City of Chicago's Request for Waiver of VHF-UHF Narrowbanding Deadline
Federal Communications CommissionNews Media Information 202 / 418-0500
Fax-On-Demand 202 / 418-2830
445 12th St., S.W.
TTY 202 / 418-2555
Washington, D.C. 20554Internet: http://www.fcc.gov
Released: October 2, 2012
WIRELESS TELECOMMUNICATIONS BUREAU AND PUBLIC SAFETY AND HOMELAND
SECURITY BUREAU SEEK COMMENT ON THE CITY OF CHICAGO OFFICE OF
EMERGENCY MANAGEMENT COMMUNICATION’S REQUEST FOR WAIVER OF THE
JANUARY 1, 2013 VHF-UHF NARROWBANDING DEADLINE
WT Docket 99-87
Comment Date: October 23, 2012
Reply Comment Date: November 2, 2012
By this Public Notice, we seek comment on a request for waiver of the Commission’s January 1,
2013 VHF-UHF narrowbanding deadline, filed on May 8, 2012,1 by the City of Chicago Office of
Emergency Management Communications (City of Chicago). Section 90.209(b)(5) of the Commission’s
rules requires private land mobile radio (PLMR) licensees in the 150-174 MHz and 450-512 MHz bands
to operate using channel bandwidth of no more than 12.5 kHz, or equivalent efficiency, by January 1,
2013.2 Specifically, the City of Chicago is seeking a twenty-four-month conditional extension of time to
complete the narrowbanding of its VHF/UHF facilities by January 1, 2015.
The City of Chicago is the third largest city in the United States, with 9.8 million inhabitants.
The City of Chicago metropolitan area extends outside the county seat of Cook County, Illinois, into
neighboring DuPage County. The City is comprised of approximately 234 square miles of urban
landscape, including 6.9 miles of the Lake Michigan waterfront, and both the Calumet and Chicago rivers
flow entirely or partially through key parts of the City. The City of Chicago is both the second largest
central business district and labor pool in the nation, and hosts millions of domestic and international
visitors each year as one of the most important worldwide international centers for commerce, finance,
To help manage and protect the City’s residents and visitors, Chicago employs thousands of first
responders and other employees who require the use of public safety communications. However, due to
budgetary and hiring constraints, the City employs only sixteen radio technicians, who are solely
responsible for the maintenance, installation, and upgrading of the City’s numerous and intricate radio
systems. Despite limited manpower and resources, these technicians have been able to perform
1 See Request for Waiver of Commission Rules (filed May 8, 2012) (Waiver Request).
2 See 47 C.F.R. § 90.209(b)(5); see also Implementation of Sections 309(j) and 337 of the Communications Act of
1934 as Amended; Promotion of Spectrum Efficient Technologies on Certain Part 90 Frequencies, Third
Memorandum Opinion and Order and Third Further Notice of Proposed Rule Making and Order, WT Docket No.
99-87, RM-9332, 19 FCC Rcd 25045 (2004). On April 26, 2012, the Wireless Telecommunications Bureau, Public
Safety and Homeland Security Bureau, and Office of Engineering and Technology waived the January 1, 2013
narrowbanding deadline for 470-512 MHz band frequencies. See Implementation of Sections 309(j) and 337 of the
Communications Act of 1934 as Amended; Promotion of Spectrum Efficient Technologies on Certain Part 90
Frequencies, Order, WT Docket No. 99-87, 27 FCC Rcd 4213 (WTB/PSHSB/OET 2012).
maintenance and to complete a significant number of necessary and mandated upgrades to the City of
Chicago’s extensive public safety radio networks.
The City of Chicago’s request describes its past and continuing efforts to bring its mission critical
communications networks into compliance with the January 1, 2013 narrowbanding mandate, and states it
is near completion of its multi-site UHF T-band fire digital system, among other public safety radio
projects.3 The City of Chicago notes, however, that it has “been occupied in responding to other regional
and national initiatives such as expanding its video surveillance system and engagement in Operation
Virtual Shield in cooperation with the Department of Homeland Security and Department of Justice.”4
The City of Chicago claims that it has been working diligently and in good faith towards
narrowbanding, making substantial investments in new infrastructure and reprogramming existing
equipment.5 However, because of budget constraints and the diversion of financial resources to other
federal projects, the City of Chicago claims that it is unable to complete narrowbanding by the January 1,
2013 target. Therefore, given its considerable efforts towards narrowbanding to date, the City of Chicago
contends that it is entitled to a waiver and extension of the deadline.
We seek comments on the waiver request in light of the July 13, 2011 Public Notice providing
guidance on the submission of requests for waiver of the narrowband deadline.6 In particular, we seek
comment from parties whose operations could be impacted by grant of the waiver.
3 Waiver Request at 6.
6 See Wireless Telecommunications Bureau, Public Safety and Homeland Security Bureau, and Office of
Engineering and Technology Provide Reminders of the January 1, 2013 Deadline for Transition to Narrowband
Operations in the 150-174 MHz and 421-512 MHz Bands and Guidance for Submission of Requests for Waiver and
Other Matters, Public Notice, 26 FCC Rcd 9647 (WTB/PSHSB/OET 2011); see also Wireless Telecommunications
Bureau and Public Safety and Homeland Security Bureau Provide Supplemental Guidance for Licensees in the 150-
174 MHz and 421-512 MHz Bands Seeking Waivers of the January 1, 2013 Narrowbanding Deadline, Public
Notice, 27 FCC Rcd 1936 (WTB/PSHSB 2012).
Waiver Request: Extending the narrowbanding deadline by twenty-four months, to January 1, 2015, for
the following frequencies and call signs:
CALL SIGNS FOR WHICH WAIVER OF SECTION 90.209(B) IS REQUESTED
City of Chicago VHF 150-174 MHz Channels(FRN 0002833416)
KBW414, KBW415, KBW416, KBW421, KF5671
KJY777, KJY778, KJY779, KK9884
City of Chicago UHF 450 — 470 MHz Channels(FRN 0002833416)
KNEW594, KNEW595, KNGN514, KNGN516, WFK423, WGQ939
KNEW594, KNEW595, KNGN514, KNGN516, WFK423, WGQ939
Procedural MattersInterested parties may file comments and reply comments in response to the waiver request on or
before the dates listed on the first page of this Public Notice. All pleadings must reference WT Docket
No. 99-87. Parties may file comments using (1) the Commission’s Electronic Comment Filing System
(ECFS), (2) the Federal Government’s eRulemaking Portal, or (3) by filing paper copies.7
Electronic Filers: File comments electronically using the Internet by accessing the ECFS:
http://www.fcc.gov/cgb/ecfs/ or the Federal eRulemaking Portal: http://www.regulations.gov.
Filers should follow the instructions provided on the website for submitting comments.
If multiple docket or rulemaking numbers appear in the caption of this proceeding, ECFS filers
must transmit one electronic copy of the comments for each docket or rulemaking number
referenced in the caption. In completing the transmittal screen, filers should include their full
name, U.S. Postal Service mailing address, and the applicable docket or rulemaking number.
Parties may also submit an electronic comment by Internet e-mail. To get filing instructions, filers
should send an e-mail to email@example.com, and include the following words in the body of the
message, “get form.” A sample form and directions will be sent in response.
Paper Filers: Parties who choose to file by paper must file an original and four copies of each
filing. If more than one docket or rulemaking number appears in the caption of this proceeding,
filers must submit two additional copies for each additional docket or rulemaking number.
Send filings by hand or messenger delivery, by commercial overnight courier, or by first-class or
overnight U.S. Postal Service mail (although we continue to experience delays in receiving U.S. Postal
Service mail). Address filings to the Commission’s Secretary, Office of the Secretary, Federal
Deliver hand-delivered or messenger-delivered paper filings to FCC Headquarters at 445
12th St., SW, Room TW-A325, Washington, DC 20554 between 8:00 AM and 7:00 PM.
Use rubber bands or fasteners to hold deliveries together. Dispose of all envelopes before
entering the building.
Send commercial overnight mail (other than U.S. Postal Service Express Mail and
Priority Mail) to 9300 East Hampton Drive, Capitol Heights, MD 20743.
Send U.S. Postal Service first-class, Express, and Priority mail to 445 12th Street, SW,
Washington DC 20554.
Parties are requested to send one copy of their comments and reply comments to Best Copy and
Printing, Inc., Portals II, 445 12th Street, S.W., Room CY-B402, Washington, D.C. 20554, (800) 378-
3160, e-mail FCC@BCPIWEB.com.
Documents in WT Docket No. 99-87 available for viewing on ECFS,
http://www.fcc.gov/cgb/ecfs, by entering the docket number, WT 99-87. These documents are are
available for public inspection and copying during business hours at the FCC Reference Information
Center, Portals II, 445 12th St. SW, Room CY-A257, Washington, D.C. 20554. The documents are also
available for purchase from Best Copy and Printing, Inc., telephone (800) 378-3160, facsimile (301) 816-
0169, e-mail FCC@BCPIWEB.com, telephone (202) 488-5300, facsimile (202) 488-5563, TTY (202)
488-5562, e-mail firstname.lastname@example.org.
Alternate formats of this Public Notice (computer diskette, large print, audio recording, and
Braille) are available to persons with disabilities by contacting the Consumer & Governmental Affairs
Bureau at (202) 418-0530 (voice), (202) 418-0432 (TTY), or send an e-mail to email@example.com.
7 See Electronic Filing of Documents in Rulemaking Proceedings, Report and Order, GC Docket No. 97-113, 13
FCC Rcd 11322 (1998).
This proceeding has been designated as a “permit-but-disclose” proceeding in accordance with
the Commission's ex parte rules.8 Persons making ex parte presentations must file a copy of any written
presentation or a memorandum summarizing any oral presentation within two business days after the
presentation (unless a different deadline applicable to the Sunshine period applies). Persons making oral
ex parte presentations are reminded that memoranda summarizing the presentation must (1) list all
persons attending or otherwise participating in the meeting at which the ex parte presentation was made,
and (2) summarize all data presented and arguments made during the presentation. If the presentation
consisted in whole or in part of the presentation of data or arguments already reflected in the presenter’s
written comments, memoranda or other filings in the proceeding, the presenter may provide citations to
such data or arguments in his or her prior comments, memoranda, or other filings (specifying the relevant
page and/or paragraph numbers where such data or arguments can be found) in lieu of summarizing them
in the memorandum. Documents shown or given to Commission staff during ex parte meetings are
deemed to be written ex parte presentations and must be filed consistent with rule 1.1206(b). In
proceedings governed by rule 1.49(f) or for which the Commission has made available a method of
electronic filing, written ex parte presentations and memoranda summarizing oral ex parte presentations,
and all attachments thereto, must be filed through the electronic comment filing system available for that
proceeding, and must be filed in their native format (e.g., .doc, .xml, .ppt, searchable .pdf). Participants in
this proceeding should familiarize themselves with the Commission’s ex parte rules.
For further information, contact Mr. Melvin Spann of the Wireless Telecommunications Bureau
at (202) 418-1333, or via e-mail at Melvin.Spann@fcc.gov or Mr. Roberto Mussenden of the Public
Safety and Homeland Security Bureau at (202) 418-1428, or via e-mail at Roberto.Mussenden@fcc.gov.
Action by the Deputy Chief, Mobility Division, Wireless Telecommunications Bureau and the
Deputy Chief, Policy and Licensing Division, Public Safety and Homeland Security Bureau.
- FCC -
8 See 47 C.F.R. §§ 1.1200(a), 1.1206.
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