THE PROPOSED KLEW-DT MINOR CHANGE APPLICATION WILL COMPLY WITH THE 0.5% DE MINIMIS INTERFERENCE PROTECTION REQUIREMENTS, WILL PROVIDE THE REQUISITE CITY GRADE SIGNAL TO ALL OF LEWISTON (SEE FIGURE 1) AND WILL PROVIDE 102% REPLICATION OF THE AUTHORIZED OPERATION (BPCDT-19991021ACJ)/APPENDIX B SERVICE POPULATION. THE RELEVANT NET SERVICE POPULATION FIGURES ARE AS FOLLOWS BASED ON AN OET-69 LONGLEY-RICE COVERAGE ANALYSIS CONSIDERING LOSSES DUE TO TERRAIN AND INTERFERENCE, USING 2000 CENSUS DATA: KLEW-DT AUTHORIZED/APPENDIX B CHANNEL 32 OPERATION: 133,000 PERSONS KLEW-DT PROPOSED CHANNEL 32 OPERATION: 135,582 PERSONS THE PROPOSED OPERATION WILL PROVIDE THE NECESSARY PROTECTION TO RADIO ASTRONOMY INSTALLATIONS AND FCC MONITORING STATIONS. CANADIAN COORDINATION - THE PROPOSED TRANSMITTER SITE IS LOCATED 282.6 KM FROM THE US-CANADIAN BORDER. THEREFORE, IT IS REPECTFULLY REQUESTED THAT THE FCC COORDINATE THIS PROPOSAL WITH CANADA, IF NECESSARY. IT IS NOTED THAT THE PROPOSED FACILITIES ARE FULLY-SPACED TO ALL PERTINENT CANADIAN NTSC AND DTV ALLOTMENTS AS DEMONSTRATED IN THE ATTACHED CANADIAN SEPARATION STUDY (FIGURE 3). RFR COMPLIANCE - THE PROPOSED FACILITIES WERE EVALUATED IN TERMS OF POTENTIAL RADIO FREQUENCY (RF) ENERGY EXPOSURE AT GROUND LEVEL TO WORKERS AND THE GENERAL PUBLIC. THE RADIATION CENTER FOR THE PROPOSED DTV ANTENNA IS LOCATED 48 METERS ABOVE GROUND LEVEL. THE MAXIMUM DTV ERP IS 133 KW (HORIZONTAL POLARIZATION). A WORST-CASE VERTICAL PLANE RELATIVE FIELD VALUE OF 0.2 (FOR ANGLES BELOW 60 DEGREES DOWNWARD) IS PRESUMED FOR THE ANTENNA'S DOWNWARD RADIATION (SEE FIGURE 2). THE CALCULATED POWER DENSITY AT A POINT 2 METERS ABOVE GROUND LEVEL IS 0.084 MW/CM2. THIS IS 21.7% OF THE FCC'S RECOMMENDED LIMIT OF 0.387 MW/CM2 FOR CHANNEL 32 FOR AN UNCONTROLLED ENVIRONMENT. HOWEVER, AS THIS IS A MULTIPLE-USER SITE ALL EXISTING AND AUTHORIZED BROADCAST FACILITIES IN THE VICINITY MUST BE CONSIDERED IN THE RFR EVALUATION. IN ADDITION TO KLEW-DT, FM STATIONS KCLK-FM (BLH-19831227AC), KNWV (BLED-20090312ABV) AND KVAB (BLH-1997 OPERATE FROM THE PROPOSED SITE LOCATION. THE POWER DENSITY FOR KCLK-FM WAS CALCULATED TO BE 4.5% OF THE LIMIT BASED ON AN ANTENNA HEIGHT ABOVE GROUND LEVEL OF 86 METERS, AN ERP OF 200 KW (H+V) AND A CONSERVATIVE VERTICAL PLANE RELATIVE FIELD VALUE OF 0.2. THE POWER DENSITY FOR KNWV WAS CALCULATED TO BE 1.7% OF THE LIMIT BASED ON AN ANTENNA HEIGHT ABOVE GROUND LEVEL OF 18 METERS, A TOTAL ERP OF 0.84 KW (H+V) AND A WORST-CASE VERTICAL PLANE RELATIVE FIELD VALUE OF 1.0. THE POWER DENSITY FOR KVAB WAS CALCULATED TO BE 0.6% OF THE LIMIT BASED ON AN ANTENNA HEIGHT ABOVE GROUND LEVEL OF 67 METERS, A TOTAL ERP OF 0.88 KW (H+V) AND A WORST-CASE VERTICAL PLANE RELATIVE FIELD VALUE OF 1.0. THE SUMMATION OF THE ABOVE FRACTIONS OF THE ANSI LIMIT FOR EACH OF THE ABOVE STATIONS IS 0.255. SINCE THIS IS LESS THAN UNITY, THE COMBINED POWER DENSITY AT 2 METERS ABOVE GROUND LEVEL WILL BE LESS THAN THE ANSI RECOMMENDED LIMIT APPLICABLE TO GENERAL POPULATION/UNCONTROLLED EXPOSURE AREAS. THUS, IT IS BELIEVED THAT THE PROPOSED KLEW-DT FACILITY IS IN FULL COMPLIANCE WITH THE FCCS REQUIREMENTS WITH REGARD TO RADIO FREQUENCY RADIATION EXPOSURE. ACCESS TO THE TRANSMITTING SITE IS RESTRICTED AND APPROPRIATELY MARKED WITH RFR WARNING SIGNS. FURTHERMORE, AS THIS IS A MULTI-USER SITE, A PROTOCOL WILL BE IN EFFECT WITH THE OTHER STATIONS IN THE EVENT THAT WORKERS OR OTHER AUTHORIZED PERSONNEL ENTER THE RESTRICTED AREA OR CLIMB THE TOWER TO ENSURE THAT APPROPRIATE MEASURES 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. FINALLY, IT IS NOTED THAT THIS TECHNICAL EXHIBIT ONLY ADDRESSES THE POTENTIAL FOR RADIO FREQUENCY ELECTROMAGNETIC FIELD EXPOSURE.