New Life
Team
Partners

Pastor Darrell Huffman

New Life Team Partners
P O Box 1113
Huntington, WV 25713
Office (304) 733-4423
Fax (304) 736-3873
www.nlconline.org


December 15, 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

New Life Team, an outreach of New Life Church, [hereinafter, NLT] 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.  
NLT believes their program New Life Today qualifies for this exemption for the 
following reasons: 

Part 79.1 Section (D)
Item (8) New Life Today is a 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 NLT and New Life Church for the 
following reasons: 

(1) Since New Life Church does not have "closed captioning" equipment, it would 
be necessary to send the programs to an outside source for captioning.  This 
would severely impact meeting airdate deadlines, and further, the added 
production cost would make production of the television program unaffordable. 
NLT and New Life Church would have to discontinue programming and cease 
broadcast operations.  An affidavit showing the unaffordable cost is hereto 
attached and labeled EXHIBIT "A". 

(2) NLT is not funded or granted in any way by outside sources.  NLT depends 
on support from individual donors and from New Life Church.  The significant 
added cost would be an undue burden on the Ministry at this time. 

(3) NLT is an outreach ministry of New Life Church whose sole purpose is to 
share the abundant life we have through Jesus Christ with our local community. 

Again we respectfully request that New Life Team and outreach of New Life 
Church be exempted from the closed captioning requirement for the above stated 
reasons.  We may be reached at: 

New Life Team
1101 Cedar Crest Drive
P.O. Box 1113
Huntington, WV 25713
(304) 733-4423

In His Service,

/s/
Pastor Darrell Huffman
President





AFFIDAVIT

Exhibit "A"

State of West Virginia
County of Kanawha, ss

1. Introduction.  Being duly sworn, Robert St. Clair, deposes and says:

2. Description of Deponent.  I am the Owner of Saints Video Solutions Corp., a 
corporation organized and existing under the laws of the State of West 
Virginia, and qualified to do business under the laws of the State of West 
Virginia, with its principal offices at 164 South Edgemont Rd. Huntington, WV. 

3. Statement of Fact.  We regularly engage in the business of producing 
"closed captioning" for various programs, news & sporting events which are 
broadcast on television.  We are knowledgeable of the procedures and the costs 
associated with such production.  The cost to add closed captioning to the 
weekly ministry television program known as New Life Today, an outreach 
television ministry of New Life Church will be $600.00 per program.  Said cost 
of this closed captioning production is in addition to any regular production 
costs. 

To the best of my knowledge, these facts are a true representation of the 
costs associated with the production of closed captioning for the 
aforementioned program. 

/s/ Robert St. Clair
Deponent


Sworn before me this the 24th day of December, 2003.

/s/ Debra C. Price
Notary Public

STATE OF WEST VIRGINIA
OFFICIAL SEAL
NOTARY PUBLIC
STATE OF WEST VIRGINIA
DEBRA C. PRICE
6683 MUD RIVER ROAD
BARBOURSVILLE, WV 25504
My commission expires April 11, 2011