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:
0000027250
FRN:
0002710192
Facility ID:
36504
Repack Channel:
36 (UHF)
Entity:
Broadcaster
Filing Status:
Submitted
Date Submitted:
08/29/2017

Applicant Information

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Applicant Name, Type, and Contact Information

Applicant Address Phone Email Applicant Type

SCRIPPS BROADCASTING HOLDINGS LLC

David Giles

C/O SCRIPPS MEDIA, INC.

312 WALNUT STREET, 28TH FLOOR

CINCINNATI, OH 45202

United States

+1 (513) 977-3000 DAVE.GILES@SCRIPPS.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

Ray Thurber

Vice President / Engineering

SCRIPPS BROADCASTING HOLDINGS LLC

Ray Thurber

312 Walnut St.

Cincinnati, OH 45202

United States

+1 (248) 827-9202 ray.thurber@scripps.com

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 WTVF must replace its main antenna and transmitter in order to move it its new channel. It will need to install interim facilities in order to be able to replace the main facility. See attached narrative for a more detailed explanation.

Transmitters

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

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 DCX-2
Year 2001
Type Inductive Output Tube
IOT Power Type Two
Description  
Power capacity 60 kw
Solid State Cooling  
Solid State Power Capacity  
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? Yes
Manufacturer
Model ULXTE100
Transmitter Type Solid state
IOT Power Type  
Other  
Power capacity  
Solid State Cooling Liquid
Solid State Power Capacity 62.9 kw
Other Transmitter Type  
Justification for New Transmitter Current transmitter is no longer supported by the manufacturer except for maintenance. Available parts are in very limited supply and in some cases are no longer available. Manufacturer says it cannot be re-tuned.

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) Yes
Transformer (480V) No
Power
Rigid Conduit and Wiring No
Size
Length
Other Electrical Service Yes
Description Necessary conduit, wiring and fuse disconnects as quoted by electrical contractor.
HVAC Service Does the replacement transmitter require HVAC Service? Yes
Type Cooling Only
Size 25 tons
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

Name Description

Ice Bridge and Concrete Pad

Concrete pad needed for new transmitter heat exchangers and ice bridge to cover them.

Antennas

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

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? Yes
Is antenna in operating condition? Yes
Is antenna located on or in close proximity to an antenna farm? No
Existing Antenna Manufacturer and Type Class Full Power
Mounting Top-mount stacked
Antenna position in stack Top
Polarization Elliptical
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: 1000.00 kW
Manufacturer
Model ATW24HS3-ETOX-25H
Year 2012

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? Yes
Will antenna be located on or in close proximity to an antenna farm? No
New Antenna Manufacturer and Type Class Full Power
Mounting Top-mount stacked
Antenna position in stack Top
Polarization Elliptical
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: 1000.00 kW
Manufacturer
Model ATW24HS3-ETOX-36H
Year 2019
Justification for New Antenna Existing main antenna is a coaxial slot antenna that is channel specific and cannot be reused on the new channel.

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? No
Broadband or Single Channel? N/A
Feed Line Size N/A
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

Tennessee Sales Tax

Tennessee Sales Tax for Antenna

Interim Antenna

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New Antenna Costs

Section Question Response
New Antenna Description Use Interim
Description of Use N/A
Change Type Purchase New
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? No
New Antenna Manufacturer and Type Class Full Power
Mounting Side-mount
Antenna position in stack Not in Stack
Polarization Elliptical
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: 600.00 kW
Manufacturer
Model ATW16HS3-ETOX-25H
Year 2019
Justification for New Antenna WTVF needs to provide service from an interim antenna while replacing the main antenna for the new channel.

Interim 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? No
Broadband or Single Channel? N/A
Feed Line Size N/A
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

Interim Antenna

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Other Antenna Cost Not Listed

Information not provided.

Transmission Line

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Section Question Response
Transmission Line Related Expenses Do you have transmission line related expenses? Yes

Primary Transmission Line

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Existing Transmission Line

Section Question Response
Existing Transmission Line Description Type of change Purchase New
Use Primary (Main)
Description of Use N/A
Ownership Owned
Owner N/A
Site N/A
Is the existing transmission line shared with another station or stations? No
Is Transmission Line in operating condition? Yes
Existing Transmission Line Manufacturer and Type Manufacturer
Type Rigid
Diameter 6 1/8 inches
Segment Length 19 ½ '
Other Segment Length
Number of parallel runs 1
Length 1170 feet per run

Primary Transmission Line

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New Transmission Line

Section Question Response
New Transmission Line Costs Use Primary (Main)
Description of Use N/A
Change Type Purchase New
Is this a request for upgraded equipment? No
Type Rigid
Diameter 7 3/16 inches
Segment Length 20'
Other Segment Length
Number of parallel runs 1
Length 1170 feet per run
Justification for New Transmission Line Larger transmission line is needed due to the change in power handling capability as a result of the channel change. There is not enough headroom in 6-1/8" line on the new channel.

Primary Transmission Line

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Other Transmission Line Expenses Not Listed

Name Description

Tennessee Sales Tax

Tennessee Sales Tax for Transmission Line

Transmission Line System Design and Survey

Needed to determine the exact length of the line, the type and number of hangers and obstruction avoidance.

Interim Transmission Line

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New Transmission Line

Section Question Response
New Transmission Line Costs Use Interim
Description of Use N/A
Change Type Purchase New
Type Rigid
Diameter 6 1/8 inches
Segment Length 19 ¾ '
Other Segment Length
Number of parallel runs 1
Length 870 feet per run
Justification for New Transmission Line WTVF needs to provide service from an interim antenna while replacing the main antenna for the new channel. It will need new transmission line to do that.

Interim Transmission Line

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Other Transmission Line Expenses Not Listed

Information not provided.

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 Modify Existing
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? Yes
Existing Tower Structure Registration Do you have a tower registration number? Yes
ASR Number 1041373
Coordinates (NAD83) Latitude (NAD83) 36° 16' 05.0" N-
Longitude (NAD83) 086° 47' 16.0" W-
Overall Structure Height 1178.14 feet
Support Structure Height 1011.80 feet
Ground Elevation Above Mean Sea Level (AMSL) 869.08 feet
Structure Type LTOWER - Lattice Tower
Tower Owner NewsChannel 5 Network, LLC
Date Constructed 11/01/2012


Primary Tower

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Tower Modification Costs

Section Question Response
Engineering Study Please what type of engineering study is required, if any: Study needed for documented tower
Tower Reinforcements Please select whether tower reinforcements are needed: Minor Reinforcements needed

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

Tennessee Sales Tax

Tennessee Sales Tax for Rigging and Tower Equipment

Outside Professional Services Costs

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Section Question Response
Outside Project Management Services Do you require outside project management services? Yes
Number of Hours 240
Explanation Project manager needed to manage all work at transmitter site required to transition to new channel (both the main and interim facilities). With the size of the current engineering staff, WTVF cannot spare personnel to ensure these tasks are completed.
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 No
For Main Facility Yes
Prepare request for Special Temporary Authority Yes
Quantity 1
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 No
For Main Facility Yes
Prepare and file Form FCC License to Cover Application Yes
For Auxiliary Facility No
For Main Facility Yes
Prepare request for Special Temporary Authority Yes
Quantity 1
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 No
RF exposure measurements Yes
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

Site Survey

GatesAir performed a site survey to access changes to facility as necessary to transition to new channel including, power and HVAC requirements, available transmitter room space and existing antenna and transmission line RF characteristics at new channel.

Tennessee Sales Tax

Tennessee Sales Tax on Professional Serivces

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 Yes
BLM or NFS Coordination No
FCC Construction Permit Minor Change No
FCC License to Cover Application Yes
FCC Special Temporary Authority Application Yes
Other Miscellaneous Expenses Does this relocation require paying Disposal Costs (for equipment and other waste, net of any salvage value)? Yes
Does this relocation require Equipment Delivery or Handling Charges not otherwise included in individual item costs? Yes
Does this relocation require Equipment Storage? Yes
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

Name Description

Employee Time

Time needed by Scripps corporate and WTVF employees to work on the transition to a new channel.

Tennessee Sales Tax

Tennessee Sales Tax on Other Expenses

In-Building Deconstruction

Work necessary to disassemble and remove existing transmitter, beam supplies, step starts, heat exchangers and mask filter.

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 $1,808,874.37 $1,778,987.37 N/A $0.00 N/A
Total for all systems $3,913,091.97 $3,779,129.97 N/A $0.00 N/A
Primary Transmitter ULXTE100 $1,808,874.37 $1,778,987.37 $0.00
25 Ton system $87,000.00 $57,113.00 See attached justification for the HVAC unit. N/A N/A
Ice Bridge and Concrete Pad $28,548.00 $28,548.00 N/A N/A N/A
Other Electrical Service: Necessary conduit, wiring and fuse disconnects as quoted by electrical contractor. $12,300.00 $12,300.00 N/A N/A N/A
Switchgear - industrial 800 amp $36,300.00 $36,300.00 N/A N/A N/A
UHF - Liquid Cooled Solid State Transmitter 62.9 kW $1,644,726.37 $1,644,726.37 N/A 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 $571,159.00 $571,159.00 N/A $0.00 N/A
Total for all systems $3,913,091.97 $3,779,129.97 N/A $0.00 N/A
Interim Antenna ATW16HS3-ETOX-25H $241,400.00 $241,400.00 $0.00
Sweep test of existing antenna $6,400.00 $6,400.00 N/A N/A N/A
UHF - High Power, Side Mount, basic slot antenna, 600 kW input, elliptically or circularly polarized $235,000.00 $235,000.00 N/A N/A N/A
Primary Antenna ATW24HS3-ETOX-36H $329,759.00 $329,759.00 $0.00
Tennessee Sales Tax $48,359.00 $48,359.00 N/A N/A N/A
Sweep test of existing antenna $6,400.00 $6,400.00 N/A N/A N/A
UHF - High Power Top Mount (200-1000 kW), One station antenna , elliptically or circularly polarized $275,000.00 $275,000.00 N/A N/A N/A

Components

Information not provided.

Cost Information

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Transmission Line

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 $544,841.00 $544,841.00 N/A $0.00 N/A
Total for all systems $3,913,091.97 $3,779,129.97 N/A $0.00 N/A
Interim Transmission Line $167,040.00 $167,040.00 $0.00
Rigid Transmission Line - copper, 6 1/8" $167,040.00 $167,040.00 N/A N/A N/A
Primary Transmission Line $377,801.00 $377,801.00 $0.00
Tennessee Sales Tax $46,131.00 $46,131.00 N/A N/A N/A
Transmission Line System Design and Survey $8,750.00 $8,750.00 N/A N/A N/A
Rigid Transmission Line - copper, 7 3/16" $322,920.00 $322,920.00 N/A N/A N/A

Components

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 $604,358.00 $500,283.00 N/A $0.00 N/A
Total for all systems $3,913,091.97 $3,779,129.97 N/A $0.00 N/A
Primary Tower LTOWER $604,358.00 $500,283.00 $0.00
Tennessee Sales Tax $42,358.00 $42,358.00 N/A N/A N/A
Complex Tower (includes, for example, those with candelabras and/or stacked antennas) $400,000.00 $295,925.00 Rigging for main and interim antennas and transmission lines. See attached quote from ERI. N/A N/A
Structural engineering tower load study for well documented tower $12,000.00 $12,000.00 N/A N/A N/A
Minor tower reinforcement/modifications $150,000.00 $150,000.00 N/A 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 $110,822.00 $110,822.00 N/A $0.00 N/A
Total for all systems $3,913,091.97 $3,779,129.97 N/A $0.00 N/A
Outside Professional Services $110,822.00 $110,822.00 $0.00
Attorney Fees - Prepare and File request for Special Temporary Authorization $3,500.00 $3,500.00 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
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 request for Special Temporary Authorization $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
Prepare engineering section of FCC Form 2100 (main), Construction Permit Application $3,000.00 $3,000.00 N/A N/A N/A
Perform engineering study for new channel assignment and antenna development $7,000.00 $7,000.00 N/A 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 and or review reimbursement form $2,500.00 $2,500.00 N/A N/A N/A
Project management of the transition $36,000.00 $36,000.00 N/A N/A N/A
RF Exposure Measurements $20,000.00 $20,000.00 N/A N/A N/A
Site Survey $16,900.00 $16,900.00 N/A N/A N/A
Tennessee Sales Tax $9,172.00 $9,172.00 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 $273,037.60 $273,037.60 N/A $0.00 N/A
Total for all systems $3,913,091.97 $3,779,129.97 N/A $0.00 N/A
Other Expenses $273,037.60 $273,037.60 $0.00
Employee Time $124,217.60 $124,217.60 N/A N/A N/A
Equipment Delivery and Handling Charges $25,000.00 $25,000.00 N/A N/A N/A
In-Building Deconstruction $25,000.00 $25,000.00 N/A N/A N/A
Tennessee Sales Tax $9,805.00 $9,805.00 N/A N/A N/A
MVPD Notification of Channel Change $2,500.00 $2,500.00 N/A N/A N/A
Develop and air announcement of upcoming channel change $5,000.00 $5,000.00 N/A N/A N/A
Equipment Storage $20,000.00 $20,000.00 N/A N/A N/A
Disposal Costs (for equipment and other waste, net of any salvage value) $25,000.00 $25,000.00 N/A N/A N/A
FCC Filing Fees - Special Temporary Authorization request $190.00 $190.00 N/A N/A N/A
FCC Filing Fees - Form 2100 license to cover application $325.00 $325.00 N/A N/A N/A
DTV Medical Facility Notification $11,000.00 $11,000.00 N/A N/A N/A
Non-zoning permits $25,000.00 $25,000.00 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 $3,913,091.97 $3,779,129.97 $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.

Ray Thurber

Vice President / Engineering


08/29/2017

Attachments

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