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Seeks Comment on Maine's Request for Waiver of Paging Requirements

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Released: July 9, 2013

Federal Communications Commission

News Media Information 202 / 418-0500
445 12th Street, S.W.
Fax-On-Demand 202 / 418-2830

Washington, D.C. 20554

TTY 202 / 418-2555

DA 13-1536

Released: July 9, 2013





File No. 0005722810

Comment Date: July 19, 2013
Reply Comment Date: July 26, 2013

The State of Maine (Maine or the State) filed an application and waiver request seeking authority
to operate Public Safety Pool frequency 157.450 MHz at its Huntoon Hill site as part of its VHF
statewide public safety radio system.1 Operations on frequency 157.450 MHz are only for one-way
paging communications to mobile receivers with a maximum transmitter output power of 30 watts.2
Maine seeks a waiver to operate this frequency in the voice mode with a maximum transmitter output
power of 110 watts.3
Maine is in the process of implementing a new narrowband (12.5 kHz channel bandwidth) VHF
Project 25 trunked radio system.4 In its ongoing effort to achieve statewide operability and
interoperability on this system, Maine states that it "conducted a thorough search of Public Safety Pool
frequencies for a site located at Huntoon Hill, which is needed to fill in system coverage along a portion
of the Maine coastline," and concluded that 157.450 MHz is the only Public Safety Pool frequency
available at this location.5 Maine's statewide radio system, however, is a "state-of-the-art" two-way
voice communications system that is incompatible with limitations the Commission has imposed on the

1 See File No. 0005722810. See also Request for Waiver, dated April 2013, attached to File No. 0005722810
(Waiver Request).
2 47 C.F.R. 90.20(d)(13) and (45).
3 Waiver Request at 3-4. In its application, Maine noted an output power of 110 watts, but its waiver request noted
85 watts.
4 Id. at 1.
5 Id. at 3.

use of this frequency.6 Maine thus seeks waiver relief of Sections 90.20(d)(13) and (45) of the
Commission's rules in order to incorporate the channel into its statewide network.7
Maine states that, while frequency 157.450 MHz is designated as a one-way paging channel, it
should be allowed to operate voice communications on the channel because "there is no longer a demand
for public safety paging in Maine."8 The State notes that the Commission has previously granted waivers
to allow public safety use of frequencies limited to paging-related operations for voice communications.9
Maine furthermore claims its proposed operation of the frequency will utilize a more efficient bandwidth
of 12.5 kHz or less, as opposed to the current 25 kHz bandwidth specification.10
In seeking a waiver from the 30 watts maximum transmitter output power limitation, Maine
states that "the power level limitation is not served insofar as the ERP [effective radiated power] of the
proposed operation would be less than the ERP of a typical operation at the power output set forth in the
rule."11 Maine claims that, although it requires use of an "85 watt transmitter"12 to achieve necessary
coverage in the area, its antenna/transmitter line configuration will actually allow it to operate with an
ERP of 141.3 watts, while a more typical 30 watt transmitter would result in an ERP of 150 watts.13
Furthermore, Maine notes that the Commission has previously granted the State waivers on this
project to "facilitate the modernization of the State's sub-standard radio system" and acknowledged the
State's limited frequency options outside the VHF band due to its difficult terrain and proximity to
Canada.14 Maine contends that a waiver of these limitations would be in the public interest because "it
would allow for Maine's new statewide interoperability public safety communications network to extend
into an otherwise underserved coastal area" without undermining the underlying purpose of the

6 Id. at 4.
7 Id. Section 90.20(d)(13) states that frequency 157.450 MHz will be assigned only for one-way paging
communications while Section 90.20(d)(45) limits operations to 30 watts transmitter output power. See 47 C.F.R.
90.20(d)(13) and (45).
8 Waiver Request at 4.
9 Id. Maine itself received a waiver to operate portions of its statewide network on Part 22 paging channels for
which it obtained licenses. See State of Maine MSCommNet Project, Request for Waiver of Sections 90.35(a),
20.9(a)(6), 22.377, and 22.565(f) of the Commission's Rules, Order, 27 FCC Rcd 8891(PSHSB/WTB 2012)
(Maine I/B Waiver Order).
10 Waiver Request at 4. See also 47 C.F.R. 90.20(d)(30) (permitting licensees to operate with an authorized
bandwidth up to 25 kHz on frequency 157.450 MHz).
11 Waiver Request at 5.
12 See supra note 3 (Maine noted an output power of 110 watts in its application, but its waiver request noted 85
13 Id. at 4. Maine notes that a 47.77 dBm (30 watt) transmitter would typically have an assumed antenna gain of 6
dB, and an average line and filtering loss of 2 dB, resulting in an ERP of 51.77 dBm (150 watts).
14 Waiver Request at 3. See also Maine I/B Waiver Order, 27 FCC Rcd 8894 at 11.

Commission's rules.15 Finally, Maine notes that no incumbents operate on this channel within the state
other than Maine itself, and that the State "obviously concurs with this new application."16
Accordingly, by this public notice we seek comment on Maine's application and waiver request
to use frequency 157.450 MHz in the voice mode with a maximum transmitter output power of 110 watts
as part of its new statewide public safety radio system. In particular, we seek comment from any parties
who would be impacted by Maine's voice operation on this frequency.
Interested parties may file comments on or before

July 19, 2013

.17 Parties may file replies on or

July 26, 2013

.18 Parties may file statements and replies electronically19 or by paper.
All comments and reply comments should reference the subject Maine Waiver Request and the
DA number indicated on this Public Notice. Comments may be filed: (1) electronically by accessing the
applicant's file number(s) in the Commission's Universal Service Licensing System (ULS),20 or (2) by
filing paper copies.
Electronic Filers: Pleadings may be submitted electronically as follows:

From the ULS website at, begin the process of submitting a
pleading by clicking on the "ULS Pleadings" link in the menu on the lower left side of the
ULS web page. The link will take you to the "Pleading Information" screen for "Non-
docketed Pleadings" where you select "Reply" in the drop-down window for the type of
pleading and then enter the pleadings filer information. Completion of the contact
information is optional. Upon completion of this screen, please note the instructions for the
filing: "Pleadings must be dated and must include a signature, in this instance an electronic
signature, and the address and phone number of the signing party
."21 Click on

The second step is to complete the File Numbers/Call Signs screen. Click if the pleading
pertains to a File Number or Call Sign and enter the File Number or Call Sign. Please note
that you must enter a File Number or Call Sign to continue. If the pleading pertains to
multiple applications or licenses, you must enter each File Number or Call Sign as
appropriate. After clicking the "SUBMIT" button, the screen will update to show all the File

15 Waiver Request at 4.
16 Id. at 3.
17 47 C.F.R. 1.405.
18 Id.
19 See Electronic Filing of Documents in Rulemaking Proceedings, 63 FR 24121 (1998)
20 See "Wireless Telecommunications Bureau Enhances the Commission's Universal Licensing System to
Implement Electronic Filing for Pleadings," Public Notice, 21 FCC Rcd 424 (WTB 2006). See
21 See 47 C.F.R. Part 1.

Numbers/Call Signs associated with the pleading. At this time, you may delete selected File
Numbers/Call Signs from the page before continuing.

The third step is to complete the Attach File screen to attach the pleading document. Use the
drop down box to select Pleading or Confidential Pleading. The "BROWSE" button opens a
file upload window where you will locate and select your pleading file. The Description
field allows you to enter a brief description for the pleading. Click the "ADD
ATTACHMENT" button to upload your pleading. You may submit up to thirty files for
each pleading but each file must be smaller than 10 MB in size. You also have the
opportunity to delete any selected file from the pleading.

Finally, to complete your electronic pleading submission, click on the "SUBMIT
PLEADING" button and the Confirmation screen will be displayed. The Confirmation
screen will display your Confirmation Number as well as your entered pleadings information.
You may print this page for your records by selecting the Print Page link at the top of the
page and have the option of submitting another pleading or returning to the ULS website by
selecting a link at the bottom of the page.
The ULS Application and License Search results will display pleadings under the ADMIN tab
when a comment or reply comment has been filed. Users can view the pleading by clicking on the link
for the specific comment or reply comment in the Description field. The general public will not be able
to view confidential pleadings.
For additional information or assistance on how to file a comment or reply comment or other
relevant pleading, you may visit the Web at You may also call the FCC ULS
Customer Support Center at (877) 480-3201 and select option 2, or (888) 225-5322 and select Option 2,
or (717) 338-2888. For TTY, please call (717) 338-2824. Assistance from the FCC ULS Customer
Support Center is available between the hours of 8 a.m. to 6:00 p.m. Eastern Time, Monday through
Friday (except Federal holidays). To provide quality service and ensure security, all telephone calls to
FCC ULS Customer Support Center are recorded.
Paper Filers: Parties who choose to file by paper must submit an original and four copies of each

Send hand-delivered or messenger-delivered paper filings for the Commission's Secretary to
FCC Headquarters at 445 12th St., SW, Room TW-A325, Washington, DC 20554. The
filing hours are 8:00 a.m. to 7:00 p.m. All hand deliveries must be held together with rubber
bands or fasteners. Any envelopes and boxes must be disposed of before entering the

Send commercial overnight mail (other than U.S. Postal Service Express Mail and Priority
Mail) to 9300 East Hampton Drive, Capitol Heights, M.D. 20743.

Send U.S. Postal Service first-class, Express, and Priority to 445 12th Street, SW,
Washington, D.C. 20554.

The application(s), waiver request, and comments and reply comments can be accessed
electronically via the Commission's Universal Licensing System, The full
text of the Maine Waiver Request, comments and reply comments will be available for inspection and
copying during business hours at the FCC Reference Information Center, Portals II, 445 12th St. SW,
Room CY-A257, Washington, D.C. 20554. The documents may also be purchased from BCPI. Email or call the Consumer & Governmental Affairs Bureau, (voice) (202) 418-0530, (TTY)
(202)-418-0432 to request materials in formats accessible to people with disabilities, e.g. Braille, large
print, electronic files, audio format.
For further information regarding this proceeding contact Brian Marenco, Policy and Licensing
Division, Public Safety and Homeland Security Bureau, (voice) (202) 418-0838 or
-- FCC --

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