From:      jeremy d. lansman <jeremydl@kyes.com>
To:        J4.J4(dtvallotments)
Date:      12 Dec 1996 10:44p
Subject:   ASCII version of comments, KYES-(TV)

This is an unofficial version, text only.  The original Microsoft
Word file, with graphics, about 1/2 megabyte, and a compressed
(zip) version of same (less than 50K) can be found and downloaded
by visiting http://www.kyes.com/html/kyes_body_engineering.html.
Use the right hand mouse button to force a save to file.  Also
you may anonymous
FTP://kyes.com/pub/jeremy.

In this ASCII version, footnotes are in a group at the end of the
main body
& before the attachment.

Thanks

Jeremy Lansman/president and owner/KYES-(TV), Anchorage, AK.
.................................................................
...........
................................
Before the
Federal Communications Commission
Washington, D.C.


In the Matter of         )
Advanced Television Systems   ) and Their Impact upon the   )    
     MM Docket No. 87-268
Existing Television Broadcast )
Service                  )


Comments in response to the Sixth Further Notice Of Proposed Rule
Making
Fireweed Communications Corporation
KYES-TV, Anchorage, Alaska

To:  The Commission:                    November 20, 1996


     Fireweed Communications Corporation ("Fireweed") , licensee
of KYES-(TV),
Anchorage, AK., respectfully submits these comments in response
to the
Sixth Norice of Proposed Rule Making, released on August 14,
1996, 61 F.
Reg. 43209, August 21, 1996.

SUMMARY

     KYES-(TV), Channel 5, Anchorage, Alaska, may not survive a
permanent change to a UHF channel, as proposed.  However, at
little cost, KYES could operate a small temporary digital UHF
channel.  During DTV transition, KYES could, at no cost, convert
channel five to Digital and the UHF temporary channel to NTSC,
simply by swapping exciters between the UHF and VHF transmitters.
Following transition, KYES would return the low power UHF channel
to the government.

KYES serves communities and area not served by any other TV
station. See figure 1, below.  DBS is too weak to reach this area
without expensive, large dishes.  Cable TV is not available in
any location between the present KYES grade A and Grade B
contour.=20

=20
FIGURE 1
Coverage of all existing TV stations in South Central Alaska.

Examples of small communities within the KYES grade B and not
within any other station grade B contour include, but are not
limited to, Sterling,
Talkeetna, Nikishka, and Trapper Creek. =20
=20
 As shown below, a switch to UHF would reduce KYES coverage. 
Even assuming
 KYES could afford a reasonably sized 1.24 megawatt peak power
(312 kW average DTV) facility, coverage would be lost in white
areas covered by no other station.  Figure 2 is a comparison of
present KYES 100 kW VHF Grade B and 312 kW UHF-DTV cliff contours
using cliff field strength as proposed in the NPRM.

=20
FIGURE 2
Green represents the present KYES Grade B contour
Red represents a 312 kW (average) UHF-DTV cliff contour

(Note to ascii readers.  A higher gain antenna, as required for a
practical
UHF xmtr will cause a narrow vertical beam, skipping over the
heads of residents living under the tower and blocked by terrain.
This graphic shows the loss.  If KYES operated at, lets say, 8 kW
DTV on channel 5, digital coverage would extend beyond the old
grade B coverage.)

=20
As shown below,  UHF Propagation cannot cover parts of Anchorage
that VHF can and currently does reach.  Figure 3 shows in red,
loss of coverage in the Eagle River section of Anchorage, Alaska,
an area near by the KYES=
 tower.

=20
FIGURE 3
Bullington Coverage Study
Green represents 43.8 dBu area covered by a channel 21 312 kW
average DTV
ERP signal at the present KYES site with the present KYES
horizontal antenna pattern using a 24 bay UHF antenna with null
fill and =BD degree bea= m tilt.  Red represents additional area
covered (26.8 dBu) on channel 5 with
6.3 kW average DTV ERP and the existing KYES antenna and
transmitter.

(Note to ASCII readers.  This map shows large coverage loss given
a realistic, but very expensive UHF xmtr plant.)

Comments on the Sixth Further Notice of Proposed Rule Making

     In the above captioned NPRM, the Commission invited comment
on several issues, upon which Fireweed hereby respectfully offers
the following:

     Low Band VHF Spectrum.   The NPRM proposes a "Core area"
option that, following transition,  would remove present channel
2-6 from the broadcast television service.  The NPRM asks for
comment on =85"our assessment that VH=
F channels 2-6 are less suitable for broadcasting because of high
levels of noise" and asks for specific engineering analysis on
"=85the longer range propagation characteristics of channels
2-6=85" and higher levels of noise
(Paragraph 35).  The Commission, in Appendix C of the Initial
Regulatory
Flexibility Analysis ("IRFA") seeks comment on impact on smaller
entities, and:

 "=85whether the Commission should adopt measures that will
assist small stations (as classified under either the SBA
definition or their number of employees) in their transition, =85
in their cost to upgrade technical operations=85"=20

FINANCIAL CONSIDERATIONS

     Continued Operation of KYES Requires the Low Cost of Low
Band VHF.  KYES has  survived because it was on a Low Band VHF
channel..  KYES was built in
1989 in Anchorage Alaska, a very competitive, though small market
with 7 commercial TV stations.  At that time the market of 98,000
households had
NBC (KTUU) , CBS (KTVA) , ABC (KIMO) , Fox (KTBY),  PBS (KAKM),
Religious(
K20AG), the Cartoon Channel (K14AP), and music TV (K22AG)
stations .=20

     Anchorage is the 156th TV market.  We are aware of no market
so small that offers viewers so much over the air choice.  If the
station is to survive, it has to operate on minimum capital and
budget.  The low cost of operating on channel 5 is an essential
part of the stations budget.  VHF is part of the Fireweed=92s
long range plan.  We believe that if KYES began operations on, or
had to operate on UHF , it would no longer be in existence.=20

     KYES transmits from a site 1,000 feet higher than any other
Anchorage VHF station.  Due to this elevation it is the only TV
station of any kind covering substantial white area.    Any
attempt to replicate this service on a UHF channel is doomed to
failure.  Even if required zoning and Radio
Exposure limits to humans could be met, and even if money were
available to construct and run a mammoth transmitter  (see
Attachment A) , replication of KYES VHF service on UHF would
require a transmitter of higher power than ever before built in
North America.

VHF Spectrum Reclamation and the Initial Regulatory Flexibility
Analysis.
In the IRFA, on page C-5 of the NPRM, the commission states:

 "All of the affected stations will have to operate on the new
DTV channels.  The cost of equipment to operate on these new
channels is expected to vary from  $750,000 upwards to $10
million.
=09
We respectfully suggest that should the FCC provide for continued
operation on all VHF channels, the costs can be much lower. 
KYES, and many other small market TV stations already have the
most expensive part of a digital transmission plant, their
present transmitter and antenna!  As in the
Charlotte tests, the broadcaster need only change the exciter to
switch from NTSC to digital.  Today, a digital DVB compliant
satellite up link exciter cost $8,700. Today, a hand made Grand
Alliance exciter cost
$80,000, a cost that is sure to decrease as production ramps up

It would be preferable to operate a lower powered second channel
that reaches most of the city of Anchorage Alaska.  KYES could
install a standard 1 K.W. LPTV transmitter at the KYES
transmitter site, along with a simple, inexpensive LPTV antenna 
and still reach about 80% of its present audience.  KYES already
owns a, licensed LPTV station that could be converted to DTV use. 
So,  as of today, KYES could provide a DTV signal to much of our
viewing area for the price of an exciter.

When sufficient numbers of DTV sets are in the marketplace, KYES
could, at no cost, swap exciters between the UHF and VHF
transmitters.  The limited coverage UHF signal could continue to
provide NTSC service to the dwindling numbers of NTSC TV sets.

     Under the Commission=92s plan, according to the
Commission=92s own statemen= ts, the minimum cost of DTV
conversion is expected to be at least $750,000.
That expense, one which KYES is unable to bear, would vastly
reduce KYES rural coverage, much of which is to white area not
served by any other TV station.

Under Fireweed=92s plan, for much less than $80,000, after
transition, KYES could deliver DTV to all the households it does
today, on channel 5.
During the transition, it could deliver DTV and NTSC to most of
those households.

ENGINEERING CONSIDERATIONS

The Charlotte Study.  The NPRM says the Commission has made an
"=85 assessment that VHF channels 2-6 are less suitable for
broadcasting because of high levels of noise".  Urban noise
should have been expected.  In 1977 the NTSC planning factors
provide for 14 dB Low Band VHF urban noise adjustment at the
Grade A contour and 0 dB at the grade B contour .  Of course, a
station, such as the Charlotte test station,  operating at low
power, putting a grade B contour into an urban area, should
suffer from far more from noise than a high powered station.

 Fireweed believes the assumption that Low Band VHF is too noisy
for DTV rests exclusively upon data found in the Field Test
Results of the Grand
Alliance HDTV Transmission Subsystem , by AMST, Cable TV Labs,
and PBS,
Sept. 16, 1995 ("Report").  However, that test, the Charlotte
study, and related anlysis are inadequate to demonstrate this
crucial conclusion.
Fireweed=92s operational experience, in many ways, refutes the
conclusion that Low Band VHF is too noisy.

The Report said, at 10% power, VHF channel 6 did very poorly,
both with
NTSC and DTV.  For example, the Report shows in table 3 on page
14 says the percent of locations getting satisfactory reception
of NTSC test signals at
Charlotte on channel 6  was only 39.6%;  but on UHF channel 53
the number was up to 76.3%.   If true, Charlotte shows VHF is far
inferior to UHF for
NTSC.

With thousands of VHF and UHF NTSC stations on the air, how and
why have
UHF stations kept their superiority a secret for so long?  One
would assume that eventually as the secret advantage of UHF would
leak out.  We should have witnessed a land rush as ABC, NBC and
CBS stations attempted to beat one another to grab up all the
major market UHF slots.

Fireweed respectfully suggests that Charlotte does not prove UHF
is superior to VHF.  It only proved a Low Band VHF  station
"dropped in" that runs 10% of normal power won=92t do well
compared to a 10% power UHF station received on a tuner fitted
with an expensive low noise amplifier.  =20

At Charlotte, VHF Channel 6 had significant handicaps.   Yet, 
when
Charlotte DTV power on both UHF and VHF was raised form 10% to
40% of nominal, the higher power UHF signal and VHF signal were
equal.   In fact, the test shows VHF was superior at greater
distance.   Either way, low powered or high powered, the presence
of urban noise is not a new discovery. In 1977 the NTSC planning
factors provided for a 14 dB Low Band
VHF urban noise adjustment at the Grade A contour and 0 dB of
adjustment at the grade B contour .  Of course, a station, such
as the Charlotte test station, operating at low power, putting a
grade B contour into an urban area, should suffer from far more
from noise than a high powered station.

Fireweed believes that much of the problem in Charlotte at low
power on channel 6 was a normal high level of urban noise .  This
was overcome when
DTV power was raised to 2.52 kW.  At full proposed low band VHF
power, 6.3 kW, Fireweed expects the DTV Cliff contour to extend
beyond present NTSC grade B.

Finally, at Charlotte, in every case DTV proved superior to NTSC.
VHF stations would lose nothing, and could convert to DTV at much
lower cost by switching their present NTSC facility to DTV on
their present channel.

The Notice also fails to explain the belief that noise prone
frequencies used for TV channels 2-6, with the huge installed
base of home TV receivers, would somehow be more useful or more
valuable if shifted away from television use.

In Alaska VHF propagation is superior to UHF

  Several factors distinguish Alaska from Charlotte.

1.  Urban noise levels are lower as there is less urban area and
lower population density within urban areas.
2.  Alaska has substantial white area, not served by any full
service TV station or cable.  The ability of VHF signals to
propagate over the horizon allows some degree of service where
none would otherwise exist.
3.  Interference from full service stations is less, or
non-existent.  In the case of KYES, for example, the closest US
full service channel 5 is in
Seattle,  more than 2,400 miles distant, the closest adjacent TV
station is in Spokane, on channel 6.=20
4.  Very rugged terrain, such as that found in Alaska,  is best
served with longer wavelengths that better overcome terrain
obstruction. =20
5.  It is claimed by some that translators can fill in those
places where the UHF signal cannot replace a present VHF service. 
However, in Alaska, many of these areas have too few people to
justify an expensive translator, or translator site rental.

KYES Viewers Need VHF propagation.

Lets make the assumption that KYES could afford to broadcast on a
UHF DTV channel such as 21, the channel assigned KYES in the
NPRM,  from its present site, using an antenna of the same
vertical height (40 feet vertical aperture) , the same horizontal
directional pattern,  from the same position on the same 75 foot
tall tower (maximum allowed under
Municipal zoning code) with a transmitter of about twice present
peak power
 (DTV=3D30 kW peak, or 7.5 kW average) .  This hypothetical
station might have 312 kW average DTV ERP, nearly 10 times that
used at Charlotte.

 Close in Multipath and Shadows:  Multipath and shadowing will
become worse at UHF costing cost KYES loss of coverage within its
city of license.  See
Figure 3.
=20
   KYES transmits 1890 feet above part of Anchorage known as
Eagle River.
Much of Eagle River is terrain shielded from KYES.  A switch from
VHF to
UHF will deepen the shadows near the transmitter.  Use of a high
gain transmitting antenna causes more loss of signal near the
tower, leading to multipath, while signals directed to nearby,
higher mountains will still be strong, exaggerating reflections
and multipath.
=20
 Loss of Presently Covered White Area.  Figure 1 shows the grade
B contour of all Anchorage Alaska television stations.  No fringe
signals from any other market can be seen within the Anchorage
market.  In the North and
South West directions, KYES covers area and communities not
covered by any other television station.  See, for example,
Talketna Alaska, a town of 500 people having no cable TV and no
DBS (the DBS signal is weak).  Only KYES includes Talkeetna
within its grade B contour.  (Talkeetna is denoted in
Figure 1 and Figure 2 as the red + symbol under the letter T in
Matanuska.)
=20
 Figure 2 shows loss of service to Talkeetna should KYES convert
to UHF
DTV.  Converting channel 5 to DTV would not reduce KYES channel 5
coverage.
 We have shown that if KYES is forced to switch to UHF, Talkeetna
might lose its only television service.
     =20
 CONCLUSIONS
=20
=B7 All TV channels, especially VHF should continue to be
available for television broadcasting.  It is needed for service
in some rural areas.
The Commission lacks evidence that channels 2-6 are disadvantaged
for TV broadcasting, and the entire history of the service since
1947 refutes that notion.
=20
=B7 Minimum required DTV power should, in no event, be greater
than that presently required for NTSC (see 73.614 & 73.685(a)).
=20
=20
=B7 Stations should be able to elect a maximum DTV loaner channel
facility power of 10% or less of that required for replication,
with protection to be limited to the lower power. Protection to
the low power loaner channel will assume NTSC operation to the
grade A contour.
=20
=B7 A station making such election should be allowed to operate
the loaner channel with NTSC upon conversion of its original
channel to DTV, and may operate the loaner channel with NTSC
until the end of transition.  At the end of transition, the
station making such election would continue to operate DTV on the
original channel and submit the loaner license for cancellation.
=20
=B7 If, in the future, spectrum is auctioned, or otherwise
awarded for new entry,  the new spectrum user should be fully
responsible to any TV broadcast station, LPTV or translator, for
all costs incurred to replace any lost coverage or replace,
broadcast equipment.  Such costs should include higher increased
cost of transmission, electricity, site rental and equipment
maintenance as required to maintain the same level of broadcast
service.  The new spectrum entrant would guarantee such operating
payments so long as the entrant operates its facility.  If such
coverage cannot be replaced, the broadcast station, LPTV station,
or translator may continue to operate indefinitely.



          For these reasons, Fireweed requests that the
Commission=92s proposals in the Sixth Further Notice of Proposed
Rule Making be modified to reflect the ideas and concerns stated
herein.

         Respectfully submitted,=20






Jeremy D. Lansman
President, Fireweed Communications Corp.
3700 Woodland Dr., #800
Anchorage, Alaska, 99517
907-248-5937 (voice)
907-243-0709 (fax) jeremydl@kyes.com (e-mail)

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--------------------------------------------
FOOTNOTES:

 1 At present there are seven local commercial TV stations. 
K22AG is now a translator of KTBN, Los Angeles; K14AP went dark
and the, license has been deleted;  KDMD-(TV), channel 33, is a
new full service Home Shopping
Network Affiliate, using a 1 K.W. UHF transmitter.

2  Digital or NTSC, UHF costs more.  See Comparability for UHF
Television,
Final Report, UHF Comparability Task Force, Office of Plans and
Policy,
FCC, Sept. 1980.Table 5-2.  In 1980 dollars, total discounted
cost of investment for a UHF transmitter plant of 2 MW peak
output (equal to about
500 kW DTV average) was $2.58 million, high band VHF was $1.044
million, and low band VHF was $.887 million.

3  The present KYES 100 kW transmitter plant cost about $45,000,
including two 1 kW drivers, an 18 kW transmitter, a 37 kW single
to three phase power converter, and a "home brew" broadcasting
antenna.  The monthly electric bill is $1,300.=20

4  See Figure 1, a coverage map of all Anchorage Full Service TV
stations.
One penalty KYES pays for providing coverage into white areas is
that KYES must operate without three phase electrical power, and
must pay for generation of the extra phase.  Conversion cost more
as power increases.
UHF requires far more electrical power than VHF for equal
coverage using
FCC f(50,50) or f(50,90) curves.  Although Fireweed believes UHF
can be superior to VHF under certain conditions, VHF is clearly
superior where terrain obstructs coverage, and costs must be kept
low, as in Anchorage.

     At the present time, Anchorage area DBS reception requires a
1.8 meter dish, not the 18" dish required in the lower 48. For
all practical purposes, DBS is not available at a reasonable
price.

     Although Paragraph 40 of the NPRM assumes higher cable
penetration on the edges of station coverage, no cable system
operates between the KYES grade
A and B contours.  For many persons living between the KYES grade
A and grade B contour, KYES is the only television service of any
kind at less than the cost of a large satellite dish.

5  It is well known that UHF signals suffer more from terrain
obstruction than VHF.  It is also known that UHF transmission
over the horizon requires very high power.  A maximum facility
Low Band ("LB") VHF station, (2,000 feet HAAT and 100 K.W. E.R.P.
in zone 2) will project a grade B signal to a distance of 80
miles.  Under proposed DTV standards, an 80 mile service contour
(43.8 dBu F50:90) requires 4 megawatts AVERAGE E.R.P.  Since PEAK
ERP must be at least four times higher, the UHF DTV broadcaster
would have to install a 16 megawatt Peak Power ERP transmitter
plant in order to replicate a maximum facility NTSC VHF signal. 
A VHF to be replicated on
UHF having  100 kW at less than maximum height might need even
greater=
 power.

6  Fireweed owns LPTV station K18CS.  It uses a 1 kW UHF
transmitter, which can produce peak powers of 1 K.W. equal to
about 250 watts DTV average.
K18CS uses a Scala SL-8 antenna having a gain multiplier of about
8.
Therefore fitting K18CS with a digital exciter would, with the
present antenna, produce a DTV power of 2 K.W. average ERP.=20

7  See A Review of the Technical Planning Factors for VHF
Television
Service,  FCC Office of Chief Engineer, Research & Standards
Division,
RS77-01, March 1, 1977,  Gary S. Kalagian., Table 4A & 4B, Page 8
& 9.

8  See Field Test Results of the Grand Alliance HDTV Transmission
Subsystem, Sept. 16, 1994, Figure 2, Field Truck RF Distribution
System,
ATV Field Test project, Charlotte, North Carolina.  The Scala Low
Noise UHF
Preamp, costing $220, is rated at 1.4 dB Noise Figure.  Proposed
DTV planning Factors suggest a UHF 10 dB noise figure.  A UHF
transmitter would need 9.1 times more power to overcome that
extra receiver noise.  At
Charlotte, the DTV station operated at 31.6 K.W. E.R.P.  To
account for a
TV set with 10 dB N.F. the station would have needed 287.6 K.W.
E.R.P. for equal coverage.  To generate this E.R.P. the
transmitter would need peak power capability of 1.15 Megawatts.
Since VHF reception is more limited by man made and natural noise
than receiver noise, a low noise pre amp is less beneficial at
VHF.

9  See Field Test Results of the Grand Alliance HDTV Transmission
Subsystem, Sept. 16, 1994, Page 10, paragraph 2 about
interference from FM stations.  In addition, channel 6 TV
stations WECT, WVVA, WATE and WJBF are located 134 to 188 miles
from the DTV test transmitter.  Their respective
F50:10 field strengths at the DTV transmitter site are 36.46,
28.6, 20.2 and 31.1 dBu, (based upon average HAAT and ERP). This
much co-channel interference should seriously impair NTSC or DTV
reception of a drop in channel 6.

10  Table 8 and 9 on Page 19 of the tests show that when power
was raised from 10% of proposed DTV maximum to 40%, UHF and VHF
both had acceptable signals at 94% of sites surveyed.  Especially
important to Fireweed, in the band from 50 to 56 miles, the most
distant band measured, VHF beat out UHF by 4%.  Fireweed believes
that a VHF full power DTV station properly spaced from co-channel
neighbors will prove vastly superior to UHF at distances from the
transmitter of 56 miles or more.

11  Charlotte test broadcast antennas were about 1,330 feet above
ground on a site with little elevation above average terrain. 
The radio horizon from that site is about 50 miles distant. 
Given sufficient power, VHF will better propagate over the
horizon, so we would expect channel 6 to begin to excel as the
signals hit the horizon.

 12 See A Review of the Technical Planning Factors for VHF
Television
Service,  FCC Office of Chief Engineer, Research & Standards
Division,
RS77-01, March 1, 1977,  Gary S. Kalagian., Table 4A & 4B, Page 8
& 9.

13  It is safe to assume that as population density increases, so
will urban noise.  New technology, especially computers, have
created new sources of interference.  As computers clock faster,
we can expect their
R.F. pollution to march up the spectrum.  Today, 100 MHz
computers are common.  In the future, we may see a reduction in
VHF noise and an increase in UHF noise as computers approach UHF
frequencies.=20

14   Present horizontal pattern power multiplier is about 2.175,
a 24 bay antenna with null fill and beam tilt would  gain 20.8. 
3" coax, 100 =91 lon= g loss is X .918 at 512 MHz.  If ERP in the
main lobe is 312 kW, then
TPO=3D312/20.8*2.175*.918 or 7.512 kW.  If peak to average is 6
dB, or *4, then peak=3D7.512*4=3D30.05 kW peak.=20

15  In Advanced Television Transmission, Planning Your Stations
Transition,
T. Vaughan Associates, 1995, table VII-4, page VII-5, Section
VII, shows a peak to average ratio of 6 dB is optimistic.  The
table shows a 30 kW IOT
UHF transmitter as capable of only 6.8 kW average DTV power, less
than used in the estimate herein.  In spite of our optimism, the
table estimates transmitter cost at $420,000.  Our hypothetical
antenna is similar to an
Andrew ALP24-3HSPR, able to handle up to 28 kW, costing $49,000
(phone call to Jenny Schaack at Andrew 11-20-96. =20


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-----------------------------------

 ATTACHMENT A
REQUEST FOR DTV TRANSMITTER QUOTE
SENT TO HARRIS CORP. & OTHERS
------------------------------------
     As, per our conversation, here is a request for price and
availability for a digital TV transmission plant for a KYES-High
Definition transmitter.  We desire a plant that can meet the
requirements of the FCC=92s 6th Report and order, in that it
should match the coverage of KYES-(TV).

     However, we recognize that an operation that would match
KYES coverage might not be practical, so we are requesting two
proposals.

     Three phase power is not available at our present
transmitter site.  Thus we request that you provide a line item
in the proposal to engineer and build a single phase modification
of the transmitter.  We will compare that cost to the cost of
having the utility provide three phase power at our location.

     And exact match would use the same antenna gain in the
horizontal and vertical planes, so that, aside from wavelength,
coverage below the antenna tower would be the same as that
presently enjoyed by KYES.  The community of Eagle River at about
200 feet AMSL, a portion of the Municipality of
Anchorage, is located under the 1,900 foot AMSL transmitter site. 
On the other side of Eagle River and about 5 miles away we have a
mountain more than 4,100 feet AMSL.   In addition, people reside
on the hillside directly below our tower.  Therefore, due to
bouncing off that mountain and others, we would lose coverage to
multipath is we increase antenna gain.

     Our present gain, overall, is a multiple of 8.7. 
Transmission line run is about 70 feet.  In waveguide,
transmission line loss would be negligible, and will be ignored. 
The FCC has determined that our coverage will be matched at an
E.R.P. of 4.897 Megawatts, average.

     Thus:  (4.9MW erp/8.7 ant gain)=3D TPO 563.3 KW.
          AV TPO=3D563.3 x 6 dB =3D 2.25 MW Peak TPO

     Please quote price for this plant, both with single phase
and polyphase power..  Please indicate peak electric utility
load.

     In the case of reduced coverage due to higher antenna gain
in the vertical plane, I have used, as an example, a 15 level
Andrew with a P2 pattern.
The P2 approximates the present KYES horizontal plane pattern.

     Total peak antenna gain is 33.  Thus: (4.9 MW erp /33 ant
gain)=3D 148.5 KW
TPO.  Again, using a 6 dB peak to average ratio, peak power would
be
148.5x4=3D594 kw.

     Please, also quote a cost of plant and power consumption for
both single and polyphase electric service in the 594 KW case.

     Thank you very much for your time.

     Yours Truly,

     Jeremy Lansman
        President, Fireweed Communications Corp
        KYES-(TV)
        Anchorage AK.
        fireweed@alaska.net

 REPLY FROM HARRIS CORP.

Hi Jeremy,

          Here are some very budgetary quotes for the 2.25MW and
594kW peak
DTV power transmitter systems.  These do not include
   the transmitter building, antenna and waveguide, AC power
distribution, building HVAC, lighting, spare parts, etc.

          From our point of view, these two solutions do not
represent an economically viable approach to DTV.  A lower
service area, or fill-in using LPTV translators, may be required.
          We anticipate that most stations would not choose a
transmitter of larger than 1 or 2 IOT's (70kW or 140kW peak       
  DTV power).

          Regards,  Martyn Horspool  - UHF TV Product Manager
_________________________________________________________
          1. 2.25MW Peak Power Sigma IOT Transmitter
             (uses 32 x 70 kW amplifiers)

          a) Transmitter Sigma CD280 x 8     5,353,600
          b) IOT7360/cct assy x 32           2,336,800
          c) RF system & waveguide comb      1,100,000
          d) Voltage regulator x 8             320,000
          e) Surge Eliminator x 8              168,000
          f) Installation c/o & proof          800,000
          g) Misc hardware & parts             200,000

             Total Transmitter             $10,278,400

          Preliminary specifications:
          Operating voltage:   480V, 3-phase Wye, +/-2%
          Power consumption:   2.32 MW
          Power factor:         .9  typical
          Dimensions:          158' W x 55" D x 72" H
          Weight:              58,000 lbs

          Note: A single phase version is not practical, due to
the high line currents.  The Harris CD280 transmitter is only     
    offered as a
480 volt, 3-phase system.

         =20
 _________________________________________________________
          2. 594kW peak Power Sigma IOT Transmitter
             (Sigma CD280 x 2, plus 1 tube)

          a) Transmitter Sigma 2 x CD280+1   1,439,000
          b) IOT7360/cct assy x 9              657,225
          c) RF system $ w/g combiner          200,000
          d) Voltage Regulators                100,000
          e) Surge eliminators                  47,000
          f) Installation checkout & proof     200,000
          g) Misc hardware & parts              60,000

             Total transmitter              $2,703,225

          Preliminary specifications:
          Operating voltage:   480V, 3-phase Wye, +/-2%
          Power consumption:   576kW
          Power factor:         .9  typical
          Dimensions:          46' W x 55" D x 72" H
          Weight:              17,000 lbs

          Note: A single phase version is not practical, due to
the high line currents.  The Harris CD280 transmitter is only     
  offered as a
480 volt, 3-phase system.