Attachment Petition Reinstate

This document pretains to SES-RWL-INTR2019-00246 for Renewal on a Satellite Earth Station filing.

IBFS_SESRWLINTR201900246_1619872

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In re: ) ) University of Tennessee ) ) Domestic Fixed Satellite ) Earth Station E040049 ) ) Attn: International Bureau PETITION FOR REINSTATEMENT The University of Tennessee, pursuant to Section 25.163 of the Commission’s Rules, hereby respectfully petitions for reinstatement of the registration for domestic fixed satellite earth station E040049 in connection with the instant FCC Form 312-R license renewal submission. Background. The University of Tennessee originally applied to register this C-Band receive-only earth station facility in 2004, in FCC File No. SES-REG-20040123-00124, for use in connection with distribution of public radio programming for the University’s noncommercial educational FM radio station WUOT(FM), Knoxville, Tennessee, FCC Facility ID 69161. The FCC granted the earth station registration on March 9, 2004 under call sign E040049, with a registration expiration date of January 23, 2019. Renewal/Reinstatement Request. The University of Tennessee respectfully requests the FCC’s indulgence for the lateness of this renewal application submission for E040049 and, given the timing of this submission after the deadline prescribed by Section 25.121 of the Commission’s Rules, respectfully seeks processing of the E040049 renewal at this time in connection with this Petition for Reinstatement pursuant to Section 25.163 of the Rules. In accordance with Section 25.163(a)(1) of the Rules, this Petition is submitted within 30 days of the January 23, 2019 expiration of the E040049 license period.

In response to Section 25.163(a)(b) of the Rules, the University of Tennessee submits that the failure to file a timely renewal application for E040049 was due to various reasons. Specifically, the December 25, 2018 filing deadline for the renewal fell during a period of when the licensee University was in the midst of an administrative closure for the Winter Holiday.1 That said, the University acknowledges that staff error in failing to more closely monitor the deadline in advance, while handling other technical and regulatory compliance matters, certainly played a role as well. In addition, the length of time and personnel turnover since the original (and last) filing for the license over fifteen years ago, made it difficult for current station staff and representatives to track the renewal deadline in current systems as needed. However, in accordance with Section 25.163(a)(c) of the Rules, the University will establish procedures to ensure timely filings in the future with respect to this license. Specifically, the University’s outside communications legal counsel will enter this earth station authorization and its deadlines into its electronic deadline tracking database, providing additional logging and monitoring services to assist and back-up the efforts of station personnel. The University of Tennessee respectfully submits that the renewal and reinstatement of the E040049 registration will greatly serve the public interest, convenience and necessity by allowing the continued use of this facility in connection with the provision of noncommercial educational broadcast programming over station WUOT(FM). As a public service component of the University of Tennessee, the stated mission of WUOT(FM) is to inform, educate, entertain and enhance the lives of listeners and others it serves. 1 See https://hr.tennessee.edu/benefits/holiday-schedule/ -2-

Respectfully submitted, University of Tennessee Gray Miller Persh LLP By: /s/ Barry S. Persh 1200 New Hampshire Ave., Ste. 410 Barry S. Persh, its Counsel Washington, DC 20036 (202) 776-2458 February 6, 2019 -3-


Document Created: 2019-02-06 11:25:56
Document Modified: 2019-02-06 11:25:56
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