ORIGINAL
Before the

FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554
In re Applications of
CALVARY CHAPEL OF TWIN
FALLS, INC.

AN 232014
mrnunicathjils
irc nf th Spcrntarv

For Renewal of License for the
following broadcast stations in the
State of Oregon:
K247AQ (139138)

File No. BRFT-20130926AQD

/ KDJC-FM (121839)

File No. BRED-20130926AMU

'K2O3DY (88518)

File No. BRFT-20130926AQC

JK2OIDV (77718)

File No. BRFT-20130926AQA

IK2O2DT (91875)

File No. BRFT- 20130926APZ

K2I8DP (90439)

File No. BRFT-20130926APY

IK2I6EH (91971)

File No. BRFT-20130926APX

.iKJCH-FM (90263)

File No. BRED-20130926AMV

v21 2AK (72002)

File No. BRFT-20130926APU

;K273AJ (91973)

File No. BRFT-20130926APS

K2O5DM (92498)

File No. BRFT-20130926APQ

K2O2EH (90256)

File No. BRFT-20130926APP

1K213CF (82789)

File No. BRFT-20130926AP0

'f KQDL-FM (174458)

)

File No. BRED-20130926AMY

KPIJ-FM (92491)

File No. BRED-20130926ANG

K246BB (139146) V

File No. BRFT-20130926APL

K22011 (122157)

File No. BRFT-201 30926APJ

K296BS (71972)

File No. BRFT-20130926APH

K276E0 (139145)

File No. BRFT-20130926APG

K2O1DH (77128) ,/

File No. BRFT-20130926APE

K2201N (121763)

File No. BRFT-20130926APD

K288FT (138942)

File No. BRFT-201 30926A0X

KKJA-FM (92285)

File No. BRED-20130926ANA

K2I4CM (77106)

File No. BRFT-20130926APC

K29OBK (138665) V

File No. BRFT-20130926APB

K28OBK (71989)

File No. BRFT-20130926APA

K205EG (91527)

File No. 20130926A0Y

To:
Office of the Secretary
Attn: The Commission

OPPOSITION TO
PETITION TO DENY
Calvary Chapel of Twin Falls, Inc. ("CCTF"), by counsel, and pursuant to
Section 1.45 of the Commission's Rules, hereby opposes the "Petition to Deny" filed
January 2, 2014 by Cohn Innes ("Innes) against the above-captioned pending license

2

renewal applications.!1

For the reasons explained below, CCTF submits that the Innes

petition is replete with substantially false conclusions of fact and a total lack of
knowledge of longstanding thoughtful FCC policy. Innes has not supplied one factually
correct statement to support the denial of any of the CCTF license renewal applications,
nor has Innes correctly applied established FCC policy.

The Innes petition is nothing

more than a complaint about certain broadcast policies of the Commission.

Those

matters should be addressed in the context of a Petition for Rule Making rather than
against the license renewal applications of CCTF. In support hereof, CCTF submits the
following:

Background
By way of brief summary, the introductory paragraph of the Innes petition states
that CCTF neglects coverage of community issues, abuses the main studio waiver rules
and provides redundant and abused translator service.

lnnes states immediately

thereafter that CCTF's facilities prevent the use of LPFM channels for local community
use, and he questions how any studio-waived station can provide local public service
programming to the satellite station community. See, initial page of the Innes petition.
On the third page of his petition, Innes asks the FCC to define "serving the public
interest."

Innes wrongfully concludes that CCTF's stations "merely play music, provide

biased editorials, promote calls to action and contains no local public affairs coverage."
On the fourth and fifth pages Innes complains that the FCC does not audit main studio
waivers, and he concludes that CCTF does not qualify as an NCE licensee. Innes
1 Public Notice of the lnnes petition issued on January 7, 2014. See, Public Notice
Report No. 28150.

3

concludes his petition by stating that CCTF's large number of translator stations is
"excessive."

The Truth of These Matters Completely Contradict Innes' Allegations
At the outset, the Commission should recognize that none of the allegations
raised in the lnnes petition are supported by actual facts. Attached hereto as Exihibit
No. I is the Declaration of Mike Stocklin, the Chief Executive Officer of CCTF.

Mr.

Stocklin's sworn statement states the following:

The programs broadcast over the CCTF network are all produced by various
ministries throughout the country and the programming topics include
salvation, marriage, counseling, anti-abortion, raising children, human
health, mental illness and hundreds of other topics.
are musical in nature.

None of the programs

A representative weekly program schedule is

attached to Mr. Stocklin's Declaration.

2.

CCTF's regular radio programming includes content that originates from
ministries located in Oregon.

Every Monday through Friday at 12:30 pm

Mountain Time CCTF broadcasts "Searchlight" with Pastor Jon Courson
from Applegate, Oregon.

And every Monday through Friday at 5:00 pm

Mountain Time CCTF broadcasts "The Way, the Life, the Truth" with Pastor
Mall Foxx from Coos Bay, Oregon.

3.

CCTF has received no complaints from Oregon residents about its radio
programming, and CCTF has over 300 Oregon residents noted on its

4

Donor's List.

4.

With regard to maintaining proper main studio waivers, where applicable, Mr.
Stocklin's Declaration includes a second attachment that shows the required
protocols undertaken by CCTF - the maintenance of a toll free telephone
number, access to the station public file at no charge, local representatives
that hold meetings and advise CCTF on local issues, local on-air promotions
for community and church events, and other outreach efforts.

All in all, the facts demonstrate that all of the Innes allegations that relate to the
programming record and public service efforts of CCTF are fundamentally and
completely incorrect.

It is no surprise that nowhere in the Innes petition does it state

that lnnes actually listens to CCTF programming.

The Commission's limited time and

resources should not be expended on such uninformed opinions.!2

The Opinions of Innes Contradict Thoughtful Longstanding Policies of the FCC
The FCC's FM Translator Policies:

Contrary to the opinion of Innes, during the

past forty-three years the FCC has developed a thoughtful FM translator policy, and
CCTF has availed itself of that policy to provide meaningful, spiritual and positive
By way of FCC policy background, the FM

programming throughout the United State.

2

In the second paragraph of his petition, Innes claims that CCTF's licenses prevent
Not only is that argument
the use of LPFM channels for local community use.
technically untrue, but it also shows the real motivation behind his petition. The FCC
designed the LPFM service to co-exist with existing full power FM and existing FM
translator stations, not to replace them. See generally, Creation of Low Power Radio
Service, Report & Order, 15 FCC Rcd 2205 (2000).

5

Translator service was instituted in 1970 as a means to supplement the primary service
provided by full facility FM stations. See, Report and Order in Docket No. 17159, 20 RR
2d 1538 (1970). The translator rules initially adopted by the Commission restricted both
commercial and noncommercial FM translators to the rebroadcast of signals received
directly over-the-air from their primary stations or another translator. Subsequently the
Commission accepted a Petition for Rule Making and commenced a Rule Making
proceeding in Notice of Proposed Rule Making in MM Docket No. 86-112, 104 FCC 2d
318 (1986). On the basis of the record developed in that proceeding, the Commission
modified Section 74.1231(b) to provide for a Noncommercial Educational FM ("NCEFM") translator station that is operating on a reserved channel and is owned and
operated by the licensee of the primary NCE-FM station it rebroadcasts to use
alternative signal delivery means, including but not limited to, satellite and terrestrial
microwave facilities. See Amendment of Part 74 of the Commission's Rules to Provide
for Satellite and Terrestrial Microwave Feeds to Noncommercial Educational FM
Translators Report and Order, 3 FCC Rcd 2196 (1988)("1988 Report and Order");
recon. granted in part, 4 FCC Rcd 6459 (1989).
In expanding upon the over-the-air reception option that was previously provided
for translator signal delivery, the 1988 Report and Order found it desirable to provide
NCE licensees operating in the reserved band full discretion to choose the means of
input signal delivery most suitable to their particular circumstances in delivering signals
to their commonly-licensed translators.

The Commission found that such expanded

licensee discretion would serve the public interest by expanding opportunities for

6

providing quality FM service to unserved and underserved areas, without altering the
secondary status of NCE translators vis-a-vis full service FM stations.!3
Over time, and in response to changes in the broadcast industry and
technological advancements, the Commission provided additional modest refinements
to its translator policies. For example, by Letter Ruling dated November 7, 2000 (in re
BPFT-1 9981 023TB; Lawton, Oklahoma) the Commission decided that the satellite feed
from a parent NCE-FM station to its commercial frequency translator station may
emanate directly from the programming production facilities of the parent NCE-FM
station, rather than directly from the parent NCE-FM station's transmitter.

The

Commission concluded that simultaneous satellite signal delivery from the programming
production facilities to both the parent NCE-FM station and its translator was permissible
so long as the translator ceased operating when the parent NCE-FM station ceased
operating for any reason.
The Commission also modified another longstanding FM Translator policy in the
above-referenced Lawton, Oklahoma case. Until that time, the Commission would not
consider authorizing an FM Translator station on the same frequency as its Primary
Station. However, when BPFT-19981023TB was granted on November 7, 2000, FM
Translator Station K21ODJ was authorized to carry Primary Station KWKL-FM (Channel
210) from Grandfield, Oklahoma. See, FCC Construction Permit BPFT-19981023TB for
K2IODJ, issued November 7, 2000.

So the FCC will consider co-channel Primary

The 1988 Report and Order recognized that this rule change increased the
likelihood that translator networks would be created, but held fast that a network of only
translators would not be permitted.

7

Station I Translator situations if the Translator Station does not operate in the immediate
vicinity of the Primary Station.
In keeping with the longstanding tradition that FM translator stations be utilized to
expand the areas and population coverage of full power radio stations, the Commission
more recently took another bold step forward when it changed the FM translator rules to
allow certain FM translator stations to rebroadcast certain AM broadcast stations.

See,

Report and Order in MB Docket No. 07-172, FCC 09-59, issued June 29, 2009.
CCTF submits that the FM translator policy that Innes objects to is
unquestionably in concert with the public interest. CCTF, like numerous other broadcast
licensees, availed itself of these policies to provide both regional and national coverage
of its religious and educational programming. Many of CCTF's FM translator stations
serve just a few thousand people, and they provide religious and spiritual programming
to rural areas that receive no other similar alternative radio programming.
exactly what the FM translator service was designed to do.

And this is

So, to the extent lnnes

wants these policies reviewed by the Commission, such matters should be addressed in
a formal rule making proceeding and not within the context of a license renewal
challenge.!4

lnnes alleges that CCTF's FM translator network provides redundant programming.
See, Innes petition at Page 1. Such allegations run completely in the face of the
Commission's analysis when it authorizes a new or modified FM translator station.
FCC Form 349 includes a Section Ill-A certification about "multiple translators." An
FM translator will not be authorized if that licensee has another FM translator station
that serves substantially the same area and rebroadcasts the same full power FM
primary signal. Although CCTF provides substantial coverage of the United States
with its large number of FM translator stations, such service is anything but redundant.

8

The Main Studio Waiver Policy:

Although Section 73.1125(a) of the

Commission's Rules requires each broadcast station to maintain a main studio within
the station's community of license, or within the principal community contour of any
other broadcast station licensed to the same community, or within 25 miles of the center
of the community of license, this requirement will be waived where good cause exists.
Each waiver request by an NCE station seeking to operate as a satellite of another NCE
station is considered on a case-by-case basis. The Commission has recognized the
benefits of centralized operations for NCE stations, given their limited funding/5, and
thus found good cause exists to waive the main studio location requirement where
satellite operations are proposed.

See, Review of the Commission's Rules Regarding

the Main Studio and Local Public Inspection Files of Broadcast Television and Radio
Stations ("Reconsideration Order'), 13 FCC Rcd 15691 (1998); recon. granted in part,
14 FCC Rcd 11113 (1999).

Generally the Commission requires the licensee of a

studio-waived station to appoint a local representative in the satellite community area,
hold meetings in the satellite community area to ascertain programming interests and
needs, to subscribe to or monitor local publications and to maintain a toll-free telephone
number for residents of the satellite community to call the licensee.

The Commission's

main studio waiver policy is well-established and time tested.

See, Nebraska

Educational Television Comm., 4 RR 2d 771 (1965); Georgia State Board of Education,
70 FCC 2d 948 (1979), recon. Denied, 71 FCC 2d 227 (1979); Sound of Life, Inc. 4 FCC

To a large degree, NCE-FM broadcast stations have limited funding since they can
only broadcast underwriting announcements for for-profit entities. Traditionally
underwriting announcements generate less revenue than commercial advertisements.

9

Rcd 8273 (1989); The Cedarville College, 6 FCC Rcd 538 (1991); Letter to Roy R.
Russo, Esq. (dated Januaiy 24, 1994); Letter to WPVA-FM (dated November 13, 2003).
Dozens of educational and religious broadcasters have availed themselves of the
main studio waiver policy with little complaint from the public.

By doing so, the

Commission recognizes that there are numerous ways to provide local public interest
programming.

As noted in the above-referenced Declaration of Mike Stocklin, CCTF

maintains the necessary protocols to sustain each main studio waiver in compliance with
Commission rules and policies.

FCC Programming Policies To Serve Community Interests & Needs
The Innes petition generally questions how any studio-waiver station can provide
programming that is responsive to the interests and needs of the local community.
Unfortunately Innes fails to recognize established FCC policy in this area.

lnnes

exhibits a narrow view of these matters that not only demonstrates his lack of
fundamental knowledge of FCC policy but also shows his prejudice against religious
programming as a whole.
Long ago the Commission declared that "[un serving the needs of his community,
the broadcaster is not required to meet all community problems; rather, a licensee may
determine in good faith which problems merit treatment by the station. In making this
determination, it may consider the particular format of the station, the composition of its
audience and the programming offered by other stations in the community.

Taft

Broadcasting Company, 38 FCC 2d 770, 790; 26 RR 2d 269 (1973); Miami Valley

10

Broadcasting Corp., 48 FCC 2d 177, 187; 30 RR 2d 1742 (1974).
In a more recent ruling it was stated that "the Commission has specifically noted
that programming not produced in or targeted at a local community may nonetheless
serve the needs and interests of the community. Indeed, the issues selected by a
licensee to be addressed may be determined by the interests and nature of its audience
and the availability of other program services, including national programs." See, KGAN
Licensee, LLC, 25 FCC Rcd 2549, 2557 (2010); WHYY Licensee, LLC, DA 10-1352
(released July 23, 2010). Although licensees have a duty to respond to local needs by
choosing appropriate programming, they also have broad discretion to determine, in
good faith, the issues they believe to be of concern to their communities and the manner
in which to address those issues.

See, Time-Life Broadcast, Inc., 33 FCC 2d 1081,

1092 (1972); Philadelphia Station License Renewals, 8 FCC Rcd 6400, 6401 (1993);
Radio License Holding VII, LLC, DA 13-2 106 (released October 31, 2013).

The

Commission will not intervene unless a licensee has abused this discretion and has
consistently and unreasonably ignored matters of public concern.

See, Columbia

Broadcasting System, Inc., 51 FCC 2d 273, 280 (1975); 0 & H Media, LLC, DA 13-1699
(released August 2, 2013).
The Commission's general policy to leave format issues to the discretion of the
licensee is particularly so with regard to NCE stations. The Commission historically has
had the appropriately limited role of facilitating the development of the public
broadcasting system rather than determining the content of its programming.

See,

Revision of Programming Policies and Reporting Requirements Related to Public
Broadcasting Licensees, NPRM, 87 FCC 2d 716, 732 (1981); College of Staten Island,
DA 07-1249 (released March 13, 2007).
The Commission is prohibited from exercising any power of censorship over

11

broadcast stations with respect to content-based programming decisions.

A licensee

has broadcast discretion - based on its right to free speech - to choose the
programming that it believes serves the needs and interests of the members of its
audience.

See, KFBB(AM), Sacramento and KSTE(AM), Rancho Cordova, California,

Letter, 22 FCC Rcd 4804, 4805 (MB 2007); 47 U.S. C. §326; Radio License Holding
VII,LLC, DA 13-2106 (released October 31,2013)
In light of the foregoing FCC policy and in consideration of CCTF's diverse
programming schedule that is derived from input from various ministries throughout the
country - including some programming that is locally produced and originated in Oregon
-- Innes' allegations that CCTF does not serve the interests and needs of various
Oregon communities is completely without merit.

The Commission's Standard of Review Supports CCTF
In cases involving a petition to deny, the Commission applies a two-step analysis
under the public interest standard. The Commission must first determine whether the
petition contains specific allegations of fact sufficient to show that granting the
application(s) in question would be prima facie inconsistent with the public interest.

The

first step "is much like that performed by a trial judge considering a motion for directed
verdict:

if all of the supporting facts alleged in the [petition] were true, could a

reasonable fact finder conclude that the ultimate fact in dispute had been established."
See, Gencom, Inc. v. FCC, 832 F.2d 171, 181 (D.C. Cir. 1987).

If the lnnes petition

meets this first step, the Commission must determine whether on the basis of the CCTF
license renewal applications, the pleadings filed, or other matters which the Commission
may officially take notice, Innes has raised a substantial and material question of fact as
to whether grant of the license renewal applications would service the public interest.

12

See, Astroline Communications Co., Ltd. Partnership v. FCC, 857 F.2d 1556 (D.C. Cir.
1988).
CCTF submits that Innes has failed to meet his burden.

The Innes petition is

completely comprised of false statements of fact and a fundamental lack of knowledge
of applicable FCC policy.

The Innes petition is nothing more than a complaint about

existing FCC policy. An attack on CCTF's license renewal applications is not the proper
means to address such matters.

Conclusion
The foregoing premises considered, CCTF submits that the lnnes petition be
DENIED in its entirety, and that each of CCTF's above-captioned license renewal
applications be GRANTED.

Respectfully submitted,
CALVARY CHAPEL OF TWIN FALLS, INC.

By:
Cary S. Tepper
Its Attorney

Booth, Freret, Imlay & Tepper, PC
4900 Auburn Avenue
Suite 100
Bethesda, MD 20814-2632
(301) 718-1818

January 23, 2014

13

Exhibit No. I

Declaration of Mike Stocklin
(and supporting attachments)

Declaration of
Mike Stocklin
I am Mike Stocklin, the Chief Executive Officer of Calvary Chapel of Twin Falls, Inc.
("CCTF"). My office is located at 4002 N. 3300 E., Twin Falls, Idaho 83301.
I offer this Declaration in response to the "Petition to Deny" filed January 2, 2014 by
Cohn Innes against numerous CCTF license renewal applications for FM broadcast
stations and FM translator stations located in the State of Oregon.
Cohn Innes has completely mischaracterized CCTF's radio prograrriming. The
programs broadcast: over the CCTF network are all produced by vrious ministries
throughout the country and the programming topics include salvation, marriage
counseling, anti-abortion, raising children, human health, mental illness and hundreds of
other topics. None of the programs are musical, although an occasional song might be
included in a certain discussion progran-1. Attached please find a copy of a current
weekday programming schedule from December 2013.
The diversity of CCTF's
programming is self-evident.
CCTF's regular radio programming includes content that originates from ministries
Every Monday through Friday at 12:30 pm Mountain Time we
located in Oregon.
broadcast "Searchlight" with Pastor Jon Courson from Applegate, Oregon. Every Monday
through Friday at 5:00 pm Mountain Time we broadcast "The Way, the Life, the Truth" with
Pastor Matt Foxx from Coos Bay, Oregon.
We have received no complaints from Oregon residents about our radio
programming, and we have over 300 Oregon residents noted on our Donor's List.
With regard to CCTF's responsiveness to each satellite-waiver community, also
attached is a summary sheet of the local public service efforts we conduct. We maintain a
local toll free telephone number. We provide access to the station's public file at no
charge. We have a local representative who holds meetings and advises us on local
issues. We broadcast local promotions for community and church events, and we reach
out in a number of other ways.
The foregoing statements are true to the best of my Information and belief, and are
made under the penalty of perjury.

Date

Mike Stocklin

Truth For Life / Alistair Begg
. 10:OOom(Su-Th) . 1 1 :OOpm(Su-Th) ................ 12:00am .................. 1:00am .................. 2:00am .................. 3:00am
Walk In The Word !James MacDonald ................ ,...11:OOpm(Su-Th) ................ 12:00am .................. 1:00am .................. 2:00am .................. 3:00am .................. 4:00am
1:00am .................. 2:00am .................. 3:00am .................. 4:00am .................. 5:00am .................. 6:00am
Spirit Truth /JerryChaddck .................................
1:30am
.................. 2:30am .................. 3:30am .................. 4:30am .................. 5:30am .................. 6:30am
Sharing The Light / Alan Wrgn ...........................
2:00am .................. 3:00am .................. 4:00am .................. 5:00am .................. 6:00am .................. 7:00am
Destined For Victwy/ Paw Sheopard ...................
2:30am .................. 3:30am .................. 4:30am .................. 5:30am .................. 6:30am .................. 7:30am
Compassion Radio / Norm Nelson ......................
3:00am .................. 4:00am .................. 5:00am .................. 6:00am .................. 7:00am .................. 8:00am
Turning Point / David jeremiah ...........................
3:30am .................. 4:30am .................. 5:30am .................. 6:30am .................. 7:30am .................. 8:30am
Love Worth Finding / Adrian Rogers ...................
4:00am .................. 5:00am .................. 6:00am .................. 7:00am .................. 8:00am .................. 9:00am
Power Point /Jack Graham .................................
4:30am .................. 5:30am .................. 6:30am .................. 7:30am .................. 8:30am .................. 9:30am
.................................
Family Talk /James Dooson
5:00am .................. 6:00am .................. 7:00am .................. 8:00am .................. 9:00am ................ 10:00am
A New Beginning / Greg Laurie ...........................
5:30am .................. 6:30am .................. 7:30am .................. 8:30am .................. 9:30am ................ 10:30am
Walk In The Word !james MacDora d ...............
6:00am .................. 7:00am .................. 8:00am .................. 9:00am ................ 10:00am ................ 11:00am
Truth For Life / Alistair Begg ................................
6:30am .................. 7:30am .................. 8:30am .................. 9:30am ................ 10:30am ................ 11:30am
The Connection / Skip Heitt g ..............................
7:00am .................. 8:00am .................. 9:00am ................ 10:00am ................ 11:00am ................ 12:00pm
Jay Sekulow (Live) ...............................................
7:30am .................. 8:30am .................. 9:30am ................ 10:30am ................ 11:30am ................ 12:30pm
The Simple Life / Ron Vietti .................................
8:00am .................. 9:00am ................ 10:00am ................ 11:00am ................ 12:00pm .................. 1:00pm
Living On The Edge / Chip Ingram .......................
8:30am .................. 9:30am ................ 10:30am ................ 11:30am ................ 12:30pm .................. 1:30pm
From His Heart! Jeff Schreve ..............................
9:00am ................. 10:00am ................ 11:00am ............... 12:00pm .................. 1:00pm .................. 2:00pm
A New Beginning! Greg Laurie ...........................
9:30am ................ 10:30am ................ 11:30am ............... 12:30pm .................. 1:30pm .................. 2:30pm
Searchlight /jon Courson ....................................
10:00am ................ 11:00am ................ 12:00pm ................. 1:00pm .................. 2:00pm .................. 3:00pm
Winning Walk! Dr. EdYog ..............................
10:30am ................ 11:30am ................ 12:30pm ................. 1:30pm .................. 2:30pm .................. 3:30pm
Pathway To Victory! Robert jeffress ....................
11:00am ............... 12:00pm .................. 1:00pm ................. 2:00pm .................. 3:00pm .................. 4:00pm
Thru The Bible !j. Vernon McGee ......................
11:30am ............... 12:30pm .................. 1:30pm ................. 2:30pm .................. 3:30pm .................. 4:30pm
Growing Thru Grace ! Jack Abeeren .....................
11:57am ............... 12:57pm .................. 1:57pm ................. 2:57pm .................. 3:57pm .................. 4:57pm
Man In The Mirror / Pathck Morley .....................
12:00pm
................. 1:00pm .................. 2:00pm ................. 3:00pm .................. 4:00pm .................. 5:00pm
66/40! Chuck Miss er.. .......................................
12:27pm ................. 1:27pm .................. 2:27pm ................. 3:27pm .................. 4:27pm .................. 5:27pm
Chapter By Chapter! Sandy Adams .....................
12:30pm ................. 1:30pm .................. 2:30pm ................. 3:30pm .................. 4:30pm .................. 5:30pm
..................................
Focal Point! Mike Fabaret
1:00pm ................. 2:00pm .................. 3:00pm ................. 4:00pm .................. 5:00pm .................. 6:00pm
To Every Man an Answer (Live call-in program)
2:00pm ................. 3:00pm .................. 4:00pm ................. 5:00pm .................. 6:00pm .................. 7:00pm
The Way, The Life & The TruTh / Mat: Fox .............
2:27pm ................. 3:27pm .................. 4:27pm ................. 5:27pm .................. 6:27pm .................. 7:27pm
Beyond Imagination / Shana Schutte ..................
2:30pm ................. 3:30pm .................. 4:30pm ................. 5:30pm .................. 6:30pm .................. 7:30pm
Somebody Loves You / Raul Res .........................
3:00pm ................. 4:00pm .................. 5:00pm ................. 6:00pm .................. 7:00pm .................. 8:00pm
Cross The Bridge! Davd McGee .........................
3:30pm ................. 4:30pm .................. 5:30pm ................. 6:30pm .................. 7:30pm .................. 8:30pm
Compassion Radio ! Norm Nelson ......................
4:00pm ................. 5:00pm .................. 6:00pm ................. 7:00pm .................. 8:00pm .................. 9:00pm
Know The Truth! Philip Dc Courcy ......................
4:30pm ................. 5:30pm .................. 6:30pm ................. 7:30pm .................. 8:30pm .................. 9:30pm
Telling The Truth / Stuart. jIl & Pete Briscoe ........
5:00pm ................. 6:00pm .................. 7:00pm ................. 8:00pm .................. 9:00pm ................ 10:00pm
The Alternative! Tony Evans ................................

2013 (SN international www.csnradio.com PC) Box 391,Twin Falls, ID 83303 800.357,4226

Saturday Schedule

Eastern
Central
Pacific M ounta i n
Alaskan
Hawaiian
Program / Speaker
7:00am ........... ....... 8:00am
............... . . . 5:00am ........... ....... 6:00am ............. .....
4:00am
.....
.............
3:00am
............
Road To Reali / K,P. Yohannan ...................................
7:00am ............ ...... 8:00am .......... ........ 9:00am
............. ..... 5:00am .............. .... 6:00am .......... ........
4:00am
............
...........................................
Family Talk flames Dobson
8:00am ............ ...... 9:00am .......... ...... 10:00am
5:00am ............ ...... 6:00am .............. .... 7:00am .......... ........
.............
........................................
Spirit Truth /jerry Chaddck
8:30am ............ ...... 9:30am .......... ...... 10:30am
5:30am ............ ...... 6:30am .............. .. .. 7:30am .......... ........
Issues In EducaHon / Boo & Cell Boyd ......................... .............
10:00am .......... ...... 1 1:00am
7:00am .............. .... 8:00am .......... ........ 9:00am ............ ....
......
............
6:00am
.............
.....................
12:00pm
Castng Cares / jerel & Merrily Hagorman
......... ....... 10:00am ........... ..... 11:00am .......... ......
............. 7:00am ............ ...... 8:00am ............. ..... 9:00am
.................................................
jay Sekulow Weekend
11:00am ........... ..... 12:00pm ......... ......... 1:00pm
. ........... ....... 9:00am ............. ... 10:00am ......... .......
ParentingTodaSTeen5! MarkGmgSto .................. .............. 8:00am
12:00pm ........... ....... 1:00pm ......... ......... 2:00pm
........... ..... 10:00am ............. ... 11:00am ......... ......
9:00am
..............
.......................
Achosen Generation! Derad S&nner
12:30pm ........... ....... 1:30pm ......... ......... 2:30pm
........... ..... 10:30am ............ .... 11:30am. ......... ......
9:30am
..............
................................
joshua Springs / jerel Hagerman
1:00pm........... ........ 2:00pm ......... ......... 3:00pm
........... ..... 11:0 0 am ............ .... 12:00pm ........ . . . ......
10:00am
............
......................
UnderstandiflgThe Tmes / jan Markell
........ .......... 4:00pm
...... 1:0 0 pm ........ ......... 2:00pm .......... . ....... 3:00pm
............
12:00pm
.....
..........
11:00am
.............
Pure Milk Of The Word / Tom Luit\Meler ...................
4:00pm .......... ........ 5:00pm .................. 6:00pm
1:00pm .......... ....... 2:0 0 pm ............ ...... 3:00pm ..... . . . .........
...............
..........................
Grace Intemention / Bk GiovanneD
4:27pm .......... ........ 5:27pm ........ .......... 6:27pm
1:27pm .......... ....... 2: 27 pm ........... ....... 3:27pm ..... .. ..........
...............
.....................................................
Israel In The News
6:00pm ......... ......... 7:00pm ....... ........... 8:00pm
3: 00 pm .......... ....... 4:00pm .... .. . .... ....... 5:00pm ....... ..........
Road To Reality! K.P. 7oi'annan ................................ ...............
8:00pm ....... ........... 9:00pm
5:00pm .......... . ....... 6:00pm ....... .......... 7:00pm ......... .........
........
.........
4:00pm
................
.......................
Live Semite / Calva of Albuquerque
8:00pm ......... ......... 9:00pm ....... ......... 10:00pm
5:00pm ......... ........ 6:0 0 pm ........... ....... 7:00pm ...... . ..........
................
.............................................
Saturday Night Life me

Sunday Schedule

Eastern
Central
Pacific Mounta i n
Alaskan
Hawaiian
Program / Speaker
6:30am .................. 7:30am ...... ............ 8:30am
3:30am ........ .......... 4:30am .......... ........ 5:30am ...... ............
.................
.....................
Issues In Educahon / Boo & Cerl Boyd
8:00am ...... ............ 9:00am
......... ......... 6:00am ...... ............ 7:00am ........ ..........
5:00am
..........
........
4:00am
.................
Worship Generation / Joey Bmdn ...........................
7:30am ....... ........... 8:30am ..... ............. 9:30am
4:30am ........ .......... 5:30am ......... ......... 6:30am ..... .............
.................
....................................
Truth For Life! Alistair Begg
8:00am ....... ........... 9:00am ..... ........... 10:00am
....... ........... 6:00am ......... ......... 7:00am ..... .............
5:00am
..................
..............................
The Lutheran Hour! Greg Selta
9:00am ....... ......... 10:00am ..... ........... 11:00am
6:00am ....... ........... 7:00am ......... ......... 8:00am ..... .............
Wings Of Healing! Thomas R. Wyatt ...................... ..................
10:00am ....... ......... 11:00am ..... ........... 12:00pm
....... ........... 8:00am ........ .......... 9:00am ..... ...........
7:00am
..................
..........
Live Semite! The River Christian Fellowship
...... ............ 1:00pm .... .............. 2:00pm
......... 10:00am ........ ........ 11 : 00am .... ........... 12:00pm
.......
9:00am
..................
......................
Lacharius
Let My People Thina / Ruvi
12:30pm .................. 1:30pm .... .............. 2:30pm
9:30am ....... ......... 10:30am ........ ........ 11:30am .... ...........
...................
.........................
Joshua Springs! Jer& Hagerman
3:00pm .... .............. 4:00pm
....... . .. ........ 1:00pm .... ............. 2:00pm ...... ............
12:00pm
.........
......
11:00am
.................
Cross Talk / Randy Weiss .......................................
3:30pm .................. 4:30pm .................. 5:30pm
...... ........... 1:30pm ....... . .......... 2:30pm .... .............
12:
30
am
.................
.........................
The Field Report! Geoge Bryson
4:00pm ..... ............. 5:00pm ... ............... 6:00pm
1:00pm ...... ........... 2:00pm ....... ... ........ 3:00pm .................
SpiritTruth!ierryChadoicK .................................. .......
..... ............. 6:00pm ... ............... 7:00pm
............ 3:00pm ....... ........... 4:00pm ................. 5:00pm
A Word for the Church / Scott ParKer .................... .................... 2: 00 pm .....
8:30pm ... ............... 9:30pm
5: 30 pm ....... ........... 6:30pm ... ..... ......... 7:30pm ..... .............
............
.....
4:30pm
....................
........
Live Sece !The River Christian FellowShip
9:00pm ..... ........... 10:00pm ... .............. 1:00pm
..... ............ 7 : 00 pm ....... ........... 8:00pm ... .. . ... ........
6:00pm
....................
...............................
Surfing The Word! Steve Rex

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csn international
Public Service for CSN Oregon Stations
KDJC Baker City, OR I KPIJ Junction City, OR I KKJA Redmond, OR
Our toll free phone number is published in the local phone book
Our public file is available at no charge to the community
We have a local representative who communicates quarterly to advise us of issues and conduct meetings
We hold quarterly meetings in the city of license to ascertain the issues important to the community
Announcement for this meeting is published in the local newspaper prior to the meeting
(Advanced notice is also broadcast iocaiiy on KDJC)

We maintain our list of public issues that we identify and address via our on air programming
We broadcast local promotion for events and churches in the community at a reduced cost
We comply with all broadcast rules including EAS
We regularly broadcast our contact information and invitations for the community to get in touch with us
via mail, email or telephone
KQDL Hines, OR
Our toll free phone number is published in the local phone book
Our public file is available at no charge to the community
We have a local representative who communicates quarterly to advise us of issues and conduct meetings
We hold quarterly meetings in Hines to ascertain the issues important to the community
Announcement for this meeting is published in the local newspaper prior to the meeting
We maintain our list of public issues that we identify and address via our on air programming
We have an active affiliation with the local news publication, the Burns Times Herald that sends us news
stories that we broadcast daily on KQDL. The Herald only publishes once a week, KQDL broadcasts
news on a daily basis.
We broadcast weather reports twice a day
We broadcast local promotion for events and churches in the community at a reduced cost
We comply with all broadcast rules including EAS
We regularly broadcast our contact information and invitations for the community to get in touch with us
via mail, email or telephone

CERTIFICATE OF SERVICE
I, Cary S. Tepper, Esquire, hereby certify that on this 23rd day of January, 2014, I
have served a copy of the foregoing "Opposition to Petition to Deny" first-class,
postage-prepaid, on the following:
*peter Doyle
Chief, Audio Services Division
Media Bureau
Federal Communications Commission
445 12th Street, S.W.; Room 2-A360
Washington, D.C. 20554
Cohn Innes
868 NE Liberty
Portland, OR 97211

Cary S. Tepper, Esq.
*/ indicates delivery by hand