LPFM Portland Metro Review: Licensed-CP's-Applications

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  • #2771
    Andy Brown
    Participant

    The FCC has dismissed the LPFM application of P:Ear as per the applicant’s request.

    Originally MX group #296 consisted of Yale Union and P:Ear. Yale Union had its application dismissed as part of a mutual settlement.

    P:Ear had proposed to put its antenna on Rocky Butte’s microwave relay tower.

    Here is their request:

    http://licensing.fcc.gov/cgi-bin/prod/cdbs/forms/prod/getimportletter_exh.cgi?import_letter_id=49545

    Previous to acting on this request, the FCC sent them notice that they were requesting to be on an unregistered tower and needed to register it. This is wholly inaccurate, as the tower proposed is indeed registered. It’s a moot point now, but curious nonetheless.

    I have no idea why they dropped their CP. Probably money, inability to provide programming, and their mysterious relationship with KXRY/Common Frequency.

    Here is the FCC’s letter:

    http://licensing.fcc.gov/cgi-bin/prod/cdbs/forms/prod/getimportletter_exh.cgi?import_letter_id=49090

    Tower:

    http://wireless2.fcc.gov/UlsApp/AsrSearch/asrRegistration.jsp?regKey=601456

    I do not know if Yale Union can now file successfully for reinstatement of their application for this frequency. My original research for 97.5 showed K248BS in Newberg now at only 3 Watts but also a CP at 65 Watts, another LPFM CP in Hood River, class C1 KNLR in Bend, class C2 KSLH in Gleneden Beach and a class C3 Vacancy in Manzanita. The first adjacent list is either too far away or too low in power to be much of a concern.

    #2772
    Andy Brown
    Participant

    Here’s an updated manifest of LPFM’s (APP, CP, CP MOD, LIC) within 50 km of Stonehenge (KGON tower).

    http://tinyurl.com/q3w8en8

    There are still unresolved MX (mutually exclusive, meaning only one permit to construct can be granted amongst these applications) groups seeking 96.7, 99.1, 100.7, 101.5, 102.5 and 105.5.

    #2773
    Andy Brown
    Participant

    Rusting Sprocket has applied to amend its CP for 106.3 due to anticipated interference. They propose to move to 97.5, the available frequency vacated by the self dismissal of P:Ear’s application on that frequency.

    http://tinyurl.com/lk6vmug

    According to Todd Urick of Common Frequency, the FCC has granted moves of over +- 3 channels to not only licensees seeking interference displacement but also to permittees like Rusting Sprocket.

    http://transition.fcc.gov/fcc-bin/fmq?list=0&facid=196313

    The list of potential co channel interference sources on 97.5 is less intimidating than going up against KLOO on 106.3. The list contains K248BS in Newberg now at only 3 Watts but also a CP at 65 Watts, another LPFM CP in Hood River, class C1 KNLR in Bend, class C2 KSLH in Gleneden Beach and a class C3 Vacancy in Manzanita. The first adjacent list is either too far away or too low in power to be much of a concern.

    KLOO has been on 106.3 since it was forced to move there from 106.1 in 1988 to enable the creation of Vancouver, WA’s first FM service on 105.9 in 1989. Hey, I know a lot about that one 🙂

    According to Urick a station in Sacramento (that he did the paperwork for) received such a waiver of the minor modification rule of up or down 3 channels using the same criteria, although in that proceeding there was a petition to deny filed against the permittee. No petition to deny has been filed against Rusting Sprocket.

    http://tinyurl.com/kr28u7k

    Other LPFM’s are facing the same issues, that is, their proposals are awash in approximately 50 dBu of co channel interference.

    #2774
    Andy Brown
    Participant

    “I don’t understand the 3 wire feed at all.”

    I believe this constitutes a “skirt fed” example of slant wire shunt feeding. This would then be a “self tuned” arrangement and less expensive than caps, inductors and a messy, more expensive arrangement. It also offers optimum bandwidth.

    http://www.hatdaw.com/papers/Dawson_Slant_Wire_Shunt_Fed_IEEE_BTS_2010.pdf

    #2775
    Andy Brown
    Participant

    Freeform Beaverton is now proposing to move to SE Portland.

    http://tinyurl.com/n77vlkt

    This amendment to their grant to change channels does not show a channel spacing study, so it appears the illustrious Mr. Urick has once again submitted an incomplete set of paperwork. He also continues to refer to the proposal as serving Beaverton when that’s a total laugher. He also refers to the move as 5.x km when it appears to be about 12 km. Does Todd think the engineers at the FCC are idiots? Shall we have a pool to see how many times he needs to amend this to get it right and/or whether the FCC will allow this rather large scale move which clearly is against the rules which I’ve cited many times?

    #2776
    Andy Brown
    Participant

    Also, because the proposal constitutes a major change and major changes are not allowed except within the appropriate window, this will probably be returned. A move of greater than 5.6 km constitutes a major change, just for clarification. Also without a channel study, the application is incomplete and will probably be returned.

    http://tinyurl.com/nfs5fjy

    #2777
    Andy Brown
    Participant

    The MX for 105.5 is heating up.

    Portland State University (PSU) has filed a Petition to Deny against its competitors, The Reed Institute (Reed) and Portland Russia Media Center (PRMC).

    The Petition To Deny filed by PSU:

    https://licensing.fcc.gov/cdbs/CDBS_Attachment/getattachment.jsp?appn=101646585&qnum=5000&copynum=1&exhcnum=1

    The reply filed by PRMC:

    https://licensing.fcc.gov/cdbs/CDBS_Attachment/getattachment.jsp?appn=101646934&qnum=5000&copynum=1&exhcnum=1

    If those links expire (which /getattachment links seem to do), you can access these filings at:

    http://licensing.fcc.gov/cgi-bin/ws.exe/prod/cdbs/pubacc/prod/corrp_list.pl?Application_id=1622139&File_Prefix=BNPL&App_Arn=20131104ATH&Facility_id=193599

    After that loads, click on the links therein and scroll down for the attachment link at the bottom of the form.

    It’s an interesting argument that is about the status of PSU’s independence from the state system which although was passed had not yet been implemented, resulting in PSU losing a point in the comparative process which they are petitioning to get back, since they did not explain initially to the FCC what was going on.

    Of course, Reed, whom has never amended their application and are proposing a signal that barely covers the Reed College Campus from site coordinates that have never been verifiable (looks like Todd U. copied the PSU application near verbatim), PSU later amended its coordinates to reflect the actual site they were proposing which can be seen here:

    https://maps.google.com/?q=http:%2F%2Ftransition.fcc.gov%2Ffcc-bin%2Fcontourplot.kml%3Fgmap%3D2%26appid%3D1634905%26call%3DNEW%26freq%3D105.5%26contour%3D60%26city%3DPORTLAND%26state%3DOR.kml&ll=45.509664,-122.683342&spn=0.002113,0.002905&t=h&z=19

    on the Penthouse of the multistory residence.

    Meanwhile, Reed is proposing the site here:

    https://maps.google.com/?q=http:%2F%2Ftransition.fcc.gov%2Ffcc-bin%2Fcontourplot.kml%3Fgmap%3D2%26appid%3D1622139%26call%3DNEW%26freq%3D105.5%26contour%3D60%26city%3DPORTLAND%26state%3DOR.kml&ll=45.509715,-122.681923&spn=0.002103,0.002905&t=h&z=19

    which is a block and half away, yet they describe the site as on a penthouse roof when the coordinates specified are on a one story building. The 5″ difference in the original coordinates specified by both parties and PSU’s corrected amended coordinates appears to be an error caused by not converting GPS WSG84/NAD83 coordinates to NAD27 coordinates as required by the FCC. Amended by PSU a long time ago and not amended by Reed. A minor point, but I would have mentioned it if I was involved in PSU’s petition to deny since it reflects poor engineering by Reed who after all is proposing a signal that will barely reach their campus. What is that all about?

    Another Todd blunder?

    Meanwhile, having exchanged emails with the GM of PRMC numerous times, they are not interested in time sharing from Reed’s proposed site should the FCC deny this petition by PSU to reinstate their lost point in the MX analysis and restore the three way bottleneck that previously existed. PRMC wants to put their site out in east county. However, their GM was under the impression their signal was going to cover a lot more ground than it will, reaching into Vancouver and SE Portland reliably. Not going to happen and I told him so. It appears no one has learned the lessons of KXRY thinking their signal was going to cover the whole metro. BTW, the difference between KXRY’s signal at 7 W ERP and a signal at their location with 100 W equivalent coverage is very small, the full LPFM pushing its 60 dBu contour out maybe 2 km further, clearly not enough from PRMC’s proposed site @ 44.6 W to reach Vancouver or SE Portland with all the co channel interference they will be encountering.

    PSU’s & Reed proposal:

    https://maps.google.com/?q=http:%2F%2Ftransition.fcc.gov%2Ffcc-bin%2Fcontourplot.kml%3Fgmap%3D2%26appid%3D1634905%26call%3DNEW%26freq%3D105.5%26contour%3D60%26city%3DPORTLAND%26state%3DOR.kml&ll=45.509715,-122.683296&spn=0.190311,0.371819&t=m&z=12

    PRMC’s proposal:

    https://maps.google.com/?q=http:%2F%2Ftransition.fcc.gov%2Ffcc-bin%2Fcontourplot.kml%3Fgmap%3D2%26appid%3D1579734%26call%3DNEW%26freq%3D105.5%26contour%3D60%26city%3DPORTLAND%26state%3DOR.kml&ll=45.525592,-122.506828&spn=0.190258,0.371819&t=m&z=12

    #2778
    Andy Brown
    Participant

    The logjam at 101.5 appears to have been resolved. The FCC has granted a CP to Tool Shed who jointly proposed with Cascade Community Radio a novel solution to the MX 295 situation. An earlier proposal to move these two applicants farther apart was denied since the move was in excess of that allowed. The new proposal seems to be more of the same but the FCC has approved Tool Shed’s request to move way out in the southwest of town, well beyond Portland’s city limits out past Tigard to somewhere up in the hills above King City. Cascade’s application remains un approved although they requested moving closer in from Rocky Butte to somewhere along MLK Blvd.

    Todd Urick’s engineering is so incomplete and lackluster IMO that it is hard to understand why the FCC would approve this arrangement after denying a similar one a few months ago. The two stations, according to the proposal would both broadcast simultaneously and only be 18 km apart although the application states they would be 24 km apart (the required minimum for co channel LPFM’s), but not so when you plug the two sets of new coordinates into a distance calculator. It appears Urick has proposed moving Cascade’s proposed site eastward but has actually moved it westward. With Tool Shed’s application now approved, it would appear Cascade’s amended application will have to be resubmitted with yet another set of coordinates reflecting a move eastward towards Gresham and not westward to somewhere along MLK. Todd doesn’t seem to be able to get anything correct on his first attempts based on his recent history of mistakes.

    http://tinyurl.com/larm5nu

    New Tool Shed:

    https://maps.google.com/?q=http:%2F%2Ftransition.fcc.gov%2Ffcc-bin%2Fcontourplot.kml%3Fgmap%3D2%26appid%3D1640533%26call%3DNEW%26freq%3D101.5%26contour%3D60%26city%3DPORTLAND%26state%3DOR.kml&ll=45.418214,-122.823372&spn=0.190621,0.371819&t=m&z=12

    https://licensing.fcc.gov/cdbs/CDBS_Attachment/getattachment.jsp?appn=101640533&qnum=5100©num=1&exhcnum=1

    https://licensing.fcc.gov/cdbs/CDBS_Attachment/getattachment.jsp?appn=101640517&qnum=5100©num=1&exhcnum=1

    #2779
    Andy Brown
    Participant
    #2780
    Andy Brown
    Participant

    The MX at 105.5 continues to generate money for the attorneys as petitions, replies and associated filings continue to pile up.

    The latest is that Reed College is claiming that Portland Russia Media Center (PRMC) has no site assurance and should be dismissed, PRMC is still claiming that Portland State University (PSU) should not be allowed the diversity point that PSU is trying to get back due to the FCC’s lack of information about the break up of the higher education system in Oregon from one central body into individual bodies,

    The latest filings:

    http://licensing.fcc.gov/cgi-bin/prod/cdbs/forms/prod/getimportletter_exh.cgi?import_letter_id=52697

    https://licensing.fcc.gov/cdbs/CDBS_Attachment/getattachment.jsp?appn=101649242&qnum=5000&copynum=1&exhcnum=1

    List of all the filings if the above links expire or if you want to see them all:

    http://licensing.fcc.gov/cgi-bin/ws.exe/prod/cdbs/pubacc/prod/corrp_list.pl?Application_id=1579734&File_Prefix=BNPL&App_Arn=20131113AED&Facility_id=193303

    This all brings back memories to me from the past and I have to laugh. I think the same b.s. is going to flow with the remaining MX in Portland at 100.7 once the FCC makes the cuts. 6 applicants remain on that one.

    http://tinyurl.com/q3w8en8

    #2781
    Andy Brown
    Participant

    An LPFM CP was granted to Community Alliance Of Tenants for 96.7. Explanation below:

    http://feedback.pdxradio.com/topic/lpfm-portland-metro-review-licensed-cps-applications#post-198170

    (two posts up)

    #2782
    Andy Brown
    Participant
    #2783
    Andy Brown
    Participant

    There has been some action on the 6 way log jam at 100.7 whereby various “partnerships” and proposed time share solutions are now competing. An actual proposal was filed and one of those applicants not included has filed an objection. The copy and past of these documents has been edited for clarity, but you should go to the tiny url links at the end of each document I’ve provided if possible to get a much more user friendly experience unless the links expire which they sometime do.

    Before the

    FEDERAL COMMUNICATIONS COMMISSION

    Washington, D.C. 20554 In re Applications in LPFM MX Group 238:

    The Creative Music Guild For a Construction Permit For a New LPFM Station at Portland, Oregon

    )

    ) File No. BNPL-20131114BUV ) Facility ID No. 196305

    ) The Oregon Center For

    )

    The Photographic Arts, For a Construction Permit For a New LPFM Station at Portland, Oregon )

    Metroeast Community Media For a Construction Permit For a New LPFM Station at Gresham, Oregon )

    PARTIAL SETTLEMENT AGREEMENT

    The Creative Music Guild (“CMG”)

    Oregon Center For The Photographic Arts (“OCPA”)

    Metroeast Community Media (“Metroeast”)

    (collectively “CH 264 Applicants”) have reached a mutual partial settlement agreement regarding the use of Channel 264L1 in the Portland area.

    This Partial Settlement Agreement was designed in a manner that would most efficiently use Channel 264L1 in Portland through a time sharing arrangement. No simultaneous operations are proposed. SLAVIC COMMUNITY CENTER OF NW, INC (Fac ID No 196785) and JEHOVAH JIREH INTERNATIONAL MISSION (Fac ID No 194894) have proposed a 10-point aggregated time share for 100.7 where each applicant would get 12-hours a day. This document proposes a timely-filed timeshare of 15 points which should trump the SLAVIC-JEHOVAH proposed point-combining timeshare.

    All applicants are proposing at least 10 hours per week. As both of these applicants are in the same MX group and none are proposing a channel change as a part of this partial settlement agreement, the points for these applicants can be aggregated and as a result, the CH 264 Applicants can claim a combined 15 points.

    OPERATION AGREEMENT

    264 Metroeast Community Media

    20131114AXB

    196088

    264 The Creative Music Guild 264 The Oregon Center For The Photographic Arts,

    OR Portland OR Portland WA Vancouver 264 Enlighten State Academic Services, Corp 20131114BNN 196942

    ) File No. BNPL- 20131114BUZ ) Facility ID No. 196398

    ) ) File No. BNPL-20131114AXB ) Facility ID No. 196088

    20131114BUV 201311114BUZ

    196305 196398

    CMG Monday through Sunday: 8:00AM~4:00PM OCPA Monday through Sunday: 4:00PM~Midnight Metroeast Monday through Sunday: Midnight to 8:00AM

    FINDINGS

    A settlement agreement has been reached between the CH 264 Applicants in the above captioned proceeding. The CH 264 Applicants have determined it would be in the public interest to enter into this partial settlement agreement in accordance with §73.872(c) of the Commission’s Rules. This settlement represents a group of two applicants that agree that acceptance of this partial settlement would serve the objectives of the Communications Act of 1934, as amended as well as the rules and policies of the Commission. In addition, the settlement will conserve Commission resources, promote spectrum efficiency, promote localism and will result in the expedited implementation of the proposed LPFM stations.

    None of the CH 264 Applicants filed their applications for the purpose of reaching or carrying out such an agreement. The settlement agreements agreed into by the parties contain the entire understandings and undertakings between the parties pertaining to these matters.

    CONCLUSION

    The undersigned ask that the Commission accept this partial settlement agreement with an aggregated score of 15 points.

    CMG OCPA METROEAST (See following pages for signatures.)

    http://tinyurl.com/m75mbg7

    Slavic Community Center has filed an objection:

    OREGON CENTER FOR THE PHOTOGRAPHIC ARTS (BNPL-20131114BUZ) METROEAST COMMUNITY MEDIA (BNPL-20131114AXB) THE CREATIVE MUSIC GUILD (BNPL-20131114BUV)

    INFORMAL OBJECTION

    Slavic Community Center of NW, Inc. (Slavic)1 is objecting to the grant of the above captioned LPFM applications and the associated time share agreement for the reasons herein.

    Applications and time share agreement were not signed by an officer

    §73.3513(a)(3) of the Commission’s Rules states that for a corporation, applications, amendments thereto and related statements of fact required by the FCC (which would include time share agreements) must be signed by an officer of the corporation2. Section II, question 3a of Form 318 specifies that the applicant needs to “list separately each party to the application, as applicable, the applicant, its officers, directors, five percent or greater stockholders, and all other persons and entities with attributable interests.”

    Oregon Center for the Photographic Arts (OCPA)

    OCPA shows their officers on their application to include:  Christopher Rauschenberg  Tom Champion  Ann Kendellen

     Keren Ceballos  Teresa Dooling  Chip Hudson  Eric Merten

    Of these applicants, Rauschenberg and Champion show on the September 9, 2013 annual report for OCPA as President and Secretary respectively3.

    Despite the considerable number of board members and being a long established non- profit public benefit corporation, the application and the time share agreement was signed by Amanda Clem, who holds the title of “Gallery Manager”.

    Ms. Clem is not a party to this application. She is not authorized under §73.3513(a)(3) to sign applications and other statements of fact such as time share agreements on behalf of OCPA. For this reason, OCPA did not properly prosecute the time share

    1 – Slavic is an applicant in MX Group #283 (BNPL-20131114BHV).

    2 – See 47 C.F.R. §73.3513(a)(3).

    3-

    http://records.sos.state.or.us/webdrawer/webdrawer.dll/webdrawer/rec/2895185/view/SOS%20-%20Corp oration%20-%20Business%20Entity%20Filing%20Records%20-%2011183316.PDF

    agreement and furthermore, their Form 318 is not valid as it was not signed by an officer.

    Metroeast Community Media (Metroeast)

    Metroeast shows the parties to their application as follows:  Victoria Alley  Shannon Chisum  Travis Stovall

     Doug Sweet  Bruce Fife  Miguel Tellez  Neri Reyes

     Clark Santee

    The application and time share agreement were signed by Robet Brading who has the title of Executive Director. Robert Brading does not show as a party to this application. He is not authorized under §73.3513(a)(3) to sign applications and other statements of fact such as time share agreements on behalf of Metroeast. For this reason, Metroeast did not properly prosecute the time share agreement and furthermore, their Form 318 is not valid as it was not signed by an officer and therefore making their time share agreement invalid.

    The Creative Music Guild (CMG)

    Slavic does not oppose the application of CMG other than being a party to a time share agreement that includes OCPA and Metroeast.

    Conclusion

    Due to the fact that joint time share agreement was not signed by the officers of OCPA and Metroeast, the time share agreement is not valid and therefore should be denied. In addition, the applications ofr OCPA and Metroeast were not properly signed by an officer in compliance with §73.3513(a)(3) and therefore should be dismissed.

    http://tinyurl.com/p8jytrd

    #3141
    Andy Brown
    Participant

    The 105.5 MX continues to be a volley of paper slung by attorneys laughing all the way to the bank. As I previously noted on numerous occasions, Tenacious Todd prepared an application for Reed Institute to be in on the LPFM window. It was probably part of the deal that landed Todd and his bosses at Common Frequency the keys to Reed’s old Class D license which became KXRY-FM, now operating at 8 Watts on Rocky Butte and whose future is totally dependent on the MetroEast owned translator operating at 28 Watts on 107.1 located at Stonehenge in the West Hills (Healey Heights). The Reed LPFM application specified the same coordinates originally filed on by Portland State University, also competing for 105.5 in the MX mess along with the Portland Russian Media Center. As I pointed out numerous times, those original coordinates did not match the description in the applications, which (in the case of PSU’s app) specified a penthouse on a multi story building and an elevation indicating so. The coordinates however, specified a one story building two blocks from where they meant it to be. Probably a NAD83/WGS84 conversion omission. Portland State corrected this error early on (probably after reading my post here on the forum). Reed did not. PSU is trying to fight off their elimination from the MX due to the SNAFU about the breakup of the Oregon Higher Ed system from being under one umbrella into individual entities, which the FCC originally interpreted as making them a less desirable applicant due to other broadcast holdings around the state. I have written about that earlier in this thread. Now Portland Russian Media Center is filing an informal objection that Reed did not have reasonable site assurance. They themselves have been accused of the same thing in the proceeding for their site in a NE Portland parking lot by Portland State. Here’s a link to the latest filing.

    http://tinyurl.com/kkw2p4j

    If PSU’s MX status is reinstated (and IMO it should be), their application is the most sound of all of them. The building they proposed for their antenna is a dorm of some sort which they own. Their signal will cover the PSU campus quite nicely. They have experience running not only a streaming station, but were running KBPS over the summers for some time in the past. Reeds proposal will barely reach their own campus. PRMC is proposing a signal that they think is going to reach all over the place to reach their target listenership which is not in the actual area to be served by the proposal. Assuming they can escape the proposed site assurance challenge, they will have to time share with PSU but build a separate site of their own.

    Along with the 6 way MX at 100.7, this is the last of the unresolved LPFM MX’s in the Portland Metro. There are quite a few CP’s now on the clock. Remember, these stations will cover about a 5 km (3 mile) radius, so their location is pretty critical to whether or not you will be able to receive them.

    I’ll be generating a map in the near future of all the CP’s proposed coverage and post it in a new thread. I’d like to include 100.7 and 105.5, but my experience in the 105.9 MX (which lasted 10 years) tells me I may have to just leave them off the map or show them with dashed lines or another color. Oh boy, I get to play in Illustrator and Photoshop for hours.

    #3451
    Alfredo_T
    Participant

    If the 104.5 construction permit in Vernonia (KVPB-LP) is built, would K283BL (Way FM) have to change facilities? KVPB-LP might be a fun DX catch from my location in Hillsboro.

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