Attachment Narrative E861076.pd

This document pretains to SES-STA-20100527-00656 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2010052700656_819754

                                                                                    Attachment
                                                                              FCC Form 312 STA
                                                                                      May 2010



                               EXPLANATORY STATEMENT


       Radio License Holding I, LLC ("RLH I") hereby requests special temporary authority
("STA") to operate one existing temporary fixed—satellite earth station (Call Sign E861076) in
advance of FCC action on its pending application for assignment of the earth station
authorizations from Radio License Holding I, LLC, Debtor—in—Possession ("RLH I DIP") to RLH
I. The Assignment Application was filed on April 7, 2010 (FCC File No. SES—ASG—INTR2010—
01099); however, the FCC did not issue public notice of the application and as a result, the
application is still pending.

       RLH I DIP is a wholly—owned subsidiary of Citadel Broadcasting Corporation, Debtor—in—
Possession ("Citadel"). On December 20, 2009, Citadel, together with its subsidiaries, filed
voluntary petitions ("Petitions") in the United States Bankruptcy Court of the Southern District
of New York ("Bankruptcy Court") seeking relief under the provisions of chapter 11 of the
Bankruptcy Code to effectuate a pre—negotiated restructuring of its debt obligations.      On May
17, 2010, the Bankruptcy Court confirmed the Second Modified Joint Plan of Reorganization.
Citadel plans to emerge from bankruptcy as soon as possible. The Commission has already
granted its consent to transfer of control of Citadel‘s 228 radio station licenses from Citadel to
Citadel Broadcasting Corporation (as Reorganized) ("Reorganized Citadel"). Upon emergence
from bankruptcy, RLH I will be an indirect, wholly—owned subsidiary of Reorganized Citadel.
The Commission has already had an opportunity to review and approve Reorganized Citadel‘s
qualifications to operate FCC—licensed facilities, and there is no need for delay in granting it
permission to operate an additional facility on a temporary basis.

        Moreover, RLH I has a near term need to operate the earth stations to transmit news and
information programming. Accordingly, RLH I seeks expedited grant of an STA to permit it to
proceed with its plans. It respectfully requests that action on this STA application be completed
by Friday, May 28, 2010, if possible. RLH I anticipates that the underlying assignment
application will be granted during the effective period of the requested STA. See 47 C.F.R.
§ 25.120(b).



Document Created: 2010-05-28 12:59:04
Document Modified: 2010-05-28 12:59:04

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