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                      THE CGC COMMUNICATOR
                            CGC #687
                    Wednesday,  May 18, 2005
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                 Robert F. Gonsett, W6VR, Editor
                      <r.gonsett@ieee.org>
    Copyright 2005, Communications General® Corporation (CGC)
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  MAJOR OFFENSIVE AGAINST BONILLA'S CROSS-BORDER AUTHORITIES
  A major offensive has been launched on the Section 325(c)
cross-border program transmission authorities associated with
Jaime Bonilla's XHBCE-FM, 105.7 MHz, in Baja California North.
  By using an airplane and flying to the coordinates published
for XHBCE's Class B operation, nothing but wild brush and grass
were found.  There were no power lines, roads or trails serving
the site, and a picture was provided to demonstrate that point.
Further, there was "no physical evidence to suggest that a
transmitter was ever built there" or anywhere nearby (a search
was made).  Thus, it is claimed, the transmitter site that XHBCE
has reportedly been using all these months does not exist, so
all 325(c) requests relative to that site constitute fraud.
  The real XHBCE transmitter was discovered on Cerro Bola
mountain 10-miles away and at a much higher elevation than the
authorized Class B site.  A number of technical questions
have arisen regarding the facilities found there.  But there
is more.
  Mr. Bonilla's XEKTT, 1700 kHz, should be using two towers of
equal height, but two towers of "grossly unequal height" were
found instead, calling into question the nighttime radiation
pattern of that station.  XESDD, 1030 kHz, should be using a
three-tower directional antenna array to beam its signal away
from the U.S. both day and night, but was photographed using one
tower (presumably omni-directional) instead.  And XESS, 620 kHz,
should have been sharing that same three tower array to protect
the U.S. full time, but XESS' transmitter had mysteriously
migrated 21 miles closer to the U.S. and was discovered at the
XEKTT site, virtually right on the U.S./Mexican border, without
the required three tower array.
  To see and read more, open the two pdf documents below.
The first doc contains an Engineering Statement with colored
photographs of the numerous alleged technical transgressions; the
second doc is a copy of the complete legal and engineering package
filed with the FCC as a formal complaint (the engineering photos
did not reproduce properly in this, the only pdf doc available to
us at this time, hence the separate posting of the Engineering
Statement).
  There is much more to this story, probably one of the biggest
stories to break in the local broadcast community in years.  From
this one 325(c) case, a number of legal actions may follow
including demands for massive power rollbacks at some or all of
the Bonilla properties, and retractions of all 325(c) permits.
  Keep in mind that the charges made so far are only allegations
and that the Bonilla organization needs to be given an opportunity
to respond.  There may be mitigating technical factors at work or
special agreements between the U.S. and Mexico of which we are
unaware.
  Our experience indicates that there are many fully
compliant broadcast facilities in Mexico and that this case
- if the allegations hold - is not representative of the Mexican
broadcast industry as a whole, and should not reflect negatively
on the many fine people in Mexico who strive for excellence.
  Engineering Statement alone (1 mega byte in size):
  http://earthsignals.com/add_CGC/baja_engr.pdf
  Complete Petition to Deny (sans photos, 2 mega bytes in size):
  http://earthsignals.com/add_CGC/pet_to_deny.pdf
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