Covenant International Church

Larry W. Seratt
Senior Pastor

"Beloved,
I wish above all
things that you
prosper and be
in health, even
as your soul
prospers."
III John 2

P. O. Box 5747
Glendale, AZ 85312
Phone 623.842.8421
fax 623.842.5081

Larry Seratt Ministries
Covenant International Church
E-mail: info@covenantinternationalchurch.com
Web: www.covenantinternationalchurch.com


December 24, 2003

FCC
Attn: Secretary's Office
Closed Captioning
445 12th Street, S.W.
Washington, D.C. 20554

RE: REQUEST FOR EXEMPTION FROM COMMISSION'S
CLOSED CAPTIONING RULES

Covenant International Church respectfully submits this petition requesting 
exemption from the closed captioning requirements, under Section 79.1 of the 
Commission's rules, 47 C.F.R. & 79.1.  Covenant International Church believes 
their program "Your Time Has come" qualifies for this exemption for the 
following reasons: 

Part 79.1 Section (D)
Item (8) "Your Time Has Come" is locally produced and distributed non-news 
program with no repeat value.  The program is of local public interest, is not 
a news program, and the "electronic news room" technique of captioning is 
unavailable. 

Part 79.1 Section (F)
Compliance would impose an undue burden to Covenant International Church for 
the following reasons: 

(1) It would be necessary to send the programs to an outside source for 
captioning.  This would impact meeting airdate deadlines and the added 
production cost would make production unaffordable. (see attached) 

(2) Covenant International Church would have to discontinue our program and 
cease broadcast operations. 

(3) Covenant International Church is self-funded and the added cost would be 
an undue burden on the Ministry at this time. 

Again, we respectfully request that Covenant International Church be exempted 
from the closed captioning requirement for the above stated reasons.  We may 
be reached at: 

Covenant International Church
8807 North 61st Ave.
Glendale, AZ 85312
Phone #: 623-842-8421
Fax #: 623-824-5081
Email: info@larryseratt.com

Sincerely,

/s/
Pastor Larry W. Seratt





December 24, 2003

Page 2

RE:  REQUEST FOR EXEMPTION FROM COMMISSION'S
CLOSED CAPTIONING RULES

 Part 79.1 Section (F)
(1) Attachment - Covenant International Church Affidavit of: Airtime, Production and Captioning Costs

1 - AIRTIME
* 551.25 Per Program.
52 programs x $551.25 = $28,665.00 per year.


2 - PRODUCTION
* $1077.00 Per Week
52 weeks x $1077.00 = $56,004.00 per year

Total Yearly Costs of: $84,669.00 per year


3 - ADDED CAPTIONING COSTS
* $327.00 Per 30-minute Weekly Program.
52 weeks x $327.00 = $17,004.00 per year

Total Yearly Costs of: $101,673.00 per year