Federal Communications Commission DA 11-1952 
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter 
PAGING SYSTEMS, INC.
Applications to Renew Licenses for Stations 
WPKC922 and WPKC923 
Applications to Renew Licenses for Stations 
WNGR945 and WNGM656
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File Nos. 0002925303, 0002925304
File Nos. 0004439316, 0004445768
ORDER ON RECONSIDERATION
Adopted:  November 29, 2011 Released:  November 30, 2011
By the Deputy Chief, Mobility Division, Wireless Telecommunications Bureau:
1. Introduction.  This Order on Reconsideration addresses three petitions filed by Warren C. 
Havens, Environmentel LLC (Environmentel), Intelligent Transportation & Monitoring Wireless LLC, 
Verde Systems LLC, V2G LLC (V2G), Telesaurus Holdings GB LLC, and Skybridge Spectrum 
Foundation (collectively Petitioners) for reconsideration of our grant of the above-captioned applications 
of Paging Systems, Inc. (PSI) to renew its licenses for the above-captioned Part 90 Commercial 
Industrial/Business Pool stations.  For the reasons stated below, we deny the petitions.
2. Background.  Stations WPKC922 and WPKC923.  The licenses for Stations WPKC922 and 
WPKC923 were previously granted with an expiration date of January 23, 2007.  On January 16, 2007, 
PSI filed applications to modify the licenses.1 On January 23, 2007, the licenses expired by their own 
terms.  On February 22, 2007, PSI amended the modification applications to add an attachment requesting 
that the applications be treated as applications for renewal/modification (purpose code RM), rather than 
applications only to modify the licenses (purpose code MD); it stated that it had intended to file RM 
applications, but inadvertently filed MD applications.  Commission staff then informed PSI that a MD 
application cannot be amended to request license renewal.  On February 26, 2007, PSI filed applications 
to renew the licenses and requested waivers to permit late filing of the applications.2  
3. Petitioners filed a petition to deny the renewal applications.3 Most of Petitioners’ arguments 
did not involve the instant applications; instead, Petitioners alleged that PSI’s conduct with respect to 
other licenses demonstrated that PSI lacked character and fitness to be a Commission licensee, and 
incorporated by reference arguments they raised in other proceedings involving other PSI licenses.  The 
Division declined to address these arguments, stating, “The Commission has . . . held . . . that 
‘Petitioners’ allegations regarding PSI’s character qualifications, which relate to other PSI licenses and 
are the subject of other pending proceedings, are more appropriately addressed elsewhere.’  We therefore 
will not address those arguments in this proceeding.”4 With respect to Petitioners’ argument that a waiver 
  
1 See FCC File Nos. 0002879164 (WPKC922), 0002879169 (WPKC923).  PSI proposed to delete one location from 
the license for Station WPKC922 and two locations from the license for Station WPKC923.  
2 FCC File Nos. 0002925303 (WPKC923), 0002925304 (WPKC922).
3 V2G was not a party to the petition to deny.
4 See Paging Systems, Inc, Order, 26 FCC Rcd 5913, 5915 ¶ 5  (WTB MD 2011) (Order) (footnote omitted) 
(quoting Paging Systems, Inc., Memorandum Opinion and Order, 25 FCC Rcd 450, 454 ¶ 4 (2010), aff’d, Order on 
Reconsideration, FCC 11-172 (rel. Nov. 29, 2011)).
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to permit late filing of the renewal applications was not appropriate under the circumstances presented, 
the Division concluded, based on prior decisions, that the filing of a timely but defective renewal 
application warrants a waiver to permit the late filing of a subsequent renewal application where the 
licensee acted in good faith and moved promptly to file a proper renewal application after learning that 
the original attempt fell short.5 Consequently, the renewal applications were granted.  Petitioners filed a 
petition for reconsideration.6
4. On reconsideration, Petitioners argue that PSI’s circumstances did not meet the requirements 
of Section 1.925 of the Commission’s Rules7 for a waiver, and that the Division failed to refute their 
arguments that the waiver requests should be denied.8 Petitioners also argue that all applications should 
not have been granted because PSI does not possess the character and fitness to be a Commission 
licensee.9 Specifically, Petitioners allege that PSI’s conduct with respect to other licenses demonstrates 
that PSI lacks character and fitness to be a Commission licensee, and they incorporate by reference 
arguments they raised in other proceedings involving other PSI licenses.10  
5. Stations WNGR945 and WNGM656.  PSI’s unopposed timely applications to renew the 
licenses for Stations WNGR945 and WNGM656 were granted on December 28, 2010 and January 4, 
2011, respectively.11 Petitioners filed a petition for reconsideration of the grants, and Environmentel filed 
a separate petition for reconsideration that incorporates the other petition by reference.12 Petitioners’ 
arguments do not involve the instant applications; instead, Petitioners allege that PSI’s conduct with 
respect to other licenses demonstrates that PSI lacks character and fitness to be a Commission licensee, 
and incorporate by reference arguments they raised in other proceedings involving other PSI licenses.13  
6. Discussion.  With respect to Stations WPKC922 and WPKC923, we disagree with 
  
5 See id. at 5916 ¶ 6 (citing City of Dardanelle Fire Department, Order, 17 FCC Rcd 10901, 10902 ¶ 4 (WTB 
PSPWD 2002) (citing Florida Power and Light Co., Order, 15 FCC Rcd 13607 (WTB PSPWD 2000)); KNTV 
License, Inc., Order, 16 FCC Rcd 20440, 20442-43 ¶¶ 6-7 (WTB PSPWD 2001) (citing Navopache Electric 
Cooperative, Inc., Order, 16 FCC Rcd 11870 (WTB PSPWD 2001)); City of Henderson, Nevada, Order, 14 FCC 
Rcd 16156, 16158-59 ¶ 7 (WTB PSPWD 1999)).  The Division explained that it would not rely on dicta in 
Huntsman Corporation, Order on Reconsideration, 18 FCC Rcd 3814, 3816 n.24 (WTB PSPWD PRB 2003), 
because that case – which involved a timely but defective attempt to renew – erroneously relied on WLOS Licensee, 
Inc., Order on Reconsideration, 15 FCC Rcd 11047 (WTB PSPWD 2000), where the licensee made no attempt to 
renew the license before it expired.  See Order, 26 FCC Rcd at 5915 n.15.
6 Petition for Reconsideration (filed May 16, 2011) (May PFR).  PSI filed an opposition.  Petitioners filed a reply.
7 47 C.F.R. § 1.925.
8 May PFR at 4-6.
9 Id. at 7.
10 Id. at 9-27.
11 FCC File Nos. 0004439316 (WNGR945), 0004445768 (WNMG656).  The grants appeared on public notice on 
January 5 and 12, 2011, respectively.
12 See Petition for Reconsideration, or in the Alternative Section 1.41 Request (filed Feb. 4, 2011) (February PFR); 
Petition for Reconsideration, or in the Alternative Section 1.41 Request filed by Environmentel LLC (filed Feb. 4, 
2011) (Environmentel PFR).  PSI filed a consolidated opposition.  Petitioners filed a consolidated reply.  We note 
PSI’s argument that these petitions should be dismissed pursuant to Section 1.106(b)(1) of the Commission’s Rules, 
47 C.F.R. § 1.106(b)(1), because Petitioners have not demonstrated why they could not have participated earlier 
with respect to Stations WNGR945 and WNGM656, and due to other defects.  Given the overlap between these 
petitions and the May PFR, however, we decline to address these procedural issues at this time.
13 See February PFR at 15-26; Environmentel PFR at 4-5.
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Petitioners’ argument that PSI’s circumstances fell short of the requirements for a waiver to permit late 
filing of a renewal application.  As noted above, the Division cited numerous decisions holding that the 
filing of a timely but defective renewal application warranted a waiver to permit the late filing of a 
subsequent renewal application, where the licensee acted in good faith and moved promptly to file a 
proper renewal application after learning that the original attempt fell short.14 The precedent cited by 
Petitioners in response is inapposite, for the licensees in those cases made no attempt to renew the 
licenses before they expired.15
7. With respect to Petitioners’ arguments that do not involve the instant applications, the 
Commission recently reiterated that issues regarding PSI’s character qualifications that relate to other 
licenses not the subject of the proceeding at issue are more appropriately addressed elsewhere.16  
Therefore, we will not address Petitioners’ arguments concerning PSI’s other licenses in this 
proceeding.17
8. In addition, Petitioners’ suggestion that they receive disparate treatment from the 
Commission compared to PSI is neither relevant to the instant matter nor borne out by the matter to which 
they refer.18 Finally, Petitioners’ suggestion that the undersigned official’s prior interaction with the 
parties requires his recusal from this matter19 has been rejected elsewhere20 and will not be addressed 
further herein.
9. Accordingly, IT IS ORDERED that, pursuant to Sections 4(i), 303(r), and 405 of the 
Communications Act of 1934, as amended, 47 U.S.C. §§ 154(i), 303(r), 405, and Section 1.106 of the 
Commission’s Rules, 47 C.F.R. § 1.106, the petition for reconsideration filed by Warren C. Havens, 
Environmentel LLC, Intelligent Transportation & Monitoring Wireless LLC, Verde Systems LLC, V2G 
LLC, Telesaurus Holdings GB LLC, and Skybridge Spectrum Foundation on May 16, 2011, IS DENIED.
10. IT IS FURTHER ORDERED that, pursuant to Sections 4(i), 303(r), and 405 of the 
Communications Act of 1934, as amended, 47 U.S.C. §§ 154(i), 303(r), 405, and Section 1.106 of the 
Commission’s Rules, 47 C.F.R. § 1.106, the petition for reconsideration or, in the alternative, Section 
1.41 request, filed by Warren C. Havens, Environmentel LLC, Intelligent Transportation & Monitoring 
Wireless LLC, Verde Systems LLC, V2G LLC, Telesaurus Holdings GB LLC, and Skybridge Spectrum 
Foundation on February 4, 2011, IS DENIED.
  
14 See note 5, supra. 
15 See May PFR at 4-6 (citing Derek M. Fukunaga, Letter, 26 FCC Rcd 6712 (WTB BD 2011); Roger Given, Letter, 
24 FCC Rcd 11769 (WTB BD 2009); Gene A. Smith, Order, 17 FCC Rcd 13366 (WTB CWD PRB 2002); Fresno 
City and County Housing Authorities, Order on Reconsideration, 15 FCC Rcd 10998 (WTB PSPWD 2000); 
Plumas-Sierra Rural Electric Cooperative, Order, 15 FCC Rcd 5572 (WTB PSPWD 2000)).  Other precedent cited 
by Petitioners is irrelevant because it pertains to waivers of the statutory deadline for filing petitions for 
reconsideration rather than the rules governing renewal applications.  See id. at 6-7 (citing Gardner v. FCC, 530 F.2d 
1086 (D.C. Cir. 1976)).  
16 See Paging Systems, Inc., Order on Reconsideration, FCC 11-172, ¶ 8 (rel. Nov. 29, 2011).
17 Nor do we agree with Petitioners that those allegations constitute “good cause for challenging the [instant] 
Licenses as not properly and timely constructed,” see May PFR at 13; February PFR at 22, given that Petitioners 
have provided no evidence regarding the construction or operational status of the licenses at issue.
18 See May PFR at 8 (citing then-pending litigation where the court subsequently affirmed the Commission’s 
actions:  Warren C. Havens v. FCC, Docket Nos. 02-1359, 02-1360 (D.C. Cir. May 24, 2011) (per curiam)).
19 See id. at 27.
20 See Northeast Utilities Service Co., Order, 24 FCC Rcd 3310, 3312 n.22 (WTB MD 2009), recon. pending.
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11. IT IS FURTHER ORDERED that, pursuant to Sections 4(i), 303(r), and 405 of the 
Communications Act of 1934, as amended, 47 U.S.C. §§ 154(i), 303(r), 405, and Section 1.106 of the 
Commission’s Rules, 47 C.F.R. § 1.106, the petition for reconsideration or, in the alternative, Section 
1.41 request, filed by filed by Environmentel LLC on February 4, 2011, IS DENIED.
12. These actions are taken under delegated authority pursuant to sections 0.131 and 0.331 of the 
Commission's Rules, 47 C.F.R. §§ 0.131, 0.331.
FEDERAL COMMUNICATIONS COMMISSION
Scot Stone 
Deputy Chief, Mobility Division
Wireless Telecommunications Bureau