Attachment Renewal Request

This document pretains to SES-RWL-20170913-01009 for Renewal on a Satellite Earth Station filing.

IBFS_SESRWL2017091301009_1275173

                                                                               BFI Licenses, LLC
                                                                                FCC Form 312-R
                                                                                 September 2017



        REQUEST FOR GRANT OF LATE-FILED RENEWAL APPLICATION

        BFI Licenses, LLC (“BFI”) hereby seeks renewal of its temporary-fixed satellite
earth station license under Call Sign E920540 (the “License”). The License was renewed in
2002 with an expiration date of October 2, 2017.1 Due to an administrative oversight, BFI
did not timely submit its renewal application within the renewal window provided for
under the FCC’s Rules. Accordingly, to the extent required, BFI requests waiver of Section
25.121(e) of the Commission’s Rules, which requires that renewal applications be filed no later than
30 days before the expiration of the license.2

        The Commission may waive its rules when good cause is shown. 3 The de minimis
delay in submitting the renewal application – after the end of the customary filing window
but prior to expiration – will have no negative impact on any other FCC-licensee or entity,
as the earth station in question, originally licensed in 1992, has been in use for twenty-five
years. Indeed, the Commission’s Rules provide a 30-day period following expiration
within which an expired license may be reinstated.4 Granting the requested relief will
affirmatively serve the public interest by allowing BFI to continue its ongoing operations,
which provide a variety of transportable uplink and on-site production services to
broadcasters, cable networks, government agencies and others throughout the country.

        Moreover, BFI is implementing improved monitoring procedures to ensure that
future renewal applications are timely filed. In particular, the company’s enhanced
calendaring system will alert it to all license expirations ninety (90) days in advance of the
expiration date, and thus sixty (60) days in advance of the deadline for renewal applications.
This system should avoid future recurrence of late-filed renewal applications. Accordingly,
grant of the requested waiver, if required, is in the public interest.




1
    See FCC File No. SES-RWL-20020812-01316 (granted 8/14/2002).
2
    See 47 C.F.R. §25.121(e).
3
  Northeast Cellular Telephone Co., L.P. v. FCC, 897 F.2d 1164, 1166 (D.C. Cir. 1990)
(“Northeast Cellular”); see also WAIT Radio v. FCC, 418 F.2d 1153, 1159 (D.C. Cir.
1969) (“WAIT Radio”); 47 C.F.R. § 1.3.
4
    See 47 C.F.R. § 25.163(a).



Document Created: 2017-09-13 14:04:10
Document Modified: 2017-09-13 14:04:10

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