Huntington Park Church of Christ

6161 West 70th

Shreveport, LA 71129

318-686-0873 [email protected]

Huntington Park Church of Christ

12 December 2011

Office of the Secretary Federal Communications Commission Attention: Disability Rights Office, Room 3-B431 445 12th Street, SW Washington, DC 20554

References: Huntington Park Church of Christ / Search for Direction Case Identifier: CGB-CC-0341

,

Gentlemen:

Received & In£:oe"4pd

DEC 1 9 2011

FCC Mail Room

We are in receipt of your letter of 25 October 2011 advising ofthe reversed decision for the closed caption exemption granted to us in September 2006. We reapplying for reconsideration of that exemption.

Huntington Park Church of Christ is a 110 member congregation based in Shreveport, Louisiana. As part of our missionary work, we produce a 30 minute television program called Search for Direction.

The budget for the church is $201,000.00 which hasn't been met Ofthat amount, Huntington has set aside $12,000.00 for our part ofthe cost ofthe television show. The cost of the show is $446.00 per week or $23,192.99 per year. The remaining $11,192.00 is provided by some 10 outside congregations in and around our viewing area. Many of those congregations have memberships of 50 people or less. By themselves, they are not capable of much outside missionary work, but most can provide us with $100.00 per month to help with the program. Every year our congregation solicits funds from outside congregations, and these congregations are the only ones which have agreed to helping with the cost of the program.

To save on costs, the television show is recorded in house in a class room. The television station we use to air the program is identified as KSHV, MY 45, located at 3519 Jewella

Elders: Ronnie Hollis, & Neil Walker Millistel": .FlQyd ,. }onnlioll • • • • • • • • • • • • • • • •

Page Two Ref: Huntington Park Church of Christ

Avenue in Shreveport, Louisiana. We have been advised by the station closed captioning is not required as the station has less than $3,000,000 in revenues. They also advise us that they are not capable of closed captioning in house, but can send out our program to a sister station in Houston, Texas which can do that work. The cost of captioning one program is $400.00 plus there is a turn around of 2 weeks. We record our program on Tuesday night for airing on the following Sunday morning so the turn around alone would present a difficulty for us. We attach a letter from the station supporting this information.

In addition to the recorded show, Huntington makes an audio CD available of each television show we produce. On average, we have requests for 8 to 10 CDs each week. This cost is shouldered by Huntington Park.

Huntington Park has investigated the possibility of using an outside source for closed captioning. The various facilities we have contacted cost from $175.00 to $200.00 on average. However, many of those facilities provide the captioning on a separate tape which must be reattached to the program. Huntington Park does not have the equipment to reattach that captioning. We record our program directly to a DVD and pass it on to our Television Station which processes the program into their system.

To recap our request, Huntington Park Church of Christ requests they be granted an exemption for closed captioning because the cost of providing that service would almost double the cost of airing the programming. We do not have the finances to absorb that cost, and our outside contributors cannot as well. Our Television Station does not have closed captioning capabilities, and the use of their sister station would send the costs into orbit. The extra expense would jeopardize our ability to continue producing this program for our local community.

Producing our television show is an all volunteer situation. Our show is recorded on a Tuesday night for airing on Sunday. The turn around time would be an inconvenience since our volunteers are available on Tuesday. Huntington would have to produce several shows per week to have enough available to even consider sending them off.

Huntington Park feels our television work is an effective way in which we are able to get the gospel message out to our local community. Placing the added burden of closed captioning of our program places the cost at the point where we may not be able to continue producing it. We attach a copy of our supporting congregations along with a copy of our budget, invoice from the television station, and the letter from KSHV.

Page Three: Ref: Huntington Park Church of Christ

We attach a redacted copy of this petition for public inspection. We ask that you grant us an exemption for closed captioning so we can continue our work producing the program without a continued fear of a looming cloud overhead.

Respectfully submitted,

~~~'~"'~ Michael L. England For the Elders

Enclosures: Letters from KHSV (2) Copy of Budget List of Supporting Congregations Correspondence from Closed Caption Companies

Budget - Current Year 1/1/2011 through 12131/2011 Using Budget 2

12/11/2011 Page 1 111/2011 12131/2011

Category Description Actual Budget Difference - - ---

INCQME Interest Inc 58.82 0.00 58.82 Other Inc 0.00 0.00 0.00 Reg Contributions 177,813.60 201,326.00 -23,512.40 Tax Refund 2,891.40 0.00 2,891.40

Divlnc 860.92 - 0.00 860.92 Intlnc 0.00 0.00 0.00

--- ---TOTAL INCOME 181,624.74 201,326.00 -19,701.26

EXPENSgS

Administration

equip repairs 0.00 1,500.00 1,500.00 insurance

building 3,419.72 5,700.00 2,280.28

comp 0.00 2,000.00 2,000.00

Other Administration :insurance 0.00 0.00 0.00 - ._- -- --- -- - -TOTAL insurance 3,419.72 7,700.00 4,280.28

office supplies 7,719.39 8,000.00 280.61

postage 3,042.77 3,500.00 457.23

use taxes 0.00 100.00 100.00 Other Administration 0.00 0.00 0.00

TOTAL Administration 14,181 .88 20,800.00 6,618.12

Benevolence

$ Day -1,458.00 0.00 1,458.00

personal aid 1,900.00 1,000.00 -900.00

remembrance 465.21 300.00 -165.21

Southern Christian Home 6,224.00 4,200.00 -2,024.00

Other Benevolence 0.00 0.00 0.00

TOTAL Benevolence 7,131 .21 5,500.00 -1 .631.21

Facilities

alarm expense 291.55 300.00 8.45

build repairs 5,480.76 3,000.00 -2,480.76

carpet cleaning

contingency 0.00 400.00 400.00

Other Facilities:carpet cleaning 0.00 300.00 300.00

TOTAL carpet cleaning 0.00 700.00 -----

700.00

cleaning service 15,668.52 16,400.00 731.48

custodial supplies 2,170.15 1,800.00 -370.15

equip and furnishings 0.00 800.00 800.00

garbage collection 1,100.37 1,000.00 -100.37

nursery items 0.00 0.00 0.00

pest control 375.00 375.00 0.00

Other Facilities 0.00 0.00 0.00

TOTAL Facilities 25,086.35 24,375.00 -711.35

Grounds

ground expense 0.00 2,000.00 2,000.00

mowing 3,150.00 4,000.00 850.00

Other Grounds 0.00 0.00 0.00 ------ -- - - 6,000.00 2,850.00 TOTAL Grounds 3,150.00

Meetings

gospel meeting 1,607.66 1,000.00 -607.66

lectureship 1,851 .68 2,000.00 148.32

spec speakers 0.00 300.00 300.00

vbs 336.76 800.00 463.24

Other Meetings 0.00 0.00 0.00

TOTAL Meetings ----

3,796.10 4 ,100.00 303.90

Missionary work

,.

12/11/2011

Budget - Current Year 1/1/2011 through 12131/2011 Using Budget 2

Category Description ----- - ----contingency india IGT La tech Other Missionary work TOTAL Missionary work- ---- -

Payroll 941 payments preacher

expenses IRA salary Other Payroll:preacher TOTAL preacher

secretary fed wh fica

salary

1/1/2011 Actual

300.00 10,000.00

950.00 200.00

11,450.00

2,928.00

14,575.00 -2,551 .35 54,903.66

0.00 66,927.31

-1,082.76 -1,237.72 15,468.52

0.00

12/31/2011 Difference

---Budget

2,000.00 6,000.00

600.00 0.00

8,600.00

6,60000

15,900.00 0.00

58,211 .00 0.00

74,111 .00

-1,120.00 -1,280.00 16,400.00

0.00

1,700.00 -4,000.00

-350.00 -200.00

-2,850.00

3,672.00

1,325.00 2,551.35 3,307.34

0.00 7,183.69

-37.24 -42.28 931.48

0.00 Other Payroll:secretary ---=:::-=:-:--..0..---,-----'-----------:-:-:-,-:.---- _. _ ____ _ _ _ _ _ .. ____ _

TOTAL secretary 13,148.04 14,000.00 851.96 Other Payroll 0.00 0.00 0.00 - ---------- ----_.-TOTAL Payroll 83,003.35 94,711 .00 11,707.65

Teaching advertisements 0.00 100.00 100.00 books and tracts 385.62 800.00 414.38 class materials 2,333.16 2,500.00 166.84 Other Teaching 0.00 0.00 0.00

---==-:-=-:---~---- - ---------- .---- - ----- -- -. __ ._ - -- ------ - ---------TOTAL Teaching 2,718.78 3,400.00 681 .22

Television contributions My Network 45 video supplies and equipment Other Television TOTAL Television

Utilities electric telephone water Other Utilities TOTAL Utilities

Youth Pettyjohn Springs summer series young at heart Other Youth TOTAL Youth

TOTAL EXPENSES O-=C:-:V=-ERA==--:CL:-:L-cr:;::O:=";r""'A'-;L--- - - ~-- ----

-12,060.00 22,183.00

4,119.53 0.00

14,242.53

10,431.62 3,538.80

924.17 0.00

14,894.59

5,500.87 0.00 0.00 0.00

5,500.87 185,155.66

-3,530.92

-12,000.00 23,400.00

2,000.00 0.00

13,400.00

60.00 1,217.00

-2,119.53 0.00

-842.53

11,000.00 568.38 3,900.00 361.20

640.00 -284.17 0.00 0.00

15,540.07:0,----6,,--45.41

4,000.00 -1,500.87 300.00 300.00 600.00 600.00

0.00 0.00 4,900.00 -600.87

- 201,326.0=0:------=1-=-6,--=-17=0:--,.3:::-:4

0.00 -3,530.92

Page 2

CONTRIBUTING CONGREGATIONS

( 2011 Budget Date)

Carriage Oaks Church of Christ

Plain Dealing Church of Christ

Ringgold Church of Christ

Serepta Church of Christ

Cotton Valley Church of Christ

Waskom Church of Christ

Atlanta Church of Christ

Stamps Church of Christ

Hope Church of Christ

East Land Church of Christ (one time contrib. )

www.kshv.com

Billing Address:

Send Payment To:

KSHV 3519 Jewella Ave Shreveport, LA 71109 Main: (318)631-4545 Billing: (318)631-4545

Huntington Park Church Attention: Accounts Payable 6161 West 70th Street Shreveport,LA 71129

INVOICE

Invoice #

39523-11

Station

KSHV

Advertiser

Account Executive

Cynthia Holman

Invoice Month

November 2011

Product

Huntington Park Church 2011 Search For Direction

[Special Handling

Page 1 of 1

Safes Region

Local

KSHV POBox 30045 Shreveport,LA 71130

IIDB# IAdvertiser Code 1 Product Code

Line Start Date End Date Description Start/End Time

501/02/11 12/25/11 Paid Program Sun 8-8:30;8-830a

Weeks: Start Date End Date MlWTF55 10/31/11 11/06/11 ------5

Spots: '!! Ch Q§:t Air Date Air Time Description

Spots/Week 1

149 KSHV Su 11/06/11 8:00 AM Paid Program Sun 8-8:30a Weeks: Start Date End Date MlWTF55 Spots/Week

11/07/11 11/13/11 ------5 1 Spots: '!! Ch Q§:t Air Date Air Time Description

150 KSHV Su 11/13/11 8:00 AM Paid Program Sun 8-8:30a Weeks: Start Date End Date MlWTF55 Spots/Week


151 KSHV Su 11/20/11 8:00 AM Paid Program Sun 8-8:30a Weeks: Start Date End Date MTWTFSS Spots/Week


152 KSHV Su 11/27/11 8:00 AM Paid Program Sun 8-8:30a

Payment Terms 30 Days

MTWTF55

------5

Rate $446.00

Start/End Time 8-830a

Rate $446.00


Rate $446.00


Rate $446.00


Total Spots

rgenCYRef

Spots/

Length Week

28:30 1

Length Ad-ID 28:10 HP 1106

Length Ad-IO 28:30 HP 1113



4

rdVertiSer Ref

Rate Type

$446.00 NM

Net Total

Rate IYP.§

$446.00 NM

Rate IYP.§

$446.00 NM

Rate IYP.§

$446.00 NM

Rate IYP.§

$446.00 NM

$1,784.00

We warrant that the actual broadcast information shown on this invoice was taken from the program log . This station does not accept advertising contracts that impermissibly discriminate against race or ethnicity

TO: Michael England Huntington Park Church of Christ Shreveport, LA

FROM: Susan Newman, General Sales Manager KSHV TV, Shreveport, LA

DATE: December 1,2011

In response to Huntington Park Church's request for information necessary to petition for an exemption from FCC closed captioning rules, this will serve as confirmation that KSHV TV, Shreveport, LA, is exempt from closed captioning obligations in accordance with the FCC ruling pertaining to channels with less than $3 million annual revenue.

If you have further questions, please contact me directly at 671-7257 or [email protected]

Thank you.

KSHV My45 3519 Jewella Avenue Shreveport, LA 71109 Phone: 318-631-5677

!-lUi Itington Park. Chwdl of Chri " t Video Inspiri'ltions

61 :~2W 70

St1i"i~vepc(t, '-fl, 71129

A MERRILL COMMUNICATIONS COMPANY

! un(ierstand Hunthgt,)n F'ark Chl.j;-c;-I of C!lrist Video In3piratio'1s may be requil-ed to caption previously exempt

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November 2, 2011

Dear Media Director,

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IMPORTANT CLOSED CAPTIONING INFORMATION

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~flIo; FCC Closed-Captioning Exemption Rule Changed

You have options: '\

1. The least expensive way is to supply the TV station a CCed DVD. We create a 'caption file' you add to the DVD; Apple DVD StudioProlEncore. Cost is $1 OO/per half-hour weekly program.

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3. You caif't!'t1d~,~~s a DVlBetaSP tape, we create a CCed BetaSp and forward it to the TV station. Cost is $ 150/per program.

Huntington Park Church of Christ

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