WOMBLE
CARLYLE
SANDRIDGE
& RICE
A LIMITED LIABILITY
PARTNERSHIP

1200 Nineteenth Street, NW
Suite 500
Washington, DC 20036
Telephone: (202) 467-6900
Fax: (202) 467-6910
VwFww.WCsr.COIn

Gregg P. Skall
Direct Dial: 202-857-4441
Direct Fax: 202-261-0041
E-mail: GSkall@wcsr.com

December 1, 2016

Marlene H. Dortch, Secretary
Federal Communications Commission
Office of the Secretary
445 12t" Street SW, Room TW-8325
Washington D.C. 20554
Re: INTERFERENCE COMPLAINT
W225AP FAC. ID: 142406 St. Paul, Minnesota
Educational Media Foundation
Dear Ms. Dortch:
Gabriel Media, ("Gabriel") licensee of FM Radio Station KKJM, St. Joseph, Minnesota,
by its counsel and pursuant to Section 74.1203(a)(3) hereby files its interference complaint
against the above referenced translator station W225AP, FAC. ID: 142406 St. Paul, Minnesota,
licensed to Educational Media Foundation ("EMF").
KKJM operates on Channel 225 at 92.9 MHz. It has operated on channel 225 since 1996,
See BLH-1996051OKA.
Since the February 12, 2015 commencement of W225AP, KKJM(FM) has experienced
routine co-channel interference from the EMF Translator. Beginning at about that time, Gabriel
began receiving complaints from its listeners of interference to their reception of KKJM
identified as coming from W225AP. A number of those complaints are appended hereto as
exhibits to the attached Engineering Statement.
The attached Engineering Exhibit, amply demonstrates that the source of the interference
to KKJM identified by its listeners is W225AP by calculating the reports of interference and by
further engineering analysis of the undesired to desired interference contour relationships under
the Commission's own standard propagation method.
Pursuant to §74.1203(a)(1), an authorized FM Translator will not be permitted to
continue to operate if it causes any actual interference to the transmission of any authorized
broadcast station. §74.1203(a)(3) again reiterates an authorized FM Translator will not be
permitted to continue to operate if it causes any actual interference to the direct reception by the
public of the off-the-air signals of any authorized broadcast station. §73.1203(a)(3) further
clarifies that interference will be considered to occur whenever reception of a regularly used

CALIFORNIA / DELAWARE / GEORGIA / MARYLAND / NORTH CAROLINA / SOUTH CAROLINA / VIRGINIA / WASHINGTON D.C.

WOMBLE

CAR'

December 1, 2016
Page 2

SANDRIDGE

RicE
LLP

signal is impaired by the signals radiated by the FM Translator, regardless of the quality of such
reception, the strength of the signal so used, or the channel on which the protected signal is
transmitted.
Pursuant to Section 74.1203(a)(3) of the Commission's rules, Gabriel hereby demands
that W225AP suspend operations and not resume broadcasting unless and until all interference
caused to KKJM is completely eliminated.

Sincerely,
0~

Grg. Skall
Counse ,Gabriel Media
cc:

James Bradshaw, Deputy Chief Audio Division
Robert Gates, Audio Division
Educational Media Foundation
Mary M. O'Connor, Wilkinson, Barker, Knauer, LLP

37945909v1

ENGINEERING STATEMENT
IN SUPPORT OF A
§74.1203(a)(1 &3)
Interference Objection
against
W225AP.L - St. Paul, MN
License File No. BLFT-20150212AAA
(Facility ID No. 142406)
CH225D - 92.9 MHz

CERTIFICATION OF TECHNICIAN
The firm of Munn-Reese, Inc., Broadcast Engineering Consultants, with offices at 385 Airport Drive, Coldwater, Michigan,
has been retained for the purpose of preparing the technical data forming this report.
The data utilized in this report was taken from the FCC Secondary Database and data on file. While this information is
believed accurate, errors or omissions in the database and file data are possible. This firm may not be held liable for damages as a
result of such data errors or omissions.
The report has been prepared by properly trained electronics specialists under the direction of the undersigned whose
qualifications are a matter of record before the Federal Communications Commission.
I declare under penalty of the laws of perjury that the contents of this report are true and accurate to the best of my
knowledge and belief.
November 22, 2016

MUNN-REESE
385 Airport Drive, PO Box 220
Coldwater, Michigan 49036
Telephone:

By
Bruce Bellamy, President

517-278-7339

MUNN-REESE
Broadcast Engineering Consultants
Coldwater, MI 49036

ENGINEERING STATEMENT
This Engineering Statement supports a §74.1203(a)(1&3) based objection as submitted by Gabriel Media
("Gabriel"). This objection is being filed against FM Translator License BLFT-20150212AAA for W225AP.L - St.
Paul, MN (Facility ID No. 142406). The licensee of W225AP.L is Educational Media Foundation ("EMF"). The
Translator in question operates on CH225D (92.9 MHz) with 0.099 kW ERP at 504 meters AMSL. Gabriel station
KKJM(FM) - St. Joseph, MN (Facility ID No. 62129), operates under License BLH-1996051OKA with 25.0W ERP at
448 meters AMSL on CH225C3 (92.9 MHz). Therefore KKJM(FM) operates co-channel to the W225AP.L
Translator.
Since the February 12, 2015 commencement of W225AP.L, KKJM(FM) has experienced routine co-channel
interference from the EMF Translator'. As this ongoing interference has not been resolved to the satisfaction of
the KKJM(FM) listening audience, Gabriel wishes to invoke its rights as outlined under §74.1203(a)(1 &3).
Pursuant to §74.1203(a)(1), an authorized FM Translator will not be permitted to continue to operate if it
causes any actual interference to the transmission of any authorized broadcast station. §74.12O3(a)(3) again
reiterates an authorized FM Translator will not be permitted to continue to operate if it causes any actual
interference to the direct reception by the public of the off-the-air signals of any authorized broadcast station.
§73.1203(a)(3) further clarifies that interference will be considered to occur whenever reception of a regularly used
signal is impaired by the signals radiated by the FM Translator, regardless of the quality of such reception, the
strength of the signal so used, or the channel on which the protected signal is transmitted.
At this time, Gabriel wishes to submit complaints from four (4) valid KKJM(FM) listeners representing eleven
(11) individual and distinct locations of observed interference. Areas of observed interference included home
addresses, public areas and defined sections of roads or highways. A summary of the locations of observed
interference has been provided below. A map of the locations of observed interference has been provided in
Exhibit 1.1. Copies of the actual interference declarations have been provided in Exhibit(s) 2.1 to 2.4.

Name

Address

Jenny Power

555 Broadway Ave
Cokato, MN 55321
407 9th Street NE #4
Buffalo, MN 55313

Nancy Anderson

Gene Persian
Ted Roberts

3822 Colbert Ave NW
Buffalo, MN 55313
10398 61st Street NE
Albertville, MN 55301

Contact Info
_,,_Phone/email

_

1(320)224-6760
Jenn828@hotmail.com
1(763)350-1958
naa_us@yahoo.com

_;

1(763)229-6070
gapersian@yahoo.com
1(763)497-7145
teddybear9l@icloud.com

Description of Interference
On Highway 12 from Waverly to Delano
On Highway 52 from Monticello to St. Michael;
On County Road 35 from St. Michael to Buffalo;
On Highw 25 from Buffalo to Monticello
Home Address - 3822 Colbert Ave NW
_Buffalo, MN 55313
Home Address -10398 61st Street NE
Albertville, MN 55301
Riverside Church - 20314 County Road 14 NW
Big Lake, MN 55309
(general area of) Saint Michael, MN
(general area of) Rogers, MN
(general area of) Maple Grove, MN
(general area of) Dayton MN

Within the Exhibit 1.1 map, these eleven (11) individual locations of observed interference have
been plotted. Areas of noted interference include three (3) stationary addresses; four (4) sections of roads;
and four general areas (communities) of noted interference. The three stationary addresses have been
identified by the physical mailing address as well as latitude and longitude coordinates expressed as
Degree-Minutes-Seconds. The four general areas (communities) have been identified by the community
center latitude and longitude coordinates expressed as Degree-Minutes-Seconds. The four segments of
road based interference complaints have been highlighted in red. Based on the beginning and ending
landmarks as noted from each complaint, and the proliferation of road mapping software available on the
internet, the locations of each of these road based segments is considered to be a matter of record before
the Commission. However further documentation of these road based segments will be supplied upon
request.

' The objector would like to note that although W225AP.L has been operating since early 2015, co-channel interference to KKJM(FM) has continued to be an
on-going issue since the initial commencement of the Translator. The timing of this §74.1203 based objection now is a function of the culmination of on-going
interference, and also due to the objector being made recently aware of the §74.1203 interference resolution protocols of which it was formerly unfamiliar with.
MUNN-REESE
Broadcast Engineering Consultants
Coldwater, MI 49036

ENGINEERING STATEMENT

(continued

To assist in in promulgating §73.1203(a)(1&3), the objector has chosen to address a series of four
(4) criteria for this interference complaint as a whole. The criteria are:
(1) The name and specific address of each affected listener. The names and addresses of the four (4)
KKJM(FM) - St. Joseph, MN listeners experiencing actual interference have been included both within this
technical discussion as well as individually within the Exhibit(s) 2.1 to 2.4 complainant declarations
themselves.
(2) Some demonstration that the address or area of each purported listener interference remains
valid for reception of the signal in question. The addresses, communities or sections of roads
representing the interference areas in question have been plotted in Exhibit 1.1. The objector fully
acknowledges the provisions of §74.1203 do not require any signal threshold other than "the reception of a
regularly used signal". However, out of an overabundance of caution, the reception areas in question have
been analyzed and represent a KKJM(FM) off-air reception signal strength ranging from 52.0 dBp F(50:50)
to 36.0 dBp F(50:50). Such a reception signal strength is well with the scope of a listenable signal strength
with regard to §74.1203. Therefore the Commission's own standard propagation method supports the notion
that purported listener reception of the signal remains valid for this area in question. The relevant KKJM(FM)
reception contours have been plotted in Exhibit 1.1.
(3) A declaration from each of the affected listeners that he or she listens to the full-service station at
the specified location and is experiencing interference from the Translator in question. Declarations
of the four (4) KKJM(FM) listeners have been included in Exhibit(s) 2.1 to 2.4. Each listener states he or
she listens to KKJM(FM) at his or her home address, public area or defined section of road or highway, and
is experiencing interference as noted there-in.
(4) Some evidence that the authorized Translator has resulted in interference to the reception of the
full-service station in question. The addresses, communities or sections of roads representing the
interference areas in question have again been plotted in Exhibit 1.1.
The objector again fully
acknowledges the provisions of §74.1203 do not require any interference signal threshold other than a
listener experiencing "interference to the reception of a regularly used signal". Therefore the existence of the
Exhibits) 2.1 to 2.4 listener complaints are believed sufficient to meet this criteria. However, out of an
overabundance of caution, the previously identified KKJM(FM) off-air reception signal strength area, ranging
from 52.0 dBp F(50:50) to 36.0 dBp F(50:50), has been analyzed with regard to incoming Translator
interference employing the FCC's standard method. The plotted "U to D", Undesired to Desired, contour
relationships between KKJM(FM) and W225AP.L therefore requires a Translator interference signal ranging
from 32.0 dBp F(50:10) to 16.0 dBp F(50:10) over this same area (based on a §74.1204(a) co-channel
interference threshold of -20 dBla). In all cases, the Translator interference contour signal strength toward
KKJM(FM) meets or exceeds 38 dBp over this entire range. Therefore the Commission's own standard
propagation method supports the notion that purported listener interference to the KKJM(FM) signal remains
valid for the area in question over and above the listener complaints as submitted in Exhibit(s) 2.1 to 2.4.
The relevant W225AP.L interference contour has been plotted in Exhibit 1.1.

As a result of the documentation submitted here-in, specifically the existence of four (4) valid
KKJM(FM) listeners representing eleven (11) individual and distinct locations of observed interference, the
Commission is encouraged to immediately enforce the provisions of §74.1203(e) whereby EMF bears the
responsibility, as the licensee of an FM Translator, to correct any condition of interference which results from
the radiation of radio frequency energy by its equipment on any frequency outside the assigned channel.
Also pursuant to §74.1203(e), the Commission is encouraged to notify the Translator station licensee in
question, that as such interference is being caused, the operation of the FM Translator station should be
suspended and should not be resumed until the interference has been eliminated.

MUNN-REESE
Broadcast Engineering Consultants
Coldwater, MI 49036

Exhibit 1.1
Map of Observed Interference
MIIa ra
W225AP - St. Paul, MN

KKJM(FM)

BLH19960510KA
Latitude: 45-38-19 N
Longitude: 094-22-23 W
ERP: 25.00 kW
Channel: 225
Frequency: 92.9 MHz
AMSL Height: 448.0 m

to
KKJM(FM)

KKJM(FM) - St. Joseph, MN

KkJM(FM)-60.0 dBNF(5050)

ID

KkJM(FM) - 52.0 dBp F(50:50)
W225AP.L

.11

•

BLFT20150212AAA

1

E Saint Cid

Latitude: 44-58-36 N
Longitude: 093-16-15 W
ERP: 0.099 kW
Channel: 225
Frequency: 92.9 MHz
AMSL Height: 504.0 m

KkJM(FM) - 36.0 dBU F(5,050)
Cbr.Jge

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Bran

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Sai rancis

10398 61st Street NE
Albertville, MN 55301

45-14-19 N; 093-40-37 W

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20314 County Road 14 NW
Big Lake, MN 55309

, Dayton, MN
int-Michael, MN _,
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,Rogers MN
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3822Colbert Ave NW+

45-18-37 N; 093-47-16W

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3822 Colbert Ave NW
Buffalo, MN 55313
45-12-20 N; 093-55-46 W
Dayton, MN
45-14-38 N; 093-30-51 W

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Cokato

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Rogers, MN
45-11-18 N; 093-33-06W

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W225AP.L 38.5 dBN F(50.10)

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St. Michael, MN
45-12-35 N; 093-39-55 W
Scale 1:600,000

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Broadcast Engineering Consultants
COLDWATER, MI 49036

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Deb
Spirit 92.9 [deb@gabrielmedia.info]

From:
Sent :
To:
Subject:

Saturday, November 05, 2016 10:03 AM
Deb; Jessica Hart
Spirit 92.9 Signal Interruption Report

Spirit 92.9 Signal Interruption Report
Your First & Last

Name
Street

Address / CitylState/Zip

Jenny Power
555 Broadway Ave
Cokato, MN 55321

Email address

Jenn828la~ hotmaii.com

Phone Number with

3202246760

Area Code
Please list most
recent date you have
experienced signal
interruption
(mmlddfyyyy):

11 /4/2016

Where do you
experience the

Waverly through Delano on Highway

interference? (Please

12.

be as specific as
possible with
location)

Please describe the
interference with as
much detail as
possible:

Air One broadcasts on the exact same

frequency, and I can't tune into Spirit
or Air One. It basically sounds like you
put a radio in a blender. Its pretty
annoying.

Any additional
comments?

It would be nice if Air One would have

to change frequencies since Spirit was
here first.

1

Deb
From:
Sent:
To:
Subject:

Spirit 92.9 [deb@gabrielmedia.info]
Sunday, October 30, 2016 3:41 PM
Deb; Jessica Hart
Spirit 92.9 Signal Interruption Report

Spirit 92.9 Signal Interruption Report
Your First & Last
Name

Nancy Anderson

Street
Address/City/State/Zip

407 9th Street NE #4

Buffalo, MN 55313
Email address

naa us(a)yahoo.com

Phone Number with
Area Code

7633501958

Please list most
recent date you have
experienced signal
interruption
(mm/dd/yyyy):

10/30/16

Where do you
experience the
interference? (Please
be as specific as
possible with
location)

I travel daily between Monticello, St.
Michael, and Buffalo. I used to receive
the station very clearly. Now, I get it
for very short spurts. Rarely through a
full song.

Please describe the
interference with as
much detail as
possible:

Now the sound just get static. In the
few months before that, another
station would bleed over. Ironically, it
was Air 1

Any additional
comments?

I miss having Spirit 92! Please fix it as
soon as possible:)

1

Deb
From:
Sent:

To:
Subject:

Spirit 92.9 [deb@gabrielmedia.info]
Monday, October 17, 2016 9:33 AM
Deb; Jessica Hart
Spirit 92.9 Signal Interruption Report

Spirit 92.9 Signal Interruption Report
Your First & Last
Name

Gene Persian

Street
Add resslCity/StatelZip

3822 Colbert ave nw
buffalo, mn. 55313

Email address

Aapersian a)_Vahoo.com

Phone Number with
Area Code

763-229-6070

Please list most
recent date you have
experienced signal
interruption

10-17-16

(mmlddlyyyy):
Where do you
experience the
interference? (Please
be as specific as
possible with
location)
Please describe the
interference with as
much detail as
possible:

the above listed address

reception fades in and out, static

Deb
From: Spirit 92.9 tmailho:deb(aipabrielmedia.infol
Sent Saturday, November 12, 2016 5:31 PM

To: Deb; Jessica Hart
Subject: Spirit 92.9 Signal Interruption Report

Spirit 92.9 Signal Interruption Report
Your First & Last
Name
Street
A ddresslCity/State/Zip

Ted Roberts
10398 61st Street NE
Albertville, MN 55301-4313

Email address

teddvrbear91Cc.icloud.corn

Phone Number with
Area Code
Please list most
recent date you have
experienced signal
interruption
(mmldd/yyyy):
where do you
experience the
interference? (Please
be as specific as
possible with
location)

763-497-7145
11/12/2016

Everywhere around my house. In the
car right around Monticello when I
have tune in in the past 6months
when I have gone to Riverside Church
in Big Lake. Also I have had problems
tuning in when I have been taken
places such as Saint Michael, Rogers,
and Maple Towards Maple Grove
such as Dayton

Please describe the
with as
much detail as
possible:

Iet
g interference from Airl as theyy
recently boosted the power on their
translator station in Minneapolis.
According to the Airl app I should be
getting 3 out of 5 bars reception for
that signal. KTCZ owns that signal as
they rebroadcast Airl radio on KTCZ
HD2 in Minneapolis. KTCZ is Cities
97. Airl lost a signal to Hot 102.5
which is carried on 97.1 KTCZ HD3.
Airl got their 102.5 signal taken and
given to Hot 102.5 that comes from
somewhere out of state 1 think. I used
to get Spirit 92.9 crystal clear in
Albertville and now I get a lot of static
on your radio station when I try to tune
in, I have a Bose radio which is top of
the line for FM reception quality so
there is no excuse to not get your
station in unless another station is
interfering with the signal. Airl is
based out of Rocklin, California. Airl
is also a Christian station.