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TCI thereafter filed an "Opposition," and WHCTTV replied to it, to which TCI filed a  xzresponse, along with a motion for leave to file it. Subsequently, WHCTTV filed comments on TCI's  x[response, along with a motion for leave to file them, to which TCI filed a further response, together with  S-a motion for leave to file it.z yO`- xY#X\  P6G;P#эIn the interest of developing as complete a record as possible in this proceeding, these pleadings will be accepted for filing.  S-4 SUMMARY OF THE PLEADINGS   x2. In support of its complaint, WHCTTV states that it is a full power commercial broadcast  xstation assigned to the same ADI as TCI's systems, and that it ". . . stands ready to provide special  xequipment or technical assistance as necessary to assure good signal quality at Operators' headends. Any  xexpense for such equipment or assistance will be borne by WHCT." According to WHCTTV, it advised  xTCI, pursuant to  76.61(a)(1) of the Commission's rules, by letters dated June 27, 1997, from its General  xManager, Joseph F. Hennessey, to each of TCI's five systems, that it intended to invoke its mustcarry" ,**88 ""  S- xZrights.A yOh- x#X\  P6G;P#эIn these letters, WHCTTV stated that it expected to be in operation seven days a week, twentyfour hours each  xday, with programming by Infomall Television Network (as opposed to its prior carriage of the Worship Channel  xbetween the hours of 9:00 am and 5:00 pm Sunday through Friday and 7:00 am to 5:00 pm on Saturday) by August  x1, 1997, even though it had been offtheair for more than six years, and had had to install a new Comark transmitter.  xThe station, however, also noted that it had experienced occasional transmitting equipment malfunctions, that it had  xZhad to adjust, reposition, or replace certain microwave links, and that its original "Must Carry" request by letters  xYdated March 7, 1997 obviously was incorrect when it stated that WHCTTV had returned to operations on February  x12, 1997. The station then concluded that it ". . . regrets any confusion that may have been caused by the WHCT Must Carry  notification letter of March 7, 1997." According to WHCTTV, however, TCI did not respond within thirty days to WHCTTV's notice,  x=as it was required to do pursuant to  76.61(a)(2) of the Commission's rules. Instead, representatives of  x.TCI's systems at Branford and at Hartford jointly responded, by letter dated July 31, 1997, stating that  xjWHCTTV's mustcarry request of June 27, 1997 was too late in view of WHCT TV's prior request by  xletter dated March 7, 1997 that they had received. The TCI systems added that, since they had not  xresponded to that request within thirty days, WHCTTV was required to file its "Complaint" within sixty  S- xdays thereafter, which it did not do. Citing the Bureau's prior decision in Complaint of Fant Broadcasting  S- x-Company of Nebraska, Inc.,fA yO"-#X\  P6G;P#э10 FCC Rcd 8340 (1995).f the systems conclude that "WHCT's failure to file any complaints at the FCC  xby that date renders its carriage requests moot." In addition, the systems note that the station was offthe xair for nearly six years, and that it is only broadcasting pursuant to temporary authority pending a hearing  xwhich may result in revocation of its license. The systems claim, therefore, that it would be prudent to  x{await the outcome of this hearing before adding the station, particularly in view of the fact that its  xprogramming is changing from the Worship Channel to the Informall Television Network, and it is unclear  xzhow this will serve the local public interest of TCI's subscribers. According to WHCTTV, however,  xjTCI's letter did not address the only criteria for denying a valid mustcarry requestnamely, a deficiency  xin signal quality or strength, duplicative signals, or an allegation that the systems had already allocated  xup to onethird of their activated channels to carriage of other local mustcarry signals. Moreover,  xWHCTTV contends that the cable operators improperly presume that they are the final judges of the  x!public interest and it states that its letter dated March 7, 1997". . . was superseded by numerous  xLdiscussions with cable system operators in an effort to work cooperatively with them so that carriage of  x/WHCT's signal could commence when a full program schedule was aired." The station states that it,  xKtherefore, correctly filed the instant "Complaint" within sixty days of TCI's failure to respond within thirty  x days to the station's mustcarry requests dated June 27, 1997, pursuant to  76.7(c)(4)(iii)(B) of the  Sl-Commission's rules.   S-  x3. According to TCI, however, since WHCTTV's "Complaint" was not filed within sixty days  xof TCI's failure to respond to the station's initial mustcarry requests on March 7, 1997, the instant  x"Complaint" must be dismissed, pursuant to  76.7(c)(4)(iii) of the Rules. TCI explains that because it  xdid not respond to WHCTTV's carriage requests dated March 7, 1997 within thirty days, WHCTTV had  xsixty days to file a timely "Complaint" with the Commission, pursuant to  76.7(c)(4)(iii) of the  xCommission's rules. Instead, the station mailed a second carriage request by letter dated April 4, 1997,  xafter which, Mr. Hennessey was informed during a telephone discussion on April 17, 1997 with Matt  x-Fleury, at the time, Director of Communications and Government for TCI of Central Connecticut, that TCI  x>would not add WHCTTV. Even if April 17, 1997 were the correct time to begin the pleading cycle,  xkWHCTTV's "Complaint" was due to be filed with the Commission on June 16, 1997. However, the"( ,`(`(88"  xstation decided to request mandatory signal carriage a third time by letter dated June 27, 1997, to which  xTCI responded by letter dated July 31, 1997, stating that this carriage request was untimely, citing the  S- xBureau's prior decision in Fant Broadcasting Company.[A {O-#X\  P6G;P#эSupra.[ According to TCI, this last carriage request does  x>not restart the Commission's schedule for filing a "Complaint," citing the Bureau's prior decisions in  Sb- xHorizon Broadcasting Corporation against Horizon Cable I Limited Partnership,vbZA yO\-#X\  P6G;P#эDA 972226 (released October 21, 1997).v and in Friendly Bible  S<- x[Church, Inc.<A {O -#X\  P6G;P#э9 FCC Rcd 7907 (1994), rev. denied 11 FCC Rcd 17115 (1996). TCI states that no conversations superseded WHCTTV's initial carriage request by letter  x>dated March 7, 1997, and adds that the station has provided no details of any discussions with cable  xzoperators concerning its carriage, including which operators were involved and when such discussions  xoccurred. TCI also notes that WHCTTV's continued operation is somewhat questionable, given the fact  x=that it is presently being operated by a trustee in bankruptcy, and that its 1988 renewal application was  Sv- xdesignated for hearing on April 28, 1997 on misrepresentation issues.fv|A yO-#X\  P6G;P#э12 FCC Rcd 5224 (1997).f Therefore, the station is currently  xoperating on an expired license, which may be revoked or denied at any time. In addition, WHCTTV's  xprogramming is somewhat uncertain. WHCTTV changed to an Infomercial home shopping format on  xAugust 1, 1997, and TCI contends that it is questionable whether mandatory carriage of the station would  xserve the public interest of subscribers in the Hartford ADI, particularly since the station's promise to carry local programming is merely speculative since WHCTTV has yet to specify any such programming.  S^- x 4. WHCTTV contends, in reply, that TCI is not empowered to judge whether or not carriage  x of the station will serve the public interest, particularly insofar as this decision is based on a content  xjudgement. Citing a declaration from Joseph F. Hennessey, the station explains that its prior letters of  x=March 7 and April 4, 1997 were merely meant to be informational, letting cable operators know that the  xstation was back on the air and opening discussions concerning eventual testing and carriage. "[T]hese  xletters were not intended to serve as an irrevocable invocation of the station's must carry rights," according  xto WHCTTV. The station adds that it never had reason to believe that TCI would not carry it until it  x/received TCI's letters dated July 31, 1997. Therefore, WHCTTV previously had no reason to file a  xformal complaint with the Commission, particularly in view of the discussions between station and system  xrepresentatives, including one of TCI's local attorneys, Howard L. Slater, between March and July 1997,  xduring which time no one indicated that the systems would attempt to avoid mandatory carriage of  xWHCTTV. In fact, during a subsequent meeting on October 23, 1997 between Mr. Slater and Mr.  xHennessey, Mr. Slater stated that he ". . . could not reconcile . . ." the July 31, 1997 TCI letter with the  xjprior discussions that he, and Hennessey, and others had had earlier. According to WHCTTV, denial of  x[the instant "Complaint" would undermine Commission policy and contravene the underlying purpose of  x-the mustcarry rules. The station argues that its "Complaint" was timely filed, but it also requests a waiver  x{of  76.7 of the Commission's rules, if necessary, in light of its struggle and good faith attempts to  S-perpetuate a local signal via cable carriage.    x5. In response, TCI submits a "Declaration" from Mr. Slater stating that, although he  xyrepresents several other cable systems, he does not represent TCI's and that this point was made clear to  xMr. Hennessey. Therefore, Mr. Slater states that he did not, and could not, negotiate with WHCTTV on"  ,`(`(88!"  xbehalf of TCI, and that he would not have been concerned with reconciling any inconsistencies between TCI's letter dated July 31, 1997 and prior discussions with the station.   Nx6. In a further declaration, Mr. Hennessey states that he has no recollection of being informed  xby Mr. Slater that he did not work for TCI, and that he could not speak on its behalf. In fact, Mr.  x<Hennessey contends that his memory is to the contrary, and he notes that TCI is listed as one of the clients  S- xLof Mr. Slater's firm in the 1997 MartindaleHubbell Legal Directory. Mr. Hennessey adds that WHCT xTV negotiated for carriage with seven other Connecticut cable systems that were represented either by Mr.  xLSlater or by his firm, none of which argued that WHCTTV's letter of March 7, 1997 barred it from later  xasserting mandatory carriage. Moreover, according to Mr. Hennessey, TCI's employee, Matt Fleury,  xclearly indicated that TCI would add WHCTTV at least twice. Once, when he informed Mr. Hennessey  xthat cable operators were required to give their subscribers sixty days notice of changes in their channel  xlineups and again, when he informed Mike Lupo of Channel 10, Hartford, Connecticut, that TCI might not carry his station because of WHCTTV's carriage rights.   x7. In response, TCI suggests that WHCTTV be subject to administrative sanctions for abuse  xzof process in filing untimely and unauthorized pleadings, adding that since WHCTTV first requested  xmandatory carriage in its letter of March 7, 1997, its "Complaint" was due to be filed in June 1997, but  xthat the discussions with Mr. Mr. Slater and Mr. Fleury took place in July or later, well after WHCTTV  xshould have filed its "Complaint." In any event, any discussions with Mr. Lupo were hearsay and any  xstatements made to him were done so confidentially, while Mr. Fleury's statements concerning notice were  xnot meant to indicate that TCI would add WHCTTV. In fact, the sixty day notice requirement was a  x[reason to refuse to add the station, because it was uncertain that it would still be on the air in sixty days,  xgiven the fact that it had been off the air for six years, that it was operating on a challenged renewal  xapplication, and that it was being operated by a trustee in bankruptcy. Moreover, in his further  xjdeclaration, Mr, Slater states that he repeatedly informed Mr. Hennessey that he "did no work" for TCI,  xalthough his friend and law partner, Burton B. Cohen, did, and that Mr. Cohen has since stated that he has never spoken with Mr. Hennessey about anything.  Sz-( DISCUSSION ă  S*-  x8. As the Bureau previously explained in its decision in Friendly Bible Church, Inc.,a *A yO-#X\  P6G;P#э9 FCC Rcd at 7907.a the  xCommission's rules concerning its mustcarry complaint procedure are quite clear: "No mustcarry  xcomplaint filed pursuant to  76.61 will be accepted by the Commission if filed more than sixty (60) days  S- xafter the . . . denial by a cable television system operator of a request for carriage . . . ."p XA yO -#X\  P6G;P#э47 C. F. R.  76.7(c)(4)(iii).p In denying an  S- xapplication for review of Friendly Bible Church, Inc., the Commission explained that adoption of a time  xlimit both for mustcarry and for channel positioning complaints was appropriate, because it balanced the  x interests of broadcast stations in asserting their carriage rights, with the interests of cable systems in  xhaving certainty in their channel and carriage obligations to broadcasters, together with the interests of  xsubscribers in having minimal viewing disruption and certainty of service. The Commission added that,  xif within thirty days of the cable operator's initial request for carriage or for channel position, the cable  xoperator either denied it or did not respond to it, the cable system then only had sixty days to file a"" ,`(`(88'$"  S-complaint with the Commission.c A yOh-#X\  P6G;P#э11 FCC Rcd at 17118.c   Ax9. According to 76.55(e) of the Commission's rules, the market of commercial television  x=broadcast station, such as WHCTTV, is defined as its ADI. A commercial station is entitled to request  xzcarriage on any cable system operating in the same ADI. 47 C.F.R.  76.55(c). Both WHCTTV and  xTCI's five systems are located in the same ADI. However, TCI maintains that WHCTTV failed to file  xa complaint, as required by Commission rules, within sixty days after TCI either ignored or denied the  S- xstation's initial letters dated March 7 and April 4, 1997, both of which requested mandatory carriage. XA yO -#X\  P6G;P#э See  76.7(c)(4)(iii)(B) of the Commission's rules.  xiTCI contends that, after the specified thirty day response period, WHCTTV was bound to file a complaint  xwithin sixty days with the Commission, which would have been either by June 6, 1997 (after the first  xkletter), or by July 7 1997 (after the second letter), which it did not do. Although TCI did not add the  xysignal and did not respond to WHCTTV's March 7, 1997 letter, WHCTTV did not file its "Complaint"  xwith the Commission until September 25, 1997, more than six months later. Even WHCTTV referred  S - xyto its letters dated March 7, 1997 as "the 'Must Carry  request we originally sent out,"m A {O-#X\  P6G;P#эSee note 3, supra.m and the fact that  S - xit also sent out later requests for carriage does not toll the Commission's filing period,y\ zA {O- x#X\  P6G;P#эSee Complaint of Horizon Broadcasting Corporation against Horizon Cable I Limited Partnership, DA 972226  {O- xJ(released October 21, 1997); Complaint of United Broadcast Group II, Inc. against Buford Television, Inc., 12 FCC Rcd 8446, 8447 (1997).y nor has the station  xpresented sufficient grounds to waive  76.7 of the Rules for other reasons. Because WHCTTV's  xcomplaint was not filed within sixty days of Century's failure to respond to its original carriage request  xof March 7, 1997, its "Complaint" must be dismissed, pursuant to  76.7(c)(4)(iii)(B) of the Commission's  xxRules.   S-  ORDERING CLAUSES  S-  S-   x10. Accordingly, IT IS ORDERED, that the "Complaint" (CSR5109M), filed September 25,  xj1997, by Martin W. Hoffman, Esq., Trustee in Bankruptcy for the Estate of Astroline Communications,  xL. P., licensee of Station WHCTTV (Channel 18), Hartford, Connecticut, IS DISMISSED as untimely filed.  S-  x11. This action is taken pursuant to authority delegated by 0.321 of the Commission's rules. pX` hp x (#%'0*,.8135@8: