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WTB Denies 220 MHz Reconsideration from Havens, Skybridge and Verde

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Released: February 3, 2014

Federal Communications Commission

DA 14-121

Before the

Federal Communications Commission

Washington, D.C. 20554

In the matter of
)
)

WARREN C. HAVENS
)
See Attachment A for Calls Signs and
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Associated FCC File Nos.
SKYBRIDGE SPECTRUM FOUNDATION
)

)
VERDE SYSTEMS, LLC
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And its predecessor in interest, TELESAURUS
)
VPC, LLC
)
)

Applications for Waiver and/or Extension of the
)
Five and Ten Year Construction Deadlines
)
)

Applications for Renewal of 220 MHz Licenses
)

Order on Reconsideration

Adopted: February 3, 2014

Released: February 3, 2014

By the Deputy Chief, Mobility Division, Wireless Telecommunications Bureau:

I.

INTRODUCTION

1. For the reasons set forth below, we deny the Petition for Reconsideration filed by Warren C.
Havens (“Warren Havens”), Telesaurus VPC, LLC (“Telesaurus”), Verde Systems, LLC (“Verde”), and
Skybridge Spectrum Foundation (“Skybridge”)1 of the Mobility Division’s (“Division”) May 31, 2012
Order2 terminating 394 licenses held by the Petitioners.3 Petitioners assert that the Division erred by: (1)

1 We note for the record that Warren Havens is the president of Verde, Telesaurus, and Skybridge and is a signatory
to all of the applications addressed in this order. Where appropriate, we refer to filings, arguments, and assertions
made by Warren Havens and his companies jointly as having been made by “Havens,” “Petitioners,” or
“Applicants.” When referring to Warren Havens individually, we refer to him as “Warren Havens.”
2 See Warren C. Havens, Skybridge Spectrum Foundation, Verde Systems, LLC and its predecessor in interest,
Telesaurus VPC, LLC, Applications for Waiver and/or Extension of the Five and Ten Year Construction Deadlines,
Applications for Renewal of 220 MHz Licenses, Order, 27 FCC Rcd 5841 (2012) (“Havens 220 MHz Termination
Order”).
3 See Attachment A for a complete list of the 394 licenses, their associated call signs, the FCC file numbers of their
associated applications, and their associated construction and renewal deadlines. Skybridge was the licensee for call
signs WQHZ577-773 (“Skybridge Licenses”). Warren Havens was the licensee for call signs WPOI514-622,
WPOI843, WPOJ290-306, WPOK862-869, WPOK871-889, WPOK893-900, and WPOK933. Verde was the
licensee for call signs WPOK890-892 and WPOK901-926, and WPOK928-932 (these licenses were assigned from
Telesaurus to Verde). Since, at different points in time with respect to the issues addressed in this order, Warren
Havens filed jointly with Verde and Telesaurus, and Warren Havens is the president of both companies, we refer to
the licenses most recently held by Warren Havens and Verde (previously, Telesaurus) collectively as the “Havens
Licenses” except where reference to specific licenses or their respective licensees is necessary.
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denying the renewal applications for the Skybridge Licenses; (2) denying the extension requests for the
Havens Licenses; and (3) denying the Applicants’ request for a fee waiver.4 Petitioners also request
permission to submit evidence of additional “due diligence” pertinent to their extension and renewal
requests.5 We hereby deny Havens’ requests in full and reaffirm the Division’s findings set forth in the
Havens 220 MHz Termination Order.

II.

BACKGROUND

2. The Havens Licenses were originally granted in 1999 as part of Auction 24.6 Pursuant to
Section 90.767 of the Commission’s rules, an Economic Area (“EA”) or Regional Economic Area
Grouping (“REAG”) 220 MHz licensee must construct a sufficient number of base stations for land mobile
and/or paging operations to “provide coverage to at least one-third of the population of its EA or REAG
within five years of the issuance of its initial license and at least two-thirds of the population of its EA or
REAG within ten years of the issuance of its initial license.”7 Alternately, licensees may provide
substantial service to their licensed area at the appropriate five-year and ten-year benchmarks.8 Further,
pursuant to Section 1.946(c), “[i]f a licensee fails to commence service or operations by the expiration of
its construction period or to meet its coverage or substantial service obligations by the expiration of its
coverage period, its authorization terminates automatically, without specific Commission action, on the
date the construction or coverage period expires.”9
3. On January 12, 2004, Warren Havens filed requests for extension or removal of the five-year
construction deadline set forth in Section 90.767(a) of the Commission’s rules10 for his 220 MHz
licenses.11 Warren Havens argued, in part, that extension or waiver of the construction requirement was
justified due to a lack of appropriate equipment available for use in the 220 MHz band.12 In response, on
July 13, 2004, the Wireless Telecommunications Bureau (“Bureau”) released a Memorandum Opinion and
Order
extending the five-year construction deadlines to November 5, 2007 for all Phase II13 EA and
REAG 220 MHz licenses that had filed requests for extension or whose first construction deadline fell

4 See Warren Havens, Skybridge Spectrum Foundation, and Verde Systems, LLC, Petition for Reconsideration of
May 31, 2012 Order and Request to Permit Submission of Further Due Diligence Facts (July 2, 2012) (“Havens
Petition for Reconsideration”).
5 See Havens Petition for Reconsideration at 22-23.
6 See Phase II 220 MHz Spectrum Auction Closes, Public Notice, 14 FCC Rcd 11218 (July 1999). Some of the
subject licenses were acquired by Havens in secondary market transactions after the close of Auction 24.
7 47 C.F.R. § 90.767(a). For consistency, we refer to this as the “construction requirement” or “construction
deadline.”
8 Id.
9 47 C.F.R. § 1.946(c).
10 47 C.F.R. § 90.767(a).
11 See Warren Havens, Petition to Waive or Extend the Five-Year Construction Requirement: Partial Waiver of
Section 90.767, with requests to apply to other Regional and EA Licenses (Jan. 12, 2004) (“2004 Extension
Request”).
12 2004 Extension Request at 7-17.
13 See Amendment of Part 90 of the Commission’s Rules to Provide for the Use of the 220-222 MHz Band by the
Private Land Mobile Radio Service, Third Report and Order, 12 FCC Rcd 10943 (1997) (“Third Report and
Order
”) (Establishing rules to govern the operation and licensing of the 220 MHz band, including the Phase II
licenses.)
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after the date of the order.14 The Bureau found that the public interest would be served by granting these
220 MHz licensees, including Warren Havens, this extension and that an additional three years would be
sufficient time for the licensees to construct their systems using available or soon to be released
equipment.15
4. On October 24, 2007, Warren Havens submitted applications to disaggregate a large portion of
the spectrum in each of his 220 MHz licenses and assign it to Skybridge.16 Telesaurus filed similar
applications on November 1, 2007.17 For each of the subject licenses, Warren Havens and Telesaurus
maintained only a fraction of the original licensed spectrum.18 In addition, for each of the licenses, save
for call sign WQHZ610, Warren Havens and Telesaurus indicated that the assignor would be responsible
for meeting the construction deadlines set forth in Section 90.767 of the Commission’s rules.19 For call
sign WQHZ610, Warren Havens indicated that the assignor and assignee would be jointly responsible for
meeting the build-out deadlines.20 Warren Havens subsequently claimed that the difference in the
WQHZ610 application was an administrative error and asked the Bureau to modify the application for to
render it consistent with the applications for the other call signs.21
5. On November 4, 2007, Warren Havens and Telesaurus applied for waiver or further extension
of the five-year construction deadline for their Licenses pursuant to Section 1.946(e) of the Commission’s
rules.22 Warren Havens and Telesaurus advanced several arguments in favor of their extension request,
including that: (1) there was a continuing lack of 5 kHz trunked equipment for the 220 MHz band,
hampering build-out capabilities; (2) that they had conducted extensive due diligence with respect to the
use of Terrestrial Trunked Radio (“TETRA”), Digital Mobile Radio (“DMR”), and other Intelligent
Transportation Systems (“ITS”) for use in the 220 MHz band; (3) that the use of the Licenses for ITS in
conjunction with 900 MHz LMS licenses held by Havens-affiliated entities constituted the best use of the
spectrum; (4) that Warren Havens had acquired several of his Licenses in a bankruptcy proceeding that had
not concluded until 2007; and (5) that the disaggregation of spectrum to Skybridge23 constituted a donation
for public interest uses.24 In addition, Warren Havens and Telesaurus requested that they each be granted a
consolidated license for their 220 MHz holdings and that some or all of the fees associated with the

14 See Warren C. Havens, Bizcom USA, and Cornerstone SMR, Memorandum Opinion and Order, 19 FCC Rcd
12994 ¶ 19 (WTB-2004) (“220 MHz Extension Order”).
15 Id. at ¶ 20.
16 See FCC File No. 0003208764 disaggregating and assigning spectrum from call signs WPOI514-622, WPOI843,
WPOJ290-306, WPOK862-864, WPOK866-869, WPOK871-877, WPOK879-889, and WPOK893-900, and
WQHZ610; FCC File No. 0003218561 disaggregating and assigning call sign WPOK933; and FCC File
No.0003210896 disaggregating and assigning call signs WPOK865 and WPOK878.
17 See FCC File No. 0003218990 disaggregating and assigning spectrum from call signs WPOK891-892,
WPOK901-908, WPOK910-925, and WPOK928-932; and FCC File No.0003218951 disaggregating and assigning
spectrum from call signs WPOK890, WPOK909, and WPOK926. The applications in notes 16 and 17 are
collectively referred to as the “Havens Disaggregation Applications.”
18 This varies from license to license but, in many cases, the original licensee retained 20 percent or less of the
spectrum in each license area.
19 See Havens Disaggregation Applications, Schedule B.
20 See FCC File No. 0003208764 .
21 See WQHZ610 Petition at 1.
22 See 47 C.F.R. § 1.946(e); Warren Havens and Telesaurus VPC LLC, Petition to Waive or Extend the Five-Year
Construction Requirement (filed November 4, 2007) (“2007 Extension Request”).
23 See supra, paragraph 4.
24 2007 Extension Request at 5-9.
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Applications be waived.25 Warren Havens and Telesaurus also argued that the Applications met the
extension standards set forth in Section 1.946(e)(1) of the Commission’s rules26 and the waiver standard set
forth in Section 1.925 of the Commission’s rules.27 However, they did not specifically plead the requisite
elements of the waiver standard.28 On June 27, 2008, Warren Havens and Telesaurus filed a supplement to
the 2007 Extension Request that purported to show the applicants’ due diligence in seeking to obtain
TETRA technology for use with their Licenses.29
6. On March 23, 2009, Warren Havens filed renewal applications for his Licenses.30 In these
Renewal Applications, Warren Havens argued that he and his companies engaged in substantial due
diligence to research and develop ITS technology and services for use in the 220 MHz band.31 He also
claimed that, “[h]ad the FCC ruled on the 2007 Extension Request, and it was granted, then [he] could
have proceeded with the needed further development of technology and equipment to construct the
licenses…and constructed today or, at minimum would have been much further along in completing due
diligence to obtain the advanced 220 MHz technology and equipment for the nationwide ITS wireless plan
for which the Licenses are dedicated…”32 He asserted that these showings, along with those set forth in
the 2007 Extension Request and the March 2009 Amended Extension Request, were sufficient to satisfy
the renewal and renewal expectancy requirements in Section 90.74333 of the Commission’s Rules.34
7. On the same day, Warren Havens also filed an amendment to his 2007 Extension Request.35
In this Amended Extension Request, Warren Havens requested an extension of both the five and ten-year
construction deadlines for his Licenses until March 23, 2015.36 Warren Havens again claimed that he had
conducted substantial due diligence to obtain advanced wireless technology to put the 220 MHz spectrum
to its highest and best use.37 He also reiterated, and incorporated the arguments and assertions from his
prior filings.38

25 Id. at 9-10.
26 47 C.F.R. § 1.946(e)(1).
27 See 47 C.F.R. § 1.925; 2007 Extension Request at 4 and 9.
28 Id. at 9 (The section titled “Section 1.946(e)(1) and Waiver Standards Met” states only that “[t]his is evident from
the substance of this request”).
29 See Warren Havens and Telesaurus VPC, Supplement to Pending 220-222 MHz Extension Requests (filed June
27, 2008) (“June 2008 Supplement”).
30 See Warren Havens, 220 MHz Licenses: Renewal Applications (filed March 23, 2009) (“Havens March 2009
Renewal Applications”).
31 Id. at 2-4 and Attachments 1-3.
32 Id. at 1.
33 47 C.F.R. § 90.743; see infra, Section III(C).
34 See Havens March 2009 Renewal Applications at 4.
35 See Warren C. Havens Regional and EA Licenses, Amendment of Pending 2007 Petition to Waive or Extend the
Five-Year Construction Requirement and the Ten-Year Construction Requirement (filed March 23, 2009) (“March
2009 Amended Extension Request”).
36 Id. at 2.
37 Id. at 4.
38 Id. at 2-3.
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8. On March 23, 2009, Skybridge also filed renewal applications for several of its Licenses.39
Skybridge claimed that, pursuant to the earlier disaggregation and assignment action, its licenses do not
include construction requirements.40 As a result, according to Skybridge, it “has no substantial service
obligation, and thus has no substantial service showing to make.”41 Skybridge asserted that it “is using all
of the subject Licenses in active research and development, and thereafter deployment, of advanced
wireless for the nation’s Intelligent Transportation Systems (‘ITS’) and associated smart critical
infrastructure and environment-resource monitoring and protection….”42 However, Skybridge did not
claim to have built any facilities or provide any actual service in its license areas. Skybridge also
referenced the Havens March 2009 Renewal Applications in support of its claims.43 Skybridge filed a
similar renewal application for its remaining licenses on October 6, 2009, which referenced and
incorporated the Skybridge March 2009 Renewal Applications and provided additional information
regarding its plans to provide ITS, and specifically Network-RTK (“N-RTK”), services over its 220 MHz
spectrum.44
9. On October 7, 2009, Warren Havens and Verde filed a joint application to: (1) renew all of the
Havens and Verde Licenses that were not included in the Havens March 2009 Renewal Applications; (2)
amend and supplement the 2007 Extension Request for those Licenses that were not included in the
Havens March 2009 Extension Request; and (3) obtain waivers of the fees associated with the renewal and
extension filings.45 This Application restated and incorporated many of the renewal and extension
showings made in the prior filings of Warren Havens, Verde, and Skybridge.46 In addition, Warren
Havens and Verde argued that they had “demonstrated important research and developments to put the
spectrum to the highest and best use… with a focus… in support of N-RTK which is one of the most
important new forms of wireless for the nation.”47 They also claimed that the Applications meet the
waiver standard set forth in Section 1.925 of the Commission’s rules48 because: (1) the future use of the
licenses will be the highest and best use; (2) the licenses would be used by a nonprofit corporation that is
legally required to use the licenses in direct support of government agency needs and other public interest
purposes; (3) until recently, no commercially viable equipment was available for the subject spectrum and
the equipment available now will require modification into N-RTK GNSS receivers; and (4) application of
the construction deadline will frustrate the purpose of the rule.49 Warren Havens and Verde argued that

39 See Skybridge Spectrum Foundation, 220 MHz Licenses: Renewal Applications (filed March 23, 2009)
(“Skybridge March 2009 Renewal Applications”).
40 Id. at 1.
41 Id. at 1.
42 Id. at 1.
43 Id. at 2.
44 See Skybridge Spectrum Foundation, 220 MHz Licenses: Renewal Applications (filed October 6, 2009)
(“Skybridge October 2009 Renewal Applications”) (See Attachment A for associated FCC file numbers). Except
where reference to a specific application is necessary, we refer to the Skybridge March 2009 Renewal Applications
and the Skybridge October 2009 Renewal Applications collectively as the “Skybridge Renewal Applications.”
45 See Warren C. Havens and Verde Systems LLC, Fee Waiver and Refund Request, Amendment to Pending
Extension Request Due to Lack of FCC Decision On It, Request for One “Ten Year” Construction Deadline of
October 7, 2015, and Supportive Showing for Amended Extension Request, Renewal Expectancy Showing for
Renewal Applications for all the Subject Licenses (filed October 7, 2009) (“Havens/Verde Extension and Renewal
Applications”).
46 Id.
47 Id. at 8.
48 47 C.F.R. § 1.925.
49 Id.
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even though they have requested several construction deadline extensions, the amended Applications
should be granted for “entirely clear public interest reasons” in that the spectrum at issue “will, at last, be
put to an excellent purpose – one that did not exist until recently.”50 However, Warren Havens and Verde
did not claim that they were providing service, substantial or otherwise, within their respective license
areas. On September 23, 2010, Warren Havens, Verde, and Skybridge filed a further supplement to their
Extension and Renewal Applications to “demonstrate major additional due diligence and otherwise to
support the previous requests for either extension or renewal as clearly in the public interest to grant.”51
10. On November 6, 2009, Maritime filed Petitions to Deny the Havens/Verde Extension and
Renewal Applications, the Skybridge October 2009 Renewal Applications, and the associated request for a
fee waiver.52 Maritime asserted that these Applications are procedurally defective and were filed
improperly. Further, Maritime argued that Commission precedent compels denial of the applications and
that Skybridge had not made its case for renewal.53 Maritime also questioned Warren Havens’ candor
based on his actions in other dockets.54
11. On November 19, 2009, Warren Havens, Verde, and Skybridge filed an Opposition to
Maritime’s Petition to Deny.55 Havens argued that Maritime: (1) lacked standing to bring its Petition to
Deny; (2) that the Petition to Deny was an impermissible “strike petition”; (3) and that the Petition
contains numerous other procedural defects.56 Havens also countered Maritime’s arguments regarding the
validity of the Havens/Verde Extension and Renewal Requests.57 Maritime filed a Reply to the Opposition
on November 25, 2009.58
12. On January 16, 2010, Warren Havens, Verde, and Skybridge submitted a supplement to the
Applications and the Opposition.59 In the Supplement, the Applicants again asserted that N-RTK is the
highest and best use of the subject spectrum and presented evidence of their ongoing diligence to obtain

50 Id. at 9.
51 See Warren Havens, Verde Systems LLC, and Skybridge Spectrum Foundation, Supplement to Extension and
Renewal Applications (filed September 23, 2010) (“September 2010 Supplement”).
52 See Maritime Communications/Land Mobile LLC, Petition to Deny (filed November 6, 2009) (“Maritime Petition
to Deny”); Maritime Communications/Land Mobile LLC, Petition to Deny Fee Waiver Request (filed November 6,
2009) (“Maritime Petition to Deny Fee Waiver”). All filings related to the Maritime Petition to Deny and
subsequent replies, oppositions, supplements and other related filings apply to FCC file numbers: 0003990344-379,
0003989107-176, 0003990398-431, 0003223118-153, and 0003223081-114. See Attachment A for associated call
signs.
53 See Maritime Petition to Deny at 2-11.
54 Id. at 11-14.
55 See Warren Havens, Verde Systems, LLC, and Skybridge Spectrum Foundation, Opposition to Maritime Petition
to Deny
(filed November 19, 2009) (“Opposition to Maritime Petition to Deny”). All citations are to the errata
version of the Opposition, which was filed on November 20, 2009.
56 Id.
57 Id.
58 See Maritime Communications/Land Mobile LLC, Reply to Opposition to Petition to Deny (filed November 25,
2009) (“Maritime Reply”).
59 See Warren Havens, Verde Systems, LLC, and Skybridge Spectrum Foundation, Supplement to Applications and
Opposition to Petition to Deny
(filed January 16, 2010) (“Havens January 2010 Supplement); Warren Havens,
Verde Systems, LLC, and Skybridge Spectrum Foundation, Request to Accept Supplement to Applications and
Opposition to Petition to Deny
(filed January 16, 2010) (“Havens Request to Accept January 2010 Supplement”).
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the requisite technology and approvals to deploy N-RTK across the Havens and Skybridge Licenses.60 On
January 28, 2010, Maritime filed Oppositions to the January 2010 Supplement and the Request to Accept
the January 2010 Supplement.61 Subsequently, on October 5, 2010, Maritime filed a Petition to Deny the
Amended Applications, contending that the amendments “provided no information even to suggest that he
[Havens] had constructed any facility during the ten years that he held the licenses…”62 Warren Havens,
Verde, and Skybridge filed an Opposition to this Petition to Deny on October 20, 201063 and Maritime
submitted a Reply on November 1, 2010.64
13. On May 31, 2012, the Division released an Order granting Warren Havens’ petition for
reconsideration of the pending termination status of call sign WQHZ610 and denying: (1) the Extension
and Renewal Applications filed by Warren Havens, Verde, and Skybridge for all of the 220 MHz Licenses,
including WQHZ610; (2) the requests for waivers of filing fees associated with the subject applications;
and (3) the requests for consolidation of the subject licenses under a single call sign for each licensee.65
The Division also dismissed as moot the Petitions to Deny filed by Maritime as well as all subsequent
responsive filings by Maritime or Havens.66
14. On July 2, 2012, Warren Havens, Verde, and Skybridge filed a Petition for Reconsideration of
the Havens 220 MHz Termination Order along with an appendix containing seventeen supporting
exhibits.67 The Petitioners assert that the Division erred by: (1) denying the renewal applications for the
Skybridge Licenses; (2) denying the extension requests for the Havens Licenses; and (3) denying the
Applicants’ request for a fee waiver.68 The Petitioners also submit purportedly new evidence supporting
the earlier extension requests.69
15. On July 16, 2012, Maritime filed an Opposition to Havens’ Petition for Reconsideration.70
Maritime asserts that the Havens Petition for Reconsideration should be dismissed because: (1) it exceeds
the maximum page limit for petitions for reconsideration set forth in Section 1.106(f) of the Commission’s
rules;71 (2) Petitioners made a voluntary business decision not to provide service in any of its license areas;

60 Id. at 5-7.
61 See Maritime Communications/Land Mobile LLC, Opposition to Request to Accept Supplement to Applications
and Opposition to Petition to Deny
(filed January 28, 2010) (“Maritime Opposition to Havens Request to Accept
Supplement”); Maritime Communications/Land Mobile LLC, Opposition to Supplement to Applications and
Opposition to Petition to Deny
(filed January 28, 2010) (“Maritime Opposition to Havens January 2010
Supplement”).
62 See Maritime Communications/Land Mobile LLC, Petition to Deny Amended Application (filed October 5, 2010)
(erratum filed October 7, 2010) (“Maritime Petition to Deny Amended Applications”).
63 See Warren Havens, Verde Systems, LLC, and Skybridge Spectrum Foundation, Opposition to Petition to Deny
Amended Applications
(filed October 20, 2010) (“Havens Opposition to Petition to Deny Amended Applications”).
64 See Maritime Communications/Land Mobile LLC, Reply to Opposition to Petition to Deny Amended Application
(filed October 5, 2010) (“Maritime Reply to Opposition to Petition to Deny Amended Applications”).
65 See Havens 220 MHz Termination Order. The reasoning and support for these actions is outlined in the
discussion below addressing Havens’ Petition for Reconsideration, infra ¶¶ 21-40.
66 See Havens 220 MHz Termination Order at ¶ 32.
67 See Havens Petition for Reconsideration.
68 See Havens Petition for Reconsideration.
69 See Havens Petition for Reconsideration at 22-25.
70 See Maritime Communications/Land Mobile, LLC – Debtor in Possession, Opposition (filed July 16, 2012)
(“Maritime Opposition”).
71 47 C.F.R. § 1.106(f).
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and (3) that Havens fails to demonstrate that his claims are consistent with the precedents cited in the
Petition for Reconsideration.72
16. On July 27, 2012, Havens filed a Motion to Strike, Motion for Sanctions, and Reply to
Maritime’s Opposition.73 Petitioners assert that Maritime’s Opposition should be stricken from the record
as an unauthorized individual filing by Dennis Brown who is not authorized to represent Maritime
Communications/Land Mobile LLC – Debtor in Possession (“Maritime DIP”).74 According to Havens,
Mr. Brown had not been approved as counsel by the Mississippi Bankruptcy Court at the time the
Opposition was filed and, as such, could not represent Maritime DIP before the Commission.75 Havens
argues that Dennis Brown should be sanctioned as a result.76 Havens also asserts that the Opposition did
not cover all of the Havens Licenses and only mentions Verde and Warren Havens and, as such, should be
dismissed as to those licenses and applications it did not specifically reference.77 Havens also challenged
Maritime’s substantive claims and took the opportunity to submit additional evidence of continuing “due
diligence” in developing the Havens Licenses.78 Maritime filed an opposition to the motion to strike and
request for sanctions on August 3, 2012.79

III.

DISCUSSION

17. After careful review of the record, including the arguments presented by the Petitioners and
Maritime, we hereby deny the relief requested in the Petition for Reconsideration and reaffirm the findings
in the Havens 220 MHz Termination Order. We also deny the Petitioners’ request to submit additional
“due diligence” in support of their claims. Finally, we dismiss the Maritime Opposition, Havens July 2012
Reply, and Maritime Opposition to Motion to Strike as moot.

A.

Procedural Issues

1.

Filing Requirements

18. The Petition for Reconsideration consists of 26 main body pages and over 250 pages of
appendices and exhibits. Section 1.106 (f) of the Commission’s rules states, in relevant part that “[t]he
petition for reconsideration shall not exceed 25 double spaced typewritten pages.”80 Havens asserts that,
when considering the Petition without the table of contents or summary, as permitted under section 1.49 of
the Commission’s Rules, the Petition is under 25 pages and that the requirements of section 1.49 do not
apply to electronic filings.81 While we agree with Havens that the main body of his Petition complies with

72 See Maritime Opposition.
73 See Warren C. Havens, Verde Systems, LLC, and Skybridge Spectrum Foundation, Motion to Strike, Motion for
Sanctions & Reply to Opposition to Petition for Reconsideration of May 31, 2012 Order
(filed July 27, 2012)
(“Havens July 2012 Reply”). All references to the Havens July 2012 Reply refer to the revised version of that filing
which was filed on August 1, 2012.
74 Id. at 1-2.
75 Id.
76 Id. at 3.
77 Id. at 3-4.
78 Id. at 8-10 and Exhibit 1.
79 Maritime Communications/Land Mobile, LLC – Debtor in Possession, Opposition to Motion (filed August 3,
2012) (“Maritime Opposition to Motion to Strike”).
80 47 C.F.R. § 1.106 (f).
81 See Havens July 2012 Reply at 2.
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the requirements of section 1.106, we do not agree that our filing rules do not apply to electronic filings.82
Moreover, the exhibits filed by Havens, which contain substantive arguments and commentary from the
Petitioners,83 far exceed the limits set forth in section 1.106.84 Indeed, the Petition for Reconsideration
contains exhibits and appendices totaling over 250 pages.85
19. Page limits serve the important function of requiring parties to write concise pleadings that
focus on the important issues raised in the pleading, 86 which allows both the decision-maker and opposing
parties to focus on the key issues in a case. The Petitioners’ filing greatly exceeds the page limits set forth
in section 1.106 and represents a flagrant violation of the Commission’s rules. Moreover, the Petitioners
did not seek a waiver to exceed the Commission’s clearly delineated page limits nor do we see a
compelling reason to allow them to do so. Therefore, we find that the totality of the Petition for
Reconsideration exceeds the maximum filing length set forth in the rules and, as such, the exhibits and
appendices attached thereto shall be stricken.
2.

Request to submit additional materials

20. Havens requests permission to supplement the 2007 Extension Requests to demonstrate
“further due diligence.”87 Havens claims that these supplemental filings will include “facts, easily verified
in public records, and supported by experts, that support the subject Applications and reversal of the
Order.”88 However, Havens does not claim that this supplemental information includes evidence that any
of the licensees have constructed any facilities within their license areas or provided service to any
customer. Nor do the Petitioners claim this information would directly contradict our finding that the
failure to construct was due to a voluntary business decision. A review of the record attached to the
subject licensees reflects that from 2007 and 2010 Havens has submitted hundreds of pages of
documentation in support of the purported due diligence efforts of the Petitioners which we have
thoroughly examined.89 Nevertheless, these filings were insufficient to support extension, waiver, or

82 See 47 C.F.R. § 1.49 (f) (3) (“For purposes of paragraph (b) and (c) of this section, and any prescribed pleading
lengths, the length of any document filed in electronic form shall be equal to the length of the document if printed
out and formatted according to the specifications of paragraph (a) of this section, or shall be no more than 250 words
per page.”). As a frequent participant in Commission proceedings, Mr. Havens should be aware of this rule. Indeed,
the Commission recently rejected an Application for Review filed electronically by Mr. Havens and Skybridge for
failure to comply with applicable page limit requirements. See In the Matter of Skybridge Spectrum Foundation and
Warren Havens On Request for Inspection of Records, Memorandum Opinion and Order, FOIA Control Nos. 2013-
021 and 2013-022, FCC 13-120 (rel. September 17, 2013).
83 See Havens Petition for Reconsideration at 8 (“Petitioners include Appendix 1, attached hereto, that lists and
describes 17 exhibits. The exhibits contain certain notations: all of the margin notes added, and highlights added, in
the exhibits are referenced and incorporated into the text of the Petition.”)
84 See 47 C.F.R. § 1.106 (f).
85 See Havens Petition for Reconsideration at Appendix 1 and exhibits 1-17.
86 See Fleming v. County of Kane, 855 F.2d 496, 497 (7th Cir. 1988) (page limitations encourage litigants to hone
their arguments and to eliminate excessive verbiage); Snyder v. HSBC Bank, USA, N.A., 913 F. Supp.2d 755 (D.
Ariz. 2012) (judicial economy and concise argument are purposes of the page limit); Burger v. Kuimelis, 325 F.
Supp.2d 1026, 1031 (N.D. Cal. 2004) (the page limit forces moving parties to focus their discussion on the most
important issues).
87 See Havens Petition for Reconsideration at 23.
88 Id.
89 See supra ¶¶ 4-12.
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renewal of any of the Havens Licenses.90 Additional, similar information would not alter our analysis.
Therefore, we deny Petitioners’ request for permission to submit additional evidence into the record. To
the extent that such additional evidence was submitted as an exhibit to the Havens July 2012 Reply, it is
stricken as well.91

B.

Skybridge Renewals

21. In the Havens 220 MHz Termination Order, we denied the Skybridge Renewal Applications
on the grounds that they had not met the substantial service requirement to warrant renewal, as set forth in
section 90.743 of the Commission’s rules.92 Havens argues that, since Skybridge acquired the Skybridge
Licenses via disaggregation and assignment from Verde and Warren Havens, and the construction
obligations remained with the original licenses,93 Skybridge should not have been required to meet a
substantial service requirement to renew its licenses.94 Specifically, Havens argues that “service and
network construction are inexorably linked” and that, by requiring Skybridge to provide substantial service
upon renewal, the Division effectively imposed a construction requirement on Skybridge where none
existed.95 Havens asserts that the Division’s decision: (1) is inconsistent with the letter and purpose of the
Commission’s rules; (2) constituted the unlawful adoption of a substantive rule; and (3) constituted an
unlawful ruling on a “novel question of law and fact.”96 We find these arguments unconvincing and deny
the Petitioners’ request to reinstate the Skybridge Licenses.
22. As an initial matter, the Petitioners’ arguments misrepresent the Commission’s rules and
established precedent on this issue. As we stated in the Havens 220 MHz Termination Order, the
Commission made it clear in establishing the partitioning and disaggregation rules for the 220 MHz
service that the parties could choose which licensee or licensees would have responsibility for meeting the
construction requirements for the post-partition/disaggregation licenses.97 This flexibility is limited to
construction requirements and does not extend to renewal requirements.98 Indeed, the Commission noted
that “if one party (generally the original licensee) certifies that it will meet all future construction
requirements, the other party need only demonstrate that it is providing ‘substantial service’ for its
remaining license.”99 Petitioners do not cite Commission precedents or provide any evidence that support
their conclusory assertion that enforcing the explicit renewal requirements set forth in section 90.743 of the
Commission’s rules is somehow unlawful or improper.

90 See e.g. June 2008 Supplement, Havens 2009 Renewal Applications, March 2009 Amended Extension Request,
and Skybridge Renewal Applications.
91 See Havens July 2012 Reply at 9-10 and Attachments.
92 See Havens 220 MHz Termination Order at ¶¶ 26-29; 47 C.F.R. § 90.743 (a)(1).
93 The exception being WQHZ610, which was inadvertently assigned to Skybridge with a joint construction
requirement. See Havens Disaggregation Applications and WQHZ Petition. In the Havens 220 MHz Termination
Order, we granted the request of Warren Havens and Skybridge to treat WQHZ610 as if the construction obligation
had been retained by the original licensee. See Havens 220 MHz Termination Order at ¶ 15.
94 See Havens Petition for Reconsideration at 11-16.
95 Id. at 12.
96 Id. at 13-16.
97 See Havens 220 MHz Termination Order at ¶ 27 quoting Amendment of Part 90 of the Commission’s Rules to
Provide for the Use of the 220-222 MHz Band by the Private Land Mobile Radio Service, Fifth Report and Order,
13 FCC Rcd 24615, 24633 at ¶ 24 (1998) (“220 MHz Fifth R&O”).
98 See Havens 220 MHz Termination Order at ¶ 27 and 220 MHz Fifth R&O at ¶ 24.
99 See 220 MHz Fifth R&O at ¶ 24.
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23. In fact, the recent Uniform Renewal NPRM, which Petitioners cite in support of their
arguments, fully reinforces the findings in the Havens 220 MHz Termination Order.100 One of the main
goals of the Uniform Renewal NPRM was to revise service specific geographic partitioning and
disaggregation rules to require that each party to such an arrangement independently satisfy construction
obligations under the applicable service rules.101 Havens cites a few sentences of the Commission’s rules
to support his assertion that “[o]nly the licenses of the party with the construction responsibility terminate
by virtue of the failure to construct.”102 However, in the same paragraph that Havens cites, the
Commission states that “in services where there is currently no specific requirement to provide actual
service to obtain renewal, a licensee could hold spectrum licenses without providing service
indefinitely.”103 Here, the Commission once again draws a clear distinction between construction
requirements and service requirements at renewal. Thus, in services with service requirements at renewal,
such as the 220 MHz service, even licensees that have assigned their construction requirements to others
must satisfy a separate standard to warrant renewal of partitioned or disaggregated licenses.
24. As a matter of policy, the Commission remains committed to the notion that “the goal of our
construction requirements in both the partitioning and disaggregation contexts is to ensure that the
spectrum is used to the same degree that would have been required had the partitioning or disaggregation
transaction not taken place.”104 The Commission has not deviated from this longstanding policy and
clearly reiterated it in the Uniform Renewal NPRM.105 To do otherwise would encourage spectrum
warehousing and disincentivize the valuable development and use of spectrum resources. Havens’
position is clearly inconsistent with the text of the Commission’s rules, the Commission’s longstanding
policies, and the public interest. Thus, in denying the Skybridge Renewal Applications, the Division
simply applied the Commission’s existing rules and policies in reaching its decision. Thus, the Division’s
actions were well within the scope of its delegated authority and did not constitute an unlawful rulemaking
or an unlawful ruling on a unique question of law or fact.

C.

Extension Requests

25. In the Havens 220 MHz Termination Order, the Division denied Petitioners’ requests for
extension or waiver of the construction deadlines for the Havens Licenses.106 Under Section 1.946(e) of
the Commission’s rules, an extension of time to complete construction “may be granted if the licensee
shows that the failure to meet the construction or coverage deadline is due to involuntary loss of site or
other causes beyond its control.”107 Section 1.946 also lists specific circumstances where extension
requests will not be granted, including delays caused by a failure to obtain financing, because the license
undergoes a transfer of control, or because the licensee fails to order equipment in a timely manner.108 The

100 See Amendment of Parts 1, 22, 24, 27, 74, 80, 90, 95, and 101 To Establish Uniform License Renewal,
Discontinuance of Operation, and Geographic Partitioning and Spectrum Disaggregation Rules and Policies for
Certain Wireless Radio Services, Notice of Proposed Rulemaking and Order, 25 FCC Rcd 6996 (“Uniform Renewal
NPRM”).
101 Id. at ¶ 72.
102 See Havens Petition for Reconsideration at 13.
103 See Uniform Renewal NPRM at ¶ 87.
104 See Uniform Renewal NPRM at ¶ 77 quoting Geographic Partitioning and Spectrum Disaggregation by
Commercial Mobile Radio Service Licensees, Report and Order and Further Notice of Proposed Rulemaking, 11
FCC Rcd 21831 (1996) at ¶ 61.
105 Id.
106 See Havens 220 MHz Termination Order at ¶¶ 16-25.
107 See 47 C.F.R. § 1.946(e).
108 See 47 C.F.R. § 1.946(e)(2)-(3).
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applicable extension standard must be considered in conjunction with Section 309(j) of the
Communications Act, as amended, which states that the Commission shall include performance
requirements to ensure prompt delivery of services, to prevent stockpiling and warehousing of spectrum by
licensees, and to promote investment and deployment of new technologies and services.109 We found that
“(1) Applicants have not provided actual service in their license areas; (2) this failure was not caused by
circumstances beyond their control; (3) the claimed due diligence, conceptual plans, or other factors
described in Applicants’ filings do not support a further extension of the construction deadline; (4)
Applicants have presented no compelling precedent or evidence to support their request for special
considerations based on their donation of spectrum to Skybridge or their acquisition of certain 220 MHz
licenses during a bankruptcy proceeding; and (5) allowing Warren Havens and Verde to continue to hold
these licenses without constructing facilities or providing any actual service would undermine the purpose
of the Commission’s rules and Section 309(j) of the Communications Act.”110
26. The Division also found that the Petitioners had failed to meet the standard for waiver of the
construction requirements as set forth in section 1.925 of the Commission’s rules.111 Specifically, the
Petitioners had not presented evidence to establish that enforcement of the construction deadline would
undermine the purpose of the rule or be otherwise inequitable, unduly burdensome, or contrary to the
public interest.112 Indeed, the Division found that “granting the Applicants’ waiver request would harm the
public interest since it would run counter to established Commission precedent and could encourage other
present and future licensees to voluntarily pursue regulatory relief instead of providing actual service in
their license areas.”113
27. In the Petition for Reconsideration, Havens argues that the Division erred in denying the 2007
Extension Request.114 Havens claims that the Division:115 (1) disregarded the public interest in reaching its
decision and, specifically, ignored the “highest and best use of the spectrum;” (2) failed to consider
supporting evidence submitted by Havens; (3) improperly relied on its own expertise rather than the
expertise of outside experts in assessing the supporting evidence submitted by Havens; (4) failed to
consider the public interest benefits of non-profit spectrum use; and (5) failed to take a “hard look” at the
Petitioners’ waiver request as required by the Commission’s rules.116 Havens also asserts that the Division
violated the Petitioners’ equal protection rights since the Commission has granted waivers or extensions to
other licensees in the 220 MHz service.117 For the reasons set forth below, we find the Petitioners’
arguments to be without merit and reaffirm the Division’s denial of the Extension Requests.

109 See 47 U.S.C § 309(j)(4)(B).
110 See Havens 220 MHz Termination Order at ¶ 20.
111 47 C.F.R. § 1.925. Under Section 1.925 of the Commission’s rules, a waiver may be granted if the petitioner
establishes either that: (1) the underlying purpose of the rule would not be served or would be frustrated by
application to the instant case, and that grant of the waiver would be in the public interest; or (2) where the petitioner
establishes unique or unusual factual circumstances, application of the rule would be inequitable, unduly
burdensome, or contrary to the public interest, or the applicant has no reasonable alternative.
112 See Havens 220 MHz Termination Order at ¶ 24.
113 See Havens 220 MHz Termination Order at ¶ 24.
114 Havens Petition for Reconsideration at 16.
115 Havens consistently refers to the decisions of “the Bureau” throughout the Petition for Reconsideration.
However, the Order was released by the Mobility Division.
116 See Havens Petition for Reconsideration at 16-22.
117 See Havens Petition for Reconsideration at 23-24.
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1.

The Division’s Decision was in the Public Interest.

a.

Highest and Best Use of the Spectrum

28. Havens errs in claiming that the Division disregarded the public interest by failing to consider
the highest and best use of the 220 MHz spectrum held by the Licensees.118 The Division’s decision was
based largely on the fact that Havens did not provide any actual service in the applicable license areas and
that this failure was due to voluntary decisions made by the Petitioners.119 As we noted, it is well
established that voluntary business decisions are not circumstances beyond the licensee’s control for the
purposes of satisfying the requirements of section 1.946.120 Petitioners acknowledge that, unlike other 220
MHz licensees,121 they chose not to avail themselves of readily available technology to deploy service in
the 220 MHz band.122 Instead, they chose to pursue other technologies for which appropriate equipment
was not available.123 One could not ask for a better example of a voluntary business decision.
29. Petitioners rely on recent waivers granted to Sprint Nextel Inc. to support their assertion that
they are entitled to an extension based on their pursuit of supposedly superior technology in the band.124
However, Sprint-Nextel’s waiver requests are easily distinguished on both factual and legal grounds.
Sprint-Nextel requested a declaratory ruling modifying the narrowbanding requirements in Section 90.209
of the Commission’s rules125 to update their existing subscriber network using CDMA technology in the
800 MHz SMR band along with interim waivers of these requirements in designated license areas.126 The
Commission denied the Sprint-Nextel Petition, but granted the waiver requests and ultimately changed the
narrowbanding requirements in the SMR Flexibility Order.127 At no time did Sprint request an extension
of its construction deadlines for these license areas. Rather, Sprint sought a universal modification of the
Commission’s rules to augment its existing network to facilitate the deployment of advanced
communications technology. Furthermore, Sprint was already providing service to customers in these
license areas in accordance with the Commission’s rules. Thus, Sprint-Nextel’s request is factually and
legally distinct from the extensions sought by the Petitioners and the Commission’s actions in that

118 See Havens Petition for Reconsideration at 16-18.
119 See Havens 220 MHz Termination Order at ¶¶ 16-21.
120 See 47 C.F.R. § 1.946(e).
121 See, e.g., Coverage Notifications of Data Radio Management Co, Inc. for Call Signs WPOK830, WPOK831, and
WPOK834 (filed October 7, 2009); Coverage Notifications of ESP Wireless Technology Group for Call Signs
WPOJ377 and WPOJ389 (filed April 13, 2009); Coverage Notifications of Communications Specialists Inc. for Call
Signs WPOI493, WPOI494, WPOI495, WPOI496, WPOI497 (filed January 6, 2009).
122 See Havens Petition for Reconsideration at 16-17.
123 Id; See also 2007 Extension Request at 4-7 and Exhibits; June 2008 Supplement; September 2010 Supplement;
Havens/Verde Extension and Renewal Applications at 4-9.
124 See Havens Petition for Reconsideration at 18; Improving Spectrum Efficiency Through Flexible Channel
Spacing and Bandwidth Utilization for Economic Area-based 800 MHz Specialized Mobile Radio Licensees, Report
and Order
, WT Docket Nos. 12-64, 11-110, 27 FCC Rcd 6489 (rel. May 24, 2012) (SMR Flexibility Order) at note
21.
125 47 C.F.R. § 90.209.
126 See SMR Flexibility Order, 27 FCC Rcd 6491-6493 at ¶¶ 5-7; Request for Declaratory Ruling that the
Commission’s Rules Authorize Greater than 25 kHz Bandwidth Operations in the 817-824/862-869 MHz Band,
Petition for Declaratory Ruling, WT Docket No. 11-110 (filed June 3, 2011) (Sprint-Nextel Petition).
127 See SMR Flexibility Order, 27 FCC Rcd 6493-6501 at ¶¶ 8-18; Sprint-Nextel Petition; Sprint-Nextel Call Signs
WPLM660, WPLM661, WQNX442, WQNX443, WQNX444, WQOQ770, WQOQ771, WQOQ772, and
WQOU823.
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proceeding have no precedential effect here.
30. With regards to the appropriate use of the spectrum, Petitioners correctly state that the
Commission is concerned with ensuring the highest and best use of radio spectrum.128 One of the ways
that the Commission promotes spectrum being put to its highest and best use is through rules that require
licensees to actually construct facilities and deploy service. As we stated in the Order, “[w]hile licensees
are free to investigate, invest in, and pursue a wide range of technologies and service options, regulatory
compliance is ultimately demonstrated by material accomplishments in the use of the spectrum resource to
provide service.”129 The Petitioners focus solely on their own interpretation of the highest and best use of
the spectrum, to provide ITS services, while ignoring the essential requirement to provide service within
the timeframe set forth in the Commission’s rules.
b.

Supplementary Information did not Support Extension or Waiver of
the Construction Requirements.

31. In the Petition for Reconsideration, Petitioners claim that the Division disregarded “extensive
evidence” that they submitted in support of the 2007 Extension Requests.130 This “evidence” includes
hundreds of pages of information included in the Petitioners filings, websites related to TETRA, ex parte
filings in WT Docket No. 06-49, and other supplementary materials.131 Petitioners claim that these filings
show the value of TETRA and ITS technologies and demonstrate their due diligence in pursuing these
technologies for use in the 220 MHz band.132 Petitioners argue that these supplemental filings support
their request for waiver or extension of the construction deadlines and that the Division failed to give these
materials due consideration in reaching its decision.133 Petitioners also claim that the Division should have
deferred to the expert reports submitted by the Petitioners in reaching its decision.134
32. Our review gave serious consideration to Petitioners’ waiver request, despite the fact that
Petitioners did not plead the elements of the waiver standard in the 2007 Extension Requests135 and
provided scant support for their requests even in later pleadings.136 However, the requirement to take a
“hard look” at pending waiver requests137 does not require the Division to provide detailed analysis of each
piece of purported supplementary material provided by Petitioners. As noted in the Havens 220 MHz
Termination Order, Division staff reviewed each of the filings submitted by the Petitioners in reaching its

128 The term “highest and best use” is not used in the Communications Act. However, it does appear on the
Commission’s website and accurately encapsulates one aspect of the Commission’s responsibility with regards to
regulation of spectrum. See FCC, “ What We Do,” available at: http://www.fcc.gov/what-we-do.
129 See Havens 220 MHz Termination Order at ¶ 20.
130 See Havens Petition for Reconsideration at 18.
131 See Havens Petition for Reconsideration at 18-19 (listing supplementary materials submitted in support of the
2007 Extension Requests).
132 See Havens Petition for Reconsideration at 18-22. See also 2007 Extension Request; June 2008 Supplement,
Havens 2009 Renewal Applications, March 2009 Amended Extension Request, and Skybridge Renewal
Applications.
133 See Havens Petition for Reconsideration at 20-21.
134 See Havens Petition for Reconsideration at 21-22.
135 See 2007 Extension Request at 9 (asserting that satisfaction of the waiver standards is “evident from the
substance of the request”).
136 See Havens/Verde Extension and Renewal Application at 8-9.
137 See Havens Petition for Reconsideration at 20-21.
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decision.138 These materials support our finding that the Petitioners’ failure to satisfy the construction
requirements was wholly due to their voluntary decision to pursue technology and business strategies that
were unsupported by the existing technology ecosystem of the band. Moreover, nothing in the supporting
documentation indicates that the Petitioners have satisfied the requirements of section 1.925.139 As we
stated in the Havens 220 MHz Order, “we do not believe that the Applicants have presented convincing
evidence that enforcement of the construction deadline would frustrate the purpose of the rule or be
otherwise inequitable, unduly burdensome, or contrary to the public interest.”140 Indeed, granting a waiver
or extension to the Petitioners would undermine the very purpose of the construction obligations,
contradict Commission precedent, encourage spectrum warehousing, and run counter to the public interest.
33. Finally, the Petitioners’ contention that the Division should have deferred to the opinions
expressed in the expert reports appended to their filings with regard to TETRA and ITS is both unfounded
and irrelevant.141 In this case, appropriate Division personnel reviewed the reports and supplemental
information submitted by Havens. However, these submissions did not address issues relevant to the
disposition of this case. The Petitioners’ reports dealt with the purported value of the new technologies
and services that Havens sought to deploy but did not present evidence that Havens had actually deployed
any such technology or satisfied the elements of the applicable extension or waiver standards. The
potential merits of these technologies and services have no bearing on whether the Petitioners satisfied the
Commission’s requirements for extension or waiver of the applicable construction requirements. Thus, in
reaching its decision, the Division did not, as Havens claims, “counter an expert report with a non-expert
opinion.”142 Rather, the Division properly found these “expert reports” to be substantively irrelevant to the
Petitioners’ waiver and extension requests.143
c.

Skybridge’s Non-Profit Status Does Not Entitle Petitioners to
Extension or Waiver of the Construction Requirements

34. The Division also gave proper weight to Petitioners claims for special consideration based on
Skybridge’s non-profit status.144 Havens has provided no support for his contention that a non-profit
licensee is entitled to special consideration in applications for extension or waiver of its construction
requirements.145 The mere fact that a licensee is a non-profit organization does not entitle such an
organization to a waiver of any regulation under section 1.925 of the Commission’s rules.146 The
Commission’s rules make no distinction between for-profit and non-profit entities for purposes of
determining compliance with construction requirements and Havens has provided no precedent to support
a deviation from this policy.
35. In short, the public interest cannot be served solely by promises of future deployment. At
some point theory must give way to action and “due diligence” must yield tangible results. For Havens
that time has long since passed. Petitioners have held the Havens Licenses since 1999 and yet have failed
to construct facilities or provide service in any of their license areas, even as other licensees have begun to

138 See Havens 220 MHz Termination Order at ¶ 24.
139 See id.
140 Id.
141 See Havens Petition for Reconsideration at 21-22.
142 See Havens Petition for Reconsideration at 21.
143 See Havens 220 MHz Termination Order at ¶¶ 20, 24.
144 See Havens 220 MHz Termination Order at ¶ 23-25.
145 See Havens Petition for Reconsideration at 22.
146 See 47 C.F.R. § 1.925.
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offer meaningful service in the 220 MHz band. Instead, the Licensees made the voluntary decision to
pursue technologies that, whatever their theoretical merits, were not supported by the existing 220 MHz
device ecosystem. Thus, we find that the public interest is best served by affirming the termination of the
Havens Licenses and allowing other parties the opportunity to make actual use of the spectrum resource.
2.

The Division’s Decision did not Violate Havens’ Equal Protection Rights

36. Havens argues that, because the Division has granted extensions to other 220 MHz license
holders, Havens is entitled to the same treatment on equal protection grounds.147 Havens also argues that,
since the Commission has granted waivers of construction requirements for similarly situated parties, it is
required to waive the construction requirements for the Havens Licenses.148 These claims are wholly
without merit and misrepresent the Commission’s legal obligations and applicable precedent.
37. As an initial matter, Havens misrepresents the Division’s actions with regard to other 220
MHz licensees. The mere fact that the Commission has granted extensions or waivers to select 220 MHz
licensees due to the unique circumstances of their claims does not entitle Petitioners to the same outcome.
As we noted in the Havens 220 MHz Termination Order, our denial of the Havens Extension Requests is
wholly consistent with our treatment of similarly situated licensees.149 We have consistently denied
extension requests from licensees in the 220 MHz band when those licensees made the voluntary decision
not to deploy available equipment to provide service within their license areas.150 This approach is also
consistent with our treatment of similarly situated licensees in the 218-219 MHz band.151
38. The Petitioners cite three instances where the Commission or the Bureau granted certain 220
MHz license holders extensions or waivers of their construction requirements based on unique factual
circumstances not present in this proceeding.152 Havens makes no attempt to connect the facts in these

147 See Havens Petition for Reconsideration at 23.
148 See Havens Petition for Reconsideration at 24.
149 See Havens 220 MHz Termination Order at ¶ 21.
150 See Havens 220 MHz Termination Order, note 85, citing Letter dated June 26, 2009, from Roger S. Noel, Chief,
Mobility Division, Wireless Telecommunications Bureau, to Nancy J. Douglas, Douglas SMR Works, Inc., 24 FCC
Rcd 8596 (WTB-MD 2009); Letter dated June 26, 2009, from Roger S. Noel, Chief, Mobility Division, Wireless
Telecommunications Bureau, to Robert LaRue, Know LaRue Separate Property Trust, 24 FCC Rcd 8621 (WTB-MD
2009); Letter dated June 26, 2009, from Roger S. Noel, Chief, Mobility Division, Wireless Telecommunications
Bureau, to Kansas City Wireless Partners, LLP, 24 FCC Rcd 8625 (WTB-MD 2009); Letter dated June 26, 2009,
from Roger S. Noel, Chief, Mobility Division, Wireless Telecommunications Bureau, to David G. Boyle, 24 FCC
Rcd 8600 (WTB-MD 2009).
151 See Havens 220 MHz Termination Order, note 85, citing Letter dated May 31, 2005 from Katherine M. Harris,
Deputy Chief, Mobility Division, Wireless Telecommunications Bureau, to Buddy C. Stanley, ITV, Inc., 20 FCC
Rcd 9548, recon den., Application of ITV, Inc., Memorandum Opinion and Order, 22 FCC Rcd 1908 (WTB-CWD
2007); Letter dated January 31, 2007, from Thomas P. Derenge, Deputy Chief, Mobility Division, Wireless
Telecommunications Bureau, to Stephen E. Coran, Esquire, Counsel for U.S. Telemetry, 22 FCC Rcd 1921 (WTB-
MD 2007).
152 See National Rural Telecommunications Cooperative Request for Clarification or Extension of Time to Construct
a 220-222 MHz Nationwide Land Mobile Radio System, Order, 15 FCC Rcd 6637 (WTB, Commercial Wireless
Division - 1999) (Granting a limited one-year extension of Phase I license construction deadlines to allow licensee
to align its Phase I licenses with its existing Phase II authorizations); Request of PTC-220, LLC for Waivers of
Certain 220 MHz Rules, Memorandum Opinion and Order, WT Docket No. 08-256, 24 FCC Rcd 8537 (WTB -
2009) (Granting PTC-220, LLC a conditional waiver of construction requirements to allow it to construct a system
that complies with a Congressional mandate to construct a nationwide positive train control system); Niagara
Mohawk Power Corporation Call Signs WPCW863, WPCX746, WPCX405, WPCX407, WPCX408, WPCV961,
WPCV948 and WPCV949 Request for Extension of Time to construct and operate its 220–222 MHz Land Mobile
(continued....)
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cases to his arguments beyond the false assertion that, since the Commission granted waivers in these
cases, they constitute binding precedent for the Commission to grant the requests of the Petitioners.153 As
Havens himself notes, the Commission is required to take a hard look at individual applications for waiver,
and decide each case on its merits.154 The petitioners in the cases cited by Havens met the Commission’s
standards for waiver or extension of the Construction requirements by demonstrating that their unique
circumstances qualified them for relief and that granting such relief would be in the public interest, in
accordance with the Commission’s rules. The Petitioners, like the other 220 MHz licensees listed in
footnote 149,155 did not meet these requirements. Consequently Petitioners are not entitled to the relief
they seek.

D.

Fee Waiver Requests

39. Havens claims that the Division erred in denying the Petitioners’ request for waiver of fees
associated with the Extension and Waiver Requests.156 Petitioners claim that the Division: (1) failed to
take a hard look at the request for waiver; (2) neglected to provide a reasoned basis for its decision; and (3)
improperly used denial of the underlying applications as a basis for denying the waiver requests.157 What
Petitioners fail to mention is that they never once plead the required elements of their waiver request with
specificity.
40. As Petitioners correctly point out, Section 1.1119 of the Commission’s rules158 requires that
fee waiver requests be filed separately from the underlying pleading.159 This means that Petitioners are
required to satisfy the elements of the waiver standard set forth in Section 1.925 of the Commission’s rules
specifically for the fee waiver request.160 Petitioners simply state that the fee waiver request should be
granted for the same reasons that their other waiver and extension requests should be granted.161 Such

(...continued from previous page)
Systems, Order, 9 FCC Rcd 4838 (Private Radio Bureau, Licensing Division – 1994) (Granting an eight month
extension of licensee’s construction requirements to allow licensee to complete coordination negotiations with
Canada); See also Maritel, Inc. Request for Waiver of Part 80 Regulations to Permit Use of 12.5 kHz Radio
Equipment Operating in the 156-162 MHz Frequency Band, Order, 16 FCC Rcd 9294 (WTB, Public Safety and
Private Wireless Division – 2001) (Havens cites Maritel as an example of a similarly situated party that was granted
a waiver of its construction requirements. Maritel actually asked for and received a waiver of the Commission’s
Part 80 rules to permit the certification of equipment capable of operating on 12.5 kHz offset channels in the 156-
162 MHz band).
153 See Havens Petition for Reconsideration at 23-24.
154 See Havens Petition for Reconsideration at 23-24; See also WAIT Radio, Inc. v. FCC, 418 F.2d 1153, 1157 (D.C.
Cir. 1969); K. Rupert Murdoch (Transferor) and Fox Entertainment Group (Transferee) Applications for Transfer of
Control of Fox Television Stations, Inc., Memorandum Opinion and Order on Reconsideration, 24 FCC Rcd 5824,
5828 (2009) at ¶ 16 (“the Commission is obligated to take a “hard look” at waiver requests to determine whether the
application of a rule in a particular circumstance would disserve the public interest”).
155 See supra note 149.
156 See Havens Petition for Reconsideration at 25.
157 See Havens Petition for Reconsideration at 25.
158 47 C.F.R. § 1.119.
159 See Havens Petition for Reconsideration at 24-25.
160 47 C.F.R. § 1.925.
161 See Havens 2007 Extension Request at 10 (“the above waiver request to grant consolidated licenses should be
granted in the public interest, and if granted, then there would be only one extension request and one fee for it, not
the large numbers of fees paid when this extension request is submitted, and (ii) the substantial ongoing due
diligence (which will benefit the larger 220 MHz market also), the special bankruptcy circumstance noted above, the
(continued....)
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conclusory statements do not constitute a “separate pleading” as required by Section 1.119 and are
insufficient to satisfy the requirements of Section 1.925. As such, we uphold our earlier denial of the
Petitioners’ request for waiver of application fees.

E.

Maritime Petitions and Havens Responses

41. As detailed above, Maritime filed an opposition to the Petition for Reconsideration which
Havens subsequently opposed.162 However, since we reached our conclusions without the need for any of
the information included in these filings, we hereby dismiss the Maritime Opposition, Havens July 2012
Reply, and Maritime Opposition to Motion to Strike as moot.163

IV.

CONCLUSION

42. For the reasons set forth above, the Havens Petition for Reconsideration is denied in its
entirety and all of the decisions set forth in the Havens 220 MHz Termination Order are hereby affirmed.

V.

ORDERING CLAUSES

43. Accordingly, IT IS ORDERED that, pursuant to Section 1.106 of the Commission’s Rules, 47
C.F.R., § 1.106, the Petition for Reconsideration filed by Petitioners is DENIED.

FEDERAL COMMUNICATIONS COMMISSION
Thomas Derenge
Deputy Chief, Mobility Division
Wireless Telecommunications Bureau

(...continued from previous page)
special involvement of SSF (and support of SSF by the charitable assignments of 220 MHz spectrum from
Applicants to SSF), and applicants commitment to high public interest wireless with all of the subject 220 MHz
spectrum (as described at www.telsaurus.com ) all warrant grant of this fee waiver request”); Havens/Verde
Extension and Renewal Applications at 2 (“It is clearly in the public interest for the FCC to find that SSF’s use of its
220-222 MHz spectrum, along with its use of the Licensees 220-222 MHz spectrum under the just described option
and lease, warrants a waiver of the fees paid with the Havens and VSL renewal applications filed today for the
above-captioned call signs, as it warrants a waiver of the fees that SSF paid for its 220-222 MHz renewal
applications filed on October 6, 2009…”)
162 See Maritime Opposition and Havens July 2012 Reply.
163 See Maritime Opposition, Havens July 2012 Reply, and Maritime Opposition to Motion to Strike.
18

Federal Communications Commission

DA 14-121

ATTACHMENT A

Renewal
First
Second
Extension
Application - License
License
Construction Construction Request - FCC FCC File
Expiration
Grant Date Call Sign
Licensee Name
Deadline
Deadline
File Number
Number
Date
03/23/99 WPOI514 Havens, Warren C
11/05/07
03/23/09 0003222953
0003783529
03/23/09
03/23/99 WPOI515 Havens, Warren C
11/05/07
03/23/09 0003222954
0003783599
03/23/09
03/23/99 WPOI516 Havens, Warren C
11/05/07
03/23/09 0003222955
0003783530
03/23/09
03/23/99 WPOI517 Havens, Warren C
11/05/07
03/23/09 0003222956
0003783609
03/23/09
03/23/99 WPOI518 Havens, Warren C
11/05/07
03/23/09 0003222957
0003783531
03/23/09
03/23/99 WPOI519 Havens, Warren C
11/05/07
03/23/09 0003222958
0003783532
03/23/09
03/23/99 WPOI520 Havens, Warren C
11/05/07
03/23/09 0003222959
0003783620
03/23/09
03/23/99 WPOI521 Havens, Warren C
11/05/07
03/23/09 0003222960
0003783626
03/23/09
03/23/99 WPOI522 Havens, Warren C
11/05/07
03/23/09 0003222961
0003783533
03/23/09
03/23/99 WPOI523 Havens, Warren C
11/05/07
03/23/09 0003222962
0003783641
03/23/09
03/23/99 WPOI524 Havens, Warren C
11/05/07
03/23/09 0003222963
0003783534
03/23/09
03/23/99 WPOI525 Havens, Warren C
11/05/07
03/23/09 0003222964
0003783600
03/23/09
03/23/99 WPOI526 Havens, Warren C
11/05/07
03/23/09 0003222965
0003783642
03/23/09
03/23/99 WPOI527 Havens, Warren C
11/05/07
03/23/09 0003222966
0003783535
03/23/09
03/23/99 WPOI528 Havens, Warren C
11/05/07
03/23/09 0003222967
0003783536
03/23/09
03/23/99 WPOI529 Havens, Warren C
11/05/07
03/23/09 0003222968
0003783537
03/23/09
03/23/99 WPOI530 Havens, Warren C
11/05/07
03/23/09 0003222969
0003783538
03/23/09
03/23/99 WPOI531 Havens, Warren C
11/05/07
03/23/09 0003222970
0003783627
03/23/09
03/23/99 WPOI532 Havens, Warren C
11/05/07
03/23/09 0003222971
0003783640
03/23/09
03/23/99 WPOI533 Havens, Warren C
11/05/07
03/23/09 0003222972
0003783539
03/23/09
03/23/99 WPOI534 Havens, Warren C
11/05/07
03/23/09 0003222973
0003783540
03/23/09
03/23/99 WPOI535 Havens, Warren C
11/05/07
03/23/09 0003222974
0003783541
03/23/09
03/23/99 WPOI536 Havens, Warren C
11/05/07
03/23/09 0003222975
0003783601
03/23/09
03/23/99 WPOI537 Havens, Warren C
11/05/07
03/23/09 0003222976
0003783643
03/23/09
03/23/99 WPOI538 Havens, Warren C
11/05/07
03/23/09 0003222977
0003783542
03/23/09
03/23/99 WPOI539 Havens, Warren C
11/05/07
03/23/09 0003222978
0003783543
03/23/09
03/23/99 WPOI540 Havens, Warren C
11/05/07
03/23/09 0003222979
0003783544
03/23/09
03/23/99 WPOI541 Havens, Warren C
11/05/07
03/23/09 0003222980
0003783616
03/23/09
03/23/99 WPOI542 Havens, Warren C
11/05/07
03/23/09 0003222981
0003783628
03/23/09
03/23/99 WPOI543 Havens, Warren C
11/05/07
03/23/09 0003222982
0003783545
03/23/09
03/23/99 WPOI544 Havens, Warren C
11/05/07
03/23/09 0003222983
0003783546
03/23/09
03/23/99 WPOI545 Havens, Warren C
11/05/07
03/23/09 0003222984
0003783547
03/23/09
03/23/99 WPOI546 Havens, Warren C
11/05/07
03/23/09 0003222985
0003783602
03/23/09
03/23/99 WPOI547 Havens, Warren C
11/05/07
03/23/09 0003222986
0003783621
03/23/09
03/23/99 WPOI548 Havens, Warren C
11/05/07
03/23/09 0003222987
0003783610
03/23/09
03/23/99 WPOI549 Havens, Warren C
11/05/07
03/23/09 0003222988
0003783548
03/23/09
03/23/99 WPOI550 Havens, Warren C
11/05/07
03/23/09 0003222989
0003783644
03/23/09
03/23/99 WPOI551 Havens, Warren C
11/05/07
03/23/09 0003222990
0003783549
03/23/09
03/23/99 WPOI552 Havens, Warren C
11/05/07
03/23/09 0003222991
0003783550
03/23/09
03/23/99 WPOI553 Havens, Warren C
11/05/07
03/23/09 0003222992
0003783629
03/23/09
03/23/99 WPOI554 Havens, Warren C
11/05/07
03/23/09 0003222993
0003783551
03/23/09
03/23/99 WPOI555 Havens, Warren C
11/05/07
03/23/09 0003222994
0003783552
03/23/09
03/23/99 WPOI556 Havens, Warren C
11/05/07
03/23/09 0003222995
0003783603
03/23/09
03/23/99 WPOI557 Havens, Warren C
11/05/07
03/23/09 0003222996
0003783553
03/23/09
03/23/99 WPOI558 Havens, Warren C
11/05/07
03/23/09 0003222997
0003783611
03/23/09
03/23/99 WPOI559 Havens, Warren C
11/05/07
03/23/09 0003222998
0003783554
03/23/09
03/23/99 WPOI560 Havens, Warren C
11/05/07
03/23/09 0003222999
0003783555
03/23/09
03/23/99 WPOI561 Havens, Warren C
11/05/07
03/23/09 0003223000
0003783622
03/23/09
03/23/99 WPOI562 Havens, Warren C
11/05/07
03/23/09 0003223001
0003783630
03/23/09
03/23/99 WPOI563 Havens, Warren C
11/05/07
03/23/09 0003223002
0003783556
03/23/09
03/23/99 WPOI564 Havens, Warren C
11/05/07
03/23/09 0003223003
0003783617
03/23/09
03/23/99 WPOI565 Havens, Warren C
11/05/07
03/23/09 0003223004
0003783557
03/23/09
03/23/99 WPOI566 Havens, Warren C
11/05/07
03/23/09 0003223005
0003783639
03/23/09
03/23/99 WPOI567 Havens, Warren C
11/05/07
03/23/09 0003223006
0003783645
03/23/09
19

Federal Communications Commission

DA 14-121

Renewal
First
Second
Extension
Application - License
License
Construction Construction Request - FCC FCC File
Expiration
Grant Date Call Sign
Licensee Name
Deadline
Deadline
File Number
Number
Date
03/23/99 WPOI568 Havens, Warren C
11/05/07
03/23/09 0003223007
0003783558
03/23/09
03/23/99 WPOI569 Havens, Warren C
11/05/07
03/23/09 0003223008
0003783559
03/23/09
03/23/99 WPOI570 Havens, Warren C
11/05/07
03/23/09 0003223009
0003783560
03/23/09
03/23/99 WPOI571 Havens, Warren C
11/05/07
03/23/09 0003223010
0003783561
03/23/09
03/23/99 WPOI572 Havens, Warren C
11/05/07
03/23/09 0003223011
0003783631
03/23/09
03/23/99 WPOI573 Havens, Warren C
11/05/07
03/23/09 0003223012
0003783612
03/23/09
03/23/99 WPOI574 Havens, Warren C
11/05/07
03/23/09 0003223013
0003783562
03/23/09
03/23/99 WPOI575 Havens, Warren C
11/05/07
03/23/09 0003223014
0003783563
03/23/09
03/23/99 WPOI576 Havens, Warren C
11/05/07
03/23/09 0003223015
0003783564
03/23/09
03/23/99 WPOI577 Havens, Warren C
11/05/07
03/23/09 0003223016
0003783604
03/23/09
03/23/99 WPOI578 Havens, Warren C
11/05/07
03/23/09 0003223017
0003783646
03/23/09
03/23/99 WPOI579 Havens, Warren C
11/05/07
03/23/09 0003223018
0003783565
03/23/09
03/23/99 WPOI580 Havens, Warren C
11/05/07
03/23/09 0003223019
0003783566
03/23/09
03/23/99 WPOI581 Havens, Warren C
11/05/07
03/23/09 0003223020
0003783567
03/23/09
03/23/99 WPOI582 Havens, Warren C
11/05/07
03/23/09 0003223021
0003783618
03/23/09
03/23/99 WPOI583 Havens, Warren C
11/05/07
03/23/09 0003223022
0003783632
03/23/09
03/23/99 WPOI584 Havens, Warren C
11/05/07
03/23/09 0003223023
0003783568
03/23/09
03/23/99 WPOI585 Havens, Warren C
11/05/07
03/23/09 0003223024
0003783569
03/23/09
03/23/99 WPOI586 Havens, Warren C
11/05/07
03/23/09 0003223025
0003783570
03/23/09
03/23/99 WPOI587 Havens, Warren C
11/05/07
03/23/09 0003223026
0003783605
03/23/09
03/23/99 WPOI588 Havens, Warren C
11/05/07
03/23/09 0003223027
0003783623
03/23/09
03/23/99 WPOI589 Havens, Warren C
11/05/07
03/23/09 0003223028
0003783653
03/23/09
03/23/99 WPOI590 Havens, Warren C
11/05/07
03/23/09 0003223029
0003783571
03/23/09
03/23/99 WPOI591 Havens, Warren C
11/05/07
03/23/09 0003223030
0003783647
03/23/09
03/23/99 WPOI592 Havens, Warren C
11/05/07
03/23/09 0003223031
0003783572
03/23/09
03/23/99 WPOI593 Havens, Warren C
11/05/07
03/23/09 0003223032
0003783573
03/23/09
03/23/99 WPOI594 Havens, Warren C
11/05/07
03/23/09 0003223033
0003783633
03/23/09
03/23/99 WPOI595 Havens, Warren C
11/05/07
03/23/09 0003223034
0003783574
03/23/09
03/23/99 WPOI596 Havens, Warren C
11/05/07
03/23/09 0003223035
0003783575
03/23/09
03/23/99 WPOI597 Havens, Warren C
11/05/07
03/23/09 0003223036
0003783652
03/23/09
03/23/99 WPOI598 Havens, Warren C
11/05/07
03/23/09 0003223037
0003783576
03/23/09
03/23/99 WPOI599 Havens, Warren C
11/05/07
03/23/09 0003223038
0003783613
03/23/09
03/23/99 WPOI600 Havens, Warren C
11/05/07
03/23/09 0003223039
0003783577
03/23/09
03/23/99 WPOI601 Havens, Warren C
11/05/07
03/23/09 0003223040
0003783578
03/23/09
03/23/99 WPOI602 Havens, Warren C
11/05/07
03/23/09 0003223041
0003783624
03/23/09
03/23/99 WPOI603 Havens, Warren C
11/05/07
03/23/09 0003223042
0003783634
03/23/09
03/23/99 WPOI604 Havens, Warren C
11/05/07
03/23/09 0003223043
0003783579
03/23/09
03/23/99 WPOI605 Havens, Warren C
11/05/07
03/23/09 0003223044
0003783619
03/23/09
03/23/99 WPOI606 Havens, Warren C
11/05/07
03/23/09 0003223045
0003783580
03/23/09
03/23/99 WPOI607 Havens, Warren C
11/05/07
03/23/09 0003223046
0003783606
03/23/09
03/23/99 WPOI608 Havens, Warren C
11/05/07
03/23/09 0003223047
0003783648
03/23/09
03/23/99 WPOI609 Havens, Warren C
11/05/07
03/23/09 0003223048
0003783581
03/23/09
03/23/99 WPOI610 Havens, Warren C
11/05/07
03/23/09 0003223049
0003783582
03/23/09
03/23/99 WPOI611 Havens, Warren C
11/05/07
03/23/09 0003223050
0003783583
03/23/09
03/23/99 WPOI612 Havens, Warren C
11/05/07
03/23/09 0003223051
0003783584
03/23/09
03/23/99 WPOI613 Havens, Warren C
11/05/07
03/23/09 0003223052
0003783635
03/23/09
03/23/99 WPOI614 Havens, Warren C
11/05/07
03/23/09 0003223053
0003783614
03/23/09
03/23/99 WPOI615 Havens, Warren C
11/05/07
03/23/09 0003223054
0003783585
03/23/09
03/23/99 WPOI616 Havens, Warren C
11/05/07
03/23/09 0003223055
0003783586
03/23/09
03/23/99 WPOI617 Havens, Warren C
11/05/07
03/23/09 0003223056
0003783587
03/23/09
03/23/99 WPOI618 Havens, Warren C
11/05/07
03/23/09 0003223057
0003783607
03/23/09
03/23/99 WPOI619 Havens, Warren C
11/05/07
03/23/09 0003223058
0003783649
03/23/09
03/23/99 WPOI620 Havens, Warren C
11/05/07
03/23/09 0003223059
0003783588
03/23/09
03/23/99 WPOI621 Havens, Warren C
11/05/07
03/23/09 0003223060
0003783589
03/23/09
20

Federal Communications Commission

DA 14-121

Renewal
First
Second
Extension
Application - License
License
Construction Construction Request - FCC FCC File
Expiration
Grant Date Call Sign
Licensee Name
Deadline
Deadline
File Number
Number
Date
03/23/99 WPOI622 Havens, Warren C
11/05/07
03/23/09 0003223061
0003783590
03/23/09
03/22/99 WPOI843 Havens, Warren C
11/05/07
03/22/09 0003223062
0003781371
03/22/09
03/23/99 WPOJ290 Havens, Warren C
11/05/07
03/23/09 0003223063
0003783654
03/23/09
03/23/99 WPOJ291 Havens, Warren C
11/05/07
03/23/09 0003223064
0003783636
03/23/09
03/23/99 WPOJ292 Havens, Warren C
11/05/07
03/23/09 0003223065
0003783591
03/23/09
03/23/99 WPOJ293 Havens, Warren C
11/05/07
03/23/09 0003223066
0003783592
03/23/09
03/23/99 WPOJ294 Havens, Warren C
11/05/07
03/23/09 0003223067
0003783593
03/23/09
03/23/99 WPOJ295 Havens, Warren C
11/05/07
03/23/09 0003223068
0003783608
03/23/09
03/23/99 WPOJ296 Havens, Warren C
11/05/07
03/23/09 0003223069
0003783625
03/23/09
03/23/99 WPOJ297 Havens, Warren C
11/05/07
03/23/09 0003223070
0003783615
03/23/09
03/23/99 WPOJ298 Havens, Warren C
11/05/07
03/23/09 0003223071
0003783594
03/23/09
03/23/99 WPOJ299 Havens, Warren C
11/05/07
03/23/09 0003223072
0003783650
03/23/09
03/23/99 WPOJ300 Havens, Warren C
11/05/07
03/23/09 0003223073
0003783595
03/23/09
03/23/99 WPOJ301 Havens, Warren C
11/05/07
03/23/09 0003223074
0003783596
03/23/09
03/23/99 WPOJ302 Havens, Warren C
11/05/07
03/23/09 0003223075
0003783637
03/23/09
03/23/99 WPOJ303 Havens, Warren C
11/05/07
03/23/09 0003223076
0003783597
03/23/09
03/23/99 WPOJ304 Havens, Warren C
11/05/07
03/23/09 0003223077
0003783638
03/23/09
03/23/99 WPOJ305 Havens, Warren C
11/05/07
03/23/09 0003223078
0003783598
03/23/09
03/23/99 WPOJ306 Havens, Warren C
11/05/07
03/23/09 0003223079
0003783651
03/23/09
10/07/99 WPOK862 Havens, Warren C
11/05/07
10/07/09 0003223118
0003990376
10/07/09
10/07/99 WPOK863 Havens, Warren C
11/05/07
10/07/09 0003223119
0003990345
10/07/09
10/07/99 WPOK864 Havens, Warren C
11/05/07
10/07/09 0003223120
0003990344
10/07/09
10/07/99 WPOK865 Havens, Warren C
11/05/07
10/07/09 0003223121
0003990346
10/07/09
10/07/99 WPOK866 Havens, Warren C
11/05/07
10/07/09 0003223122
0003990347
10/07/09
10/07/99 WPOK867 Havens, Warren C
11/05/07
10/07/09 0003223123
0003990348
10/07/09
10/07/99 WPOK868 Havens, Warren C
11/05/07
10/07/09 0003223124
0003990373
10/07/09
10/07/99 WPOK869 Havens, Warren C
11/05/07
10/07/09 0003223125
0003990349
10/07/09
10/07/99 WPOK871 Havens, Warren C
11/05/07
10/07/09 0003223126
0003990371
10/07/09
10/07/99 WPOK872 Havens, Warren C
11/05/07
10/07/09 0003223127
0003990350
10/07/09
10/07/99 WPOK873 Havens, Warren C
11/05/07
10/07/09 0003223128
0003990369
10/07/09
10/07/99 WPOK874 Havens, Warren C
11/05/07
10/07/09 0003223129
0003990377
10/07/09
10/07/99 WPOK875 Havens, Warren C
11/05/07
10/07/09 0003223130
0003990351
10/07/09
10/07/99 WPOK876 Havens, Warren C
11/05/07
10/07/09 0003223131
0003990352
10/07/09
10/07/99 WPOK877 Havens, Warren C
11/05/07
10/07/09 0003223132
0003990353
10/07/09
10/07/99 WPOK878 Havens, Warren C
11/05/07
10/07/09 0003223133
0003990354
10/07/09
10/07/99 WPOK879 Havens, Warren C
11/05/07
10/07/09 0003223134
0003990374
10/07/09
10/07/99 WPOK880 Havens, Warren C
11/05/07
10/07/09 0003223135
0003990355
10/07/09
10/07/99 WPOK881 Havens, Warren C
11/05/07
10/07/09 0003223136
0003990367
10/07/09
10/07/99 WPOK882 Havens, Warren C
11/05/07
10/07/09 0003223137
0003990356
10/07/09
10/07/99 WPOK883 Havens, Warren C
11/05/07
10/07/09 0003223138
0003990357
10/07/09
10/07/99 WPOK884 Havens, Warren C
11/05/07
10/07/09 0003223139
0003990378
10/07/09
10/07/99 WPOK885 Havens, Warren C
11/05/07
10/07/09 0003223140
0003990358
10/07/09
10/07/99 WPOK886 Havens, Warren C
11/05/07
10/07/09 0003223141
0003990359
10/07/09
10/07/99 WPOK887 Havens, Warren C
11/05/07
10/07/09 0003223142
0003990360
10/07/09
10/07/99 WPOK888 Havens, Warren C
11/05/07
10/07/09 0003223143
0003990375
10/07/09
10/07/99 WPOK889 Havens, Warren C
11/05/07
10/07/09 0003223144
0003990370
10/07/09
10/07/99 WPOK890 Verde Systems LLC
11/05/07
10/07/09 0003223081
0003990428
10/07/09
10/07/99 WPOK891 Verde Systems LLC
11/05/07
10/07/09 0003223082
0003990398
10/07/09
10/07/99 WPOK892 Verde Systems LLC
11/05/07
10/07/09 0003223083
0003990399
10/07/09
10/07/99 WPOK893 Havens, Warren C
11/05/07
10/07/09 0003223145
0003990361
10/07/09
10/07/99 WPOK894 Havens, Warren C
11/05/07
10/07/09 0003223146
0003990362
10/07/09
10/07/99 WPOK895 Havens, Warren C
11/05/07
10/07/09 0003223147
0003990363
10/07/09
10/07/99 WPOK896 Havens, Warren C
11/05/07
10/07/09 0003223148
0003990364
10/07/09
10/07/99 WPOK897 Havens, Warren C
11/05/07
10/07/09 0003223149
0003990379
10/07/09
21

Federal Communications Commission

DA 14-121

Renewal
First
Second
Extension
Application - License
License
Construction Construction Request - FCC FCC File
Expiration
Grant Date Call Sign
Licensee Name
Deadline
Deadline
File Number
Number
Date
10/07/99 WPOK898 Havens, Warren C
11/05/07
10/07/09 0003223150
0003990368
10/07/09
10/07/99 WPOK899 Havens, Warren C
11/05/07
10/07/09 0003223151
0003990372
10/07/09
10/07/99 WPOK900 Havens, Warren C
11/05/07
10/07/09 0003223152
0003990365
10/07/09
10/07/99 WPOK901 Verde Systems LLC
11/05/07
10/07/09 0003223084
0003990400
10/07/09
10/07/99 WPOK902 Verde Systems LLC
11/05/07
10/07/09 0003223085
0003990401
10/07/09
10/07/99 WPOK903 Verde Systems LLC
11/05/07
10/07/09 0003223086
0003990402
10/07/09
10/07/99 WPOK904 Verde Systems LLC
11/05/07
10/07/09 0003223087
0003990425
10/07/09
10/07/99 WPOK905 Verde Systems LLC
11/05/07
10/07/09 0003223088
0003990403
10/07/09
10/07/99 WPOK906 Verde Systems LLC
11/05/07
10/07/09 0003223089
0003990404
10/07/09
10/07/99 WPOK907 Verde Systems LLC
11/05/07
10/07/09 0003223090
0003990423
10/07/09
10/07/99 WPOK908 Verde Systems LLC
11/05/07
10/07/09 0003223091
0003990429
10/07/09
10/07/99 WPOK909 Verde Systems LLC
11/05/07
10/07/09 0003223092
0003990421
10/07/09
10/07/99 WPOK910 Verde Systems LLC
11/05/07
10/07/09 0003223093
0003990405
10/07/09
10/07/99 WPOK911 Verde Systems LLC
11/05/07
10/07/09 0003223094
0003990406
10/07/09
10/07/99 WPOK912 Verde Systems LLC
11/05/07
10/07/09 0003223095
0003990407
10/07/09
10/07/99 WPOK913 Verde Systems LLC
11/05/07
10/07/09 0003223096
0003990408
10/07/09
10/07/99 WPOK914 Verde Systems LLC
11/05/07
10/07/09 0003223097
0003990426
10/07/09
10/07/99 WPOK915 Verde Systems LLC
11/05/07
10/07/09 0003223098
0003990409
10/07/09
10/07/99 WPOK916 Verde Systems LLC
11/05/07
10/07/09 0003223099
0003990410
10/07/09
10/07/99 WPOK917 Verde Systems LLC
11/05/07
10/07/09 0003223100
0003990411
10/07/09
10/07/99 WPOK918 Verde Systems LLC
11/05/07
10/07/09 0003223101
0003990430
10/07/09
10/07/99 WPOK919 Verde Systems LLC
11/05/07
10/07/09 0003223102
0003990412
10/07/09
10/07/99 WPOK920 Verde Systems LLC
11/05/07
10/07/09 0003223103
0003990413
10/07/09
10/07/99 WPOK921 Verde Systems LLC
11/05/07
10/07/09 0003223104
0003990414
10/07/09
10/07/99 WPOK922 Verde Systems LLC
11/05/07
10/07/09 0003223105
0003990427
10/07/09
10/07/99 WPOK923 Verde Systems LLC
11/05/07
10/07/09 0003223106
0003990415
10/07/09
10/07/99 WPOK924 Verde Systems LLC
11/05/07
10/07/09 0003223107
0003990422
10/07/09
10/07/99 WPOK925 Verde Systems LLC
11/05/07
10/07/09 0003223108
0003990416
10/07/09
10/07/99 WPOK926 Verde Systems LLC
11/05/07
10/07/09 0003223109
0003990417
10/07/09
10/07/99 WPOK928 Verde Systems LLC
11/05/07
10/07/09 0003223110
0003990418
10/07/09
10/07/99 WPOK929 Verde Systems LLC
11/05/07
10/07/09 0003223111
0003990419
10/07/09
10/07/99 WPOK930 Verde Systems LLC
11/05/07
10/07/09 0003223112
0003990431
10/07/09
10/07/99 WPOK931 Verde Systems LLC
11/05/07
10/07/09 0003223113
0003990424
10/07/09
10/07/99 WPOK932 Verde Systems LLC
11/05/07
10/07/09 0003223114
0003990420
10/07/09
10/07/99 WPOK933 Havens, Warren C
11/05/07
10/07/09 0003223153
0003990366
10/07/09
10/26/07 WQHZ577 Skybridge Spectrum Foundation
0003989107
10/07/09
10/26/07 WQHZ578 Skybridge Spectrum Foundation
0003989150
10/07/09
10/24/07 WQHZ579 Skybridge Spectrum Foundation
0003710186
03/23/09
10/24/07 WQHZ580 Skybridge Spectrum Foundation
0003710256
03/23/09
10/24/07 WQHZ581 Skybridge Spectrum Foundation
0003710187
03/23/09
10/24/07 WQHZ582 Skybridge Spectrum Foundation
0003710266
03/23/09
10/24/07 WQHZ583 Skybridge Spectrum Foundation
0003710188
03/23/09
10/24/07 WQHZ584 Skybridge Spectrum Foundation
0003710189
03/23/09
10/24/07 WQHZ585 Skybridge Spectrum Foundation
0003710277
03/23/09
10/24/07 WQHZ586 Skybridge Spectrum Foundation
0003710283
03/23/09
10/24/07 WQHZ587 Skybridge Spectrum Foundation
0003710190
03/23/09
10/24/07 WQHZ588 Skybridge Spectrum Foundation
0003710298
03/23/09
10/24/07 WQHZ589 Skybridge Spectrum Foundation
0003710191
03/23/09
10/24/07 WQHZ590 Skybridge Spectrum Foundation
0003710257
03/23/09
10/24/07 WQHZ591 Skybridge Spectrum Foundation
0003710299
03/23/09
10/24/07 WQHZ592 Skybridge Spectrum Foundation
0003710192
03/23/09
10/24/07 WQHZ593 Skybridge Spectrum Foundation
0003710193
03/23/09
10/24/07 WQHZ594 Skybridge Spectrum Foundation
0003710194
03/23/09
10/24/07 WQHZ595 Skybridge Spectrum Foundation
0003710195
03/23/09
22

Federal Communications Commission

DA 14-121

Renewal
First
Second
Extension
Application - License
License
Construction Construction Request - FCC FCC File
Expiration
Grant Date Call Sign
Licensee Name
Deadline
Deadline
File Number
Number
Date
10/24/07 WQHZ596 Skybridge Spectrum Foundation
0003710284
03/23/09
10/24/07 WQHZ597 Skybridge Spectrum Foundation
0003710297
03/23/09
10/24/07 WQHZ598 Skybridge Spectrum Foundation
0003710196
03/23/09
10/24/07 WQHZ599 Skybridge Spectrum Foundation
0003710197
03/23/09
10/24/07 WQHZ600 Skybridge Spectrum Foundation
0003710198
03/23/09
10/24/07 WQHZ601 Skybridge Spectrum Foundation
0003710258
03/23/09
10/24/07 WQHZ602 Skybridge Spectrum Foundation
0003710300
03/23/09
10/24/07 WQHZ603 Skybridge Spectrum Foundation
0003710199
03/23/09
10/24/07 WQHZ604 Skybridge Spectrum Foundation
0003710200
03/23/09
10/24/07 WQHZ605 Skybridge Spectrum Foundation
0003710201
03/23/09
10/24/07 WQHZ606 Skybridge Spectrum Foundation
0003710273
03/23/09
10/24/07 WQHZ607 Skybridge Spectrum Foundation
0003710285
03/23/09
10/24/07 WQHZ608 Skybridge Spectrum Foundation
0003710202
03/23/09
10/24/07 WQHZ609 Skybridge Spectrum Foundation
0003710203
03/23/09
10/24/07 WQHZ611 Skybridge Spectrum Foundation
0003710204
03/23/09
10/24/07 WQHZ612 Skybridge Spectrum Foundation
0003710259
03/23/09
10/24/07 WQHZ613 Skybridge Spectrum Foundation
0003710278
03/23/09
10/24/07 WQHZ614 Skybridge Spectrum Foundation
0003710267
03/23/09
10/24/07 WQHZ615 Skybridge Spectrum Foundation
0003710205
03/23/09
10/24/07 WQHZ616 Skybridge Spectrum Foundation
0003710301
03/23/09
10/24/07 WQHZ617 Skybridge Spectrum Foundation
0003710206
03/23/09
10/24/07 WQHZ618 Skybridge Spectrum Foundation
0003710207
03/23/09
10/24/07 WQHZ619 Skybridge Spectrum Foundation
0003710286
03/23/09
10/24/07 WQHZ620 Skybridge Spectrum Foundation
0003710208
03/23/09
10/24/07 WQHZ621 Skybridge Spectrum Foundation
0003710209
03/23/09
10/24/07 WQHZ622 Skybridge Spectrum Foundation
0003710260
03/23/09
10/24/07 WQHZ623 Skybridge Spectrum Foundation
0003710210
03/23/09
10/24/07 WQHZ624 Skybridge Spectrum Foundation
0003710268
03/23/09
10/24/07 WQHZ625 Skybridge Spectrum Foundation
0003710211
03/23/09
10/24/07 WQHZ626 Skybridge Spectrum Foundation
0003710212
03/23/09
10/24/07 WQHZ627 Skybridge Spectrum Foundation
0003710279
03/23/09
10/24/07 WQHZ628 Skybridge Spectrum Foundation
0003710287
03/23/09
10/24/07 WQHZ629 Skybridge Spectrum Foundation
0003710213
03/23/09
10/24/07 WQHZ630 Skybridge Spectrum Foundation
0003710274
03/23/09
10/24/07 WQHZ631 Skybridge Spectrum Foundation
0003710214
03/23/09
10/24/07 WQHZ632 Skybridge Spectrum Foundation
0003710296
03/23/09
10/24/07 WQHZ633 Skybridge Spectrum Foundation
0003710302
03/23/09
10/24/07 WQHZ634 Skybridge Spectrum Foundation
0003710215
03/23/09
10/24/07 WQHZ635 Skybridge Spectrum Foundation
0003710216
03/23/09
10/24/07 WQHZ636 Skybridge Spectrum Foundation
0003710217
03/23/09
10/24/07 WQHZ637 Skybridge Spectrum Foundation
0003710218
03/23/09
10/24/07 WQHZ638 Skybridge Spectrum Foundation
0003710288
03/23/09
10/24/07 WQHZ639 Skybridge Spectrum Foundation
0003710269
03/23/09
10/24/07 WQHZ640 Skybridge Spectrum Foundation
0003710219
03/23/09
10/24/07 WQHZ641 Skybridge Spectrum Foundation
0003710220
03/23/09
10/24/07 WQHZ642 Skybridge Spectrum Foundation
0003710221
03/23/09
10/24/07 WQHZ643 Skybridge Spectrum Foundation
0003710261
03/23/09
10/24/07 WQHZ644 Skybridge Spectrum Foundation
0003710303
03/23/09
10/24/07 WQHZ645 Skybridge Spectrum Foundation
0003710222
03/23/09
10/24/07 WQHZ646 Skybridge Spectrum Foundation
0003710223
03/23/09
10/24/07 WQHZ647 Skybridge Spectrum Foundation
0003710224
03/23/09
10/24/07 WQHZ648 Skybridge Spectrum Foundation
0003710275
03/23/09
10/24/07 WQHZ649 Skybridge Spectrum Foundation
0003710289
03/23/09
10/24/07 WQHZ650 Skybridge Spectrum Foundation
0003710225
03/23/09
23

Federal Communications Commission

DA 14-121

Renewal
First
Second
Extension
Application - License
License
Construction Construction Request - FCC FCC File
Expiration
Grant Date Call Sign
Licensee Name
Deadline
Deadline
File Number
Number
Date
10/24/07 WQHZ651 Skybridge Spectrum Foundation
0003710226
03/23/09
10/24/07 WQHZ652 Skybridge Spectrum Foundation
0003710227
03/23/09
10/24/07 WQHZ653 Skybridge Spectrum Foundation
0003710262
03/23/09
10/24/07 WQHZ654 Skybridge Spectrum Foundation
0003710280
03/23/09
10/24/07 WQHZ655 Skybridge Spectrum Foundation
0003710310
03/23/09
10/24/07 WQHZ656 Skybridge Spectrum Foundation
0003710228
03/23/09
10/24/07 WQHZ657 Skybridge Spectrum Foundation
0003710304
03/23/09
10/24/07 WQHZ658 Skybridge Spectrum Foundation
0003710229
03/23/09
10/24/07 WQHZ659 Skybridge Spectrum Foundation
0003710230
03/23/09
10/24/07 WQHZ660 Skybridge Spectrum Foundation
0003710290
03/23/09
10/24/07 WQHZ661 Skybridge Spectrum Foundation
0003710231
03/23/09
10/24/07 WQHZ662 Skybridge Spectrum Foundation
0003710232
03/23/09
10/24/07 WQHZ663 Skybridge Spectrum Foundation
0003710309
03/23/09
10/24/07 WQHZ664 Skybridge Spectrum Foundation
0003710233
03/23/09
10/24/07 WQHZ665 Skybridge Spectrum Foundation
0003710270
03/23/09
10/24/07 WQHZ666 Skybridge Spectrum Foundation
0003710234
03/23/09
10/24/07 WQHZ667 Skybridge Spectrum Foundation
0003710235
03/23/09
10/24/07 WQHZ668 Skybridge Spectrum Foundation
0003710281
03/23/09
10/24/07 WQHZ669 Skybridge Spectrum Foundation
0003710291
03/23/09
10/24/07 WQHZ670 Skybridge Spectrum Foundation
0003710236
03/23/09
10/24/07 WQHZ671 Skybridge Spectrum Foundation
0003710276
03/23/09
10/24/07 WQHZ672 Skybridge Spectrum Foundation
0003710237
03/23/09
10/24/07 WQHZ673 Skybridge Spectrum Foundation
0003710263
03/23/09
10/24/07 WQHZ674 Skybridge Spectrum Foundation
0003710305
03/23/09
10/24/07 WQHZ675 Skybridge Spectrum Foundation
0003710238
03/23/09
10/24/07 WQHZ676 Skybridge Spectrum Foundation
0003710239
03/23/09
10/24/07 WQHZ677 Skybridge Spectrum Foundation
0003710240
03/23/09
10/24/07 WQHZ678 Skybridge Spectrum Foundation
0003710241
03/23/09
10/24/07 WQHZ679 Skybridge Spectrum Foundation
0003710292
03/23/09
10/24/07 WQHZ680 Skybridge Spectrum Foundation
0003710271
03/23/09
10/24/07 WQHZ681 Skybridge Spectrum Foundation
0003710242
03/23/09
10/24/07 WQHZ682 Skybridge Spectrum Foundation
0003710243
03/23/09
10/24/07 WQHZ683 Skybridge Spectrum Foundation
0003710244
03/23/09
10/24/07 WQHZ684 Skybridge Spectrum Foundation
0003710264
03/23/09
10/24/07 WQHZ685 Skybridge Spectrum Foundation
0003710306
03/23/09
10/24/07 WQHZ686 Skybridge Spectrum Foundation
0003710245
03/23/09
10/24/07 WQHZ687 Skybridge Spectrum Foundation
0003710246
03/23/09
10/24/07 WQHZ688 Skybridge Spectrum Foundation
0003710247
03/22/09
10/24/07 WQHZ689 Skybridge Spectrum Foundation
0003710311
03/23/09
10/24/07 WQHZ690 Skybridge Spectrum Foundation
0003710293
03/23/09
10/24/07 WQHZ691 Skybridge Spectrum Foundation
0003710248
03/23/09
10/24/07 WQHZ692 Skybridge Spectrum Foundation
0003710249
03/23/09
10/24/07 WQHZ693 Skybridge Spectrum Foundation
0003710250
03/23/09
10/24/07 WQHZ694 Skybridge Spectrum Foundation
0003710265
03/23/09
10/24/07 WQHZ695 Skybridge Spectrum Foundation
0003710282
03/23/09
10/24/07 WQHZ696 Skybridge Spectrum Foundation
0003710272
03/23/09
10/24/07 WQHZ697 Skybridge Spectrum Foundation
0003710251
03/23/09
10/24/07 WQHZ698 Skybridge Spectrum Foundation
0003710307
03/23/09
10/24/07 WQHZ699 Skybridge Spectrum Foundation
0003710252
03/23/09
10/24/07 WQHZ700 Skybridge Spectrum Foundation
0003710253
03/23/09
10/24/07 WQHZ701 Skybridge Spectrum Foundation
0003710294
03/23/09
10/24/07 WQHZ702 Skybridge Spectrum Foundation
0003710254
03/23/09
10/24/07 WQHZ703 Skybridge Spectrum Foundation
0003710295
03/23/09
10/24/07 WQHZ704 Skybridge Spectrum Foundation
0003710255
03/23/09
24

Federal Communications Commission

DA 14-121

Renewal
First
Second
Extension
Application - License
License
Construction Construction Request - FCC FCC File
Expiration
Grant Date Call Sign
Licensee Name
Deadline
Deadline
File Number
Number
Date
10/24/07 WQHZ705 Skybridge Spectrum Foundation
0003710308
03/23/09
10/24/07 WQHZ706 Skybridge Spectrum Foundation
0003989108
10/07/09
10/24/07 WQHZ707 Skybridge Spectrum Foundation
0003989152
10/07/09
10/24/07 WQHZ708 Skybridge Spectrum Foundation
0003989109
10/07/09
10/24/07 WQHZ709 Skybridge Spectrum Foundation
0003989110
10/07/09
10/24/07 WQHZ710 Skybridge Spectrum Foundation
0003989159
10/07/09
10/24/07 WQHZ711 Skybridge Spectrum Foundation
0003989163
10/07/09
10/24/07 WQHZ712 Skybridge Spectrum Foundation
0003989111
10/07/09
10/24/07 WQHZ713 Skybridge Spectrum Foundation
0003989155
10/07/09
10/24/07 WQHZ714 Skybridge Spectrum Foundation
0003989112
10/07/09
10/24/07 WQHZ715 Skybridge Spectrum Foundation
0003989151
10/07/09
10/24/07 WQHZ716 Skybridge Spectrum Foundation
0003989170
10/07/09
10/24/07 WQHZ717 Skybridge Spectrum Foundation
0003989113
10/07/09
10/24/07 WQHZ718 Skybridge Spectrum Foundation
0003989114
10/07/09
10/24/07 WQHZ719 Skybridge Spectrum Foundation
0003989115
10/07/09
10/24/07 WQHZ720 Skybridge Spectrum Foundation
0003989116
10/07/09
10/24/07 WQHZ721 Skybridge Spectrum Foundation
0003989164
10/07/09
10/24/07 WQHZ722 Skybridge Spectrum Foundation
0003989153
10/07/09
10/24/07 WQHZ723 Skybridge Spectrum Foundation
0003989117
10/07/09
10/24/07 WQHZ724 Skybridge Spectrum Foundation
0003989118
10/07/09
10/24/07 WQHZ725 Skybridge Spectrum Foundation
0003989119
10/07/09
10/24/07 WQHZ726 Skybridge Spectrum Foundation
0003989176
10/07/09
10/24/07 WQHZ727 Skybridge Spectrum Foundation
0003989171
10/07/09
10/24/07 WQHZ728 Skybridge Spectrum Foundation
0003989120
10/07/09
10/24/07 WQHZ729 Skybridge Spectrum Foundation
0003989121
10/07/09
10/24/07 WQHZ730 Skybridge Spectrum Foundation
0003989122
10/07/09
10/24/07 WQHZ731 Skybridge Spectrum Foundation
0003989156
10/07/09
10/24/07 WQHZ732 Skybridge Spectrum Foundation
0003989165
10/07/09
10/24/07 WQHZ733 Skybridge Spectrum Foundation
0003989123
10/07/09
10/24/07 WQHZ734 Skybridge Spectrum Foundation
0003989124
10/07/09
10/24/07 WQHZ735 Skybridge Spectrum Foundation
0003989125
10/07/09
10/24/07 WQHZ736 Skybridge Spectrum Foundation
0003989162
10/07/09
10/24/07 WQHZ737 Skybridge Spectrum Foundation
0003989160
10/07/09
10/24/07 WQHZ738 Skybridge Spectrum Foundation
0003989154
10/07/09
11/01/07 WQHZ739 Skybridge Spectrum Foundation
0003989126
10/07/09
11/01/07 WQHZ740 Skybridge Spectrum Foundation
0003989172
10/07/09
11/01/07 WQHZ741 Skybridge Spectrum Foundation
0003989127
10/07/09
11/01/07 WQHZ742 Skybridge Spectrum Foundation
0003989128
10/07/09
11/01/07 WQHZ743 Skybridge Spectrum Foundation
0003989166
10/07/09
11/01/07 WQHZ744 Skybridge Spectrum Foundation
0003989129
10/07/09
11/01/07 WQHZ745 Skybridge Spectrum Foundation
0003989173
10/07/09
11/01/07 WQHZ746 Skybridge Spectrum Foundation
0003989130
10/07/09
11/01/07 WQHZ747 Skybridge Spectrum Foundation
0003989131
10/07/09
11/01/07 WQHZ748 Skybridge Spectrum Foundation
0003989132
10/07/09
11/01/07 WQHZ749 Skybridge Spectrum Foundation
0003989133
10/07/09
11/01/07 WQHZ750 Skybridge Spectrum Foundation
0003989134
10/07/09
11/01/07 WQHZ751 Skybridge Spectrum Foundation
0003989167
10/07/09
11/01/07 WQHZ752 Skybridge Spectrum Foundation
0003989135
10/07/09
11/01/07 WQHZ753 Skybridge Spectrum Foundation
0003989136
10/07/09
11/01/07 WQHZ754 Skybridge Spectrum Foundation
0003989161
10/07/09
11/01/07 WQHZ755 Skybridge Spectrum Foundation
0003989174
10/07/09
11/01/07 WQHZ756 Skybridge Spectrum Foundation
0003989157
10/07/09
11/01/07 WQHZ757 Skybridge Spectrum Foundation
0003989137
10/07/09
11/01/07 WQHZ758 Skybridge Spectrum Foundation
0003989138
10/07/09
25

Federal Communications Commission

DA 14-121

Renewal
First
Second
Extension
Application - License
License
Construction Construction Request - FCC FCC File
Expiration
Grant Date Call Sign
Licensee Name
Deadline
Deadline
File Number
Number
Date
11/01/07 WQHZ759 Skybridge Spectrum Foundation
0003989139
10/07/09
11/01/07 WQHZ760 Skybridge Spectrum Foundation
0003989140
10/07/09
11/01/07 WQHZ761 Skybridge Spectrum Foundation
0003989168
10/07/09
11/01/07 WQHZ762 Skybridge Spectrum Foundation
0003989141
10/07/09
11/01/07 WQHZ763 Skybridge Spectrum Foundation
0003989142
10/07/09
11/01/07 WQHZ764 Skybridge Spectrum Foundation
0003989143
10/07/09
11/01/07 WQHZ765 Skybridge Spectrum Foundation
0003989175
10/07/09
11/01/07 WQHZ766 Skybridge Spectrum Foundation
0003989144
10/07/09
11/01/07 WQHZ767 Skybridge Spectrum Foundation
0003989145
10/07/09
11/01/07 WQHZ768 Skybridge Spectrum Foundation
0003989146
10/07/09
11/01/07 WQHZ769 Skybridge Spectrum Foundation
0003989169
10/07/09
11/01/07 WQHZ770 Skybridge Spectrum Foundation
0003989147
10/07/09
11/01/07 WQHZ771 Skybridge Spectrum Foundation
0003989158
10/07/09
11/01/07 WQHZ772 Skybridge Spectrum Foundation
0003989148
10/07/09
11/01/07 WQHZ773 Skybridge Spectrum Foundation
0003989149
10/07/09
10/24/07 WQHZ610 Skybridge Spectrum Foundation
03/23/09

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