Federal Communications Commission DA 14-121
1
Before the
Federal Communications Commission
Washington, D.C. 20554
In the matter of
WARREN C. HAVENS
SKYBRIDGE SPECTRUM FOUNDATION
VERDE SYSTEMS, LLC 
And its predecessor in interest, TELESAURUS 
VPC, LLC
Applications for Waiver and/or Extension of the 
Five and Ten Year Construction Deadlines
Applications for Renewal of 220 MHz Licenses
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    See Attachment A for Calls Signs and 
Associated FCC File Nos.
     
Order on Reconsideration
   Adopted: February 3, 2014 Released:  February 3, 2014
By the Deputy Chief, Mobility Division, Wireless Telecommunications Bureau:
I. INTRODUCTION
1. For the reasons set forth below, we deny the Petition for Reconsideration filed by Warren C. 
Havens (“Warren Havens”), Telesaurus VPC, LLC (“Telesaurus”), Verde Systems, LLC (“Verde”), and 
Skybridge Spectrum Foundation (“Skybridge”)
1
of the Mobility Division’s (“Division”) May 31, 2012 
Order
2
terminating 394 licenses held by the Petitioners.
3
  Petitioners assert that the Division erred by: (1) 
                                                          
1
We note for the record that Warren Havens is the president of Verde, Telesaurus, and Skybridge and is a signatory 
to all of the applications addressed in this order.  Where appropriate, we refer to filings, arguments, and assertions 
made by Warren Havens and his companies jointly as having been made by “Havens,” “Petitioners,” or 
“Applicants.”  When referring to Warren Havens individually, we refer to him as “Warren Havens.”
2
See Warren C. Havens, Skybridge Spectrum Foundation, Verde Systems, LLC and its predecessor in interest, 
Telesaurus VPC, LLC, Applications for Waiver and/or Extension of the Five and Ten Year Construction Deadlines,
Applications for Renewal of 220 MHz Licenses, Order, 27 FCC Rcd 5841 (2012) (“Havens 220 MHz Termination 
Order”).
3
See Attachment A for a complete list of the 394 licenses, their associated call signs, the FCC file numbers of their 
associated applications, and their associated construction and renewal deadlines.  Skybridge was the licensee for call 
signs WQHZ577-773 (“Skybridge Licenses”).  Warren Havens was the licensee for call signs WPOI514-622, 
WPOI843, WPOJ290-306, WPOK862-869, WPOK871-889, WPOK893-900, and WPOK933.  Verde was the 
licensee for call signs WPOK890-892 and WPOK901-926, and WPOK928-932 (these licenses were assigned from 
Telesaurus to Verde).  Since, at different points in time with respect to the issues addressed in this order, Warren 
Havens filed jointly with Verde and Telesaurus, and Warren Havens is the president of both companies, we refer to 
the licenses most recently held by Warren Havens and Verde (previously, Telesaurus) collectively as the “Havens 
Licenses” except where reference to specific licenses or their respective licensees is necessary.
Federal Communications Commission DA 14-121
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denying the renewal applications for the Skybridge Licenses; (2) denying the extension requests for the 
Havens Licenses; and (3) denying the Applicants’ request for a fee waiver.
4
  Petitioners also request 
permission to submit evidence of additional “due diligence” pertinent to their extension and renewal 
requests.
5
  We hereby deny Havens’ requests in full and reaffirm the Division’s findings set forth in the
Havens 220 MHz Termination Order.
II. BACKGROUND
2. The Havens Licenses were originally granted in 1999 as part of Auction 24.
6
  Pursuant to 
Section 90.767 of the Commission’s rules, an Economic Area (“EA”) or Regional Economic Area 
Grouping (“REAG”) 220 MHz licensee must construct a sufficient number of base stations for land mobile 
and/or paging operations to “provide coverage to at least one-third of the population of its EA or REAG 
within five years of the issuance of its initial license and at least two-thirds of the population of its EA or 
REAG within ten years of the issuance of its initial license.”
7
  Alternately, licensees may provide 
substantial service to their licensed area at the appropriate five-year and ten-year benchmarks.
8
  Further, 
pursuant to Section 1.946(c), “[i]f a licensee fails to commence service or operations by the expiration of 
its construction period or to meet its coverage or substantial service obligations by the expiration of its 
coverage period, its authorization terminates automatically, without specific Commission action, on the 
date the construction or coverage period expires.”
9
3. On January 12, 2004, Warren Havens filed requests for extension or removal of the five-year 
construction deadline set forth in Section 90.767(a) of the Commission’s rules
10
for his 220 MHz 
licenses.
11
  Warren Havens argued, in part, that extension or waiver of the construction requirement was 
justified due to a lack of appropriate equipment available for use in the 220 MHz band.
12
  In response, on 
July 13, 2004, the Wireless Telecommunications Bureau (“Bureau”) released a Memorandum Opinion and 
Order extending the five-year construction deadlines to November 5, 2007 for all Phase II
13
EA and 
REAG 220 MHz licenses that had filed requests for extension or whose first construction deadline fell 
                                                          
4
See Warren Havens, Skybridge Spectrum Foundation, and Verde Systems, LLC, Petition for Reconsideration of 
May 31, 2012 Order and Request to Permit Submission of Further Due Diligence Facts (July 2, 2012) (“Havens 
Petition for Reconsideration”).
5
See Havens Petition for Reconsideration at 22-23.
6
See Phase II 220 MHz Spectrum Auction Closes, Public Notice, 14 FCC Rcd 11218 (July 1999).  Some of the 
subject licenses were acquired by Havens in secondary market transactions after the close of Auction 24.
7
47 C.F.R. § 90.767(a).  For consistency, we refer to this as the “construction requirement” or “construction 
deadline.”
8
Id.
9
47 C.F.R. § 1.946(c).
10
47 C.F.R. § 90.767(a).
11
See Warren Havens, Petition to Waive or Extend the Five-Year Construction Requirement: Partial Waiver of 
Section 90.767, with requests to apply to other Regional and EA Licenses (Jan. 12, 2004) (“2004 Extension 
Request”).
12
2004 Extension Request at 7-17.
13
See Amendment of Part 90 of the Commission’s Rules to Provide for the Use of the 220-222 MHz Band by the 
Private Land Mobile Radio Service, Third Report and Order, 12 FCC Rcd 10943 (1997) (“Third Report and 
Order”) (Establishing rules to govern the operation and licensing of the 220 MHz band, including the Phase II 
licenses.)
Federal Communications Commission DA 14-121
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after the date of the order.
14
  The Bureau found that the public interest would be served by granting these 
220 MHz licensees, including Warren Havens, this extension and that an additional three years would be 
sufficient time for the licensees to construct their systems using available or soon to be released 
equipment.
15
4. On October 24, 2007, Warren Havens submitted applications to disaggregate a large portion of 
the spectrum in each of his 220 MHz licenses and assign it to Skybridge.
16
  Telesaurus filed similar 
applications on November 1, 2007.
17
  For each of the subject licenses, Warren Havens and Telesaurus 
maintained only a fraction of the original licensed spectrum.
18
  In addition, for each of the licenses, save 
for call sign WQHZ610, Warren Havens and Telesaurus indicated that the assignor would be responsible 
for meeting the construction deadlines set forth in Section 90.767 of the Commission’s rules.
19
  For call 
sign WQHZ610, Warren Havens indicated that the assignor and assignee would be jointly responsible for 
meeting the build-out deadlines.
20
  Warren Havens subsequently claimed that the difference in the 
WQHZ610 application was an administrative error and asked the Bureau to modify the application for to 
render it consistent with the applications for the other call signs.
21
5. On November 4, 2007, Warren Havens and Telesaurus applied for waiver or further extension 
of the five-year construction deadline for their Licenses pursuant to Section 1.946(e) of the Commission’s 
rules.
22
  Warren Havens and Telesaurus advanced several arguments in favor of their extension request, 
including that: (1) there was a continuing lack of 5 kHz trunked equipment for the 220 MHz band, 
hampering build-out capabilities; (2) that they had conducted extensive due diligence with respect to the 
use of Terrestrial Trunked Radio (“TETRA”), Digital Mobile Radio (“DMR”), and other Intelligent 
Transportation Systems (“ITS”) for use in the 220 MHz band; (3) that the use of the Licenses for ITS in 
conjunction with 900 MHz LMS licenses held by Havens-affiliated entities constituted the best use of the 
spectrum; (4) that Warren Havens had acquired several of his Licenses in a bankruptcy proceeding that had 
not concluded until 2007; and (5) that the disaggregation of spectrum to Skybridge
23
constituted a donation 
for public interest uses.
24
  In addition, Warren Havens and Telesaurus requested that they each be granted a 
consolidated license for their 220 MHz holdings and that some or all of the fees associated with the 
                                                          
14
See Warren C. Havens, Bizcom USA, and Cornerstone SMR, Memorandum Opinion and Order, 19 FCC Rcd 
12994 ¶ 19 (WTB-2004) (“220 MHz Extension Order”).
15
Id. at ¶ 20.
16
See FCC File No. 0003208764 disaggregating and assigning spectrum from call signs WPOI514-622, WPOI843, 
WPOJ290-306, WPOK862-864, WPOK866-869, WPOK871-877, WPOK879-889, and WPOK893-900, and 
WQHZ610; FCC File No. 0003218561 disaggregating and assigning call sign WPOK933; and FCC File 
No.0003210896 disaggregating and assigning call signs WPOK865 and WPOK878.
17
See FCC File No. 0003218990 disaggregating and assigning spectrum from call signs WPOK891-892,   
WPOK901-908, WPOK910-925, and WPOK928-932; and FCC File No.0003218951 disaggregating and assigning 
spectrum from call signs WPOK890, WPOK909, and WPOK926.  The applications in notes 16 and 17 are 
collectively referred to as the “Havens Disaggregation Applications.”
18
This varies from license to license but, in many cases, the original licensee retained 20 percent or less of the 
spectrum in each license area.
19
See Havens Disaggregation Applications, Schedule B.
20
See FCC File No. 0003208764 .
21
See WQHZ610 Petition at 1.
22
See 47 C.F.R. § 1.946(e); Warren Havens and Telesaurus VPC LLC, Petition to Waive or Extend the Five-Year 
Construction Requirement (filed November 4, 2007) (“2007 Extension Request”).
23
See supra, paragraph 4.
24
2007 Extension Request at 5-9.
Federal Communications Commission DA 14-121
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Applications be waived.
25
  Warren Havens and Telesaurus also argued that the Applications met the 
extension standards set forth in Section 1.946(e)(1) of the Commission’s rules
26
and the waiver standard set 
forth in Section 1.925 of the Commission’s rules.
27
  However, they did not specifically plead the requisite 
elements of the waiver standard.
28
  On June 27, 2008, Warren Havens and Telesaurus filed a supplement to 
the 2007 Extension Request that purported to show the applicants’ due diligence in seeking to obtain 
TETRA technology for use with their Licenses.
29
6. On March 23, 2009, Warren Havens filed renewal applications for his Licenses.
30
  In these 
Renewal Applications, Warren Havens argued that he and his companies engaged in substantial due 
diligence to research and develop ITS technology and services for use in the 220 MHz band.
31
  He also 
claimed that, “[h]ad the FCC ruled on the 2007 Extension Request, and it was granted, then [he] could 
have proceeded with the needed further development of technology and equipment to construct the 
licenses…and constructed today or, at minimum would have been much further along in completing due 
diligence to obtain the advanced 220 MHz technology and equipment for the nationwide ITS wireless plan 
for which the Licenses are dedicated…”
32
  He asserted that these showings, along with those set forth in 
the 2007 Extension Request and the March 2009 Amended Extension Request, were sufficient to satisfy 
the renewal and renewal expectancy requirements in Section 90.743
33
of the Commission’s Rules.
34
7. On the same day, Warren Havens also filed an amendment to his 2007 Extension Request.
35
  
In this Amended Extension Request, Warren Havens requested an extension of both the five and ten-year 
construction deadlines for his Licenses until March 23, 2015.
36
  Warren Havens again claimed that he had
conducted substantial due diligence to obtain advanced wireless technology to put the 220 MHz spectrum 
to its highest and best use.
37
  He also reiterated, and incorporated the arguments and assertions from his 
prior filings.
38
                                                          
25
Id. at 9-10.
26
47 C.F.R. § 1.946(e)(1).
27
See 47 C.F.R. § 1.925; 2007 Extension Request at 4 and 9.
28
Id. at 9 (The section titled “Section 1.946(e)(1) and Waiver Standards Met” states only that “[t]his is evident from 
the substance of this request”).
29
See Warren Havens and Telesaurus VPC, Supplement to Pending 220-222 MHz Extension Requests (filed June 
27, 2008) (“June 2008 Supplement”).
30
See Warren Havens, 220 MHz Licenses: Renewal Applications (filed March 23, 2009) (“Havens March 2009 
Renewal Applications”).
31
Id. at 2-4 and Attachments 1-3.
32
Id. at 1.
33
47 C.F.R. § 90.743; see infra, Section III(C).
34
See Havens March 2009 Renewal Applications at 4.
35
See Warren C. Havens Regional and EA Licenses, Amendment of Pending 2007 Petition to Waive or Extend the 
Five-Year Construction Requirement and the Ten-Year Construction Requirement (filed March 23, 2009) (“March 
2009 Amended Extension Request”).
36
Id. at 2.
37
Id. at 4.
38
Id. at 2-3.
Federal Communications Commission DA 14-121
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8. On March 23, 2009, Skybridge also filed renewal applications for several of its Licenses.
39
  
Skybridge claimed that, pursuant to the earlier disaggregation and assignment action, its licenses do not 
include construction requirements.
40
  As a result, according to Skybridge, it “has no substantial service 
obligation, and thus has no substantial service showing to make.”
41
  Skybridge asserted that it “is using all 
of the subject Licenses in active research and development, and thereafter deployment, of advanced 
wireless for the nation’s Intelligent Transportation Systems (‘ITS’) and associated smart critical 
infrastructure and environment-resource monitoring and protection….”
42
  However, Skybridge did not 
claim to have built any facilities or provide any actual service in its license areas.  Skybridge also 
referenced the Havens March 2009 Renewal Applications in support of its claims.
43
  Skybridge filed a 
similar renewal application for its remaining licenses on October 6, 2009, which referenced and 
incorporated the Skybridge March 2009 Renewal Applications and provided additional information 
regarding its plans to provide ITS, and specifically Network-RTK (“N-RTK”), services over its 220 MHz 
spectrum.
44
9. On October 7, 2009, Warren Havens and Verde filed a joint application to: (1) renew all of the 
Havens and Verde Licenses that were not included in the Havens March 2009 Renewal Applications; (2) 
amend and supplement the 2007 Extension Request for those Licenses that were not included in the 
Havens March 2009 Extension Request; and (3) obtain waivers of the fees associated with the renewal and 
extension filings.
45
  This Application restated and incorporated many of the renewal and extension 
showings made in the prior filings of Warren Havens, Verde, and Skybridge.
46
  In addition, Warren 
Havens and Verde argued that they had “demonstrated important research and developments to put the 
spectrum to the highest and best use… with a focus… in support of N-RTK which is one of the most 
important new forms of wireless for the nation.”
47
  They also claimed that the Applications meet the 
waiver standard set forth in Section 1.925 of the Commission’s rules
48
because: (1) the future use of the 
licenses will be the highest and best use; (2) the licenses would be used by a nonprofit corporation that is 
legally required to use the licenses in direct support of government agency needs and other public interest 
purposes; (3) until recently, no commercially viable equipment was available for the subject spectrum and 
the equipment available now will require modification into N-RTK GNSS receivers; and (4) application of 
the construction deadline will frustrate the purpose of the rule.
49
Warren Havens and Verde argued that 
                                                          
39
See Skybridge Spectrum Foundation, 220 MHz Licenses: Renewal Applications (filed March 23, 2009) 
(“Skybridge March 2009 Renewal Applications”).
40
Id. at 1.
41
Id. at 1.
42
Id. at 1.
43
Id. at 2.
44
See Skybridge Spectrum Foundation, 220 MHz Licenses: Renewal Applications (filed October 6, 2009) 
(“Skybridge October 2009 Renewal Applications”) (See Attachment A for associated FCC file numbers).  Except 
where reference to a specific application is necessary, we refer to the Skybridge March 2009 Renewal Applications 
and the Skybridge October 2009 Renewal Applications collectively as the “Skybridge Renewal Applications.”
45
See Warren C. Havens and Verde Systems LLC, Fee Waiver and Refund Request, Amendment to Pending 
Extension Request Due to Lack of FCC Decision On It, Request for One “Ten Year” Construction Deadline of 
October 7, 2015, and Supportive Showing for Amended Extension Request, Renewal Expectancy Showing for 
Renewal Applications for all the Subject Licenses (filed October 7, 2009) (“Havens/Verde Extension and Renewal 
Applications”).
46
Id.
47
Id. at 8.
48
47 C.F.R. § 1.925.
49
Id.
Federal Communications Commission DA 14-121
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even though they have requested several construction deadline extensions, the amended Applications 
should be granted for “entirely clear public interest reasons” in that the spectrum at issue “will, at last, be 
put to an excellent purpose – one that did not exist until recently.”
50
  However, Warren Havens and Verde 
did not claim that they were providing service, substantial or otherwise, within their respective license 
areas.  On September 23, 2010, Warren Havens, Verde, and Skybridge filed a further supplement to their 
Extension and Renewal Applications to “demonstrate major additional due diligence and otherwise to 
support the previous requests for either extension or renewal as clearly in the public interest to grant.”
51
  
10. On November 6, 2009, Maritime filed Petitions to Deny the Havens/Verde Extension and 
Renewal Applications, the Skybridge October 2009 Renewal Applications, and the associated request for a 
fee waiver.
52
  Maritime asserted that these Applications are procedurally defective and were filed 
improperly.  Further, Maritime argued that Commission precedent compels denial of the applications and 
that Skybridge had not made its case for renewal.
53
  Maritime also questioned Warren Havens’ candor 
based on his actions in other dockets.
54
  
11. On November 19, 2009, Warren Havens, Verde, and Skybridge filed an Opposition to 
Maritime’s Petition to Deny.
55
  Havens argued that Maritime: (1) lacked standing to bring its Petition to 
Deny; (2) that the Petition to Deny was an impermissible “strike petition”; (3) and that the Petition 
contains numerous other procedural defects.
56
  Havens also countered Maritime’s arguments regarding the 
validity of the Havens/Verde Extension and Renewal Requests.
57
  Maritime filed a Reply to the Opposition 
on November 25, 2009.
58
12. On January 16, 2010, Warren Havens, Verde, and Skybridge submitted a supplement to the 
Applications and the Opposition.
59
  In the Supplement, the Applicants again asserted that N-RTK is the 
highest and best use of the subject spectrum and presented evidence of their ongoing diligence to obtain 
                                                          
50
Id. at 9.
51
See Warren Havens, Verde Systems LLC, and Skybridge Spectrum Foundation, Supplement to Extension and 
Renewal Applications (filed September 23, 2010) (“September 2010 Supplement”).
52
See Maritime Communications/Land Mobile LLC, Petition to Deny (filed November 6, 2009) (“Maritime Petition 
to Deny”); Maritime Communications/Land Mobile LLC, Petition to Deny Fee Waiver Request (filed November 6, 
2009) (“Maritime Petition to Deny Fee Waiver”). All filings related to the Maritime Petition to Deny and 
subsequent replies, oppositions, supplements and other related filings apply to FCC file numbers: 0003990344-379, 
0003989107-176, 0003990398-431, 0003223118-153, and 0003223081-114.  See Attachment A for associated call 
signs.
53
See Maritime Petition to Deny at 2-11.
54
Id. at 11-14.
55
See Warren Havens, Verde Systems, LLC, and Skybridge Spectrum Foundation, Opposition to Maritime Petition 
to Deny (filed November 19, 2009) (“Opposition to Maritime Petition to Deny”).  All citations are to the errata 
version of the Opposition, which was filed on November 20, 2009.
56
Id. 
57
Id. 
58
See Maritime Communications/Land Mobile LLC, Reply to Opposition to Petition to Deny (filed November 25, 
2009) (“Maritime Reply”).
59
See Warren Havens, Verde Systems, LLC, and Skybridge Spectrum Foundation, Supplement to Applications and 
Opposition to Petition to Deny (filed January 16, 2010) (“Havens January 2010 Supplement); Warren Havens, 
Verde Systems, LLC, and Skybridge Spectrum Foundation, Request to Accept Supplement to Applications and 
Opposition to Petition to Deny (filed January 16, 2010) (“Havens Request to Accept January 2010 Supplement”).
Federal Communications Commission DA 14-121
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the requisite technology and approvals to deploy N-RTK across the Havens and Skybridge Licenses.
60
  On 
January 28, 2010, Maritime filed Oppositions to the January 2010 Supplement and the Request to Accept 
the January 2010 Supplement.
61
  Subsequently, on October 5, 2010, Maritime filed a Petition to Deny the 
Amended Applications, contending that the amendments “provided no information even to suggest that he 
[Havens] had constructed any facility during the ten years that he held the licenses…”
62
  Warren Havens, 
Verde, and Skybridge filed an Opposition to this Petition to Deny on October 20, 2010
63
and Maritime 
submitted a Reply on November 1, 2010.
64
13. On May 31, 2012, the Division released an Order granting Warren Havens’ petition for 
reconsideration of the pending termination status of call sign WQHZ610 and denying: (1) the Extension 
and Renewal Applications filed by Warren Havens, Verde, and Skybridge for all of the 220 MHz Licenses, 
including WQHZ610; (2) the requests for waivers of filing fees associated with the subject applications; 
and (3) the requests for consolidation of the subject licenses under a single call sign for each licensee.
65
  
The Division also dismissed as moot the Petitions to Deny filed by Maritime as well as all subsequent 
responsive filings by Maritime or Havens.
66
14. On July 2, 2012, Warren Havens, Verde, and Skybridge filed a Petition for Reconsideration of 
the Havens 220 MHz Termination Order along with an appendix containing seventeen supporting 
exhibits.
67
  The Petitioners assert that the Division erred by: (1) denying the renewal applications for the 
Skybridge Licenses; (2) denying the extension requests for the Havens Licenses; and (3) denying the 
Applicants’ request for a fee waiver.
68
  The Petitioners also submit purportedly new evidence supporting 
the earlier extension requests.
69
15. On July 16, 2012, Maritime filed an Opposition to Havens’ Petition for Reconsideration.
70
  
Maritime asserts that the Havens Petition for Reconsideration should be dismissed because: (1) it exceeds 
the maximum page limit for petitions for reconsideration set forth in Section 1.106(f) of the Commission’s 
rules;
71
(2) Petitioners made a voluntary business decision not to provide service in any of its license areas; 
                                                          
60
Id. at 5-7.
61
See Maritime Communications/Land Mobile LLC, Opposition to Request to Accept Supplement to Applications 
and Opposition to Petition to Deny (filed January 28, 2010) (“Maritime Opposition to Havens Request to Accept 
Supplement”); Maritime Communications/Land Mobile LLC, Opposition to Supplement to Applications and 
Opposition to Petition to Deny (filed January 28, 2010) (“Maritime Opposition to Havens January 2010 
Supplement”).
62
See Maritime Communications/Land Mobile LLC, Petition to Deny Amended Application (filed October 5, 2010) 
(erratum filed October 7, 2010) (“Maritime Petition to Deny Amended Applications”).
63
See Warren Havens, Verde Systems, LLC, and Skybridge Spectrum Foundation, Opposition to Petition to Deny 
Amended Applications (filed October 20, 2010) (“Havens Opposition to Petition to Deny Amended Applications”).
64
See Maritime Communications/Land Mobile LLC, Reply to Opposition to Petition to Deny Amended Application
(filed October 5, 2010) (“Maritime Reply to Opposition to Petition to Deny Amended Applications”).  
65
See Havens 220 MHz Termination Order.  The reasoning and support for these actions is outlined in the 
discussion below addressing Havens’ Petition for Reconsideration, infra ¶¶ 21-40.  
66
See Havens 220 MHz Termination Order at ¶ 32.
67
See Havens Petition for Reconsideration.
68
See Havens Petition for Reconsideration.
69
See Havens Petition for Reconsideration at 22-25.
70
See Maritime Communications/Land Mobile, LLC – Debtor in Possession, Opposition (filed July 16, 2012) 
(“Maritime Opposition”).
71
47 C.F.R. § 1.106(f).
Federal Communications Commission DA 14-121
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and (3) that Havens fails to demonstrate that his claims are consistent with the precedents cited in the 
Petition for Reconsideration.
72
16. On July 27, 2012, Havens filed a Motion to Strike, Motion for Sanctions, and Reply to 
Maritime’s Opposition.
73
  Petitioners assert that Maritime’s Opposition should be stricken from the record 
as an unauthorized individual filing by Dennis Brown who is not authorized to represent Maritime 
Communications/Land Mobile LLC – Debtor in Possession (“Maritime DIP”).
74
  According to Havens, 
Mr. Brown had not been approved as counsel by the Mississippi Bankruptcy Court at the time the 
Opposition was filed and, as such, could not represent Maritime DIP before the Commission.
75
  Havens 
argues that Dennis Brown should be sanctioned as a result.
76
  Havens also asserts that the Opposition did 
not cover all of the Havens Licenses and only mentions Verde and Warren Havens and, as such, should be 
dismissed as to those licenses and applications it did not specifically reference.
77
  Havens also challenged 
Maritime’s substantive claims and took the opportunity to submit additional evidence of continuing “due 
diligence” in developing the Havens Licenses.
78
  Maritime filed an opposition to the motion to strike and 
request for sanctions on August 3, 2012.
79
III. DISCUSSION
17. After careful review of the record, including the arguments presented by the Petitioners and 
Maritime, we hereby deny the relief requested in the Petition for Reconsideration and reaffirm the findings
in the Havens 220 MHz Termination Order.  We also deny the Petitioners’ request to submit additional 
“due diligence” in support of their claims.  Finally, we dismiss the Maritime Opposition, Havens July 2012 
Reply, and Maritime Opposition to Motion to Strike as moot.
A. Procedural Issues
1. Filing Requirements
18. The Petition for Reconsideration consists of 26 main body pages and over 250 pages of 
appendices and exhibits.  Section 1.106 (f) of the Commission’s rules states, in relevant part that “[t]he 
petition for reconsideration shall not exceed 25 double spaced typewritten pages.”
80
  Havens asserts that, 
when considering the Petition without the table of contents or summary, as permitted under section 1.49 of 
the Commission’s Rules, the Petition is under 25 pages and that the requirements of section 1.49 do not 
apply to electronic filings.
81
  While we agree with Havens that the main body of his Petition complies with 
                                                          
72
See Maritime Opposition.
73
See Warren  C. Havens, Verde Systems, LLC, and Skybridge Spectrum Foundation, Motion to Strike, Motion for 
Sanctions & Reply to Opposition to Petition for Reconsideration of May 31, 2012 Order (filed July 27, 2012) 
(“Havens July 2012 Reply”).  All references to the Havens July 2012 Reply refer to the revised version of that filing 
which was filed on August 1, 2012.
74
Id. at 1-2.
75
Id.
76
Id. at 3.
77
Id. at 3-4.
78
Id. at 8-10 and Exhibit 1.
79
Maritime Communications/Land Mobile, LLC – Debtor in Possession, Opposition to Motion (filed August 3, 
2012) (“Maritime Opposition to Motion to Strike”).
80
47 C.F.R. § 1.106 (f).
81
See Havens July 2012 Reply at 2.
Federal Communications Commission DA 14-121
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the requirements of section 1.106, we do not agree that our filing rules do not apply to electronic filings.
82
  
Moreover, the exhibits filed by Havens, which contain substantive arguments and commentary from the 
Petitioners,
83
far exceed the limits set forth in section 1.106.
84
  Indeed, the Petition for Reconsideration 
contains exhibits and appendices totaling over 250 pages.
85
  
19. Page limits serve the important function of requiring parties to write concise pleadings that 
focus on the important issues raised in the pleading,
86
which allows both the decision-maker and opposing 
parties to focus on the key issues in a case.  The Petitioners’ filing greatly exceeds the page limits set forth 
in section 1.106 and represents a flagrant violation of the Commission’s rules.  Moreover, the Petitioners 
did not seek a waiver to exceed the Commission’s clearly delineated page limits nor do we see a 
compelling reason to allow them to do so.  Therefore, we find that the totality of the Petition for 
Reconsideration exceeds the maximum filing length set forth in the rules and, as such, the exhibits and 
appendices attached thereto shall be stricken.  
2. Request to submit additional materials
20. Havens requests permission to supplement the 2007 Extension Requests to demonstrate 
“further due diligence.”
87
  Havens claims that these supplemental filings will include “facts, easily verified 
in public records, and supported by experts, that support the subject Applications and reversal of the 
Order.”
88
  However, Havens does not claim that this supplemental information includes evidence that any 
of the licensees have constructed any facilities within their license areas or provided service to any 
customer.  Nor do the Petitioners claim this information would directly contradict our finding that the 
failure to construct was due to a voluntary business decision.  A review of the record attached to the 
subject licensees reflects that from 2007 and 2010 Havens has submitted hundreds of pages of
documentation in support of the purported due diligence efforts of the Petitioners which we have 
thoroughly examined.
89
  Nevertheless, these filings were insufficient to support extension, waiver, or 
                                                          
82
See 47 C.F.R. § 1.49 (f) (3) (“For purposes of paragraph (b) and (c) of this section, and any prescribed pleading 
lengths, the length of any document filed in electronic form shall be equal to the length of the document if printed 
out and formatted according to the specifications of paragraph (a) of this section, or shall be no more than 250 words 
per page.”). As a frequent participant in Commission proceedings, Mr. Havens should be aware of this rule.  Indeed, 
the Commission recently rejected an Application for Review filed electronically by Mr. Havens and Skybridge for 
failure to comply with applicable page limit requirements. See In the Matter of Skybridge Spectrum Foundation and 
Warren Havens On Request for Inspection of Records, Memorandum Opinion and Order, FOIA Control Nos. 2013-
021 and 2013-022, FCC 13-120 (rel. September 17, 2013).
83
See Havens Petition for Reconsideration at 8 (“Petitioners include Appendix 1, attached hereto, that lists and 
describes 17 exhibits.  The exhibits contain certain notations: all of the margin notes added, and highlights added, in 
the exhibits are referenced and incorporated into the text of the Petition.”)
84
See 47 C.F.R. § 1.106 (f).
85
See Havens Petition for Reconsideration at Appendix 1 and exhibits 1-17.
86
See Fleming v. County of Kane, 855 F.2d 496, 497 (7th Cir. 1988) (page limitations encourage litigants to hone 
their arguments and to eliminate excessive verbiage); Snyder v. HSBC Bank, USA, N.A., 913 F. Supp.2d 755 (D. 
Ariz. 2012) (judicial economy and concise argument are purposes of the page limit); Burger v. Kuimelis, 325 F. 
Supp.2d 1026, 1031 (N.D. Cal. 2004) (the page limit forces moving parties to focus their discussion on the most 
important issues).
87
See Havens Petition for Reconsideration at 23.
88
Id.
89
See supra ¶¶ 4-12.
Federal Communications Commission DA 14-121
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renewal of any of the Havens Licenses.
90
  Additional, similar information would not alter our analysis.  
Therefore, we deny Petitioners’ request for permission to submit additional evidence into the record.  To 
the extent that such additional evidence was submitted as an exhibit to the Havens July 2012 Reply, it is 
stricken as well.
91
B. Skybridge Renewals
21. In the Havens 220 MHz Termination Order, we denied the Skybridge Renewal Applications 
on the grounds that they had not met the substantial service requirement to warrant renewal, as set forth in 
section 90.743 of the Commission’s rules.
92
  Havens argues that, since Skybridge acquired the Skybridge 
Licenses via disaggregation and assignment from Verde and Warren Havens, and the construction 
obligations remained with the original licenses,
93
Skybridge should not have been required to meet a 
substantial service requirement to renew its licenses.
94
  Specifically, Havens argues that “service and 
network construction are inexorably linked” and that, by requiring Skybridge to provide substantial service 
upon renewal, the Division effectively imposed a construction requirement on Skybridge where none 
existed.
95
  Havens asserts that the Division’s decision: (1) is inconsistent with the letter and purpose of the 
Commission’s rules; (2) constituted the unlawful adoption of a substantive rule; and (3) constituted an 
unlawful ruling on a “novel question of law and fact.”
96
  We find these arguments unconvincing and deny 
the Petitioners’ request to reinstate the Skybridge Licenses.
22. As an initial matter, the Petitioners’ arguments misrepresent the Commission’s rules and 
established precedent on this issue.  As we stated in the Havens 220 MHz Termination Order, the 
Commission made it clear in establishing the partitioning and disaggregation rules for the 220 MHz 
service that the parties could choose which licensee or licensees would have responsibility for meeting the 
construction requirements for the post-partition/disaggregation licenses.
97
  This flexibility is limited to 
construction requirements and does not extend to renewal requirements.
98
  Indeed, the Commission noted 
that “if one party (generally the original licensee) certifies that it will meet all future construction 
requirements, the other party need only demonstrate that it is providing ‘substantial service’ for its 
remaining license.”
99
  Petitioners do not cite Commission precedents or provide any evidence that support 
their conclusory assertion that enforcing the explicit renewal requirements set forth in section 90.743 of the 
Commission’s rules is somehow unlawful or improper.
                                                          
90
See e.g. June 2008 Supplement, Havens 2009 Renewal Applications, March 2009 Amended Extension Request, 
and Skybridge Renewal Applications.
91
See Havens July 2012 Reply at 9-10 and Attachments.
92
See Havens 220 MHz Termination Order at ¶¶ 26-29; 47 C.F.R. § 90.743 (a)(1).
93
The exception being WQHZ610, which was inadvertently assigned to Skybridge with a joint construction 
requirement.  See Havens Disaggregation Applications and WQHZ Petition.  In the Havens 220 MHz Termination 
Order, we granted the request of Warren Havens and Skybridge to treat WQHZ610 as if the construction obligation 
had been retained by the original licensee.  See Havens 220 MHz Termination Order at ¶ 15.
94
See Havens Petition for Reconsideration at 11-16.
95
Id. at 12.
96
Id. at 13-16.
97
See Havens 220 MHz Termination Order at ¶ 27 quoting Amendment of Part 90 of the Commission’s Rules to 
Provide for the Use of the 220-222 MHz Band by the Private Land Mobile Radio Service, Fifth Report and Order, 
13 FCC Rcd 24615, 24633 at ¶ 24 (1998) (“220 MHz Fifth R&O”).
98
See Havens 220 MHz Termination Order at ¶ 27 and 220 MHz Fifth R&O at ¶ 24.
99
See 220 MHz Fifth R&O at ¶ 24.
Federal Communications Commission DA 14-121
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23. In fact, the recent Uniform Renewal NPRM, which Petitioners cite in support of their 
arguments, fully reinforces the findings in the Havens 220 MHz Termination Order.
100
  One of the main 
goals of the Uniform Renewal NPRM was to revise service specific geographic partitioning and 
disaggregation rules to require that each party to such an arrangement independently satisfy construction 
obligations under the applicable service rules.
101
  Havens cites a few sentences of the Commission’s rules 
to support his assertion that “[o]nly the licenses of the party with the construction responsibility terminate 
by virtue of the failure to construct.”
102
  However, in the same paragraph that Havens cites, the 
Commission states that “in services where there is currently no specific requirement to provide actual 
service to obtain renewal, a licensee could hold spectrum licenses without providing service 
indefinitely.”
103
  Here, the Commission once again draws a clear distinction between construction 
requirements and service requirements at renewal.  Thus, in services with service requirements at renewal, 
such as the 220 MHz service, even licensees that have assigned their construction requirements to others 
must satisfy a separate standard to warrant renewal of partitioned or disaggregated licenses.
24. As a matter of policy, the Commission remains committed to the notion that “the goal of our 
construction requirements in both the partitioning and disaggregation contexts is to ensure that the 
spectrum is used to the same degree that would have been required had the partitioning or disaggregation 
transaction not taken place.”
104
  The Commission has not deviated from this longstanding policy and 
clearly reiterated it in the Uniform Renewal NPRM.
105
To do otherwise would encourage spectrum 
warehousing and disincentivize the valuable development and use of spectrum resources.  Havens’ 
position is clearly inconsistent with the text of the Commission’s rules, the Commission’s longstanding 
policies, and the public interest.  Thus, in denying the Skybridge Renewal Applications, the Division 
simply applied the Commission’s existing rules and policies in reaching its decision.  Thus, the Division’s 
actions were well within the scope of its delegated authority and did not constitute an unlawful rulemaking 
or an unlawful ruling on a unique question of law or fact.
C. Extension Requests
25. In the Havens 220 MHz Termination Order, the Division denied Petitioners’ requests for 
extension or waiver of the construction deadlines for the Havens Licenses.
106
  Under Section 1.946(e) of 
the Commission’s rules, an extension of time to complete construction “may be granted if the licensee 
shows that the failure to meet the construction or coverage deadline is due to involuntary loss of site or 
other causes beyond its control.”
107
  Section 1.946 also lists specific circumstances where extension 
requests will not be granted, including delays caused by a failure to obtain financing, because the license 
undergoes a transfer of control, or because the licensee fails to order equipment in a timely manner.
108
  The 
                                                          
100
See Amendment of Parts 1, 22, 24, 27, 74, 80, 90, 95, and 101 To Establish Uniform License Renewal, 
Discontinuance of Operation, and Geographic Partitioning and Spectrum Disaggregation Rules and Policies for 
Certain Wireless Radio Services, Notice of Proposed Rulemaking and Order, 25 FCC Rcd 6996 (“Uniform Renewal 
NPRM”).
101
Id. at ¶ 72.
102
See Havens Petition for Reconsideration at 13.  
103
See Uniform Renewal NPRM at ¶ 87.
104
See Uniform Renewal NPRM at ¶ 77 quoting Geographic Partitioning and Spectrum Disaggregation by 
Commercial Mobile Radio Service Licensees, Report and Order and Further Notice of Proposed Rulemaking, 11 
FCC Rcd 21831 (1996) at ¶ 61.
105
Id.
106
See Havens 220 MHz Termination Order at ¶¶ 16-25.
107
See 47 C.F.R. § 1.946(e).
108
See 47 C.F.R. § 1.946(e)(2)-(3).
Federal Communications Commission DA 14-121
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applicable extension standard must be considered in conjunction with Section 309(j) of the 
Communications Act, as amended, which states that the Commission shall include performance 
requirements to ensure prompt delivery of services, to prevent stockpiling and warehousing of spectrum by 
licensees, and to promote investment and deployment of new technologies and services.
109
  We found that 
“(1) Applicants have not provided actual service in their license areas; (2) this failure was not caused by 
circumstances beyond their control; (3) the claimed due diligence, conceptual plans, or other factors 
described in Applicants’ filings do not support a further extension of the construction deadline; (4) 
Applicants have presented no compelling precedent or evidence to support their request for special 
considerations based on their donation of spectrum to Skybridge or their acquisition of certain 220 MHz 
licenses during a bankruptcy proceeding; and (5) allowing Warren Havens and Verde to continue to hold 
these licenses without constructing facilities or providing any actual service would undermine the purpose 
of the Commission’s rules and Section 309(j) of the Communications Act.”
110
26. The Division also found that the Petitioners had failed to meet the standard for waiver of the 
construction requirements as set forth in section 1.925 of the Commission’s rules.
111
  Specifically, the 
Petitioners had not presented evidence to establish that enforcement of the construction deadline would 
undermine the purpose of the rule or be otherwise inequitable, unduly burdensome, or contrary to the 
public interest.
112
  Indeed, the Division found that “granting the Applicants’ waiver request would harm the 
public interest since it would run counter to established Commission precedent and could encourage other 
present and future licensees to voluntarily pursue regulatory relief instead of providing actual service in 
their license areas.”
113
27. In the Petition for Reconsideration, Havens argues that the Division erred in denying the 2007 
Extension Request.
114
  Havens claims that the Division:
115
(1) disregarded the public interest in reaching its 
decision and, specifically, ignored the “highest and best use of the spectrum;” (2) failed to consider 
supporting evidence submitted by Havens; (3) improperly relied on its own expertise rather than the 
expertise of outside experts in assessing the supporting evidence submitted by Havens; (4) failed to 
consider the public interest benefits of non-profit spectrum use; and (5) failed to take a “hard look” at the 
Petitioners’ waiver request as required by the Commission’s rules.
116
  Havens also asserts that the Division 
violated the Petitioners’ equal protection rights since the Commission has granted waivers or extensions to 
other licensees in the 220 MHz service.
117
  For the reasons set forth below, we find the Petitioners’ 
arguments to be without merit and reaffirm the Division’s denial of the Extension Requests.
                                                          
109
See 47 U.S.C § 309(j)(4)(B).
110
See Havens 220 MHz Termination Order at ¶ 20.
111
47 C.F.R. § 1.925.  Under Section 1.925 of the Commission’s rules, a waiver may be granted if the petitioner 
establishes either that: (1) the underlying purpose of the rule would not be served or would be frustrated by 
application to the instant case, and that grant of the waiver would be in the public interest; or (2) where the petitioner 
establishes unique or unusual factual circumstances, application of the rule would be inequitable, unduly 
burdensome, or contrary to the public interest, or the applicant has no reasonable alternative.
112
See Havens 220 MHz Termination Order at ¶ 24.
113
See Havens 220 MHz Termination Order at ¶ 24.
114
Havens Petition for Reconsideration at 16.
115
Havens consistently refers to the decisions of “the Bureau” throughout the Petition for Reconsideration.  
However, the Order was released by the Mobility Division.
116
See Havens Petition for Reconsideration at 16-22.
117
See Havens Petition for Reconsideration at 23-24.
Federal Communications Commission DA 14-121
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1. The Division’s Decision was in the Public Interest.
a. Highest and Best Use of the Spectrum
28. Havens errs in claiming that the Division disregarded the public interest by failing to consider 
the highest and best use of the 220 MHz spectrum held by the Licensees.
118
  The Division’s decision was 
based largely on the fact that Havens did not provide any actual service in the applicable license areas and 
that this failure was due to voluntary decisions made by the Petitioners.
119
  As we noted, it is well 
established that voluntary business decisions are not circumstances beyond the licensee’s control for the 
purposes of satisfying the requirements of section 1.946.
120
  Petitioners acknowledge that, unlike other 220 
MHz licensees,
121
they chose not to avail themselves of readily available technology to deploy service in 
the 220 MHz band.
122
  Instead, they chose to pursue other technologies for which appropriate equipment 
was not available.
123
  One could not ask for a better example of a voluntary business decision.
29. Petitioners rely on recent waivers granted to Sprint Nextel Inc. to support their assertion that 
they are entitled to an extension based on their pursuit of supposedly superior technology in the band.
124
  
However, Sprint-Nextel’s waiver requests are easily distinguished on both factual and legal grounds.  
Sprint-Nextel requested a declaratory ruling modifying the narrowbanding requirements in Section 90.209
of the Commission’s rules
125
to update their existing subscriber network using CDMA technology in the 
800 MHz SMR band along with interim waivers of these requirements in designated license areas.
126
  The 
Commission denied the Sprint-Nextel Petition, but granted the waiver requests and ultimately changed the 
narrowbanding requirements in the SMR Flexibility Order.
127
  At no time did Sprint request an extension 
of its construction deadlines for these license areas.  Rather, Sprint sought a universal modification of the 
Commission’s rules to augment its existing network to facilitate the deployment of advanced 
communications technology.  Furthermore, Sprint was already providing service to customers in these 
license areas in accordance with the Commission’s rules.  Thus, Sprint-Nextel’s request is factually and 
legally distinct from the extensions sought by the Petitioners and the Commission’s actions in that 
                                                          
118
See Havens Petition for Reconsideration at 16-18.
119
See Havens 220 MHz Termination Order at ¶¶ 16-21.
120
See 47 C.F.R. § 1.946(e).
121
See, e.g., Coverage Notifications of Data Radio Management Co, Inc. for Call Signs WPOK830, WPOK831, and 
WPOK834 (filed October 7, 2009); Coverage Notifications of ESP Wireless Technology Group for Call Signs 
WPOJ377 and WPOJ389 (filed April 13, 2009); Coverage Notifications of Communications Specialists Inc. for Call
Signs WPOI493, WPOI494, WPOI495, WPOI496, WPOI497 (filed January 6, 2009).
122
See Havens Petition for Reconsideration at 16-17.
123
Id; See also 2007 Extension Request at 4-7 and Exhibits; June 2008 Supplement; September 2010 Supplement; 
Havens/Verde Extension and Renewal Applications at 4-9.
124
See Havens Petition for Reconsideration at 18; Improving Spectrum Efficiency Through Flexible Channel 
Spacing and Bandwidth Utilization for Economic Area-based 800 MHz Specialized Mobile Radio Licensees, Report 
and Order, WT Docket Nos. 12-64, 11-110, 27 FCC Rcd 6489 (rel. May 24, 2012) (SMR Flexibility Order) at note 
21.
125
47 C.F.R. § 90.209.
126
See SMR Flexibility Order, 27 FCC Rcd 6491-6493 at ¶¶ 5-7; Request for Declaratory Ruling that the 
Commission’s Rules Authorize Greater than 25 kHz Bandwidth Operations in the 817-824/862-869 MHz Band, 
Petition for Declaratory Ruling, WT Docket No. 11-110 (filed June 3, 2011) (Sprint-Nextel Petition). 
127
See SMR Flexibility Order, 27 FCC Rcd 6493-6501 at ¶¶ 8-18; Sprint-Nextel Petition; Sprint-Nextel Call Signs
WPLM660, WPLM661, WQNX442, WQNX443, WQNX444, WQOQ770, WQOQ771, WQOQ772, and 
WQOU823. 
Federal Communications Commission DA 14-121
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proceeding have no precedential effect here.
30. With regards to the appropriate use of the spectrum, Petitioners correctly state that the 
Commission is concerned with ensuring the highest and best use of radio spectrum.
128
  One of the ways 
that the Commission promotes spectrum being put to its highest and best use is through rules that require 
licensees to actually construct facilities and deploy service.  As we stated in the Order, “[w]hile licensees 
are free to investigate, invest in, and pursue a wide range of technologies and service options, regulatory 
compliance is ultimately demonstrated by material accomplishments in the use of the spectrum resource to 
provide service.”
129
  The Petitioners focus solely on their own interpretation of the highest and best use of 
the spectrum, to provide ITS services, while ignoring the essential requirement to provide service within 
the timeframe set forth in the Commission’s rules.
b. Supplementary Information did not Support Extension or Waiver of 
the Construction Requirements.
31. In the Petition for Reconsideration, Petitioners claim that the Division disregarded “extensive 
evidence” that they submitted in support of the 2007 Extension Requests.
130
  This “evidence” includes 
hundreds of pages of information included in the Petitioners filings, websites related to TETRA, ex parte
filings in WT Docket No. 06-49, and other supplementary materials.
131
Petitioners claim that these filings 
show the value of TETRA and ITS technologies and demonstrate their due diligence in pursuing these 
technologies for use in the 220 MHz band.
132
  Petitioners argue that these supplemental filings support 
their request for waiver or extension of the construction deadlines and that the Division failed to give these 
materials due consideration in reaching its decision.
133
  Petitioners also claim that the Division should have 
deferred to the expert reports submitted by the Petitioners in reaching its decision.
134
32. Our review gave serious consideration to Petitioners’ waiver request, despite the fact that 
Petitioners did not plead the elements of the waiver standard in the 2007 Extension Requests
135
and 
provided scant support for their requests even in later pleadings.
136
  However, the requirement to take a 
“hard look” at pending waiver requests
137
does not require the Division to provide detailed analysis of each 
piece of purported supplementary material provided by Petitioners.  As noted in the Havens 220 MHz 
Termination Order, Division staff reviewed each of the filings submitted by the Petitioners in reaching its 
                                                          
128
The term “highest and best use” is not used in the Communications Act.  However, it does appear on the 
Commission’s website and accurately encapsulates one aspect of the Commission’s responsibility with regards to 
regulation of spectrum.  See FCC, “ What We Do,” available at: http://www.fcc.gov/what-we-do.
129
See Havens 220 MHz Termination Order at ¶ 20.
130
See Havens Petition for Reconsideration at 18.
131
See Havens Petition for Reconsideration at 18-19 (listing supplementary materials submitted in support of the 
2007 Extension Requests).
132
See Havens Petition for Reconsideration at 18-22.  See also 2007 Extension Request; June 2008 Supplement, 
Havens 2009 Renewal Applications, March 2009 Amended Extension Request, and Skybridge Renewal 
Applications.
133
See Havens Petition for Reconsideration at 20-21.
134
See Havens Petition for Reconsideration at 21-22.
135
See 2007 Extension Request at 9 (asserting that satisfaction of the waiver standards is “evident from the 
substance of the request”).
136
See Havens/Verde Extension and Renewal Application at 8-9.
137
See Havens Petition for Reconsideration at 20-21.
Federal Communications Commission DA 14-121
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decision.
138
  These materials support our finding that the Petitioners’ failure to satisfy the construction 
requirements was wholly due to their voluntary decision to pursue technology and business strategies that 
were unsupported by the existing technology ecosystem of the band.  Moreover, nothing in the supporting 
documentation indicates that the Petitioners have satisfied the requirements of section 1.925.
139
  As we 
stated in the Havens 220 MHz Order, “we do not believe that the Applicants have presented convincing 
evidence that enforcement of the construction deadline would frustrate the purpose of the rule or be 
otherwise inequitable, unduly burdensome, or contrary to the public interest.”
140
  Indeed, granting a waiver 
or extension to the Petitioners would undermine the very purpose of the construction obligations, 
contradict Commission precedent, encourage spectrum warehousing, and run counter to the public interest.
33. Finally, the Petitioners’ contention that the Division should have deferred to the opinions 
expressed in the expert reports appended to their filings with regard to TETRA and ITS is both unfounded 
and irrelevant.
141
  In this case, appropriate Division personnel reviewed the reports and supplemental 
information submitted by Havens.  However, these submissions did not address issues relevant to the 
disposition of this case.  The Petitioners’ reports dealt with the purported value of the new technologies
and services that Havens sought to deploy but did not present evidence that Havens had actually deployed 
any such technology or satisfied the elements of the applicable extension or waiver standards. The 
potential merits of these technologies and services have no bearing on whether the Petitioners satisfied the 
Commission’s requirements for extension or waiver of the applicable construction requirements. Thus, in 
reaching its decision, the Division did not, as Havens claims, “counter an expert report with a non-expert 
opinion.”
142
  Rather, the Division properly found these “expert reports” to be substantively irrelevant to the 
Petitioners’ waiver and extension requests.
143
  
c. Skybridge’s Non-Profit Status Does Not Entitle Petitioners to 
Extension or Waiver of the Construction Requirements 
34. The Division also gave proper weight to Petitioners claims for special consideration based on 
Skybridge’s non-profit status.
144
  Havens has provided no support for his contention that a non-profit 
licensee is entitled to special consideration in applications for extension or waiver of its construction 
requirements.
145
  The mere fact that a licensee is a non-profit organization does not entitle such an 
organization to a waiver of any regulation under section 1.925 of the Commission’s rules.
146
  The 
Commission’s rules make no distinction between for-profit and non-profit entities for purposes of 
determining compliance with construction requirements and Havens has provided no precedent to support 
a deviation from this policy. 
35. In short, the public interest cannot be served solely by promises of future deployment.  At 
some point theory must give way to action and “due diligence” must yield tangible results.  For Havens 
that time has long since passed.  Petitioners have held the Havens Licenses since 1999 and yet have failed 
to construct facilities or provide service in any of their license areas, even as other licensees have begun to 
                                                          
138
See Havens 220 MHz Termination Order at ¶ 24.
139
See id.
140
Id.
141
See Havens Petition for Reconsideration at 21-22.
142
See Havens Petition for Reconsideration at 21.
143
See Havens 220 MHz Termination Order at ¶¶ 20, 24.
144
See Havens 220 MHz Termination Order at ¶ 23-25.
145
See Havens Petition for Reconsideration at 22.
146
See 47 C.F.R. § 1.925.
Federal Communications Commission DA 14-121
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offer meaningful service in the 220 MHz band.  Instead, the Licensees made the voluntary decision to 
pursue technologies that, whatever their theoretical merits, were not supported by the existing 220 MHz 
device ecosystem.  Thus, we find that the public interest is best served by affirming the termination of the 
Havens Licenses and allowing other parties the opportunity to make actual use of the spectrum resource.
2. The Division’s Decision did not Violate Havens’ Equal Protection Rights
36. Havens argues that, because the Division has granted extensions to other 220 MHz license 
holders, Havens is entitled to the same treatment on equal protection grounds.
147
  Havens also argues that, 
since the Commission has granted waivers of construction requirements for similarly situated parties, it is 
required to waive the construction requirements for the Havens Licenses.
148
  These claims are wholly 
without merit and misrepresent the Commission’s legal obligations and applicable precedent.
37. As an initial matter, Havens misrepresents the Division’s actions with regard to other 220 
MHz licensees.  The mere fact that the Commission has granted extensions or waivers to select 220 MHz 
licensees due to the unique circumstances of their claims does not entitle Petitioners to the same outcome.  
As we noted in the Havens 220 MHz Termination Order, our denial of the Havens Extension Requests is 
wholly consistent with our treatment of similarly situated licensees.
149
  We have consistently denied 
extension requests from licensees in the 220 MHz band when those licensees made the voluntary decision 
not to deploy available equipment to provide service within their license areas.
150
  This approach is also 
consistent with our treatment of similarly situated licensees in the 218-219 MHz band.
151
38. The Petitioners cite three instances where the Commission or the Bureau granted certain 220 
MHz license holders extensions or waivers of their construction requirements based on unique factual 
circumstances not present in this proceeding.
152
  Havens makes no attempt to connect the facts in these 
                                                          
147
See Havens Petition for Reconsideration at 23.
148
See Havens Petition for Reconsideration at 24.
149
See Havens 220 MHz Termination Order at ¶ 21.
150
See Havens 220 MHz Termination Order, note 85, citing Letter dated June 26, 2009, from Roger S. Noel, Chief, 
Mobility Division, Wireless Telecommunications Bureau, to Nancy J. Douglas, Douglas SMR Works, Inc., 24 FCC 
Rcd 8596 (WTB-MD 2009); Letter dated June 26, 2009, from Roger S. Noel, Chief, Mobility Division, Wireless 
Telecommunications Bureau, to Robert LaRue, Know LaRue Separate Property Trust, 24 FCC Rcd 8621 (WTB-MD 
2009); Letter dated June 26, 2009, from Roger S. Noel, Chief, Mobility Division, Wireless Telecommunications 
Bureau, to Kansas City Wireless Partners, LLP, 24 FCC Rcd 8625 (WTB-MD 2009); Letter dated June 26, 2009, 
from Roger S. Noel, Chief, Mobility Division, Wireless Telecommunications Bureau, to David G. Boyle, 24 FCC 
Rcd 8600 (WTB-MD 2009).
151
See Havens 220 MHz Termination Order, note 85, citing Letter dated May 31, 2005 from Katherine M. Harris, 
Deputy Chief, Mobility Division, Wireless Telecommunications Bureau, to Buddy C. Stanley, ITV, Inc., 20 FCC 
Rcd 9548, recon den., Application of ITV, Inc., Memorandum Opinion and Order, 22 FCC Rcd 1908 (WTB-CWD 
2007);  Letter dated January 31, 2007,  from Thomas P. Derenge, Deputy Chief, Mobility Division, Wireless 
Telecommunications Bureau, to Stephen E. Coran, Esquire, Counsel for U.S. Telemetry, 22 FCC Rcd 1921 (WTB-
MD 2007).
152
See National Rural Telecommunications Cooperative Request for Clarification or Extension of Time to Construct 
a 220-222 MHz Nationwide Land Mobile Radio System, Order, 15 FCC Rcd 6637 (WTB, Commercial Wireless 
Division - 1999) (Granting a limited one-year extension of Phase I license construction deadlines to allow licensee 
to align its Phase I licenses with its existing Phase II authorizations); Request of PTC-220, LLC for Waivers of 
Certain 220 MHz Rules, Memorandum Opinion and Order, WT Docket No. 08-256, 24 FCC Rcd 8537 (WTB -
2009) (Granting PTC-220, LLC a conditional waiver of construction requirements to allow it to construct a system 
that complies with a Congressional mandate to construct a nationwide positive train control system); Niagara 
Mohawk Power Corporation Call Signs WPCW863, WPCX746, WPCX405, WPCX407, WPCX408, WPCV961, 
WPCV948 and WPCV949 Request for Extension of Time to construct and operate its 220–222 MHz Land Mobile 
(continued....)
Federal Communications Commission DA 14-121
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cases to his arguments beyond the false assertion that, since the Commission granted waivers in these 
cases, they constitute binding precedent for the Commission to grant the requests of the Petitioners.
153
  As 
Havens himself notes, the Commission is required to take a hard look at individual applications for waiver, 
and decide each case on its merits.
154
  The petitioners in the cases cited by Havens met the Commission’s 
standards for waiver or extension of the Construction requirements by demonstrating that their unique 
circumstances qualified them for relief and that granting such relief would be in the public interest, in 
accordance with the Commission’s rules.  The Petitioners, like the other 220 MHz licensees listed in 
footnote 149,
155
did not meet these requirements.  Consequently Petitioners are not entitled to the relief 
they seek.
D. Fee Waiver Requests
39. Havens claims that the Division erred in denying the Petitioners’ request for waiver of fees 
associated with the Extension and Waiver Requests.
156
  Petitioners claim that the Division: (1) failed to 
take a hard look at the request for waiver; (2) neglected to provide a reasoned basis for its decision; and (3) 
improperly used denial of the underlying applications as a basis for denying the waiver requests.
157
  What 
Petitioners fail to mention is that they never once plead the required elements of their waiver request with 
specificity.  
40. As Petitioners correctly point out, Section 1.1119 of the Commission’s rules
158
requires that 
fee waiver requests be filed separately from the underlying pleading.
159
  This means that Petitioners are 
required to satisfy the elements of the waiver standard set forth in Section 1.925 of the Commission’s rules 
specifically for the fee waiver request.
160
  Petitioners simply state that the fee waiver request should be 
granted for the same reasons that their other waiver and extension requests should be granted.
161
  Such 
                                                          
(...continued from previous page)
Systems, Order, 9 FCC Rcd 4838 (Private Radio Bureau, Licensing Division – 1994) (Granting an eight month 
extension of licensee’s construction requirements to allow licensee to complete coordination negotiations with 
Canada); See also Maritel, Inc. Request for Waiver of Part 80 Regulations to Permit Use of 12.5 kHz Radio 
Equipment Operating in the 156-162 MHz Frequency Band, Order, 16 FCC Rcd 9294 (WTB, Public Safety and 
Private Wireless Division – 2001) (Havens cites Maritel as an example of a similarly situated party that was granted 
a waiver of its construction requirements.  Maritel actually asked for and received a waiver of the Commission’s 
Part 80 rules to permit the certification of equipment capable of operating on 12.5 kHz offset channels in the 156-
162 MHz band).
153
See Havens Petition for Reconsideration at 23-24.
154
See Havens Petition for Reconsideration at 23-24; See also WAIT Radio, Inc. v. FCC, 418 F.2d 1153, 1157 (D.C. 
Cir. 1969); K. Rupert Murdoch (Transferor) and Fox Entertainment Group (Transferee) Applications for Transfer of 
Control of Fox Television Stations, Inc., Memorandum Opinion and Order on Reconsideration, 24 FCC Rcd 5824, 
5828 (2009) at ¶ 16 (“the Commission is obligated to take a “hard look” at waiver requests to determine whether the 
application of a rule in a particular circumstance would disserve the public interest”).
155
See supra note 149.
156
See Havens Petition for Reconsideration at 25.
157
See Havens Petition for Reconsideration at 25.
158
47 C.F.R. § 1.119.
159
See Havens Petition for Reconsideration at 24-25.
160
47 C.F.R. § 1.925.
161
See Havens 2007 Extension Request at 10 (“the above waiver request to grant consolidated licenses should be 
granted in the public interest, and  if granted, then there would be only one extension request and one fee for it, not 
the large numbers of fees paid when this extension request is submitted, and (ii) the substantial ongoing due 
diligence (which will benefit the larger 220 MHz market also), the special bankruptcy circumstance noted above, the 
(continued....)
Federal Communications Commission DA 14-121
18
conclusory statements do not constitute a “separate pleading” as required by Section 1.119 and are 
insufficient to satisfy the requirements of Section 1.925.  As such, we uphold our earlier denial of the 
Petitioners’ request for waiver of application fees.
E. Maritime Petitions and Havens Responses
41. As detailed above, Maritime filed an opposition to the Petition for Reconsideration which 
Havens subsequently opposed.
162
  However, since we reached our conclusions without the need for any of 
the information included in these filings, we hereby dismiss the Maritime Opposition, Havens July 2012 
Reply, and Maritime Opposition to Motion to Strike as moot.
163
IV. CONCLUSION
42. For the reasons set forth above, the Havens Petition for Reconsideration is denied in its 
entirety and all of the decisions set forth in the Havens 220 MHz Termination Order are hereby affirmed.
V. ORDERING CLAUSES
43. Accordingly, IT IS ORDERED that, pursuant to Section 1.106 of the Commission’s Rules, 47 
C.F.R., § 1.106, the Petition for Reconsideration filed by Petitioners is DENIED.
                                                                     
       FEDERAL COMMUNICATIONS COMMISSION
                                                                                       Thomas Derenge
                                                                                       Deputy Chief, Mobility Division
                                                                                       Wireless Telecommunications Bureau
                                                          
(...continued from previous page)
special involvement of SSF (and support of SSF by the charitable assignments of 220 MHz spectrum from 
Applicants to SSF), and applicants commitment to high public interest wireless with all of the subject 220 MHz 
spectrum (as described at www.telsaurus.com ) all warrant grant of this fee waiver request”); Havens/Verde 
Extension and Renewal Applications at 2 (“It is clearly in the public interest for the FCC to find that SSF’s use of its 
220-222 MHz spectrum, along with its use of the Licensees 220-222 MHz spectrum under the just described option 
and lease, warrants a waiver of the fees paid with the Havens and VSL renewal applications filed today for the 
above-captioned call signs, as it warrants a waiver of the fees that SSF paid for its 220-222 MHz renewal 
applications filed on October 6, 2009…”)
162
See Maritime Opposition and Havens July 2012 Reply.
163
See Maritime Opposition, Havens July 2012 Reply, and Maritime Opposition to Motion to Strike.
Federal Communications Commission DA 14-121
19
ATTACHMENT A
License
Grant Date Call Sign Licensee Name
First 
Construction 
Deadline
Second 
Construction 
Deadline
Extension 
Request - FCC 
File Number
Renewal 
Application -
FCC File 
Number
License 
Expiration 
Date
03/23/99 WPOI514 Havens, Warren C 11/05/07 03/23/09 0003222953 0003783529 03/23/09
03/23/99 WPOI515 Havens, Warren C 11/05/07 03/23/09 0003222954 0003783599 03/23/09
03/23/99 WPOI516 Havens, Warren C 11/05/07 03/23/09 0003222955 0003783530 03/23/09
03/23/99 WPOI517 Havens, Warren C 11/05/07 03/23/09 0003222956 0003783609 03/23/09
03/23/99 WPOI518 Havens, Warren C 11/05/07 03/23/09 0003222957 0003783531 03/23/09
03/23/99 WPOI519 Havens, Warren C 11/05/07 03/23/09 0003222958 0003783532 03/23/09
03/23/99 WPOI520 Havens, Warren C 11/05/07 03/23/09 0003222959 0003783620 03/23/09
03/23/99 WPOI521 Havens, Warren C 11/05/07 03/23/09 0003222960 0003783626 03/23/09
03/23/99 WPOI522 Havens, Warren C 11/05/07 03/23/09 0003222961 0003783533 03/23/09
03/23/99 WPOI523 Havens, Warren C 11/05/07 03/23/09 0003222962 0003783641 03/23/09
03/23/99 WPOI524 Havens, Warren C 11/05/07 03/23/09 0003222963 0003783534 03/23/09
03/23/99 WPOI525 Havens, Warren C 11/05/07 03/23/09 0003222964 0003783600 03/23/09
03/23/99 WPOI526 Havens, Warren C 11/05/07 03/23/09 0003222965 0003783642 03/23/09
03/23/99 WPOI527 Havens, Warren C 11/05/07 03/23/09 0003222966 0003783535 03/23/09
03/23/99 WPOI528 Havens, Warren C 11/05/07 03/23/09 0003222967 0003783536 03/23/09
03/23/99 WPOI529 Havens, Warren C 11/05/07 03/23/09 0003222968 0003783537 03/23/09
03/23/99 WPOI530 Havens, Warren C 11/05/07 03/23/09 0003222969 0003783538 03/23/09
03/23/99 WPOI531 Havens, Warren C 11/05/07 03/23/09 0003222970 0003783627 03/23/09
03/23/99 WPOI532 Havens, Warren C 11/05/07 03/23/09 0003222971 0003783640 03/23/09
03/23/99 WPOI533 Havens, Warren C 11/05/07 03/23/09 0003222972 0003783539 03/23/09
03/23/99 WPOI534 Havens, Warren C 11/05/07 03/23/09 0003222973 0003783540 03/23/09
03/23/99 WPOI535 Havens, Warren C 11/05/07 03/23/09 0003222974 0003783541 03/23/09
03/23/99 WPOI536 Havens, Warren C 11/05/07 03/23/09 0003222975 0003783601 03/23/09
03/23/99 WPOI537 Havens, Warren C 11/05/07 03/23/09 0003222976 0003783643 03/23/09
03/23/99 WPOI538 Havens, Warren C 11/05/07 03/23/09 0003222977 0003783542 03/23/09
03/23/99 WPOI539 Havens, Warren C 11/05/07 03/23/09 0003222978 0003783543 03/23/09
03/23/99 WPOI540 Havens, Warren C 11/05/07 03/23/09 0003222979 0003783544 03/23/09
03/23/99 WPOI541 Havens, Warren C 11/05/07 03/23/09 0003222980 0003783616 03/23/09
03/23/99 WPOI542 Havens, Warren C 11/05/07 03/23/09 0003222981 0003783628 03/23/09
03/23/99 WPOI543 Havens, Warren C 11/05/07 03/23/09 0003222982 0003783545 03/23/09
03/23/99 WPOI544 Havens, Warren C 11/05/07 03/23/09 0003222983 0003783546 03/23/09
03/23/99 WPOI545 Havens, Warren C 11/05/07 03/23/09 0003222984 0003783547 03/23/09
03/23/99 WPOI546 Havens, Warren C 11/05/07 03/23/09 0003222985 0003783602 03/23/09
03/23/99 WPOI547 Havens, Warren C 11/05/07 03/23/09 0003222986 0003783621 03/23/09
03/23/99 WPOI548 Havens, Warren C 11/05/07 03/23/09 0003222987 0003783610 03/23/09
03/23/99 WPOI549 Havens, Warren C 11/05/07 03/23/09 0003222988 0003783548 03/23/09
03/23/99 WPOI550 Havens, Warren C 11/05/07 03/23/09 0003222989 0003783644 03/23/09
03/23/99 WPOI551 Havens, Warren C 11/05/07 03/23/09 0003222990 0003783549 03/23/09
03/23/99 WPOI552 Havens, Warren C 11/05/07 03/23/09 0003222991 0003783550 03/23/09
03/23/99 WPOI553 Havens, Warren C 11/05/07 03/23/09 0003222992 0003783629 03/23/09
03/23/99 WPOI554 Havens, Warren C 11/05/07 03/23/09 0003222993 0003783551 03/23/09
03/23/99 WPOI555 Havens, Warren C 11/05/07 03/23/09 0003222994 0003783552 03/23/09
03/23/99 WPOI556 Havens, Warren C 11/05/07 03/23/09 0003222995 0003783603 03/23/09
03/23/99 WPOI557 Havens, Warren C 11/05/07 03/23/09 0003222996 0003783553 03/23/09
03/23/99 WPOI558 Havens, Warren C 11/05/07 03/23/09 0003222997 0003783611 03/23/09
03/23/99 WPOI559 Havens, Warren C 11/05/07 03/23/09 0003222998 0003783554 03/23/09
03/23/99 WPOI560 Havens, Warren C 11/05/07 03/23/09 0003222999 0003783555 03/23/09
03/23/99 WPOI561 Havens, Warren C 11/05/07 03/23/09 0003223000 0003783622 03/23/09
03/23/99 WPOI562 Havens, Warren C 11/05/07 03/23/09 0003223001 0003783630 03/23/09
03/23/99 WPOI563 Havens, Warren C 11/05/07 03/23/09 0003223002 0003783556 03/23/09
03/23/99 WPOI564 Havens, Warren C 11/05/07 03/23/09 0003223003 0003783617 03/23/09
03/23/99 WPOI565 Havens, Warren C 11/05/07 03/23/09 0003223004 0003783557 03/23/09
03/23/99 WPOI566 Havens, Warren C 11/05/07 03/23/09 0003223005 0003783639 03/23/09
03/23/99 WPOI567 Havens, Warren C 11/05/07 03/23/09 0003223006 0003783645 03/23/09
Federal Communications Commission DA 14-121
20
License
Grant Date Call Sign Licensee Name
First 
Construction 
Deadline
Second 
Construction 
Deadline
Extension 
Request - FCC 
File Number
Renewal 
Application -
FCC File 
Number
License 
Expiration 
Date
03/23/99 WPOI568 Havens, Warren C 11/05/07 03/23/09 0003223007 0003783558 03/23/09
03/23/99 WPOI569 Havens, Warren C 11/05/07 03/23/09 0003223008 0003783559 03/23/09
03/23/99 WPOI570 Havens, Warren C 11/05/07 03/23/09 0003223009 0003783560 03/23/09
03/23/99 WPOI571 Havens, Warren C 11/05/07 03/23/09 0003223010 0003783561 03/23/09
03/23/99 WPOI572 Havens, Warren C 11/05/07 03/23/09 0003223011 0003783631 03/23/09
03/23/99 WPOI573 Havens, Warren C 11/05/07 03/23/09 0003223012 0003783612 03/23/09
03/23/99 WPOI574 Havens, Warren C 11/05/07 03/23/09 0003223013 0003783562 03/23/09
03/23/99 WPOI575 Havens, Warren C 11/05/07 03/23/09 0003223014 0003783563 03/23/09
03/23/99 WPOI576 Havens, Warren C 11/05/07 03/23/09 0003223015 0003783564 03/23/09
03/23/99 WPOI577 Havens, Warren C 11/05/07 03/23/09 0003223016 0003783604 03/23/09
03/23/99 WPOI578 Havens, Warren C 11/05/07 03/23/09 0003223017 0003783646 03/23/09
03/23/99 WPOI579 Havens, Warren C 11/05/07 03/23/09 0003223018 0003783565 03/23/09
03/23/99 WPOI580 Havens, Warren C 11/05/07 03/23/09 0003223019 0003783566 03/23/09
03/23/99 WPOI581 Havens, Warren C 11/05/07 03/23/09 0003223020 0003783567 03/23/09
03/23/99 WPOI582 Havens, Warren C 11/05/07 03/23/09 0003223021 0003783618 03/23/09
03/23/99 WPOI583 Havens, Warren C 11/05/07 03/23/09 0003223022 0003783632 03/23/09
03/23/99 WPOI584 Havens, Warren C 11/05/07 03/23/09 0003223023 0003783568 03/23/09
03/23/99 WPOI585 Havens, Warren C 11/05/07 03/23/09 0003223024 0003783569 03/23/09
03/23/99 WPOI586 Havens, Warren C 11/05/07 03/23/09 0003223025 0003783570 03/23/09
03/23/99 WPOI587 Havens, Warren C 11/05/07 03/23/09 0003223026 0003783605 03/23/09
03/23/99 WPOI588 Havens, Warren C 11/05/07 03/23/09 0003223027 0003783623 03/23/09
03/23/99 WPOI589 Havens, Warren C 11/05/07 03/23/09 0003223028 0003783653 03/23/09
03/23/99 WPOI590 Havens, Warren C 11/05/07 03/23/09 0003223029 0003783571 03/23/09
03/23/99 WPOI591 Havens, Warren C 11/05/07 03/23/09 0003223030 0003783647 03/23/09
03/23/99 WPOI592 Havens, Warren C 11/05/07 03/23/09 0003223031 0003783572 03/23/09
03/23/99 WPOI593 Havens, Warren C 11/05/07 03/23/09 0003223032 0003783573 03/23/09
03/23/99 WPOI594 Havens, Warren C 11/05/07 03/23/09 0003223033 0003783633 03/23/09
03/23/99 WPOI595 Havens, Warren C 11/05/07 03/23/09 0003223034 0003783574 03/23/09
03/23/99 WPOI596 Havens, Warren C 11/05/07 03/23/09 0003223035 0003783575 03/23/09
03/23/99 WPOI597 Havens, Warren C 11/05/07 03/23/09 0003223036 0003783652 03/23/09
03/23/99 WPOI598 Havens, Warren C 11/05/07 03/23/09 0003223037 0003783576 03/23/09
03/23/99 WPOI599 Havens, Warren C 11/05/07 03/23/09 0003223038 0003783613 03/23/09
03/23/99 WPOI600 Havens, Warren C 11/05/07 03/23/09 0003223039 0003783577 03/23/09
03/23/99 WPOI601 Havens, Warren C 11/05/07 03/23/09 0003223040 0003783578 03/23/09
03/23/99 WPOI602 Havens, Warren C 11/05/07 03/23/09 0003223041 0003783624 03/23/09
03/23/99 WPOI603 Havens, Warren C 11/05/07 03/23/09 0003223042 0003783634 03/23/09
03/23/99 WPOI604 Havens, Warren C 11/05/07 03/23/09 0003223043 0003783579 03/23/09
03/23/99 WPOI605 Havens, Warren C 11/05/07 03/23/09 0003223044 0003783619 03/23/09
03/23/99 WPOI606 Havens, Warren C 11/05/07 03/23/09 0003223045 0003783580 03/23/09
03/23/99 WPOI607 Havens, Warren C 11/05/07 03/23/09 0003223046 0003783606 03/23/09
03/23/99 WPOI608 Havens, Warren C 11/05/07 03/23/09 0003223047 0003783648 03/23/09
03/23/99 WPOI609 Havens, Warren C 11/05/07 03/23/09 0003223048 0003783581 03/23/09
03/23/99 WPOI610 Havens, Warren C 11/05/07 03/23/09 0003223049 0003783582 03/23/09
03/23/99 WPOI611 Havens, Warren C 11/05/07 03/23/09 0003223050 0003783583 03/23/09
03/23/99 WPOI612 Havens, Warren C 11/05/07 03/23/09 0003223051 0003783584 03/23/09
03/23/99 WPOI613 Havens, Warren C 11/05/07 03/23/09 0003223052 0003783635 03/23/09
03/23/99 WPOI614 Havens, Warren C 11/05/07 03/23/09 0003223053 0003783614 03/23/09
03/23/99 WPOI615 Havens, Warren C 11/05/07 03/23/09 0003223054 0003783585 03/23/09
03/23/99 WPOI616 Havens, Warren C 11/05/07 03/23/09 0003223055 0003783586 03/23/09
03/23/99 WPOI617 Havens, Warren C 11/05/07 03/23/09 0003223056 0003783587 03/23/09
03/23/99 WPOI618 Havens, Warren C 11/05/07 03/23/09 0003223057 0003783607 03/23/09
03/23/99 WPOI619 Havens, Warren C 11/05/07 03/23/09 0003223058 0003783649 03/23/09
03/23/99 WPOI620 Havens, Warren C 11/05/07 03/23/09 0003223059 0003783588 03/23/09
03/23/99 WPOI621 Havens, Warren C 11/05/07 03/23/09 0003223060 0003783589 03/23/09
Federal Communications Commission DA 14-121
21
License
Grant Date Call Sign Licensee Name
First 
Construction 
Deadline
Second 
Construction 
Deadline
Extension 
Request - FCC 
File Number
Renewal 
Application -
FCC File 
Number
License 
Expiration 
Date
03/23/99 WPOI622 Havens, Warren C 11/05/07 03/23/09 0003223061 0003783590 03/23/09
03/22/99 WPOI843 Havens, Warren C 11/05/07 03/22/09 0003223062 0003781371 03/22/09
03/23/99 WPOJ290 Havens, Warren C 11/05/07 03/23/09 0003223063 0003783654 03/23/09
03/23/99 WPOJ291 Havens, Warren C 11/05/07 03/23/09 0003223064 0003783636 03/23/09
03/23/99 WPOJ292 Havens, Warren C 11/05/07 03/23/09 0003223065 0003783591 03/23/09
03/23/99 WPOJ293 Havens, Warren C 11/05/07 03/23/09 0003223066 0003783592 03/23/09
03/23/99 WPOJ294 Havens, Warren C 11/05/07 03/23/09 0003223067 0003783593 03/23/09
03/23/99 WPOJ295 Havens, Warren C 11/05/07 03/23/09 0003223068 0003783608 03/23/09
03/23/99 WPOJ296 Havens, Warren C 11/05/07 03/23/09 0003223069 0003783625 03/23/09
03/23/99 WPOJ297 Havens, Warren C 11/05/07 03/23/09 0003223070 0003783615 03/23/09
03/23/99 WPOJ298 Havens, Warren C 11/05/07 03/23/09 0003223071 0003783594 03/23/09
03/23/99 WPOJ299 Havens, Warren C 11/05/07 03/23/09 0003223072 0003783650 03/23/09
03/23/99 WPOJ300 Havens, Warren C 11/05/07 03/23/09 0003223073 0003783595 03/23/09
03/23/99 WPOJ301 Havens, Warren C 11/05/07 03/23/09 0003223074 0003783596 03/23/09
03/23/99 WPOJ302 Havens, Warren C 11/05/07 03/23/09 0003223075 0003783637 03/23/09
03/23/99 WPOJ303 Havens, Warren C 11/05/07 03/23/09 0003223076 0003783597 03/23/09
03/23/99 WPOJ304 Havens, Warren C 11/05/07 03/23/09 0003223077 0003783638 03/23/09
03/23/99 WPOJ305 Havens, Warren C 11/05/07 03/23/09 0003223078 0003783598 03/23/09
03/23/99 WPOJ306 Havens, Warren C 11/05/07 03/23/09 0003223079 0003783651 03/23/09
10/07/99 WPOK862 Havens, Warren C 11/05/07 10/07/09 0003223118 0003990376 10/07/09
10/07/99 WPOK863 Havens, Warren C 11/05/07 10/07/09 0003223119 0003990345 10/07/09
10/07/99 WPOK864 Havens, Warren C 11/05/07 10/07/09 0003223120 0003990344 10/07/09
10/07/99 WPOK865 Havens, Warren C 11/05/07 10/07/09 0003223121 0003990346 10/07/09
10/07/99 WPOK866 Havens, Warren C 11/05/07 10/07/09 0003223122 0003990347 10/07/09
10/07/99 WPOK867 Havens, Warren C 11/05/07 10/07/09 0003223123 0003990348 10/07/09
10/07/99 WPOK868 Havens, Warren C 11/05/07 10/07/09 0003223124 0003990373 10/07/09
10/07/99 WPOK869 Havens, Warren C 11/05/07 10/07/09 0003223125 0003990349 10/07/09
10/07/99 WPOK871 Havens, Warren C 11/05/07 10/07/09 0003223126 0003990371 10/07/09
10/07/99 WPOK872 Havens, Warren C 11/05/07 10/07/09 0003223127 0003990350 10/07/09
10/07/99 WPOK873 Havens, Warren C 11/05/07 10/07/09 0003223128 0003990369 10/07/09
10/07/99 WPOK874 Havens, Warren C 11/05/07 10/07/09 0003223129 0003990377 10/07/09
10/07/99 WPOK875 Havens, Warren C 11/05/07 10/07/09 0003223130 0003990351 10/07/09
10/07/99 WPOK876 Havens, Warren C 11/05/07 10/07/09 0003223131 0003990352 10/07/09
10/07/99 WPOK877 Havens, Warren C 11/05/07 10/07/09 0003223132 0003990353 10/07/09
10/07/99 WPOK878 Havens, Warren C 11/05/07 10/07/09 0003223133 0003990354 10/07/09
10/07/99 WPOK879 Havens, Warren C 11/05/07 10/07/09 0003223134 0003990374 10/07/09
10/07/99 WPOK880 Havens, Warren C 11/05/07 10/07/09 0003223135 0003990355 10/07/09
10/07/99 WPOK881 Havens, Warren C 11/05/07 10/07/09 0003223136 0003990367 10/07/09
10/07/99 WPOK882 Havens, Warren C 11/05/07 10/07/09 0003223137 0003990356 10/07/09
10/07/99 WPOK883 Havens, Warren C 11/05/07 10/07/09 0003223138 0003990357 10/07/09
10/07/99 WPOK884 Havens, Warren C 11/05/07 10/07/09 0003223139 0003990378 10/07/09
10/07/99 WPOK885 Havens, Warren C 11/05/07 10/07/09 0003223140 0003990358 10/07/09
10/07/99 WPOK886 Havens, Warren C 11/05/07 10/07/09 0003223141 0003990359 10/07/09
10/07/99 WPOK887 Havens, Warren C 11/05/07 10/07/09 0003223142 0003990360 10/07/09
10/07/99 WPOK888 Havens, Warren C 11/05/07 10/07/09 0003223143 0003990375 10/07/09
10/07/99 WPOK889 Havens, Warren C 11/05/07 10/07/09 0003223144 0003990370 10/07/09
10/07/99 WPOK890 Verde Systems LLC 11/05/07 10/07/09 0003223081 0003990428 10/07/09
10/07/99 WPOK891 Verde Systems LLC 11/05/07 10/07/09 0003223082 0003990398 10/07/09
10/07/99 WPOK892 Verde Systems LLC 11/05/07 10/07/09 0003223083 0003990399 10/07/09
10/07/99 WPOK893 Havens, Warren C 11/05/07 10/07/09 0003223145 0003990361 10/07/09
10/07/99 WPOK894 Havens, Warren C 11/05/07 10/07/09 0003223146 0003990362 10/07/09
10/07/99 WPOK895 Havens, Warren C 11/05/07 10/07/09 0003223147 0003990363 10/07/09
10/07/99 WPOK896 Havens, Warren C 11/05/07 10/07/09 0003223148 0003990364 10/07/09
10/07/99 WPOK897 Havens, Warren C 11/05/07 10/07/09 0003223149 0003990379 10/07/09
Federal Communications Commission DA 14-121
22
License
Grant Date Call Sign Licensee Name
First 
Construction 
Deadline
Second 
Construction 
Deadline
Extension 
Request - FCC 
File Number
Renewal 
Application -
FCC File 
Number
License 
Expiration 
Date
10/07/99 WPOK898 Havens, Warren C 11/05/07 10/07/09 0003223150 0003990368 10/07/09
10/07/99 WPOK899 Havens, Warren C 11/05/07 10/07/09 0003223151 0003990372 10/07/09
10/07/99 WPOK900 Havens, Warren C 11/05/07 10/07/09 0003223152 0003990365 10/07/09
10/07/99 WPOK901 Verde Systems LLC 11/05/07 10/07/09 0003223084 0003990400 10/07/09
10/07/99 WPOK902 Verde Systems LLC 11/05/07 10/07/09 0003223085 0003990401 10/07/09
10/07/99 WPOK903 Verde Systems LLC 11/05/07 10/07/09 0003223086 0003990402 10/07/09
10/07/99 WPOK904 Verde Systems LLC 11/05/07 10/07/09 0003223087 0003990425 10/07/09
10/07/99 WPOK905 Verde Systems LLC 11/05/07 10/07/09 0003223088 0003990403 10/07/09
10/07/99 WPOK906 Verde Systems LLC 11/05/07 10/07/09 0003223089 0003990404 10/07/09
10/07/99 WPOK907 Verde Systems LLC 11/05/07 10/07/09 0003223090 0003990423 10/07/09
10/07/99 WPOK908 Verde Systems LLC 11/05/07 10/07/09 0003223091 0003990429 10/07/09
10/07/99 WPOK909 Verde Systems LLC 11/05/07 10/07/09 0003223092 0003990421 10/07/09
10/07/99 WPOK910 Verde Systems LLC 11/05/07 10/07/09 0003223093 0003990405 10/07/09
10/07/99 WPOK911 Verde Systems LLC 11/05/07 10/07/09 0003223094 0003990406 10/07/09
10/07/99 WPOK912 Verde Systems LLC 11/05/07 10/07/09 0003223095 0003990407 10/07/09
10/07/99 WPOK913 Verde Systems LLC 11/05/07 10/07/09 0003223096 0003990408 10/07/09
10/07/99 WPOK914 Verde Systems LLC 11/05/07 10/07/09 0003223097 0003990426 10/07/09
10/07/99 WPOK915 Verde Systems LLC 11/05/07 10/07/09 0003223098 0003990409 10/07/09
10/07/99 WPOK916 Verde Systems LLC 11/05/07 10/07/09 0003223099 0003990410 10/07/09
10/07/99 WPOK917 Verde Systems LLC 11/05/07 10/07/09 0003223100 0003990411 10/07/09
10/07/99 WPOK918 Verde Systems LLC 11/05/07 10/07/09 0003223101 0003990430 10/07/09
10/07/99 WPOK919 Verde Systems LLC 11/05/07 10/07/09 0003223102 0003990412 10/07/09
10/07/99 WPOK920 Verde Systems LLC 11/05/07 10/07/09 0003223103 0003990413 10/07/09
10/07/99 WPOK921 Verde Systems LLC 11/05/07 10/07/09 0003223104 0003990414 10/07/09
10/07/99 WPOK922 Verde Systems LLC 11/05/07 10/07/09 0003223105 0003990427 10/07/09
10/07/99 WPOK923 Verde Systems LLC 11/05/07 10/07/09 0003223106 0003990415 10/07/09
10/07/99 WPOK924 Verde Systems LLC 11/05/07 10/07/09 0003223107 0003990422 10/07/09
10/07/99 WPOK925 Verde Systems LLC 11/05/07 10/07/09 0003223108 0003990416 10/07/09
10/07/99 WPOK926 Verde Systems LLC 11/05/07 10/07/09 0003223109 0003990417 10/07/09
10/07/99 WPOK928 Verde Systems LLC 11/05/07 10/07/09 0003223110 0003990418 10/07/09
10/07/99 WPOK929 Verde Systems LLC 11/05/07 10/07/09 0003223111 0003990419 10/07/09
10/07/99 WPOK930 Verde Systems LLC 11/05/07 10/07/09 0003223112 0003990431 10/07/09
10/07/99 WPOK931 Verde Systems LLC 11/05/07 10/07/09 0003223113 0003990424 10/07/09
10/07/99 WPOK932 Verde Systems LLC 11/05/07 10/07/09 0003223114 0003990420 10/07/09
10/07/99 WPOK933 Havens, Warren C 11/05/07 10/07/09 0003223153 0003990366 10/07/09
10/26/07 WQHZ577 Skybridge Spectrum Foundation 0003989107 10/07/09
10/26/07 WQHZ578 Skybridge Spectrum Foundation 0003989150 10/07/09
10/24/07 WQHZ579 Skybridge Spectrum Foundation 0003710186 03/23/09
10/24/07 WQHZ580 Skybridge Spectrum Foundation 0003710256 03/23/09
10/24/07 WQHZ581 Skybridge Spectrum Foundation 0003710187 03/23/09
10/24/07 WQHZ582 Skybridge Spectrum Foundation 0003710266 03/23/09
10/24/07 WQHZ583 Skybridge Spectrum Foundation 0003710188 03/23/09
10/24/07 WQHZ584 Skybridge Spectrum Foundation 0003710189 03/23/09
10/24/07 WQHZ585 Skybridge Spectrum Foundation 0003710277 03/23/09
10/24/07 WQHZ586 Skybridge Spectrum Foundation 0003710283 03/23/09
10/24/07 WQHZ587 Skybridge Spectrum Foundation 0003710190 03/23/09
10/24/07 WQHZ588 Skybridge Spectrum Foundation 0003710298 03/23/09
10/24/07 WQHZ589 Skybridge Spectrum Foundation 0003710191 03/23/09
10/24/07 WQHZ590 Skybridge Spectrum Foundation 0003710257 03/23/09
10/24/07 WQHZ591 Skybridge Spectrum Foundation 0003710299 03/23/09
10/24/07 WQHZ592 Skybridge Spectrum Foundation 0003710192 03/23/09
10/24/07 WQHZ593 Skybridge Spectrum Foundation 0003710193 03/23/09
10/24/07 WQHZ594 Skybridge Spectrum Foundation 0003710194 03/23/09
10/24/07 WQHZ595 Skybridge Spectrum Foundation 0003710195 03/23/09
Federal Communications Commission DA 14-121
23
License
Grant Date Call Sign Licensee Name
First 
Construction 
Deadline
Second 
Construction 
Deadline
Extension 
Request - FCC
File Number
Renewal 
Application -
FCC File 
Number
License 
Expiration 
Date
10/24/07 WQHZ596 Skybridge Spectrum Foundation 0003710284 03/23/09
10/24/07 WQHZ597 Skybridge Spectrum Foundation 0003710297 03/23/09
10/24/07 WQHZ598 Skybridge Spectrum Foundation 0003710196 03/23/09
10/24/07 WQHZ599 Skybridge Spectrum Foundation 0003710197 03/23/09
10/24/07 WQHZ600 Skybridge Spectrum Foundation 0003710198 03/23/09
10/24/07 WQHZ601 Skybridge Spectrum Foundation 0003710258 03/23/09
10/24/07 WQHZ602 Skybridge Spectrum Foundation 0003710300 03/23/09
10/24/07 WQHZ603 Skybridge Spectrum Foundation 0003710199 03/23/09
10/24/07 WQHZ604 Skybridge Spectrum Foundation 0003710200 03/23/09
10/24/07 WQHZ605 Skybridge Spectrum Foundation 0003710201 03/23/09
10/24/07 WQHZ606 Skybridge Spectrum Foundation 0003710273 03/23/09
10/24/07 WQHZ607 Skybridge Spectrum Foundation 0003710285 03/23/09
10/24/07 WQHZ608 Skybridge Spectrum Foundation 0003710202 03/23/09
10/24/07 WQHZ609 Skybridge Spectrum Foundation 0003710203 03/23/09
10/24/07 WQHZ611 Skybridge Spectrum Foundation 0003710204 03/23/09
10/24/07 WQHZ612 Skybridge Spectrum Foundation 0003710259 03/23/09
10/24/07 WQHZ613 Skybridge Spectrum Foundation 0003710278 03/23/09
10/24/07 WQHZ614 Skybridge Spectrum Foundation 0003710267 03/23/09
10/24/07 WQHZ615 Skybridge Spectrum Foundation 0003710205 03/23/09
10/24/07 WQHZ616 Skybridge Spectrum Foundation 0003710301 03/23/09
10/24/07 WQHZ617 Skybridge Spectrum Foundation 0003710206 03/23/09
10/24/07 WQHZ618 Skybridge Spectrum Foundation 0003710207 03/23/09
10/24/07 WQHZ619 Skybridge Spectrum Foundation 0003710286 03/23/09
10/24/07 WQHZ620 Skybridge Spectrum Foundation 0003710208 03/23/09
10/24/07 WQHZ621 Skybridge Spectrum Foundation 0003710209 03/23/09
10/24/07 WQHZ622 Skybridge Spectrum Foundation 0003710260 03/23/09
10/24/07 WQHZ623 Skybridge Spectrum Foundation 0003710210 03/23/09
10/24/07 WQHZ624 Skybridge Spectrum Foundation 0003710268 03/23/09
10/24/07 WQHZ625 Skybridge Spectrum Foundation 0003710211 03/23/09
10/24/07 WQHZ626 Skybridge Spectrum Foundation 0003710212 03/23/09
10/24/07 WQHZ627 Skybridge Spectrum Foundation 0003710279 03/23/09
10/24/07 WQHZ628 Skybridge Spectrum Foundation 0003710287 03/23/09
10/24/07 WQHZ629 Skybridge Spectrum Foundation 0003710213 03/23/09
10/24/07 WQHZ630 Skybridge Spectrum Foundation 0003710274 03/23/09
10/24/07 WQHZ631 Skybridge Spectrum Foundation 0003710214 03/23/09
10/24/07 WQHZ632 Skybridge Spectrum Foundation 0003710296 03/23/09
10/24/07 WQHZ633 Skybridge Spectrum Foundation 0003710302 03/23/09
10/24/07 WQHZ634 Skybridge Spectrum Foundation 0003710215 03/23/09
10/24/07 WQHZ635 Skybridge Spectrum Foundation 0003710216 03/23/09
10/24/07 WQHZ636 Skybridge Spectrum Foundation 0003710217 03/23/09
10/24/07 WQHZ637 Skybridge Spectrum Foundation 0003710218 03/23/09
10/24/07 WQHZ638 Skybridge Spectrum Foundation 0003710288 03/23/09
10/24/07 WQHZ639 Skybridge Spectrum Foundation 0003710269 03/23/09
10/24/07 WQHZ640 Skybridge Spectrum Foundation 0003710219 03/23/09
10/24/07 WQHZ641 Skybridge Spectrum Foundation 0003710220 03/23/09
10/24/07 WQHZ642 Skybridge Spectrum Foundation 0003710221 03/23/09
10/24/07 WQHZ643 Skybridge Spectrum Foundation 0003710261 03/23/09
10/24/07 WQHZ644 Skybridge Spectrum Foundation 0003710303 03/23/09
10/24/07 WQHZ645 Skybridge Spectrum Foundation 0003710222 03/23/09
10/24/07 WQHZ646 Skybridge Spectrum Foundation 0003710223 03/23/09
10/24/07 WQHZ647 Skybridge Spectrum Foundation 0003710224 03/23/09
10/24/07 WQHZ648 Skybridge Spectrum Foundation 0003710275 03/23/09
10/24/07 WQHZ649 Skybridge Spectrum Foundation 0003710289 03/23/09
10/24/07 WQHZ650 Skybridge Spectrum Foundation 0003710225 03/23/09
Federal Communications Commission DA 14-121
24
License
Grant Date Call Sign Licensee Name
First 
Construction 
Deadline
Second 
Construction 
Deadline
Extension 
Request - FCC 
File Number
Renewal 
Application -
FCC File 
Number
License 
Expiration 
Date
10/24/07 WQHZ651 Skybridge Spectrum Foundation 0003710226 03/23/09
10/24/07 WQHZ652 Skybridge Spectrum Foundation 0003710227 03/23/09
10/24/07 WQHZ653 Skybridge Spectrum Foundation 0003710262 03/23/09
10/24/07 WQHZ654 Skybridge Spectrum Foundation 0003710280 03/23/09
10/24/07 WQHZ655 Skybridge Spectrum Foundation 0003710310 03/23/09
10/24/07 WQHZ656 Skybridge Spectrum Foundation 0003710228 03/23/09
10/24/07 WQHZ657 Skybridge Spectrum Foundation 0003710304 03/23/09
10/24/07 WQHZ658 Skybridge Spectrum Foundation 0003710229 03/23/09
10/24/07 WQHZ659 Skybridge Spectrum Foundation 0003710230 03/23/09
10/24/07 WQHZ660 Skybridge Spectrum Foundation 0003710290 03/23/09
10/24/07 WQHZ661 Skybridge Spectrum Foundation 0003710231 03/23/09
10/24/07 WQHZ662 Skybridge Spectrum Foundation 0003710232 03/23/09
10/24/07 WQHZ663 Skybridge Spectrum Foundation 0003710309 03/23/09
10/24/07 WQHZ664 Skybridge Spectrum Foundation 0003710233 03/23/09
10/24/07 WQHZ665 Skybridge Spectrum Foundation 0003710270 03/23/09
10/24/07 WQHZ666 Skybridge Spectrum Foundation 0003710234 03/23/09
10/24/07 WQHZ667 Skybridge Spectrum Foundation 0003710235 03/23/09
10/24/07 WQHZ668 Skybridge Spectrum Foundation 0003710281 03/23/09
10/24/07 WQHZ669 Skybridge Spectrum Foundation 0003710291 03/23/09
10/24/07 WQHZ670 Skybridge Spectrum Foundation 0003710236 03/23/09
10/24/07 WQHZ671 Skybridge Spectrum Foundation 0003710276 03/23/09
10/24/07 WQHZ672 Skybridge Spectrum Foundation 0003710237 03/23/09
10/24/07 WQHZ673 Skybridge Spectrum Foundation 0003710263 03/23/09
10/24/07 WQHZ674 Skybridge Spectrum Foundation 0003710305 03/23/09
10/24/07 WQHZ675 Skybridge Spectrum Foundation 0003710238 03/23/09
10/24/07 WQHZ676 Skybridge Spectrum Foundation 0003710239 03/23/09
10/24/07 WQHZ677 Skybridge Spectrum Foundation 0003710240 03/23/09
10/24/07 WQHZ678 Skybridge Spectrum Foundation 0003710241 03/23/09
10/24/07 WQHZ679 Skybridge Spectrum Foundation 0003710292 03/23/09
10/24/07 WQHZ680 Skybridge Spectrum Foundation 0003710271 03/23/09
10/24/07 WQHZ681 Skybridge Spectrum Foundation 0003710242 03/23/09
10/24/07 WQHZ682 Skybridge Spectrum Foundation 0003710243 03/23/09
10/24/07 WQHZ683 Skybridge Spectrum Foundation 0003710244 03/23/09
10/24/07 WQHZ684 Skybridge Spectrum Foundation 0003710264 03/23/09
10/24/07 WQHZ685 Skybridge Spectrum Foundation 0003710306 03/23/09
10/24/07 WQHZ686 Skybridge Spectrum Foundation 0003710245 03/23/09
10/24/07 WQHZ687 Skybridge Spectrum Foundation 0003710246 03/23/09
10/24/07 WQHZ688 Skybridge Spectrum Foundation 0003710247 03/22/09
10/24/07 WQHZ689 Skybridge Spectrum Foundation 0003710311 03/23/09
10/24/07 WQHZ690 Skybridge Spectrum Foundation 0003710293 03/23/09
10/24/07 WQHZ691 Skybridge Spectrum Foundation 0003710248 03/23/09
10/24/07 WQHZ692 Skybridge Spectrum Foundation 0003710249 03/23/09
10/24/07 WQHZ693 Skybridge Spectrum Foundation 0003710250 03/23/09
10/24/07 WQHZ694 Skybridge Spectrum Foundation 0003710265 03/23/09
10/24/07 WQHZ695 Skybridge Spectrum Foundation 0003710282 03/23/09
10/24/07 WQHZ696 Skybridge Spectrum Foundation 0003710272 03/23/09
10/24/07 WQHZ697 Skybridge Spectrum Foundation 0003710251 03/23/09
10/24/07 WQHZ698 Skybridge Spectrum Foundation 0003710307 03/23/09
10/24/07 WQHZ699 Skybridge Spectrum Foundation 0003710252 03/23/09
10/24/07 WQHZ700 Skybridge Spectrum Foundation 0003710253 03/23/09
10/24/07 WQHZ701 Skybridge Spectrum Foundation 0003710294 03/23/09
10/24/07 WQHZ702 Skybridge Spectrum Foundation 0003710254 03/23/09
10/24/07 WQHZ703 Skybridge Spectrum Foundation 0003710295 03/23/09
10/24/07 WQHZ704 Skybridge Spectrum Foundation 0003710255 03/23/09
Federal Communications Commission DA 14-121
25
License
Grant Date Call Sign Licensee Name
First 
Construction 
Deadline
Second 
Construction 
Deadline
Extension 
Request - FCC 
File Number
Renewal 
Application -
FCC File 
Number
License 
Expiration 
Date
10/24/07 WQHZ705 Skybridge Spectrum Foundation 0003710308 03/23/09
10/24/07 WQHZ706 Skybridge Spectrum Foundation 0003989108 10/07/09
10/24/07 WQHZ707 Skybridge Spectrum Foundation 0003989152 10/07/09
10/24/07 WQHZ708 Skybridge Spectrum Foundation 0003989109 10/07/09
10/24/07 WQHZ709 Skybridge Spectrum Foundation 0003989110 10/07/09
10/24/07 WQHZ710 Skybridge Spectrum Foundation 0003989159 10/07/09
10/24/07 WQHZ711 Skybridge Spectrum Foundation 0003989163 10/07/09
10/24/07 WQHZ712 Skybridge Spectrum Foundation 0003989111 10/07/09
10/24/07 WQHZ713 Skybridge Spectrum Foundation 0003989155 10/07/09
10/24/07 WQHZ714 Skybridge Spectrum Foundation 0003989112 10/07/09
10/24/07 WQHZ715 Skybridge Spectrum Foundation 0003989151 10/07/09
10/24/07 WQHZ716 Skybridge Spectrum Foundation 0003989170 10/07/09
10/24/07 WQHZ717 Skybridge Spectrum Foundation 0003989113 10/07/09
10/24/07 WQHZ718 Skybridge Spectrum Foundation 0003989114 10/07/09
10/24/07 WQHZ719 Skybridge Spectrum Foundation 0003989115 10/07/09
10/24/07 WQHZ720 Skybridge Spectrum Foundation 0003989116 10/07/09
10/24/07 WQHZ721 Skybridge Spectrum Foundation 0003989164 10/07/09
10/24/07 WQHZ722 Skybridge Spectrum Foundation 0003989153 10/07/09
10/24/07 WQHZ723 Skybridge Spectrum Foundation 0003989117 10/07/09
10/24/07 WQHZ724 Skybridge Spectrum Foundation 0003989118 10/07/09
10/24/07 WQHZ725 Skybridge Spectrum Foundation 0003989119 10/07/09
10/24/07 WQHZ726 Skybridge Spectrum Foundation 0003989176 10/07/09
10/24/07 WQHZ727 Skybridge Spectrum Foundation 0003989171 10/07/09
10/24/07 WQHZ728 Skybridge Spectrum Foundation 0003989120 10/07/09
10/24/07 WQHZ729 Skybridge Spectrum Foundation 0003989121 10/07/09
10/24/07 WQHZ730 Skybridge Spectrum Foundation 0003989122 10/07/09
10/24/07 WQHZ731 Skybridge Spectrum Foundation 0003989156 10/07/09
10/24/07 WQHZ732 Skybridge Spectrum Foundation 0003989165 10/07/09
10/24/07 WQHZ733 Skybridge Spectrum Foundation 0003989123 10/07/09
10/24/07 WQHZ734 Skybridge Spectrum Foundation 0003989124 10/07/09
10/24/07 WQHZ735 Skybridge Spectrum Foundation 0003989125 10/07/09
10/24/07 WQHZ736 Skybridge Spectrum Foundation 0003989162 10/07/09
10/24/07 WQHZ737 Skybridge Spectrum Foundation 0003989160 10/07/09
10/24/07 WQHZ738 Skybridge Spectrum Foundation 0003989154 10/07/09
11/01/07 WQHZ739 Skybridge Spectrum Foundation 0003989126 10/07/09
11/01/07 WQHZ740 Skybridge Spectrum Foundation 0003989172 10/07/09
11/01/07 WQHZ741 Skybridge Spectrum Foundation 0003989127 10/07/09
11/01/07 WQHZ742 Skybridge Spectrum Foundation 0003989128 10/07/09
11/01/07 WQHZ743 Skybridge Spectrum Foundation 0003989166 10/07/09
11/01/07 WQHZ744 Skybridge Spectrum Foundation 0003989129 10/07/09
11/01/07 WQHZ745 Skybridge Spectrum Foundation 0003989173 10/07/09
11/01/07 WQHZ746 Skybridge Spectrum Foundation 0003989130 10/07/09
11/01/07 WQHZ747 Skybridge Spectrum Foundation 0003989131 10/07/09
11/01/07 WQHZ748 Skybridge Spectrum Foundation 0003989132 10/07/09
11/01/07 WQHZ749 Skybridge Spectrum Foundation 0003989133 10/07/09
11/01/07 WQHZ750 Skybridge Spectrum Foundation 0003989134 10/07/09
11/01/07 WQHZ751 Skybridge Spectrum Foundation 0003989167 10/07/09
11/01/07 WQHZ752 Skybridge Spectrum Foundation 0003989135 10/07/09
11/01/07 WQHZ753 Skybridge Spectrum Foundation 0003989136 10/07/09
11/01/07 WQHZ754 Skybridge Spectrum Foundation 0003989161 10/07/09
11/01/07 WQHZ755 Skybridge Spectrum Foundation 0003989174 10/07/09
11/01/07 WQHZ756 Skybridge Spectrum Foundation 0003989157 10/07/09
11/01/07 WQHZ757 Skybridge Spectrum Foundation 0003989137 10/07/09
11/01/07 WQHZ758 Skybridge Spectrum Foundation 0003989138 10/07/09
Federal Communications Commission DA 14-121
License
Grant Date Call Sign Licensee Name
First 
Construction 
Deadline
Second 
Construction 
Deadline
Extension 
Request - FCC 
File Number
Renewal 
Application -
FCC File 
Number
License 
Expiration 
Date
11/01/07 WQHZ759 Skybridge Spectrum Foundation 0003989139 10/07/09
11/01/07 WQHZ760 Skybridge Spectrum Foundation 0003989140 10/07/09
11/01/07 WQHZ761 Skybridge Spectrum Foundation 0003989168 10/07/09
11/01/07 WQHZ762 Skybridge Spectrum Foundation 0003989141 10/07/09
11/01/07 WQHZ763 Skybridge Spectrum Foundation 0003989142 10/07/09
11/01/07 WQHZ764 Skybridge Spectrum Foundation 0003989143 10/07/09
11/01/07 WQHZ765 Skybridge Spectrum Foundation 0003989175 10/07/09
11/01/07 WQHZ766 Skybridge Spectrum Foundation 0003989144 10/07/09
11/01/07 WQHZ767 Skybridge Spectrum Foundation 0003989145 10/07/09
11/01/07 WQHZ768 Skybridge Spectrum Foundation 0003989146 10/07/09
11/01/07 WQHZ769 Skybridge Spectrum Foundation 0003989169 10/07/09
11/01/07 WQHZ770 Skybridge Spectrum Foundation 0003989147 10/07/09
11/01/07 WQHZ771 Skybridge Spectrum Foundation 0003989158 10/07/09
11/01/07 WQHZ772 Skybridge Spectrum Foundation 0003989148 10/07/09
11/01/07 WQHZ773 Skybridge Spectrum Foundation 0003989149 10/07/09
10/24/07 WQHZ610 Skybridge Spectrum Foundation 03/23/09