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ADCOMM ENGINEERING COMPANY

Communications Consulting Engineers

March 10, 2008 Federal Communications Commission Washington DC 20554 Subject: Benton County Emergency Services (BCES) Waiver Request for Rebanding Completion Date per WT Docket 02-55

On behalf of Benton County Emergency Services (BCES), we are submitting a waiver request for the rebanding completion date of June 26, 2008 per WT Docket 02-55. BCES has an FRA with Sprint-Nextel and has been working on implementing rebanding. BCES is just getting started on their rebanding implementation work. Please feel free to contact me if you have any questions or Mr. Doug deGraaf, BCES Technical Services Manager, 509-628-1552. Sincerely,

Joe Blaschka Jr., PE

3929 184th Place SE Bothell, WA 98012-8827 Voice: 4258218827 Fax: 4254883952 E-mail: [email protected]

Joe Blaschka, Jr., P.E.

Before the Federal Communications Commission Washington, DC 20554

In the Matter of Improving Public Safety Communications in the 800 MHz Band

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WT Docket No. 02-55 Licensee Name: _Benton County, Emergency Services_ Call Sign _KNNT477, WPYD863, WQGQ611___________________

March 14, 2008 To: Public Safety and Homeland Security Bureau, Federal Communications Commission REQUEST FOR WAIVER OF THE JUNE 26, 2008 DEADLINE FOR COMPLETION OF 800 MHZ REBANDING

Pursuant to Section 1.925 (47 C.F.R. § 1.925) of the rules of the Federal Communications Commission (Commission) and the Commission's Public Notice,1 the above-referenced licensee ("Licensee") requests a waiver of the Commission's requirement for the Licensee to complete its 800 MHz rebanding by June 26, 2008.2 The Licensee recognizes that the Commission has noted: "Requests for extension will be subject to a high level of scrutiny. Licensees will be expected to demonstrate that they have worked diligently and in good faith to complete rebanding expeditiously, and that the amount of additional time requested is no more than is reasonably necessary to complete the rebanding process."3 Specifically, the Licensee requests until February 2009 to complete its 800 MHz rebanding. The public interest would be served by granting the requested waiver because it would allow Licensee to reband its 800 MHz system in a reasonable, prudent and timely manner consistent with the goals of the

Federal Communications Commission Provides Guidance for Submission of Requests for Waiver of June 26, 2008 Deadline for Completion of 800 MHz Rebanding, Public Notice, FCC 08-23 (rel. Jan. 17, 2008). 2 See Improving Public Safety Communications in the 800 MHz Band, Report and Order, Fifth Report and Order, Fourth Memorandum Opinion and Order, 19 FCC Rcd 14969 (2004), Third Memorandum Opinion and Order, 22 FCC Rcd 17209, 17224 ¶ 48 (2007). 3 See FCC Announces Supplemental Procedures And Provides Guidance For Completion Of 800 MHz Rebanding, Public Notice, 22 FCC Rcd 17227, 17232 (2007).

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Request for Waiver of the June 26, 2008 Deadline for Completion of 800 MHz Rebanding Licensee Name _Benton County Emergency Services Call Sign KNNT477, WPYD863, WQGQ611 DL 8910427614

800 MHz rebanding program. In support of this Request for Waiver the Licensee provides the attached Waiver Request Information Form and the following explanation of the reason(s) for not completing reconfiguration by June 26, 2008, which is consistent with the assertion that a grant of the waiver would serve the public interest. Benton County Emergency Services (BCES) has a signed FRA with Sprint Nextel dated February 26, 2008. BCES is moving two channels out of the expansion band and changing the frequencies of the National Public Safety Planning Advisory Committee (NPSPAC) mutual aid channels. BCES received an approved Planning Funding Agreement on January 9, 2007. The original rebanding plan draft was submitted to Sprint Nextel in August of 2007 but a final agreement was not signed until February 26, 2008. BCES has contracted with Motorola to perform the rebanding work on the subscribers and infrastructure. BCES is in the process of expanding their system and that work has resulted in resource limitations to perform the planning work on a faster schedule. Motorola is training a new project manager for this project and the initial kick off meeting will be on April 2, 2008. It is currently estimated work on subscriber units will start in May 2008 and be completed by December 2008 with infrastructure work starting in January 2009 and being completed in March of 2009 with final project close out being in May 2009 Check if additional sheets are attached.

Finally, the licensee seeks confidential treatment of the Waiver Request Information Form pursuant to Section 0.459 of the FCC's Rules because the information contained therein is highly sensitive regarding the operations of a public safety organization's communications system. Furthermore, the information contained in the form is not otherwise publicly available. The Licensee consents to the disclosure of the form to the 800 MHz Transition Administrator ("TA") and Sprint Nextel and requests that they treat the form as confidential.

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Request for Waiver of the June 26, 2008 Deadline for Completion of 800 MHz Rebanding Licensee Name _Benton County Emergency Services Call Sign KNNT477, WPYD863, WQGQ611 DL 8910427614

Respectfully Submitted,

___________________________3/14/08_ Signature Date

_Valerie Eveland, System Manager Name and Title

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Microsoft Word - FCC_Waiver_rebanding_Request_080310.doc