New FM Channel 232BWilkerson, California

Section 307(b) Analysis

The underlying allotment awarded in FM Auction 109 was for Channel 233A at Cartago, California. It is herein proposed to impliment operation on Channel 232B at Wilkerson, California. As a result of grant of this proposal, the community of Wilkerson will receive its first local service.

FM station contours in this application are calculated using the 30 second terrain database and population figures are from the 2010 census.

Wilkerson Channel 232B Spacing Study

An allocation study exhibit included in this application shows that the proposed Wilkerson Channel 232B allotment site meets the spacing requirements for Class A stations are required in 47CFR73.207 of the Commission's Rules. The spacing study also demonstrates that this proposal is mutually exclusive with the retention of the original Channel 233A allotment at Cartago.

The proposed allotment site is located 17.1 kilometers from the far side of Wilkerson. The standard 70 dBu contour distance for a Class B station is 32.6 kilometers. Therefore, and as shown in the map exhibit, the proposedallotment site will provide a 70 dBu contour to 100 percent of Wilkerson.

Wilkerson Will Receive its First Local Service

This proposal will provide the first local service to the community of Wilkerson (Priority 3), a Census Designated Place in Inyo County Californiahaving a 2010 Census population of 563 persons. The FCC considers a town or city to be a community for allotment purposes when it is either incorporated or listed in the US Census.

Wilkerson, California, in addition to being listed as a CDP in the US

Census, is a significant community deserving of its own FM allotment. Wilkerson has many businesses including; Mammoth Concrete Pumping (concrete supplier); Apple Hill Ranch (U Pick Apple Orchard); WeathersfordIrragation and Lanscaping (landscaping company); Wilkerson Storage (storage company); Ralph Reeves Pump and Well Service (well company); Dave Bowlan Plumbing (plumber); Sierra Granite Estates Mutual Water Company (water company); and Wilder-Barton Environmental and Ecological Service (evironmental consultant). Wilkerson's most famous and largest business is Keogh Hot Springs, which is a Resort, Hotel, Restaraunt, and Hot Springs Complex. As such, Wilkerson is deserving of its own local FM allotment.

Cartago is No Longer a Community for Allotment Purposes

The community of Cartago, California no longer deserves to have a Local FM allotment because Cartago has become a "Ghost Town". Attached are pictures of a defunct gas station and an abandoned restaraunt, a couple of examples of the state of Cartago. There are currently NO Retail Businesses existing in Cartago. In fact the only business of any kind even near Cartago (located just across the border south of Cartago in Olancha, CA) is the Crystal Geyser Spring Water Company which has a small bottling and truck terminal about 2 kilometers south of Cartago. At one time, decades ago, Cartago had a larger population and a few businesses, they are all gone. In the 2010 US Census, Cartago was listed as having a population of 92 persons. This has greatly decreased. "Google Search" now lists the corrected population of Cartago as being 5 persons. To makematters worse, Caltrans is planning to build a highway bypass around Cartago in 2022 and 2023 removing the traffic from US Highway 395 that runs through the center of Cartago.

No "Tuck" Study is Required

The community of Wilkerson is not located within any Urbanized Area, and the 70 dBu contour from the Wilkerson 232B facility will not encompass anypart of any Urbanized Area. There are no urbanized areas even remotely

close to this proposed facility, the nearest Urbanized Area is the Fresno, CA Urbanized Area which is over 90 kilometers from the nearest point of the Wilkerson 232B facility 70 dBu contour. Also,the Fresno Urbanized area is on the opposite side of the Sierra Nevada Mountain Range, creatinga massive signal block.

The Second Report and Order in MB Docket 09-52, Policies to Promote Rural Radio Service and to Streamline Allotment and Assignment Procedures (Rural Radio) Urban Area rules are not implicated because thisfacility is not near any Urbanized area. As such, the improvement in population served for the alloted community from Cartago (2010 population92) to Wilkerson (2010 population 563) would implicate allotment Priority 3 in this case. Priority 4 is also a factor here as the overall service contour population is greatly increased. The original allotment scenario with this facility alloted to Cartago, CA on Channel 233A produces a standard 28 km60 dBu coverage contour with 712 persons covered. The proposed allotment scenario with this facility alloted to Wilkerson, CA on Channel 232B produces a 54 dBu coverage contour with 17,831 persons covered. It should be noted that 378 persons of the 712 persons within the Cartago popcount are within the 17,831persons, Wilkerson, CA popcount. Attachedis a Gain and Loss comparison study map.

Attached as a separate exhibit is a White and Grey Area study.

Page 1 of 1Date: 9/13/2021 6:47:36 PMrfInvestigator Version 3.8.16 by rfSoftware, Inc.

Kevin FitzgeraldJob: New FM Wilkerson Allotment Study.fmjMaster Database: 2021_Sep_12.fmdLat: N37:16:19 Lon: W118:11:50 NAD-83Channel: 232 Class: BStatus: Licensed, Construction Permit, Application, Vacant/ReservedChannels: Co-Channel, 1st Adj, 2nd Adj, 3rd Adj, IFRange: 100 kmComments: No CommentsDescription: Proposed, 94.3, Wilkerson, CA; Allotment Study; The Cartago ReferenceCoordinates are the line identified as DKWTY.

Callsign Ser City StateLatitude (NAD8 Longitude (NA Channel Clas Stat73 207 73 207 ClERP HAAT Adjacen DistancBear 73 215 ClDKWTY FM CARTAGO CA N36:19:16 W118:01:25 233 : 94.5 MA VA 113 -6.35 0.00 0 1st Adj 106.65 172 10.65KOKO-FM FM KERMAN CA N36:44:29 W120:05:11 232 : 94.3 MA LIC 178 0.17 6.00 100 Co-Chan178.17 251 35.17KBOS-FM FM TULARE CA N36:38:11 W118:56:37 235 : 94.9 MB LIC 74 22.91 16.50 263 3rd Adj 96.91 223 28.91KAWJ FM COARSEGOL CA N37:25:10 W119:44:44 233 : 94.5 MA LIC 113 25.16 0.48 352 1st Adj 138.16 277 42.16KSKS FM FRESNO CA N37:04:39 W119:26:05 229 : 93.7 MB LIC 74 37.99 68.00 580 3rd Adj 111.99 259 43.99KGRB FM JACKSON CA N38:24:10 W120:39:19 232 : 94.3 MB1 LIC 211 39.14 4.30 241 Co-Chan250.14 300 72.14KISV FM BAKERSFIEL CA N35:26:17 W118:44:25 231 : 94.1 MB LIC 169 40.26 4.50 406 1st Adj 209.26 193 64.26KGEN-FM FM HANFORD CA N36:12:16 W119:33:57 233 : 94.5 MA LIC 113 57.22 3.30 136 1st Adj 170.22 226 74.22KDUC FM BARSTOW CA N34:58:15 W117:02:25 232 : 94.3 MB1 LIC 211 64.75 4.60 239 Co-Chan275.75 158 97.75KBKY FM MERCED CA N37:27:59 W120:14:13 231 : 94.1 MA LIC 113 68.96 6.00 100 1st Adj 181.96 277 85.96

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Class B Standard 32.6 km Distance 70 dBu

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Wilkerson Allot

Wilkerson Boundary

Contour AnalysisrfInvestigator Version 3.8.16by rfSoftware, Inc.Date: 9/13/2021 6:42:52 PMKey: City Grade Protected Co-Channel 1st Adj 2nd/3rd Adj

Kevin FitzgeraldJob: New FM Wilkerson Allotment Study.fmjMaster Database: 2021_Sep_12.fmdLat: N37:16:19 Lon: W118:11:50 NAD-83Scale: 1:500000Channel: 232 Class: BStatus: Licensed, Construction Permit, Application, Vacant/ReservedChannels: Co-Channel, 1st Adj, 2nd Adj, 3rd Adj, IFRange: 100 km, Clearance: -0.5kmComments: No CommentsDescription: Proposed, 94.3, Wilkerson, CA; Allotment Study Map