FCC Record, Volume 27, No. 3, Pages 1878 to 2785, February 21 - March 16, 2012 Page: 1,933
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of the new system, Petitioners have submitted and received Commission approval for an extended
implementation schedule until December 31, 2013." Under these circumstances, we conclude that the
one-year waiver period requested by Petitioners is no more than is reasonably necessary to vacate their
existing VHF/UHF facilities.23
8. Second, the record indicates that grant of the waiver will not hann neighboring systems
or impair interoperability during the one-year waiver period.-4 Because the waiver will cover most
VHF/UHF operations in the St. Louis Urban Area, we find no indication that it will have any negative
impact on co-channel or adjacent channel VHF/UHF operations.
9. Third, Petitioners plan to relinquish substantial VHF/UHF spectrum once Petitioners and
other licensees migrate to the new 800 MHz system.25 Grant of the waiver will avoid the diversion of
Petitioners' financial, technical, and administrative resources to narrowbanding their existing VHF/UHF
facilities pending the transition to the 800 MHz band and will allow Petitioners to devote their resources
to decommissioning their existing wideband facilities and vacating their VHF/UHF frequencies. This
will facilitate efficient use of scarce VHF/UHIF spectrum and free up capacity for potential new spectrum
users, which are key goals of the narrowbanding program.26 Petitioners have shown that these
circumstances support a temporary extension of the deadline.
10. However, while the Petitioners represent the interests of multiple licensees, we agree with
Region 24 that they lack the authority to legally bind all of the licensees whose authorizations are the
subject of this waiver request.27 Thus, as a condition of the waiver, we require that each individual
licensee in the St. Louis Urban Area that seeks the benefit of the waiver relief granted by this Order must
submit to the Commission, within 90 days of the release date of this Order, a letter confirming that, as
represented in Petitioners' waiver requests, it consents to the terms of this Order and will transition its
operations to the new 800 MHz system and, upon doing so, relinquish any VHF/UHF spectrum for which
it has obtained relief under this Order. Licensees should attach these letters to their licenses via the
Commission's Universal Licensing System (ULS). Any licensee that does not file such a letter in ULS
will not be afforded the waiver relief granted by this Order and therefore must comply with the January 1,
2013 narrowbanding deadline.
11. Further, Petitioners have not yet identified the exact scope of the existing VHF/UHF
frequencies and licenses that each county will relinquish by December 31, 2013. or of the VHF/UHF
frequencies and licenses that each county intends to retain and narrowband by the January 1, 2013
22 See St. Louis Waiver Request. Appendix E. St. Charles Waiver Request, Appendix C; Jefferson Waiver Request.
Appendix C. The Bureau's approval of extended implementation is attached to each authorization in IULS.
23 See Narrowbanding Waiver Guidance Notice. 26 FCC Red at 9649 (waiver applicant should show that "the
amount of time for which a waiver is requested is no more than is reasonably necessary to complete the
24 See id (waiver applicant should show planss to minimize the negative impact of extended wideband operations
on co-channel and adjacent channel operations").
" See id (waiver applicant migrating to a non-VHF/UHF band (e.g.. 700 MHz or 800 MHz) should indicate
"whether it will relinquish VI IF/U:F spectrum once it has migrated and the amount of spectrum to be
relinquished"). Petitioners' seek a waiver for more than 700 frequencies. see note 3. supra which they plan to
vacate and relinquish once the licensees transition to their new 800 MHz system.
26 See Replacement of Part 90 by Part 88 to Revise the Private Land Mobile Radio Services and Modify the Policies
Governing Them, Report and Order and Further Notice of Proposed Rule Making. PR Docket No. 92-235. 10 FCC
Red 10076, 10077 2 (1995).
27 Region 24 Comments at 3.
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/m1/74/: accessed August 23, 2017), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.