Go to the Federal Communications Commission homepage at www.fcc.gov

FCC Form 399: Incentive Auction Relocation Reimbursement Fund System

Approved by OMB 3060-1178
Go to the Federal Communications Commission homepage at www.fcc.gov

(REFERENCE COPY - Not for submission)FCC Form 399: Incentive Auction Relocation Reimbursement Fund System

File Number:
0000026327
FRN:
0013597448
Facility ID:
8617
Repack Channel:
9 (High VHF)
Entity:
Broadcaster
Filing Status:
Submitted
Date Submitted:
07/31/2017

Applicant Information

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Applicant Name, Type, and Contact Information

Applicant Address Phone Email Applicant Type

WTVD TELEVISION, LLC

Doing Business As: WTVD TELEVISION, LLC

77 WEST 66TH STREET, 16TH FLR

ATTN: JOHN W. ZUCKER, ESQ.

NEW YORK, NY 10023

United States

+1 (212) 456-7777 john.w.zucker@abc.com Limited Liability Company

Reimbursement Contact Information

Reimbursement Contact Name and Information

Applicant Address Phone Email

[Confidential]

 

 

 


Preparer Contact Information

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Preparer Contact Name and Information

Applicant Address Phone Email

The Preparer is same as the reimbursement contact.

 

 

 

Broadcaster Information and Transition Plan

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Question Response
Will the station be sharing equipment with another broadcast television station or stations (e.g., a shared antenna, co-location on a tower, use of the same transmitter room, multiple transmitters feeding a combiner, etc.)? If yes, enter the facility ID's of the other stations and click 'prefill' to download those stations' licensing information. No
Briefly describe transition plan Please see attachment for WTVD facilities and transition plan details.

Transmitters

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Section Question Response
Transmitter Related Expenses Do you have transmitter related expenses? Yes

Auxiliary Transmitter

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Existing Transmitter Information

Section Question Response
Existing Transmitter Description Type of change Purchase New
Use Auxiliary (Backup)
Description of Use Auxiliary (Backup)
Ownership Owned
Owner  
Site  
Is this transmitter currently shared with another station? No
Is this transmitter currently in operating condition? Yes
Existing Transmitter Manufacturer and Type Manufacturer
Model PTCD40P4i
Year 2010
Type Solid state
IOT Power Type  
Description  
Power capacity  
Solid State Cooling Air
Solid State Power Capacity 16 kw
Other Transmitter Type  

Auxiliary Transmitter

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New Transmitter Costs

Section Question Response
New Transmitter Use Auxiliary (Backup)
Description of Use Auxiliary (Backup)
Change Type Purchase New
Is this a request for upgraded equipment? No
Manufacturer
Model VAXTE-24R44
Transmitter Type Solid state
IOT Power Type  
Other  
Power capacity  
Solid State Cooling Air
Solid State Power Capacity 19.2 kw
Other Transmitter Type  
Justification for New Transmitter The current channel 11 Auxiliary (Backup) transmitter cannot be re-channeled to meet new assignment on channel 9.

Auxiliary Transmitter

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Other Transmitter Costs

Section Question Response
Electrical Service Service Entrance (3 phases 800A 208V) No
Switchgear (industrial 800 amp) No
Transformer (480V) No
Power
Rigid Conduit and Wiring No
Size
Length
Other Electrical Service No
Description  
HVAC Service Does the replacement transmitter require HVAC Service? No
Type
Size
Other Size  
Transmitter Building Addition/Modification or Leasehold Improvement Does the Transmitter Building require an addition, modification, other leashold improvement? No
Size
Channel 14 Costs Is an RF Consulting Engineer needed?
Is a channel 14 Mask Filer needed?
Is additional field engineering time needed?
Number of Days  

Auxiliary Transmitter

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Other Transmitter Cost Not Listed

Information not provided.

Primary Transmitter

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Existing Transmitter Information

Section Question Response
Existing Transmitter Description Type of change Purchase New
Use Primary (Main)
Description of Use  
Ownership Owned
Owner  
Site  
Is this transmitter currently shared with another station? No
Is this transmitter currently in operating condition? Yes
Existing Transmitter Manufacturer and Type Manufacturer
Model PTCD40P4i
Year 2010
Type Solid state
IOT Power Type  
Description  
Power capacity  
Solid State Cooling Air
Solid State Power Capacity 16 kw
Other Transmitter Type  

Primary Transmitter

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New Transmitter Costs

Section Question Response
New Transmitter Use Primary (Main)
Description of Use  
Change Type Purchase New
Is this a request for upgraded equipment? No
Manufacturer
Model VAXTE-24R44
Transmitter Type Solid state
IOT Power Type  
Other  
Power capacity  
Solid State Cooling Air
Solid State Power Capacity 19.2 kw
Other Transmitter Type  
Justification for New Transmitter The current channel 11 Primary (Main) transmitter cannot be re-channeled to meet new assignment on channel 9

Primary Transmitter

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Other Transmitter Costs

Section Question Response
Electrical Service Service Entrance (3 phases 800A 208V) No
Switchgear (industrial 800 amp) No
Transformer (480V) No
Power
Rigid Conduit and Wiring No
Size
Length
Other Electrical Service No
Description  
HVAC Service Does the replacement transmitter require HVAC Service? No
Type
Size
Other Size  
Transmitter Building Addition/Modification or Leasehold Improvement Does the Transmitter Building require an addition, modification, other leashold improvement? No
Size
Channel 14 Costs Is an RF Consulting Engineer needed?
Is a channel 14 Mask Filer needed?
Is additional field engineering time needed?
Number of Days  

Primary Transmitter

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Other Transmitter Cost Not Listed

Information not provided.

Antennas

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Section Question Response
Antenna Related Expenses Do you have antenna related expenses? Yes

Auxiliary Antenna

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Existing Antenna Information

Section Question Response
Existing Antenna Description Type of change Purchase New
Antenna Use Auxiliary (Backup)
Description of Use Auxiliary (Backup)
Ownership Owned
Owner N/A
Site N/A
Is the existing antenna shared with another station or stations? No
Is the existing antenna directional? No
Is antenna in operating condition? Yes
Is antenna located on or in close proximity to an antenna farm? Yes
Existing Antenna Manufacturer and Type Class Full Power
Mounting Side-mount
Antenna position in stack Not in Stack
Polarization Circular
Type Slotted coaxial
Number of Stations Supported N/A
Number of Panels N/A
Design power capacity in use N/A
Lower Limit N/A
Upper Limit N/A
Other Antenna Type N/A
ERP: 45.00 kW
Manufacturer
Model TLS-V8/VP-R S180
Year 2010

Auxiliary Antenna

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New Antenna Costs

Section Question Response
New Antenna Description Use Auxiliary (Backup)
Description of Use Auxiliary (Backup)
Change Type Purchase New
Is this a request for upgraded equipment? No
Ownership Owned
Owner N/A
Is antenna shared? No
Is antenna directional? No
Will antenna be located on or in close proximity to an antenna farm? Yes
New Antenna Manufacturer and Type Class Full Power
Mounting Side-mount
Antenna position in stack Not in Stack
Polarization Circular
Type Slotted coaxial
Number of Stations Supported N/A
Number of Panels/Bays N/A
Lower Limit N/A
Upper Limit N/A
Design power capacity in use N/A
Other Antenna Type N/A
ERP: 45.00 kW
Manufacturer
Model TLS-V8/VPR S180
Year 2018
Justification for New Antenna The current channel 11 Auxiliary (Backup) antenna cannot be re-channeled to meet new assignment on channel 9.

Auxiliary Antenna

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Other Antenna Costs

Section Question Response
Combiner for Shared Antenna Do you need a Combiner for a Shared Antenna? No
Type
Number of channels supported N/A
Frequencies of channels supported N/A
Frequency N/A
Do you need a combiner output splitter/switcher for dual feed lines? N/A
Elbow Complex Do you require the separate purchase of the Elbow Complex? Yes
Broadband or Single Channel? Single Channel
Feed Line Size 4 1/16 inches
Side Mount Brackets Do you require the separate purchase of side mount brackets for a high power antenna? Yes
Pattern Scatter Analysis Do you require separate purchase of pattern scatter analysis for a side mount high or medium power antenna? No
Sweep Test Do you require the sweep testing of transmission line and antenna? Yes

Auxiliary Antenna

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Other Antenna Cost Not Listed

Information not provided.

Primary Antenna

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Existing Antenna Information

Section Question Response
Existing Antenna Description Type of change Purchase New
Antenna Use Primary (Main)
Description of Use N/A
Ownership Owned
Owner N/A
Site N/A
Is the existing antenna shared with another station or stations? No
Is the existing antenna directional? No
Is antenna in operating condition? Yes
Is antenna located on or in close proximity to an antenna farm? Yes
Existing Antenna Manufacturer and Type Class Full Power
Mounting Top-mount single
Antenna position in stack Not in Stack
Polarization Circular
Type Slotted coaxial
Number of Stations Supported N/A
Number of Panels N/A
Design power capacity in use N/A
Lower Limit N/A
Upper Limit N/A
Other Antenna Type N/A
ERP: 45.00 kW
Manufacturer
Model THV-9A11/CP-R O4
Year 2010

Primary Antenna

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New Antenna Costs

Section Question Response
New Antenna Description Use Primary (Main)
Description of Use N/A
Change Type Purchase New
Is this a request for upgraded equipment? No
Ownership Owned
Owner N/A
Is antenna shared? No
Is antenna directional? No
Will antenna be located on or in close proximity to an antenna farm? Yes
New Antenna Manufacturer and Type Class Full Power
Mounting Top-mount single
Antenna position in stack Not in Stack
Polarization Circular
Type Slotted coaxial
Number of Stations Supported N/A
Number of Panels/Bays N/A
Lower Limit N/A
Upper Limit N/A
Design power capacity in use N/A
Other Antenna Type N/A
ERP: 45.00 kW
Manufacturer
Model THV-9A9/CP-R O4
Year 2018
Justification for New Antenna The current channel 11 Primary (Main)antenna cannot be re-channeled to meet new assignment on channel 9

Primary Antenna

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Other Antenna Costs

Section Question Response
Combiner for Shared Antenna Do you need a Combiner for a Shared Antenna? No
Type
Number of channels supported N/A
Frequencies of channels supported N/A
Frequency N/A
Do you need a combiner output splitter/switcher for dual feed lines? N/A
Elbow Complex Do you require the separate purchase of the Elbow Complex? Yes
Broadband or Single Channel? Single Channel
Feed Line Size 6 1/8 inches
Side Mount Brackets Do you require the separate purchase of side mount brackets for a high power antenna? No
Pattern Scatter Analysis Do you require separate purchase of pattern scatter analysis for a side mount high or medium power antenna? No
Sweep Test Do you require the sweep testing of transmission line and antenna? Yes

Primary Antenna

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Other Antenna Cost Not Listed

Name Description

Mounting pole

New channel 9 Primary (Main) antenna requires a shorter mounting pole to maintain current antenna aperture and HAAT.

Transmission Line

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Section Question Response
Transmission Line Related Expenses Do you have transmission line related expenses? No

Tower Equipment And Rigging Costs

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Section Question Response
Tower Equipment or Rigging Costs Changes Do you have tower equipment or rigging costs changes? Yes

Primary Tower

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Existing Tower

Section Question Response
Existing Tower Description Type of change Move Equipment
Tower Use Primary (Main)
Description of Use N/A
Ownership Owned
Is this tower consider Complex?
Is this tower currently shared with any other stations? No
One or more FM, AM or TV radio broadcaster(s) N/A
Others Types of Users N/A
Is tower documented for structural analysis? Yes
Is tower compliant with Rev G? No
Existing Tower Structure Registration Do you have a tower registration number? Yes
ASR Number 1010348
Coordinates (NAD83) Latitude (NAD83) 35° 40' 06.0" N-
Longitude (NAD83) 078° 31' 58.0" W-
Overall Structure Height 1994.07 feet
Support Structure Height 1885.80 feet
Ground Elevation Above Mean Sea Level (AMSL) 318.89 feet
Structure Type TOWER - Free Standing or Guyed Structure
Tower Owner WTVD Television, LLC
Date Constructed 01/01/1978


Primary Tower

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Tower Rigging Costs

Section Question Response
Tower Rigging Costs Complex Tower Other
Helicopter Services Required Are helicopter services required? No

Primary Tower

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Other Tower Expenses Not Listed

Name Description

Tower reinforcements

Reinforcements necessary to comply with ANSI/TIA-222-G standard

Outside Professional Services Costs

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Section Question Response
Outside Project Management Services Do you require outside project management services?
Number of Hours N/A
Explanation N/A
Outside RF consulting Engineering Services Perform engineering study for new channel assignment and antenna development Yes
Prepare engineering section of Form FCC Construction Permit Application Yes
For Auxiliary Facility N/A
For Main Facility Yes N/A
Prepare engineering section of Form FCC License to Cover Application Yes
For Auxiliary Facility Yes
For Main Facility Yes
Prepare request for Special Temporary Authority No
Quantity N/A
Do you have Distributed Transmission System engineering services? N/A
Critical Facility N/A
Terrain-Shielded Facility N/A
Attorney and Other Outside Consulting Services Prepare and file Form FCC Construction Permit Application Yes
For Auxiliary Facility Yes
For Main Facility Yes
Prepare and file Form FCC License to Cover Application Yes
For Auxiliary Facility Yes
For Main Facility Yes
Prepare request for Special Temporary Authority No
Quantity N/A
NEPA Section 106 environmental review No
Environmental Assessment No
ASR Modification No
FAA Consultation (including preparation of FAA Form 7460) No
Negotiation of Lease and other Matter for Shared Locations No
Prepare or Review FCC Form 399 for Reimbursement Yes
Address transition timing and coordination issues w/ other stations and wireless providers Yes
RF Field Engineering Services Comprehensive coverage verification via field study Yes
RF exposure measurements No
Additional Field Engineering Service No
Number of Days N/A
Justification N/A

Outside Professional Services Costs

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Other Professional Services Expenses Not Listed

Name Description

Structural Analysis

Structural analysis to comply with TIA/EIA-222-G and design of required reinforcement.

Structural project management

Structural Engineering services to manage tower reinforcements, antenna replacements and rigging plans.

Legal Advice re Reimbursement Process

Outside counsel advice re reimbursement and repacking procedures.

Other Expenses

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Section Question Response
AM Pattern Disturbance Is an Impact Study needed? No
Is Remediation needed? No
Facility Expenses Name N/A
Other Distributed Transmission System Expenses Not listed N/A
Name N/A
Is Notification of a Medical Facility required as a result of DTV broadcasting? Yes
Permit and Filing Costs Local Zoning No
Non-zoning permits No
BLM or NFS Coordination No
FCC Construction Permit Minor Change No
FCC License to Cover Application Yes
FCC Special Temporary Authority Application No
Other Miscellaneous Expenses Does this relocation require paying Disposal Costs (for equipment and other waste, net of any salvage value)? No
Does this relocation require Equipment Delivery or Handling Charges not otherwise included in individual item costs? No
Does this relocation require Equipment Storage? No
Does this relocation require the Development and Airing of an Announcement regarding an upcoming channel change? Yes
Does this relocation require MVPD Notification of a Channel Change? Yes

Other Expenses

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Other Expenses Not Listed

Information not provided.

Cost Information

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Transmitters

Where no predetermined cost estimate is available, any estimate provided will also become the predetermined cost (displayed in italics).
Description Predetermined
Cost Estimate
Estimated Cost Estimated Cost Justification Actual Cost Actual Cost Justification
Sub-total $1,000,000.00 $1,047,414.20 N/A $0.00 N/A
Total for all systems $2,231,386.57 $2,126,010.77 N/A $0.00 N/A
Primary Transmitter VAXTE-24R44 $500,000.00 $523,707.10 $0.00
High VHF - Air Cooled Solid State Transmitter 16.6 . 20.7 kW $500,000.00 $523,707.10 See attached quote from GatesAir, which includes costs of power transformer, mask filter, shipping, and installation. N/A N/A
Auxiliary Transmitter VAXTE-24R44 $500,000.00 $523,707.10 $0.00
High VHF - Air Cooled Solid State Transmitter 16.6 . 20.7 kW $500,000.00 $523,707.10 See attached quote from GatesAir, which includes costs of power transformer, mask filter, shipping, and installation N/A N/A

Components

Information not provided.

Cost Information

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Antennas

Where no predetermined cost estimate is available, any estimate provided will also become the predetermined cost (displayed in italics).
Description Predetermined
Cost Estimate
Estimated Cost Estimated Cost Justification Actual Cost Actual Cost Justification
Sub-total $592,417.00 $574,665.00 N/A $0.00 N/A
Total for all systems $2,231,386.57 $2,126,010.77 N/A $0.00 N/A
Primary Antenna THV-9A9/CP-R O4 $449,599.00 $444,923.00 $0.00
Mounting pole $125,722.00 $125,722.00 A shorter mounting pole for the new channel 9 Primary antenna is required to maintain current antenna aperture and HAAT. The cost for this mounting pole is included in the attached Dielectric Primary (Main) antenna quote. N/A N/A
Elbow complex, single channel, at antenna input, per 6 1/8. feedline (if needed) $11,700.00 $7,024.00 This cost is included in the attached Dielectric Main antenna quote. N/A N/A
High VHF - High Power Top Mount One Station elliptically or circularly polarized $305,777.00 $305,777.00 See attached quote from Dielectric. This Primary (Main) top-mount channel 9 antenna is a direct replacement for our current channel 11 Primary (Main) antenna. N/A N/A
Sweep test of existing antenna $6,400.00 $6,400.00 This cost is included in the attached Dielectric Main antenna quote. N/A N/A
Auxiliary Antenna TLS-V8/VPR S180 $142,818.00 $129,742.00 $0.00
High VHF - High Power Side Mount One Station elliptically or circularly polarized $105,318.00 $105,318.00 See attached quote from Dielectric. This Auxiliary (Backup) side-mount channel 9 antenna is a direct replacement for our current channel 11 Auxiliary (Backup) antenna. N/A N/A
Sweep test of existing antenna $6,400.00 $6,400.00 This cost is included in the attached Dielectric Auxiliary (Backup) antenna quote. N/A N/A
Elbow complex, single channel, at antenna input, per 4 1/16. feedline (if needed) $9,100.00 $7,024.00 This cost is included in the attached Dielectric Auxiliary (Backup) antenna quote. N/A N/A
Side mount brackets for high power antennas (if not included in antenna base cost) $22,000.00 $11,000.00 This cost is included in the attached Dielectric Auxiliary (Backup) antenna quote. N/A N/A

Components

Information not provided.

Cost Information

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Transmission Line

Information not provided.

Cost Information

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Tower Equipment and Rigging Costs

Where no predetermined cost estimate is available, any estimate provided will also become the predetermined cost (displayed in italics).
Description Predetermined
Cost Estimate
Estimated Cost Estimated Cost Justification Actual Cost Actual Cost Justification
Sub-total $459,650.00 $332,364.00 N/A $0.00 N/A
Total for all systems $2,231,386.57 $2,126,010.77 N/A $0.00 N/A
Primary Tower TOWER $459,650.00 $332,364.00 $0.00
Tower reinforcements $59,650.00 $59,650.00 Tower reinforcements are necessary to comply with TIA/EIA-222-G standards with the new antenna loads. N/A N/A
Complex Tower (includes, for example, those with candelabras and/or stacked antennas) $400,000.00 $272,714.00 See attached quotes from Coast to Coast Tower Service which includes replacements of Primary and Auxiliary (Backup) antennas. N/A N/A

Components

Information not provided.

Cost Information

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Outside Professional Services

Where no predetermined cost estimate is available, any estimate provided will also become the predetermined cost (displayed in italics).
Description Predetermined
Cost Estimate
Estimated Cost Estimated Cost Justification Actual Cost Actual Cost Justification
Sub-total $163,994.57 $161,949.57 N/A $0.00 N/A
Total for all systems $2,231,386.57 $2,126,010.77 N/A $0.00 N/A
Outside Professional Services $163,994.57 $161,949.57 $0.00
Legal Advice re Reimbursement Process $14,194.57 $14,194.57 Legal services relating to research and advice regarding reimbursable legal expenses and required backup support. See two attached quotes from Akin Gump. N/A N/A
Structural project management $28,550.00 $28,550.00 See attached quote from Turris Engineering to provide rigging plan and engineering services for antenna replacements and structural modifications. N/A N/A
Address transition timing and coordination issues w/ other stations and wireless $2,500.00 $2,500.00 N/A N/A N/A
Prepare engineering section of FCC Form 2100 (main), Construction Permit Application $3,000.00 $3,000.00 N/A N/A N/A
Attorney Fees -Prepare and File FCC Form 2100 (main), License to Cover Application $2,250.00 $2,250.00 N/A N/A N/A
Comprehensive coverage verification via field study, if needed $80,000.00 $79,955.00 Attached quote includes services for field strength study to verify antenna and coverage performance. N/A N/A
Structural Analysis $10,000.00 $10,000.00 Structural analysis required to comply with current tower standards. See attached quote from Turris Engineering. N/A N/A
Perform engineering study for new channel assignment and antenna development $7,000.00 $5,000.00 N/A N/A N/A
Attorney Fees - Aux Antenna, prepare and File Form 2100 Construction Permit or License Application $4,000.00 $4,000.00 N/A N/A N/A
RF Consulting Engineer Fees- Aux Antenna: Prepare engineering section of FCC Form 2100, License to Cover Application $1,500.00 $1,500.00 N/A N/A N/A
Prepare engineering section of FCC Form 2100 (main), License to Cover Application $1,500.00 $1,500.00 N/A N/A N/A
RF Consulting Engineer Fees- Aux Antenna: Prepare engineering section of FCC Form 2100, Construction Permit Application $2,000.00 $2,000.00 N/A N/A N/A
Attorney Fees - Prepare and File FCC Form 2100 (main), Construction Permit Application $5,000.00 $5,000.00 N/A N/A N/A
Prepare and or review reimbursement form $2,500.00 $2,500.00 N/A N/A N/A

Components

Information not provided.

Cost Information

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Other Expenses

Where no predetermined cost estimate is available, any estimate provided will also become the predetermined cost (displayed in italics).
Description Predetermined
Cost Estimate
Estimated Cost Estimated Cost Justification Actual Cost Actual Cost Justification
Sub-total $15,325.00 $9,618.00 N/A $0.00 N/A
Total for all systems $2,231,386.57 $2,126,010.77 N/A $0.00 N/A
Other Expenses $15,325.00 $9,618.00 $0.00
MVPD Notification of Channel Change $0.00 $0.00 Do not anticipate seeking reimbursement for this expense at this time. N/A N/A
Develop and air announcement of upcoming channel change $4,000.00 $4,000.00 N/A N/A N/A
FCC Filing Fees - Form 2100 license to cover application $325.00 $750.00 WTVD will be required to file license applications for both the Primary and Auxiliary facilities. N/A N/A
DTV Medical Facility Notification $11,000.00 $4,868.00 N/A N/A N/A

Components

Information not provided.

Cost Information

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Grand Total

Predetermined
Cost Estimate
Estimated Cost Actual Cost
Total for all systems $2,231,386.57 $2,126,010.77 $0.00

Construction Status

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Question Response
Is construction complete? No

Certification

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Section Question Response
Submission of Estimated Expenses Statements

WILLFUL FALSE STATEMENTS ON THIS FORM ARE PUNISHABLE BY FINE AND/OR IMPRISONMENT (U.S. CODE, TITLE 18, SECTION 1001), AND/OR REVOCATION OF ANY STATION LICENSE OR CONSTRUCTION PERMIT (U.S. CODE, TITLE 47, SECTION 312(a)(1), AND/OR FORFEITURE (U.S. CODE, TITLE 47, SECTION 503), AND ANY FALSE STATEMENTS COULD SUBJECT THIS ENTITY TO LIABILITY UNDER THE FALSE CLAIMS ACT.

  1. The Authorized Person signing below certifies that he/she is authorized to submit this TV Broadcaster Relocation Fund Reimbursement Form on behalf of the above-named entity.

  2. The above-named entity acknowledges that all certifications and attached documentation are considered material representations.

  3. The above-named entity acknowledges the submission of the information herein creates no obligation on the part of the government to pay any amount.

  4. The above-named entity certifies that the equipment and services paid for with money from the TV Broadcaster Relocation Fund are necessary to change channels (broadcasters) or to continue to carry the signal of a broadcaster that changes channels (MVPD).

  5. The above-named entity certifies that all payments from the TV Broadcaster Relocation Fund (Fund) received by the entity listed on this form will be used only for expenses that are eligible for reimbursement from the Fund.

  6. The above-named entity certifies that it will maintain and provide to the Commission detailed records, including receipts, of all costs eligible for reimbursement actually incurred.

  7. The above-named entity acknowledges that overpayments or payments in error must be promptly refunded to the Commission.

  8. The above-named entity certifies that it is in full compliance with all statutes, rules, regulations and governmental requirements for which compliance is a pre-requisite for obtaining the payments herein requested.

I declare, under penalty of perjury, that I am an authorized representative of the above-named applicant for the Authorization(s) specified above.

John W. Zucker

Assistant Secretary


07/31/2017

Attachments

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