FCC Record, Volume 27, No. 5, Pages 3728 to 4696, April 9 - April 27, 2012 Page: 3,810

mobile and portable radios.'o However, PPI cites the lack of interoperability with public safety and
Ameren as the basis for the instant waiver request.
4. PPI states that "[m]ost of [its] members operate separate systems without any form of
interoperability, despite their need to dispatch and coordinate repair crews during emergencies to clear
and restore downed power lines and interrupted service and to coordinate electric transmission and
delivery.""' It further notes that "[a]nother critical gap is the existing systems' lack of interoperability
with the public safety agencies and other utilities with whom PPI and its member cooperatives must often
communicate during emergencies."'2 For example, immediately after severe weather events, fallen power
lines and utility poles can often hinder first responders' ability to reach those in need of medical
assistance or rescue."3 PPI claims public safety entities depend "on robust lines of communication with
PPI and its members to ensure that damaged power lines have been rendered inert before State and local
personnel can safety undertake law enforcement, rescue and repair operations."'4
5. PPI notes specifically its need for interoperability with neighboring Ameren, a major
investor-owned electric and gas utility that provides wholesale power delivery services to PPI.'5 PPI
notes Ameren and PPI must coordinate power delivery paths, which require communication between PPI
and Ameren dispatch centers and mobile users.'6 To illustrate the importance of interoperability, PPI
recounts a major storm during the summer of 2011 where "PPI employees had to drive approximately ten
miles during the storm to make cellular telephone contact with PPI's and Ameren's dispatch centers to
coordinate" the safe restoration of electricity.'" PPI seeks a waiver of the Commission's Rules to permit
the shared use of 800 MHz public safety frequencies, in part to avoid situations like the summer 2011
storm.'8
6. Section 90.179(a), which governs sharing of Part 90 frequencies, states that entities "may
share a radio station only on frequencies for which they would be eligible for a separate authorization."'9
PPI requests this waiver because, as electric utility providers operating on Industrial/Business pool
frequencies, they are not eligible for a separate authorization under Section 90.20 of the Commission's
Rules20 to use STARCOM21's 800 MHz public safety spectrum.21
7. PPI submits that Illinois determined that PPI is eligible to subscribe to the network and
that PPI's land mobile requirements will not limit STARCOM21's public safety operations.22 PPI notes
that STARCOM21 "has extremely light usage in rural areas of the state", whereas PPI and its members
operate extensively in rural areas with "minimal communications needs" in the urban areas of the state.23
o Id
" Id at 2-3.
SId. at 3.
'3 Id.
'4 Id
5 Id.
16 Id
" Id. at 3-4.
'5 Id. at 4.
9 47 C.F.R. 90.179(a).
20 47 C.F.R. 90.20.
21 Waiver Request at i.
22 Id. at 4.
23 Id

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Federal Communications Commission

DA 12-558