FCC Record, Volume 27, No. 3, Pages 1878 to 2785, February 21 - March 16, 2012 Page: 1,931
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is in the process of constructing a multi-county interoperable 800 MHz radio system.4 Petitioners note
that they have passed sales tax initiatives to secure funding for the new system,5 which has a
Commission-approved extended implementation construction schedule until December 31, 2013.'
Petitioners state that upon completion of the 800 MHz system, they intend to transition their VHF/UHF
operations that are the subject of the Waiver Requests onto the new system and will vacate their
associated VHF and UHF authorizations.7 However, because the new system will not be operational by
the January 1, 2013 narrowbanding deadline, Petitioners seek a waiver of the deadline until December 31,
2013 to avoid having to divert financial, technical, and administrative resources to narrowbanding their
existing VHF/UHF facilities pending the transition.8
3. On November 12. 2011, the Public Safety and Homeland Security Bureau (Bureau)
issued a Public Notice seeking comment on the Waiver Request.9 We received comments from the
Region 24 800 MHz Regional Planning Committee (Region 24)10 and joint comments from the
International Municipal Signal Association (IMSA) and International Association of Fire Chiefs
(IAFC)." Region 24 supports the Waiver Requests but expresses two concerns. First, Region 24 states
that it has requested but has yet to receive a list of VHF/UHF frequencies and licenses that each Petitioner
will relinquish when construction of the 800 MHz system is completed." Second, Region 24 notes that
many of the VHF/UHF licenses in the Petitioners' counties are held by agencies other than the Petitioners
and that Petitioners have proposed no mechanism to ensure that these agencies will relinquish VHF/UHF
spectrum."3 IMSA and IAFC also support the Waiver Requests but question whether it is necessary for
the Bureau to issue a narrative public notice seeking comment each time a licensee files a request for
waiver of the narrowbanding deadline."4
4. Petitioners seek relief pursuant to Section 1.925 of the Commission's rules, which
provides that to obtain a waiver of the Commission's rules, a petitioner must demonstrate either that: (i)
Appendix B. Jefferson County seeks waivers for 274 frequencies held by 27 licensees. Jefferson Waiver Request at
7, Appendix B.
4 The St. Louis Urban Area consists of the Missouri counties of Franklin, Jefferson. St. Charles. St. Louis, the
independent City of St. Louis, and the Illinois counties of Madison. Monroe, and St. Clair. See Jefferson Waiver
Request at 2-3. fn. 2.
St. Louis Waiver Request at 5; Jefferson Waiver Request at 5; St. Charles Waiver Request at 5.
6 St. Louis Waiver Request at 5, 8: St. Charles Waiver Request at 5, 8; Jefferson Waiver Request at 5. 8.
7 St. Charles Waiver Request at 8: St. L.ouis Waiver Request at 8: Jefferson Waiver Request at 8.
8 St. Charles Waiver Request at 7; St. Louis Waiver Request at 7; Jefferson Waiver Request at 7.
9See Public Safety and Homeland Security Bureau Seeks Comment on Requests for Waiver Of The January 1. 2013
VH F-UHF Narrowbanding Deadline Filed By St. Louis County, Missouri. St. Charles County., Missouri, Jefferson
County 9-1-1 Dispatch Board and The East-West Gateway Council Of Governments, Public Notice, DA 11-1784
(rel. Oct. 26. 2011).
1o Region 24 is the State of Missouri, which includes the Petitioners' jurisdictions.
" Comments of the Region 24 800 MHtz Regional Planning Committee, filed Nov. 9, 2011 (Region 24 Comments);
Comments of the International Municipal Signal Association and the International Association of Fire Chiefs, filed
Nov. 10, 2011 (IMSAIAFC Joint Comments).
2 Region 24 Comments at 2.
" Id at 2-3.
'~ IMSA/IAFC Joint Comments at 6-9.
Federal Communications Commission
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United States. Federal Communications Commission. FCC Record, Volume 27, No. 3, Pages 1878 to 2785, February 21 - March 16, 2012, book, March 2012; Washington D.C.. (digital.library.unt.edu/ark:/67531/metadc94252/m1/72/: accessed April 26, 2017), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.