APPLICATION FOR A NEW LOW POWER DIGITAL TRANSLATOR FOR DTV STATION KLEW-TV AT LEWISTON, IDAHO (BMPCDT-20091009AAR, LICENSE APPLICATION PENDING, BLCDT-20100111ADM). IN THE FCC'S REPORT AND ORDER, AMENDMENTS OF PARTS 73 AND 74 OF THE COMMISSIONS RULES TO ESTABLISH RULES FOR REPLACEMENT DIGITAL LOW POWER TELEVISION TRANSLATOR STATIONS, A NEW REPLACEMENT DIGITAL TELEVISION TRANSLATOR SERVICE WAS CREATED TO PERMIT FULL-SERVICE TELEVISION STATIONS TO CONTINUE TO PROVIDE SERVICE TO VIEWERS WITHIN THEIR COVERAGE AREAS WHO HAVE LOST SERVICE AS A RESULT OF THE DIGITAL TRANSITION. STATION KLEW-TV HAS RECEIVED NUMEROUS COMPLAINTS FROM VIEWERS IN THE AREA TO BE COVERED BY THE PROPOSED TRANSLATOR OF DIFFICULTIES WITH RECEPTION OF THE STATION'S POST-TRANSITION DIGITAL SIGNAL. THESE VIEWERS WERE ABLE TO GET GOOD RECEPTION OF THE STATION'S PRE-TRANSITION ANALOG SIGNAL, AND THE LICENSEE BELIEVES THAT THE PROPOSED TRANSLATOR WILL HELP TO ALLEVIATE THESE DIGITAL RECEPTION ISSUES. SPECIFICALLY, THIS APPLICATION PROPOSES A NEW DIGITAL TRANSLATOR FACILITY ON CHANNEL 22, TO FILL IN A PORTION OF THE KLEW-TV LOSS AREA IN THE VICINITY OF MOSCOW. THE PROPOSED FACILITY WILL OPERATE WITH A DIRECTIONAL EFFECTIVE RADIATED POWER (ERP) OF 1 KILOWATT, AN ANTENNA RADIATION CENTER HEIGHT ABOVE MEAN SEA LEVEL (RCAMSL) OF 1399 METERS, AND EMPLOY A SCALA MODEL SL-8 DIRECTIONAL ANTENNA (ANTENNA ID 23503). THE ANTENNA WILL BE MOUNTED AT THE 24 METER LEVEL ON AN EXISTING 43 METER TOWER. FIGURE 1 DEPICTS THE FCC PREDICTED 47 DBU (GRADE B) CONTOUR FOR THE KLEW-TV ANALOG OPERATION (CH 3, BLCT-19910628KE), THE FCC PREDICTED 41 DBU (NOISE-LIMITED) CONTOUR FOR THE KLEW-TV DIGITAL OPERATION (CH 32, BMPCDT-20091009AAR, LICENSE APPLICATION PENDING, BLCDT-20100111ADM) AND THE FCC PREDICTED 51 DBU CONTOUR FOR THE PROPOSED LOW POWER DIGITAL TRANSLATOR OPERATION. AS SHOWN, THERE IS COMMON AREA WHERE THE FORMER ANALOG GRADE B AND PROPOSED TRANSLATOR 51 DBU CONTOURS OVERLAP. FURTHERMORE, IT IS BELIEVED THAT THE SLIGHT EXTENSION OF THE PROPOSED TRANSLATOR CONTOUR BEYOND THE ANALOG GRADE B CONTOUR IS DE MINIMIS. CANADIAN PROTECTION - THE PROPOSED DIGITAL CHANNEL 22 OPERATION WILL BE LOCATED 243 KILOMETERS FROM THE CLOSEST POINT OF THE US-CANADIAN COMMON BORDER. SINCE, THERE ARE NO SPECIFIC RULES REGARDING DIGITAL LOW POWER STATIONS ALONG THE COMMON BORDER, THE RULES REGARDING FULL POWER DTV STATIONS WERE EMPLOYED. SPECIFICALLY, CONSIDERATION WAS GIVEN TO THE EXISTING US-CANADIAN TV AGREEMENT (1994) AND LETTER OF UNDERSTANDING (LOU) BETWEEN THE FCC AND INDUSTRY CANADA RELATED TO DTV SERVICE ALONG THE COMMON BORDER (SEPTEMBER 12, 2000). PURSUANT TO THE EXISTING AGREEMENT AND LOU, DTV STATIONS WILL BE REFERRED IF THE PERTINENT INTERFERING CONTOUR WOULD FALL WITHIN THE TERRITORY OF THE OTHER COUNTRY. THE PERTINENT INTERFERING CONTOUR APPLICABLE TOWARDS CO-CHANNEL NTSC STATIONS IS THE 30.2 DBU, F(50,10) CONTOUR. THE PERTINENT INTERFERING CONTOUR APPLICABLE TOWARDS CO-CHANNEL DTV OPERATIONS IS THE 19.5 DBU, F(50,10) CONTOUR. FIGURE 2 DEPICTS THE LOCATIONS OF BOTH THE 19.5 DBU, F(50,10) AND 30.2 DBU, F(50,10) INTERFERING CONTOURS BASED ON THE PROPOSED DTV CHANNEL 22 FACILITIES. AS INDICATED ON FIGURE 2, NEITHER THE 19.5 DBU, F(50,10) NOR THE 30.2 DBU, F(50,10) CONTOUR OVERLAPS CANADIAN LAND AREA. THEREFORE, IT IS NOT BELIEVED NECESSARY TO REFER THE PROPOSAL TO CANADA. RFR COMPLIANCE - THE PROPOSED FACILITIES WERE EVALUATED IN TERMS OF POTENTIAL RADIOFREQUENCY RADIATION EXPOSURE AT 2 METERS ABOVE GROUND LEVEL IN ACCORDANCE WITH OST BULLETIN NO. 65, EVALUATING COMPLIANCE WITH FCC-SPECIFIED GUIDELINES FOR HUMAN EXPOSURE TO RADIOFREQUENCY RADIATION. THIS BULLETIN PROVIDES ASSISTANCE IN DETERMINING WHETHER FCC-REGULATED TRANSMITTING FACILITIES, OPERATIONS OR DEVICES COMPLY WITH LIMITS FOR HUMAN EXPOSURE TO RADIOFREQUENCY (RF) ELECTROMAGNETIC FIELDS ADOPTED BY THE COMMISSION IN 1996. THE CALCULATED POWER DENSITY AT 2 METERS ABOVE GROUND LEVEL AT THE BASE OF THE TOWER WAS CALCULATED USING THE APPROPRIATE EQUATION CONTAINED IN THE BULLETIN. USING A WORST-CASE VERTICAL RELATIVE FIELD VALUE OF 0.25 (SEE FIGURE 3), A MAXIMUM ERP OF 1 KILOWATT, AND AN ANTENNA CENTER OF RADIATION HEIGHT ABOVE GROUND LEVEL OF 24 METERS, THE CALCULATED POWER DENSITY AT TWO METERS ABOVE GROUND LEVEL AT THE BASE OF THE TOWER IS 0.0043 MILLIWATT PER SQUARE CENTIMETER (MW/CM2), OR 1.24 PERCENT OF THE COMMISSION'S RECOMMENDED LIMIT APPLICABLE TO GENERAL POPULATION/UNCONTROLLED EXPOSURE AREAS (0.347 MW/CM2 FOR TV CHANNEL 22). THEREFORE, THE FACILITY COMPLIES WITH THE FCCS RF EMISSION RULES. THE SITE WILL BE APPROPRIATELY MARKED WITH RFR WARNING SIGNS. FURTHERMORE, A PROTOCOL WILL BE IN PLACE IN THE EVENT THAT WORKERS OR OTHER AUTHORIZED PERSONAL CLIMB THE TOWER TO ENSURE THAT APPROPRIATE MEASURE WILL BE TAKEN TO ASSURE WORKER SAFETY WITH RESPECT TO RADIO FREQUENCY RADIATION EXPOSURE. SUCH MEASURES INCLUDE REDUCING THE AVERAGE EXPOSURE BY SPREADING OUT THE WORK OVER A LONGER PERIOD OF TIME, WEARING ACCEPTED RFR PROTECTIVE CLOTHING AND/OR RFR EXPOSURE MONITORS OR SCHEDULING WORK WHEN THE STATIONS ARE AT REDUCED POWER OR SHUT DOWN. IT IS NOTED THAT THIS STATEMENT ONLY ADDRESSES THE POTENTIAL FOR RADIOFREQUENCY ELECTROMAGNETIC FIELD EXPOSURE.