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Seeks Comment on Montana Applications for VHF Maritime Frequencies

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Released: May 8, 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 13-1012

Released: May 8, 2013




File Numbers Listed in Appendix

Comment Date: June 7, 2013
Reply Comment Date: June 24, 2013

The State of Montana, the Montana Department of Transportation and the County of Jefferson,
Montana (collectively Montana) have filed four applications1 seeking authority to operate trunked and
conventional private land mobile radio facilities on VHF frequencies in the 150 MHz band assigned to
the VHF Maritime Service.2
Montana filed a waiver request in connection with these applications seeking waiver of the
eligibility and operating requirements applicable to licensees operating on these maritime frequencies.3
The County of Jefferson also seeks to license one 450 MHz frequency from the Industrial/Business Pool.4
In its waiver request, Montana states that the purpose of the applications is to add new sites to its
Interoperability Montana System (IM System) to expand coverage to un-served areas and increase
capacity.5 Montana’s IM System uses VHF trunked digital radio technology to enable interoperable
mobile wireless communications between Montana’s state and county public safety agencies, Indian
tribes, and the Federal government.6 Montana contends that interoperable communications are critical
because the State’s 550-mile border with Canada presents communication challenges to its law
enforcement, federal, state, local and tribal entities.7

1 The file numbers for these applications are listed in the attached Appendix.
2 47 C.F.R. § 80.373(f).
3 See Request for Waiver attached to the applications listed in the Appendix (Montana Waiver Request).
4 See ULS File No. 0005028256. See also 47 C.F.R. § 90.35(b)(3).
5 Montana Waiver Request at 3.
6 Id. at 1.
7 Id. at 2-3.

Due to Montana’s extensive geography and sparse population, it chose VHF frequencies for its
IM System because VHF wireless technology provides an “optimum signal in terms of reliability and
geographic coverage.”8 Montana argues that the “cost savings of a VHF network over 800 MHz, 900
MHz and 700 MHz systems are substantial.”9
Montana further states that its proposed expansion of the IM System is premised on maximum
channel re-use of the public safety frequencies listed in Section 90.20 of the Commission’s rules.10
Nonetheless, due to unanticipated high levels of traffic on the initially constructed sites, Montana claims
that additional spectrum is needed to meet the requirements of the IM System.11
Consequently, Montana requests waiver of the Commission’s Part 80 regulations so that it may
expand the IM System through inclusion of Maritime Service frequencies listed in Section 80.373(f)12 of
the Commission’s rules.13
Specifically, Montana seeks a waiver of Sections 80.105, 80.106, 80.203, 80.211, 80.213, 80.215
and 80.37314 of the Commission’s rules in order to incorporate Maritime Service frequencies into its IM
System.15 Montana claims it satisfies the five factors which the Commission generally considers when
applicants seek to use maritime spectrum for land mobile use.16
Furthermore, although not specifically addressed in its waiver request, the County of Jefferson
also seeks to license a 450 MHz frequency from the Industrial/Business Pool.17
Interested parties may file comments on or before June 7, 201318 and reply comments on or
before June 24, 2013.19 Parties may file comments and replies electronically20 or by paper.

8 Id. at 3.
9 Id.
10 Id.
11 Id. at 4.
12 47 C.F.R. § 80.373(f).
13 Montana Waiver Request. at 1, 8-9.
14 47 C.F.R. §§ 80.105, 80.106, 80.203, 80.211, 80.213, 80.215, 80.373.
15 Montana Waiver Request at 8. Montana references Section 80.206 in its waiver request but because there is no
such rule section we assume Montana intends to refer to Section 80.106 entitled “Intercommunication in the mobile
service.” See 47 C.F.R. § 80.106.
16 Montana Waiver Request at 10-11.
17 The County of Jefferson seeks to license Industrial/Business Pool frequency 452.175 MHz at location 7 on ULS
File No. 0005028256.
18 47 C.F.R. § 1.405.

All comments and reply comments should reference the subject Montana 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),21 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
.”22 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.23 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
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.

19 Id.
20 See Electronic Filing of Documents in Rulemaking Proceedings, 63 FR 24121 (1998)
21 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
22 See 47 C.F.R. Part 1.
23 The file numbers of Montana’s applications are listed in the Appendix.

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 Montana 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 --


Montana Applications Seeking VHF Public Coast and Maritime Frequencies

Maritime Sec. 80.373(f)
Industrial/Business Frequency
County of Jefferson
County of Jefferson
Montana Dept of Transportation
Yes (offset)
Montana Dept of Transportation

24 This application is in return status pending additional information from the applicant on its request to license
frequency 452.175 MHz from the Industrial/Business Pool.
25 This application seeks to license frequency 156.990 MHz which is a non-standard frequency offset between
maritime service frequencies 156.975 MHz and 157.000 MHz. See 47 C.F.R. § 80.373(f).

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