Federal Communications Commission DA 14-623
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Improving Public Safety Communications in the 
800 MHz Band
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WT Docket No. 02-55
Adopted:  May 9, 2014 Released: May 9, 2014
ORDER
By the Deputy Chief, Policy and Licensing Division, Public Safety and Homeland Security Bureau
I. INTRODUCTION
1. Under consideration is the May 6, 2014 Request for Extension of Time (Request) filed by 
Orange County, California (County) seeking an extension of time until July 14, 2014 to submit a cost 
estimate for the reconfiguration of the County’s 800 MHz communications system.  For the reasons set 
out below, we grant the County’s request.
II. DISCUSSION
2. Earlier, the Public Safety and Homeland Security Bureau granted the County an extension of 
time until June 22, 2014 to submit a cost estimate to Sprint Corporation (Sprint) and the 800 MHz 
Transition Administrator (TA).  The County’s assessment of when the cost estimate would be provided 
was premised on its vendor, Motorola Solutions, Inc. (Motorola), providing the County with a Statement 
of Work by May 22, 2014.1 Recently, Motorola informed the County that it would be unable to meet the 
May 22, 2014 delivery date for the Statement of Work.  Motorola attributes its inability to meet the 
delivery date to the County’s system being “one of the [most] challenging Rebanding Planning projects 
we have done.”2 On May 2, 2014 The Motorola representative informed the County that “several 
Engineering deliverables [ ] remain incomplete at this time and [ ] I do not believe it is possible to 
finalize our proposal with accuracy and completeness in the allotted time.”3 Motorola commits to 
delivery of the Statement of Work to the County “no later than June 13th, certainly quicker if possible.”4  
The County submits that it will take a month to review and revise the Statement of Work before filing it 
with Sprint and the TA.5
  
1 Request at 1.
2 Id. at attachment (email from Randy Brooks, Motorola, to Denis Marin, et al., May 2, 2014).
3 Id.
4 Id.
5 Request at 1.
Federal Communications Commission DA 14-623
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3. Section 1.46(a) of the Commission’s rules6 states that [i]t is the policy of the Commission 
that extensions of time shall not be routinely granted.  The “import of that rule is especially relevant to 
800 MHz rebanding where delay in rebanding by one licensee can cause a ‘domino effect’ delay in the 
rebanding efforts of other licensees that have met the Commission’s 800 MHz band reconfiguration 
deadlines with a consequent delay of the overall program. We therefore afford a high degree of scrutiny 
to the reasons licensees advance for extensions of time.”7
III. DECISION
4. We have applied the requisite high degree of scrutiny to the County’s Request and find that 
the County has exercised diligence and credit the County’s representation that it exerted “best efforts to 
timely supply all information necessary for the creation of the Statement of Work.”8 It is apparent that 
the scope of effort required to produce the Statement of Work has overtaxed Motorola’s resources 
through no fault of the County.  While it is problematic whether the County actually requires one month 
to review, revise if necessary, and accept the Statement of Work, we take notice of the size of the 
County’s system and credit its representation that the time requested is necessary.
IV. ORDERING CLAUSE
5. Accordingly IT IS ORDERED that that Request for Extension of Time filed May 6, 2014 by 
Orange County, California IS GRANTED.
6. IT IS FURTHER ORDERED that Orange County shall file its cost estimate with Sprint 
Corporation and the 800 MHz Transition Administrator on or before July 14, 2014.
7. This action is taken under delegated authority pursuant to Sections 0.191 and 0.392 of the 
Commission’s rules, 47 C.F.R. §§ 0.191, 0.392.
FEDERAL COMMUNICATIONS COMMISSION 
Michael J. Wilhelm
Deputy Chief, Policy and Licensing Division
Public Safety and Homeland Security Bureau 
  
6 47 C.F.R. § 1.46(a).
7 Regents of the University of California, Order, 28 FCC Rcd 15920, 15921 (PSHSB 2013).
8 Request at 2.