Federal Communications Commission DA 10-857 
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
COUNTY OF OAKLAND, MICHIGAN 
 
Licensee of Private Land Mobile Radio Station 
WPPC814
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ORDER PROPOSING MODIFICATION
Adopted: May 21, 2010 Released: May 21, 2010
By the Deputy Chief, Policy Division, Public Safety and Homeland Security Bureau:
I. INTRODUCTION
1. By this Order Proposing Modification, we initiate a proceeding to modify the license of the 
County of Oakland, Michigan (Oakland County) for Private Land Mobile Radio (PLMR) Station 
WPPC814 by: 1) reducing the Effective Radiated Power (ERP) of all base station locations and 2) 
restricting the area of operation of all mobile units and control stations operating above 2.5 watts ERP to 
more then 30 kilometers from the Canada-United States border.  We take this action in furtherance of 
ensuring compliance with international obligations. 
II. BACKGROUND
2. Oakland County is licensed to operate PLMR Station WPPC814 at numerous locations 
throughout the County.  Because Station WPPC814 operates in the 800 MHz band and is located within 
140 kilometers of the border with Canada, it is subject to the provisions of a bilateral annex with Canada 
(Arrangement F) and an associated Interim Arrangement which specify the conditions under which 800 
MHz PLMR stations may operate along the common border.1  
3. Arrangement F and the associated Interim Arrangement divide the 800 MHz band into band 
segments and assign primary access to these band segments to either licensees in the U.S. or Canada.2  
U.S. licensees may operate on band segments designated as primary to licensees in Canada, but only if 
  
1 See Arrangement Between the Dept. of Communications of Canada and the FCC of the United States Concerning 
the Use Along the US-Canada Border of the Band 806-890 MHz (Jan. 1994) (Arrangement F); see also
Arrangement Between the Dept. of Communications of Canada and the FCC of the United States Concerning the 
Use Along the US-Canada Border of the Bands 821-824 MHz and 866-869 MHz (Sep. 1990) (Interim 
Arrangement) both as modified by attachment to letter from Robert W. McCaugern, Deputy Director General, 
Spectrum Engineering to Mr. Bruce Franca, Deputy Chief Engineer, Office of Engineering and Technology, 
Federal Communications Commission (Dec. 9, 1994) (Letter Amendment).  
2 Arrangement F at ¶¶ 3-4.  Interim Arrangement at ¶¶ 2-3.  
Federal Communications Commission DA 10-857 
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they satisfy certain signal strength limits at the border.3 These signal strength limits are specified in 
terms of power flux density (PFD) and vary depending on the height of the transmitting antenna.4  
4. Oakland County’s license, call sign WPPC814, authorizes operation on multiple channels in 
the 821-821.45 MHz/866-866.45 MHz band segment which is primary to licensees in Canada under the 
Interim Arrangement.5 Consequently, we have calculated the PFD at the border from Oakland County’s 
stations and listed the results in Attachment I, Table A2 (for base stations) and Table A5 (for mobile and 
control stations).  The PFD values from each base station exceed the permitted PFD at the border by at 
least 3 dB on the frequencies identified in Table A3 of Attachment I.  The PFD values from mobile units 
and control stations authorized to operate at 35 watts ERP exceed the PFD at the border by 7 dB when 
located at the boundary of the County closest to the border with Canada on the frequencies identified in 
Attachment I, Table A6.       
III. DISCUSSION
5. Based on the information before us, we conclude that the license, call sign WPPC814, should 
be modified by: (1) reducing the ERP of the base station locations to the levels indicated in Attachment I, 
Table A3 and, (2) restricting the operating area of mobile units and control stations authorized for 
operation at 35 watts ERP to locations further than 30 kilometers from the Canada border on the 
frequencies listed in Attachment I, Table A6.6 We propose these modifications in order to bring Station 
WPPC814 into compliance with the PFD limits specified in Arrangement F and the associated Interim 
Arrangement.        
6. In accordance with Section 1.87(a) of the Commission's Rules,7 we will refrain from 
modifying the license, call sign WPPC814, until Oakland County has received notice of this proposed 
action and has had an opportunity to file a protest.  To protest the license modification, Oakland County 
must, within thirty days of the release date of this Order Proposing Modification, submit a written 
statement protesting the proposed modification and proposing an alternate means for bringing Station 
  
3 Letter Amendment at Annex A.
4 Id. at Annex B, Tables C1 and C2.
5 Interim Arrangement at ¶ 2.1(a).  License WPPC814 authorizes the County of Oakland to operate on the 
following channel pairs which are primary to licensees in Canada in Canada Border Region 3 which includes 
Oakland County, Michigan: 821.1000 MHz/866.1000 MHz, 821.1375 MHz/ 866.1375 MHz, 821.2125 
MHz/866.2125 MHz, 821.2500 MHz/866.2500 MHz, and 821.3500 MHz/866.3500 MHz.  License WPPC814 
also authorizes Oakland County to transmit on the five mutual aid channels which are co-primary to licensees in 
Canada.
6 We propose restricting the operating area of the control stations and mobile units because we believe this is a 
more practical solution to achieve compliance with the PFD limits than reducing the power of these stations. A 
control or mobile station operated at the boundary of Oakland County closest to Canada would be limited to, 
nominally, 7 watts ERP.  Consequently, we chose 30 kilometers from the border as the limiting distance because 
this is the restriction placed on such units operating near the Canada border in the 700 MHz band which has similar 
propagation characteristics to the 800 MHz band.  See Sharing Arrangement Between the Department of Industry 
Canada and the Federal Communications Commission of the United States of America Concerning the Use of the 
Frequency Bands 764 to 776 and 794 to 806 MHz by the Land Mobile Service Along the Canada-United States 
Border (Jun. 2005) at ¶ 7.1(e).    
7 47 C.F.R. § 1.87(a).
Federal Communications Commission DA 10-857 
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WPPC814 into compliance with Arrangement F and the associated Interim Arrangement.  We remind 
Oakland County that the Federal Communications Commission lacks the authority to waive or modify 
the provisions of international treaties or their associated arrangements. Oakland County’s statement 
must be filed with the Office of the Secretary, Federal Communications Commission, 445 Twelfth Street, 
S.W., Room TW-A325, Washington, DC 20554.8 In addition, please provide an electronic copy of the 
statement to Brian Marenco, Policy Division, Public Safety and Homeland Security Bureau, at 
Brian.Marenco@fcc.gov.   
7. If no timely protest is filed, Oakland County will have waived its right to protest the 
proposed modifications and will be deemed to have consented to the modifications.  The license for 
WPPC814 will then be modified to (1) reduce the ERP of the WPPC814 base stations to the values 
shown in Attachment I, Table A3, and (2) restrict the operating area of mobile units and control stations 
authorized for operation at 35 watts ERP to further than 30 kilometers from the U.S./Canada border on 
the frequencies listed in Attachment I, Table A6 in compliance with Arrangement F and the associated 
Interim Arrangement as detailed in Attachment I.      
V. ORDERING CLAUSES
8. ACCORDINGLY, IT IS PROPOSED, pursuant to Sections 4(i) and 316 of the 
Communications Act of 1934, as amended, 47 U.S.C. §§ 154(i), 316, and Section 1.87 of the 
Commission’s rules, 47 C.F.R. § 1.87 that the license for Private Land Mobile Radio Service Station 
WPPC814, held by Oakland, County of, BE MODIFIED to: (1) reduce the ERP of the WPPC814 base 
stations to the values shown in Attachment I, Table A3, and (2) restrict the operating area of mobile units 
and control stations authorized for operation at 35 watts ERP to further than 30 kilometers from the 
U.S./Canada border on the frequencies listed in Attachment I, Table A6. 
9. IT IS FURTHER ORDERED that this Order Proposing Modification shall be sent by 
certified mail, return receipt requested, to Oakland, County of, 1200 N. Telegraph, Bldg. 16 East, 
Pontiac, MI 48341.    
  
8 Filings can be sent by hand or messenger delivery, by commercial overnight courier, or by first-class or overnight 
U.S. Postal Service mail.  All filings must be addressed to the Commission’s Secretary, Office of the Secretary, 
Federal Communications Commission.  All hand-delivered or messenger-delivered paper filings for the 
Commission’s Secretary must be delivered to FCC Headquarters at 445 12th St., SW, Room TW-A325, 
Washington, DC 20554.  All hand deliveries must be held together with rubber bands or fasteners.  Any envelopes 
must be disposed of before entering the building.  Commercial overnight mail (other than U.S. Postal Service 
Express Mail and Priority Mail) must be sent to 9300 East Hampton Drive, Capitol Heights, MD 20743.  U.S. 
Postal Service first-class, Express, and Priority mail must be addressed to 445 12th Street, SW, Washington DC  
20554.
Federal Communications Commission DA 10-857 
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10. This action is taken under delegated authority pursuant to Sections 0.191 and 0.392 of the 
Commission’s Rules, 47 C.F.R. §§ 0.191, 0.392.
FEDERAL COMMUNICATIONS COMMISSION
Michael J. Wilhelm
Deputy Chief, Policy Division
Public Safety and Homeland Security Bureau
Federal Communications Commission DA 10-857 
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Attachment I
Maximum Permitted PFD at Border on Canada Primary Spectrum 
Under Arrangement F and the Interim Arrangement 
Below we calculate the PFD at the border with Canada from each base station, mobile unit and control 
station location authorized under call sign WPPC814.  We then compare the predicted PFD value with 
the maximum permitted PFD under Arrangement F and the associated Interim Arrangement for operation 
on Canada primary spectrum.  
Formula for Calculating PFD 
The following formula, based on free-space propagation, predicts PFD at the border with Canada.    
S(dBW/m2)  = PdBm – 20Log(d) – 38.8
S is the PFD in dBW/m2
P is the ERP in dBm
d is the distance to the border in meters.  
Maximum Permitted PFD
Station WPPC814 is licensed to the County of Oakland, Michigan which is located in Sharing Zone I 
under Arrangement F and the associated Interim Arrangement.  
The PFD limits for Sharing Zone I are based on the Effective Antenna Height (EAH) of the transmitting 
antenna.  The EAH is calculated by subtracting the Assumed Average Terrain Elevation (AATE) listed in 
Table A3 of the Interim Arrangement from the antenna radiation center above mean sea level 
(RCAMSL).  
EAH = RCAMSL – AATE
Using the EAH value, the maximum permitted PFD at the border with Canada for operation on Canada 
primary spectrum is listed in Table C1 of the Letter Amendment.9   
  
9 See supra note 1.
Federal Communications Commission DA 10-857 
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Base Station Locations
In Table A1 below, we list the maximum permitted PFD values, at the border, for operation on 
frequencies primary to licensees in Canada for each base station location.    
Table A1 – Maximum Permitted PFD (Base Stations)
Call Sign Location 
No.
Lat.
(N)
Long.
(W)
RCAMSL 
(meters)
AATE 
(meters)
EAH 
(meters)
Permitted PFD at 
border
(dBW/m2)
WPPC814 1 42° 38’ 41.0” 083° 17’ 52.0” 377.8 183 194.8 -90
WPPC814 2 42° 35’ 48.1” 083° 10’ 01.8” 301.0 183 118.0 -84
WPPC814 3 42° 33’ 28.1” 083° 22’ 16.8” 341.0 183 158.0 -90
WPPC814 4 42° 39’ 16.1” 083° 19’ 50.8” 341.0 183 158.0 -90
WPPC814 7 42° 44’ 32.0” 083° 23’ 31.0” 449.2 183 266.2 -90
The predicted PFD at the border with Canada is listed below in Table A2 for each base station location 
authorized on a frequency primary to licensees in Canada.  The predicted value is based on the free-space 
formula listed above.  
Table A2 – Predicted PFD (Base Stations)
Call Sign Location 
No.
Current 
Frequency
(MHz)
Replacement  
Frequency
(MHz)
ERP
(watts)
PdBm
(ERP in dBm)
d
(Distance to 
Border in 
meters)
S(dBW/m2)
(Predicted PFD at 
Border)
WPPC814 1 866.1000 857.5875 125 50.97 41,100 -80.1
WPPC814 1 866.1375 851.1375 150 51.76 41,100 -79.3
WPPC814 1 866.2125 857.7375 150 51.76 41,100 -79.3
WPPC814 1 866.2500 857.9375 125 50.97 41,100 -80.1
WPPC814 2 866.2125 857.7375 75 48.75 32,056 -80.2
WPPC814 2 866.2500 857.9375 75 48.75 32,056 -80.2
WPPC814 2 866.3500 857.7875 75 48.75 32,056 -80.2
WPPC814 3 866.2125 857.7375 160 52.04 36,600 -78.0
WPPC814 3 866.2500 857.9375 160 52.04 36,600 -78.0
WPPC814 3 866.3500 857.7875 160 52.04 36,600 -78.0
WPPC814 4 866.2125 857.7375 160 52.04 43,400 -79.5
WPPC814 7 866.2125 857.7375 125 50.97 54,300 -82.5
Federal Communications Commission DA 10-857 
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In Table A3 below, we compare the predicted PFD to the maximum permitted PFD at the border and 
calculate the ERP at which compliance would be achieved for each base station location licensed on a 
frequency primary to licensees in Canada.10  
Table A3 – Predicted PFD vs. Maximum Permitted PFD (Base Stations)
Call Sign Location 
No.
Current 
Frequency
(MHz)
Replacement  
Frequency
(MHz)
Predicted PFD 
at Border from 
Table A2
(dBW/m2)
Max. PFD at 
Border from 
Table A1
(dBW/m2)
Max. ERP to 
comply with 
PFD Limit
(dBm)
Max. ERP to 
comply with 
PFD limit
(watts)
WPPC814 1 866.1000 857.5875 -80.1 -90 41.08 12.8
WPPC814 1 866.1375 851.1375* -79.3 -90 41.08 12.8
WPPC814 1 866.2125 857.7375 -79.3 -90 41.08 12.8
WPPC814 1 866.2500 857.9375 -80.1 -90 41.08 12.8
WPPC814 2 866.2125 857.7375 -80.2 -84 44.92 31.0
WPPC814 2 866.2500 857.9375 -80.2 -84 44.92 31.0
WPPC814 2 866.3500 857.7875 -80.2 -84 44.92 31.0
WPPC814 3 866.2125 857.7375 -78.0 -90 40.07 10.2
WPPC814 3 866.2500 857.9375 -78.0 -90 40.07 10.2
WPPC814 3 866.3500 857.7875 -78.0 -90 40.07 10.2
WPPC814 4 866.2125 857.7375 -79.5 -90 41.55 14.3
WPPC814 7 866.2125 857.7375 -82.5 -90 43.50 22.4
* Base stations retuning to a replacement frequency which is primary to licensees in the U.S. must satisfy the ERP 
and antenna height limits specified in Annex A of Arrangement F when operation begins on the replacement 
frequency.  
  
10 The PFD limitation applies to both currently licensed frequencies and 800 MHz rebanding replacement 
frequencies.  See Improving Public Safety Communications in the 800 MHz Band, Report and Order, Fifth Report 
and Order, Fourth Memorandum Opinion and Order, and Order, 19 FCC Rcd 14969, 15077 ¶ 201 (2004).
Federal Communications Commission DA 10-857 
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Mobile Units and Control Stations
In Table A4 below, we calculate the permitted PFD at the border with Canada for each control station 
and mobile unit location authorized under call sign WPPC814.  The mobile units and control stations are 
authorized to operate at any location within Oakland County.  Below the permitted PFD is calculated 
when the mobile unit or control station is operating at a randomly chosen location (locations 5, 6 and 8) 
along the southeast edge of the county (nearest the border with Canada).  
For each calculation, the antenna height above ground is assumed to be 2 meters and the EAH is 
determined based on the ground elevation at the randomly chosen location.  
Table A4 – Maximum Permitted PFD (Control Stations and Mobile Units)
Call Sign Location 
No.
Lat.
(N)
Long.
(W)
RCAMSL 
(meters)
AATE 
(meters)
EAH 
(meters)
Permitted PFD at 
border
(dBW/m2)
WPPC814 5 42° 27’ 19.0” 083° 05’ 40.0” 195.0 183 12.0 -84
WPPC814 6 42° 27’ 19.0” 083° 05’ 40.0” 195.0 183 12.0 -84
WPPC814 8 42° 27’ 19.0” 083° 05’ 40.0” 195.0 183 12.0 -84
The predicted PFD at the border with Canada is listed below in Table A5 for each mobile unit and 
control station location authorized on a frequency primary to licensees in Canada.  
The predicted PFD is calculated using the free-space propagation formula noted above and based upon a 
mobile unit or control station operating at the randomly chosen location in Table A4, above.  
Table A5 – Predicted PFD (Mobile Units and Control Stations)
Call Sign Location 
No.
Station 
Class
Current 
Frequency
(MHz)
Replacement  
Frequency
(MHz)
ERP
(watts)
PdBm
(ERP in dBm)
d
(Distance to 
Border in 
meters)
S(dBW/m2)
(Predicted PFD 
at Border)
WPPC814 5 MO 821.2125 812.7375 35 45.4 15,255 -77.1
WPPC814 5 MO 821.2500 812.9375 35 45.4 15,255 -77.1
WPPC814 5 MO 821.3500 812.7875 35 45.4 15,255 -77.1
WPPC814 5 MO 821.1375 806.1375 35 45.4 15,255 -77.1
WPPC814 5 MO 821.1000 812.5875 35 45.4 15,255 -77.1
WPPC814 5 MO 866.1000 857.5875 35 45.4 15,255 -77.1
WPPC814 6 FX1 821.1375 806.1375 35 45.4 15,255 -77.1
WPPC814 6 FX1 821.1000 812.5875 35 45.4 15,255 -77.1
WPPC814 8 MO3 866.2125 857.7375 2.5 34.0 15,255 -88.5
Federal Communications Commission DA 10-857 
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Call Sign Location 
No.
Station 
Class
Current 
Frequency
(MHz)
Replacement  
Frequency
(MHz)
ERP
(watts)
PdBm
(ERP in dBm)
d
(Distance to 
Border in 
meters)
S(dBW/m2)
(Predicted PFD 
at Border)
WPPC814 8 MO3 866.3500 857.7875 2.5 34.0 15,255 -88.5
WPPC814 8 MO3 866.1500 851.1500 2.5 34.0 15,255 -88.5
WPPC814 8 MO3 866.2375 856.2625 2.5 34.0 15,255 -88.5
WPPC814 8 MO3 821.1500 806.1500 2.5 34.0 15,255 -88.5
WPPC814 8 MO 821.2375 811.2625 2.5 34.0 15,255 -88.5
WPPC814 8 MO 823.0375 808.0375 2.5 34.0 15,255 -88.5
WPPC814 8 MO 821.2125 812.7375 2.5 34.0 15,255 -88.5
WPPC814 8 MO 821.3500 812.7875 2.5 34.0 15,255 -88.5
In Table A6 below, we compare the predicted PFD to the maximum permitted PFD at the border and 
calculate the ERP at which compliance would be achieved for mobile units and control stations which 
exceed the permitted PFD and are licensed on a frequency primary to licensees in Canada.11  
Table A6 – Maximum Permitted PFD vs. Predicted PFD (Control Stations and Mobile Units)
Call Sign Location 
No.
Station 
Class
Current 
Frequency
(MHz)
Replacement 
Frequency
(MHz)
Predicted PFD 
at Border from 
Table A2
(dBW/m2)
Permitted PFD 
at Border from 
Table A1
(dBW/m2)
ERP needed 
to comply 
with PFD 
Limit
(dBm)
ERP 
needed to 
comply 
with PFD 
limit
(watts)
WPPC814 5 MO 821.2125 812.7375 -77.1 -84 38.5 7.0
WPPC814 5 MO 821.2500 812.9375 -77.1 -84 38.5 7.0
WPPC814 5 MO 821.3500 812.7875 -77.1 -84 38.5 7.0
WPPC814 5 MO 821.1375 806.1375* -77.1 -84 38.5 7.0
WPPC814 5 MO 821.1000 812.5875 -77.1 -84 38.5 7.0
WPPC814 5 MO 866.1000 857.5875 -77.1 -84 38.5 7.0
WPPC814 6 FX1 821.1375 806.1375* -77.1 -84 38.5 7.0
WPPC814 6 FX1 821.1000 812.5875 -77.1 -84 38.5 7.0
WPPC814 8 MO3 866.2125 857.7375 -88.5 -84 N/A N/A
  
11 Id.
Federal Communications Commission DA 10-857 
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Call Sign Location 
No.
Station 
Class
Current 
Frequency
(MHz)
Replacement 
Frequency
(MHz)
Predicted PFD 
at Border from 
Table A2
(dBW/m2)
Permitted PFD 
at Border from 
Table A1
(dBW/m2)
ERP needed 
to comply 
with PFD 
Limit
(dBm)
ERP 
needed to 
comply 
with PFD 
limit
(watts)
WPPC814 8 MO3 866.3500 857.7875 -88.5 -84 N/A N/A
WPPC814 8 MO3 866.1500 851.1500 -88.5 -84 N/A N/A
WPPC814 8 MO3 866.2375 856.2625 -88.5 -84 N/A N/A
WPPC814 8 MO3 821.1500 806.1500* -88.5 -84 N/A N/A
WPPC814 8 MO 821.2375 811.2625 -88.5 -84 N/A N/A
WPPC814 8 MO 823.0375 808.0375* -88.5 -84 N/A N/A
WPPC814 8 MO 821.2125 812.7375 -88.5 -84 N/A N/A
WPPC814 8 MO 821.3500 812.7875 -88.5 -84 N/A N/A
* Control Stations and mobile units retuning to a replacement frequency which is primary to licensees in the U.S. no 
longer need to comply with the PFD limits when operation begins on the replacement channel.