Federal Communications Commission DA 12-1594
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Peoria County Emergency Telephone System 
Board
Request for Waiver of Section 90.209(b) of the 
Commission’s Rules
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WT Docket 99-87
ORDER
Adopted: October 12, 2012 Released: October 12, 2012
By the Deputy Chief, Policy and Licensing Division Public Safety and Homeland Security Bureau:
I. INTRODUCTION
1. The Peoria County Emergency Telephone System Board (ETSB) filed a request1 for 
waiver, until June 30, 2014, of the Commission’s VHF/UHF narrowbanding deadline, which requires 
private land mobile radio licensees in the 150-174 MHz and 450-512 MHz bands to operate using channel 
bandwidth of no more than 12.5 kHz, or equivalent efficiency, by January 1, 2013.2 By this Order, we 
grant the Waiver Request.
II. BACKGROUND
2. ETSB manages and represents the communications needs for public safety and non-
public safety users within Peoria County, Illinois.3 ETSB is seeking a waiver of the deadline on behalf of 
several county agencies that will migrate from seventy-eight VHF and UHF radio authorizations to a new 
county-wide 700 MHz/800 MHz system.4 ETSB seeks a waiver of the deadline to allow these agencies to 
avoid the expense of narrowbanding authorizations that they will decommission (and in many cases 
surrender) after they transition to the new system.5  
3. In 2006, ETSB released a Request for Proposal for a county-wide interoperable radio 
system and awarded a contract to Harris Corporation in September 2007.6 The system is funded by a 
combination of dedicated local funds and federal grants.7 ETSB anticipates the system will be ready on 
  
1 See Narrowband Deadline Waiver Request, filed January 11, 2012, by the Peoria County Emergency System 
Board (Waiver Request).  See also Implementation of Sections 309(j) and 337 of the Communications Act of 1934 as 
Amended; Promotion of Spectrum Efficient Technologies on Certain Part 90 Frequencies, Third Memorandum 
Opinion and Order and Third Further Notice of Proposed Rule Making and Order, WT Docket No. 99-87, RM-
9332, 19 FCC Rcd 25045 (2004).
2 47 C.F.R § 90.209(b).
3 Waiver Request at 3.
4 Id. at 3,8.
5 Id. at 3.
6 Id. at 4.
7 Id. at 6-7.
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August 31, 2013, and all agencies will have completed their cut-over to the new system by March 31, 
2014.8  
4. As of August 2012, ETSB has applied for 800 MHz frequencies from the relevant 
National Public Safety Planning Advisory Committee (NPSPAC) Region, completed all work associated 
with the radio transmit sites regarding surveys, soil borings and construction plans, and is nearly ready to
commence construction of new towers and shelters.9 ETSB is also in the process of evaluating 
microwave system proposals for the new system, and anticipates awarding the contract at its November 7, 
2012 Board Meeting. 10
5. On January 27, 2012, the Public Safety and Homeland Security Bureau (Bureau) issued a 
Public Notice seeking comment on the Waiver Request.11 No party filed comments in support or in 
opposition of the request.
III. DISCUSSION
6. ETSB seeks relief pursuant to Section 1.925 of the Federal Communications 
Commission’s (FCC or Commission) rules, which provides that to obtain a waiver of the Commission’s 
rules, a petitioner must demonstrate either that: (i) the underlying purpose of the rule(s) would not be 
served or would be frustrated by application to the present case, and that a grant of the waiver would be in 
the public interest;12 or (ii) in view of unique or unusual factual circumstances of the instant case, 
application of the rule(s) would be inequitable, unduly burdensome, or contrary to the public interest, or 
the applicant has no reasonable alternative.13  
7. Applying this standard to narrowbanding, we have stated in the Narrowbanding Waiver 
Guidance Notice, jointly issued by the Wireless Telecommunications Bureau, the Public Safety and 
Homeland Security Bureau, and the Office of Engineering and Technology, that narrowbanding waiver 
requests “will be subject to a high level of scrutiny” under the waiver standard.14 We have also provided 
recommended guidance on the factors that licensees should address in their requests and have 
recommended that in addressing these factors, licensees should seek to demonstrate that “(i) they have 
worked diligently and in good faith to narrowband their systems expeditiously; (ii) their specific 
circumstances warrant a temporary extension of the deadline; and (iii) the amount of time for which a 
waiver is requested is no more than is reasonably necessary to complete the narrowbanding process.”15
  
8 Id. at 5.
9 See email, dated August 9, 2012 from Dan Voiland, Peoria County Radio System Manager, to Roberto Mussenden 
(August Voiland Email).
10 See email, dated October 1, 2012 from Dan Voiland, Peoria County Radio System Manager, to Roberto 
Mussenden (October Voiland Email).
11 See Public Safety and Homeland Security Bureau Seeks Comment on Requests for Waiver of the January 1, 2013 
VHF-UHF Narrowbanding Deadline, Public Notice, DA 12-90 (PSHSB 2012).
12 47 C.F.R. § 1.925(b)(3)(i).
13 47 C.F.R. § 1.925(b)(3)(ii).
14 Wireless Telecommunications Bureau, Public Safety and Homeland Security Bureau, and Office Of Engineering 
and Technology Provide Reminder of January 1, 2013 Deadline for Transition to Narrowband Operations in the 
150-174 MHz and 421-512 MHz Bands and Guidance for Submission of Requests for Waiver and Other Matters, 
Public Notice, 26 FCC Rcd 9647 (2011) (Narrowbanding Waiver Guidance Notice).
15 Id. at 9649.
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8. Based on the record before us, we conclude that the County’s request warrants waiver 
relief because it has demonstrated that the underlying purpose of the narrowbanding deadline – to 
promote spectrum efficiency and increase available capacity – would not be served by strict application to 
the present case, and that a grant of the waiver would be in the public interest. 
9. The record shows that since 2006, ETSB has been diligently engaged in constructing a 
new radio communications system that would obviate the need for ETSB to comply with the 
narrowbanding requirements.16 In this regard, we note that ETSB is in the process of procuring twenty-
seven FCC NPSPAC, 700/800 MHz narrowband frequencies, in addition to thirteen 800 MHz channels it 
acquired earlier.17 In granting relief to ETSB, we also consider the complexity and scale of its new multi-
jurisdictional radio communications system and the unexpected delays ETSB encountered during the 
planning process.18 Notwithstanding these delays, we find encouraging ETSB’s commitment to vacate its 
use of the UHF and VHF bands within less than two years of the January 1, 2013 deadline.  As a result, 
we find that strict enforcement of the narrowbanding deadline under these circumstances would not serve 
the underlying purpose of the rule.  We also find that waiver relief is consistent with the public interest 
because it will enable the County to leverage its limited resources to complete an improved, county-wide, 
multi-agency, interoperable communications system.19
IV. CONCLUSION
10. Based on the foregoing, we conclude that grant of the waiver is in the public interest.  
Accordingly, we grant on the a waiver of the Commission’s January 1, 2013 VHF/UHF narrowbanding 
deadline for the agencies and call signs listed in Appendix A until June 30, 2014.
V. ORDERING CLAUSES
11. Accordingly, IT IS ORDERED pursuant to Section 4(i) of the Communications Act of 
1934, as amended, 47 U.S.C. § 154(i), and Section 1.925(b)(3)(i) of the Commission’s rules, 47 C.F.R. 
§ 1.925(b)(3)(i), that the Request for Waiver filed by the Peoria County Emergency Telephone System 
Board IS GRANTED.
12. 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
Zenji Nakazawa
Deputy Chief, Policy and Licensing Division
Public Safety and Homeland Security Bureau
  
16 See Waiver Request at 4.
17 Id.
18 See id. at 6-7. 
19 See Waiver Request at 6.
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Appendix A:  List of Affected Call Signs
KSD224 Limestone Township Fire Protection District
WNZX975 Limestone Township Fire Protection District
KF2549 West Peoria Fire Protection District
KNBD811 West Peoria Fire Protection District
KNBD911 West Peoria Fire Protection District
KSE413 West Peoria Fire Protection District
WPKH458 Timber Hollis Fire Protection District
KGW779 Elmwood Fire Department Inc.
KMB642 Greater Peoria Airport Authority
KUN861 Greater Peoria Airport Authority
WNGT256 Greater Peoria Airport Authority
KA87841 Peoria, County of Sheriffs Dept
KNNS796 Peoria, County of Sheriffs Dept
KSH226 Peoria, County of Sheriffs Dept
KCJ417 Peoria, City of
KEL390 Peoria, City of
KNAT718 Peoria, City of
KSA946 Peoria, City of
KTE551 Peoria, City of
KZP220 Peoria, City of
KZZ351 Peoria, City of
WXL707 Peoria, City of
WXL708 Peoria, City of
KD49135 Elmwood, City of
KVM479 Elmwood, City of
KSB568 Chillicothe, City of
WPVP778 Chillicothe, City of
KNFL520 Limestone, Township of
WPCI769 Ambulance Rescue 33 LTD
WQAC661 Ambulance Rescue 33 LTD
KNBB289 Logan Trivoli Fire Protection District
KNBM215 Logan Trivoli Fire Protection District
KSE428 Logan Trivoli Fire Protection District
KAZ687 Akron Princeville Ambulance Inc
KSE279 Akron Princeville Fire Protection District
KNFZ525 Chillicothe, City of
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WPDI624 Chillicothe Sanitary District
KNFS610 OSF Saint Francis Medical Center 
KRG841 OSF Saint Francis Medical Center 
WPEY891 OSF Saint Francis Medical Center 
WPUD413 OSF Saint Francis Medical Center 
WPXK935 OSF Saint Francis Medical Center 
WPYG591 OSF Saint Francis Medical Center 
WQEN997 OSF Saint Francis Medical Center 
KNFF287 Bradley University 
KA76306 B Y E Ambulance Service
KYR211 Tuscarora Fire Protection District
WPDA313 Tuscarora Fire Protection District
KFV554 Dunlap Fire Protection District
KNBC439 Dunlap Community Fire Protection Dist
KAJ202 Dunlap Rescue Squad
KJU336 Peoria Heights, Village of
KNFM242 Peoria Heights, Village of
WNDS205 Peoria Heights, Village of
WQKN408 Peoria Heights, Village of
KNBC440 Dunlap, Village of
KSO416 Dunlap, Village of
WPEC819 Dunlap, Village of
KNBW723 Bartonville, Village of
KNBY462 Bartonville, Village of
KNGD359 Bartonville Volunteer Fire Dept
WPHI870 Bartonville, Village of
WPKF842 Bartonville, Village of
WPDU357 Greater Peoria Sanitary and Sewage Disposal District
KTH434 Peoria, County of  
WPCH274 Akron Princeville Fire Protection District
KZV871 Chillicothe, Township of
KSE293 Timber Hollis Fire Protection District
KNBH431 Peoria, County of
KSD295 Peoria, County of
WPEC820 Peoria, County of
WNWL489 Proctor Hospital 
WQEK224 Proctor Hospital 
KSE880 Brimfield Community Fire Protection District
KNDJ429 Peoria, City of
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WPMG684 OSF Healthcare System
WPWY525 OSF Healthcare System
WQLR520 Peoria Police Department
WQNG453 Trivoli Township