission for the following four modifications (collectively the ldquoProposalrdquo)
modification of the Commissionrsquos Table of Allotments for FM Broadcast Stations (Section 73202 of the Commissionrsquos Rules) to (i) delete Channel 247A from Oak Harbor Ohio and (ii) add Channel 247A t o Genoa Ohio
contingent on Commission approval of the above change in the Table of Allotments modification of the Commissionrsquos Table of Allotments for FM Broadcast Stations (Section 73202 of the Commissionrsquos Rules) to (i) delete Channel 268B from Toledo Ohio and (ii) add Channel 268B to Oak Harbor Ohio and
modification of the license of WJZE to specify operations on Channel 247A in Genoa Ohio in lieu of operation on Channel 247A in Oak Harbor Ohio and
DC ~ 581760217 - 1616128 ldquo2
d) contingent on the above changes modification of the license of WRVF t o specify operations on Channel 268B in Oak Harbor Ohio in lieu of operation on Channel 268B in Toledo Ohio
In reviewing a proposed change to the FM Table of Allotments the
Commission asks whether the proposal would serve one or more of the
Commissions four allotment priorities I Here the Proposal would serve the third
allotment priority by providing a first local aural transmission service to Genoa
Ohio
The community of Genoa has been identsed in both the 1990 and
2000 Censuses and has a 2000 Census population of 2230 residents 21 Genoa has
its own government its own schools its own fire and police departments its own
churches its own retail outlets its own post office and its own zip code (43430) 31
Under any readmg of Commission precedent Genoa also deserves its own local
transmission service 41
- 11 four allotment priorities are i) one full-time aural reception service to a community ii) a second full-time aural reception service to a community iii) one local transmission service to a community or iv) other public interest factors Id The second and third criteria have equal priority Id
- 21 See Exhibit 1
- 31 See id
- 4 not require a Tuck showing that Genoa is separate and distinct from Toledo See Faye and Richard Tuck 3 FCC Rcd 5347 (1988) Under Tuck (and subsequent Commission precedent) a showing that the new community of license of a proposed allotment is not interdependent on a nearby major city is required If i) for the first time the allotment from the proposed reference coordinates will encompass at least 50 percent of the relevant urbanized area within its projected 70 dBu contour or ii) if the proposed allotment will not encompass at least 50 percent of the
See Parker amp Port St Joe RampO 11 FCC Rcd 1095 1095 (7 4) (1996) The
The proposed re-allotment of Channel 247A from Oak Harbor to Genoa does
The Proposal will cause no disruption to existing levels of service
Under the Proposal and consistent with FCC precedent Oak Harbor will maintain
a local FM transmission service through the reallotment of WRVF from Toledo to
Oak Harbor 51 while Toledo d 1 remain the community of license of 12 other radio
stations even after the proposed move of WRVF Also because the proposed
allotment changes will be made without the need to re-locate the transmitting
facilities of either WJZE or WRVF the Proposal will not result in any loss of
established service 61
The attached Technical Exhibit demonstrates that the Proposal is
consistent with the Commissionrsquos technical requirements assuming that the
Commission employs a sensible reading of its established allocations policy
regardmg stations that seek to change their communities of license without
changing their actual transmitter sites and are already subject to Section 73215 of
the Commissionrsquos Rules Under Section 73215 of the Commissionrsquos Rules the
relevant urbanized area the proposed community of license but not the current community of license is part of the relevant urbanized area See eg Memphis Tennessee Olive Branch and Horn Lake Mississippi Report and Order MM Docket No 02-31 (Allocations May 1 2002) Here Genoa is not part of the Toledo Urbanized Area see Technical Exhibit (attached as Exhibit 2) at Figure 1 and the proposed reallotment of Channel 247A to Genoa does not involve any change in WJZErsquos established parameters Accordingly the proposal does not require a Tuck showing Likewise the proposed re-allotment of Channel 268B from Toledo to Oak Harbor does not require a Tuck showing because it does not involve any change in the allotmentrsquos reference coordinates and Oak Harbor is not part of any urbanized area Seeid
- 51 See id
- 61 See Technical Exhibit a t 1 3
3
Commission wJl approve an application to move a stationrsquos transmitter site to a
location closer to another stationrsquos site than would be permitted under
Section 73207 so long as the re-locating station provides contour protection to the
other station For allotment purposes Commission precedent has accepted a
proposed reference site that is the existing site of a station seeking t o change its
community of license even though that site satisfies the Commissionrsquos technical
requirements only through Section 7321521 In this precedent the Commission
approves the proposed change if ldquono new short-spacing would be created and no
existing short-spacing exacerbatedrdquo 81 To date the Commission has used this
policy only to authorize a community of license change by a station that became
subject to Section 73215 because of a processing request by another station But
the Commission likewise should not deny a quali6ed community its first local
transmission service simply because a station wishing to be reassigned to that
community previously had requested Section 73215 processing in a permit
application At a minimum there is no reason to deny a community its first local
transmission service when the relevant station encompassed the proposed
community with its projected 70 d s u contour (pursuant to Allocationsrsquo uniform
terrain maximum facilities methodology) prior to the application in which the
station requested Section 732 15 processing
- 71 (Allocations 2000)
- 81 Id
See Killeen and Cedar Park Terns Report and Order 15 FCC Rcd 1945
An example demonstrates the point Under the Commissionrsquos current
Section 73215 allotment policy a station that has never requested Section 73215
processing could petition to become the first local transmission service for an
eligible community (the ldquoCommunityrdquo) so long as its 70 dBu contour encompasses
the Community (and it satisfies other technical standards) Once that change
occurs the station then could request Section 73215 processing with respect to a
second station as part of an application t o move to a better transmitter site
Accordingly the same station should be able t o obtain Commission approval for the
exact same requests in reverse order first the station requests Section 73215
processing to move closer t o another station second the station requests a change
in its community of license to a community that had been encompassed by its
predicted 70 dBu signal from both its pre-Section 73215 and its current transmitter
site As each set of changes reach the same real world result there is no non-
arbitrary basis for permitting the first set of moves as consistent with the public
interest but precluding the second as contrary to the public interest
Here the Proposal does not involve a station that seeks to be re-
assigned to a community that was outside its projected 70 dl3u contour from its pre-
Section 73215 site WJZE using the maximum facilities and uniform terrain
projection method employed in the allocations process provided 70 dBu coverage of
Genoa from its pre-Section 73215 site 91 Also the proposed re-allotment satisfies
the actual test employed by the Commission in its precedent approving the
___ - 91 See Technical Exhibit a t 3
reallotment of Section 732 15-designated stations the proposed Genoa re-allotment
neither creates nor exacerbates any short spacing prohibited by Section 73215
Accordingly that WJZE requested Section 732 15 processing with respect to a
single station - W M E E O Fort Wayne Inhana -in order to improve service
several years ago should not preclude the proposed reallotment which does not
exacerbate or create any short-spacing and will not enable a station t o be assigned
to a community to which it could not have been assigned but for a previous
Section 73215 request by that station
Grant of the proposal advances the public interest First it satisfies
one of the Commissionrsquos key allotment priorities it provides a deserving community
its first local transmission service Second adoption of the proposal will confirm
that the Commission does not intend t o maintain an arbitrary disparity in the way
it processes an allotment request depending on when a station might have
requested Section 73215 treatment which also will ensure that all stations are
able to maximize their service to the public
For all the foregoing reasons the Commission should issue an
appropriate Notice of Proposed Rule Making and then approve the proposed
modifications of the Table of Allotments and WJZErsquos and WRVFrsquos licenses under
Section 1420(i) of the Commissionrsquos Rules
Respectfully submitted
REDDY BEGLEY amp MCCORMICK
2175 K Street NW Suite 350 Washington DC 20037-1803
Telephone 202-659-5700 Facsimile 202-659-571 1
Attorneys for Rasp Broadcasting Enterprises Inc
September 26 2002
HOGAN amp HARTSON LLP
By Marissa G Repp lsquo
555 Thirteenth Street NW Washington DC 20004- 1109 Telephone 202-637-6845 Facsimile 202-637-5910
Attorneys for Citicasters Licenses Inc
EXHIBIT 1
Table DP1 Profile of General Demographic Characteristics 2000 Geographic Area Genoa village Ohio [For information on confidentiality protection nonsampiing error and definitions see text]
Subject Number Percent Subjen
Total populallon SEX AND AGE Male Female Under 5 years 5 to 9 years 10 to 14 years 15 to 19 yeam 20 lo 24 years 25 to 34 years 35 to44 years 45 to 54 years 55 to 59 years
75 lo 84 years 85 years and over
Median age (yean) 18 years and over
Male Female
21 years and over
65 years and over Male Female
RACE One race
White Black or African American American Indian and Alaska Native Asian
Asian Indian Chinese
Native Hawaiian Guamanian or Chamom Samoan Other Pacific Islander
Some ather race Two or more races Race elone or In comblnstlon wlth one
While Black or African American American Indian and Alaska Nati Asian Native Hawaiian and Ofher P a d
or mom other 11caa
I
2230
1062 1168
122 169 173 159 88
291 353 294 90 90
152 178 71
383
1859 751 908
1583 451 401 129 272
2197 2120
8 7 6 1
2
2 1 1
1
55 33
2152 11 14 9 4
1000
476 524 55 78 78 71 39
130 l58 132 40 40 6 8 80 32
(x 744 337 407 71 O 202 180 58
122
98 5 951 04 0 3 0 3
O
01
25 15
-
96 5
E
HISPANIC OR LATINO AND RACE Total populallon
hispanic or LaLna (of any race) Mexican Pueno Rtcan Cunan Otner Hispanic or LSI~O
Whne aone
RELATIONSHIP ~ o t a ~ popu~m~on
In haampenom riousehoiaer Spouse Chid
Own chid unoer I8 years Otner re atives
Jnaer 18 years honrelatwes
Unmarriea partner
hot Hispanic or Latino
In group quarters Insttutionalized ppulat on honlnsttut onallzed popdjatlon
HOUSEHOLD BY N P E Tot81 houuholda
Famly housemlas (tamlies) WiIh own chmen unaer 18 years
Mamea-couple family W th own children under 18 years
Female musenolder no hasDana present Witn own chilaren maer 18 years
hontamily nouseholds Householoer living aone
rlouseholaer 65 yeas ano over
Households with Inawlduals under 18 years rlousenolas wnn inaividJals 65 years ana over
0wneroccupiea homng units Renter-occupiea housing unts
For seasonai receatona or
02 Average household size of owner-occupied unil 33 I Averam household size of renter-occuoied unit Some other race
Number I Percent
74
2230 152 125
2
25 2078 2042
2230 2140
851 443 720 533 70 29 56 26 90 90
851 583 283 443 206 98 54
268 248 123
304 241
251 311
883 851 32
03 43
851 651 200
270
1000 68 56 01
11 932 918
1000 960 382 199 323 239
31 13 25 12 40 40
1000 685 333 521 242 115 63
315 291 145
357 283
(X) (X)
1000 964 36
(X) (X)
1000 765 235
- Represents zero or rounds to zero Other Asian alone or two or more Asian categories Other Pacific Islander alone or two or more Native Hawaiian and Other Pacific Islander categories
(X) Not applicable
In combination with one or more of the other races listed The six numbers may add to more than the total population and the six percentages may add to more than 1W percent because individuals may repon more than one race
Source US Census Bureau Census 2000
1731 U8 Census Bureau
Yahoo Yellow Pages Page 1 of 2
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Lop gt Co_mmuampy gt GwernmM gt General
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I Showing 1-4 of 4 I Beyond Genoa
Address 21774 E Holts Rd GenoaOH
GenoaVi l lae Adm (419) 855-7791
102 E 6th St GenoaOH Map
Genoa Village Offices 1419) 855-7791
102 E 6th St GenoaOH Map
Genoa Village Utility Office (419) 855-7791
102 E 6th St GenoaOH Map
Showing 1-4 of 4 I Beyond Genoa
Beyond Cenoa
Business Information provided by InfoUSA corn Foster City California Copyright 0 2002
1 1 am Vice President of RASP Broadcast Enterprises bc (lsquoaASPrdquo) the license of WJZB(FM) C h e l 2 4 7 A Oak Harbor Obio
RASP intends to apply for a construction permit for Channel 247A to specify oper Itions for WJZE in Genoa Ohio upon adoption ofthe Proposal as outljned h e n through the relevant Notice of Pmposed Rule Making
If am ardd the construction permit for Channel 247A RASP promptlywill construct and ITamp such facilities
2
3
Iherebydec are underpenallyofperjurythat thes ta tementsmade ia th i sdec l~~on~~e and accurate to the Ixst of my howledge information and belief
September a 2 002
DECLARATION
I Jeff Littlejohn declare as follows
3 I am Senior Vice President Engineering of Citicasters Licenses Inc (ldquoCiticastersrdquo) the licensee of WRVF(FM) Channel 268B Toledo Ohio
Citicasters intends to apply for a construction permit for Channel 268B to specamp operations for WRVF in Oak Harbor Ohio upon adoption of the Proposal as outlined herein through the relevant Notice of Proposed Rule Making
If awarded the construction permit for Channel 268B Citicasters promptly wi l l construct and operate such facilities
4
3
I hereby declare under penalty of perjury that the statements made in
this declaration are true and accurate to the best of my knowledge information and
belief
du Treil Lundin amp Rackley Inc Consulting Engineers
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Technical Narrative
This Technical Exhibit of which this Narrative is part proposes an FM Rule Making to modify the Commissions Table of Allotments contained within Section 73202 within the Commissions Rules It is proposed herein to modify the community of license of two FM stations No change in the stations reference coordinates are proposed
Summary of Rule Making Proposal
Below is a summary of the allocation changes requested in the Joint Petition for Rule Making
0 Delete Channel 247A at Oak Harbor Ohio and allot
Contingent on the adoption of the above change Channel 24A at Genoa Ohio
delete Channel 268B at Toledo Ohio and allot Channel 268B at Oak Harbor Ohio
Pursuant to Section 142O(i) of the Commissions Rules the Petition also requests modifications to the licenses of WJZE(FM) Channel 24A Oak Harbor Ohio and WRVF(FM) Channel 268B Toledo Ohio accordingly
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 2
Proposed Channel 247A Genoa Ohio
It is proposed to delete Channel 247A at Oak Harbor and allot Channel 247A to Genoa Ohio The Genoa proposal is mutually exclusive with the current Oak Harbor allotment As no change in the reference site change is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Genoa as shown in Figure 1
Below are the Channel 247A Genoa reference site geographic coordinates
41deg 29 17 North Latitude 83O 19 25 West Longitude
The existing Channel 241A reference coordinates do not satisfy the spacing requirements of Section 73207 with respect to three stations as identified in the allocation study provided in Figure 2 Each is discussed below
First under Section 73207 the proposed Channel 247A reference site is short-spaced to CHYR-FM on Channel 244C1 at Leamington Ontario Canada The required minimum separation distance is 90 kilometers the actual separation distance is 86 kilometers a short- spacing of 4 kilometers This Canadian allotment is a specially negotiated short-spaced allotment which was accepted by the Commission on September 2 1992 Petitionerrs Channel 247A is also a specially negotiated short-spaced allotment which was accepted by Canada on December 14 1992 Therefore because the proposed allotment does not involve any change in the relevant site this previously accepted spacing should satisfy the Commissions allocation requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 3
Second under Section 73207 the proposed Channel 248A reference site is short-spaced to WKRK-FM on Channel 246B at Detroit Michigan The required minimum separation distance is 113 kilometers the actual separation distance is 111 kilometers a short-spacing of 2 kilometers Petitioners Channel 247A was initially allocated as a 3 kilowatt100 meter facility and it remains as an equivalent facility Therefore for allotment purposes WKRK-FM can be protected pursuant to Section 73213(c) of the Commissions Rules which requires a minimum separation distance of 105 kilometers The proposed reference coordinates satisfies this requirement
Third under Section 73207 the proposed Channel 247A reference site is short-spaced to WMEE(FM) on Channel 247B at Fort Wayne Indiana The station was authorized to operate from the reference site (its current site) pursuant to the stations request to be processed under Section 73215 The required minimum separation distance is 178 kilometers the actual separation distance is 162 kilometers a short-spacing of 16 kilometers
However the proposed allotment does not create a new short or not exacerbate any short-spacing (under Section 73207) with regard to WMEE(FM) In addition WJZE(FM) already has been approved to operate at the reference site to the extent is affords WMEE(FM) contour protection pursuant to Section 73215 and the proposed allotment contemplates no change in WJZE(FM)s operating parameters Moreover WJZE(FM)s former (pre-Section 73215) transmitter site satisfied the relevant spacing requirement - the Section 73213(c) separation distance of 163 kilometers with regard to WMEE(FM) As shown in Figure 1 the projected city grade reference contour (70 dBu) of the allotment from this former site encompassed
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 4
the proposed community of Genoa this pre-Section 73215 site is provided in Figure 2
An allocation study from
Figure 5 is an Area-to-Locate map for Channel 247A As can be seen there is no present fully-spaced area-to-locate for this allotment
Proposed Channel 268B Oak Harbor Ohio
It is proposed to delete Channel 268B at Toledo and allot Channel 268B to Oak Harbor Ohio This Oak Harbor proposal is mutually exclusive with the current Toledo allotment As no change in the reference site is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Oak Harbor as shown in Figure 1
Below are the Channel 268B Oak Harbor reference site geographic coordinates
41O 40 23 North Latitude 83O 25 31 West Longitude
The existing Channel 268B reference coordinates do not satisfy Section 73201 requirements with respect to five stations as shown by the allocation study provided in Figure 4 Each short-spacing is discussed below
First under Section 73207 the proposed Channel 268B reference site is short-spaced to WMJK(FM) on Channel 265A at Clyde Ohio The required minimum separation distance is 69 kilometers the actual separation distance is 64 kilometers a short-spacing of 5 kilometers WMJK(FM) is a 3 kilowatt100 meter type Class A facility and therefore is processed pursuant to Section
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 5
13213 of the Rules as the short-spacing (under Section 13207) is not exacerbated
Second under Section 73207 the proposed Channel 268B reference site is short-spaced to WNCO-FM on Channel 267B at Ashland Ohio The required minimum separation distance is 169 kilometers the actual separation distance is 129 kilometers a short-spacing of 40 kilometers However because the Channel 268B allotment and WNCO-FM have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Third under Section 73207 the proposed Channel 268B reference site is short-spaced to a Canadian allotment on Channel 268A The required minimum separation distance is 210 kilometers the actual separation distance is 167 kilometers a short-spacing of 43 kilometers This Canadian allotment is a specially negotiated short-spaced allotment Therefore because the proposed allotment does not involve a change in the relevant site this previously accepted spacing should satisfy the Commissionrsquos allocation requiremements
Fourth under Section 73207 the proposed Channel 268B reference site is short-spaced to the current licensed and authorized facility of WWBN(FM) on Channel 268A at Tuscola Michigan because WWBN(FM) is authorized pursuant to Section 73215 with regard to WRVF(FM) Therefore as WRVF(FM) did not initiate this short- spacing and the proposed re-allotment involves no change in the WRVF(FM)rsquos current transmitter site the proposed spacing satisfies the Commissionrsquos allotment requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 6
Fifth under Section 73207 the proposed Channel 268B reference site is short-spaced to WNSN(FM) on Channel 268B at South Bend Indiana The required minimum separation distance is 14 kilometers the actual separation distance is 68 kilometers a short-spacing of 6 kilometers However because the Channel 268B allotment and WNSN(FM) have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Proposed Modifications to Table of Allotments
This proposal provides for the following allotment changes to Section 73202 The Commissionrsquos Table of FM Allotments
Lowell Oil Center (historical) hobth Amsden Maple Grove
Watson lie Mount Gilead
10 0 10 20 30 40 miles
H H H H t I I I I I I
H H H H I I I I I I I I 10 0 10 20 30 40 50 kilometers
CITY GRADE REFERENCE CONTOURS
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 2
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 241A Genoa Ohio Allocation Study Proposed Reference Site
41deg 29rsquo 17rdquo North Latitude 8 3 O 19rsquo 25ldquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(rn) Longitude deg-True (km) (hi) WBVI FOSTORIA BLH 244A 30 41-06-00 1964 4494 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR- F LEAMINGTON 244C1 910 42-00-35 472 8582 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
d) contingent on the above changes modification of the license of WRVF t o specify operations on Channel 268B in Oak Harbor Ohio in lieu of operation on Channel 268B in Toledo Ohio
In reviewing a proposed change to the FM Table of Allotments the
Commission asks whether the proposal would serve one or more of the
Commissions four allotment priorities I Here the Proposal would serve the third
allotment priority by providing a first local aural transmission service to Genoa
Ohio
The community of Genoa has been identsed in both the 1990 and
2000 Censuses and has a 2000 Census population of 2230 residents 21 Genoa has
its own government its own schools its own fire and police departments its own
churches its own retail outlets its own post office and its own zip code (43430) 31
Under any readmg of Commission precedent Genoa also deserves its own local
transmission service 41
- 11 four allotment priorities are i) one full-time aural reception service to a community ii) a second full-time aural reception service to a community iii) one local transmission service to a community or iv) other public interest factors Id The second and third criteria have equal priority Id
- 21 See Exhibit 1
- 31 See id
- 4 not require a Tuck showing that Genoa is separate and distinct from Toledo See Faye and Richard Tuck 3 FCC Rcd 5347 (1988) Under Tuck (and subsequent Commission precedent) a showing that the new community of license of a proposed allotment is not interdependent on a nearby major city is required If i) for the first time the allotment from the proposed reference coordinates will encompass at least 50 percent of the relevant urbanized area within its projected 70 dBu contour or ii) if the proposed allotment will not encompass at least 50 percent of the
See Parker amp Port St Joe RampO 11 FCC Rcd 1095 1095 (7 4) (1996) The
The proposed re-allotment of Channel 247A from Oak Harbor to Genoa does
The Proposal will cause no disruption to existing levels of service
Under the Proposal and consistent with FCC precedent Oak Harbor will maintain
a local FM transmission service through the reallotment of WRVF from Toledo to
Oak Harbor 51 while Toledo d 1 remain the community of license of 12 other radio
stations even after the proposed move of WRVF Also because the proposed
allotment changes will be made without the need to re-locate the transmitting
facilities of either WJZE or WRVF the Proposal will not result in any loss of
established service 61
The attached Technical Exhibit demonstrates that the Proposal is
consistent with the Commissionrsquos technical requirements assuming that the
Commission employs a sensible reading of its established allocations policy
regardmg stations that seek to change their communities of license without
changing their actual transmitter sites and are already subject to Section 73215 of
the Commissionrsquos Rules Under Section 73215 of the Commissionrsquos Rules the
relevant urbanized area the proposed community of license but not the current community of license is part of the relevant urbanized area See eg Memphis Tennessee Olive Branch and Horn Lake Mississippi Report and Order MM Docket No 02-31 (Allocations May 1 2002) Here Genoa is not part of the Toledo Urbanized Area see Technical Exhibit (attached as Exhibit 2) at Figure 1 and the proposed reallotment of Channel 247A to Genoa does not involve any change in WJZErsquos established parameters Accordingly the proposal does not require a Tuck showing Likewise the proposed re-allotment of Channel 268B from Toledo to Oak Harbor does not require a Tuck showing because it does not involve any change in the allotmentrsquos reference coordinates and Oak Harbor is not part of any urbanized area Seeid
- 51 See id
- 61 See Technical Exhibit a t 1 3
3
Commission wJl approve an application to move a stationrsquos transmitter site to a
location closer to another stationrsquos site than would be permitted under
Section 73207 so long as the re-locating station provides contour protection to the
other station For allotment purposes Commission precedent has accepted a
proposed reference site that is the existing site of a station seeking t o change its
community of license even though that site satisfies the Commissionrsquos technical
requirements only through Section 7321521 In this precedent the Commission
approves the proposed change if ldquono new short-spacing would be created and no
existing short-spacing exacerbatedrdquo 81 To date the Commission has used this
policy only to authorize a community of license change by a station that became
subject to Section 73215 because of a processing request by another station But
the Commission likewise should not deny a quali6ed community its first local
transmission service simply because a station wishing to be reassigned to that
community previously had requested Section 73215 processing in a permit
application At a minimum there is no reason to deny a community its first local
transmission service when the relevant station encompassed the proposed
community with its projected 70 d s u contour (pursuant to Allocationsrsquo uniform
terrain maximum facilities methodology) prior to the application in which the
station requested Section 732 15 processing
- 71 (Allocations 2000)
- 81 Id
See Killeen and Cedar Park Terns Report and Order 15 FCC Rcd 1945
An example demonstrates the point Under the Commissionrsquos current
Section 73215 allotment policy a station that has never requested Section 73215
processing could petition to become the first local transmission service for an
eligible community (the ldquoCommunityrdquo) so long as its 70 dBu contour encompasses
the Community (and it satisfies other technical standards) Once that change
occurs the station then could request Section 73215 processing with respect to a
second station as part of an application t o move to a better transmitter site
Accordingly the same station should be able t o obtain Commission approval for the
exact same requests in reverse order first the station requests Section 73215
processing to move closer t o another station second the station requests a change
in its community of license to a community that had been encompassed by its
predicted 70 dBu signal from both its pre-Section 73215 and its current transmitter
site As each set of changes reach the same real world result there is no non-
arbitrary basis for permitting the first set of moves as consistent with the public
interest but precluding the second as contrary to the public interest
Here the Proposal does not involve a station that seeks to be re-
assigned to a community that was outside its projected 70 dl3u contour from its pre-
Section 73215 site WJZE using the maximum facilities and uniform terrain
projection method employed in the allocations process provided 70 dBu coverage of
Genoa from its pre-Section 73215 site 91 Also the proposed re-allotment satisfies
the actual test employed by the Commission in its precedent approving the
___ - 91 See Technical Exhibit a t 3
reallotment of Section 732 15-designated stations the proposed Genoa re-allotment
neither creates nor exacerbates any short spacing prohibited by Section 73215
Accordingly that WJZE requested Section 732 15 processing with respect to a
single station - W M E E O Fort Wayne Inhana -in order to improve service
several years ago should not preclude the proposed reallotment which does not
exacerbate or create any short-spacing and will not enable a station t o be assigned
to a community to which it could not have been assigned but for a previous
Section 73215 request by that station
Grant of the proposal advances the public interest First it satisfies
one of the Commissionrsquos key allotment priorities it provides a deserving community
its first local transmission service Second adoption of the proposal will confirm
that the Commission does not intend t o maintain an arbitrary disparity in the way
it processes an allotment request depending on when a station might have
requested Section 73215 treatment which also will ensure that all stations are
able to maximize their service to the public
For all the foregoing reasons the Commission should issue an
appropriate Notice of Proposed Rule Making and then approve the proposed
modifications of the Table of Allotments and WJZErsquos and WRVFrsquos licenses under
Section 1420(i) of the Commissionrsquos Rules
Respectfully submitted
REDDY BEGLEY amp MCCORMICK
2175 K Street NW Suite 350 Washington DC 20037-1803
Telephone 202-659-5700 Facsimile 202-659-571 1
Attorneys for Rasp Broadcasting Enterprises Inc
September 26 2002
HOGAN amp HARTSON LLP
By Marissa G Repp lsquo
555 Thirteenth Street NW Washington DC 20004- 1109 Telephone 202-637-6845 Facsimile 202-637-5910
Attorneys for Citicasters Licenses Inc
EXHIBIT 1
Table DP1 Profile of General Demographic Characteristics 2000 Geographic Area Genoa village Ohio [For information on confidentiality protection nonsampiing error and definitions see text]
Subject Number Percent Subjen
Total populallon SEX AND AGE Male Female Under 5 years 5 to 9 years 10 to 14 years 15 to 19 yeam 20 lo 24 years 25 to 34 years 35 to44 years 45 to 54 years 55 to 59 years
75 lo 84 years 85 years and over
Median age (yean) 18 years and over
Male Female
21 years and over
65 years and over Male Female
RACE One race
White Black or African American American Indian and Alaska Native Asian
Asian Indian Chinese
Native Hawaiian Guamanian or Chamom Samoan Other Pacific Islander
Some ather race Two or more races Race elone or In comblnstlon wlth one
While Black or African American American Indian and Alaska Nati Asian Native Hawaiian and Ofher P a d
or mom other 11caa
I
2230
1062 1168
122 169 173 159 88
291 353 294 90 90
152 178 71
383
1859 751 908
1583 451 401 129 272
2197 2120
8 7 6 1
2
2 1 1
1
55 33
2152 11 14 9 4
1000
476 524 55 78 78 71 39
130 l58 132 40 40 6 8 80 32
(x 744 337 407 71 O 202 180 58
122
98 5 951 04 0 3 0 3
O
01
25 15
-
96 5
E
HISPANIC OR LATINO AND RACE Total populallon
hispanic or LaLna (of any race) Mexican Pueno Rtcan Cunan Otner Hispanic or LSI~O
Whne aone
RELATIONSHIP ~ o t a ~ popu~m~on
In haampenom riousehoiaer Spouse Chid
Own chid unoer I8 years Otner re atives
Jnaer 18 years honrelatwes
Unmarriea partner
hot Hispanic or Latino
In group quarters Insttutionalized ppulat on honlnsttut onallzed popdjatlon
HOUSEHOLD BY N P E Tot81 houuholda
Famly housemlas (tamlies) WiIh own chmen unaer 18 years
Mamea-couple family W th own children under 18 years
Female musenolder no hasDana present Witn own chilaren maer 18 years
hontamily nouseholds Householoer living aone
rlouseholaer 65 yeas ano over
Households with Inawlduals under 18 years rlousenolas wnn inaividJals 65 years ana over
0wneroccupiea homng units Renter-occupiea housing unts
For seasonai receatona or
02 Average household size of owner-occupied unil 33 I Averam household size of renter-occuoied unit Some other race
Number I Percent
74
2230 152 125
2
25 2078 2042
2230 2140
851 443 720 533 70 29 56 26 90 90
851 583 283 443 206 98 54
268 248 123
304 241
251 311
883 851 32
03 43
851 651 200
270
1000 68 56 01
11 932 918
1000 960 382 199 323 239
31 13 25 12 40 40
1000 685 333 521 242 115 63
315 291 145
357 283
(X) (X)
1000 964 36
(X) (X)
1000 765 235
- Represents zero or rounds to zero Other Asian alone or two or more Asian categories Other Pacific Islander alone or two or more Native Hawaiian and Other Pacific Islander categories
(X) Not applicable
In combination with one or more of the other races listed The six numbers may add to more than the total population and the six percentages may add to more than 1W percent because individuals may repon more than one race
Source US Census Bureau Census 2000
1731 U8 Census Bureau
Yahoo Yellow Pages Page 1 of 2
Home - Yahoo1 - Maps -Address Book - HelL
Welcome Guest User
Yahoo Yellow Pages Genoa OH
Lop gt Co_mmuampy gt GwernmM gt General
All Businesses Business Name Clay Township Trustees (419) 855-7878
Create My Favorite Locations -Sign In
Change Location -Save This Location
I Showing 1-4 of 4 I Beyond Genoa
Address 21774 E Holts Rd GenoaOH
GenoaVi l lae Adm (419) 855-7791
102 E 6th St GenoaOH Map
Genoa Village Offices 1419) 855-7791
102 E 6th St GenoaOH Map
Genoa Village Utility Office (419) 855-7791
102 E 6th St GenoaOH Map
Showing 1-4 of 4 I Beyond Genoa
Beyond Cenoa
Business Information provided by InfoUSA corn Foster City California Copyright 0 2002
1 1 am Vice President of RASP Broadcast Enterprises bc (lsquoaASPrdquo) the license of WJZB(FM) C h e l 2 4 7 A Oak Harbor Obio
RASP intends to apply for a construction permit for Channel 247A to specify oper Itions for WJZE in Genoa Ohio upon adoption ofthe Proposal as outljned h e n through the relevant Notice of Pmposed Rule Making
If am ardd the construction permit for Channel 247A RASP promptlywill construct and ITamp such facilities
2
3
Iherebydec are underpenallyofperjurythat thes ta tementsmade ia th i sdec l~~on~~e and accurate to the Ixst of my howledge information and belief
September a 2 002
DECLARATION
I Jeff Littlejohn declare as follows
3 I am Senior Vice President Engineering of Citicasters Licenses Inc (ldquoCiticastersrdquo) the licensee of WRVF(FM) Channel 268B Toledo Ohio
Citicasters intends to apply for a construction permit for Channel 268B to specamp operations for WRVF in Oak Harbor Ohio upon adoption of the Proposal as outlined herein through the relevant Notice of Proposed Rule Making
If awarded the construction permit for Channel 268B Citicasters promptly wi l l construct and operate such facilities
4
3
I hereby declare under penalty of perjury that the statements made in
this declaration are true and accurate to the best of my knowledge information and
belief
du Treil Lundin amp Rackley Inc Consulting Engineers
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Technical Narrative
This Technical Exhibit of which this Narrative is part proposes an FM Rule Making to modify the Commissions Table of Allotments contained within Section 73202 within the Commissions Rules It is proposed herein to modify the community of license of two FM stations No change in the stations reference coordinates are proposed
Summary of Rule Making Proposal
Below is a summary of the allocation changes requested in the Joint Petition for Rule Making
0 Delete Channel 247A at Oak Harbor Ohio and allot
Contingent on the adoption of the above change Channel 24A at Genoa Ohio
delete Channel 268B at Toledo Ohio and allot Channel 268B at Oak Harbor Ohio
Pursuant to Section 142O(i) of the Commissions Rules the Petition also requests modifications to the licenses of WJZE(FM) Channel 24A Oak Harbor Ohio and WRVF(FM) Channel 268B Toledo Ohio accordingly
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 2
Proposed Channel 247A Genoa Ohio
It is proposed to delete Channel 247A at Oak Harbor and allot Channel 247A to Genoa Ohio The Genoa proposal is mutually exclusive with the current Oak Harbor allotment As no change in the reference site change is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Genoa as shown in Figure 1
Below are the Channel 247A Genoa reference site geographic coordinates
41deg 29 17 North Latitude 83O 19 25 West Longitude
The existing Channel 241A reference coordinates do not satisfy the spacing requirements of Section 73207 with respect to three stations as identified in the allocation study provided in Figure 2 Each is discussed below
First under Section 73207 the proposed Channel 247A reference site is short-spaced to CHYR-FM on Channel 244C1 at Leamington Ontario Canada The required minimum separation distance is 90 kilometers the actual separation distance is 86 kilometers a short- spacing of 4 kilometers This Canadian allotment is a specially negotiated short-spaced allotment which was accepted by the Commission on September 2 1992 Petitionerrs Channel 247A is also a specially negotiated short-spaced allotment which was accepted by Canada on December 14 1992 Therefore because the proposed allotment does not involve any change in the relevant site this previously accepted spacing should satisfy the Commissions allocation requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 3
Second under Section 73207 the proposed Channel 248A reference site is short-spaced to WKRK-FM on Channel 246B at Detroit Michigan The required minimum separation distance is 113 kilometers the actual separation distance is 111 kilometers a short-spacing of 2 kilometers Petitioners Channel 247A was initially allocated as a 3 kilowatt100 meter facility and it remains as an equivalent facility Therefore for allotment purposes WKRK-FM can be protected pursuant to Section 73213(c) of the Commissions Rules which requires a minimum separation distance of 105 kilometers The proposed reference coordinates satisfies this requirement
Third under Section 73207 the proposed Channel 247A reference site is short-spaced to WMEE(FM) on Channel 247B at Fort Wayne Indiana The station was authorized to operate from the reference site (its current site) pursuant to the stations request to be processed under Section 73215 The required minimum separation distance is 178 kilometers the actual separation distance is 162 kilometers a short-spacing of 16 kilometers
However the proposed allotment does not create a new short or not exacerbate any short-spacing (under Section 73207) with regard to WMEE(FM) In addition WJZE(FM) already has been approved to operate at the reference site to the extent is affords WMEE(FM) contour protection pursuant to Section 73215 and the proposed allotment contemplates no change in WJZE(FM)s operating parameters Moreover WJZE(FM)s former (pre-Section 73215) transmitter site satisfied the relevant spacing requirement - the Section 73213(c) separation distance of 163 kilometers with regard to WMEE(FM) As shown in Figure 1 the projected city grade reference contour (70 dBu) of the allotment from this former site encompassed
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 4
the proposed community of Genoa this pre-Section 73215 site is provided in Figure 2
An allocation study from
Figure 5 is an Area-to-Locate map for Channel 247A As can be seen there is no present fully-spaced area-to-locate for this allotment
Proposed Channel 268B Oak Harbor Ohio
It is proposed to delete Channel 268B at Toledo and allot Channel 268B to Oak Harbor Ohio This Oak Harbor proposal is mutually exclusive with the current Toledo allotment As no change in the reference site is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Oak Harbor as shown in Figure 1
Below are the Channel 268B Oak Harbor reference site geographic coordinates
41O 40 23 North Latitude 83O 25 31 West Longitude
The existing Channel 268B reference coordinates do not satisfy Section 73201 requirements with respect to five stations as shown by the allocation study provided in Figure 4 Each short-spacing is discussed below
First under Section 73207 the proposed Channel 268B reference site is short-spaced to WMJK(FM) on Channel 265A at Clyde Ohio The required minimum separation distance is 69 kilometers the actual separation distance is 64 kilometers a short-spacing of 5 kilometers WMJK(FM) is a 3 kilowatt100 meter type Class A facility and therefore is processed pursuant to Section
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 5
13213 of the Rules as the short-spacing (under Section 13207) is not exacerbated
Second under Section 73207 the proposed Channel 268B reference site is short-spaced to WNCO-FM on Channel 267B at Ashland Ohio The required minimum separation distance is 169 kilometers the actual separation distance is 129 kilometers a short-spacing of 40 kilometers However because the Channel 268B allotment and WNCO-FM have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Third under Section 73207 the proposed Channel 268B reference site is short-spaced to a Canadian allotment on Channel 268A The required minimum separation distance is 210 kilometers the actual separation distance is 167 kilometers a short-spacing of 43 kilometers This Canadian allotment is a specially negotiated short-spaced allotment Therefore because the proposed allotment does not involve a change in the relevant site this previously accepted spacing should satisfy the Commissionrsquos allocation requiremements
Fourth under Section 73207 the proposed Channel 268B reference site is short-spaced to the current licensed and authorized facility of WWBN(FM) on Channel 268A at Tuscola Michigan because WWBN(FM) is authorized pursuant to Section 73215 with regard to WRVF(FM) Therefore as WRVF(FM) did not initiate this short- spacing and the proposed re-allotment involves no change in the WRVF(FM)rsquos current transmitter site the proposed spacing satisfies the Commissionrsquos allotment requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 6
Fifth under Section 73207 the proposed Channel 268B reference site is short-spaced to WNSN(FM) on Channel 268B at South Bend Indiana The required minimum separation distance is 14 kilometers the actual separation distance is 68 kilometers a short-spacing of 6 kilometers However because the Channel 268B allotment and WNSN(FM) have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Proposed Modifications to Table of Allotments
This proposal provides for the following allotment changes to Section 73202 The Commissionrsquos Table of FM Allotments
Lowell Oil Center (historical) hobth Amsden Maple Grove
Watson lie Mount Gilead
10 0 10 20 30 40 miles
H H H H t I I I I I I
H H H H I I I I I I I I 10 0 10 20 30 40 50 kilometers
CITY GRADE REFERENCE CONTOURS
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 2
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 241A Genoa Ohio Allocation Study Proposed Reference Site
41deg 29rsquo 17rdquo North Latitude 8 3 O 19rsquo 25ldquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(rn) Longitude deg-True (km) (hi) WBVI FOSTORIA BLH 244A 30 41-06-00 1964 4494 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR- F LEAMINGTON 244C1 910 42-00-35 472 8582 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
The Proposal will cause no disruption to existing levels of service
Under the Proposal and consistent with FCC precedent Oak Harbor will maintain
a local FM transmission service through the reallotment of WRVF from Toledo to
Oak Harbor 51 while Toledo d 1 remain the community of license of 12 other radio
stations even after the proposed move of WRVF Also because the proposed
allotment changes will be made without the need to re-locate the transmitting
facilities of either WJZE or WRVF the Proposal will not result in any loss of
established service 61
The attached Technical Exhibit demonstrates that the Proposal is
consistent with the Commissionrsquos technical requirements assuming that the
Commission employs a sensible reading of its established allocations policy
regardmg stations that seek to change their communities of license without
changing their actual transmitter sites and are already subject to Section 73215 of
the Commissionrsquos Rules Under Section 73215 of the Commissionrsquos Rules the
relevant urbanized area the proposed community of license but not the current community of license is part of the relevant urbanized area See eg Memphis Tennessee Olive Branch and Horn Lake Mississippi Report and Order MM Docket No 02-31 (Allocations May 1 2002) Here Genoa is not part of the Toledo Urbanized Area see Technical Exhibit (attached as Exhibit 2) at Figure 1 and the proposed reallotment of Channel 247A to Genoa does not involve any change in WJZErsquos established parameters Accordingly the proposal does not require a Tuck showing Likewise the proposed re-allotment of Channel 268B from Toledo to Oak Harbor does not require a Tuck showing because it does not involve any change in the allotmentrsquos reference coordinates and Oak Harbor is not part of any urbanized area Seeid
- 51 See id
- 61 See Technical Exhibit a t 1 3
3
Commission wJl approve an application to move a stationrsquos transmitter site to a
location closer to another stationrsquos site than would be permitted under
Section 73207 so long as the re-locating station provides contour protection to the
other station For allotment purposes Commission precedent has accepted a
proposed reference site that is the existing site of a station seeking t o change its
community of license even though that site satisfies the Commissionrsquos technical
requirements only through Section 7321521 In this precedent the Commission
approves the proposed change if ldquono new short-spacing would be created and no
existing short-spacing exacerbatedrdquo 81 To date the Commission has used this
policy only to authorize a community of license change by a station that became
subject to Section 73215 because of a processing request by another station But
the Commission likewise should not deny a quali6ed community its first local
transmission service simply because a station wishing to be reassigned to that
community previously had requested Section 73215 processing in a permit
application At a minimum there is no reason to deny a community its first local
transmission service when the relevant station encompassed the proposed
community with its projected 70 d s u contour (pursuant to Allocationsrsquo uniform
terrain maximum facilities methodology) prior to the application in which the
station requested Section 732 15 processing
- 71 (Allocations 2000)
- 81 Id
See Killeen and Cedar Park Terns Report and Order 15 FCC Rcd 1945
An example demonstrates the point Under the Commissionrsquos current
Section 73215 allotment policy a station that has never requested Section 73215
processing could petition to become the first local transmission service for an
eligible community (the ldquoCommunityrdquo) so long as its 70 dBu contour encompasses
the Community (and it satisfies other technical standards) Once that change
occurs the station then could request Section 73215 processing with respect to a
second station as part of an application t o move to a better transmitter site
Accordingly the same station should be able t o obtain Commission approval for the
exact same requests in reverse order first the station requests Section 73215
processing to move closer t o another station second the station requests a change
in its community of license to a community that had been encompassed by its
predicted 70 dBu signal from both its pre-Section 73215 and its current transmitter
site As each set of changes reach the same real world result there is no non-
arbitrary basis for permitting the first set of moves as consistent with the public
interest but precluding the second as contrary to the public interest
Here the Proposal does not involve a station that seeks to be re-
assigned to a community that was outside its projected 70 dl3u contour from its pre-
Section 73215 site WJZE using the maximum facilities and uniform terrain
projection method employed in the allocations process provided 70 dBu coverage of
Genoa from its pre-Section 73215 site 91 Also the proposed re-allotment satisfies
the actual test employed by the Commission in its precedent approving the
___ - 91 See Technical Exhibit a t 3
reallotment of Section 732 15-designated stations the proposed Genoa re-allotment
neither creates nor exacerbates any short spacing prohibited by Section 73215
Accordingly that WJZE requested Section 732 15 processing with respect to a
single station - W M E E O Fort Wayne Inhana -in order to improve service
several years ago should not preclude the proposed reallotment which does not
exacerbate or create any short-spacing and will not enable a station t o be assigned
to a community to which it could not have been assigned but for a previous
Section 73215 request by that station
Grant of the proposal advances the public interest First it satisfies
one of the Commissionrsquos key allotment priorities it provides a deserving community
its first local transmission service Second adoption of the proposal will confirm
that the Commission does not intend t o maintain an arbitrary disparity in the way
it processes an allotment request depending on when a station might have
requested Section 73215 treatment which also will ensure that all stations are
able to maximize their service to the public
For all the foregoing reasons the Commission should issue an
appropriate Notice of Proposed Rule Making and then approve the proposed
modifications of the Table of Allotments and WJZErsquos and WRVFrsquos licenses under
Section 1420(i) of the Commissionrsquos Rules
Respectfully submitted
REDDY BEGLEY amp MCCORMICK
2175 K Street NW Suite 350 Washington DC 20037-1803
Telephone 202-659-5700 Facsimile 202-659-571 1
Attorneys for Rasp Broadcasting Enterprises Inc
September 26 2002
HOGAN amp HARTSON LLP
By Marissa G Repp lsquo
555 Thirteenth Street NW Washington DC 20004- 1109 Telephone 202-637-6845 Facsimile 202-637-5910
Attorneys for Citicasters Licenses Inc
EXHIBIT 1
Table DP1 Profile of General Demographic Characteristics 2000 Geographic Area Genoa village Ohio [For information on confidentiality protection nonsampiing error and definitions see text]
Subject Number Percent Subjen
Total populallon SEX AND AGE Male Female Under 5 years 5 to 9 years 10 to 14 years 15 to 19 yeam 20 lo 24 years 25 to 34 years 35 to44 years 45 to 54 years 55 to 59 years
75 lo 84 years 85 years and over
Median age (yean) 18 years and over
Male Female
21 years and over
65 years and over Male Female
RACE One race
White Black or African American American Indian and Alaska Native Asian
Asian Indian Chinese
Native Hawaiian Guamanian or Chamom Samoan Other Pacific Islander
Some ather race Two or more races Race elone or In comblnstlon wlth one
While Black or African American American Indian and Alaska Nati Asian Native Hawaiian and Ofher P a d
or mom other 11caa
I
2230
1062 1168
122 169 173 159 88
291 353 294 90 90
152 178 71
383
1859 751 908
1583 451 401 129 272
2197 2120
8 7 6 1
2
2 1 1
1
55 33
2152 11 14 9 4
1000
476 524 55 78 78 71 39
130 l58 132 40 40 6 8 80 32
(x 744 337 407 71 O 202 180 58
122
98 5 951 04 0 3 0 3
O
01
25 15
-
96 5
E
HISPANIC OR LATINO AND RACE Total populallon
hispanic or LaLna (of any race) Mexican Pueno Rtcan Cunan Otner Hispanic or LSI~O
Whne aone
RELATIONSHIP ~ o t a ~ popu~m~on
In haampenom riousehoiaer Spouse Chid
Own chid unoer I8 years Otner re atives
Jnaer 18 years honrelatwes
Unmarriea partner
hot Hispanic or Latino
In group quarters Insttutionalized ppulat on honlnsttut onallzed popdjatlon
HOUSEHOLD BY N P E Tot81 houuholda
Famly housemlas (tamlies) WiIh own chmen unaer 18 years
Mamea-couple family W th own children under 18 years
Female musenolder no hasDana present Witn own chilaren maer 18 years
hontamily nouseholds Householoer living aone
rlouseholaer 65 yeas ano over
Households with Inawlduals under 18 years rlousenolas wnn inaividJals 65 years ana over
0wneroccupiea homng units Renter-occupiea housing unts
For seasonai receatona or
02 Average household size of owner-occupied unil 33 I Averam household size of renter-occuoied unit Some other race
Number I Percent
74
2230 152 125
2
25 2078 2042
2230 2140
851 443 720 533 70 29 56 26 90 90
851 583 283 443 206 98 54
268 248 123
304 241
251 311
883 851 32
03 43
851 651 200
270
1000 68 56 01
11 932 918
1000 960 382 199 323 239
31 13 25 12 40 40
1000 685 333 521 242 115 63
315 291 145
357 283
(X) (X)
1000 964 36
(X) (X)
1000 765 235
- Represents zero or rounds to zero Other Asian alone or two or more Asian categories Other Pacific Islander alone or two or more Native Hawaiian and Other Pacific Islander categories
(X) Not applicable
In combination with one or more of the other races listed The six numbers may add to more than the total population and the six percentages may add to more than 1W percent because individuals may repon more than one race
Source US Census Bureau Census 2000
1731 U8 Census Bureau
Yahoo Yellow Pages Page 1 of 2
Home - Yahoo1 - Maps -Address Book - HelL
Welcome Guest User
Yahoo Yellow Pages Genoa OH
Lop gt Co_mmuampy gt GwernmM gt General
All Businesses Business Name Clay Township Trustees (419) 855-7878
Create My Favorite Locations -Sign In
Change Location -Save This Location
I Showing 1-4 of 4 I Beyond Genoa
Address 21774 E Holts Rd GenoaOH
GenoaVi l lae Adm (419) 855-7791
102 E 6th St GenoaOH Map
Genoa Village Offices 1419) 855-7791
102 E 6th St GenoaOH Map
Genoa Village Utility Office (419) 855-7791
102 E 6th St GenoaOH Map
Showing 1-4 of 4 I Beyond Genoa
Beyond Cenoa
Business Information provided by InfoUSA corn Foster City California Copyright 0 2002
1 1 am Vice President of RASP Broadcast Enterprises bc (lsquoaASPrdquo) the license of WJZB(FM) C h e l 2 4 7 A Oak Harbor Obio
RASP intends to apply for a construction permit for Channel 247A to specify oper Itions for WJZE in Genoa Ohio upon adoption ofthe Proposal as outljned h e n through the relevant Notice of Pmposed Rule Making
If am ardd the construction permit for Channel 247A RASP promptlywill construct and ITamp such facilities
2
3
Iherebydec are underpenallyofperjurythat thes ta tementsmade ia th i sdec l~~on~~e and accurate to the Ixst of my howledge information and belief
September a 2 002
DECLARATION
I Jeff Littlejohn declare as follows
3 I am Senior Vice President Engineering of Citicasters Licenses Inc (ldquoCiticastersrdquo) the licensee of WRVF(FM) Channel 268B Toledo Ohio
Citicasters intends to apply for a construction permit for Channel 268B to specamp operations for WRVF in Oak Harbor Ohio upon adoption of the Proposal as outlined herein through the relevant Notice of Proposed Rule Making
If awarded the construction permit for Channel 268B Citicasters promptly wi l l construct and operate such facilities
4
3
I hereby declare under penalty of perjury that the statements made in
this declaration are true and accurate to the best of my knowledge information and
belief
du Treil Lundin amp Rackley Inc Consulting Engineers
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Technical Narrative
This Technical Exhibit of which this Narrative is part proposes an FM Rule Making to modify the Commissions Table of Allotments contained within Section 73202 within the Commissions Rules It is proposed herein to modify the community of license of two FM stations No change in the stations reference coordinates are proposed
Summary of Rule Making Proposal
Below is a summary of the allocation changes requested in the Joint Petition for Rule Making
0 Delete Channel 247A at Oak Harbor Ohio and allot
Contingent on the adoption of the above change Channel 24A at Genoa Ohio
delete Channel 268B at Toledo Ohio and allot Channel 268B at Oak Harbor Ohio
Pursuant to Section 142O(i) of the Commissions Rules the Petition also requests modifications to the licenses of WJZE(FM) Channel 24A Oak Harbor Ohio and WRVF(FM) Channel 268B Toledo Ohio accordingly
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 2
Proposed Channel 247A Genoa Ohio
It is proposed to delete Channel 247A at Oak Harbor and allot Channel 247A to Genoa Ohio The Genoa proposal is mutually exclusive with the current Oak Harbor allotment As no change in the reference site change is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Genoa as shown in Figure 1
Below are the Channel 247A Genoa reference site geographic coordinates
41deg 29 17 North Latitude 83O 19 25 West Longitude
The existing Channel 241A reference coordinates do not satisfy the spacing requirements of Section 73207 with respect to three stations as identified in the allocation study provided in Figure 2 Each is discussed below
First under Section 73207 the proposed Channel 247A reference site is short-spaced to CHYR-FM on Channel 244C1 at Leamington Ontario Canada The required minimum separation distance is 90 kilometers the actual separation distance is 86 kilometers a short- spacing of 4 kilometers This Canadian allotment is a specially negotiated short-spaced allotment which was accepted by the Commission on September 2 1992 Petitionerrs Channel 247A is also a specially negotiated short-spaced allotment which was accepted by Canada on December 14 1992 Therefore because the proposed allotment does not involve any change in the relevant site this previously accepted spacing should satisfy the Commissions allocation requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 3
Second under Section 73207 the proposed Channel 248A reference site is short-spaced to WKRK-FM on Channel 246B at Detroit Michigan The required minimum separation distance is 113 kilometers the actual separation distance is 111 kilometers a short-spacing of 2 kilometers Petitioners Channel 247A was initially allocated as a 3 kilowatt100 meter facility and it remains as an equivalent facility Therefore for allotment purposes WKRK-FM can be protected pursuant to Section 73213(c) of the Commissions Rules which requires a minimum separation distance of 105 kilometers The proposed reference coordinates satisfies this requirement
Third under Section 73207 the proposed Channel 247A reference site is short-spaced to WMEE(FM) on Channel 247B at Fort Wayne Indiana The station was authorized to operate from the reference site (its current site) pursuant to the stations request to be processed under Section 73215 The required minimum separation distance is 178 kilometers the actual separation distance is 162 kilometers a short-spacing of 16 kilometers
However the proposed allotment does not create a new short or not exacerbate any short-spacing (under Section 73207) with regard to WMEE(FM) In addition WJZE(FM) already has been approved to operate at the reference site to the extent is affords WMEE(FM) contour protection pursuant to Section 73215 and the proposed allotment contemplates no change in WJZE(FM)s operating parameters Moreover WJZE(FM)s former (pre-Section 73215) transmitter site satisfied the relevant spacing requirement - the Section 73213(c) separation distance of 163 kilometers with regard to WMEE(FM) As shown in Figure 1 the projected city grade reference contour (70 dBu) of the allotment from this former site encompassed
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 4
the proposed community of Genoa this pre-Section 73215 site is provided in Figure 2
An allocation study from
Figure 5 is an Area-to-Locate map for Channel 247A As can be seen there is no present fully-spaced area-to-locate for this allotment
Proposed Channel 268B Oak Harbor Ohio
It is proposed to delete Channel 268B at Toledo and allot Channel 268B to Oak Harbor Ohio This Oak Harbor proposal is mutually exclusive with the current Toledo allotment As no change in the reference site is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Oak Harbor as shown in Figure 1
Below are the Channel 268B Oak Harbor reference site geographic coordinates
41O 40 23 North Latitude 83O 25 31 West Longitude
The existing Channel 268B reference coordinates do not satisfy Section 73201 requirements with respect to five stations as shown by the allocation study provided in Figure 4 Each short-spacing is discussed below
First under Section 73207 the proposed Channel 268B reference site is short-spaced to WMJK(FM) on Channel 265A at Clyde Ohio The required minimum separation distance is 69 kilometers the actual separation distance is 64 kilometers a short-spacing of 5 kilometers WMJK(FM) is a 3 kilowatt100 meter type Class A facility and therefore is processed pursuant to Section
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 5
13213 of the Rules as the short-spacing (under Section 13207) is not exacerbated
Second under Section 73207 the proposed Channel 268B reference site is short-spaced to WNCO-FM on Channel 267B at Ashland Ohio The required minimum separation distance is 169 kilometers the actual separation distance is 129 kilometers a short-spacing of 40 kilometers However because the Channel 268B allotment and WNCO-FM have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Third under Section 73207 the proposed Channel 268B reference site is short-spaced to a Canadian allotment on Channel 268A The required minimum separation distance is 210 kilometers the actual separation distance is 167 kilometers a short-spacing of 43 kilometers This Canadian allotment is a specially negotiated short-spaced allotment Therefore because the proposed allotment does not involve a change in the relevant site this previously accepted spacing should satisfy the Commissionrsquos allocation requiremements
Fourth under Section 73207 the proposed Channel 268B reference site is short-spaced to the current licensed and authorized facility of WWBN(FM) on Channel 268A at Tuscola Michigan because WWBN(FM) is authorized pursuant to Section 73215 with regard to WRVF(FM) Therefore as WRVF(FM) did not initiate this short- spacing and the proposed re-allotment involves no change in the WRVF(FM)rsquos current transmitter site the proposed spacing satisfies the Commissionrsquos allotment requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 6
Fifth under Section 73207 the proposed Channel 268B reference site is short-spaced to WNSN(FM) on Channel 268B at South Bend Indiana The required minimum separation distance is 14 kilometers the actual separation distance is 68 kilometers a short-spacing of 6 kilometers However because the Channel 268B allotment and WNSN(FM) have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Proposed Modifications to Table of Allotments
This proposal provides for the following allotment changes to Section 73202 The Commissionrsquos Table of FM Allotments
Lowell Oil Center (historical) hobth Amsden Maple Grove
Watson lie Mount Gilead
10 0 10 20 30 40 miles
H H H H t I I I I I I
H H H H I I I I I I I I 10 0 10 20 30 40 50 kilometers
CITY GRADE REFERENCE CONTOURS
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 2
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 241A Genoa Ohio Allocation Study Proposed Reference Site
41deg 29rsquo 17rdquo North Latitude 8 3 O 19rsquo 25ldquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(rn) Longitude deg-True (km) (hi) WBVI FOSTORIA BLH 244A 30 41-06-00 1964 4494 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR- F LEAMINGTON 244C1 910 42-00-35 472 8582 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Commission wJl approve an application to move a stationrsquos transmitter site to a
location closer to another stationrsquos site than would be permitted under
Section 73207 so long as the re-locating station provides contour protection to the
other station For allotment purposes Commission precedent has accepted a
proposed reference site that is the existing site of a station seeking t o change its
community of license even though that site satisfies the Commissionrsquos technical
requirements only through Section 7321521 In this precedent the Commission
approves the proposed change if ldquono new short-spacing would be created and no
existing short-spacing exacerbatedrdquo 81 To date the Commission has used this
policy only to authorize a community of license change by a station that became
subject to Section 73215 because of a processing request by another station But
the Commission likewise should not deny a quali6ed community its first local
transmission service simply because a station wishing to be reassigned to that
community previously had requested Section 73215 processing in a permit
application At a minimum there is no reason to deny a community its first local
transmission service when the relevant station encompassed the proposed
community with its projected 70 d s u contour (pursuant to Allocationsrsquo uniform
terrain maximum facilities methodology) prior to the application in which the
station requested Section 732 15 processing
- 71 (Allocations 2000)
- 81 Id
See Killeen and Cedar Park Terns Report and Order 15 FCC Rcd 1945
An example demonstrates the point Under the Commissionrsquos current
Section 73215 allotment policy a station that has never requested Section 73215
processing could petition to become the first local transmission service for an
eligible community (the ldquoCommunityrdquo) so long as its 70 dBu contour encompasses
the Community (and it satisfies other technical standards) Once that change
occurs the station then could request Section 73215 processing with respect to a
second station as part of an application t o move to a better transmitter site
Accordingly the same station should be able t o obtain Commission approval for the
exact same requests in reverse order first the station requests Section 73215
processing to move closer t o another station second the station requests a change
in its community of license to a community that had been encompassed by its
predicted 70 dBu signal from both its pre-Section 73215 and its current transmitter
site As each set of changes reach the same real world result there is no non-
arbitrary basis for permitting the first set of moves as consistent with the public
interest but precluding the second as contrary to the public interest
Here the Proposal does not involve a station that seeks to be re-
assigned to a community that was outside its projected 70 dl3u contour from its pre-
Section 73215 site WJZE using the maximum facilities and uniform terrain
projection method employed in the allocations process provided 70 dBu coverage of
Genoa from its pre-Section 73215 site 91 Also the proposed re-allotment satisfies
the actual test employed by the Commission in its precedent approving the
___ - 91 See Technical Exhibit a t 3
reallotment of Section 732 15-designated stations the proposed Genoa re-allotment
neither creates nor exacerbates any short spacing prohibited by Section 73215
Accordingly that WJZE requested Section 732 15 processing with respect to a
single station - W M E E O Fort Wayne Inhana -in order to improve service
several years ago should not preclude the proposed reallotment which does not
exacerbate or create any short-spacing and will not enable a station t o be assigned
to a community to which it could not have been assigned but for a previous
Section 73215 request by that station
Grant of the proposal advances the public interest First it satisfies
one of the Commissionrsquos key allotment priorities it provides a deserving community
its first local transmission service Second adoption of the proposal will confirm
that the Commission does not intend t o maintain an arbitrary disparity in the way
it processes an allotment request depending on when a station might have
requested Section 73215 treatment which also will ensure that all stations are
able to maximize their service to the public
For all the foregoing reasons the Commission should issue an
appropriate Notice of Proposed Rule Making and then approve the proposed
modifications of the Table of Allotments and WJZErsquos and WRVFrsquos licenses under
Section 1420(i) of the Commissionrsquos Rules
Respectfully submitted
REDDY BEGLEY amp MCCORMICK
2175 K Street NW Suite 350 Washington DC 20037-1803
Telephone 202-659-5700 Facsimile 202-659-571 1
Attorneys for Rasp Broadcasting Enterprises Inc
September 26 2002
HOGAN amp HARTSON LLP
By Marissa G Repp lsquo
555 Thirteenth Street NW Washington DC 20004- 1109 Telephone 202-637-6845 Facsimile 202-637-5910
Attorneys for Citicasters Licenses Inc
EXHIBIT 1
Table DP1 Profile of General Demographic Characteristics 2000 Geographic Area Genoa village Ohio [For information on confidentiality protection nonsampiing error and definitions see text]
Subject Number Percent Subjen
Total populallon SEX AND AGE Male Female Under 5 years 5 to 9 years 10 to 14 years 15 to 19 yeam 20 lo 24 years 25 to 34 years 35 to44 years 45 to 54 years 55 to 59 years
75 lo 84 years 85 years and over
Median age (yean) 18 years and over
Male Female
21 years and over
65 years and over Male Female
RACE One race
White Black or African American American Indian and Alaska Native Asian
Asian Indian Chinese
Native Hawaiian Guamanian or Chamom Samoan Other Pacific Islander
Some ather race Two or more races Race elone or In comblnstlon wlth one
While Black or African American American Indian and Alaska Nati Asian Native Hawaiian and Ofher P a d
or mom other 11caa
I
2230
1062 1168
122 169 173 159 88
291 353 294 90 90
152 178 71
383
1859 751 908
1583 451 401 129 272
2197 2120
8 7 6 1
2
2 1 1
1
55 33
2152 11 14 9 4
1000
476 524 55 78 78 71 39
130 l58 132 40 40 6 8 80 32
(x 744 337 407 71 O 202 180 58
122
98 5 951 04 0 3 0 3
O
01
25 15
-
96 5
E
HISPANIC OR LATINO AND RACE Total populallon
hispanic or LaLna (of any race) Mexican Pueno Rtcan Cunan Otner Hispanic or LSI~O
Whne aone
RELATIONSHIP ~ o t a ~ popu~m~on
In haampenom riousehoiaer Spouse Chid
Own chid unoer I8 years Otner re atives
Jnaer 18 years honrelatwes
Unmarriea partner
hot Hispanic or Latino
In group quarters Insttutionalized ppulat on honlnsttut onallzed popdjatlon
HOUSEHOLD BY N P E Tot81 houuholda
Famly housemlas (tamlies) WiIh own chmen unaer 18 years
Mamea-couple family W th own children under 18 years
Female musenolder no hasDana present Witn own chilaren maer 18 years
hontamily nouseholds Householoer living aone
rlouseholaer 65 yeas ano over
Households with Inawlduals under 18 years rlousenolas wnn inaividJals 65 years ana over
0wneroccupiea homng units Renter-occupiea housing unts
For seasonai receatona or
02 Average household size of owner-occupied unil 33 I Averam household size of renter-occuoied unit Some other race
Number I Percent
74
2230 152 125
2
25 2078 2042
2230 2140
851 443 720 533 70 29 56 26 90 90
851 583 283 443 206 98 54
268 248 123
304 241
251 311
883 851 32
03 43
851 651 200
270
1000 68 56 01
11 932 918
1000 960 382 199 323 239
31 13 25 12 40 40
1000 685 333 521 242 115 63
315 291 145
357 283
(X) (X)
1000 964 36
(X) (X)
1000 765 235
- Represents zero or rounds to zero Other Asian alone or two or more Asian categories Other Pacific Islander alone or two or more Native Hawaiian and Other Pacific Islander categories
(X) Not applicable
In combination with one or more of the other races listed The six numbers may add to more than the total population and the six percentages may add to more than 1W percent because individuals may repon more than one race
Source US Census Bureau Census 2000
1731 U8 Census Bureau
Yahoo Yellow Pages Page 1 of 2
Home - Yahoo1 - Maps -Address Book - HelL
Welcome Guest User
Yahoo Yellow Pages Genoa OH
Lop gt Co_mmuampy gt GwernmM gt General
All Businesses Business Name Clay Township Trustees (419) 855-7878
Create My Favorite Locations -Sign In
Change Location -Save This Location
I Showing 1-4 of 4 I Beyond Genoa
Address 21774 E Holts Rd GenoaOH
GenoaVi l lae Adm (419) 855-7791
102 E 6th St GenoaOH Map
Genoa Village Offices 1419) 855-7791
102 E 6th St GenoaOH Map
Genoa Village Utility Office (419) 855-7791
102 E 6th St GenoaOH Map
Showing 1-4 of 4 I Beyond Genoa
Beyond Cenoa
Business Information provided by InfoUSA corn Foster City California Copyright 0 2002
1 1 am Vice President of RASP Broadcast Enterprises bc (lsquoaASPrdquo) the license of WJZB(FM) C h e l 2 4 7 A Oak Harbor Obio
RASP intends to apply for a construction permit for Channel 247A to specify oper Itions for WJZE in Genoa Ohio upon adoption ofthe Proposal as outljned h e n through the relevant Notice of Pmposed Rule Making
If am ardd the construction permit for Channel 247A RASP promptlywill construct and ITamp such facilities
2
3
Iherebydec are underpenallyofperjurythat thes ta tementsmade ia th i sdec l~~on~~e and accurate to the Ixst of my howledge information and belief
September a 2 002
DECLARATION
I Jeff Littlejohn declare as follows
3 I am Senior Vice President Engineering of Citicasters Licenses Inc (ldquoCiticastersrdquo) the licensee of WRVF(FM) Channel 268B Toledo Ohio
Citicasters intends to apply for a construction permit for Channel 268B to specamp operations for WRVF in Oak Harbor Ohio upon adoption of the Proposal as outlined herein through the relevant Notice of Proposed Rule Making
If awarded the construction permit for Channel 268B Citicasters promptly wi l l construct and operate such facilities
4
3
I hereby declare under penalty of perjury that the statements made in
this declaration are true and accurate to the best of my knowledge information and
belief
du Treil Lundin amp Rackley Inc Consulting Engineers
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Technical Narrative
This Technical Exhibit of which this Narrative is part proposes an FM Rule Making to modify the Commissions Table of Allotments contained within Section 73202 within the Commissions Rules It is proposed herein to modify the community of license of two FM stations No change in the stations reference coordinates are proposed
Summary of Rule Making Proposal
Below is a summary of the allocation changes requested in the Joint Petition for Rule Making
0 Delete Channel 247A at Oak Harbor Ohio and allot
Contingent on the adoption of the above change Channel 24A at Genoa Ohio
delete Channel 268B at Toledo Ohio and allot Channel 268B at Oak Harbor Ohio
Pursuant to Section 142O(i) of the Commissions Rules the Petition also requests modifications to the licenses of WJZE(FM) Channel 24A Oak Harbor Ohio and WRVF(FM) Channel 268B Toledo Ohio accordingly
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 2
Proposed Channel 247A Genoa Ohio
It is proposed to delete Channel 247A at Oak Harbor and allot Channel 247A to Genoa Ohio The Genoa proposal is mutually exclusive with the current Oak Harbor allotment As no change in the reference site change is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Genoa as shown in Figure 1
Below are the Channel 247A Genoa reference site geographic coordinates
41deg 29 17 North Latitude 83O 19 25 West Longitude
The existing Channel 241A reference coordinates do not satisfy the spacing requirements of Section 73207 with respect to three stations as identified in the allocation study provided in Figure 2 Each is discussed below
First under Section 73207 the proposed Channel 247A reference site is short-spaced to CHYR-FM on Channel 244C1 at Leamington Ontario Canada The required minimum separation distance is 90 kilometers the actual separation distance is 86 kilometers a short- spacing of 4 kilometers This Canadian allotment is a specially negotiated short-spaced allotment which was accepted by the Commission on September 2 1992 Petitionerrs Channel 247A is also a specially negotiated short-spaced allotment which was accepted by Canada on December 14 1992 Therefore because the proposed allotment does not involve any change in the relevant site this previously accepted spacing should satisfy the Commissions allocation requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 3
Second under Section 73207 the proposed Channel 248A reference site is short-spaced to WKRK-FM on Channel 246B at Detroit Michigan The required minimum separation distance is 113 kilometers the actual separation distance is 111 kilometers a short-spacing of 2 kilometers Petitioners Channel 247A was initially allocated as a 3 kilowatt100 meter facility and it remains as an equivalent facility Therefore for allotment purposes WKRK-FM can be protected pursuant to Section 73213(c) of the Commissions Rules which requires a minimum separation distance of 105 kilometers The proposed reference coordinates satisfies this requirement
Third under Section 73207 the proposed Channel 247A reference site is short-spaced to WMEE(FM) on Channel 247B at Fort Wayne Indiana The station was authorized to operate from the reference site (its current site) pursuant to the stations request to be processed under Section 73215 The required minimum separation distance is 178 kilometers the actual separation distance is 162 kilometers a short-spacing of 16 kilometers
However the proposed allotment does not create a new short or not exacerbate any short-spacing (under Section 73207) with regard to WMEE(FM) In addition WJZE(FM) already has been approved to operate at the reference site to the extent is affords WMEE(FM) contour protection pursuant to Section 73215 and the proposed allotment contemplates no change in WJZE(FM)s operating parameters Moreover WJZE(FM)s former (pre-Section 73215) transmitter site satisfied the relevant spacing requirement - the Section 73213(c) separation distance of 163 kilometers with regard to WMEE(FM) As shown in Figure 1 the projected city grade reference contour (70 dBu) of the allotment from this former site encompassed
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 4
the proposed community of Genoa this pre-Section 73215 site is provided in Figure 2
An allocation study from
Figure 5 is an Area-to-Locate map for Channel 247A As can be seen there is no present fully-spaced area-to-locate for this allotment
Proposed Channel 268B Oak Harbor Ohio
It is proposed to delete Channel 268B at Toledo and allot Channel 268B to Oak Harbor Ohio This Oak Harbor proposal is mutually exclusive with the current Toledo allotment As no change in the reference site is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Oak Harbor as shown in Figure 1
Below are the Channel 268B Oak Harbor reference site geographic coordinates
41O 40 23 North Latitude 83O 25 31 West Longitude
The existing Channel 268B reference coordinates do not satisfy Section 73201 requirements with respect to five stations as shown by the allocation study provided in Figure 4 Each short-spacing is discussed below
First under Section 73207 the proposed Channel 268B reference site is short-spaced to WMJK(FM) on Channel 265A at Clyde Ohio The required minimum separation distance is 69 kilometers the actual separation distance is 64 kilometers a short-spacing of 5 kilometers WMJK(FM) is a 3 kilowatt100 meter type Class A facility and therefore is processed pursuant to Section
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 5
13213 of the Rules as the short-spacing (under Section 13207) is not exacerbated
Second under Section 73207 the proposed Channel 268B reference site is short-spaced to WNCO-FM on Channel 267B at Ashland Ohio The required minimum separation distance is 169 kilometers the actual separation distance is 129 kilometers a short-spacing of 40 kilometers However because the Channel 268B allotment and WNCO-FM have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Third under Section 73207 the proposed Channel 268B reference site is short-spaced to a Canadian allotment on Channel 268A The required minimum separation distance is 210 kilometers the actual separation distance is 167 kilometers a short-spacing of 43 kilometers This Canadian allotment is a specially negotiated short-spaced allotment Therefore because the proposed allotment does not involve a change in the relevant site this previously accepted spacing should satisfy the Commissionrsquos allocation requiremements
Fourth under Section 73207 the proposed Channel 268B reference site is short-spaced to the current licensed and authorized facility of WWBN(FM) on Channel 268A at Tuscola Michigan because WWBN(FM) is authorized pursuant to Section 73215 with regard to WRVF(FM) Therefore as WRVF(FM) did not initiate this short- spacing and the proposed re-allotment involves no change in the WRVF(FM)rsquos current transmitter site the proposed spacing satisfies the Commissionrsquos allotment requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 6
Fifth under Section 73207 the proposed Channel 268B reference site is short-spaced to WNSN(FM) on Channel 268B at South Bend Indiana The required minimum separation distance is 14 kilometers the actual separation distance is 68 kilometers a short-spacing of 6 kilometers However because the Channel 268B allotment and WNSN(FM) have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Proposed Modifications to Table of Allotments
This proposal provides for the following allotment changes to Section 73202 The Commissionrsquos Table of FM Allotments
Lowell Oil Center (historical) hobth Amsden Maple Grove
Watson lie Mount Gilead
10 0 10 20 30 40 miles
H H H H t I I I I I I
H H H H I I I I I I I I 10 0 10 20 30 40 50 kilometers
CITY GRADE REFERENCE CONTOURS
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 2
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 241A Genoa Ohio Allocation Study Proposed Reference Site
41deg 29rsquo 17rdquo North Latitude 8 3 O 19rsquo 25ldquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(rn) Longitude deg-True (km) (hi) WBVI FOSTORIA BLH 244A 30 41-06-00 1964 4494 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR- F LEAMINGTON 244C1 910 42-00-35 472 8582 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
An example demonstrates the point Under the Commissionrsquos current
Section 73215 allotment policy a station that has never requested Section 73215
processing could petition to become the first local transmission service for an
eligible community (the ldquoCommunityrdquo) so long as its 70 dBu contour encompasses
the Community (and it satisfies other technical standards) Once that change
occurs the station then could request Section 73215 processing with respect to a
second station as part of an application t o move to a better transmitter site
Accordingly the same station should be able t o obtain Commission approval for the
exact same requests in reverse order first the station requests Section 73215
processing to move closer t o another station second the station requests a change
in its community of license to a community that had been encompassed by its
predicted 70 dBu signal from both its pre-Section 73215 and its current transmitter
site As each set of changes reach the same real world result there is no non-
arbitrary basis for permitting the first set of moves as consistent with the public
interest but precluding the second as contrary to the public interest
Here the Proposal does not involve a station that seeks to be re-
assigned to a community that was outside its projected 70 dl3u contour from its pre-
Section 73215 site WJZE using the maximum facilities and uniform terrain
projection method employed in the allocations process provided 70 dBu coverage of
Genoa from its pre-Section 73215 site 91 Also the proposed re-allotment satisfies
the actual test employed by the Commission in its precedent approving the
___ - 91 See Technical Exhibit a t 3
reallotment of Section 732 15-designated stations the proposed Genoa re-allotment
neither creates nor exacerbates any short spacing prohibited by Section 73215
Accordingly that WJZE requested Section 732 15 processing with respect to a
single station - W M E E O Fort Wayne Inhana -in order to improve service
several years ago should not preclude the proposed reallotment which does not
exacerbate or create any short-spacing and will not enable a station t o be assigned
to a community to which it could not have been assigned but for a previous
Section 73215 request by that station
Grant of the proposal advances the public interest First it satisfies
one of the Commissionrsquos key allotment priorities it provides a deserving community
its first local transmission service Second adoption of the proposal will confirm
that the Commission does not intend t o maintain an arbitrary disparity in the way
it processes an allotment request depending on when a station might have
requested Section 73215 treatment which also will ensure that all stations are
able to maximize their service to the public
For all the foregoing reasons the Commission should issue an
appropriate Notice of Proposed Rule Making and then approve the proposed
modifications of the Table of Allotments and WJZErsquos and WRVFrsquos licenses under
Section 1420(i) of the Commissionrsquos Rules
Respectfully submitted
REDDY BEGLEY amp MCCORMICK
2175 K Street NW Suite 350 Washington DC 20037-1803
Telephone 202-659-5700 Facsimile 202-659-571 1
Attorneys for Rasp Broadcasting Enterprises Inc
September 26 2002
HOGAN amp HARTSON LLP
By Marissa G Repp lsquo
555 Thirteenth Street NW Washington DC 20004- 1109 Telephone 202-637-6845 Facsimile 202-637-5910
Attorneys for Citicasters Licenses Inc
EXHIBIT 1
Table DP1 Profile of General Demographic Characteristics 2000 Geographic Area Genoa village Ohio [For information on confidentiality protection nonsampiing error and definitions see text]
Subject Number Percent Subjen
Total populallon SEX AND AGE Male Female Under 5 years 5 to 9 years 10 to 14 years 15 to 19 yeam 20 lo 24 years 25 to 34 years 35 to44 years 45 to 54 years 55 to 59 years
75 lo 84 years 85 years and over
Median age (yean) 18 years and over
Male Female
21 years and over
65 years and over Male Female
RACE One race
White Black or African American American Indian and Alaska Native Asian
Asian Indian Chinese
Native Hawaiian Guamanian or Chamom Samoan Other Pacific Islander
Some ather race Two or more races Race elone or In comblnstlon wlth one
While Black or African American American Indian and Alaska Nati Asian Native Hawaiian and Ofher P a d
or mom other 11caa
I
2230
1062 1168
122 169 173 159 88
291 353 294 90 90
152 178 71
383
1859 751 908
1583 451 401 129 272
2197 2120
8 7 6 1
2
2 1 1
1
55 33
2152 11 14 9 4
1000
476 524 55 78 78 71 39
130 l58 132 40 40 6 8 80 32
(x 744 337 407 71 O 202 180 58
122
98 5 951 04 0 3 0 3
O
01
25 15
-
96 5
E
HISPANIC OR LATINO AND RACE Total populallon
hispanic or LaLna (of any race) Mexican Pueno Rtcan Cunan Otner Hispanic or LSI~O
Whne aone
RELATIONSHIP ~ o t a ~ popu~m~on
In haampenom riousehoiaer Spouse Chid
Own chid unoer I8 years Otner re atives
Jnaer 18 years honrelatwes
Unmarriea partner
hot Hispanic or Latino
In group quarters Insttutionalized ppulat on honlnsttut onallzed popdjatlon
HOUSEHOLD BY N P E Tot81 houuholda
Famly housemlas (tamlies) WiIh own chmen unaer 18 years
Mamea-couple family W th own children under 18 years
Female musenolder no hasDana present Witn own chilaren maer 18 years
hontamily nouseholds Householoer living aone
rlouseholaer 65 yeas ano over
Households with Inawlduals under 18 years rlousenolas wnn inaividJals 65 years ana over
0wneroccupiea homng units Renter-occupiea housing unts
For seasonai receatona or
02 Average household size of owner-occupied unil 33 I Averam household size of renter-occuoied unit Some other race
Number I Percent
74
2230 152 125
2
25 2078 2042
2230 2140
851 443 720 533 70 29 56 26 90 90
851 583 283 443 206 98 54
268 248 123
304 241
251 311
883 851 32
03 43
851 651 200
270
1000 68 56 01
11 932 918
1000 960 382 199 323 239
31 13 25 12 40 40
1000 685 333 521 242 115 63
315 291 145
357 283
(X) (X)
1000 964 36
(X) (X)
1000 765 235
- Represents zero or rounds to zero Other Asian alone or two or more Asian categories Other Pacific Islander alone or two or more Native Hawaiian and Other Pacific Islander categories
(X) Not applicable
In combination with one or more of the other races listed The six numbers may add to more than the total population and the six percentages may add to more than 1W percent because individuals may repon more than one race
Source US Census Bureau Census 2000
1731 U8 Census Bureau
Yahoo Yellow Pages Page 1 of 2
Home - Yahoo1 - Maps -Address Book - HelL
Welcome Guest User
Yahoo Yellow Pages Genoa OH
Lop gt Co_mmuampy gt GwernmM gt General
All Businesses Business Name Clay Township Trustees (419) 855-7878
Create My Favorite Locations -Sign In
Change Location -Save This Location
I Showing 1-4 of 4 I Beyond Genoa
Address 21774 E Holts Rd GenoaOH
GenoaVi l lae Adm (419) 855-7791
102 E 6th St GenoaOH Map
Genoa Village Offices 1419) 855-7791
102 E 6th St GenoaOH Map
Genoa Village Utility Office (419) 855-7791
102 E 6th St GenoaOH Map
Showing 1-4 of 4 I Beyond Genoa
Beyond Cenoa
Business Information provided by InfoUSA corn Foster City California Copyright 0 2002
1 1 am Vice President of RASP Broadcast Enterprises bc (lsquoaASPrdquo) the license of WJZB(FM) C h e l 2 4 7 A Oak Harbor Obio
RASP intends to apply for a construction permit for Channel 247A to specify oper Itions for WJZE in Genoa Ohio upon adoption ofthe Proposal as outljned h e n through the relevant Notice of Pmposed Rule Making
If am ardd the construction permit for Channel 247A RASP promptlywill construct and ITamp such facilities
2
3
Iherebydec are underpenallyofperjurythat thes ta tementsmade ia th i sdec l~~on~~e and accurate to the Ixst of my howledge information and belief
September a 2 002
DECLARATION
I Jeff Littlejohn declare as follows
3 I am Senior Vice President Engineering of Citicasters Licenses Inc (ldquoCiticastersrdquo) the licensee of WRVF(FM) Channel 268B Toledo Ohio
Citicasters intends to apply for a construction permit for Channel 268B to specamp operations for WRVF in Oak Harbor Ohio upon adoption of the Proposal as outlined herein through the relevant Notice of Proposed Rule Making
If awarded the construction permit for Channel 268B Citicasters promptly wi l l construct and operate such facilities
4
3
I hereby declare under penalty of perjury that the statements made in
this declaration are true and accurate to the best of my knowledge information and
belief
du Treil Lundin amp Rackley Inc Consulting Engineers
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Technical Narrative
This Technical Exhibit of which this Narrative is part proposes an FM Rule Making to modify the Commissions Table of Allotments contained within Section 73202 within the Commissions Rules It is proposed herein to modify the community of license of two FM stations No change in the stations reference coordinates are proposed
Summary of Rule Making Proposal
Below is a summary of the allocation changes requested in the Joint Petition for Rule Making
0 Delete Channel 247A at Oak Harbor Ohio and allot
Contingent on the adoption of the above change Channel 24A at Genoa Ohio
delete Channel 268B at Toledo Ohio and allot Channel 268B at Oak Harbor Ohio
Pursuant to Section 142O(i) of the Commissions Rules the Petition also requests modifications to the licenses of WJZE(FM) Channel 24A Oak Harbor Ohio and WRVF(FM) Channel 268B Toledo Ohio accordingly
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 2
Proposed Channel 247A Genoa Ohio
It is proposed to delete Channel 247A at Oak Harbor and allot Channel 247A to Genoa Ohio The Genoa proposal is mutually exclusive with the current Oak Harbor allotment As no change in the reference site change is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Genoa as shown in Figure 1
Below are the Channel 247A Genoa reference site geographic coordinates
41deg 29 17 North Latitude 83O 19 25 West Longitude
The existing Channel 241A reference coordinates do not satisfy the spacing requirements of Section 73207 with respect to three stations as identified in the allocation study provided in Figure 2 Each is discussed below
First under Section 73207 the proposed Channel 247A reference site is short-spaced to CHYR-FM on Channel 244C1 at Leamington Ontario Canada The required minimum separation distance is 90 kilometers the actual separation distance is 86 kilometers a short- spacing of 4 kilometers This Canadian allotment is a specially negotiated short-spaced allotment which was accepted by the Commission on September 2 1992 Petitionerrs Channel 247A is also a specially negotiated short-spaced allotment which was accepted by Canada on December 14 1992 Therefore because the proposed allotment does not involve any change in the relevant site this previously accepted spacing should satisfy the Commissions allocation requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 3
Second under Section 73207 the proposed Channel 248A reference site is short-spaced to WKRK-FM on Channel 246B at Detroit Michigan The required minimum separation distance is 113 kilometers the actual separation distance is 111 kilometers a short-spacing of 2 kilometers Petitioners Channel 247A was initially allocated as a 3 kilowatt100 meter facility and it remains as an equivalent facility Therefore for allotment purposes WKRK-FM can be protected pursuant to Section 73213(c) of the Commissions Rules which requires a minimum separation distance of 105 kilometers The proposed reference coordinates satisfies this requirement
Third under Section 73207 the proposed Channel 247A reference site is short-spaced to WMEE(FM) on Channel 247B at Fort Wayne Indiana The station was authorized to operate from the reference site (its current site) pursuant to the stations request to be processed under Section 73215 The required minimum separation distance is 178 kilometers the actual separation distance is 162 kilometers a short-spacing of 16 kilometers
However the proposed allotment does not create a new short or not exacerbate any short-spacing (under Section 73207) with regard to WMEE(FM) In addition WJZE(FM) already has been approved to operate at the reference site to the extent is affords WMEE(FM) contour protection pursuant to Section 73215 and the proposed allotment contemplates no change in WJZE(FM)s operating parameters Moreover WJZE(FM)s former (pre-Section 73215) transmitter site satisfied the relevant spacing requirement - the Section 73213(c) separation distance of 163 kilometers with regard to WMEE(FM) As shown in Figure 1 the projected city grade reference contour (70 dBu) of the allotment from this former site encompassed
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 4
the proposed community of Genoa this pre-Section 73215 site is provided in Figure 2
An allocation study from
Figure 5 is an Area-to-Locate map for Channel 247A As can be seen there is no present fully-spaced area-to-locate for this allotment
Proposed Channel 268B Oak Harbor Ohio
It is proposed to delete Channel 268B at Toledo and allot Channel 268B to Oak Harbor Ohio This Oak Harbor proposal is mutually exclusive with the current Toledo allotment As no change in the reference site is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Oak Harbor as shown in Figure 1
Below are the Channel 268B Oak Harbor reference site geographic coordinates
41O 40 23 North Latitude 83O 25 31 West Longitude
The existing Channel 268B reference coordinates do not satisfy Section 73201 requirements with respect to five stations as shown by the allocation study provided in Figure 4 Each short-spacing is discussed below
First under Section 73207 the proposed Channel 268B reference site is short-spaced to WMJK(FM) on Channel 265A at Clyde Ohio The required minimum separation distance is 69 kilometers the actual separation distance is 64 kilometers a short-spacing of 5 kilometers WMJK(FM) is a 3 kilowatt100 meter type Class A facility and therefore is processed pursuant to Section
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 5
13213 of the Rules as the short-spacing (under Section 13207) is not exacerbated
Second under Section 73207 the proposed Channel 268B reference site is short-spaced to WNCO-FM on Channel 267B at Ashland Ohio The required minimum separation distance is 169 kilometers the actual separation distance is 129 kilometers a short-spacing of 40 kilometers However because the Channel 268B allotment and WNCO-FM have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Third under Section 73207 the proposed Channel 268B reference site is short-spaced to a Canadian allotment on Channel 268A The required minimum separation distance is 210 kilometers the actual separation distance is 167 kilometers a short-spacing of 43 kilometers This Canadian allotment is a specially negotiated short-spaced allotment Therefore because the proposed allotment does not involve a change in the relevant site this previously accepted spacing should satisfy the Commissionrsquos allocation requiremements
Fourth under Section 73207 the proposed Channel 268B reference site is short-spaced to the current licensed and authorized facility of WWBN(FM) on Channel 268A at Tuscola Michigan because WWBN(FM) is authorized pursuant to Section 73215 with regard to WRVF(FM) Therefore as WRVF(FM) did not initiate this short- spacing and the proposed re-allotment involves no change in the WRVF(FM)rsquos current transmitter site the proposed spacing satisfies the Commissionrsquos allotment requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 6
Fifth under Section 73207 the proposed Channel 268B reference site is short-spaced to WNSN(FM) on Channel 268B at South Bend Indiana The required minimum separation distance is 14 kilometers the actual separation distance is 68 kilometers a short-spacing of 6 kilometers However because the Channel 268B allotment and WNSN(FM) have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Proposed Modifications to Table of Allotments
This proposal provides for the following allotment changes to Section 73202 The Commissionrsquos Table of FM Allotments
Lowell Oil Center (historical) hobth Amsden Maple Grove
Watson lie Mount Gilead
10 0 10 20 30 40 miles
H H H H t I I I I I I
H H H H I I I I I I I I 10 0 10 20 30 40 50 kilometers
CITY GRADE REFERENCE CONTOURS
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 2
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 241A Genoa Ohio Allocation Study Proposed Reference Site
41deg 29rsquo 17rdquo North Latitude 8 3 O 19rsquo 25ldquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(rn) Longitude deg-True (km) (hi) WBVI FOSTORIA BLH 244A 30 41-06-00 1964 4494 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR- F LEAMINGTON 244C1 910 42-00-35 472 8582 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
reallotment of Section 732 15-designated stations the proposed Genoa re-allotment
neither creates nor exacerbates any short spacing prohibited by Section 73215
Accordingly that WJZE requested Section 732 15 processing with respect to a
single station - W M E E O Fort Wayne Inhana -in order to improve service
several years ago should not preclude the proposed reallotment which does not
exacerbate or create any short-spacing and will not enable a station t o be assigned
to a community to which it could not have been assigned but for a previous
Section 73215 request by that station
Grant of the proposal advances the public interest First it satisfies
one of the Commissionrsquos key allotment priorities it provides a deserving community
its first local transmission service Second adoption of the proposal will confirm
that the Commission does not intend t o maintain an arbitrary disparity in the way
it processes an allotment request depending on when a station might have
requested Section 73215 treatment which also will ensure that all stations are
able to maximize their service to the public
For all the foregoing reasons the Commission should issue an
appropriate Notice of Proposed Rule Making and then approve the proposed
modifications of the Table of Allotments and WJZErsquos and WRVFrsquos licenses under
Section 1420(i) of the Commissionrsquos Rules
Respectfully submitted
REDDY BEGLEY amp MCCORMICK
2175 K Street NW Suite 350 Washington DC 20037-1803
Telephone 202-659-5700 Facsimile 202-659-571 1
Attorneys for Rasp Broadcasting Enterprises Inc
September 26 2002
HOGAN amp HARTSON LLP
By Marissa G Repp lsquo
555 Thirteenth Street NW Washington DC 20004- 1109 Telephone 202-637-6845 Facsimile 202-637-5910
Attorneys for Citicasters Licenses Inc
EXHIBIT 1
Table DP1 Profile of General Demographic Characteristics 2000 Geographic Area Genoa village Ohio [For information on confidentiality protection nonsampiing error and definitions see text]
Subject Number Percent Subjen
Total populallon SEX AND AGE Male Female Under 5 years 5 to 9 years 10 to 14 years 15 to 19 yeam 20 lo 24 years 25 to 34 years 35 to44 years 45 to 54 years 55 to 59 years
75 lo 84 years 85 years and over
Median age (yean) 18 years and over
Male Female
21 years and over
65 years and over Male Female
RACE One race
White Black or African American American Indian and Alaska Native Asian
Asian Indian Chinese
Native Hawaiian Guamanian or Chamom Samoan Other Pacific Islander
Some ather race Two or more races Race elone or In comblnstlon wlth one
While Black or African American American Indian and Alaska Nati Asian Native Hawaiian and Ofher P a d
or mom other 11caa
I
2230
1062 1168
122 169 173 159 88
291 353 294 90 90
152 178 71
383
1859 751 908
1583 451 401 129 272
2197 2120
8 7 6 1
2
2 1 1
1
55 33
2152 11 14 9 4
1000
476 524 55 78 78 71 39
130 l58 132 40 40 6 8 80 32
(x 744 337 407 71 O 202 180 58
122
98 5 951 04 0 3 0 3
O
01
25 15
-
96 5
E
HISPANIC OR LATINO AND RACE Total populallon
hispanic or LaLna (of any race) Mexican Pueno Rtcan Cunan Otner Hispanic or LSI~O
Whne aone
RELATIONSHIP ~ o t a ~ popu~m~on
In haampenom riousehoiaer Spouse Chid
Own chid unoer I8 years Otner re atives
Jnaer 18 years honrelatwes
Unmarriea partner
hot Hispanic or Latino
In group quarters Insttutionalized ppulat on honlnsttut onallzed popdjatlon
HOUSEHOLD BY N P E Tot81 houuholda
Famly housemlas (tamlies) WiIh own chmen unaer 18 years
Mamea-couple family W th own children under 18 years
Female musenolder no hasDana present Witn own chilaren maer 18 years
hontamily nouseholds Householoer living aone
rlouseholaer 65 yeas ano over
Households with Inawlduals under 18 years rlousenolas wnn inaividJals 65 years ana over
0wneroccupiea homng units Renter-occupiea housing unts
For seasonai receatona or
02 Average household size of owner-occupied unil 33 I Averam household size of renter-occuoied unit Some other race
Number I Percent
74
2230 152 125
2
25 2078 2042
2230 2140
851 443 720 533 70 29 56 26 90 90
851 583 283 443 206 98 54
268 248 123
304 241
251 311
883 851 32
03 43
851 651 200
270
1000 68 56 01
11 932 918
1000 960 382 199 323 239
31 13 25 12 40 40
1000 685 333 521 242 115 63
315 291 145
357 283
(X) (X)
1000 964 36
(X) (X)
1000 765 235
- Represents zero or rounds to zero Other Asian alone or two or more Asian categories Other Pacific Islander alone or two or more Native Hawaiian and Other Pacific Islander categories
(X) Not applicable
In combination with one or more of the other races listed The six numbers may add to more than the total population and the six percentages may add to more than 1W percent because individuals may repon more than one race
Source US Census Bureau Census 2000
1731 U8 Census Bureau
Yahoo Yellow Pages Page 1 of 2
Home - Yahoo1 - Maps -Address Book - HelL
Welcome Guest User
Yahoo Yellow Pages Genoa OH
Lop gt Co_mmuampy gt GwernmM gt General
All Businesses Business Name Clay Township Trustees (419) 855-7878
Create My Favorite Locations -Sign In
Change Location -Save This Location
I Showing 1-4 of 4 I Beyond Genoa
Address 21774 E Holts Rd GenoaOH
GenoaVi l lae Adm (419) 855-7791
102 E 6th St GenoaOH Map
Genoa Village Offices 1419) 855-7791
102 E 6th St GenoaOH Map
Genoa Village Utility Office (419) 855-7791
102 E 6th St GenoaOH Map
Showing 1-4 of 4 I Beyond Genoa
Beyond Cenoa
Business Information provided by InfoUSA corn Foster City California Copyright 0 2002
1 1 am Vice President of RASP Broadcast Enterprises bc (lsquoaASPrdquo) the license of WJZB(FM) C h e l 2 4 7 A Oak Harbor Obio
RASP intends to apply for a construction permit for Channel 247A to specify oper Itions for WJZE in Genoa Ohio upon adoption ofthe Proposal as outljned h e n through the relevant Notice of Pmposed Rule Making
If am ardd the construction permit for Channel 247A RASP promptlywill construct and ITamp such facilities
2
3
Iherebydec are underpenallyofperjurythat thes ta tementsmade ia th i sdec l~~on~~e and accurate to the Ixst of my howledge information and belief
September a 2 002
DECLARATION
I Jeff Littlejohn declare as follows
3 I am Senior Vice President Engineering of Citicasters Licenses Inc (ldquoCiticastersrdquo) the licensee of WRVF(FM) Channel 268B Toledo Ohio
Citicasters intends to apply for a construction permit for Channel 268B to specamp operations for WRVF in Oak Harbor Ohio upon adoption of the Proposal as outlined herein through the relevant Notice of Proposed Rule Making
If awarded the construction permit for Channel 268B Citicasters promptly wi l l construct and operate such facilities
4
3
I hereby declare under penalty of perjury that the statements made in
this declaration are true and accurate to the best of my knowledge information and
belief
du Treil Lundin amp Rackley Inc Consulting Engineers
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Technical Narrative
This Technical Exhibit of which this Narrative is part proposes an FM Rule Making to modify the Commissions Table of Allotments contained within Section 73202 within the Commissions Rules It is proposed herein to modify the community of license of two FM stations No change in the stations reference coordinates are proposed
Summary of Rule Making Proposal
Below is a summary of the allocation changes requested in the Joint Petition for Rule Making
0 Delete Channel 247A at Oak Harbor Ohio and allot
Contingent on the adoption of the above change Channel 24A at Genoa Ohio
delete Channel 268B at Toledo Ohio and allot Channel 268B at Oak Harbor Ohio
Pursuant to Section 142O(i) of the Commissions Rules the Petition also requests modifications to the licenses of WJZE(FM) Channel 24A Oak Harbor Ohio and WRVF(FM) Channel 268B Toledo Ohio accordingly
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 2
Proposed Channel 247A Genoa Ohio
It is proposed to delete Channel 247A at Oak Harbor and allot Channel 247A to Genoa Ohio The Genoa proposal is mutually exclusive with the current Oak Harbor allotment As no change in the reference site change is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Genoa as shown in Figure 1
Below are the Channel 247A Genoa reference site geographic coordinates
41deg 29 17 North Latitude 83O 19 25 West Longitude
The existing Channel 241A reference coordinates do not satisfy the spacing requirements of Section 73207 with respect to three stations as identified in the allocation study provided in Figure 2 Each is discussed below
First under Section 73207 the proposed Channel 247A reference site is short-spaced to CHYR-FM on Channel 244C1 at Leamington Ontario Canada The required minimum separation distance is 90 kilometers the actual separation distance is 86 kilometers a short- spacing of 4 kilometers This Canadian allotment is a specially negotiated short-spaced allotment which was accepted by the Commission on September 2 1992 Petitionerrs Channel 247A is also a specially negotiated short-spaced allotment which was accepted by Canada on December 14 1992 Therefore because the proposed allotment does not involve any change in the relevant site this previously accepted spacing should satisfy the Commissions allocation requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 3
Second under Section 73207 the proposed Channel 248A reference site is short-spaced to WKRK-FM on Channel 246B at Detroit Michigan The required minimum separation distance is 113 kilometers the actual separation distance is 111 kilometers a short-spacing of 2 kilometers Petitioners Channel 247A was initially allocated as a 3 kilowatt100 meter facility and it remains as an equivalent facility Therefore for allotment purposes WKRK-FM can be protected pursuant to Section 73213(c) of the Commissions Rules which requires a minimum separation distance of 105 kilometers The proposed reference coordinates satisfies this requirement
Third under Section 73207 the proposed Channel 247A reference site is short-spaced to WMEE(FM) on Channel 247B at Fort Wayne Indiana The station was authorized to operate from the reference site (its current site) pursuant to the stations request to be processed under Section 73215 The required minimum separation distance is 178 kilometers the actual separation distance is 162 kilometers a short-spacing of 16 kilometers
However the proposed allotment does not create a new short or not exacerbate any short-spacing (under Section 73207) with regard to WMEE(FM) In addition WJZE(FM) already has been approved to operate at the reference site to the extent is affords WMEE(FM) contour protection pursuant to Section 73215 and the proposed allotment contemplates no change in WJZE(FM)s operating parameters Moreover WJZE(FM)s former (pre-Section 73215) transmitter site satisfied the relevant spacing requirement - the Section 73213(c) separation distance of 163 kilometers with regard to WMEE(FM) As shown in Figure 1 the projected city grade reference contour (70 dBu) of the allotment from this former site encompassed
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 4
the proposed community of Genoa this pre-Section 73215 site is provided in Figure 2
An allocation study from
Figure 5 is an Area-to-Locate map for Channel 247A As can be seen there is no present fully-spaced area-to-locate for this allotment
Proposed Channel 268B Oak Harbor Ohio
It is proposed to delete Channel 268B at Toledo and allot Channel 268B to Oak Harbor Ohio This Oak Harbor proposal is mutually exclusive with the current Toledo allotment As no change in the reference site is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Oak Harbor as shown in Figure 1
Below are the Channel 268B Oak Harbor reference site geographic coordinates
41O 40 23 North Latitude 83O 25 31 West Longitude
The existing Channel 268B reference coordinates do not satisfy Section 73201 requirements with respect to five stations as shown by the allocation study provided in Figure 4 Each short-spacing is discussed below
First under Section 73207 the proposed Channel 268B reference site is short-spaced to WMJK(FM) on Channel 265A at Clyde Ohio The required minimum separation distance is 69 kilometers the actual separation distance is 64 kilometers a short-spacing of 5 kilometers WMJK(FM) is a 3 kilowatt100 meter type Class A facility and therefore is processed pursuant to Section
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 5
13213 of the Rules as the short-spacing (under Section 13207) is not exacerbated
Second under Section 73207 the proposed Channel 268B reference site is short-spaced to WNCO-FM on Channel 267B at Ashland Ohio The required minimum separation distance is 169 kilometers the actual separation distance is 129 kilometers a short-spacing of 40 kilometers However because the Channel 268B allotment and WNCO-FM have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Third under Section 73207 the proposed Channel 268B reference site is short-spaced to a Canadian allotment on Channel 268A The required minimum separation distance is 210 kilometers the actual separation distance is 167 kilometers a short-spacing of 43 kilometers This Canadian allotment is a specially negotiated short-spaced allotment Therefore because the proposed allotment does not involve a change in the relevant site this previously accepted spacing should satisfy the Commissionrsquos allocation requiremements
Fourth under Section 73207 the proposed Channel 268B reference site is short-spaced to the current licensed and authorized facility of WWBN(FM) on Channel 268A at Tuscola Michigan because WWBN(FM) is authorized pursuant to Section 73215 with regard to WRVF(FM) Therefore as WRVF(FM) did not initiate this short- spacing and the proposed re-allotment involves no change in the WRVF(FM)rsquos current transmitter site the proposed spacing satisfies the Commissionrsquos allotment requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 6
Fifth under Section 73207 the proposed Channel 268B reference site is short-spaced to WNSN(FM) on Channel 268B at South Bend Indiana The required minimum separation distance is 14 kilometers the actual separation distance is 68 kilometers a short-spacing of 6 kilometers However because the Channel 268B allotment and WNSN(FM) have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Proposed Modifications to Table of Allotments
This proposal provides for the following allotment changes to Section 73202 The Commissionrsquos Table of FM Allotments
Lowell Oil Center (historical) hobth Amsden Maple Grove
Watson lie Mount Gilead
10 0 10 20 30 40 miles
H H H H t I I I I I I
H H H H I I I I I I I I 10 0 10 20 30 40 50 kilometers
CITY GRADE REFERENCE CONTOURS
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 2
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 241A Genoa Ohio Allocation Study Proposed Reference Site
41deg 29rsquo 17rdquo North Latitude 8 3 O 19rsquo 25ldquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(rn) Longitude deg-True (km) (hi) WBVI FOSTORIA BLH 244A 30 41-06-00 1964 4494 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR- F LEAMINGTON 244C1 910 42-00-35 472 8582 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
For all the foregoing reasons the Commission should issue an
appropriate Notice of Proposed Rule Making and then approve the proposed
modifications of the Table of Allotments and WJZErsquos and WRVFrsquos licenses under
Section 1420(i) of the Commissionrsquos Rules
Respectfully submitted
REDDY BEGLEY amp MCCORMICK
2175 K Street NW Suite 350 Washington DC 20037-1803
Telephone 202-659-5700 Facsimile 202-659-571 1
Attorneys for Rasp Broadcasting Enterprises Inc
September 26 2002
HOGAN amp HARTSON LLP
By Marissa G Repp lsquo
555 Thirteenth Street NW Washington DC 20004- 1109 Telephone 202-637-6845 Facsimile 202-637-5910
Attorneys for Citicasters Licenses Inc
EXHIBIT 1
Table DP1 Profile of General Demographic Characteristics 2000 Geographic Area Genoa village Ohio [For information on confidentiality protection nonsampiing error and definitions see text]
Subject Number Percent Subjen
Total populallon SEX AND AGE Male Female Under 5 years 5 to 9 years 10 to 14 years 15 to 19 yeam 20 lo 24 years 25 to 34 years 35 to44 years 45 to 54 years 55 to 59 years
75 lo 84 years 85 years and over
Median age (yean) 18 years and over
Male Female
21 years and over
65 years and over Male Female
RACE One race
White Black or African American American Indian and Alaska Native Asian
Asian Indian Chinese
Native Hawaiian Guamanian or Chamom Samoan Other Pacific Islander
Some ather race Two or more races Race elone or In comblnstlon wlth one
While Black or African American American Indian and Alaska Nati Asian Native Hawaiian and Ofher P a d
or mom other 11caa
I
2230
1062 1168
122 169 173 159 88
291 353 294 90 90
152 178 71
383
1859 751 908
1583 451 401 129 272
2197 2120
8 7 6 1
2
2 1 1
1
55 33
2152 11 14 9 4
1000
476 524 55 78 78 71 39
130 l58 132 40 40 6 8 80 32
(x 744 337 407 71 O 202 180 58
122
98 5 951 04 0 3 0 3
O
01
25 15
-
96 5
E
HISPANIC OR LATINO AND RACE Total populallon
hispanic or LaLna (of any race) Mexican Pueno Rtcan Cunan Otner Hispanic or LSI~O
Whne aone
RELATIONSHIP ~ o t a ~ popu~m~on
In haampenom riousehoiaer Spouse Chid
Own chid unoer I8 years Otner re atives
Jnaer 18 years honrelatwes
Unmarriea partner
hot Hispanic or Latino
In group quarters Insttutionalized ppulat on honlnsttut onallzed popdjatlon
HOUSEHOLD BY N P E Tot81 houuholda
Famly housemlas (tamlies) WiIh own chmen unaer 18 years
Mamea-couple family W th own children under 18 years
Female musenolder no hasDana present Witn own chilaren maer 18 years
hontamily nouseholds Householoer living aone
rlouseholaer 65 yeas ano over
Households with Inawlduals under 18 years rlousenolas wnn inaividJals 65 years ana over
0wneroccupiea homng units Renter-occupiea housing unts
For seasonai receatona or
02 Average household size of owner-occupied unil 33 I Averam household size of renter-occuoied unit Some other race
Number I Percent
74
2230 152 125
2
25 2078 2042
2230 2140
851 443 720 533 70 29 56 26 90 90
851 583 283 443 206 98 54
268 248 123
304 241
251 311
883 851 32
03 43
851 651 200
270
1000 68 56 01
11 932 918
1000 960 382 199 323 239
31 13 25 12 40 40
1000 685 333 521 242 115 63
315 291 145
357 283
(X) (X)
1000 964 36
(X) (X)
1000 765 235
- Represents zero or rounds to zero Other Asian alone or two or more Asian categories Other Pacific Islander alone or two or more Native Hawaiian and Other Pacific Islander categories
(X) Not applicable
In combination with one or more of the other races listed The six numbers may add to more than the total population and the six percentages may add to more than 1W percent because individuals may repon more than one race
Source US Census Bureau Census 2000
1731 U8 Census Bureau
Yahoo Yellow Pages Page 1 of 2
Home - Yahoo1 - Maps -Address Book - HelL
Welcome Guest User
Yahoo Yellow Pages Genoa OH
Lop gt Co_mmuampy gt GwernmM gt General
All Businesses Business Name Clay Township Trustees (419) 855-7878
Create My Favorite Locations -Sign In
Change Location -Save This Location
I Showing 1-4 of 4 I Beyond Genoa
Address 21774 E Holts Rd GenoaOH
GenoaVi l lae Adm (419) 855-7791
102 E 6th St GenoaOH Map
Genoa Village Offices 1419) 855-7791
102 E 6th St GenoaOH Map
Genoa Village Utility Office (419) 855-7791
102 E 6th St GenoaOH Map
Showing 1-4 of 4 I Beyond Genoa
Beyond Cenoa
Business Information provided by InfoUSA corn Foster City California Copyright 0 2002
1 1 am Vice President of RASP Broadcast Enterprises bc (lsquoaASPrdquo) the license of WJZB(FM) C h e l 2 4 7 A Oak Harbor Obio
RASP intends to apply for a construction permit for Channel 247A to specify oper Itions for WJZE in Genoa Ohio upon adoption ofthe Proposal as outljned h e n through the relevant Notice of Pmposed Rule Making
If am ardd the construction permit for Channel 247A RASP promptlywill construct and ITamp such facilities
2
3
Iherebydec are underpenallyofperjurythat thes ta tementsmade ia th i sdec l~~on~~e and accurate to the Ixst of my howledge information and belief
September a 2 002
DECLARATION
I Jeff Littlejohn declare as follows
3 I am Senior Vice President Engineering of Citicasters Licenses Inc (ldquoCiticastersrdquo) the licensee of WRVF(FM) Channel 268B Toledo Ohio
Citicasters intends to apply for a construction permit for Channel 268B to specamp operations for WRVF in Oak Harbor Ohio upon adoption of the Proposal as outlined herein through the relevant Notice of Proposed Rule Making
If awarded the construction permit for Channel 268B Citicasters promptly wi l l construct and operate such facilities
4
3
I hereby declare under penalty of perjury that the statements made in
this declaration are true and accurate to the best of my knowledge information and
belief
du Treil Lundin amp Rackley Inc Consulting Engineers
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Technical Narrative
This Technical Exhibit of which this Narrative is part proposes an FM Rule Making to modify the Commissions Table of Allotments contained within Section 73202 within the Commissions Rules It is proposed herein to modify the community of license of two FM stations No change in the stations reference coordinates are proposed
Summary of Rule Making Proposal
Below is a summary of the allocation changes requested in the Joint Petition for Rule Making
0 Delete Channel 247A at Oak Harbor Ohio and allot
Contingent on the adoption of the above change Channel 24A at Genoa Ohio
delete Channel 268B at Toledo Ohio and allot Channel 268B at Oak Harbor Ohio
Pursuant to Section 142O(i) of the Commissions Rules the Petition also requests modifications to the licenses of WJZE(FM) Channel 24A Oak Harbor Ohio and WRVF(FM) Channel 268B Toledo Ohio accordingly
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 2
Proposed Channel 247A Genoa Ohio
It is proposed to delete Channel 247A at Oak Harbor and allot Channel 247A to Genoa Ohio The Genoa proposal is mutually exclusive with the current Oak Harbor allotment As no change in the reference site change is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Genoa as shown in Figure 1
Below are the Channel 247A Genoa reference site geographic coordinates
41deg 29 17 North Latitude 83O 19 25 West Longitude
The existing Channel 241A reference coordinates do not satisfy the spacing requirements of Section 73207 with respect to three stations as identified in the allocation study provided in Figure 2 Each is discussed below
First under Section 73207 the proposed Channel 247A reference site is short-spaced to CHYR-FM on Channel 244C1 at Leamington Ontario Canada The required minimum separation distance is 90 kilometers the actual separation distance is 86 kilometers a short- spacing of 4 kilometers This Canadian allotment is a specially negotiated short-spaced allotment which was accepted by the Commission on September 2 1992 Petitionerrs Channel 247A is also a specially negotiated short-spaced allotment which was accepted by Canada on December 14 1992 Therefore because the proposed allotment does not involve any change in the relevant site this previously accepted spacing should satisfy the Commissions allocation requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 3
Second under Section 73207 the proposed Channel 248A reference site is short-spaced to WKRK-FM on Channel 246B at Detroit Michigan The required minimum separation distance is 113 kilometers the actual separation distance is 111 kilometers a short-spacing of 2 kilometers Petitioners Channel 247A was initially allocated as a 3 kilowatt100 meter facility and it remains as an equivalent facility Therefore for allotment purposes WKRK-FM can be protected pursuant to Section 73213(c) of the Commissions Rules which requires a minimum separation distance of 105 kilometers The proposed reference coordinates satisfies this requirement
Third under Section 73207 the proposed Channel 247A reference site is short-spaced to WMEE(FM) on Channel 247B at Fort Wayne Indiana The station was authorized to operate from the reference site (its current site) pursuant to the stations request to be processed under Section 73215 The required minimum separation distance is 178 kilometers the actual separation distance is 162 kilometers a short-spacing of 16 kilometers
However the proposed allotment does not create a new short or not exacerbate any short-spacing (under Section 73207) with regard to WMEE(FM) In addition WJZE(FM) already has been approved to operate at the reference site to the extent is affords WMEE(FM) contour protection pursuant to Section 73215 and the proposed allotment contemplates no change in WJZE(FM)s operating parameters Moreover WJZE(FM)s former (pre-Section 73215) transmitter site satisfied the relevant spacing requirement - the Section 73213(c) separation distance of 163 kilometers with regard to WMEE(FM) As shown in Figure 1 the projected city grade reference contour (70 dBu) of the allotment from this former site encompassed
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 4
the proposed community of Genoa this pre-Section 73215 site is provided in Figure 2
An allocation study from
Figure 5 is an Area-to-Locate map for Channel 247A As can be seen there is no present fully-spaced area-to-locate for this allotment
Proposed Channel 268B Oak Harbor Ohio
It is proposed to delete Channel 268B at Toledo and allot Channel 268B to Oak Harbor Ohio This Oak Harbor proposal is mutually exclusive with the current Toledo allotment As no change in the reference site is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Oak Harbor as shown in Figure 1
Below are the Channel 268B Oak Harbor reference site geographic coordinates
41O 40 23 North Latitude 83O 25 31 West Longitude
The existing Channel 268B reference coordinates do not satisfy Section 73201 requirements with respect to five stations as shown by the allocation study provided in Figure 4 Each short-spacing is discussed below
First under Section 73207 the proposed Channel 268B reference site is short-spaced to WMJK(FM) on Channel 265A at Clyde Ohio The required minimum separation distance is 69 kilometers the actual separation distance is 64 kilometers a short-spacing of 5 kilometers WMJK(FM) is a 3 kilowatt100 meter type Class A facility and therefore is processed pursuant to Section
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 5
13213 of the Rules as the short-spacing (under Section 13207) is not exacerbated
Second under Section 73207 the proposed Channel 268B reference site is short-spaced to WNCO-FM on Channel 267B at Ashland Ohio The required minimum separation distance is 169 kilometers the actual separation distance is 129 kilometers a short-spacing of 40 kilometers However because the Channel 268B allotment and WNCO-FM have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Third under Section 73207 the proposed Channel 268B reference site is short-spaced to a Canadian allotment on Channel 268A The required minimum separation distance is 210 kilometers the actual separation distance is 167 kilometers a short-spacing of 43 kilometers This Canadian allotment is a specially negotiated short-spaced allotment Therefore because the proposed allotment does not involve a change in the relevant site this previously accepted spacing should satisfy the Commissionrsquos allocation requiremements
Fourth under Section 73207 the proposed Channel 268B reference site is short-spaced to the current licensed and authorized facility of WWBN(FM) on Channel 268A at Tuscola Michigan because WWBN(FM) is authorized pursuant to Section 73215 with regard to WRVF(FM) Therefore as WRVF(FM) did not initiate this short- spacing and the proposed re-allotment involves no change in the WRVF(FM)rsquos current transmitter site the proposed spacing satisfies the Commissionrsquos allotment requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 6
Fifth under Section 73207 the proposed Channel 268B reference site is short-spaced to WNSN(FM) on Channel 268B at South Bend Indiana The required minimum separation distance is 14 kilometers the actual separation distance is 68 kilometers a short-spacing of 6 kilometers However because the Channel 268B allotment and WNSN(FM) have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Proposed Modifications to Table of Allotments
This proposal provides for the following allotment changes to Section 73202 The Commissionrsquos Table of FM Allotments
Lowell Oil Center (historical) hobth Amsden Maple Grove
Watson lie Mount Gilead
10 0 10 20 30 40 miles
H H H H t I I I I I I
H H H H I I I I I I I I 10 0 10 20 30 40 50 kilometers
CITY GRADE REFERENCE CONTOURS
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 2
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 241A Genoa Ohio Allocation Study Proposed Reference Site
41deg 29rsquo 17rdquo North Latitude 8 3 O 19rsquo 25ldquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(rn) Longitude deg-True (km) (hi) WBVI FOSTORIA BLH 244A 30 41-06-00 1964 4494 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR- F LEAMINGTON 244C1 910 42-00-35 472 8582 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
EXHIBIT 1
Table DP1 Profile of General Demographic Characteristics 2000 Geographic Area Genoa village Ohio [For information on confidentiality protection nonsampiing error and definitions see text]
Subject Number Percent Subjen
Total populallon SEX AND AGE Male Female Under 5 years 5 to 9 years 10 to 14 years 15 to 19 yeam 20 lo 24 years 25 to 34 years 35 to44 years 45 to 54 years 55 to 59 years
75 lo 84 years 85 years and over
Median age (yean) 18 years and over
Male Female
21 years and over
65 years and over Male Female
RACE One race
White Black or African American American Indian and Alaska Native Asian
Asian Indian Chinese
Native Hawaiian Guamanian or Chamom Samoan Other Pacific Islander
Some ather race Two or more races Race elone or In comblnstlon wlth one
While Black or African American American Indian and Alaska Nati Asian Native Hawaiian and Ofher P a d
or mom other 11caa
I
2230
1062 1168
122 169 173 159 88
291 353 294 90 90
152 178 71
383
1859 751 908
1583 451 401 129 272
2197 2120
8 7 6 1
2
2 1 1
1
55 33
2152 11 14 9 4
1000
476 524 55 78 78 71 39
130 l58 132 40 40 6 8 80 32
(x 744 337 407 71 O 202 180 58
122
98 5 951 04 0 3 0 3
O
01
25 15
-
96 5
E
HISPANIC OR LATINO AND RACE Total populallon
hispanic or LaLna (of any race) Mexican Pueno Rtcan Cunan Otner Hispanic or LSI~O
Whne aone
RELATIONSHIP ~ o t a ~ popu~m~on
In haampenom riousehoiaer Spouse Chid
Own chid unoer I8 years Otner re atives
Jnaer 18 years honrelatwes
Unmarriea partner
hot Hispanic or Latino
In group quarters Insttutionalized ppulat on honlnsttut onallzed popdjatlon
HOUSEHOLD BY N P E Tot81 houuholda
Famly housemlas (tamlies) WiIh own chmen unaer 18 years
Mamea-couple family W th own children under 18 years
Female musenolder no hasDana present Witn own chilaren maer 18 years
hontamily nouseholds Householoer living aone
rlouseholaer 65 yeas ano over
Households with Inawlduals under 18 years rlousenolas wnn inaividJals 65 years ana over
0wneroccupiea homng units Renter-occupiea housing unts
For seasonai receatona or
02 Average household size of owner-occupied unil 33 I Averam household size of renter-occuoied unit Some other race
Number I Percent
74
2230 152 125
2
25 2078 2042
2230 2140
851 443 720 533 70 29 56 26 90 90
851 583 283 443 206 98 54
268 248 123
304 241
251 311
883 851 32
03 43
851 651 200
270
1000 68 56 01
11 932 918
1000 960 382 199 323 239
31 13 25 12 40 40
1000 685 333 521 242 115 63
315 291 145
357 283
(X) (X)
1000 964 36
(X) (X)
1000 765 235
- Represents zero or rounds to zero Other Asian alone or two or more Asian categories Other Pacific Islander alone or two or more Native Hawaiian and Other Pacific Islander categories
(X) Not applicable
In combination with one or more of the other races listed The six numbers may add to more than the total population and the six percentages may add to more than 1W percent because individuals may repon more than one race
Source US Census Bureau Census 2000
1731 U8 Census Bureau
Yahoo Yellow Pages Page 1 of 2
Home - Yahoo1 - Maps -Address Book - HelL
Welcome Guest User
Yahoo Yellow Pages Genoa OH
Lop gt Co_mmuampy gt GwernmM gt General
All Businesses Business Name Clay Township Trustees (419) 855-7878
Create My Favorite Locations -Sign In
Change Location -Save This Location
I Showing 1-4 of 4 I Beyond Genoa
Address 21774 E Holts Rd GenoaOH
GenoaVi l lae Adm (419) 855-7791
102 E 6th St GenoaOH Map
Genoa Village Offices 1419) 855-7791
102 E 6th St GenoaOH Map
Genoa Village Utility Office (419) 855-7791
102 E 6th St GenoaOH Map
Showing 1-4 of 4 I Beyond Genoa
Beyond Cenoa
Business Information provided by InfoUSA corn Foster City California Copyright 0 2002
1 1 am Vice President of RASP Broadcast Enterprises bc (lsquoaASPrdquo) the license of WJZB(FM) C h e l 2 4 7 A Oak Harbor Obio
RASP intends to apply for a construction permit for Channel 247A to specify oper Itions for WJZE in Genoa Ohio upon adoption ofthe Proposal as outljned h e n through the relevant Notice of Pmposed Rule Making
If am ardd the construction permit for Channel 247A RASP promptlywill construct and ITamp such facilities
2
3
Iherebydec are underpenallyofperjurythat thes ta tementsmade ia th i sdec l~~on~~e and accurate to the Ixst of my howledge information and belief
September a 2 002
DECLARATION
I Jeff Littlejohn declare as follows
3 I am Senior Vice President Engineering of Citicasters Licenses Inc (ldquoCiticastersrdquo) the licensee of WRVF(FM) Channel 268B Toledo Ohio
Citicasters intends to apply for a construction permit for Channel 268B to specamp operations for WRVF in Oak Harbor Ohio upon adoption of the Proposal as outlined herein through the relevant Notice of Proposed Rule Making
If awarded the construction permit for Channel 268B Citicasters promptly wi l l construct and operate such facilities
4
3
I hereby declare under penalty of perjury that the statements made in
this declaration are true and accurate to the best of my knowledge information and
belief
du Treil Lundin amp Rackley Inc Consulting Engineers
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Technical Narrative
This Technical Exhibit of which this Narrative is part proposes an FM Rule Making to modify the Commissions Table of Allotments contained within Section 73202 within the Commissions Rules It is proposed herein to modify the community of license of two FM stations No change in the stations reference coordinates are proposed
Summary of Rule Making Proposal
Below is a summary of the allocation changes requested in the Joint Petition for Rule Making
0 Delete Channel 247A at Oak Harbor Ohio and allot
Contingent on the adoption of the above change Channel 24A at Genoa Ohio
delete Channel 268B at Toledo Ohio and allot Channel 268B at Oak Harbor Ohio
Pursuant to Section 142O(i) of the Commissions Rules the Petition also requests modifications to the licenses of WJZE(FM) Channel 24A Oak Harbor Ohio and WRVF(FM) Channel 268B Toledo Ohio accordingly
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 2
Proposed Channel 247A Genoa Ohio
It is proposed to delete Channel 247A at Oak Harbor and allot Channel 247A to Genoa Ohio The Genoa proposal is mutually exclusive with the current Oak Harbor allotment As no change in the reference site change is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Genoa as shown in Figure 1
Below are the Channel 247A Genoa reference site geographic coordinates
41deg 29 17 North Latitude 83O 19 25 West Longitude
The existing Channel 241A reference coordinates do not satisfy the spacing requirements of Section 73207 with respect to three stations as identified in the allocation study provided in Figure 2 Each is discussed below
First under Section 73207 the proposed Channel 247A reference site is short-spaced to CHYR-FM on Channel 244C1 at Leamington Ontario Canada The required minimum separation distance is 90 kilometers the actual separation distance is 86 kilometers a short- spacing of 4 kilometers This Canadian allotment is a specially negotiated short-spaced allotment which was accepted by the Commission on September 2 1992 Petitionerrs Channel 247A is also a specially negotiated short-spaced allotment which was accepted by Canada on December 14 1992 Therefore because the proposed allotment does not involve any change in the relevant site this previously accepted spacing should satisfy the Commissions allocation requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 3
Second under Section 73207 the proposed Channel 248A reference site is short-spaced to WKRK-FM on Channel 246B at Detroit Michigan The required minimum separation distance is 113 kilometers the actual separation distance is 111 kilometers a short-spacing of 2 kilometers Petitioners Channel 247A was initially allocated as a 3 kilowatt100 meter facility and it remains as an equivalent facility Therefore for allotment purposes WKRK-FM can be protected pursuant to Section 73213(c) of the Commissions Rules which requires a minimum separation distance of 105 kilometers The proposed reference coordinates satisfies this requirement
Third under Section 73207 the proposed Channel 247A reference site is short-spaced to WMEE(FM) on Channel 247B at Fort Wayne Indiana The station was authorized to operate from the reference site (its current site) pursuant to the stations request to be processed under Section 73215 The required minimum separation distance is 178 kilometers the actual separation distance is 162 kilometers a short-spacing of 16 kilometers
However the proposed allotment does not create a new short or not exacerbate any short-spacing (under Section 73207) with regard to WMEE(FM) In addition WJZE(FM) already has been approved to operate at the reference site to the extent is affords WMEE(FM) contour protection pursuant to Section 73215 and the proposed allotment contemplates no change in WJZE(FM)s operating parameters Moreover WJZE(FM)s former (pre-Section 73215) transmitter site satisfied the relevant spacing requirement - the Section 73213(c) separation distance of 163 kilometers with regard to WMEE(FM) As shown in Figure 1 the projected city grade reference contour (70 dBu) of the allotment from this former site encompassed
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 4
the proposed community of Genoa this pre-Section 73215 site is provided in Figure 2
An allocation study from
Figure 5 is an Area-to-Locate map for Channel 247A As can be seen there is no present fully-spaced area-to-locate for this allotment
Proposed Channel 268B Oak Harbor Ohio
It is proposed to delete Channel 268B at Toledo and allot Channel 268B to Oak Harbor Ohio This Oak Harbor proposal is mutually exclusive with the current Toledo allotment As no change in the reference site is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Oak Harbor as shown in Figure 1
Below are the Channel 268B Oak Harbor reference site geographic coordinates
41O 40 23 North Latitude 83O 25 31 West Longitude
The existing Channel 268B reference coordinates do not satisfy Section 73201 requirements with respect to five stations as shown by the allocation study provided in Figure 4 Each short-spacing is discussed below
First under Section 73207 the proposed Channel 268B reference site is short-spaced to WMJK(FM) on Channel 265A at Clyde Ohio The required minimum separation distance is 69 kilometers the actual separation distance is 64 kilometers a short-spacing of 5 kilometers WMJK(FM) is a 3 kilowatt100 meter type Class A facility and therefore is processed pursuant to Section
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 5
13213 of the Rules as the short-spacing (under Section 13207) is not exacerbated
Second under Section 73207 the proposed Channel 268B reference site is short-spaced to WNCO-FM on Channel 267B at Ashland Ohio The required minimum separation distance is 169 kilometers the actual separation distance is 129 kilometers a short-spacing of 40 kilometers However because the Channel 268B allotment and WNCO-FM have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Third under Section 73207 the proposed Channel 268B reference site is short-spaced to a Canadian allotment on Channel 268A The required minimum separation distance is 210 kilometers the actual separation distance is 167 kilometers a short-spacing of 43 kilometers This Canadian allotment is a specially negotiated short-spaced allotment Therefore because the proposed allotment does not involve a change in the relevant site this previously accepted spacing should satisfy the Commissionrsquos allocation requiremements
Fourth under Section 73207 the proposed Channel 268B reference site is short-spaced to the current licensed and authorized facility of WWBN(FM) on Channel 268A at Tuscola Michigan because WWBN(FM) is authorized pursuant to Section 73215 with regard to WRVF(FM) Therefore as WRVF(FM) did not initiate this short- spacing and the proposed re-allotment involves no change in the WRVF(FM)rsquos current transmitter site the proposed spacing satisfies the Commissionrsquos allotment requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 6
Fifth under Section 73207 the proposed Channel 268B reference site is short-spaced to WNSN(FM) on Channel 268B at South Bend Indiana The required minimum separation distance is 14 kilometers the actual separation distance is 68 kilometers a short-spacing of 6 kilometers However because the Channel 268B allotment and WNSN(FM) have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Proposed Modifications to Table of Allotments
This proposal provides for the following allotment changes to Section 73202 The Commissionrsquos Table of FM Allotments
Lowell Oil Center (historical) hobth Amsden Maple Grove
Watson lie Mount Gilead
10 0 10 20 30 40 miles
H H H H t I I I I I I
H H H H I I I I I I I I 10 0 10 20 30 40 50 kilometers
CITY GRADE REFERENCE CONTOURS
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 2
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 241A Genoa Ohio Allocation Study Proposed Reference Site
41deg 29rsquo 17rdquo North Latitude 8 3 O 19rsquo 25ldquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(rn) Longitude deg-True (km) (hi) WBVI FOSTORIA BLH 244A 30 41-06-00 1964 4494 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR- F LEAMINGTON 244C1 910 42-00-35 472 8582 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Table DP1 Profile of General Demographic Characteristics 2000 Geographic Area Genoa village Ohio [For information on confidentiality protection nonsampiing error and definitions see text]
Subject Number Percent Subjen
Total populallon SEX AND AGE Male Female Under 5 years 5 to 9 years 10 to 14 years 15 to 19 yeam 20 lo 24 years 25 to 34 years 35 to44 years 45 to 54 years 55 to 59 years
75 lo 84 years 85 years and over
Median age (yean) 18 years and over
Male Female
21 years and over
65 years and over Male Female
RACE One race
White Black or African American American Indian and Alaska Native Asian
Asian Indian Chinese
Native Hawaiian Guamanian or Chamom Samoan Other Pacific Islander
Some ather race Two or more races Race elone or In comblnstlon wlth one
While Black or African American American Indian and Alaska Nati Asian Native Hawaiian and Ofher P a d
or mom other 11caa
I
2230
1062 1168
122 169 173 159 88
291 353 294 90 90
152 178 71
383
1859 751 908
1583 451 401 129 272
2197 2120
8 7 6 1
2
2 1 1
1
55 33
2152 11 14 9 4
1000
476 524 55 78 78 71 39
130 l58 132 40 40 6 8 80 32
(x 744 337 407 71 O 202 180 58
122
98 5 951 04 0 3 0 3
O
01
25 15
-
96 5
E
HISPANIC OR LATINO AND RACE Total populallon
hispanic or LaLna (of any race) Mexican Pueno Rtcan Cunan Otner Hispanic or LSI~O
Whne aone
RELATIONSHIP ~ o t a ~ popu~m~on
In haampenom riousehoiaer Spouse Chid
Own chid unoer I8 years Otner re atives
Jnaer 18 years honrelatwes
Unmarriea partner
hot Hispanic or Latino
In group quarters Insttutionalized ppulat on honlnsttut onallzed popdjatlon
HOUSEHOLD BY N P E Tot81 houuholda
Famly housemlas (tamlies) WiIh own chmen unaer 18 years
Mamea-couple family W th own children under 18 years
Female musenolder no hasDana present Witn own chilaren maer 18 years
hontamily nouseholds Householoer living aone
rlouseholaer 65 yeas ano over
Households with Inawlduals under 18 years rlousenolas wnn inaividJals 65 years ana over
0wneroccupiea homng units Renter-occupiea housing unts
For seasonai receatona or
02 Average household size of owner-occupied unil 33 I Averam household size of renter-occuoied unit Some other race
Number I Percent
74
2230 152 125
2
25 2078 2042
2230 2140
851 443 720 533 70 29 56 26 90 90
851 583 283 443 206 98 54
268 248 123
304 241
251 311
883 851 32
03 43
851 651 200
270
1000 68 56 01
11 932 918
1000 960 382 199 323 239
31 13 25 12 40 40
1000 685 333 521 242 115 63
315 291 145
357 283
(X) (X)
1000 964 36
(X) (X)
1000 765 235
- Represents zero or rounds to zero Other Asian alone or two or more Asian categories Other Pacific Islander alone or two or more Native Hawaiian and Other Pacific Islander categories
(X) Not applicable
In combination with one or more of the other races listed The six numbers may add to more than the total population and the six percentages may add to more than 1W percent because individuals may repon more than one race
Source US Census Bureau Census 2000
1731 U8 Census Bureau
Yahoo Yellow Pages Page 1 of 2
Home - Yahoo1 - Maps -Address Book - HelL
Welcome Guest User
Yahoo Yellow Pages Genoa OH
Lop gt Co_mmuampy gt GwernmM gt General
All Businesses Business Name Clay Township Trustees (419) 855-7878
Create My Favorite Locations -Sign In
Change Location -Save This Location
I Showing 1-4 of 4 I Beyond Genoa
Address 21774 E Holts Rd GenoaOH
GenoaVi l lae Adm (419) 855-7791
102 E 6th St GenoaOH Map
Genoa Village Offices 1419) 855-7791
102 E 6th St GenoaOH Map
Genoa Village Utility Office (419) 855-7791
102 E 6th St GenoaOH Map
Showing 1-4 of 4 I Beyond Genoa
Beyond Cenoa
Business Information provided by InfoUSA corn Foster City California Copyright 0 2002
1 1 am Vice President of RASP Broadcast Enterprises bc (lsquoaASPrdquo) the license of WJZB(FM) C h e l 2 4 7 A Oak Harbor Obio
RASP intends to apply for a construction permit for Channel 247A to specify oper Itions for WJZE in Genoa Ohio upon adoption ofthe Proposal as outljned h e n through the relevant Notice of Pmposed Rule Making
If am ardd the construction permit for Channel 247A RASP promptlywill construct and ITamp such facilities
2
3
Iherebydec are underpenallyofperjurythat thes ta tementsmade ia th i sdec l~~on~~e and accurate to the Ixst of my howledge information and belief
September a 2 002
DECLARATION
I Jeff Littlejohn declare as follows
3 I am Senior Vice President Engineering of Citicasters Licenses Inc (ldquoCiticastersrdquo) the licensee of WRVF(FM) Channel 268B Toledo Ohio
Citicasters intends to apply for a construction permit for Channel 268B to specamp operations for WRVF in Oak Harbor Ohio upon adoption of the Proposal as outlined herein through the relevant Notice of Proposed Rule Making
If awarded the construction permit for Channel 268B Citicasters promptly wi l l construct and operate such facilities
4
3
I hereby declare under penalty of perjury that the statements made in
this declaration are true and accurate to the best of my knowledge information and
belief
du Treil Lundin amp Rackley Inc Consulting Engineers
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Technical Narrative
This Technical Exhibit of which this Narrative is part proposes an FM Rule Making to modify the Commissions Table of Allotments contained within Section 73202 within the Commissions Rules It is proposed herein to modify the community of license of two FM stations No change in the stations reference coordinates are proposed
Summary of Rule Making Proposal
Below is a summary of the allocation changes requested in the Joint Petition for Rule Making
0 Delete Channel 247A at Oak Harbor Ohio and allot
Contingent on the adoption of the above change Channel 24A at Genoa Ohio
delete Channel 268B at Toledo Ohio and allot Channel 268B at Oak Harbor Ohio
Pursuant to Section 142O(i) of the Commissions Rules the Petition also requests modifications to the licenses of WJZE(FM) Channel 24A Oak Harbor Ohio and WRVF(FM) Channel 268B Toledo Ohio accordingly
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 2
Proposed Channel 247A Genoa Ohio
It is proposed to delete Channel 247A at Oak Harbor and allot Channel 247A to Genoa Ohio The Genoa proposal is mutually exclusive with the current Oak Harbor allotment As no change in the reference site change is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Genoa as shown in Figure 1
Below are the Channel 247A Genoa reference site geographic coordinates
41deg 29 17 North Latitude 83O 19 25 West Longitude
The existing Channel 241A reference coordinates do not satisfy the spacing requirements of Section 73207 with respect to three stations as identified in the allocation study provided in Figure 2 Each is discussed below
First under Section 73207 the proposed Channel 247A reference site is short-spaced to CHYR-FM on Channel 244C1 at Leamington Ontario Canada The required minimum separation distance is 90 kilometers the actual separation distance is 86 kilometers a short- spacing of 4 kilometers This Canadian allotment is a specially negotiated short-spaced allotment which was accepted by the Commission on September 2 1992 Petitionerrs Channel 247A is also a specially negotiated short-spaced allotment which was accepted by Canada on December 14 1992 Therefore because the proposed allotment does not involve any change in the relevant site this previously accepted spacing should satisfy the Commissions allocation requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 3
Second under Section 73207 the proposed Channel 248A reference site is short-spaced to WKRK-FM on Channel 246B at Detroit Michigan The required minimum separation distance is 113 kilometers the actual separation distance is 111 kilometers a short-spacing of 2 kilometers Petitioners Channel 247A was initially allocated as a 3 kilowatt100 meter facility and it remains as an equivalent facility Therefore for allotment purposes WKRK-FM can be protected pursuant to Section 73213(c) of the Commissions Rules which requires a minimum separation distance of 105 kilometers The proposed reference coordinates satisfies this requirement
Third under Section 73207 the proposed Channel 247A reference site is short-spaced to WMEE(FM) on Channel 247B at Fort Wayne Indiana The station was authorized to operate from the reference site (its current site) pursuant to the stations request to be processed under Section 73215 The required minimum separation distance is 178 kilometers the actual separation distance is 162 kilometers a short-spacing of 16 kilometers
However the proposed allotment does not create a new short or not exacerbate any short-spacing (under Section 73207) with regard to WMEE(FM) In addition WJZE(FM) already has been approved to operate at the reference site to the extent is affords WMEE(FM) contour protection pursuant to Section 73215 and the proposed allotment contemplates no change in WJZE(FM)s operating parameters Moreover WJZE(FM)s former (pre-Section 73215) transmitter site satisfied the relevant spacing requirement - the Section 73213(c) separation distance of 163 kilometers with regard to WMEE(FM) As shown in Figure 1 the projected city grade reference contour (70 dBu) of the allotment from this former site encompassed
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 4
the proposed community of Genoa this pre-Section 73215 site is provided in Figure 2
An allocation study from
Figure 5 is an Area-to-Locate map for Channel 247A As can be seen there is no present fully-spaced area-to-locate for this allotment
Proposed Channel 268B Oak Harbor Ohio
It is proposed to delete Channel 268B at Toledo and allot Channel 268B to Oak Harbor Ohio This Oak Harbor proposal is mutually exclusive with the current Toledo allotment As no change in the reference site is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Oak Harbor as shown in Figure 1
Below are the Channel 268B Oak Harbor reference site geographic coordinates
41O 40 23 North Latitude 83O 25 31 West Longitude
The existing Channel 268B reference coordinates do not satisfy Section 73201 requirements with respect to five stations as shown by the allocation study provided in Figure 4 Each short-spacing is discussed below
First under Section 73207 the proposed Channel 268B reference site is short-spaced to WMJK(FM) on Channel 265A at Clyde Ohio The required minimum separation distance is 69 kilometers the actual separation distance is 64 kilometers a short-spacing of 5 kilometers WMJK(FM) is a 3 kilowatt100 meter type Class A facility and therefore is processed pursuant to Section
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 5
13213 of the Rules as the short-spacing (under Section 13207) is not exacerbated
Second under Section 73207 the proposed Channel 268B reference site is short-spaced to WNCO-FM on Channel 267B at Ashland Ohio The required minimum separation distance is 169 kilometers the actual separation distance is 129 kilometers a short-spacing of 40 kilometers However because the Channel 268B allotment and WNCO-FM have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Third under Section 73207 the proposed Channel 268B reference site is short-spaced to a Canadian allotment on Channel 268A The required minimum separation distance is 210 kilometers the actual separation distance is 167 kilometers a short-spacing of 43 kilometers This Canadian allotment is a specially negotiated short-spaced allotment Therefore because the proposed allotment does not involve a change in the relevant site this previously accepted spacing should satisfy the Commissionrsquos allocation requiremements
Fourth under Section 73207 the proposed Channel 268B reference site is short-spaced to the current licensed and authorized facility of WWBN(FM) on Channel 268A at Tuscola Michigan because WWBN(FM) is authorized pursuant to Section 73215 with regard to WRVF(FM) Therefore as WRVF(FM) did not initiate this short- spacing and the proposed re-allotment involves no change in the WRVF(FM)rsquos current transmitter site the proposed spacing satisfies the Commissionrsquos allotment requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 6
Fifth under Section 73207 the proposed Channel 268B reference site is short-spaced to WNSN(FM) on Channel 268B at South Bend Indiana The required minimum separation distance is 14 kilometers the actual separation distance is 68 kilometers a short-spacing of 6 kilometers However because the Channel 268B allotment and WNSN(FM) have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Proposed Modifications to Table of Allotments
This proposal provides for the following allotment changes to Section 73202 The Commissionrsquos Table of FM Allotments
Lowell Oil Center (historical) hobth Amsden Maple Grove
Watson lie Mount Gilead
10 0 10 20 30 40 miles
H H H H t I I I I I I
H H H H I I I I I I I I 10 0 10 20 30 40 50 kilometers
CITY GRADE REFERENCE CONTOURS
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 2
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 241A Genoa Ohio Allocation Study Proposed Reference Site
41deg 29rsquo 17rdquo North Latitude 8 3 O 19rsquo 25ldquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(rn) Longitude deg-True (km) (hi) WBVI FOSTORIA BLH 244A 30 41-06-00 1964 4494 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR- F LEAMINGTON 244C1 910 42-00-35 472 8582 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Yahoo Yellow Pages Page 1 of 2
Home - Yahoo1 - Maps -Address Book - HelL
Welcome Guest User
Yahoo Yellow Pages Genoa OH
Lop gt Co_mmuampy gt GwernmM gt General
All Businesses Business Name Clay Township Trustees (419) 855-7878
Create My Favorite Locations -Sign In
Change Location -Save This Location
I Showing 1-4 of 4 I Beyond Genoa
Address 21774 E Holts Rd GenoaOH
GenoaVi l lae Adm (419) 855-7791
102 E 6th St GenoaOH Map
Genoa Village Offices 1419) 855-7791
102 E 6th St GenoaOH Map
Genoa Village Utility Office (419) 855-7791
102 E 6th St GenoaOH Map
Showing 1-4 of 4 I Beyond Genoa
Beyond Cenoa
Business Information provided by InfoUSA corn Foster City California Copyright 0 2002
1 1 am Vice President of RASP Broadcast Enterprises bc (lsquoaASPrdquo) the license of WJZB(FM) C h e l 2 4 7 A Oak Harbor Obio
RASP intends to apply for a construction permit for Channel 247A to specify oper Itions for WJZE in Genoa Ohio upon adoption ofthe Proposal as outljned h e n through the relevant Notice of Pmposed Rule Making
If am ardd the construction permit for Channel 247A RASP promptlywill construct and ITamp such facilities
2
3
Iherebydec are underpenallyofperjurythat thes ta tementsmade ia th i sdec l~~on~~e and accurate to the Ixst of my howledge information and belief
September a 2 002
DECLARATION
I Jeff Littlejohn declare as follows
3 I am Senior Vice President Engineering of Citicasters Licenses Inc (ldquoCiticastersrdquo) the licensee of WRVF(FM) Channel 268B Toledo Ohio
Citicasters intends to apply for a construction permit for Channel 268B to specamp operations for WRVF in Oak Harbor Ohio upon adoption of the Proposal as outlined herein through the relevant Notice of Proposed Rule Making
If awarded the construction permit for Channel 268B Citicasters promptly wi l l construct and operate such facilities
4
3
I hereby declare under penalty of perjury that the statements made in
this declaration are true and accurate to the best of my knowledge information and
belief
du Treil Lundin amp Rackley Inc Consulting Engineers
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Technical Narrative
This Technical Exhibit of which this Narrative is part proposes an FM Rule Making to modify the Commissions Table of Allotments contained within Section 73202 within the Commissions Rules It is proposed herein to modify the community of license of two FM stations No change in the stations reference coordinates are proposed
Summary of Rule Making Proposal
Below is a summary of the allocation changes requested in the Joint Petition for Rule Making
0 Delete Channel 247A at Oak Harbor Ohio and allot
Contingent on the adoption of the above change Channel 24A at Genoa Ohio
delete Channel 268B at Toledo Ohio and allot Channel 268B at Oak Harbor Ohio
Pursuant to Section 142O(i) of the Commissions Rules the Petition also requests modifications to the licenses of WJZE(FM) Channel 24A Oak Harbor Ohio and WRVF(FM) Channel 268B Toledo Ohio accordingly
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 2
Proposed Channel 247A Genoa Ohio
It is proposed to delete Channel 247A at Oak Harbor and allot Channel 247A to Genoa Ohio The Genoa proposal is mutually exclusive with the current Oak Harbor allotment As no change in the reference site change is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Genoa as shown in Figure 1
Below are the Channel 247A Genoa reference site geographic coordinates
41deg 29 17 North Latitude 83O 19 25 West Longitude
The existing Channel 241A reference coordinates do not satisfy the spacing requirements of Section 73207 with respect to three stations as identified in the allocation study provided in Figure 2 Each is discussed below
First under Section 73207 the proposed Channel 247A reference site is short-spaced to CHYR-FM on Channel 244C1 at Leamington Ontario Canada The required minimum separation distance is 90 kilometers the actual separation distance is 86 kilometers a short- spacing of 4 kilometers This Canadian allotment is a specially negotiated short-spaced allotment which was accepted by the Commission on September 2 1992 Petitionerrs Channel 247A is also a specially negotiated short-spaced allotment which was accepted by Canada on December 14 1992 Therefore because the proposed allotment does not involve any change in the relevant site this previously accepted spacing should satisfy the Commissions allocation requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 3
Second under Section 73207 the proposed Channel 248A reference site is short-spaced to WKRK-FM on Channel 246B at Detroit Michigan The required minimum separation distance is 113 kilometers the actual separation distance is 111 kilometers a short-spacing of 2 kilometers Petitioners Channel 247A was initially allocated as a 3 kilowatt100 meter facility and it remains as an equivalent facility Therefore for allotment purposes WKRK-FM can be protected pursuant to Section 73213(c) of the Commissions Rules which requires a minimum separation distance of 105 kilometers The proposed reference coordinates satisfies this requirement
Third under Section 73207 the proposed Channel 247A reference site is short-spaced to WMEE(FM) on Channel 247B at Fort Wayne Indiana The station was authorized to operate from the reference site (its current site) pursuant to the stations request to be processed under Section 73215 The required minimum separation distance is 178 kilometers the actual separation distance is 162 kilometers a short-spacing of 16 kilometers
However the proposed allotment does not create a new short or not exacerbate any short-spacing (under Section 73207) with regard to WMEE(FM) In addition WJZE(FM) already has been approved to operate at the reference site to the extent is affords WMEE(FM) contour protection pursuant to Section 73215 and the proposed allotment contemplates no change in WJZE(FM)s operating parameters Moreover WJZE(FM)s former (pre-Section 73215) transmitter site satisfied the relevant spacing requirement - the Section 73213(c) separation distance of 163 kilometers with regard to WMEE(FM) As shown in Figure 1 the projected city grade reference contour (70 dBu) of the allotment from this former site encompassed
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 4
the proposed community of Genoa this pre-Section 73215 site is provided in Figure 2
An allocation study from
Figure 5 is an Area-to-Locate map for Channel 247A As can be seen there is no present fully-spaced area-to-locate for this allotment
Proposed Channel 268B Oak Harbor Ohio
It is proposed to delete Channel 268B at Toledo and allot Channel 268B to Oak Harbor Ohio This Oak Harbor proposal is mutually exclusive with the current Toledo allotment As no change in the reference site is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Oak Harbor as shown in Figure 1
Below are the Channel 268B Oak Harbor reference site geographic coordinates
41O 40 23 North Latitude 83O 25 31 West Longitude
The existing Channel 268B reference coordinates do not satisfy Section 73201 requirements with respect to five stations as shown by the allocation study provided in Figure 4 Each short-spacing is discussed below
First under Section 73207 the proposed Channel 268B reference site is short-spaced to WMJK(FM) on Channel 265A at Clyde Ohio The required minimum separation distance is 69 kilometers the actual separation distance is 64 kilometers a short-spacing of 5 kilometers WMJK(FM) is a 3 kilowatt100 meter type Class A facility and therefore is processed pursuant to Section
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 5
13213 of the Rules as the short-spacing (under Section 13207) is not exacerbated
Second under Section 73207 the proposed Channel 268B reference site is short-spaced to WNCO-FM on Channel 267B at Ashland Ohio The required minimum separation distance is 169 kilometers the actual separation distance is 129 kilometers a short-spacing of 40 kilometers However because the Channel 268B allotment and WNCO-FM have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Third under Section 73207 the proposed Channel 268B reference site is short-spaced to a Canadian allotment on Channel 268A The required minimum separation distance is 210 kilometers the actual separation distance is 167 kilometers a short-spacing of 43 kilometers This Canadian allotment is a specially negotiated short-spaced allotment Therefore because the proposed allotment does not involve a change in the relevant site this previously accepted spacing should satisfy the Commissionrsquos allocation requiremements
Fourth under Section 73207 the proposed Channel 268B reference site is short-spaced to the current licensed and authorized facility of WWBN(FM) on Channel 268A at Tuscola Michigan because WWBN(FM) is authorized pursuant to Section 73215 with regard to WRVF(FM) Therefore as WRVF(FM) did not initiate this short- spacing and the proposed re-allotment involves no change in the WRVF(FM)rsquos current transmitter site the proposed spacing satisfies the Commissionrsquos allotment requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 6
Fifth under Section 73207 the proposed Channel 268B reference site is short-spaced to WNSN(FM) on Channel 268B at South Bend Indiana The required minimum separation distance is 14 kilometers the actual separation distance is 68 kilometers a short-spacing of 6 kilometers However because the Channel 268B allotment and WNSN(FM) have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Proposed Modifications to Table of Allotments
This proposal provides for the following allotment changes to Section 73202 The Commissionrsquos Table of FM Allotments
Lowell Oil Center (historical) hobth Amsden Maple Grove
Watson lie Mount Gilead
10 0 10 20 30 40 miles
H H H H t I I I I I I
H H H H I I I I I I I I 10 0 10 20 30 40 50 kilometers
CITY GRADE REFERENCE CONTOURS
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 2
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 241A Genoa Ohio Allocation Study Proposed Reference Site
41deg 29rsquo 17rdquo North Latitude 8 3 O 19rsquo 25ldquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(rn) Longitude deg-True (km) (hi) WBVI FOSTORIA BLH 244A 30 41-06-00 1964 4494 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR- F LEAMINGTON 244C1 910 42-00-35 472 8582 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Yahoo Yellow Pages Page 1 of 1
Home - Yahoo1 - Maps - Address Book - HelF -mYeilow Pages
Welcome Guest User
Yahoo Yellow Pages Genoa OH
Top gt CqmmunLty gt Governmem gt Fire Protection
Create My Favorite Locations -Sign In
Change Location - Save This~Location
1 All Businesses Showing 1-1 of 1 I Beyond Genoa
Business Name Address Genoa Fire Dept (419) 855-7000 GenoaOH
101 6th St
Showing 1-1 of 1 I Beyond Genoa
Beyond Genoa
Modify your search
(Address Intersection or Airport Code )
Address Optional I City State or Zip IGenoa OH
Country IUnited States 9
Business Information provided by lnfoUSAcom Foster City California Copyright 0 2002
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1 1 am Vice President of RASP Broadcast Enterprises bc (lsquoaASPrdquo) the license of WJZB(FM) C h e l 2 4 7 A Oak Harbor Obio
RASP intends to apply for a construction permit for Channel 247A to specify oper Itions for WJZE in Genoa Ohio upon adoption ofthe Proposal as outljned h e n through the relevant Notice of Pmposed Rule Making
If am ardd the construction permit for Channel 247A RASP promptlywill construct and ITamp such facilities
2
3
Iherebydec are underpenallyofperjurythat thes ta tementsmade ia th i sdec l~~on~~e and accurate to the Ixst of my howledge information and belief
September a 2 002
DECLARATION
I Jeff Littlejohn declare as follows
3 I am Senior Vice President Engineering of Citicasters Licenses Inc (ldquoCiticastersrdquo) the licensee of WRVF(FM) Channel 268B Toledo Ohio
Citicasters intends to apply for a construction permit for Channel 268B to specamp operations for WRVF in Oak Harbor Ohio upon adoption of the Proposal as outlined herein through the relevant Notice of Proposed Rule Making
If awarded the construction permit for Channel 268B Citicasters promptly wi l l construct and operate such facilities
4
3
I hereby declare under penalty of perjury that the statements made in
this declaration are true and accurate to the best of my knowledge information and
belief
du Treil Lundin amp Rackley Inc Consulting Engineers
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Technical Narrative
This Technical Exhibit of which this Narrative is part proposes an FM Rule Making to modify the Commissions Table of Allotments contained within Section 73202 within the Commissions Rules It is proposed herein to modify the community of license of two FM stations No change in the stations reference coordinates are proposed
Summary of Rule Making Proposal
Below is a summary of the allocation changes requested in the Joint Petition for Rule Making
0 Delete Channel 247A at Oak Harbor Ohio and allot
Contingent on the adoption of the above change Channel 24A at Genoa Ohio
delete Channel 268B at Toledo Ohio and allot Channel 268B at Oak Harbor Ohio
Pursuant to Section 142O(i) of the Commissions Rules the Petition also requests modifications to the licenses of WJZE(FM) Channel 24A Oak Harbor Ohio and WRVF(FM) Channel 268B Toledo Ohio accordingly
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 2
Proposed Channel 247A Genoa Ohio
It is proposed to delete Channel 247A at Oak Harbor and allot Channel 247A to Genoa Ohio The Genoa proposal is mutually exclusive with the current Oak Harbor allotment As no change in the reference site change is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Genoa as shown in Figure 1
Below are the Channel 247A Genoa reference site geographic coordinates
41deg 29 17 North Latitude 83O 19 25 West Longitude
The existing Channel 241A reference coordinates do not satisfy the spacing requirements of Section 73207 with respect to three stations as identified in the allocation study provided in Figure 2 Each is discussed below
First under Section 73207 the proposed Channel 247A reference site is short-spaced to CHYR-FM on Channel 244C1 at Leamington Ontario Canada The required minimum separation distance is 90 kilometers the actual separation distance is 86 kilometers a short- spacing of 4 kilometers This Canadian allotment is a specially negotiated short-spaced allotment which was accepted by the Commission on September 2 1992 Petitionerrs Channel 247A is also a specially negotiated short-spaced allotment which was accepted by Canada on December 14 1992 Therefore because the proposed allotment does not involve any change in the relevant site this previously accepted spacing should satisfy the Commissions allocation requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 3
Second under Section 73207 the proposed Channel 248A reference site is short-spaced to WKRK-FM on Channel 246B at Detroit Michigan The required minimum separation distance is 113 kilometers the actual separation distance is 111 kilometers a short-spacing of 2 kilometers Petitioners Channel 247A was initially allocated as a 3 kilowatt100 meter facility and it remains as an equivalent facility Therefore for allotment purposes WKRK-FM can be protected pursuant to Section 73213(c) of the Commissions Rules which requires a minimum separation distance of 105 kilometers The proposed reference coordinates satisfies this requirement
Third under Section 73207 the proposed Channel 247A reference site is short-spaced to WMEE(FM) on Channel 247B at Fort Wayne Indiana The station was authorized to operate from the reference site (its current site) pursuant to the stations request to be processed under Section 73215 The required minimum separation distance is 178 kilometers the actual separation distance is 162 kilometers a short-spacing of 16 kilometers
However the proposed allotment does not create a new short or not exacerbate any short-spacing (under Section 73207) with regard to WMEE(FM) In addition WJZE(FM) already has been approved to operate at the reference site to the extent is affords WMEE(FM) contour protection pursuant to Section 73215 and the proposed allotment contemplates no change in WJZE(FM)s operating parameters Moreover WJZE(FM)s former (pre-Section 73215) transmitter site satisfied the relevant spacing requirement - the Section 73213(c) separation distance of 163 kilometers with regard to WMEE(FM) As shown in Figure 1 the projected city grade reference contour (70 dBu) of the allotment from this former site encompassed
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 4
the proposed community of Genoa this pre-Section 73215 site is provided in Figure 2
An allocation study from
Figure 5 is an Area-to-Locate map for Channel 247A As can be seen there is no present fully-spaced area-to-locate for this allotment
Proposed Channel 268B Oak Harbor Ohio
It is proposed to delete Channel 268B at Toledo and allot Channel 268B to Oak Harbor Ohio This Oak Harbor proposal is mutually exclusive with the current Toledo allotment As no change in the reference site is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Oak Harbor as shown in Figure 1
Below are the Channel 268B Oak Harbor reference site geographic coordinates
41O 40 23 North Latitude 83O 25 31 West Longitude
The existing Channel 268B reference coordinates do not satisfy Section 73201 requirements with respect to five stations as shown by the allocation study provided in Figure 4 Each short-spacing is discussed below
First under Section 73207 the proposed Channel 268B reference site is short-spaced to WMJK(FM) on Channel 265A at Clyde Ohio The required minimum separation distance is 69 kilometers the actual separation distance is 64 kilometers a short-spacing of 5 kilometers WMJK(FM) is a 3 kilowatt100 meter type Class A facility and therefore is processed pursuant to Section
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 5
13213 of the Rules as the short-spacing (under Section 13207) is not exacerbated
Second under Section 73207 the proposed Channel 268B reference site is short-spaced to WNCO-FM on Channel 267B at Ashland Ohio The required minimum separation distance is 169 kilometers the actual separation distance is 129 kilometers a short-spacing of 40 kilometers However because the Channel 268B allotment and WNCO-FM have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Third under Section 73207 the proposed Channel 268B reference site is short-spaced to a Canadian allotment on Channel 268A The required minimum separation distance is 210 kilometers the actual separation distance is 167 kilometers a short-spacing of 43 kilometers This Canadian allotment is a specially negotiated short-spaced allotment Therefore because the proposed allotment does not involve a change in the relevant site this previously accepted spacing should satisfy the Commissionrsquos allocation requiremements
Fourth under Section 73207 the proposed Channel 268B reference site is short-spaced to the current licensed and authorized facility of WWBN(FM) on Channel 268A at Tuscola Michigan because WWBN(FM) is authorized pursuant to Section 73215 with regard to WRVF(FM) Therefore as WRVF(FM) did not initiate this short- spacing and the proposed re-allotment involves no change in the WRVF(FM)rsquos current transmitter site the proposed spacing satisfies the Commissionrsquos allotment requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 6
Fifth under Section 73207 the proposed Channel 268B reference site is short-spaced to WNSN(FM) on Channel 268B at South Bend Indiana The required minimum separation distance is 14 kilometers the actual separation distance is 68 kilometers a short-spacing of 6 kilometers However because the Channel 268B allotment and WNSN(FM) have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Proposed Modifications to Table of Allotments
This proposal provides for the following allotment changes to Section 73202 The Commissionrsquos Table of FM Allotments
Lowell Oil Center (historical) hobth Amsden Maple Grove
Watson lie Mount Gilead
10 0 10 20 30 40 miles
H H H H t I I I I I I
H H H H I I I I I I I I 10 0 10 20 30 40 50 kilometers
CITY GRADE REFERENCE CONTOURS
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 2
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 241A Genoa Ohio Allocation Study Proposed Reference Site
41deg 29rsquo 17rdquo North Latitude 8 3 O 19rsquo 25ldquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(rn) Longitude deg-True (km) (hi) WBVI FOSTORIA BLH 244A 30 41-06-00 1964 4494 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR- F LEAMINGTON 244C1 910 42-00-35 472 8582 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Page 1 of 1 Yahoo Yellow Pages
Home - Yahoo1 - Maps -Address Book - Hell -BYeIow Pages
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Yahoo Yellow Pages Genoa OH
Top gt Community gt Government gt Law and Justice gt Law Enforcement ~
All Businesses Business Name Address Clay Township Police Dept 21714 E Holts Rd (419) 855-3444 GenoaOH Map
Genoa Palice Dept 102 E 6th St GenoaOH Map
Change Location - Save This Location
Showing 1-2 of 2 1 Beyond Genoa
(419) 855-7747
Showing 1-2 of 2 1 Beyond Genoa
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Search by Name or Category 1-
Business Information provided by InfoUSAcom Foster City California Copyright Q 2002
All Rights Resewed Use Subject to License
Copyright 0 2002 Yahoo Inc Ail rights reserved H a - Privacv Pplicy - T-Sampe
1 1 am Vice President of RASP Broadcast Enterprises bc (lsquoaASPrdquo) the license of WJZB(FM) C h e l 2 4 7 A Oak Harbor Obio
RASP intends to apply for a construction permit for Channel 247A to specify oper Itions for WJZE in Genoa Ohio upon adoption ofthe Proposal as outljned h e n through the relevant Notice of Pmposed Rule Making
If am ardd the construction permit for Channel 247A RASP promptlywill construct and ITamp such facilities
2
3
Iherebydec are underpenallyofperjurythat thes ta tementsmade ia th i sdec l~~on~~e and accurate to the Ixst of my howledge information and belief
September a 2 002
DECLARATION
I Jeff Littlejohn declare as follows
3 I am Senior Vice President Engineering of Citicasters Licenses Inc (ldquoCiticastersrdquo) the licensee of WRVF(FM) Channel 268B Toledo Ohio
Citicasters intends to apply for a construction permit for Channel 268B to specamp operations for WRVF in Oak Harbor Ohio upon adoption of the Proposal as outlined herein through the relevant Notice of Proposed Rule Making
If awarded the construction permit for Channel 268B Citicasters promptly wi l l construct and operate such facilities
4
3
I hereby declare under penalty of perjury that the statements made in
this declaration are true and accurate to the best of my knowledge information and
belief
du Treil Lundin amp Rackley Inc Consulting Engineers
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Technical Narrative
This Technical Exhibit of which this Narrative is part proposes an FM Rule Making to modify the Commissions Table of Allotments contained within Section 73202 within the Commissions Rules It is proposed herein to modify the community of license of two FM stations No change in the stations reference coordinates are proposed
Summary of Rule Making Proposal
Below is a summary of the allocation changes requested in the Joint Petition for Rule Making
0 Delete Channel 247A at Oak Harbor Ohio and allot
Contingent on the adoption of the above change Channel 24A at Genoa Ohio
delete Channel 268B at Toledo Ohio and allot Channel 268B at Oak Harbor Ohio
Pursuant to Section 142O(i) of the Commissions Rules the Petition also requests modifications to the licenses of WJZE(FM) Channel 24A Oak Harbor Ohio and WRVF(FM) Channel 268B Toledo Ohio accordingly
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 2
Proposed Channel 247A Genoa Ohio
It is proposed to delete Channel 247A at Oak Harbor and allot Channel 247A to Genoa Ohio The Genoa proposal is mutually exclusive with the current Oak Harbor allotment As no change in the reference site change is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Genoa as shown in Figure 1
Below are the Channel 247A Genoa reference site geographic coordinates
41deg 29 17 North Latitude 83O 19 25 West Longitude
The existing Channel 241A reference coordinates do not satisfy the spacing requirements of Section 73207 with respect to three stations as identified in the allocation study provided in Figure 2 Each is discussed below
First under Section 73207 the proposed Channel 247A reference site is short-spaced to CHYR-FM on Channel 244C1 at Leamington Ontario Canada The required minimum separation distance is 90 kilometers the actual separation distance is 86 kilometers a short- spacing of 4 kilometers This Canadian allotment is a specially negotiated short-spaced allotment which was accepted by the Commission on September 2 1992 Petitionerrs Channel 247A is also a specially negotiated short-spaced allotment which was accepted by Canada on December 14 1992 Therefore because the proposed allotment does not involve any change in the relevant site this previously accepted spacing should satisfy the Commissions allocation requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 3
Second under Section 73207 the proposed Channel 248A reference site is short-spaced to WKRK-FM on Channel 246B at Detroit Michigan The required minimum separation distance is 113 kilometers the actual separation distance is 111 kilometers a short-spacing of 2 kilometers Petitioners Channel 247A was initially allocated as a 3 kilowatt100 meter facility and it remains as an equivalent facility Therefore for allotment purposes WKRK-FM can be protected pursuant to Section 73213(c) of the Commissions Rules which requires a minimum separation distance of 105 kilometers The proposed reference coordinates satisfies this requirement
Third under Section 73207 the proposed Channel 247A reference site is short-spaced to WMEE(FM) on Channel 247B at Fort Wayne Indiana The station was authorized to operate from the reference site (its current site) pursuant to the stations request to be processed under Section 73215 The required minimum separation distance is 178 kilometers the actual separation distance is 162 kilometers a short-spacing of 16 kilometers
However the proposed allotment does not create a new short or not exacerbate any short-spacing (under Section 73207) with regard to WMEE(FM) In addition WJZE(FM) already has been approved to operate at the reference site to the extent is affords WMEE(FM) contour protection pursuant to Section 73215 and the proposed allotment contemplates no change in WJZE(FM)s operating parameters Moreover WJZE(FM)s former (pre-Section 73215) transmitter site satisfied the relevant spacing requirement - the Section 73213(c) separation distance of 163 kilometers with regard to WMEE(FM) As shown in Figure 1 the projected city grade reference contour (70 dBu) of the allotment from this former site encompassed
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 4
the proposed community of Genoa this pre-Section 73215 site is provided in Figure 2
An allocation study from
Figure 5 is an Area-to-Locate map for Channel 247A As can be seen there is no present fully-spaced area-to-locate for this allotment
Proposed Channel 268B Oak Harbor Ohio
It is proposed to delete Channel 268B at Toledo and allot Channel 268B to Oak Harbor Ohio This Oak Harbor proposal is mutually exclusive with the current Toledo allotment As no change in the reference site is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Oak Harbor as shown in Figure 1
Below are the Channel 268B Oak Harbor reference site geographic coordinates
41O 40 23 North Latitude 83O 25 31 West Longitude
The existing Channel 268B reference coordinates do not satisfy Section 73201 requirements with respect to five stations as shown by the allocation study provided in Figure 4 Each short-spacing is discussed below
First under Section 73207 the proposed Channel 268B reference site is short-spaced to WMJK(FM) on Channel 265A at Clyde Ohio The required minimum separation distance is 69 kilometers the actual separation distance is 64 kilometers a short-spacing of 5 kilometers WMJK(FM) is a 3 kilowatt100 meter type Class A facility and therefore is processed pursuant to Section
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 5
13213 of the Rules as the short-spacing (under Section 13207) is not exacerbated
Second under Section 73207 the proposed Channel 268B reference site is short-spaced to WNCO-FM on Channel 267B at Ashland Ohio The required minimum separation distance is 169 kilometers the actual separation distance is 129 kilometers a short-spacing of 40 kilometers However because the Channel 268B allotment and WNCO-FM have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Third under Section 73207 the proposed Channel 268B reference site is short-spaced to a Canadian allotment on Channel 268A The required minimum separation distance is 210 kilometers the actual separation distance is 167 kilometers a short-spacing of 43 kilometers This Canadian allotment is a specially negotiated short-spaced allotment Therefore because the proposed allotment does not involve a change in the relevant site this previously accepted spacing should satisfy the Commissionrsquos allocation requiremements
Fourth under Section 73207 the proposed Channel 268B reference site is short-spaced to the current licensed and authorized facility of WWBN(FM) on Channel 268A at Tuscola Michigan because WWBN(FM) is authorized pursuant to Section 73215 with regard to WRVF(FM) Therefore as WRVF(FM) did not initiate this short- spacing and the proposed re-allotment involves no change in the WRVF(FM)rsquos current transmitter site the proposed spacing satisfies the Commissionrsquos allotment requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 6
Fifth under Section 73207 the proposed Channel 268B reference site is short-spaced to WNSN(FM) on Channel 268B at South Bend Indiana The required minimum separation distance is 14 kilometers the actual separation distance is 68 kilometers a short-spacing of 6 kilometers However because the Channel 268B allotment and WNSN(FM) have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Proposed Modifications to Table of Allotments
This proposal provides for the following allotment changes to Section 73202 The Commissionrsquos Table of FM Allotments
Lowell Oil Center (historical) hobth Amsden Maple Grove
Watson lie Mount Gilead
10 0 10 20 30 40 miles
H H H H t I I I I I I
H H H H I I I I I I I I 10 0 10 20 30 40 50 kilometers
CITY GRADE REFERENCE CONTOURS
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 2
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 241A Genoa Ohio Allocation Study Proposed Reference Site
41deg 29rsquo 17rdquo North Latitude 8 3 O 19rsquo 25ldquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(rn) Longitude deg-True (km) (hi) WBVI FOSTORIA BLH 244A 30 41-06-00 1964 4494 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR- F LEAMINGTON 244C1 910 42-00-35 472 8582 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Yahoo Yellow Pages Page 1 of 2
Home -Yahoo - Maps - Address Book - HelF
Welcome Guest User
Yahoo Yellow Pages Genoa OH
Create My Favorite Locations - Sign In
Change~Location - Save This Location
TQI gt Edlrcali~o and I n s t r u m gt K-12 gt Elementary Schools 7 All Businesses Showing 1-4 of 4 1 Beyond Genoa
Business Name Address Brunner Elementary School (419) 855-8373 GenoaOH
Cpmwni ty Christian Academy (419) 8554187 GenoaOH Map
1224 West St
303 W 4th St
Genoa Area High School (419) 855-7735 GenoaOH Map
Genoa Area Junior High School 14191 855-7781 GenoaOH Map
2980 N Genoa Clay Center Rd
303 W 4th St
Showing 1-4 of 4 I Beyond Genoa
Beyond Genoa
Modify your search
city State or Zip IGenoa OH
Business Information provided by lnfoUSAcom Foster City California Copyright o 2002
1 1 am Vice President of RASP Broadcast Enterprises bc (lsquoaASPrdquo) the license of WJZB(FM) C h e l 2 4 7 A Oak Harbor Obio
RASP intends to apply for a construction permit for Channel 247A to specify oper Itions for WJZE in Genoa Ohio upon adoption ofthe Proposal as outljned h e n through the relevant Notice of Pmposed Rule Making
If am ardd the construction permit for Channel 247A RASP promptlywill construct and ITamp such facilities
2
3
Iherebydec are underpenallyofperjurythat thes ta tementsmade ia th i sdec l~~on~~e and accurate to the Ixst of my howledge information and belief
September a 2 002
DECLARATION
I Jeff Littlejohn declare as follows
3 I am Senior Vice President Engineering of Citicasters Licenses Inc (ldquoCiticastersrdquo) the licensee of WRVF(FM) Channel 268B Toledo Ohio
Citicasters intends to apply for a construction permit for Channel 268B to specamp operations for WRVF in Oak Harbor Ohio upon adoption of the Proposal as outlined herein through the relevant Notice of Proposed Rule Making
If awarded the construction permit for Channel 268B Citicasters promptly wi l l construct and operate such facilities
4
3
I hereby declare under penalty of perjury that the statements made in
this declaration are true and accurate to the best of my knowledge information and
belief
du Treil Lundin amp Rackley Inc Consulting Engineers
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Technical Narrative
This Technical Exhibit of which this Narrative is part proposes an FM Rule Making to modify the Commissions Table of Allotments contained within Section 73202 within the Commissions Rules It is proposed herein to modify the community of license of two FM stations No change in the stations reference coordinates are proposed
Summary of Rule Making Proposal
Below is a summary of the allocation changes requested in the Joint Petition for Rule Making
0 Delete Channel 247A at Oak Harbor Ohio and allot
Contingent on the adoption of the above change Channel 24A at Genoa Ohio
delete Channel 268B at Toledo Ohio and allot Channel 268B at Oak Harbor Ohio
Pursuant to Section 142O(i) of the Commissions Rules the Petition also requests modifications to the licenses of WJZE(FM) Channel 24A Oak Harbor Ohio and WRVF(FM) Channel 268B Toledo Ohio accordingly
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 2
Proposed Channel 247A Genoa Ohio
It is proposed to delete Channel 247A at Oak Harbor and allot Channel 247A to Genoa Ohio The Genoa proposal is mutually exclusive with the current Oak Harbor allotment As no change in the reference site change is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Genoa as shown in Figure 1
Below are the Channel 247A Genoa reference site geographic coordinates
41deg 29 17 North Latitude 83O 19 25 West Longitude
The existing Channel 241A reference coordinates do not satisfy the spacing requirements of Section 73207 with respect to three stations as identified in the allocation study provided in Figure 2 Each is discussed below
First under Section 73207 the proposed Channel 247A reference site is short-spaced to CHYR-FM on Channel 244C1 at Leamington Ontario Canada The required minimum separation distance is 90 kilometers the actual separation distance is 86 kilometers a short- spacing of 4 kilometers This Canadian allotment is a specially negotiated short-spaced allotment which was accepted by the Commission on September 2 1992 Petitionerrs Channel 247A is also a specially negotiated short-spaced allotment which was accepted by Canada on December 14 1992 Therefore because the proposed allotment does not involve any change in the relevant site this previously accepted spacing should satisfy the Commissions allocation requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 3
Second under Section 73207 the proposed Channel 248A reference site is short-spaced to WKRK-FM on Channel 246B at Detroit Michigan The required minimum separation distance is 113 kilometers the actual separation distance is 111 kilometers a short-spacing of 2 kilometers Petitioners Channel 247A was initially allocated as a 3 kilowatt100 meter facility and it remains as an equivalent facility Therefore for allotment purposes WKRK-FM can be protected pursuant to Section 73213(c) of the Commissions Rules which requires a minimum separation distance of 105 kilometers The proposed reference coordinates satisfies this requirement
Third under Section 73207 the proposed Channel 247A reference site is short-spaced to WMEE(FM) on Channel 247B at Fort Wayne Indiana The station was authorized to operate from the reference site (its current site) pursuant to the stations request to be processed under Section 73215 The required minimum separation distance is 178 kilometers the actual separation distance is 162 kilometers a short-spacing of 16 kilometers
However the proposed allotment does not create a new short or not exacerbate any short-spacing (under Section 73207) with regard to WMEE(FM) In addition WJZE(FM) already has been approved to operate at the reference site to the extent is affords WMEE(FM) contour protection pursuant to Section 73215 and the proposed allotment contemplates no change in WJZE(FM)s operating parameters Moreover WJZE(FM)s former (pre-Section 73215) transmitter site satisfied the relevant spacing requirement - the Section 73213(c) separation distance of 163 kilometers with regard to WMEE(FM) As shown in Figure 1 the projected city grade reference contour (70 dBu) of the allotment from this former site encompassed
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 4
the proposed community of Genoa this pre-Section 73215 site is provided in Figure 2
An allocation study from
Figure 5 is an Area-to-Locate map for Channel 247A As can be seen there is no present fully-spaced area-to-locate for this allotment
Proposed Channel 268B Oak Harbor Ohio
It is proposed to delete Channel 268B at Toledo and allot Channel 268B to Oak Harbor Ohio This Oak Harbor proposal is mutually exclusive with the current Toledo allotment As no change in the reference site is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Oak Harbor as shown in Figure 1
Below are the Channel 268B Oak Harbor reference site geographic coordinates
41O 40 23 North Latitude 83O 25 31 West Longitude
The existing Channel 268B reference coordinates do not satisfy Section 73201 requirements with respect to five stations as shown by the allocation study provided in Figure 4 Each short-spacing is discussed below
First under Section 73207 the proposed Channel 268B reference site is short-spaced to WMJK(FM) on Channel 265A at Clyde Ohio The required minimum separation distance is 69 kilometers the actual separation distance is 64 kilometers a short-spacing of 5 kilometers WMJK(FM) is a 3 kilowatt100 meter type Class A facility and therefore is processed pursuant to Section
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 5
13213 of the Rules as the short-spacing (under Section 13207) is not exacerbated
Second under Section 73207 the proposed Channel 268B reference site is short-spaced to WNCO-FM on Channel 267B at Ashland Ohio The required minimum separation distance is 169 kilometers the actual separation distance is 129 kilometers a short-spacing of 40 kilometers However because the Channel 268B allotment and WNCO-FM have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Third under Section 73207 the proposed Channel 268B reference site is short-spaced to a Canadian allotment on Channel 268A The required minimum separation distance is 210 kilometers the actual separation distance is 167 kilometers a short-spacing of 43 kilometers This Canadian allotment is a specially negotiated short-spaced allotment Therefore because the proposed allotment does not involve a change in the relevant site this previously accepted spacing should satisfy the Commissionrsquos allocation requiremements
Fourth under Section 73207 the proposed Channel 268B reference site is short-spaced to the current licensed and authorized facility of WWBN(FM) on Channel 268A at Tuscola Michigan because WWBN(FM) is authorized pursuant to Section 73215 with regard to WRVF(FM) Therefore as WRVF(FM) did not initiate this short- spacing and the proposed re-allotment involves no change in the WRVF(FM)rsquos current transmitter site the proposed spacing satisfies the Commissionrsquos allotment requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 6
Fifth under Section 73207 the proposed Channel 268B reference site is short-spaced to WNSN(FM) on Channel 268B at South Bend Indiana The required minimum separation distance is 14 kilometers the actual separation distance is 68 kilometers a short-spacing of 6 kilometers However because the Channel 268B allotment and WNSN(FM) have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Proposed Modifications to Table of Allotments
This proposal provides for the following allotment changes to Section 73202 The Commissionrsquos Table of FM Allotments
Lowell Oil Center (historical) hobth Amsden Maple Grove
Watson lie Mount Gilead
10 0 10 20 30 40 miles
H H H H t I I I I I I
H H H H I I I I I I I I 10 0 10 20 30 40 50 kilometers
CITY GRADE REFERENCE CONTOURS
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 2
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 241A Genoa Ohio Allocation Study Proposed Reference Site
41deg 29rsquo 17rdquo North Latitude 8 3 O 19rsquo 25ldquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(rn) Longitude deg-True (km) (hi) WBVI FOSTORIA BLH 244A 30 41-06-00 1964 4494 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR- F LEAMINGTON 244C1 910 42-00-35 472 8582 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
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I Showing 1-1 of 1 I Beyond Genoa
Address 602 West St GenoaOH ampip
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I Showing 1-5 of 5 1 Beyond Genoa
Address 303 W 4th St GenoaOH ampQ
_ _ _ _ ~ ~
Genoa ChrisXaampurch 415 Main St (419) 855-3464 GenoaOH Map
Our Lady Of Lourdes Catholic (419) 855-8501 GenoaOH Map
St Johns United Church-Christ (419) 855-3906 GenoaOH Map
Trinity United Methodist Chr (419) 855-3575 GenoaOH Map
204 Main St
1213 Washington St
313 Main St
Showing 1-5 of 5 I BeyodGenoa
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1 1 am Vice President of RASP Broadcast Enterprises bc (lsquoaASPrdquo) the license of WJZB(FM) C h e l 2 4 7 A Oak Harbor Obio
RASP intends to apply for a construction permit for Channel 247A to specify oper Itions for WJZE in Genoa Ohio upon adoption ofthe Proposal as outljned h e n through the relevant Notice of Pmposed Rule Making
If am ardd the construction permit for Channel 247A RASP promptlywill construct and ITamp such facilities
2
3
Iherebydec are underpenallyofperjurythat thes ta tementsmade ia th i sdec l~~on~~e and accurate to the Ixst of my howledge information and belief
September a 2 002
DECLARATION
I Jeff Littlejohn declare as follows
3 I am Senior Vice President Engineering of Citicasters Licenses Inc (ldquoCiticastersrdquo) the licensee of WRVF(FM) Channel 268B Toledo Ohio
Citicasters intends to apply for a construction permit for Channel 268B to specamp operations for WRVF in Oak Harbor Ohio upon adoption of the Proposal as outlined herein through the relevant Notice of Proposed Rule Making
If awarded the construction permit for Channel 268B Citicasters promptly wi l l construct and operate such facilities
4
3
I hereby declare under penalty of perjury that the statements made in
this declaration are true and accurate to the best of my knowledge information and
belief
du Treil Lundin amp Rackley Inc Consulting Engineers
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Technical Narrative
This Technical Exhibit of which this Narrative is part proposes an FM Rule Making to modify the Commissions Table of Allotments contained within Section 73202 within the Commissions Rules It is proposed herein to modify the community of license of two FM stations No change in the stations reference coordinates are proposed
Summary of Rule Making Proposal
Below is a summary of the allocation changes requested in the Joint Petition for Rule Making
0 Delete Channel 247A at Oak Harbor Ohio and allot
Contingent on the adoption of the above change Channel 24A at Genoa Ohio
delete Channel 268B at Toledo Ohio and allot Channel 268B at Oak Harbor Ohio
Pursuant to Section 142O(i) of the Commissions Rules the Petition also requests modifications to the licenses of WJZE(FM) Channel 24A Oak Harbor Ohio and WRVF(FM) Channel 268B Toledo Ohio accordingly
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 2
Proposed Channel 247A Genoa Ohio
It is proposed to delete Channel 247A at Oak Harbor and allot Channel 247A to Genoa Ohio The Genoa proposal is mutually exclusive with the current Oak Harbor allotment As no change in the reference site change is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Genoa as shown in Figure 1
Below are the Channel 247A Genoa reference site geographic coordinates
41deg 29 17 North Latitude 83O 19 25 West Longitude
The existing Channel 241A reference coordinates do not satisfy the spacing requirements of Section 73207 with respect to three stations as identified in the allocation study provided in Figure 2 Each is discussed below
First under Section 73207 the proposed Channel 247A reference site is short-spaced to CHYR-FM on Channel 244C1 at Leamington Ontario Canada The required minimum separation distance is 90 kilometers the actual separation distance is 86 kilometers a short- spacing of 4 kilometers This Canadian allotment is a specially negotiated short-spaced allotment which was accepted by the Commission on September 2 1992 Petitionerrs Channel 247A is also a specially negotiated short-spaced allotment which was accepted by Canada on December 14 1992 Therefore because the proposed allotment does not involve any change in the relevant site this previously accepted spacing should satisfy the Commissions allocation requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 3
Second under Section 73207 the proposed Channel 248A reference site is short-spaced to WKRK-FM on Channel 246B at Detroit Michigan The required minimum separation distance is 113 kilometers the actual separation distance is 111 kilometers a short-spacing of 2 kilometers Petitioners Channel 247A was initially allocated as a 3 kilowatt100 meter facility and it remains as an equivalent facility Therefore for allotment purposes WKRK-FM can be protected pursuant to Section 73213(c) of the Commissions Rules which requires a minimum separation distance of 105 kilometers The proposed reference coordinates satisfies this requirement
Third under Section 73207 the proposed Channel 247A reference site is short-spaced to WMEE(FM) on Channel 247B at Fort Wayne Indiana The station was authorized to operate from the reference site (its current site) pursuant to the stations request to be processed under Section 73215 The required minimum separation distance is 178 kilometers the actual separation distance is 162 kilometers a short-spacing of 16 kilometers
However the proposed allotment does not create a new short or not exacerbate any short-spacing (under Section 73207) with regard to WMEE(FM) In addition WJZE(FM) already has been approved to operate at the reference site to the extent is affords WMEE(FM) contour protection pursuant to Section 73215 and the proposed allotment contemplates no change in WJZE(FM)s operating parameters Moreover WJZE(FM)s former (pre-Section 73215) transmitter site satisfied the relevant spacing requirement - the Section 73213(c) separation distance of 163 kilometers with regard to WMEE(FM) As shown in Figure 1 the projected city grade reference contour (70 dBu) of the allotment from this former site encompassed
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 4
the proposed community of Genoa this pre-Section 73215 site is provided in Figure 2
An allocation study from
Figure 5 is an Area-to-Locate map for Channel 247A As can be seen there is no present fully-spaced area-to-locate for this allotment
Proposed Channel 268B Oak Harbor Ohio
It is proposed to delete Channel 268B at Toledo and allot Channel 268B to Oak Harbor Ohio This Oak Harbor proposal is mutually exclusive with the current Toledo allotment As no change in the reference site is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Oak Harbor as shown in Figure 1
Below are the Channel 268B Oak Harbor reference site geographic coordinates
41O 40 23 North Latitude 83O 25 31 West Longitude
The existing Channel 268B reference coordinates do not satisfy Section 73201 requirements with respect to five stations as shown by the allocation study provided in Figure 4 Each short-spacing is discussed below
First under Section 73207 the proposed Channel 268B reference site is short-spaced to WMJK(FM) on Channel 265A at Clyde Ohio The required minimum separation distance is 69 kilometers the actual separation distance is 64 kilometers a short-spacing of 5 kilometers WMJK(FM) is a 3 kilowatt100 meter type Class A facility and therefore is processed pursuant to Section
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 5
13213 of the Rules as the short-spacing (under Section 13207) is not exacerbated
Second under Section 73207 the proposed Channel 268B reference site is short-spaced to WNCO-FM on Channel 267B at Ashland Ohio The required minimum separation distance is 169 kilometers the actual separation distance is 129 kilometers a short-spacing of 40 kilometers However because the Channel 268B allotment and WNCO-FM have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Third under Section 73207 the proposed Channel 268B reference site is short-spaced to a Canadian allotment on Channel 268A The required minimum separation distance is 210 kilometers the actual separation distance is 167 kilometers a short-spacing of 43 kilometers This Canadian allotment is a specially negotiated short-spaced allotment Therefore because the proposed allotment does not involve a change in the relevant site this previously accepted spacing should satisfy the Commissionrsquos allocation requiremements
Fourth under Section 73207 the proposed Channel 268B reference site is short-spaced to the current licensed and authorized facility of WWBN(FM) on Channel 268A at Tuscola Michigan because WWBN(FM) is authorized pursuant to Section 73215 with regard to WRVF(FM) Therefore as WRVF(FM) did not initiate this short- spacing and the proposed re-allotment involves no change in the WRVF(FM)rsquos current transmitter site the proposed spacing satisfies the Commissionrsquos allotment requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 6
Fifth under Section 73207 the proposed Channel 268B reference site is short-spaced to WNSN(FM) on Channel 268B at South Bend Indiana The required minimum separation distance is 14 kilometers the actual separation distance is 68 kilometers a short-spacing of 6 kilometers However because the Channel 268B allotment and WNSN(FM) have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Proposed Modifications to Table of Allotments
This proposal provides for the following allotment changes to Section 73202 The Commissionrsquos Table of FM Allotments
Lowell Oil Center (historical) hobth Amsden Maple Grove
Watson lie Mount Gilead
10 0 10 20 30 40 miles
H H H H t I I I I I I
H H H H I I I I I I I I 10 0 10 20 30 40 50 kilometers
CITY GRADE REFERENCE CONTOURS
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 2
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 241A Genoa Ohio Allocation Study Proposed Reference Site
41deg 29rsquo 17rdquo North Latitude 8 3 O 19rsquo 25ldquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(rn) Longitude deg-True (km) (hi) WBVI FOSTORIA BLH 244A 30 41-06-00 1964 4494 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR- F LEAMINGTON 244C1 910 42-00-35 472 8582 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Yahoo Yellow Pages Page 1 of 2
Home - Yahoo1 - Maps - Address Book - Heamp -1YeIIow Pages
Welcome Guest User
Yahoo Yellow Pages Genoa OH
Top gt Community gt R e l i h gt Churches
All Businesses Business Name Christ Community Church (419) 855-4187
Create My Favorite Locations - Sign In
Change Location -Save This Location
I Showing 1-5 of 5 1 Beyond Genoa
Address 303 W 4th St GenoaOH ampQ
_ _ _ _ ~ ~
Genoa ChrisXaampurch 415 Main St (419) 855-3464 GenoaOH Map
Our Lady Of Lourdes Catholic (419) 855-8501 GenoaOH Map
St Johns United Church-Christ (419) 855-3906 GenoaOH Map
Trinity United Methodist Chr (419) 855-3575 GenoaOH Map
204 Main St
1213 Washington St
313 Main St
Showing 1-5 of 5 I BeyodGenoa
Beyond Genoa
Modify your search
Search by Name or Category r Recent Favorite Locations Edit
1 1 am Vice President of RASP Broadcast Enterprises bc (lsquoaASPrdquo) the license of WJZB(FM) C h e l 2 4 7 A Oak Harbor Obio
RASP intends to apply for a construction permit for Channel 247A to specify oper Itions for WJZE in Genoa Ohio upon adoption ofthe Proposal as outljned h e n through the relevant Notice of Pmposed Rule Making
If am ardd the construction permit for Channel 247A RASP promptlywill construct and ITamp such facilities
2
3
Iherebydec are underpenallyofperjurythat thes ta tementsmade ia th i sdec l~~on~~e and accurate to the Ixst of my howledge information and belief
September a 2 002
DECLARATION
I Jeff Littlejohn declare as follows
3 I am Senior Vice President Engineering of Citicasters Licenses Inc (ldquoCiticastersrdquo) the licensee of WRVF(FM) Channel 268B Toledo Ohio
Citicasters intends to apply for a construction permit for Channel 268B to specamp operations for WRVF in Oak Harbor Ohio upon adoption of the Proposal as outlined herein through the relevant Notice of Proposed Rule Making
If awarded the construction permit for Channel 268B Citicasters promptly wi l l construct and operate such facilities
4
3
I hereby declare under penalty of perjury that the statements made in
this declaration are true and accurate to the best of my knowledge information and
belief
du Treil Lundin amp Rackley Inc Consulting Engineers
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Technical Narrative
This Technical Exhibit of which this Narrative is part proposes an FM Rule Making to modify the Commissions Table of Allotments contained within Section 73202 within the Commissions Rules It is proposed herein to modify the community of license of two FM stations No change in the stations reference coordinates are proposed
Summary of Rule Making Proposal
Below is a summary of the allocation changes requested in the Joint Petition for Rule Making
0 Delete Channel 247A at Oak Harbor Ohio and allot
Contingent on the adoption of the above change Channel 24A at Genoa Ohio
delete Channel 268B at Toledo Ohio and allot Channel 268B at Oak Harbor Ohio
Pursuant to Section 142O(i) of the Commissions Rules the Petition also requests modifications to the licenses of WJZE(FM) Channel 24A Oak Harbor Ohio and WRVF(FM) Channel 268B Toledo Ohio accordingly
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 2
Proposed Channel 247A Genoa Ohio
It is proposed to delete Channel 247A at Oak Harbor and allot Channel 247A to Genoa Ohio The Genoa proposal is mutually exclusive with the current Oak Harbor allotment As no change in the reference site change is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Genoa as shown in Figure 1
Below are the Channel 247A Genoa reference site geographic coordinates
41deg 29 17 North Latitude 83O 19 25 West Longitude
The existing Channel 241A reference coordinates do not satisfy the spacing requirements of Section 73207 with respect to three stations as identified in the allocation study provided in Figure 2 Each is discussed below
First under Section 73207 the proposed Channel 247A reference site is short-spaced to CHYR-FM on Channel 244C1 at Leamington Ontario Canada The required minimum separation distance is 90 kilometers the actual separation distance is 86 kilometers a short- spacing of 4 kilometers This Canadian allotment is a specially negotiated short-spaced allotment which was accepted by the Commission on September 2 1992 Petitionerrs Channel 247A is also a specially negotiated short-spaced allotment which was accepted by Canada on December 14 1992 Therefore because the proposed allotment does not involve any change in the relevant site this previously accepted spacing should satisfy the Commissions allocation requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 3
Second under Section 73207 the proposed Channel 248A reference site is short-spaced to WKRK-FM on Channel 246B at Detroit Michigan The required minimum separation distance is 113 kilometers the actual separation distance is 111 kilometers a short-spacing of 2 kilometers Petitioners Channel 247A was initially allocated as a 3 kilowatt100 meter facility and it remains as an equivalent facility Therefore for allotment purposes WKRK-FM can be protected pursuant to Section 73213(c) of the Commissions Rules which requires a minimum separation distance of 105 kilometers The proposed reference coordinates satisfies this requirement
Third under Section 73207 the proposed Channel 247A reference site is short-spaced to WMEE(FM) on Channel 247B at Fort Wayne Indiana The station was authorized to operate from the reference site (its current site) pursuant to the stations request to be processed under Section 73215 The required minimum separation distance is 178 kilometers the actual separation distance is 162 kilometers a short-spacing of 16 kilometers
However the proposed allotment does not create a new short or not exacerbate any short-spacing (under Section 73207) with regard to WMEE(FM) In addition WJZE(FM) already has been approved to operate at the reference site to the extent is affords WMEE(FM) contour protection pursuant to Section 73215 and the proposed allotment contemplates no change in WJZE(FM)s operating parameters Moreover WJZE(FM)s former (pre-Section 73215) transmitter site satisfied the relevant spacing requirement - the Section 73213(c) separation distance of 163 kilometers with regard to WMEE(FM) As shown in Figure 1 the projected city grade reference contour (70 dBu) of the allotment from this former site encompassed
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 4
the proposed community of Genoa this pre-Section 73215 site is provided in Figure 2
An allocation study from
Figure 5 is an Area-to-Locate map for Channel 247A As can be seen there is no present fully-spaced area-to-locate for this allotment
Proposed Channel 268B Oak Harbor Ohio
It is proposed to delete Channel 268B at Toledo and allot Channel 268B to Oak Harbor Ohio This Oak Harbor proposal is mutually exclusive with the current Toledo allotment As no change in the reference site is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Oak Harbor as shown in Figure 1
Below are the Channel 268B Oak Harbor reference site geographic coordinates
41O 40 23 North Latitude 83O 25 31 West Longitude
The existing Channel 268B reference coordinates do not satisfy Section 73201 requirements with respect to five stations as shown by the allocation study provided in Figure 4 Each short-spacing is discussed below
First under Section 73207 the proposed Channel 268B reference site is short-spaced to WMJK(FM) on Channel 265A at Clyde Ohio The required minimum separation distance is 69 kilometers the actual separation distance is 64 kilometers a short-spacing of 5 kilometers WMJK(FM) is a 3 kilowatt100 meter type Class A facility and therefore is processed pursuant to Section
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 5
13213 of the Rules as the short-spacing (under Section 13207) is not exacerbated
Second under Section 73207 the proposed Channel 268B reference site is short-spaced to WNCO-FM on Channel 267B at Ashland Ohio The required minimum separation distance is 169 kilometers the actual separation distance is 129 kilometers a short-spacing of 40 kilometers However because the Channel 268B allotment and WNCO-FM have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Third under Section 73207 the proposed Channel 268B reference site is short-spaced to a Canadian allotment on Channel 268A The required minimum separation distance is 210 kilometers the actual separation distance is 167 kilometers a short-spacing of 43 kilometers This Canadian allotment is a specially negotiated short-spaced allotment Therefore because the proposed allotment does not involve a change in the relevant site this previously accepted spacing should satisfy the Commissionrsquos allocation requiremements
Fourth under Section 73207 the proposed Channel 268B reference site is short-spaced to the current licensed and authorized facility of WWBN(FM) on Channel 268A at Tuscola Michigan because WWBN(FM) is authorized pursuant to Section 73215 with regard to WRVF(FM) Therefore as WRVF(FM) did not initiate this short- spacing and the proposed re-allotment involves no change in the WRVF(FM)rsquos current transmitter site the proposed spacing satisfies the Commissionrsquos allotment requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 6
Fifth under Section 73207 the proposed Channel 268B reference site is short-spaced to WNSN(FM) on Channel 268B at South Bend Indiana The required minimum separation distance is 14 kilometers the actual separation distance is 68 kilometers a short-spacing of 6 kilometers However because the Channel 268B allotment and WNSN(FM) have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Proposed Modifications to Table of Allotments
This proposal provides for the following allotment changes to Section 73202 The Commissionrsquos Table of FM Allotments
Lowell Oil Center (historical) hobth Amsden Maple Grove
Watson lie Mount Gilead
10 0 10 20 30 40 miles
H H H H t I I I I I I
H H H H I I I I I I I I 10 0 10 20 30 40 50 kilometers
CITY GRADE REFERENCE CONTOURS
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 2
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 241A Genoa Ohio Allocation Study Proposed Reference Site
41deg 29rsquo 17rdquo North Latitude 8 3 O 19rsquo 25ldquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(rn) Longitude deg-True (km) (hi) WBVI FOSTORIA BLH 244A 30 41-06-00 1964 4494 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR- F LEAMINGTON 244C1 910 42-00-35 472 8582 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
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I Showing 1-1 of 1 I Beyond Genoa
Address 22361 Holt Harrigan Rd GenoaOH W
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Business Information provided by lnfoUSAcom Foster City California Copyright 0 2002 All Rights Reserved Use Subject to License
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1 1 am Vice President of RASP Broadcast Enterprises bc (lsquoaASPrdquo) the license of WJZB(FM) C h e l 2 4 7 A Oak Harbor Obio
RASP intends to apply for a construction permit for Channel 247A to specify oper Itions for WJZE in Genoa Ohio upon adoption ofthe Proposal as outljned h e n through the relevant Notice of Pmposed Rule Making
If am ardd the construction permit for Channel 247A RASP promptlywill construct and ITamp such facilities
2
3
Iherebydec are underpenallyofperjurythat thes ta tementsmade ia th i sdec l~~on~~e and accurate to the Ixst of my howledge information and belief
September a 2 002
DECLARATION
I Jeff Littlejohn declare as follows
3 I am Senior Vice President Engineering of Citicasters Licenses Inc (ldquoCiticastersrdquo) the licensee of WRVF(FM) Channel 268B Toledo Ohio
Citicasters intends to apply for a construction permit for Channel 268B to specamp operations for WRVF in Oak Harbor Ohio upon adoption of the Proposal as outlined herein through the relevant Notice of Proposed Rule Making
If awarded the construction permit for Channel 268B Citicasters promptly wi l l construct and operate such facilities
4
3
I hereby declare under penalty of perjury that the statements made in
this declaration are true and accurate to the best of my knowledge information and
belief
du Treil Lundin amp Rackley Inc Consulting Engineers
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Technical Narrative
This Technical Exhibit of which this Narrative is part proposes an FM Rule Making to modify the Commissions Table of Allotments contained within Section 73202 within the Commissions Rules It is proposed herein to modify the community of license of two FM stations No change in the stations reference coordinates are proposed
Summary of Rule Making Proposal
Below is a summary of the allocation changes requested in the Joint Petition for Rule Making
0 Delete Channel 247A at Oak Harbor Ohio and allot
Contingent on the adoption of the above change Channel 24A at Genoa Ohio
delete Channel 268B at Toledo Ohio and allot Channel 268B at Oak Harbor Ohio
Pursuant to Section 142O(i) of the Commissions Rules the Petition also requests modifications to the licenses of WJZE(FM) Channel 24A Oak Harbor Ohio and WRVF(FM) Channel 268B Toledo Ohio accordingly
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 2
Proposed Channel 247A Genoa Ohio
It is proposed to delete Channel 247A at Oak Harbor and allot Channel 247A to Genoa Ohio The Genoa proposal is mutually exclusive with the current Oak Harbor allotment As no change in the reference site change is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Genoa as shown in Figure 1
Below are the Channel 247A Genoa reference site geographic coordinates
41deg 29 17 North Latitude 83O 19 25 West Longitude
The existing Channel 241A reference coordinates do not satisfy the spacing requirements of Section 73207 with respect to three stations as identified in the allocation study provided in Figure 2 Each is discussed below
First under Section 73207 the proposed Channel 247A reference site is short-spaced to CHYR-FM on Channel 244C1 at Leamington Ontario Canada The required minimum separation distance is 90 kilometers the actual separation distance is 86 kilometers a short- spacing of 4 kilometers This Canadian allotment is a specially negotiated short-spaced allotment which was accepted by the Commission on September 2 1992 Petitionerrs Channel 247A is also a specially negotiated short-spaced allotment which was accepted by Canada on December 14 1992 Therefore because the proposed allotment does not involve any change in the relevant site this previously accepted spacing should satisfy the Commissions allocation requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 3
Second under Section 73207 the proposed Channel 248A reference site is short-spaced to WKRK-FM on Channel 246B at Detroit Michigan The required minimum separation distance is 113 kilometers the actual separation distance is 111 kilometers a short-spacing of 2 kilometers Petitioners Channel 247A was initially allocated as a 3 kilowatt100 meter facility and it remains as an equivalent facility Therefore for allotment purposes WKRK-FM can be protected pursuant to Section 73213(c) of the Commissions Rules which requires a minimum separation distance of 105 kilometers The proposed reference coordinates satisfies this requirement
Third under Section 73207 the proposed Channel 247A reference site is short-spaced to WMEE(FM) on Channel 247B at Fort Wayne Indiana The station was authorized to operate from the reference site (its current site) pursuant to the stations request to be processed under Section 73215 The required minimum separation distance is 178 kilometers the actual separation distance is 162 kilometers a short-spacing of 16 kilometers
However the proposed allotment does not create a new short or not exacerbate any short-spacing (under Section 73207) with regard to WMEE(FM) In addition WJZE(FM) already has been approved to operate at the reference site to the extent is affords WMEE(FM) contour protection pursuant to Section 73215 and the proposed allotment contemplates no change in WJZE(FM)s operating parameters Moreover WJZE(FM)s former (pre-Section 73215) transmitter site satisfied the relevant spacing requirement - the Section 73213(c) separation distance of 163 kilometers with regard to WMEE(FM) As shown in Figure 1 the projected city grade reference contour (70 dBu) of the allotment from this former site encompassed
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 4
the proposed community of Genoa this pre-Section 73215 site is provided in Figure 2
An allocation study from
Figure 5 is an Area-to-Locate map for Channel 247A As can be seen there is no present fully-spaced area-to-locate for this allotment
Proposed Channel 268B Oak Harbor Ohio
It is proposed to delete Channel 268B at Toledo and allot Channel 268B to Oak Harbor Ohio This Oak Harbor proposal is mutually exclusive with the current Toledo allotment As no change in the reference site is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Oak Harbor as shown in Figure 1
Below are the Channel 268B Oak Harbor reference site geographic coordinates
41O 40 23 North Latitude 83O 25 31 West Longitude
The existing Channel 268B reference coordinates do not satisfy Section 73201 requirements with respect to five stations as shown by the allocation study provided in Figure 4 Each short-spacing is discussed below
First under Section 73207 the proposed Channel 268B reference site is short-spaced to WMJK(FM) on Channel 265A at Clyde Ohio The required minimum separation distance is 69 kilometers the actual separation distance is 64 kilometers a short-spacing of 5 kilometers WMJK(FM) is a 3 kilowatt100 meter type Class A facility and therefore is processed pursuant to Section
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 5
13213 of the Rules as the short-spacing (under Section 13207) is not exacerbated
Second under Section 73207 the proposed Channel 268B reference site is short-spaced to WNCO-FM on Channel 267B at Ashland Ohio The required minimum separation distance is 169 kilometers the actual separation distance is 129 kilometers a short-spacing of 40 kilometers However because the Channel 268B allotment and WNCO-FM have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Third under Section 73207 the proposed Channel 268B reference site is short-spaced to a Canadian allotment on Channel 268A The required minimum separation distance is 210 kilometers the actual separation distance is 167 kilometers a short-spacing of 43 kilometers This Canadian allotment is a specially negotiated short-spaced allotment Therefore because the proposed allotment does not involve a change in the relevant site this previously accepted spacing should satisfy the Commissionrsquos allocation requiremements
Fourth under Section 73207 the proposed Channel 268B reference site is short-spaced to the current licensed and authorized facility of WWBN(FM) on Channel 268A at Tuscola Michigan because WWBN(FM) is authorized pursuant to Section 73215 with regard to WRVF(FM) Therefore as WRVF(FM) did not initiate this short- spacing and the proposed re-allotment involves no change in the WRVF(FM)rsquos current transmitter site the proposed spacing satisfies the Commissionrsquos allotment requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 6
Fifth under Section 73207 the proposed Channel 268B reference site is short-spaced to WNSN(FM) on Channel 268B at South Bend Indiana The required minimum separation distance is 14 kilometers the actual separation distance is 68 kilometers a short-spacing of 6 kilometers However because the Channel 268B allotment and WNSN(FM) have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Proposed Modifications to Table of Allotments
This proposal provides for the following allotment changes to Section 73202 The Commissionrsquos Table of FM Allotments
Lowell Oil Center (historical) hobth Amsden Maple Grove
Watson lie Mount Gilead
10 0 10 20 30 40 miles
H H H H t I I I I I I
H H H H I I I I I I I I 10 0 10 20 30 40 50 kilometers
CITY GRADE REFERENCE CONTOURS
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 2
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 241A Genoa Ohio Allocation Study Proposed Reference Site
41deg 29rsquo 17rdquo North Latitude 8 3 O 19rsquo 25ldquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(rn) Longitude deg-True (km) (hi) WBVI FOSTORIA BLH 244A 30 41-06-00 1964 4494 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR- F LEAMINGTON 244C1 910 42-00-35 472 8582 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
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Yahoo Yellow Pages Genoa OH
Top gt Food andDiMn4 gt Restaurants gtAl l Restaurants
All Businesses Business Name Ernestos Restaurant (419) 855-9063
Create My Favorite Locations -Sign In
Change Location - Save This Location
I Showing 1-9 of 9 1 Beyond Genoa
Address 20825 State Route 51 W GenoaOH Map
Mrdees (419) 855-3092
6164 County Road 165 GenoaOH Map
~ ~
Hardees (419) 855-3991
6410 County Road 165 GenoaOH Map
Mc Donalds (419) 855-8116 GenoaOH Map
Ray 8 Jets Genoa Country Cafe (4191 855-8496 GenoaOH Map
22201 State Route 51 W
608 Main St
Subway Sandwiches amp Salads (419) 855-3844
22049 State Route 51 W GenoaOH Mae
TTOjlpCafe 638 Main St (419) 855-4325 GenoaOH Map
Taco Bell (419) 855-9916 GenoaOH Map
22210 W State Route 51
Zsuzskas 21950 W State Route 51 GenoaOH Map (419) 855-2021
1 1 am Vice President of RASP Broadcast Enterprises bc (lsquoaASPrdquo) the license of WJZB(FM) C h e l 2 4 7 A Oak Harbor Obio
RASP intends to apply for a construction permit for Channel 247A to specify oper Itions for WJZE in Genoa Ohio upon adoption ofthe Proposal as outljned h e n through the relevant Notice of Pmposed Rule Making
If am ardd the construction permit for Channel 247A RASP promptlywill construct and ITamp such facilities
2
3
Iherebydec are underpenallyofperjurythat thes ta tementsmade ia th i sdec l~~on~~e and accurate to the Ixst of my howledge information and belief
September a 2 002
DECLARATION
I Jeff Littlejohn declare as follows
3 I am Senior Vice President Engineering of Citicasters Licenses Inc (ldquoCiticastersrdquo) the licensee of WRVF(FM) Channel 268B Toledo Ohio
Citicasters intends to apply for a construction permit for Channel 268B to specamp operations for WRVF in Oak Harbor Ohio upon adoption of the Proposal as outlined herein through the relevant Notice of Proposed Rule Making
If awarded the construction permit for Channel 268B Citicasters promptly wi l l construct and operate such facilities
4
3
I hereby declare under penalty of perjury that the statements made in
this declaration are true and accurate to the best of my knowledge information and
belief
du Treil Lundin amp Rackley Inc Consulting Engineers
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Technical Narrative
This Technical Exhibit of which this Narrative is part proposes an FM Rule Making to modify the Commissions Table of Allotments contained within Section 73202 within the Commissions Rules It is proposed herein to modify the community of license of two FM stations No change in the stations reference coordinates are proposed
Summary of Rule Making Proposal
Below is a summary of the allocation changes requested in the Joint Petition for Rule Making
0 Delete Channel 247A at Oak Harbor Ohio and allot
Contingent on the adoption of the above change Channel 24A at Genoa Ohio
delete Channel 268B at Toledo Ohio and allot Channel 268B at Oak Harbor Ohio
Pursuant to Section 142O(i) of the Commissions Rules the Petition also requests modifications to the licenses of WJZE(FM) Channel 24A Oak Harbor Ohio and WRVF(FM) Channel 268B Toledo Ohio accordingly
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 2
Proposed Channel 247A Genoa Ohio
It is proposed to delete Channel 247A at Oak Harbor and allot Channel 247A to Genoa Ohio The Genoa proposal is mutually exclusive with the current Oak Harbor allotment As no change in the reference site change is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Genoa as shown in Figure 1
Below are the Channel 247A Genoa reference site geographic coordinates
41deg 29 17 North Latitude 83O 19 25 West Longitude
The existing Channel 241A reference coordinates do not satisfy the spacing requirements of Section 73207 with respect to three stations as identified in the allocation study provided in Figure 2 Each is discussed below
First under Section 73207 the proposed Channel 247A reference site is short-spaced to CHYR-FM on Channel 244C1 at Leamington Ontario Canada The required minimum separation distance is 90 kilometers the actual separation distance is 86 kilometers a short- spacing of 4 kilometers This Canadian allotment is a specially negotiated short-spaced allotment which was accepted by the Commission on September 2 1992 Petitionerrs Channel 247A is also a specially negotiated short-spaced allotment which was accepted by Canada on December 14 1992 Therefore because the proposed allotment does not involve any change in the relevant site this previously accepted spacing should satisfy the Commissions allocation requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 3
Second under Section 73207 the proposed Channel 248A reference site is short-spaced to WKRK-FM on Channel 246B at Detroit Michigan The required minimum separation distance is 113 kilometers the actual separation distance is 111 kilometers a short-spacing of 2 kilometers Petitioners Channel 247A was initially allocated as a 3 kilowatt100 meter facility and it remains as an equivalent facility Therefore for allotment purposes WKRK-FM can be protected pursuant to Section 73213(c) of the Commissions Rules which requires a minimum separation distance of 105 kilometers The proposed reference coordinates satisfies this requirement
Third under Section 73207 the proposed Channel 247A reference site is short-spaced to WMEE(FM) on Channel 247B at Fort Wayne Indiana The station was authorized to operate from the reference site (its current site) pursuant to the stations request to be processed under Section 73215 The required minimum separation distance is 178 kilometers the actual separation distance is 162 kilometers a short-spacing of 16 kilometers
However the proposed allotment does not create a new short or not exacerbate any short-spacing (under Section 73207) with regard to WMEE(FM) In addition WJZE(FM) already has been approved to operate at the reference site to the extent is affords WMEE(FM) contour protection pursuant to Section 73215 and the proposed allotment contemplates no change in WJZE(FM)s operating parameters Moreover WJZE(FM)s former (pre-Section 73215) transmitter site satisfied the relevant spacing requirement - the Section 73213(c) separation distance of 163 kilometers with regard to WMEE(FM) As shown in Figure 1 the projected city grade reference contour (70 dBu) of the allotment from this former site encompassed
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 4
the proposed community of Genoa this pre-Section 73215 site is provided in Figure 2
An allocation study from
Figure 5 is an Area-to-Locate map for Channel 247A As can be seen there is no present fully-spaced area-to-locate for this allotment
Proposed Channel 268B Oak Harbor Ohio
It is proposed to delete Channel 268B at Toledo and allot Channel 268B to Oak Harbor Ohio This Oak Harbor proposal is mutually exclusive with the current Toledo allotment As no change in the reference site is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Oak Harbor as shown in Figure 1
Below are the Channel 268B Oak Harbor reference site geographic coordinates
41O 40 23 North Latitude 83O 25 31 West Longitude
The existing Channel 268B reference coordinates do not satisfy Section 73201 requirements with respect to five stations as shown by the allocation study provided in Figure 4 Each short-spacing is discussed below
First under Section 73207 the proposed Channel 268B reference site is short-spaced to WMJK(FM) on Channel 265A at Clyde Ohio The required minimum separation distance is 69 kilometers the actual separation distance is 64 kilometers a short-spacing of 5 kilometers WMJK(FM) is a 3 kilowatt100 meter type Class A facility and therefore is processed pursuant to Section
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 5
13213 of the Rules as the short-spacing (under Section 13207) is not exacerbated
Second under Section 73207 the proposed Channel 268B reference site is short-spaced to WNCO-FM on Channel 267B at Ashland Ohio The required minimum separation distance is 169 kilometers the actual separation distance is 129 kilometers a short-spacing of 40 kilometers However because the Channel 268B allotment and WNCO-FM have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Third under Section 73207 the proposed Channel 268B reference site is short-spaced to a Canadian allotment on Channel 268A The required minimum separation distance is 210 kilometers the actual separation distance is 167 kilometers a short-spacing of 43 kilometers This Canadian allotment is a specially negotiated short-spaced allotment Therefore because the proposed allotment does not involve a change in the relevant site this previously accepted spacing should satisfy the Commissionrsquos allocation requiremements
Fourth under Section 73207 the proposed Channel 268B reference site is short-spaced to the current licensed and authorized facility of WWBN(FM) on Channel 268A at Tuscola Michigan because WWBN(FM) is authorized pursuant to Section 73215 with regard to WRVF(FM) Therefore as WRVF(FM) did not initiate this short- spacing and the proposed re-allotment involves no change in the WRVF(FM)rsquos current transmitter site the proposed spacing satisfies the Commissionrsquos allotment requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 6
Fifth under Section 73207 the proposed Channel 268B reference site is short-spaced to WNSN(FM) on Channel 268B at South Bend Indiana The required minimum separation distance is 14 kilometers the actual separation distance is 68 kilometers a short-spacing of 6 kilometers However because the Channel 268B allotment and WNSN(FM) have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Proposed Modifications to Table of Allotments
This proposal provides for the following allotment changes to Section 73202 The Commissionrsquos Table of FM Allotments
Lowell Oil Center (historical) hobth Amsden Maple Grove
Watson lie Mount Gilead
10 0 10 20 30 40 miles
H H H H t I I I I I I
H H H H I I I I I I I I 10 0 10 20 30 40 50 kilometers
CITY GRADE REFERENCE CONTOURS
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 2
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 241A Genoa Ohio Allocation Study Proposed Reference Site
41deg 29rsquo 17rdquo North Latitude 8 3 O 19rsquo 25ldquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(rn) Longitude deg-True (km) (hi) WBVI FOSTORIA BLH 244A 30 41-06-00 1964 4494 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR- F LEAMINGTON 244C1 910 42-00-35 472 8582 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Yahoo Yellow Pages Page 1 of 2
-Jellow Pages Home - Yahoo1 - Maps -Address Book - HelF
Welcome Guest User
Yahoo Yellow Pages Genoa OH
Top gt Healthand M m n e gt Doctors a_nd Clinics gt All
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I All Businesses Showing 1-10 of 10 1 Beyond Genoa
Business Name Address Family Services Of Ottawa Cnty (419) 855-7704 GenoaOH MZQ
GenoaampmCamp 300 Cherry St (419) 855-7755 GenoaOH Map
22055 State Route 51 W
Genoa Medical Ctr (419) 855-7772 GenoaOH Map
HaNey ROY MD - Harvey ROY MD (419) 855-8168 Phvsicianlnfo GenoaOH Map
22614 W State Route 51
106 E 8th St
Hutton Kim - P T Svc Inc (419) 855-8301 GenoaOH Map
Keith A Norwalk Inc (419) 855-4700 GenoaOH Mae
1515 Main St
103 W 5th St
Lauh Dennis R OD - Laub Dennis ROD (419) 8553640 GenoaOH Map
Norwalk Keith A DDS -Keith A Norwalk Inc 14191 855-4700 GenoaOH Map
626 Main St
103 W 5th St
Packer Creek Independent Livng (419) 855-4238
300 Cherry St GenoaOH Map
~~
Rich Mark E DC - Rich Chiropractic Ctr (419) 855-7776
1 1 am Vice President of RASP Broadcast Enterprises bc (lsquoaASPrdquo) the license of WJZB(FM) C h e l 2 4 7 A Oak Harbor Obio
RASP intends to apply for a construction permit for Channel 247A to specify oper Itions for WJZE in Genoa Ohio upon adoption ofthe Proposal as outljned h e n through the relevant Notice of Pmposed Rule Making
If am ardd the construction permit for Channel 247A RASP promptlywill construct and ITamp such facilities
2
3
Iherebydec are underpenallyofperjurythat thes ta tementsmade ia th i sdec l~~on~~e and accurate to the Ixst of my howledge information and belief
September a 2 002
DECLARATION
I Jeff Littlejohn declare as follows
3 I am Senior Vice President Engineering of Citicasters Licenses Inc (ldquoCiticastersrdquo) the licensee of WRVF(FM) Channel 268B Toledo Ohio
Citicasters intends to apply for a construction permit for Channel 268B to specamp operations for WRVF in Oak Harbor Ohio upon adoption of the Proposal as outlined herein through the relevant Notice of Proposed Rule Making
If awarded the construction permit for Channel 268B Citicasters promptly wi l l construct and operate such facilities
4
3
I hereby declare under penalty of perjury that the statements made in
this declaration are true and accurate to the best of my knowledge information and
belief
du Treil Lundin amp Rackley Inc Consulting Engineers
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Technical Narrative
This Technical Exhibit of which this Narrative is part proposes an FM Rule Making to modify the Commissions Table of Allotments contained within Section 73202 within the Commissions Rules It is proposed herein to modify the community of license of two FM stations No change in the stations reference coordinates are proposed
Summary of Rule Making Proposal
Below is a summary of the allocation changes requested in the Joint Petition for Rule Making
0 Delete Channel 247A at Oak Harbor Ohio and allot
Contingent on the adoption of the above change Channel 24A at Genoa Ohio
delete Channel 268B at Toledo Ohio and allot Channel 268B at Oak Harbor Ohio
Pursuant to Section 142O(i) of the Commissions Rules the Petition also requests modifications to the licenses of WJZE(FM) Channel 24A Oak Harbor Ohio and WRVF(FM) Channel 268B Toledo Ohio accordingly
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 2
Proposed Channel 247A Genoa Ohio
It is proposed to delete Channel 247A at Oak Harbor and allot Channel 247A to Genoa Ohio The Genoa proposal is mutually exclusive with the current Oak Harbor allotment As no change in the reference site change is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Genoa as shown in Figure 1
Below are the Channel 247A Genoa reference site geographic coordinates
41deg 29 17 North Latitude 83O 19 25 West Longitude
The existing Channel 241A reference coordinates do not satisfy the spacing requirements of Section 73207 with respect to three stations as identified in the allocation study provided in Figure 2 Each is discussed below
First under Section 73207 the proposed Channel 247A reference site is short-spaced to CHYR-FM on Channel 244C1 at Leamington Ontario Canada The required minimum separation distance is 90 kilometers the actual separation distance is 86 kilometers a short- spacing of 4 kilometers This Canadian allotment is a specially negotiated short-spaced allotment which was accepted by the Commission on September 2 1992 Petitionerrs Channel 247A is also a specially negotiated short-spaced allotment which was accepted by Canada on December 14 1992 Therefore because the proposed allotment does not involve any change in the relevant site this previously accepted spacing should satisfy the Commissions allocation requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 3
Second under Section 73207 the proposed Channel 248A reference site is short-spaced to WKRK-FM on Channel 246B at Detroit Michigan The required minimum separation distance is 113 kilometers the actual separation distance is 111 kilometers a short-spacing of 2 kilometers Petitioners Channel 247A was initially allocated as a 3 kilowatt100 meter facility and it remains as an equivalent facility Therefore for allotment purposes WKRK-FM can be protected pursuant to Section 73213(c) of the Commissions Rules which requires a minimum separation distance of 105 kilometers The proposed reference coordinates satisfies this requirement
Third under Section 73207 the proposed Channel 247A reference site is short-spaced to WMEE(FM) on Channel 247B at Fort Wayne Indiana The station was authorized to operate from the reference site (its current site) pursuant to the stations request to be processed under Section 73215 The required minimum separation distance is 178 kilometers the actual separation distance is 162 kilometers a short-spacing of 16 kilometers
However the proposed allotment does not create a new short or not exacerbate any short-spacing (under Section 73207) with regard to WMEE(FM) In addition WJZE(FM) already has been approved to operate at the reference site to the extent is affords WMEE(FM) contour protection pursuant to Section 73215 and the proposed allotment contemplates no change in WJZE(FM)s operating parameters Moreover WJZE(FM)s former (pre-Section 73215) transmitter site satisfied the relevant spacing requirement - the Section 73213(c) separation distance of 163 kilometers with regard to WMEE(FM) As shown in Figure 1 the projected city grade reference contour (70 dBu) of the allotment from this former site encompassed
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 4
the proposed community of Genoa this pre-Section 73215 site is provided in Figure 2
An allocation study from
Figure 5 is an Area-to-Locate map for Channel 247A As can be seen there is no present fully-spaced area-to-locate for this allotment
Proposed Channel 268B Oak Harbor Ohio
It is proposed to delete Channel 268B at Toledo and allot Channel 268B to Oak Harbor Ohio This Oak Harbor proposal is mutually exclusive with the current Toledo allotment As no change in the reference site is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Oak Harbor as shown in Figure 1
Below are the Channel 268B Oak Harbor reference site geographic coordinates
41O 40 23 North Latitude 83O 25 31 West Longitude
The existing Channel 268B reference coordinates do not satisfy Section 73201 requirements with respect to five stations as shown by the allocation study provided in Figure 4 Each short-spacing is discussed below
First under Section 73207 the proposed Channel 268B reference site is short-spaced to WMJK(FM) on Channel 265A at Clyde Ohio The required minimum separation distance is 69 kilometers the actual separation distance is 64 kilometers a short-spacing of 5 kilometers WMJK(FM) is a 3 kilowatt100 meter type Class A facility and therefore is processed pursuant to Section
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 5
13213 of the Rules as the short-spacing (under Section 13207) is not exacerbated
Second under Section 73207 the proposed Channel 268B reference site is short-spaced to WNCO-FM on Channel 267B at Ashland Ohio The required minimum separation distance is 169 kilometers the actual separation distance is 129 kilometers a short-spacing of 40 kilometers However because the Channel 268B allotment and WNCO-FM have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Third under Section 73207 the proposed Channel 268B reference site is short-spaced to a Canadian allotment on Channel 268A The required minimum separation distance is 210 kilometers the actual separation distance is 167 kilometers a short-spacing of 43 kilometers This Canadian allotment is a specially negotiated short-spaced allotment Therefore because the proposed allotment does not involve a change in the relevant site this previously accepted spacing should satisfy the Commissionrsquos allocation requiremements
Fourth under Section 73207 the proposed Channel 268B reference site is short-spaced to the current licensed and authorized facility of WWBN(FM) on Channel 268A at Tuscola Michigan because WWBN(FM) is authorized pursuant to Section 73215 with regard to WRVF(FM) Therefore as WRVF(FM) did not initiate this short- spacing and the proposed re-allotment involves no change in the WRVF(FM)rsquos current transmitter site the proposed spacing satisfies the Commissionrsquos allotment requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 6
Fifth under Section 73207 the proposed Channel 268B reference site is short-spaced to WNSN(FM) on Channel 268B at South Bend Indiana The required minimum separation distance is 14 kilometers the actual separation distance is 68 kilometers a short-spacing of 6 kilometers However because the Channel 268B allotment and WNSN(FM) have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Proposed Modifications to Table of Allotments
This proposal provides for the following allotment changes to Section 73202 The Commissionrsquos Table of FM Allotments
Lowell Oil Center (historical) hobth Amsden Maple Grove
Watson lie Mount Gilead
10 0 10 20 30 40 miles
H H H H t I I I I I I
H H H H I I I I I I I I 10 0 10 20 30 40 50 kilometers
CITY GRADE REFERENCE CONTOURS
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 2
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 241A Genoa Ohio Allocation Study Proposed Reference Site
41deg 29rsquo 17rdquo North Latitude 8 3 O 19rsquo 25ldquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(rn) Longitude deg-True (km) (hi) WBVI FOSTORIA BLH 244A 30 41-06-00 1964 4494 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR- F LEAMINGTON 244C1 910 42-00-35 472 8582 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Yahoo Yellow Pages Page 1 of 2
-Ye If o w Pages Home - Yahoo1 - Maps -Address Book - HelL
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Yahoo Yellow Pages Genoa OH
lop gt Legala_nQinancial7 Banks
Washington Mutual
Create My Favorite Locations - Sign In
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I
BankofAmerica
-0- Local ListinAs Local Listinas
All Businesses Business Name Address Genoa Bank 801 Main St (419) 855-8381 GenoaOH Map
Sky Bank 1509 Main St (419) 855-8346 GenoaOH Map
Showing 1-2 of 2 I Beyond Genoa
Showing 1-2 of 2 I Beyond Genoa
Beyond Genoa
City State or Zip IGenoa OH
Country United States 3
httpypyahoocomlpyypResultspyampampcity=Genoaampstate=OHampcount~=usamps~t=4 15 1 X I 5292002 ~ --- ------ -
Yahoo Yellow Pages
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Page 1 of 1
Genoa OH __
United States 3
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Yahoo Yellow Pages Genoa OH Change Location -Save This Location
Tog gt ANtomatire gt Repair and Service gt Auto
Showing 1-2 of 2 1 Beyond Genoa All Businesses Business Name Genoa Motors Inc (419) 855-8366
Address 221 10 State Route 51 W Genoa OH ampE
~-
Patamp Son Towing (419) 693-2222 GenoaOH Map
1524 Genoa Rd
Showing 1-2 of 2 Bevond Genoa
Beyond Genoa
Modify your search
( Address intersection or Airport Code ) I
Business Information provided by InfoUSAcom Foster Cily California Copyright 0 2002 All Rights Resewed Use Subject lo License
Copyright 0 2002 Yahoo Inc All rights resewed Help - Privacy Policy -Terms of Service
httplypyahoocomlpy~ypResultspyampampci~=Geno~state=OHampco~t~=usamps~t=4 15 18 I 5292002 ----- --
Yahoo Yellow Pages Page 1 of 1
-Yetlow Pages Home - Yahoo1 - Maps -Address Book - HelF
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Yahoo Yellow Pages Genoa OH
TQP gt Communiamp gt Post Offices
All Businesses Business Name US Post Office (800) 2754777
Create My Favorite Locations - Sign In
Change Location - SaveThis Location
I Showing 1-1 of I I Beyond Genoa
Address 606 Washington St GenoaOH LaQ
Showing 1-1 of 1 I Beyond Genoa
Beyond Genoa
Modify your search
Search by Name or Category I -
Business infonation provided by InfoUSAcom Foster City California Copyright 0 2002 All Rights Reserved Use Subject to License
CopyrightQ 2002 Yahoo Inc Ail rights reserved Help -Privacy Policy - Terms of Service
1 1 am Vice President of RASP Broadcast Enterprises bc (lsquoaASPrdquo) the license of WJZB(FM) C h e l 2 4 7 A Oak Harbor Obio
RASP intends to apply for a construction permit for Channel 247A to specify oper Itions for WJZE in Genoa Ohio upon adoption ofthe Proposal as outljned h e n through the relevant Notice of Pmposed Rule Making
If am ardd the construction permit for Channel 247A RASP promptlywill construct and ITamp such facilities
2
3
Iherebydec are underpenallyofperjurythat thes ta tementsmade ia th i sdec l~~on~~e and accurate to the Ixst of my howledge information and belief
September a 2 002
DECLARATION
I Jeff Littlejohn declare as follows
3 I am Senior Vice President Engineering of Citicasters Licenses Inc (ldquoCiticastersrdquo) the licensee of WRVF(FM) Channel 268B Toledo Ohio
Citicasters intends to apply for a construction permit for Channel 268B to specamp operations for WRVF in Oak Harbor Ohio upon adoption of the Proposal as outlined herein through the relevant Notice of Proposed Rule Making
If awarded the construction permit for Channel 268B Citicasters promptly wi l l construct and operate such facilities
4
3
I hereby declare under penalty of perjury that the statements made in
this declaration are true and accurate to the best of my knowledge information and
belief
du Treil Lundin amp Rackley Inc Consulting Engineers
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Technical Narrative
This Technical Exhibit of which this Narrative is part proposes an FM Rule Making to modify the Commissions Table of Allotments contained within Section 73202 within the Commissions Rules It is proposed herein to modify the community of license of two FM stations No change in the stations reference coordinates are proposed
Summary of Rule Making Proposal
Below is a summary of the allocation changes requested in the Joint Petition for Rule Making
0 Delete Channel 247A at Oak Harbor Ohio and allot
Contingent on the adoption of the above change Channel 24A at Genoa Ohio
delete Channel 268B at Toledo Ohio and allot Channel 268B at Oak Harbor Ohio
Pursuant to Section 142O(i) of the Commissions Rules the Petition also requests modifications to the licenses of WJZE(FM) Channel 24A Oak Harbor Ohio and WRVF(FM) Channel 268B Toledo Ohio accordingly
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 2
Proposed Channel 247A Genoa Ohio
It is proposed to delete Channel 247A at Oak Harbor and allot Channel 247A to Genoa Ohio The Genoa proposal is mutually exclusive with the current Oak Harbor allotment As no change in the reference site change is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Genoa as shown in Figure 1
Below are the Channel 247A Genoa reference site geographic coordinates
41deg 29 17 North Latitude 83O 19 25 West Longitude
The existing Channel 241A reference coordinates do not satisfy the spacing requirements of Section 73207 with respect to three stations as identified in the allocation study provided in Figure 2 Each is discussed below
First under Section 73207 the proposed Channel 247A reference site is short-spaced to CHYR-FM on Channel 244C1 at Leamington Ontario Canada The required minimum separation distance is 90 kilometers the actual separation distance is 86 kilometers a short- spacing of 4 kilometers This Canadian allotment is a specially negotiated short-spaced allotment which was accepted by the Commission on September 2 1992 Petitionerrs Channel 247A is also a specially negotiated short-spaced allotment which was accepted by Canada on December 14 1992 Therefore because the proposed allotment does not involve any change in the relevant site this previously accepted spacing should satisfy the Commissions allocation requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 3
Second under Section 73207 the proposed Channel 248A reference site is short-spaced to WKRK-FM on Channel 246B at Detroit Michigan The required minimum separation distance is 113 kilometers the actual separation distance is 111 kilometers a short-spacing of 2 kilometers Petitioners Channel 247A was initially allocated as a 3 kilowatt100 meter facility and it remains as an equivalent facility Therefore for allotment purposes WKRK-FM can be protected pursuant to Section 73213(c) of the Commissions Rules which requires a minimum separation distance of 105 kilometers The proposed reference coordinates satisfies this requirement
Third under Section 73207 the proposed Channel 247A reference site is short-spaced to WMEE(FM) on Channel 247B at Fort Wayne Indiana The station was authorized to operate from the reference site (its current site) pursuant to the stations request to be processed under Section 73215 The required minimum separation distance is 178 kilometers the actual separation distance is 162 kilometers a short-spacing of 16 kilometers
However the proposed allotment does not create a new short or not exacerbate any short-spacing (under Section 73207) with regard to WMEE(FM) In addition WJZE(FM) already has been approved to operate at the reference site to the extent is affords WMEE(FM) contour protection pursuant to Section 73215 and the proposed allotment contemplates no change in WJZE(FM)s operating parameters Moreover WJZE(FM)s former (pre-Section 73215) transmitter site satisfied the relevant spacing requirement - the Section 73213(c) separation distance of 163 kilometers with regard to WMEE(FM) As shown in Figure 1 the projected city grade reference contour (70 dBu) of the allotment from this former site encompassed
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 4
the proposed community of Genoa this pre-Section 73215 site is provided in Figure 2
An allocation study from
Figure 5 is an Area-to-Locate map for Channel 247A As can be seen there is no present fully-spaced area-to-locate for this allotment
Proposed Channel 268B Oak Harbor Ohio
It is proposed to delete Channel 268B at Toledo and allot Channel 268B to Oak Harbor Ohio This Oak Harbor proposal is mutually exclusive with the current Toledo allotment As no change in the reference site is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Oak Harbor as shown in Figure 1
Below are the Channel 268B Oak Harbor reference site geographic coordinates
41O 40 23 North Latitude 83O 25 31 West Longitude
The existing Channel 268B reference coordinates do not satisfy Section 73201 requirements with respect to five stations as shown by the allocation study provided in Figure 4 Each short-spacing is discussed below
First under Section 73207 the proposed Channel 268B reference site is short-spaced to WMJK(FM) on Channel 265A at Clyde Ohio The required minimum separation distance is 69 kilometers the actual separation distance is 64 kilometers a short-spacing of 5 kilometers WMJK(FM) is a 3 kilowatt100 meter type Class A facility and therefore is processed pursuant to Section
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 5
13213 of the Rules as the short-spacing (under Section 13207) is not exacerbated
Second under Section 73207 the proposed Channel 268B reference site is short-spaced to WNCO-FM on Channel 267B at Ashland Ohio The required minimum separation distance is 169 kilometers the actual separation distance is 129 kilometers a short-spacing of 40 kilometers However because the Channel 268B allotment and WNCO-FM have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Third under Section 73207 the proposed Channel 268B reference site is short-spaced to a Canadian allotment on Channel 268A The required minimum separation distance is 210 kilometers the actual separation distance is 167 kilometers a short-spacing of 43 kilometers This Canadian allotment is a specially negotiated short-spaced allotment Therefore because the proposed allotment does not involve a change in the relevant site this previously accepted spacing should satisfy the Commissionrsquos allocation requiremements
Fourth under Section 73207 the proposed Channel 268B reference site is short-spaced to the current licensed and authorized facility of WWBN(FM) on Channel 268A at Tuscola Michigan because WWBN(FM) is authorized pursuant to Section 73215 with regard to WRVF(FM) Therefore as WRVF(FM) did not initiate this short- spacing and the proposed re-allotment involves no change in the WRVF(FM)rsquos current transmitter site the proposed spacing satisfies the Commissionrsquos allotment requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 6
Fifth under Section 73207 the proposed Channel 268B reference site is short-spaced to WNSN(FM) on Channel 268B at South Bend Indiana The required minimum separation distance is 14 kilometers the actual separation distance is 68 kilometers a short-spacing of 6 kilometers However because the Channel 268B allotment and WNSN(FM) have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Proposed Modifications to Table of Allotments
This proposal provides for the following allotment changes to Section 73202 The Commissionrsquos Table of FM Allotments
Lowell Oil Center (historical) hobth Amsden Maple Grove
Watson lie Mount Gilead
10 0 10 20 30 40 miles
H H H H t I I I I I I
H H H H I I I I I I I I 10 0 10 20 30 40 50 kilometers
CITY GRADE REFERENCE CONTOURS
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 2
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 241A Genoa Ohio Allocation Study Proposed Reference Site
41deg 29rsquo 17rdquo North Latitude 8 3 O 19rsquo 25ldquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(rn) Longitude deg-True (km) (hi) WBVI FOSTORIA BLH 244A 30 41-06-00 1964 4494 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR- F LEAMINGTON 244C1 910 42-00-35 472 8582 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Yahoo Yellow Pages
City State or Zip
Country
Page 1 of 1
Genoa OH __
United States 3
=YeIIow Pages Home -Yahoo - Maps -Address Book - HeiF
Welcome Guest User Create My Favorite Locations -Sign In
Yahoo Yellow Pages Genoa OH Change Location -Save This Location
Tog gt ANtomatire gt Repair and Service gt Auto
Showing 1-2 of 2 1 Beyond Genoa All Businesses Business Name Genoa Motors Inc (419) 855-8366
Address 221 10 State Route 51 W Genoa OH ampE
~-
Patamp Son Towing (419) 693-2222 GenoaOH Map
1524 Genoa Rd
Showing 1-2 of 2 Bevond Genoa
Beyond Genoa
Modify your search
( Address intersection or Airport Code ) I
Business Information provided by InfoUSAcom Foster Cily California Copyright 0 2002 All Rights Resewed Use Subject lo License
Copyright 0 2002 Yahoo Inc All rights resewed Help - Privacy Policy -Terms of Service
httplypyahoocomlpy~ypResultspyampampci~=Geno~state=OHampco~t~=usamps~t=4 15 18 I 5292002 ----- --
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TQP gt Communiamp gt Post Offices
All Businesses Business Name US Post Office (800) 2754777
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I Showing 1-1 of I I Beyond Genoa
Address 606 Washington St GenoaOH LaQ
Showing 1-1 of 1 I Beyond Genoa
Beyond Genoa
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Search by Name or Category I -
Business infonation provided by InfoUSAcom Foster City California Copyright 0 2002 All Rights Reserved Use Subject to License
CopyrightQ 2002 Yahoo Inc Ail rights reserved Help -Privacy Policy - Terms of Service
1 1 am Vice President of RASP Broadcast Enterprises bc (lsquoaASPrdquo) the license of WJZB(FM) C h e l 2 4 7 A Oak Harbor Obio
RASP intends to apply for a construction permit for Channel 247A to specify oper Itions for WJZE in Genoa Ohio upon adoption ofthe Proposal as outljned h e n through the relevant Notice of Pmposed Rule Making
If am ardd the construction permit for Channel 247A RASP promptlywill construct and ITamp such facilities
2
3
Iherebydec are underpenallyofperjurythat thes ta tementsmade ia th i sdec l~~on~~e and accurate to the Ixst of my howledge information and belief
September a 2 002
DECLARATION
I Jeff Littlejohn declare as follows
3 I am Senior Vice President Engineering of Citicasters Licenses Inc (ldquoCiticastersrdquo) the licensee of WRVF(FM) Channel 268B Toledo Ohio
Citicasters intends to apply for a construction permit for Channel 268B to specamp operations for WRVF in Oak Harbor Ohio upon adoption of the Proposal as outlined herein through the relevant Notice of Proposed Rule Making
If awarded the construction permit for Channel 268B Citicasters promptly wi l l construct and operate such facilities
4
3
I hereby declare under penalty of perjury that the statements made in
this declaration are true and accurate to the best of my knowledge information and
belief
du Treil Lundin amp Rackley Inc Consulting Engineers
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Technical Narrative
This Technical Exhibit of which this Narrative is part proposes an FM Rule Making to modify the Commissions Table of Allotments contained within Section 73202 within the Commissions Rules It is proposed herein to modify the community of license of two FM stations No change in the stations reference coordinates are proposed
Summary of Rule Making Proposal
Below is a summary of the allocation changes requested in the Joint Petition for Rule Making
0 Delete Channel 247A at Oak Harbor Ohio and allot
Contingent on the adoption of the above change Channel 24A at Genoa Ohio
delete Channel 268B at Toledo Ohio and allot Channel 268B at Oak Harbor Ohio
Pursuant to Section 142O(i) of the Commissions Rules the Petition also requests modifications to the licenses of WJZE(FM) Channel 24A Oak Harbor Ohio and WRVF(FM) Channel 268B Toledo Ohio accordingly
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 2
Proposed Channel 247A Genoa Ohio
It is proposed to delete Channel 247A at Oak Harbor and allot Channel 247A to Genoa Ohio The Genoa proposal is mutually exclusive with the current Oak Harbor allotment As no change in the reference site change is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Genoa as shown in Figure 1
Below are the Channel 247A Genoa reference site geographic coordinates
41deg 29 17 North Latitude 83O 19 25 West Longitude
The existing Channel 241A reference coordinates do not satisfy the spacing requirements of Section 73207 with respect to three stations as identified in the allocation study provided in Figure 2 Each is discussed below
First under Section 73207 the proposed Channel 247A reference site is short-spaced to CHYR-FM on Channel 244C1 at Leamington Ontario Canada The required minimum separation distance is 90 kilometers the actual separation distance is 86 kilometers a short- spacing of 4 kilometers This Canadian allotment is a specially negotiated short-spaced allotment which was accepted by the Commission on September 2 1992 Petitionerrs Channel 247A is also a specially negotiated short-spaced allotment which was accepted by Canada on December 14 1992 Therefore because the proposed allotment does not involve any change in the relevant site this previously accepted spacing should satisfy the Commissions allocation requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 3
Second under Section 73207 the proposed Channel 248A reference site is short-spaced to WKRK-FM on Channel 246B at Detroit Michigan The required minimum separation distance is 113 kilometers the actual separation distance is 111 kilometers a short-spacing of 2 kilometers Petitioners Channel 247A was initially allocated as a 3 kilowatt100 meter facility and it remains as an equivalent facility Therefore for allotment purposes WKRK-FM can be protected pursuant to Section 73213(c) of the Commissions Rules which requires a minimum separation distance of 105 kilometers The proposed reference coordinates satisfies this requirement
Third under Section 73207 the proposed Channel 247A reference site is short-spaced to WMEE(FM) on Channel 247B at Fort Wayne Indiana The station was authorized to operate from the reference site (its current site) pursuant to the stations request to be processed under Section 73215 The required minimum separation distance is 178 kilometers the actual separation distance is 162 kilometers a short-spacing of 16 kilometers
However the proposed allotment does not create a new short or not exacerbate any short-spacing (under Section 73207) with regard to WMEE(FM) In addition WJZE(FM) already has been approved to operate at the reference site to the extent is affords WMEE(FM) contour protection pursuant to Section 73215 and the proposed allotment contemplates no change in WJZE(FM)s operating parameters Moreover WJZE(FM)s former (pre-Section 73215) transmitter site satisfied the relevant spacing requirement - the Section 73213(c) separation distance of 163 kilometers with regard to WMEE(FM) As shown in Figure 1 the projected city grade reference contour (70 dBu) of the allotment from this former site encompassed
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 4
the proposed community of Genoa this pre-Section 73215 site is provided in Figure 2
An allocation study from
Figure 5 is an Area-to-Locate map for Channel 247A As can be seen there is no present fully-spaced area-to-locate for this allotment
Proposed Channel 268B Oak Harbor Ohio
It is proposed to delete Channel 268B at Toledo and allot Channel 268B to Oak Harbor Ohio This Oak Harbor proposal is mutually exclusive with the current Toledo allotment As no change in the reference site is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Oak Harbor as shown in Figure 1
Below are the Channel 268B Oak Harbor reference site geographic coordinates
41O 40 23 North Latitude 83O 25 31 West Longitude
The existing Channel 268B reference coordinates do not satisfy Section 73201 requirements with respect to five stations as shown by the allocation study provided in Figure 4 Each short-spacing is discussed below
First under Section 73207 the proposed Channel 268B reference site is short-spaced to WMJK(FM) on Channel 265A at Clyde Ohio The required minimum separation distance is 69 kilometers the actual separation distance is 64 kilometers a short-spacing of 5 kilometers WMJK(FM) is a 3 kilowatt100 meter type Class A facility and therefore is processed pursuant to Section
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 5
13213 of the Rules as the short-spacing (under Section 13207) is not exacerbated
Second under Section 73207 the proposed Channel 268B reference site is short-spaced to WNCO-FM on Channel 267B at Ashland Ohio The required minimum separation distance is 169 kilometers the actual separation distance is 129 kilometers a short-spacing of 40 kilometers However because the Channel 268B allotment and WNCO-FM have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Third under Section 73207 the proposed Channel 268B reference site is short-spaced to a Canadian allotment on Channel 268A The required minimum separation distance is 210 kilometers the actual separation distance is 167 kilometers a short-spacing of 43 kilometers This Canadian allotment is a specially negotiated short-spaced allotment Therefore because the proposed allotment does not involve a change in the relevant site this previously accepted spacing should satisfy the Commissionrsquos allocation requiremements
Fourth under Section 73207 the proposed Channel 268B reference site is short-spaced to the current licensed and authorized facility of WWBN(FM) on Channel 268A at Tuscola Michigan because WWBN(FM) is authorized pursuant to Section 73215 with regard to WRVF(FM) Therefore as WRVF(FM) did not initiate this short- spacing and the proposed re-allotment involves no change in the WRVF(FM)rsquos current transmitter site the proposed spacing satisfies the Commissionrsquos allotment requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 6
Fifth under Section 73207 the proposed Channel 268B reference site is short-spaced to WNSN(FM) on Channel 268B at South Bend Indiana The required minimum separation distance is 14 kilometers the actual separation distance is 68 kilometers a short-spacing of 6 kilometers However because the Channel 268B allotment and WNSN(FM) have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Proposed Modifications to Table of Allotments
This proposal provides for the following allotment changes to Section 73202 The Commissionrsquos Table of FM Allotments
Lowell Oil Center (historical) hobth Amsden Maple Grove
Watson lie Mount Gilead
10 0 10 20 30 40 miles
H H H H t I I I I I I
H H H H I I I I I I I I 10 0 10 20 30 40 50 kilometers
CITY GRADE REFERENCE CONTOURS
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 2
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 241A Genoa Ohio Allocation Study Proposed Reference Site
41deg 29rsquo 17rdquo North Latitude 8 3 O 19rsquo 25ldquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(rn) Longitude deg-True (km) (hi) WBVI FOSTORIA BLH 244A 30 41-06-00 1964 4494 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR- F LEAMINGTON 244C1 910 42-00-35 472 8582 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Yahoo Yellow Pages Page 1 of 1
-Yetlow Pages Home - Yahoo1 - Maps -Address Book - HelF
Welcome Guest User
Yahoo Yellow Pages Genoa OH
TQP gt Communiamp gt Post Offices
All Businesses Business Name US Post Office (800) 2754777
Create My Favorite Locations - Sign In
Change Location - SaveThis Location
I Showing 1-1 of I I Beyond Genoa
Address 606 Washington St GenoaOH LaQ
Showing 1-1 of 1 I Beyond Genoa
Beyond Genoa
Modify your search
Search by Name or Category I -
Business infonation provided by InfoUSAcom Foster City California Copyright 0 2002 All Rights Reserved Use Subject to License
CopyrightQ 2002 Yahoo Inc Ail rights reserved Help -Privacy Policy - Terms of Service
1 1 am Vice President of RASP Broadcast Enterprises bc (lsquoaASPrdquo) the license of WJZB(FM) C h e l 2 4 7 A Oak Harbor Obio
RASP intends to apply for a construction permit for Channel 247A to specify oper Itions for WJZE in Genoa Ohio upon adoption ofthe Proposal as outljned h e n through the relevant Notice of Pmposed Rule Making
If am ardd the construction permit for Channel 247A RASP promptlywill construct and ITamp such facilities
2
3
Iherebydec are underpenallyofperjurythat thes ta tementsmade ia th i sdec l~~on~~e and accurate to the Ixst of my howledge information and belief
September a 2 002
DECLARATION
I Jeff Littlejohn declare as follows
3 I am Senior Vice President Engineering of Citicasters Licenses Inc (ldquoCiticastersrdquo) the licensee of WRVF(FM) Channel 268B Toledo Ohio
Citicasters intends to apply for a construction permit for Channel 268B to specamp operations for WRVF in Oak Harbor Ohio upon adoption of the Proposal as outlined herein through the relevant Notice of Proposed Rule Making
If awarded the construction permit for Channel 268B Citicasters promptly wi l l construct and operate such facilities
4
3
I hereby declare under penalty of perjury that the statements made in
this declaration are true and accurate to the best of my knowledge information and
belief
du Treil Lundin amp Rackley Inc Consulting Engineers
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Technical Narrative
This Technical Exhibit of which this Narrative is part proposes an FM Rule Making to modify the Commissions Table of Allotments contained within Section 73202 within the Commissions Rules It is proposed herein to modify the community of license of two FM stations No change in the stations reference coordinates are proposed
Summary of Rule Making Proposal
Below is a summary of the allocation changes requested in the Joint Petition for Rule Making
0 Delete Channel 247A at Oak Harbor Ohio and allot
Contingent on the adoption of the above change Channel 24A at Genoa Ohio
delete Channel 268B at Toledo Ohio and allot Channel 268B at Oak Harbor Ohio
Pursuant to Section 142O(i) of the Commissions Rules the Petition also requests modifications to the licenses of WJZE(FM) Channel 24A Oak Harbor Ohio and WRVF(FM) Channel 268B Toledo Ohio accordingly
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 2
Proposed Channel 247A Genoa Ohio
It is proposed to delete Channel 247A at Oak Harbor and allot Channel 247A to Genoa Ohio The Genoa proposal is mutually exclusive with the current Oak Harbor allotment As no change in the reference site change is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Genoa as shown in Figure 1
Below are the Channel 247A Genoa reference site geographic coordinates
41deg 29 17 North Latitude 83O 19 25 West Longitude
The existing Channel 241A reference coordinates do not satisfy the spacing requirements of Section 73207 with respect to three stations as identified in the allocation study provided in Figure 2 Each is discussed below
First under Section 73207 the proposed Channel 247A reference site is short-spaced to CHYR-FM on Channel 244C1 at Leamington Ontario Canada The required minimum separation distance is 90 kilometers the actual separation distance is 86 kilometers a short- spacing of 4 kilometers This Canadian allotment is a specially negotiated short-spaced allotment which was accepted by the Commission on September 2 1992 Petitionerrs Channel 247A is also a specially negotiated short-spaced allotment which was accepted by Canada on December 14 1992 Therefore because the proposed allotment does not involve any change in the relevant site this previously accepted spacing should satisfy the Commissions allocation requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 3
Second under Section 73207 the proposed Channel 248A reference site is short-spaced to WKRK-FM on Channel 246B at Detroit Michigan The required minimum separation distance is 113 kilometers the actual separation distance is 111 kilometers a short-spacing of 2 kilometers Petitioners Channel 247A was initially allocated as a 3 kilowatt100 meter facility and it remains as an equivalent facility Therefore for allotment purposes WKRK-FM can be protected pursuant to Section 73213(c) of the Commissions Rules which requires a minimum separation distance of 105 kilometers The proposed reference coordinates satisfies this requirement
Third under Section 73207 the proposed Channel 247A reference site is short-spaced to WMEE(FM) on Channel 247B at Fort Wayne Indiana The station was authorized to operate from the reference site (its current site) pursuant to the stations request to be processed under Section 73215 The required minimum separation distance is 178 kilometers the actual separation distance is 162 kilometers a short-spacing of 16 kilometers
However the proposed allotment does not create a new short or not exacerbate any short-spacing (under Section 73207) with regard to WMEE(FM) In addition WJZE(FM) already has been approved to operate at the reference site to the extent is affords WMEE(FM) contour protection pursuant to Section 73215 and the proposed allotment contemplates no change in WJZE(FM)s operating parameters Moreover WJZE(FM)s former (pre-Section 73215) transmitter site satisfied the relevant spacing requirement - the Section 73213(c) separation distance of 163 kilometers with regard to WMEE(FM) As shown in Figure 1 the projected city grade reference contour (70 dBu) of the allotment from this former site encompassed
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 4
the proposed community of Genoa this pre-Section 73215 site is provided in Figure 2
An allocation study from
Figure 5 is an Area-to-Locate map for Channel 247A As can be seen there is no present fully-spaced area-to-locate for this allotment
Proposed Channel 268B Oak Harbor Ohio
It is proposed to delete Channel 268B at Toledo and allot Channel 268B to Oak Harbor Ohio This Oak Harbor proposal is mutually exclusive with the current Toledo allotment As no change in the reference site is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Oak Harbor as shown in Figure 1
Below are the Channel 268B Oak Harbor reference site geographic coordinates
41O 40 23 North Latitude 83O 25 31 West Longitude
The existing Channel 268B reference coordinates do not satisfy Section 73201 requirements with respect to five stations as shown by the allocation study provided in Figure 4 Each short-spacing is discussed below
First under Section 73207 the proposed Channel 268B reference site is short-spaced to WMJK(FM) on Channel 265A at Clyde Ohio The required minimum separation distance is 69 kilometers the actual separation distance is 64 kilometers a short-spacing of 5 kilometers WMJK(FM) is a 3 kilowatt100 meter type Class A facility and therefore is processed pursuant to Section
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 5
13213 of the Rules as the short-spacing (under Section 13207) is not exacerbated
Second under Section 73207 the proposed Channel 268B reference site is short-spaced to WNCO-FM on Channel 267B at Ashland Ohio The required minimum separation distance is 169 kilometers the actual separation distance is 129 kilometers a short-spacing of 40 kilometers However because the Channel 268B allotment and WNCO-FM have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Third under Section 73207 the proposed Channel 268B reference site is short-spaced to a Canadian allotment on Channel 268A The required minimum separation distance is 210 kilometers the actual separation distance is 167 kilometers a short-spacing of 43 kilometers This Canadian allotment is a specially negotiated short-spaced allotment Therefore because the proposed allotment does not involve a change in the relevant site this previously accepted spacing should satisfy the Commissionrsquos allocation requiremements
Fourth under Section 73207 the proposed Channel 268B reference site is short-spaced to the current licensed and authorized facility of WWBN(FM) on Channel 268A at Tuscola Michigan because WWBN(FM) is authorized pursuant to Section 73215 with regard to WRVF(FM) Therefore as WRVF(FM) did not initiate this short- spacing and the proposed re-allotment involves no change in the WRVF(FM)rsquos current transmitter site the proposed spacing satisfies the Commissionrsquos allotment requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 6
Fifth under Section 73207 the proposed Channel 268B reference site is short-spaced to WNSN(FM) on Channel 268B at South Bend Indiana The required minimum separation distance is 14 kilometers the actual separation distance is 68 kilometers a short-spacing of 6 kilometers However because the Channel 268B allotment and WNSN(FM) have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Proposed Modifications to Table of Allotments
This proposal provides for the following allotment changes to Section 73202 The Commissionrsquos Table of FM Allotments
Lowell Oil Center (historical) hobth Amsden Maple Grove
Watson lie Mount Gilead
10 0 10 20 30 40 miles
H H H H t I I I I I I
H H H H I I I I I I I I 10 0 10 20 30 40 50 kilometers
CITY GRADE REFERENCE CONTOURS
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 2
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 241A Genoa Ohio Allocation Study Proposed Reference Site
41deg 29rsquo 17rdquo North Latitude 8 3 O 19rsquo 25ldquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(rn) Longitude deg-True (km) (hi) WBVI FOSTORIA BLH 244A 30 41-06-00 1964 4494 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR- F LEAMINGTON 244C1 910 42-00-35 472 8582 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
EXHIBIT 2
09232082 16 26 5864636211 DE PUSH RODS PAGE 02
DECLARATION
I Gregory P Theokas declare as fOllOW5
1 1 am Vice President of RASP Broadcast Enterprises bc (lsquoaASPrdquo) the license of WJZB(FM) C h e l 2 4 7 A Oak Harbor Obio
RASP intends to apply for a construction permit for Channel 247A to specify oper Itions for WJZE in Genoa Ohio upon adoption ofthe Proposal as outljned h e n through the relevant Notice of Pmposed Rule Making
If am ardd the construction permit for Channel 247A RASP promptlywill construct and ITamp such facilities
2
3
Iherebydec are underpenallyofperjurythat thes ta tementsmade ia th i sdec l~~on~~e and accurate to the Ixst of my howledge information and belief
September a 2 002
DECLARATION
I Jeff Littlejohn declare as follows
3 I am Senior Vice President Engineering of Citicasters Licenses Inc (ldquoCiticastersrdquo) the licensee of WRVF(FM) Channel 268B Toledo Ohio
Citicasters intends to apply for a construction permit for Channel 268B to specamp operations for WRVF in Oak Harbor Ohio upon adoption of the Proposal as outlined herein through the relevant Notice of Proposed Rule Making
If awarded the construction permit for Channel 268B Citicasters promptly wi l l construct and operate such facilities
4
3
I hereby declare under penalty of perjury that the statements made in
this declaration are true and accurate to the best of my knowledge information and
belief
du Treil Lundin amp Rackley Inc Consulting Engineers
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Technical Narrative
This Technical Exhibit of which this Narrative is part proposes an FM Rule Making to modify the Commissions Table of Allotments contained within Section 73202 within the Commissions Rules It is proposed herein to modify the community of license of two FM stations No change in the stations reference coordinates are proposed
Summary of Rule Making Proposal
Below is a summary of the allocation changes requested in the Joint Petition for Rule Making
0 Delete Channel 247A at Oak Harbor Ohio and allot
Contingent on the adoption of the above change Channel 24A at Genoa Ohio
delete Channel 268B at Toledo Ohio and allot Channel 268B at Oak Harbor Ohio
Pursuant to Section 142O(i) of the Commissions Rules the Petition also requests modifications to the licenses of WJZE(FM) Channel 24A Oak Harbor Ohio and WRVF(FM) Channel 268B Toledo Ohio accordingly
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 2
Proposed Channel 247A Genoa Ohio
It is proposed to delete Channel 247A at Oak Harbor and allot Channel 247A to Genoa Ohio The Genoa proposal is mutually exclusive with the current Oak Harbor allotment As no change in the reference site change is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Genoa as shown in Figure 1
Below are the Channel 247A Genoa reference site geographic coordinates
41deg 29 17 North Latitude 83O 19 25 West Longitude
The existing Channel 241A reference coordinates do not satisfy the spacing requirements of Section 73207 with respect to three stations as identified in the allocation study provided in Figure 2 Each is discussed below
First under Section 73207 the proposed Channel 247A reference site is short-spaced to CHYR-FM on Channel 244C1 at Leamington Ontario Canada The required minimum separation distance is 90 kilometers the actual separation distance is 86 kilometers a short- spacing of 4 kilometers This Canadian allotment is a specially negotiated short-spaced allotment which was accepted by the Commission on September 2 1992 Petitionerrs Channel 247A is also a specially negotiated short-spaced allotment which was accepted by Canada on December 14 1992 Therefore because the proposed allotment does not involve any change in the relevant site this previously accepted spacing should satisfy the Commissions allocation requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 3
Second under Section 73207 the proposed Channel 248A reference site is short-spaced to WKRK-FM on Channel 246B at Detroit Michigan The required minimum separation distance is 113 kilometers the actual separation distance is 111 kilometers a short-spacing of 2 kilometers Petitioners Channel 247A was initially allocated as a 3 kilowatt100 meter facility and it remains as an equivalent facility Therefore for allotment purposes WKRK-FM can be protected pursuant to Section 73213(c) of the Commissions Rules which requires a minimum separation distance of 105 kilometers The proposed reference coordinates satisfies this requirement
Third under Section 73207 the proposed Channel 247A reference site is short-spaced to WMEE(FM) on Channel 247B at Fort Wayne Indiana The station was authorized to operate from the reference site (its current site) pursuant to the stations request to be processed under Section 73215 The required minimum separation distance is 178 kilometers the actual separation distance is 162 kilometers a short-spacing of 16 kilometers
However the proposed allotment does not create a new short or not exacerbate any short-spacing (under Section 73207) with regard to WMEE(FM) In addition WJZE(FM) already has been approved to operate at the reference site to the extent is affords WMEE(FM) contour protection pursuant to Section 73215 and the proposed allotment contemplates no change in WJZE(FM)s operating parameters Moreover WJZE(FM)s former (pre-Section 73215) transmitter site satisfied the relevant spacing requirement - the Section 73213(c) separation distance of 163 kilometers with regard to WMEE(FM) As shown in Figure 1 the projected city grade reference contour (70 dBu) of the allotment from this former site encompassed
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 4
the proposed community of Genoa this pre-Section 73215 site is provided in Figure 2
An allocation study from
Figure 5 is an Area-to-Locate map for Channel 247A As can be seen there is no present fully-spaced area-to-locate for this allotment
Proposed Channel 268B Oak Harbor Ohio
It is proposed to delete Channel 268B at Toledo and allot Channel 268B to Oak Harbor Ohio This Oak Harbor proposal is mutually exclusive with the current Toledo allotment As no change in the reference site is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Oak Harbor as shown in Figure 1
Below are the Channel 268B Oak Harbor reference site geographic coordinates
41O 40 23 North Latitude 83O 25 31 West Longitude
The existing Channel 268B reference coordinates do not satisfy Section 73201 requirements with respect to five stations as shown by the allocation study provided in Figure 4 Each short-spacing is discussed below
First under Section 73207 the proposed Channel 268B reference site is short-spaced to WMJK(FM) on Channel 265A at Clyde Ohio The required minimum separation distance is 69 kilometers the actual separation distance is 64 kilometers a short-spacing of 5 kilometers WMJK(FM) is a 3 kilowatt100 meter type Class A facility and therefore is processed pursuant to Section
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 5
13213 of the Rules as the short-spacing (under Section 13207) is not exacerbated
Second under Section 73207 the proposed Channel 268B reference site is short-spaced to WNCO-FM on Channel 267B at Ashland Ohio The required minimum separation distance is 169 kilometers the actual separation distance is 129 kilometers a short-spacing of 40 kilometers However because the Channel 268B allotment and WNCO-FM have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Third under Section 73207 the proposed Channel 268B reference site is short-spaced to a Canadian allotment on Channel 268A The required minimum separation distance is 210 kilometers the actual separation distance is 167 kilometers a short-spacing of 43 kilometers This Canadian allotment is a specially negotiated short-spaced allotment Therefore because the proposed allotment does not involve a change in the relevant site this previously accepted spacing should satisfy the Commissionrsquos allocation requiremements
Fourth under Section 73207 the proposed Channel 268B reference site is short-spaced to the current licensed and authorized facility of WWBN(FM) on Channel 268A at Tuscola Michigan because WWBN(FM) is authorized pursuant to Section 73215 with regard to WRVF(FM) Therefore as WRVF(FM) did not initiate this short- spacing and the proposed re-allotment involves no change in the WRVF(FM)rsquos current transmitter site the proposed spacing satisfies the Commissionrsquos allotment requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 6
Fifth under Section 73207 the proposed Channel 268B reference site is short-spaced to WNSN(FM) on Channel 268B at South Bend Indiana The required minimum separation distance is 14 kilometers the actual separation distance is 68 kilometers a short-spacing of 6 kilometers However because the Channel 268B allotment and WNSN(FM) have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Proposed Modifications to Table of Allotments
This proposal provides for the following allotment changes to Section 73202 The Commissionrsquos Table of FM Allotments
Lowell Oil Center (historical) hobth Amsden Maple Grove
Watson lie Mount Gilead
10 0 10 20 30 40 miles
H H H H t I I I I I I
H H H H I I I I I I I I 10 0 10 20 30 40 50 kilometers
CITY GRADE REFERENCE CONTOURS
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 2
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 241A Genoa Ohio Allocation Study Proposed Reference Site
41deg 29rsquo 17rdquo North Latitude 8 3 O 19rsquo 25ldquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(rn) Longitude deg-True (km) (hi) WBVI FOSTORIA BLH 244A 30 41-06-00 1964 4494 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR- F LEAMINGTON 244C1 910 42-00-35 472 8582 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
09232082 16 26 5864636211 DE PUSH RODS PAGE 02
DECLARATION
I Gregory P Theokas declare as fOllOW5
1 1 am Vice President of RASP Broadcast Enterprises bc (lsquoaASPrdquo) the license of WJZB(FM) C h e l 2 4 7 A Oak Harbor Obio
RASP intends to apply for a construction permit for Channel 247A to specify oper Itions for WJZE in Genoa Ohio upon adoption ofthe Proposal as outljned h e n through the relevant Notice of Pmposed Rule Making
If am ardd the construction permit for Channel 247A RASP promptlywill construct and ITamp such facilities
2
3
Iherebydec are underpenallyofperjurythat thes ta tementsmade ia th i sdec l~~on~~e and accurate to the Ixst of my howledge information and belief
September a 2 002
DECLARATION
I Jeff Littlejohn declare as follows
3 I am Senior Vice President Engineering of Citicasters Licenses Inc (ldquoCiticastersrdquo) the licensee of WRVF(FM) Channel 268B Toledo Ohio
Citicasters intends to apply for a construction permit for Channel 268B to specamp operations for WRVF in Oak Harbor Ohio upon adoption of the Proposal as outlined herein through the relevant Notice of Proposed Rule Making
If awarded the construction permit for Channel 268B Citicasters promptly wi l l construct and operate such facilities
4
3
I hereby declare under penalty of perjury that the statements made in
this declaration are true and accurate to the best of my knowledge information and
belief
du Treil Lundin amp Rackley Inc Consulting Engineers
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Technical Narrative
This Technical Exhibit of which this Narrative is part proposes an FM Rule Making to modify the Commissions Table of Allotments contained within Section 73202 within the Commissions Rules It is proposed herein to modify the community of license of two FM stations No change in the stations reference coordinates are proposed
Summary of Rule Making Proposal
Below is a summary of the allocation changes requested in the Joint Petition for Rule Making
0 Delete Channel 247A at Oak Harbor Ohio and allot
Contingent on the adoption of the above change Channel 24A at Genoa Ohio
delete Channel 268B at Toledo Ohio and allot Channel 268B at Oak Harbor Ohio
Pursuant to Section 142O(i) of the Commissions Rules the Petition also requests modifications to the licenses of WJZE(FM) Channel 24A Oak Harbor Ohio and WRVF(FM) Channel 268B Toledo Ohio accordingly
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 2
Proposed Channel 247A Genoa Ohio
It is proposed to delete Channel 247A at Oak Harbor and allot Channel 247A to Genoa Ohio The Genoa proposal is mutually exclusive with the current Oak Harbor allotment As no change in the reference site change is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Genoa as shown in Figure 1
Below are the Channel 247A Genoa reference site geographic coordinates
41deg 29 17 North Latitude 83O 19 25 West Longitude
The existing Channel 241A reference coordinates do not satisfy the spacing requirements of Section 73207 with respect to three stations as identified in the allocation study provided in Figure 2 Each is discussed below
First under Section 73207 the proposed Channel 247A reference site is short-spaced to CHYR-FM on Channel 244C1 at Leamington Ontario Canada The required minimum separation distance is 90 kilometers the actual separation distance is 86 kilometers a short- spacing of 4 kilometers This Canadian allotment is a specially negotiated short-spaced allotment which was accepted by the Commission on September 2 1992 Petitionerrs Channel 247A is also a specially negotiated short-spaced allotment which was accepted by Canada on December 14 1992 Therefore because the proposed allotment does not involve any change in the relevant site this previously accepted spacing should satisfy the Commissions allocation requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 3
Second under Section 73207 the proposed Channel 248A reference site is short-spaced to WKRK-FM on Channel 246B at Detroit Michigan The required minimum separation distance is 113 kilometers the actual separation distance is 111 kilometers a short-spacing of 2 kilometers Petitioners Channel 247A was initially allocated as a 3 kilowatt100 meter facility and it remains as an equivalent facility Therefore for allotment purposes WKRK-FM can be protected pursuant to Section 73213(c) of the Commissions Rules which requires a minimum separation distance of 105 kilometers The proposed reference coordinates satisfies this requirement
Third under Section 73207 the proposed Channel 247A reference site is short-spaced to WMEE(FM) on Channel 247B at Fort Wayne Indiana The station was authorized to operate from the reference site (its current site) pursuant to the stations request to be processed under Section 73215 The required minimum separation distance is 178 kilometers the actual separation distance is 162 kilometers a short-spacing of 16 kilometers
However the proposed allotment does not create a new short or not exacerbate any short-spacing (under Section 73207) with regard to WMEE(FM) In addition WJZE(FM) already has been approved to operate at the reference site to the extent is affords WMEE(FM) contour protection pursuant to Section 73215 and the proposed allotment contemplates no change in WJZE(FM)s operating parameters Moreover WJZE(FM)s former (pre-Section 73215) transmitter site satisfied the relevant spacing requirement - the Section 73213(c) separation distance of 163 kilometers with regard to WMEE(FM) As shown in Figure 1 the projected city grade reference contour (70 dBu) of the allotment from this former site encompassed
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 4
the proposed community of Genoa this pre-Section 73215 site is provided in Figure 2
An allocation study from
Figure 5 is an Area-to-Locate map for Channel 247A As can be seen there is no present fully-spaced area-to-locate for this allotment
Proposed Channel 268B Oak Harbor Ohio
It is proposed to delete Channel 268B at Toledo and allot Channel 268B to Oak Harbor Ohio This Oak Harbor proposal is mutually exclusive with the current Toledo allotment As no change in the reference site is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Oak Harbor as shown in Figure 1
Below are the Channel 268B Oak Harbor reference site geographic coordinates
41O 40 23 North Latitude 83O 25 31 West Longitude
The existing Channel 268B reference coordinates do not satisfy Section 73201 requirements with respect to five stations as shown by the allocation study provided in Figure 4 Each short-spacing is discussed below
First under Section 73207 the proposed Channel 268B reference site is short-spaced to WMJK(FM) on Channel 265A at Clyde Ohio The required minimum separation distance is 69 kilometers the actual separation distance is 64 kilometers a short-spacing of 5 kilometers WMJK(FM) is a 3 kilowatt100 meter type Class A facility and therefore is processed pursuant to Section
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 5
13213 of the Rules as the short-spacing (under Section 13207) is not exacerbated
Second under Section 73207 the proposed Channel 268B reference site is short-spaced to WNCO-FM on Channel 267B at Ashland Ohio The required minimum separation distance is 169 kilometers the actual separation distance is 129 kilometers a short-spacing of 40 kilometers However because the Channel 268B allotment and WNCO-FM have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Third under Section 73207 the proposed Channel 268B reference site is short-spaced to a Canadian allotment on Channel 268A The required minimum separation distance is 210 kilometers the actual separation distance is 167 kilometers a short-spacing of 43 kilometers This Canadian allotment is a specially negotiated short-spaced allotment Therefore because the proposed allotment does not involve a change in the relevant site this previously accepted spacing should satisfy the Commissionrsquos allocation requiremements
Fourth under Section 73207 the proposed Channel 268B reference site is short-spaced to the current licensed and authorized facility of WWBN(FM) on Channel 268A at Tuscola Michigan because WWBN(FM) is authorized pursuant to Section 73215 with regard to WRVF(FM) Therefore as WRVF(FM) did not initiate this short- spacing and the proposed re-allotment involves no change in the WRVF(FM)rsquos current transmitter site the proposed spacing satisfies the Commissionrsquos allotment requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 6
Fifth under Section 73207 the proposed Channel 268B reference site is short-spaced to WNSN(FM) on Channel 268B at South Bend Indiana The required minimum separation distance is 14 kilometers the actual separation distance is 68 kilometers a short-spacing of 6 kilometers However because the Channel 268B allotment and WNSN(FM) have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Proposed Modifications to Table of Allotments
This proposal provides for the following allotment changes to Section 73202 The Commissionrsquos Table of FM Allotments
Lowell Oil Center (historical) hobth Amsden Maple Grove
Watson lie Mount Gilead
10 0 10 20 30 40 miles
H H H H t I I I I I I
H H H H I I I I I I I I 10 0 10 20 30 40 50 kilometers
CITY GRADE REFERENCE CONTOURS
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 2
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 241A Genoa Ohio Allocation Study Proposed Reference Site
41deg 29rsquo 17rdquo North Latitude 8 3 O 19rsquo 25ldquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(rn) Longitude deg-True (km) (hi) WBVI FOSTORIA BLH 244A 30 41-06-00 1964 4494 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR- F LEAMINGTON 244C1 910 42-00-35 472 8582 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
DECLARATION
I Jeff Littlejohn declare as follows
3 I am Senior Vice President Engineering of Citicasters Licenses Inc (ldquoCiticastersrdquo) the licensee of WRVF(FM) Channel 268B Toledo Ohio
Citicasters intends to apply for a construction permit for Channel 268B to specamp operations for WRVF in Oak Harbor Ohio upon adoption of the Proposal as outlined herein through the relevant Notice of Proposed Rule Making
If awarded the construction permit for Channel 268B Citicasters promptly wi l l construct and operate such facilities
4
3
I hereby declare under penalty of perjury that the statements made in
this declaration are true and accurate to the best of my knowledge information and
belief
du Treil Lundin amp Rackley Inc Consulting Engineers
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Technical Narrative
This Technical Exhibit of which this Narrative is part proposes an FM Rule Making to modify the Commissions Table of Allotments contained within Section 73202 within the Commissions Rules It is proposed herein to modify the community of license of two FM stations No change in the stations reference coordinates are proposed
Summary of Rule Making Proposal
Below is a summary of the allocation changes requested in the Joint Petition for Rule Making
0 Delete Channel 247A at Oak Harbor Ohio and allot
Contingent on the adoption of the above change Channel 24A at Genoa Ohio
delete Channel 268B at Toledo Ohio and allot Channel 268B at Oak Harbor Ohio
Pursuant to Section 142O(i) of the Commissions Rules the Petition also requests modifications to the licenses of WJZE(FM) Channel 24A Oak Harbor Ohio and WRVF(FM) Channel 268B Toledo Ohio accordingly
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 2
Proposed Channel 247A Genoa Ohio
It is proposed to delete Channel 247A at Oak Harbor and allot Channel 247A to Genoa Ohio The Genoa proposal is mutually exclusive with the current Oak Harbor allotment As no change in the reference site change is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Genoa as shown in Figure 1
Below are the Channel 247A Genoa reference site geographic coordinates
41deg 29 17 North Latitude 83O 19 25 West Longitude
The existing Channel 241A reference coordinates do not satisfy the spacing requirements of Section 73207 with respect to three stations as identified in the allocation study provided in Figure 2 Each is discussed below
First under Section 73207 the proposed Channel 247A reference site is short-spaced to CHYR-FM on Channel 244C1 at Leamington Ontario Canada The required minimum separation distance is 90 kilometers the actual separation distance is 86 kilometers a short- spacing of 4 kilometers This Canadian allotment is a specially negotiated short-spaced allotment which was accepted by the Commission on September 2 1992 Petitionerrs Channel 247A is also a specially negotiated short-spaced allotment which was accepted by Canada on December 14 1992 Therefore because the proposed allotment does not involve any change in the relevant site this previously accepted spacing should satisfy the Commissions allocation requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 3
Second under Section 73207 the proposed Channel 248A reference site is short-spaced to WKRK-FM on Channel 246B at Detroit Michigan The required minimum separation distance is 113 kilometers the actual separation distance is 111 kilometers a short-spacing of 2 kilometers Petitioners Channel 247A was initially allocated as a 3 kilowatt100 meter facility and it remains as an equivalent facility Therefore for allotment purposes WKRK-FM can be protected pursuant to Section 73213(c) of the Commissions Rules which requires a minimum separation distance of 105 kilometers The proposed reference coordinates satisfies this requirement
Third under Section 73207 the proposed Channel 247A reference site is short-spaced to WMEE(FM) on Channel 247B at Fort Wayne Indiana The station was authorized to operate from the reference site (its current site) pursuant to the stations request to be processed under Section 73215 The required minimum separation distance is 178 kilometers the actual separation distance is 162 kilometers a short-spacing of 16 kilometers
However the proposed allotment does not create a new short or not exacerbate any short-spacing (under Section 73207) with regard to WMEE(FM) In addition WJZE(FM) already has been approved to operate at the reference site to the extent is affords WMEE(FM) contour protection pursuant to Section 73215 and the proposed allotment contemplates no change in WJZE(FM)s operating parameters Moreover WJZE(FM)s former (pre-Section 73215) transmitter site satisfied the relevant spacing requirement - the Section 73213(c) separation distance of 163 kilometers with regard to WMEE(FM) As shown in Figure 1 the projected city grade reference contour (70 dBu) of the allotment from this former site encompassed
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 4
the proposed community of Genoa this pre-Section 73215 site is provided in Figure 2
An allocation study from
Figure 5 is an Area-to-Locate map for Channel 247A As can be seen there is no present fully-spaced area-to-locate for this allotment
Proposed Channel 268B Oak Harbor Ohio
It is proposed to delete Channel 268B at Toledo and allot Channel 268B to Oak Harbor Ohio This Oak Harbor proposal is mutually exclusive with the current Toledo allotment As no change in the reference site is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Oak Harbor as shown in Figure 1
Below are the Channel 268B Oak Harbor reference site geographic coordinates
41O 40 23 North Latitude 83O 25 31 West Longitude
The existing Channel 268B reference coordinates do not satisfy Section 73201 requirements with respect to five stations as shown by the allocation study provided in Figure 4 Each short-spacing is discussed below
First under Section 73207 the proposed Channel 268B reference site is short-spaced to WMJK(FM) on Channel 265A at Clyde Ohio The required minimum separation distance is 69 kilometers the actual separation distance is 64 kilometers a short-spacing of 5 kilometers WMJK(FM) is a 3 kilowatt100 meter type Class A facility and therefore is processed pursuant to Section
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 5
13213 of the Rules as the short-spacing (under Section 13207) is not exacerbated
Second under Section 73207 the proposed Channel 268B reference site is short-spaced to WNCO-FM on Channel 267B at Ashland Ohio The required minimum separation distance is 169 kilometers the actual separation distance is 129 kilometers a short-spacing of 40 kilometers However because the Channel 268B allotment and WNCO-FM have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Third under Section 73207 the proposed Channel 268B reference site is short-spaced to a Canadian allotment on Channel 268A The required minimum separation distance is 210 kilometers the actual separation distance is 167 kilometers a short-spacing of 43 kilometers This Canadian allotment is a specially negotiated short-spaced allotment Therefore because the proposed allotment does not involve a change in the relevant site this previously accepted spacing should satisfy the Commissionrsquos allocation requiremements
Fourth under Section 73207 the proposed Channel 268B reference site is short-spaced to the current licensed and authorized facility of WWBN(FM) on Channel 268A at Tuscola Michigan because WWBN(FM) is authorized pursuant to Section 73215 with regard to WRVF(FM) Therefore as WRVF(FM) did not initiate this short- spacing and the proposed re-allotment involves no change in the WRVF(FM)rsquos current transmitter site the proposed spacing satisfies the Commissionrsquos allotment requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 6
Fifth under Section 73207 the proposed Channel 268B reference site is short-spaced to WNSN(FM) on Channel 268B at South Bend Indiana The required minimum separation distance is 14 kilometers the actual separation distance is 68 kilometers a short-spacing of 6 kilometers However because the Channel 268B allotment and WNSN(FM) have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Proposed Modifications to Table of Allotments
This proposal provides for the following allotment changes to Section 73202 The Commissionrsquos Table of FM Allotments
Lowell Oil Center (historical) hobth Amsden Maple Grove
Watson lie Mount Gilead
10 0 10 20 30 40 miles
H H H H t I I I I I I
H H H H I I I I I I I I 10 0 10 20 30 40 50 kilometers
CITY GRADE REFERENCE CONTOURS
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 2
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 241A Genoa Ohio Allocation Study Proposed Reference Site
41deg 29rsquo 17rdquo North Latitude 8 3 O 19rsquo 25ldquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(rn) Longitude deg-True (km) (hi) WBVI FOSTORIA BLH 244A 30 41-06-00 1964 4494 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR- F LEAMINGTON 244C1 910 42-00-35 472 8582 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
du Treil Lundin amp Rackley Inc Consulting Engineers
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Technical Narrative
This Technical Exhibit of which this Narrative is part proposes an FM Rule Making to modify the Commissions Table of Allotments contained within Section 73202 within the Commissions Rules It is proposed herein to modify the community of license of two FM stations No change in the stations reference coordinates are proposed
Summary of Rule Making Proposal
Below is a summary of the allocation changes requested in the Joint Petition for Rule Making
0 Delete Channel 247A at Oak Harbor Ohio and allot
Contingent on the adoption of the above change Channel 24A at Genoa Ohio
delete Channel 268B at Toledo Ohio and allot Channel 268B at Oak Harbor Ohio
Pursuant to Section 142O(i) of the Commissions Rules the Petition also requests modifications to the licenses of WJZE(FM) Channel 24A Oak Harbor Ohio and WRVF(FM) Channel 268B Toledo Ohio accordingly
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 2
Proposed Channel 247A Genoa Ohio
It is proposed to delete Channel 247A at Oak Harbor and allot Channel 247A to Genoa Ohio The Genoa proposal is mutually exclusive with the current Oak Harbor allotment As no change in the reference site change is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Genoa as shown in Figure 1
Below are the Channel 247A Genoa reference site geographic coordinates
41deg 29 17 North Latitude 83O 19 25 West Longitude
The existing Channel 241A reference coordinates do not satisfy the spacing requirements of Section 73207 with respect to three stations as identified in the allocation study provided in Figure 2 Each is discussed below
First under Section 73207 the proposed Channel 247A reference site is short-spaced to CHYR-FM on Channel 244C1 at Leamington Ontario Canada The required minimum separation distance is 90 kilometers the actual separation distance is 86 kilometers a short- spacing of 4 kilometers This Canadian allotment is a specially negotiated short-spaced allotment which was accepted by the Commission on September 2 1992 Petitionerrs Channel 247A is also a specially negotiated short-spaced allotment which was accepted by Canada on December 14 1992 Therefore because the proposed allotment does not involve any change in the relevant site this previously accepted spacing should satisfy the Commissions allocation requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 3
Second under Section 73207 the proposed Channel 248A reference site is short-spaced to WKRK-FM on Channel 246B at Detroit Michigan The required minimum separation distance is 113 kilometers the actual separation distance is 111 kilometers a short-spacing of 2 kilometers Petitioners Channel 247A was initially allocated as a 3 kilowatt100 meter facility and it remains as an equivalent facility Therefore for allotment purposes WKRK-FM can be protected pursuant to Section 73213(c) of the Commissions Rules which requires a minimum separation distance of 105 kilometers The proposed reference coordinates satisfies this requirement
Third under Section 73207 the proposed Channel 247A reference site is short-spaced to WMEE(FM) on Channel 247B at Fort Wayne Indiana The station was authorized to operate from the reference site (its current site) pursuant to the stations request to be processed under Section 73215 The required minimum separation distance is 178 kilometers the actual separation distance is 162 kilometers a short-spacing of 16 kilometers
However the proposed allotment does not create a new short or not exacerbate any short-spacing (under Section 73207) with regard to WMEE(FM) In addition WJZE(FM) already has been approved to operate at the reference site to the extent is affords WMEE(FM) contour protection pursuant to Section 73215 and the proposed allotment contemplates no change in WJZE(FM)s operating parameters Moreover WJZE(FM)s former (pre-Section 73215) transmitter site satisfied the relevant spacing requirement - the Section 73213(c) separation distance of 163 kilometers with regard to WMEE(FM) As shown in Figure 1 the projected city grade reference contour (70 dBu) of the allotment from this former site encompassed
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 4
the proposed community of Genoa this pre-Section 73215 site is provided in Figure 2
An allocation study from
Figure 5 is an Area-to-Locate map for Channel 247A As can be seen there is no present fully-spaced area-to-locate for this allotment
Proposed Channel 268B Oak Harbor Ohio
It is proposed to delete Channel 268B at Toledo and allot Channel 268B to Oak Harbor Ohio This Oak Harbor proposal is mutually exclusive with the current Toledo allotment As no change in the reference site is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Oak Harbor as shown in Figure 1
Below are the Channel 268B Oak Harbor reference site geographic coordinates
41O 40 23 North Latitude 83O 25 31 West Longitude
The existing Channel 268B reference coordinates do not satisfy Section 73201 requirements with respect to five stations as shown by the allocation study provided in Figure 4 Each short-spacing is discussed below
First under Section 73207 the proposed Channel 268B reference site is short-spaced to WMJK(FM) on Channel 265A at Clyde Ohio The required minimum separation distance is 69 kilometers the actual separation distance is 64 kilometers a short-spacing of 5 kilometers WMJK(FM) is a 3 kilowatt100 meter type Class A facility and therefore is processed pursuant to Section
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 5
13213 of the Rules as the short-spacing (under Section 13207) is not exacerbated
Second under Section 73207 the proposed Channel 268B reference site is short-spaced to WNCO-FM on Channel 267B at Ashland Ohio The required minimum separation distance is 169 kilometers the actual separation distance is 129 kilometers a short-spacing of 40 kilometers However because the Channel 268B allotment and WNCO-FM have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Third under Section 73207 the proposed Channel 268B reference site is short-spaced to a Canadian allotment on Channel 268A The required minimum separation distance is 210 kilometers the actual separation distance is 167 kilometers a short-spacing of 43 kilometers This Canadian allotment is a specially negotiated short-spaced allotment Therefore because the proposed allotment does not involve a change in the relevant site this previously accepted spacing should satisfy the Commissionrsquos allocation requiremements
Fourth under Section 73207 the proposed Channel 268B reference site is short-spaced to the current licensed and authorized facility of WWBN(FM) on Channel 268A at Tuscola Michigan because WWBN(FM) is authorized pursuant to Section 73215 with regard to WRVF(FM) Therefore as WRVF(FM) did not initiate this short- spacing and the proposed re-allotment involves no change in the WRVF(FM)rsquos current transmitter site the proposed spacing satisfies the Commissionrsquos allotment requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 6
Fifth under Section 73207 the proposed Channel 268B reference site is short-spaced to WNSN(FM) on Channel 268B at South Bend Indiana The required minimum separation distance is 14 kilometers the actual separation distance is 68 kilometers a short-spacing of 6 kilometers However because the Channel 268B allotment and WNSN(FM) have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Proposed Modifications to Table of Allotments
This proposal provides for the following allotment changes to Section 73202 The Commissionrsquos Table of FM Allotments
Lowell Oil Center (historical) hobth Amsden Maple Grove
Watson lie Mount Gilead
10 0 10 20 30 40 miles
H H H H t I I I I I I
H H H H I I I I I I I I 10 0 10 20 30 40 50 kilometers
CITY GRADE REFERENCE CONTOURS
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 2
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 241A Genoa Ohio Allocation Study Proposed Reference Site
41deg 29rsquo 17rdquo North Latitude 8 3 O 19rsquo 25ldquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(rn) Longitude deg-True (km) (hi) WBVI FOSTORIA BLH 244A 30 41-06-00 1964 4494 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR- F LEAMINGTON 244C1 910 42-00-35 472 8582 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 2
Proposed Channel 247A Genoa Ohio
It is proposed to delete Channel 247A at Oak Harbor and allot Channel 247A to Genoa Ohio The Genoa proposal is mutually exclusive with the current Oak Harbor allotment As no change in the reference site change is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Genoa as shown in Figure 1
Below are the Channel 247A Genoa reference site geographic coordinates
41deg 29 17 North Latitude 83O 19 25 West Longitude
The existing Channel 241A reference coordinates do not satisfy the spacing requirements of Section 73207 with respect to three stations as identified in the allocation study provided in Figure 2 Each is discussed below
First under Section 73207 the proposed Channel 247A reference site is short-spaced to CHYR-FM on Channel 244C1 at Leamington Ontario Canada The required minimum separation distance is 90 kilometers the actual separation distance is 86 kilometers a short- spacing of 4 kilometers This Canadian allotment is a specially negotiated short-spaced allotment which was accepted by the Commission on September 2 1992 Petitionerrs Channel 247A is also a specially negotiated short-spaced allotment which was accepted by Canada on December 14 1992 Therefore because the proposed allotment does not involve any change in the relevant site this previously accepted spacing should satisfy the Commissions allocation requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 3
Second under Section 73207 the proposed Channel 248A reference site is short-spaced to WKRK-FM on Channel 246B at Detroit Michigan The required minimum separation distance is 113 kilometers the actual separation distance is 111 kilometers a short-spacing of 2 kilometers Petitioners Channel 247A was initially allocated as a 3 kilowatt100 meter facility and it remains as an equivalent facility Therefore for allotment purposes WKRK-FM can be protected pursuant to Section 73213(c) of the Commissions Rules which requires a minimum separation distance of 105 kilometers The proposed reference coordinates satisfies this requirement
Third under Section 73207 the proposed Channel 247A reference site is short-spaced to WMEE(FM) on Channel 247B at Fort Wayne Indiana The station was authorized to operate from the reference site (its current site) pursuant to the stations request to be processed under Section 73215 The required minimum separation distance is 178 kilometers the actual separation distance is 162 kilometers a short-spacing of 16 kilometers
However the proposed allotment does not create a new short or not exacerbate any short-spacing (under Section 73207) with regard to WMEE(FM) In addition WJZE(FM) already has been approved to operate at the reference site to the extent is affords WMEE(FM) contour protection pursuant to Section 73215 and the proposed allotment contemplates no change in WJZE(FM)s operating parameters Moreover WJZE(FM)s former (pre-Section 73215) transmitter site satisfied the relevant spacing requirement - the Section 73213(c) separation distance of 163 kilometers with regard to WMEE(FM) As shown in Figure 1 the projected city grade reference contour (70 dBu) of the allotment from this former site encompassed
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 4
the proposed community of Genoa this pre-Section 73215 site is provided in Figure 2
An allocation study from
Figure 5 is an Area-to-Locate map for Channel 247A As can be seen there is no present fully-spaced area-to-locate for this allotment
Proposed Channel 268B Oak Harbor Ohio
It is proposed to delete Channel 268B at Toledo and allot Channel 268B to Oak Harbor Ohio This Oak Harbor proposal is mutually exclusive with the current Toledo allotment As no change in the reference site is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Oak Harbor as shown in Figure 1
Below are the Channel 268B Oak Harbor reference site geographic coordinates
41O 40 23 North Latitude 83O 25 31 West Longitude
The existing Channel 268B reference coordinates do not satisfy Section 73201 requirements with respect to five stations as shown by the allocation study provided in Figure 4 Each short-spacing is discussed below
First under Section 73207 the proposed Channel 268B reference site is short-spaced to WMJK(FM) on Channel 265A at Clyde Ohio The required minimum separation distance is 69 kilometers the actual separation distance is 64 kilometers a short-spacing of 5 kilometers WMJK(FM) is a 3 kilowatt100 meter type Class A facility and therefore is processed pursuant to Section
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 5
13213 of the Rules as the short-spacing (under Section 13207) is not exacerbated
Second under Section 73207 the proposed Channel 268B reference site is short-spaced to WNCO-FM on Channel 267B at Ashland Ohio The required minimum separation distance is 169 kilometers the actual separation distance is 129 kilometers a short-spacing of 40 kilometers However because the Channel 268B allotment and WNCO-FM have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Third under Section 73207 the proposed Channel 268B reference site is short-spaced to a Canadian allotment on Channel 268A The required minimum separation distance is 210 kilometers the actual separation distance is 167 kilometers a short-spacing of 43 kilometers This Canadian allotment is a specially negotiated short-spaced allotment Therefore because the proposed allotment does not involve a change in the relevant site this previously accepted spacing should satisfy the Commissionrsquos allocation requiremements
Fourth under Section 73207 the proposed Channel 268B reference site is short-spaced to the current licensed and authorized facility of WWBN(FM) on Channel 268A at Tuscola Michigan because WWBN(FM) is authorized pursuant to Section 73215 with regard to WRVF(FM) Therefore as WRVF(FM) did not initiate this short- spacing and the proposed re-allotment involves no change in the WRVF(FM)rsquos current transmitter site the proposed spacing satisfies the Commissionrsquos allotment requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 6
Fifth under Section 73207 the proposed Channel 268B reference site is short-spaced to WNSN(FM) on Channel 268B at South Bend Indiana The required minimum separation distance is 14 kilometers the actual separation distance is 68 kilometers a short-spacing of 6 kilometers However because the Channel 268B allotment and WNSN(FM) have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Proposed Modifications to Table of Allotments
This proposal provides for the following allotment changes to Section 73202 The Commissionrsquos Table of FM Allotments
Lowell Oil Center (historical) hobth Amsden Maple Grove
Watson lie Mount Gilead
10 0 10 20 30 40 miles
H H H H t I I I I I I
H H H H I I I I I I I I 10 0 10 20 30 40 50 kilometers
CITY GRADE REFERENCE CONTOURS
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 2
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 241A Genoa Ohio Allocation Study Proposed Reference Site
41deg 29rsquo 17rdquo North Latitude 8 3 O 19rsquo 25ldquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(rn) Longitude deg-True (km) (hi) WBVI FOSTORIA BLH 244A 30 41-06-00 1964 4494 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR- F LEAMINGTON 244C1 910 42-00-35 472 8582 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 3
Second under Section 73207 the proposed Channel 248A reference site is short-spaced to WKRK-FM on Channel 246B at Detroit Michigan The required minimum separation distance is 113 kilometers the actual separation distance is 111 kilometers a short-spacing of 2 kilometers Petitioners Channel 247A was initially allocated as a 3 kilowatt100 meter facility and it remains as an equivalent facility Therefore for allotment purposes WKRK-FM can be protected pursuant to Section 73213(c) of the Commissions Rules which requires a minimum separation distance of 105 kilometers The proposed reference coordinates satisfies this requirement
Third under Section 73207 the proposed Channel 247A reference site is short-spaced to WMEE(FM) on Channel 247B at Fort Wayne Indiana The station was authorized to operate from the reference site (its current site) pursuant to the stations request to be processed under Section 73215 The required minimum separation distance is 178 kilometers the actual separation distance is 162 kilometers a short-spacing of 16 kilometers
However the proposed allotment does not create a new short or not exacerbate any short-spacing (under Section 73207) with regard to WMEE(FM) In addition WJZE(FM) already has been approved to operate at the reference site to the extent is affords WMEE(FM) contour protection pursuant to Section 73215 and the proposed allotment contemplates no change in WJZE(FM)s operating parameters Moreover WJZE(FM)s former (pre-Section 73215) transmitter site satisfied the relevant spacing requirement - the Section 73213(c) separation distance of 163 kilometers with regard to WMEE(FM) As shown in Figure 1 the projected city grade reference contour (70 dBu) of the allotment from this former site encompassed
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 4
the proposed community of Genoa this pre-Section 73215 site is provided in Figure 2
An allocation study from
Figure 5 is an Area-to-Locate map for Channel 247A As can be seen there is no present fully-spaced area-to-locate for this allotment
Proposed Channel 268B Oak Harbor Ohio
It is proposed to delete Channel 268B at Toledo and allot Channel 268B to Oak Harbor Ohio This Oak Harbor proposal is mutually exclusive with the current Toledo allotment As no change in the reference site is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Oak Harbor as shown in Figure 1
Below are the Channel 268B Oak Harbor reference site geographic coordinates
41O 40 23 North Latitude 83O 25 31 West Longitude
The existing Channel 268B reference coordinates do not satisfy Section 73201 requirements with respect to five stations as shown by the allocation study provided in Figure 4 Each short-spacing is discussed below
First under Section 73207 the proposed Channel 268B reference site is short-spaced to WMJK(FM) on Channel 265A at Clyde Ohio The required minimum separation distance is 69 kilometers the actual separation distance is 64 kilometers a short-spacing of 5 kilometers WMJK(FM) is a 3 kilowatt100 meter type Class A facility and therefore is processed pursuant to Section
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 5
13213 of the Rules as the short-spacing (under Section 13207) is not exacerbated
Second under Section 73207 the proposed Channel 268B reference site is short-spaced to WNCO-FM on Channel 267B at Ashland Ohio The required minimum separation distance is 169 kilometers the actual separation distance is 129 kilometers a short-spacing of 40 kilometers However because the Channel 268B allotment and WNCO-FM have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Third under Section 73207 the proposed Channel 268B reference site is short-spaced to a Canadian allotment on Channel 268A The required minimum separation distance is 210 kilometers the actual separation distance is 167 kilometers a short-spacing of 43 kilometers This Canadian allotment is a specially negotiated short-spaced allotment Therefore because the proposed allotment does not involve a change in the relevant site this previously accepted spacing should satisfy the Commissionrsquos allocation requiremements
Fourth under Section 73207 the proposed Channel 268B reference site is short-spaced to the current licensed and authorized facility of WWBN(FM) on Channel 268A at Tuscola Michigan because WWBN(FM) is authorized pursuant to Section 73215 with regard to WRVF(FM) Therefore as WRVF(FM) did not initiate this short- spacing and the proposed re-allotment involves no change in the WRVF(FM)rsquos current transmitter site the proposed spacing satisfies the Commissionrsquos allotment requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 6
Fifth under Section 73207 the proposed Channel 268B reference site is short-spaced to WNSN(FM) on Channel 268B at South Bend Indiana The required minimum separation distance is 14 kilometers the actual separation distance is 68 kilometers a short-spacing of 6 kilometers However because the Channel 268B allotment and WNSN(FM) have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Proposed Modifications to Table of Allotments
This proposal provides for the following allotment changes to Section 73202 The Commissionrsquos Table of FM Allotments
Lowell Oil Center (historical) hobth Amsden Maple Grove
Watson lie Mount Gilead
10 0 10 20 30 40 miles
H H H H t I I I I I I
H H H H I I I I I I I I 10 0 10 20 30 40 50 kilometers
CITY GRADE REFERENCE CONTOURS
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 2
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 241A Genoa Ohio Allocation Study Proposed Reference Site
41deg 29rsquo 17rdquo North Latitude 8 3 O 19rsquo 25ldquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(rn) Longitude deg-True (km) (hi) WBVI FOSTORIA BLH 244A 30 41-06-00 1964 4494 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR- F LEAMINGTON 244C1 910 42-00-35 472 8582 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 4
the proposed community of Genoa this pre-Section 73215 site is provided in Figure 2
An allocation study from
Figure 5 is an Area-to-Locate map for Channel 247A As can be seen there is no present fully-spaced area-to-locate for this allotment
Proposed Channel 268B Oak Harbor Ohio
It is proposed to delete Channel 268B at Toledo and allot Channel 268B to Oak Harbor Ohio This Oak Harbor proposal is mutually exclusive with the current Toledo allotment As no change in the reference site is proposed there is no 60 dBu gain or loss area created Operation from the reference site identified below will provide the requisite city grade signal to all of Oak Harbor as shown in Figure 1
Below are the Channel 268B Oak Harbor reference site geographic coordinates
41O 40 23 North Latitude 83O 25 31 West Longitude
The existing Channel 268B reference coordinates do not satisfy Section 73201 requirements with respect to five stations as shown by the allocation study provided in Figure 4 Each short-spacing is discussed below
First under Section 73207 the proposed Channel 268B reference site is short-spaced to WMJK(FM) on Channel 265A at Clyde Ohio The required minimum separation distance is 69 kilometers the actual separation distance is 64 kilometers a short-spacing of 5 kilometers WMJK(FM) is a 3 kilowatt100 meter type Class A facility and therefore is processed pursuant to Section
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 5
13213 of the Rules as the short-spacing (under Section 13207) is not exacerbated
Second under Section 73207 the proposed Channel 268B reference site is short-spaced to WNCO-FM on Channel 267B at Ashland Ohio The required minimum separation distance is 169 kilometers the actual separation distance is 129 kilometers a short-spacing of 40 kilometers However because the Channel 268B allotment and WNCO-FM have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Third under Section 73207 the proposed Channel 268B reference site is short-spaced to a Canadian allotment on Channel 268A The required minimum separation distance is 210 kilometers the actual separation distance is 167 kilometers a short-spacing of 43 kilometers This Canadian allotment is a specially negotiated short-spaced allotment Therefore because the proposed allotment does not involve a change in the relevant site this previously accepted spacing should satisfy the Commissionrsquos allocation requiremements
Fourth under Section 73207 the proposed Channel 268B reference site is short-spaced to the current licensed and authorized facility of WWBN(FM) on Channel 268A at Tuscola Michigan because WWBN(FM) is authorized pursuant to Section 73215 with regard to WRVF(FM) Therefore as WRVF(FM) did not initiate this short- spacing and the proposed re-allotment involves no change in the WRVF(FM)rsquos current transmitter site the proposed spacing satisfies the Commissionrsquos allotment requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 6
Fifth under Section 73207 the proposed Channel 268B reference site is short-spaced to WNSN(FM) on Channel 268B at South Bend Indiana The required minimum separation distance is 14 kilometers the actual separation distance is 68 kilometers a short-spacing of 6 kilometers However because the Channel 268B allotment and WNSN(FM) have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Proposed Modifications to Table of Allotments
This proposal provides for the following allotment changes to Section 73202 The Commissionrsquos Table of FM Allotments
Lowell Oil Center (historical) hobth Amsden Maple Grove
Watson lie Mount Gilead
10 0 10 20 30 40 miles
H H H H t I I I I I I
H H H H I I I I I I I I 10 0 10 20 30 40 50 kilometers
CITY GRADE REFERENCE CONTOURS
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 2
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 241A Genoa Ohio Allocation Study Proposed Reference Site
41deg 29rsquo 17rdquo North Latitude 8 3 O 19rsquo 25ldquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(rn) Longitude deg-True (km) (hi) WBVI FOSTORIA BLH 244A 30 41-06-00 1964 4494 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR- F LEAMINGTON 244C1 910 42-00-35 472 8582 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 5
13213 of the Rules as the short-spacing (under Section 13207) is not exacerbated
Second under Section 73207 the proposed Channel 268B reference site is short-spaced to WNCO-FM on Channel 267B at Ashland Ohio The required minimum separation distance is 169 kilometers the actual separation distance is 129 kilometers a short-spacing of 40 kilometers However because the Channel 268B allotment and WNCO-FM have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Third under Section 73207 the proposed Channel 268B reference site is short-spaced to a Canadian allotment on Channel 268A The required minimum separation distance is 210 kilometers the actual separation distance is 167 kilometers a short-spacing of 43 kilometers This Canadian allotment is a specially negotiated short-spaced allotment Therefore because the proposed allotment does not involve a change in the relevant site this previously accepted spacing should satisfy the Commissionrsquos allocation requiremements
Fourth under Section 73207 the proposed Channel 268B reference site is short-spaced to the current licensed and authorized facility of WWBN(FM) on Channel 268A at Tuscola Michigan because WWBN(FM) is authorized pursuant to Section 73215 with regard to WRVF(FM) Therefore as WRVF(FM) did not initiate this short- spacing and the proposed re-allotment involves no change in the WRVF(FM)rsquos current transmitter site the proposed spacing satisfies the Commissionrsquos allotment requirements
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 6
Fifth under Section 73207 the proposed Channel 268B reference site is short-spaced to WNSN(FM) on Channel 268B at South Bend Indiana The required minimum separation distance is 14 kilometers the actual separation distance is 68 kilometers a short-spacing of 6 kilometers However because the Channel 268B allotment and WNSN(FM) have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Proposed Modifications to Table of Allotments
This proposal provides for the following allotment changes to Section 73202 The Commissionrsquos Table of FM Allotments
Lowell Oil Center (historical) hobth Amsden Maple Grove
Watson lie Mount Gilead
10 0 10 20 30 40 miles
H H H H t I I I I I I
H H H H I I I I I I I I 10 0 10 20 30 40 50 kilometers
CITY GRADE REFERENCE CONTOURS
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 2
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 241A Genoa Ohio Allocation Study Proposed Reference Site
41deg 29rsquo 17rdquo North Latitude 8 3 O 19rsquo 25ldquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(rn) Longitude deg-True (km) (hi) WBVI FOSTORIA BLH 244A 30 41-06-00 1964 4494 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR- F LEAMINGTON 244C1 910 42-00-35 472 8582 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
du Treil Lundin amp Rackley Inc Consulting Engineers
Page 6
Fifth under Section 73207 the proposed Channel 268B reference site is short-spaced to WNSN(FM) on Channel 268B at South Bend Indiana The required minimum separation distance is 14 kilometers the actual separation distance is 68 kilometers a short-spacing of 6 kilometers However because the Channel 268B allotment and WNSN(FM) have been continually short-spaced since prior to 1964 any site modification would be processed pursuant to Section 73213(a) Therefore the proposed spacing satisfies the Commissionrsquos allocation requirements
Proposed Modifications to Table of Allotments
This proposal provides for the following allotment changes to Section 73202 The Commissionrsquos Table of FM Allotments
Lowell Oil Center (historical) hobth Amsden Maple Grove
Watson lie Mount Gilead
10 0 10 20 30 40 miles
H H H H t I I I I I I
H H H H I I I I I I I I 10 0 10 20 30 40 50 kilometers
CITY GRADE REFERENCE CONTOURS
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 2
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 241A Genoa Ohio Allocation Study Proposed Reference Site
41deg 29rsquo 17rdquo North Latitude 8 3 O 19rsquo 25ldquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(rn) Longitude deg-True (km) (hi) WBVI FOSTORIA BLH 244A 30 41-06-00 1964 4494 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR- F LEAMINGTON 244C1 910 42-00-35 472 8582 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Lowell Oil Center (historical) hobth Amsden Maple Grove
Watson lie Mount Gilead
10 0 10 20 30 40 miles
H H H H t I I I I I I
H H H H I I I I I I I I 10 0 10 20 30 40 50 kilometers
CITY GRADE REFERENCE CONTOURS
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 2
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 241A Genoa Ohio Allocation Study Proposed Reference Site
41deg 29rsquo 17rdquo North Latitude 8 3 O 19rsquo 25ldquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(rn) Longitude deg-True (km) (hi) WBVI FOSTORIA BLH 244A 30 41-06-00 1964 4494 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR- F LEAMINGTON 244C1 910 42-00-35 472 8582 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 2
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 241A Genoa Ohio Allocation Study Proposed Reference Site
41deg 29rsquo 17rdquo North Latitude 8 3 O 19rsquo 25ldquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(rn) Longitude deg-True (km) (hi) WBVI FOSTORIA BLH 244A 30 41-06-00 1964 4494 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR- F LEAMINGTON 244C1 910 42-00-35 472 8582 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 3
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Channel 247A Genoa Ohio Allocation Study Former Non-Section 73215 Licensed Site (BLH-19930823KD)
41 O 29lsquo 51ldquo North Latitude 83O 16rsquo 12rdquo West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True (km) (km) WBVI FOSTORIA BLH 244A 30 41-06-00 2013 4738 310 67709 OH LIC C 19970721KA 967 88 083-28-32
CHYR-FM LEAMINGTON 244C1 910 42-00-35 456 8185 900 94837 ON OPE C 967 145 082-33-45 (Existing short-spacing to a specially negotiated Canadian station)
WKRK-FM DETROIT BLH 246B 150 42-28-58 28 10957 1130 9618 MI LIC C 19940512KD 971 272 083-12-19 (Section 73213fc) minimum separation distance of 105 kilometers is satisfied)
WMEE FORT WAYNE BLH 247B 260 41-06-42 2557 16684 1780 51726 IN LIC C 19890914KB 973 210 085-11-43 (Section 73213ic) minimum separation distance of 163 kilometers is satisfied)
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
5 0 5 10 15 20 miles I H H I I I I I
5 0 5 10 15 20 25 kilometers I H H I I I I I 1
CHANNEL 247A AREA-TO-LOCATE MAP
PREPARE FOR CLEAR CHANNEL COMMUNICATIONS
du Treil Lundin amp Rackley Inc Sarasota Florida
Figure 4
TECHNICAL EXHIBIT PETITION FOR RULE MAKING
Proposed Channel WRVF-FM Channel 268B Oak Harbor Proposed Reference Site
41O 40 23 North Latitude 83O 25 31 West Longitude
Call City Channel ERP(kW) Latitude Bearing Dist Req Status State FCC File No Freq HAAT(m) Longitude deg-True ( k m ) ( k m ) WMJK CLYDE BMLH 265A 30 41-14-57 1377 6362 690 58344 OH LIC C 19931119KA 1009 91 082-54-47 (WMJK is Section 73213(cI to WRVF(FM1 existing short-spacing as it was initially authorized on October 17 19781
WRIF DETROIT BLH 266B 110 42-27-13 139 8936 740 11278 MI LIC C 19990708KC 1011 291 083-09-50
WNCO-FM ASHLAND BLH 267B 500 40-50-25 1357 12871 1690 2925 OH LIC C 20001218AAJ 1013 152 082-21-26 (WMJK is Section 73 213 ia1 to WRvF(FM1 as it was initially authorized July 26 19461
WRVF TOLEDO BLH 268B 410 41-40-23 1071 00 62188 OH LIC C 20020503AAB 1015 148 083-25-31 (Subject station of concern initially authorized December 12 19461
SARNIA 268A 42-58-20 300 16738 2100 1015 082-23-48 95643 ON C
(Existing short-spacing to a specially negotiated Canadian allotment)
WWBN TUSCOLA BPH 268A 18 43-12-00 3564 16997 1780 20448 MI CP C 20010129ADG 1015 149 083-33-30 (WWBN(FM1 at Tuscola sought Section 73215 processing to WRVF(FM1
WWBN TUSCOLA BLH 268A 60 43-16-06 3579 17733 1780 20448 MI LIC C 19971103KD 1015 100 083-30-20 (WBN(FM1 at Tuscola sought Section 73215 processing to WRVFIFM)
SOUTH BEND BMLH 268B 130 41-37-00 2694 23266 2410 IN LIC C 19900206KG 1015 296 086-13-01
WNSN 73984 (WNSN is Section 73213lal to WRvF(FM) as it was initially authorized March 21 19621
WDET-FM DETROIT BLED 270B 480 42-21-06 215 8112 740 71189 MI LIC C 19980624KB 1019 169 083-03-48
