Federal Communications Commission DA 15-1064 Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Request by Itron, Inc. for Waivers of the Commission’s Rules ) ) ) ) ) ) ) WT Docket No. 13-195 ORDER ON RECONSIDERATION Adopted: September 25, 2015 Released: September 25, 2015 By the Chief, Mobility Division, Wireless Telecommunications Bureau: I. INTRODUCTION 1. This Order addresses a petition by Itron, Inc. (Itron) 1 for reconsideration of our denial 2 of Itron’s request for waivers 3 of certain of the Commission's rules 4 to operate an advanced smart grid half- duplex, non-paging communications using its licenses in the 931 MHz band. As explained below, we grant the Petition in part, and otherwise deny, and therefore grant a waiver of sections 22.355, 22.515, and 22.531 for certain Itron licenses. 5 II. BACKGROUND 1 Petition for Reconsideration filed on March 2, 2015, by Itron, Inc. (Petition). 2 Letter from Roger Noel, Chief, Mobility Division, Wireless Telecommunications Bureau, to Ms. Laura Stefani and Mr. Joseph A. Godles, Goldberg, Godles, Wiener & Wright LLP, 30 FCC Rcd 137 (Jan. 13, 2015) (Waiver Denial). 3 Itron, Inc. Request for Waiver, WT Docket No. 13-195, filed Dec. 17, 2012 (Waiver Request). The Waiver Request is attached to the Universal Licensing System (ULS) record for each license listed in Attachment 1. See http://wireless.fcc.gov/uls/index.htm?job=home. 4 In its waiver request, Itron sought waiver of 47 C.F.R. §§ 22.355, 22.515, 22.531, and 22.561. In the Public Notice the Commission issued in connection with Itron’s waiver request, we stated that “[i]t appears to us that section 22.561 does not apply to Itron’s requested waiver, since that rule section does not apply to 931 MHz band paging operations.” Wireless Telecommunications Bureau Seeks Comment on Itron, Inc. Request for Waivers of Part 22 Rules to Facilitate Provision of Non-Paging Operations Over 931 MHz Licenses, Public Notice, WT Docket No. 13- 195, 28 FCC Rcd 11829, 11829 (2013) (Itron Public Notice). We further stated that “it does appear that Itron might require a waiver of section 22.531 in order to conduct its half-duplex operations, and we therefore will treat Itron’s filings as seeking a waiver of section 22.531 (instead of section 22.561) to the extent necessary.” Id. In addition, in the Petition, Itron seeks waiver of sections 22.355, 22.515, and 22.531, but not section 22.561. We therefore continue to treat Itron’s as seeking a waiver of section 22.531 rather than section 22.561 where applicable. 5 47 C.F.R. §§ 22.355, 22.515, and 22.531. 22. In 2010, the Wireless Telecommunications Bureau (Bureau) auctioned 9,603 geographic- area paging licenses, with 1,851 of those licenses being in the upper paging bands (929-931 MHz). 6 In announcing Auction 87, the Bureau explained that paging incumbent licenses existed in the bands, and these “[i]ncumbent (non-geographic) paging licensees operating under their existing authorizations are entitled to full protection from co-channel interference.” 7 Itron was the winning bidder in Auction 87 for 155 Major Economic Areas paging licenses in the 931 MHz band, 8 and the Bureau granted the licenses on November 3, 2010. 9 3. On December 17, 2012, pursuant to sections 1.3 and 1.925 of the Commission’s rules, Itron filed the Waiver Request so that it may use its paging licenses to support and improve its automatic meter reading (AMR) and advanced metering infrastructure (AMI) systems, which are smart grid components. 10 In the Waiver Request, Itron requested waivers of sections 22.515 11 and 22.531, 12 to the extent necessary, to allow it to engage in half-duplex transmissions to facilitate transmissions both to and from Itron’s meter module end points. 13 Taken together, sections 22.515 and 22.531 limit the operation of channels in the 931 MHz band to base transmitters 14 that provide paging services, whereas Itron proposes to utilize non-base transmitters to offer a non-paging data service; accordingly, Itron sought a waiver of sections 22.515 and 22.531. 15 4. Itron also requested a waiver of section 22.355 16 to permit its fixed and mobile stations that operate with an effective radiated power (ERP) of less than 2 watts to be subject to a frequency 6 See Auction of Lower & Upper Paging Bands Licenses Scheduled for May 25, 2010, Public Notice, 25 FCC Rcd 6156 (2009) (Auction 87 Announcement PN). 7 Auction 87 Announcement PN at 6157 ¶ 6 (citing Revision of Part 22 and Part 90 of the Commission’s Rules to Facilitate Future Development of Paging Systems, Implementation of Section 309(j) of the Communications Act – Competitive Bidding, WT Docket No. 96-18, Memorandum Opinion and Order on Reconsideration and Third Report and Order, 14 FCC Rcd 10030, 10059-60 ¶¶ 42-44 (1999); Revision of Part 22 and Part 90 of the Commission’s Rules to Facilitate Future Development of Paging Systems, Implementation of Section 309(j) of the Communications Act – Competitive Bidding, WT Docket No. 96-18, Second Report and Order and Further Notice of Proposed Rulemaking, 12 FCC Rcd 2732, 2764 ¶¶ 57-58 (1997); 47 C.F.R. § 22.503(i)). 8 See Auction of Lower & Upper Paging Bands Licenses Closes Winning Bidders Announced for Auction 87, Public Notice, 25 FCC Rcd 18164 (2010). 9 See Wireless Telecommunications Bureau Grants Lower & Upper Paging Bands Licenses, Public Notice, 25 FCC Rcd 15324 (2010). 10 See Waiver Request at 1, 2. Specifically, Itron seeks “to provide service, on a non-common carrier basis, to support fixed and mobile functions, including smart grid functions, such as system monitoring, system control, and smart metering.” Id. at 2. 11 Section 22.515 provides that, for all paging services, “[m]obile stations may communicate only with and through base stations. Base stations may communicate only with mobile stations and receivers on land or surface vessels.” 47 C.F.R. § 22.515. 12 Section 22.531 provides that “[t]he following channels [specifically including 931 MHz frequencies] are allocated for assignment to base transmitters that provide paging service . . . .” 47 C.F.R. § 22.531. 13 See Waiver Request at 3. 14 Section 22.99 defines a base transmitter as “[a] stationary transmitter that provides radio telecommunications service to mobile and/or fixed receivers, including those associated with mobile stations.” 15 See Waiver Request at 3-7. 16 Section 22.355 of the Commission’s rules requires that, as relevant to Itron’s proposed 931 MHz band operations, the carrier frequency of each transmitter must satisfy a frequency tolerance limit of 1.5 ppm. 47 C.F.R. § 22.355. 3tolerance of 5 ppm rather than 1.5 ppm. 17 Itron stated that its planned system architecture would consist of: (1) fixed and mobile readers that generally operate with an ERP of 40 watts or less, and that will always operate with an ERP of 100 watts or less, and (2) customer-premises end points (EPs) that are located on utility meters and that will transmit to the readers at a very low power of between 0.5 to 2 watts ERP. 18 Itron argued that, because these power levels are well below the maximum power that is permitted under the 931 MHz paging rules, the risk for interference to co-channel users of the 931 MHz band will be no more than the risk of interference from other licensed one-way paging systems. 19 Specifically, Itron stated that “[a]lthough the rules permit operation at up to 3500 watts ERP, Itron’s readers typically will operate with an ERP of 40 watts or less, and never will operate with an ERP above 100 watts[,] [and] [t]he power levels for EPs will be even lower, on the order of 0.5 to 2 watts ERP.” 20 Itron further argued that even with a frequency tolerance of 5 ppm rather than 1.5 ppm, its low-power, battery-powered EPs would afford as much or more protection to adjacent channels as devices that satisfy the 1.5 ppm standard. 21 5. USA Mobility, Inc. opposed the Waiver Request, claiming that the proposed waivers would pose a potentially serious risk of interference to USA Mobility’s paging systems. 22 USA Mobility argued that Itron did not provide enough detail about how its proposed system would operate, and therefore USA Mobility could not ascertain how its own operations would be affected. 23 For example, USA Mobility states that Itron does not specify what type of access methodology will be used by end- point devices communicating with readers, nor does Itron make clear whether the EPs might act as repeaters. 24 USA Mobility also stated its concern “that Itron’s proposed half-duplex transmissions could experience interference from USA Mobility’s high-powered paging transmissions – and that Itron in turn would seek to limit USA Mobility’s operations in some manner.” 25 In addition, USA Mobility argued that Itron’s proposed use is a fundamental change to the technical rules that should be accomplished through a rulemaking rather than by waiver. 26 6. On January 13, 2015, the Bureau denied the Waiver Request, finding that, despite Itron’s references to regulatory power limits, it was not clear how Itron would protect its co-channel site-based incumbents or co-channel geographic area licensees from harmful interference. 27 We therefore found that Itron had “not shown that a waiver here would be consistent with the underlying purpose of the rules it seeks to waive, namely interference protection to other licensees.” 28 17 See Waiver Request at 9. 18 See id. at 3-4. 19 See id. at 5-7. 20 Id. at 6. 21 See id. at 9-11. 22 See Comments of USA Mobility, Inc., WT Docket No. 13-195, filed Sept. 9, 2013, at 4-7 (USA Mobility Opposition). 23 See id. at 4-7. 24 See id. at 4-5. 25 Id. at 5. 26 Id. at 9-11. 27 Waiver Denial, 30 FCC Rcd at 141. We did, however, find that Itron had demonstrated how it would provide protection to adjacent channel licensees. Id. 28 Id. 47. On February 12, 2015, in accordance with section 1.106 of the Commission’s rules, 29 Itron filed the Petition seeking reconsideration of our decision. In the Petition, Itron claims that its fixed and mobile readers (which serve as base stations) and its EPs all will observe the co-channel protection requirements for 931 MHz paging system base stations as set forth in sections 22.537 30 and 22.503 31 of the Commission’s rules. 32 As such, if the interfering contour of one of Itron’s readers and/or EPs overlaps with the service contour of a co-channel base station in an adjacent market, then Itron will coordinate with the adjacent market licensee in accordance with section 22.503(h). 33 In addition, Itron states that it will comply with section 22.503(i) by applying this interfering contour/service contour methodology for its fixed and mobile reader stations and EPs to protect co-channel site-based incumbent licensees. 34 Itron further states that its mobile readers “have GPS functionality that enables Itron to program protection zones for them to observe based on interfering contour/service contour overlaps and the terms of coordination agreements Itron enters into with the licensees of co-channel stations.” 35 8. Spok, Inc. (Spok), formerly known as USA Mobility, filed an opposition to the Petition reiterating its previous comments, stating that “[b]ecause Itron has merely rehashed its unsupported assertion that its proposed operations will not result in harmful interference, while failing to grapple with the other fundamental flaws that preclude grant of a waiver, the Bureau should summarily deny Itron’s Petition.” 36 Spok also contends that “one-way paging systems simply were not designed to operate in an environment with mobile transmitters. While fixed base stations are sufficiently removed from one another to prevent harmful interference, Itron’s operation of mobile transmitters in proximity to paging devices may well cause critical paging messages to be dropped. Unlike the case with base-station interference, Spok would be unable to detect and respond to such intermittent interference from mobile readers because its source would be impossible to identify.” 37 Spok also argues that Itron fails to justify a waiver here because it does not show that it lacks reasonable alternatives for operating a two-way communications network. 38 Additionally, Spok argues that the Petition does not meet the procedural criteria for reconsideration under section 1.106 of our rules 39 because it merely supplements Itron’s previous technical showing. 40 9. Itron filed comments in reply to Spok 41 reiterating its contention that it “will provide at least as much protection to co-channel stations as the rules contemplate” and that “in practice, by virtue of low power levels, limited duty cycles, and other factors, its system will be more protective of co-channel 29 Id. 30 47 C.F.R § 22.537. Section 22.537 provides the technical criteria for 931 MHz licensees to provide interference protection to co-channel licensees. 31 47 C.F.R. § 22.503. Section 22.503 provides service rules for Part 22 paging geographic licensees. 32 Petition at 4-5. 33 Id. 34 Id. 35 Id. at 5. 36 Opposition of Spok, Inc., WT Docket No. 13-195, filed Sept. 9, 2013 at 1 (Spok Opposition). 37 Id. at 3. 38 Id. 47 C.F.R. § 1.925(b)(3)(ii) states that the Commission may grant a request for waiver if “the applicant has no reasonable alternative.” 39 47 C.F.R. § 1.106. 40 Spok Opposition at 2. 41 Reply of Itron, Inc., WT Docket No. 13-195, filed March 2, 2015 (Itron Reply). 5stations than a maximum-facility base station in a traditional one-way paging system.” 42 It also stated that it does need to show that it has no reasonable alternative to a waiver because it is seeking a waiver under sections 1.3 43 and 1.925(b)(3)(i) 44 of our rules rather than section 1.925(b)(3)(ii). 45 Finally, Itron counters that it “did not just repeat what it had said before and it did not make a new interference argument. Rather, Itron responded to the Bureau’s concerns by clarifying how it will avoid co-channel interference.” 46 III. DISCUSSION 10. The Commission’s rules require that a petition for reconsideration shall “state with particularity the respects in which a petitioner believes the action taken should be changed” and must specifically state the relief sought. 47 A petition for reconsideration that relies on facts or arguments not previously presented to the Commission may be granted where it is determined that consideration of the facts or arguments relied upon is “required in the public interest.” 48 Pursuant to section 1.925 of the Commission’s rules, 49 waiver may be granted if the petitioner establishes that: (1) the underlying purpose of the rule(s) would not be served or would be frustrated by application to the instant case, and the grant of the waiver would be in the public interest; or (2) in light of unique or unusual factual circumstances, application of the rule(s) would be inequitable, unduly burdensome or contrary to the public interest, or the applicant has no reasonable alternative. 50 The Commission also may waive any provision of its rules if good cause is shown. 51 In this case, Itron has requested waiver under the first prong of section 1.925(b)(3), as well as section 1.3. We agree with Itron that, in compliance with our rules, it has clarified its previous statement that it would provide at least as much protection as our Part 22 paging rules require 52 by specifying to which service rules it referred and elucidating that it will treat all of its readers and EPs as base stations under the rules. As described below, we find that the underlying purpose of sections 22.355, 22.515, and 22.531 of the Commission's rules would not be frustrated by granting waiver in the instant case. 11. As we stated in the Waiver Denial, “[t]aken together, the rules that govern the operation of 931 MHz systems provide protection to co-channel site-based incumbents, co-channel geographic licensees, and adjacent-channel licensees from inference caused by a 931 MHz licensee.” 53 In this case, Spok, has opposed the Waiver Request and Petition due to the possibility of interference to its systems. 42 Itron Reply at 2. 43 47 C.F.R. § 1.3. 44 47 C.F.R. § 1.925(b)(3)(i). 45 See Itron Reply at 6. 46 Id. at 5. 47 47 C.F.R. § 1.106(d)(1). 48 See 47 C.F.R. § 1.106(c)(2). Itron states that is not presenting new facts or arguments and is “only is clarifying the manner in which it will protect co-channel licensees . . . [but] that consideration of the facts and arguments presented in this Petition is appropriate because it is in the public interest.” Petition at 1, n. 3. 49 47 C.F.R. § 1.925. 50 47 C.F.R. § 1.925(b)(3). 51 47 C.F.R. § 1.3. 52 See supra note 19. Tables E-1 (service contour) and E-2 (interfering contour) of 47 C.F.R. § 22.537 permit operation at up to 3500 watts ERP. 53 Waiver Denial, 30 FCC Rcd at 140. 6Based upon the clarification in the Petition that Itron will provide protection per sections 22.503 and 22.537, the Bureau conducted an interference analysis of how Spok’s Part 22 paging licenses 54 would be impacted by Itron’s proposed operations. For Spok’s co-channel Part 22 paging site-based licenses, we plotted the largest possible service 55 and interference 56 contours under section 22.537 and then analyzed the potential for interference from each of Itron’s market areas. The analysis took into consideration the distance between the licensed geographic service area of Itron and Spok’s licenses and the channel spacing, coupled with the fact that pursuant to section 22.503(h), operations outside the licensed geographic areas require consent of the relevant co-channel licensee. The Mobility Division determined that out of 155 of Itron’s licenses, 128 will not cause interference to Spok’s licenses, regardless of whether Itron’s transmitters are fixed or mobile. 57 This approach provides Spok the same protections under our rules as if any of Itron’s readers and EPs – including those that are mobile – actually are base stations. 12. The Commission long has encouraged flexible and innovative use of Part 22 paging spectrum. 58 More recently, the Bureau sought comment on how it might update the Part 22 paging rules to provide flexibility in the types of uses and technologies that can operate on these channels, recognizing that additional technical and operational flexibility may promote more intensive use of these paging licenses, benefiting users nationwide. 59 The Bureau stated that “[s]uch an update could result in licensees deploying innovative technologies, deploying narrow band equipment, or using offset frequencies if they hold adjacent channel blocks.” 60 We find that Itron’s proposed use of its Part 22 paging licenses meets the Commission’s goals of fostering technological innovation and is in the public interest. 13. With regard to these 128 licenses, listed in Attachment 3, we find that the underlying purpose of sections 22.355, 22.515, and 22.531 would not be frustrated by waiver in this case. And, as stated above, we also find that it is in the public interest to grant a waiver of these rules so that Itron may implement its smart grid technology. In addition, as we have found Itron has met the waiver standard of section 1.925(b)(3)(i), we need not assess it under section 1.925(b)(3)(ii), as Spok argues. In light of all of the above, we find reconsideration here proper under our rules, and, as such, we find that a waiver of sections 22.355, 22.515, and 22.531 is warranted under the circumstances presented. 14. We also disagree with Spok’s contention that this essentially is a rulemaking by waiver. The fact pattern in this case is unique, and Itron’s proposal is a novel application of current technology in this band. Further, this Order is not an “agency statement ... of future effect” such as would constitute a 54 The Bureau used the Part 22 paging licenses assigned to Spok in the Universal Licensing System. The complete list of licenses is in Attachment 2. 55 47 C.F.R. § 22.537, Table E-1. This created a contour with a radius of 83.7 kilometers. 56 47 C.F.R. § 22.537, Table E-2. This created a contour with a radius of 191.5 kilometers. 57 We also determined the reverse, i.e., that Spok’s operations are highly unlikely to cause interference to these 128 Itron licenses. 58 See, e.g., Revision of Part 22 and Part 90 of the Commission’s Rules to Facilitate Future Development of Paging Systems, Second Report and Order and Further Notice of Proposed Rulemaking, 12 FCC Rcd 2732 (1997). 59 See Wireless Telecommunications Bureau Reminds Paging & Radiotelephone Serv. Licensees of Certain Technical Rules & Seeks Comment on the Need for Technical Flexibility, Public Notice, 29 FCC Rcd 12673, 12674 (2014) (Paging Public Notice). 60 Id. 7rule under the Administrative Procedure Act. 61 Rather, this waiver is granted on a case-specific basis and is well within the scope of the Bureau’s delegated authority. 62 15. Finally, for the remaining 27 Itron licenses, we find that Itron still has not sufficiently shown how it would protect from interference its co-channel site-based incumbents and co-channel geographic licensees. For these licenses, listed in Attachment 4, we affirm our decision in the Waiver Denial and these 27 licenses are excluded from this waiver. 16. This waiver is specifically conditioned on the following: (1) This waiver is limited to the Itron licenses listed in Attachment 3. (2) The licenses listed in Attachment 4 are excluded from this waiver. (3) Itron must provide interference protection to its co-channel site-based incumbents, co-channel geographic licensees, and adjacent-channel licensees by treating all of its readers and EPs – including those that are mobile – as base stations under the Commission’s rules. (4) Itron must operate its system as described in its Waiver Request and Petition. (5) Any readers (cell control units, mobile collectors, or hand held mobile devices) operated in connection with this waiver must be operated only within Itron’s licensed areas that are covered by this waiver. (6) Itron must exercise effective operational control over any covered mobile stations receiving service through their fixed stations. (7) If Itron receives a report that station(s) operating in the areas covered by this waiver are causing harmful interference to co-channel site-based incumbents, co-channel geographic licensees, or adjacent-channel licensees, it shall immediately suspend operation under this waiver of such station(s) except for test transmissions to identify and eliminate the interference. Itron may resume operation under this waiver of such station(s) after the interference has been successfully mitigated. 17. Accordingly, IT IS ORDERED that, pursuant to Sections 4(i), 303(r), and 405 of the Communications Act of 1934, as amended, 47 U.S.C. §§ 154(i), 303(r), 405, and sections 0.331, 1.3, 1.106, and 1.925 of the Commission’s Rules, 47 C.F.R. §§ 0.331, 1.3, 1.106, 1.925, the Petition for Reconsideration filed by Itron, Inc., on March 2, 2015, is GRANTED IN PART AND OTHERWISE DENIED, as described above. FEDERAL COMMUNICATIONS COMMISSION Roger S. Noel Chief, Mobility Division Wireless Telecommunications Bureau 61 See 5 U.S.C. § 551(4). 62 See 47 C.F.R. § 0.131. 8 9Attachment 1 List of Itron 931 MHz Licenses Call Sign Market Code Channel Block 1. WQMX694 MEA001 AL 2. WQMX695 MEA001 AM 3. WQMX696 MEA001 AN 4. WQMX697 MEA002 AP 5. WQMX698 MEA002 AQ 6. WQMX699 MEA002 BK 7. WQMX700 MEA003 AC 8. WQMX701 MEA003 AF 9. WQMX702 MEA003 AG 10. WQMX703 MEA004 AP 11. WQMX704 MEA004 AZ 12. WQMX705 MEA004 BK 13. WQMX706 MEA005 AJ 14. WQMX707 MEA005 AM 15. WQMX708 MEA005 AN 16. WQMX709 MEA005 BK 17. WQMX710 MEA006 AP 18. WQMX711 MEA006 AQ 19. WQMX712 MEA006 BF 20. WQMX713 MEA007 AC 21. WQMX714 MEA007 AG 22. WQMX715 MEA007 AM 23. WQMX716 MEA008 AW 24. WQMX717 MEA008 AY 25. WQMX718 MEA008 AZ 26. WQMX719 MEA009 AA 27. WQMX720 MEA009 AB 28. WQMX721 MEA009 AC 29. WQMX722 MEA010 AA 30. WQMX723 MEA010 AB 31. WQMX724 MEA010 AC 32. WQMX725 MEA011 AG 33. WQMX726 MEA011 AM 34. WQMX727 MEA011 BD 35. WQMX728 MEA012 AC 36. WQMX729 MEA012 AJ 37. WQMX730 MEA012 AK 38. WQMX731 MEA012 AL 39. WQMX732 MEA013 AB 40. WQMX733 MEA013 AC 41. WQMX734 MEA013 AG 42. WQMX735 MEA014 AB 43. WQMX736 MEA014 AC 44. WQMX737 MEA014 AG 10 45. WQMX738 MEA015 AF 46. WQMX739 MEA015 AG 47. WQMX740 MEA015 AH 48. WQMX741 MEA015 AI 49. WQMX742 MEA016 AB 50. WQMX743 MEA016 AY 51. WQMX744 MEA016 AZ 52. WQMX745 MEA016 BK 53. WQMX746 MEA017 AA 54. WQMX747 MEA017 AB 55. WQMX748 MEA017 AC 56. WQMX749 MEA018 AG 57. WQMX750 MEA018 BI 58. WQMX751 MEA018 BK 59. WQMX752 MEA019 AP 60. WQMX753 MEA019 BB 61. WQMX754 MEA019 BC 62. WQMX755 MEA020 AF 63. WQMX756 MEA020 AG 64. WQMX757 MEA020 BJ 65. WQMX758 MEA020 BK 66. WQMX759 MEA021 AA 67. WQMX760 MEA021 AB 68. WQMX761 MEA021 AO 69. WQMX762 MEA022 AA 70. WQMX763 MEA022 AB 71. WQMX764 MEA022 AC 72. WQMX765 MEA023 AA 73. WQMX766 MEA023 AB 74. WQMX767 MEA023 AC 75. WQMX768 MEA024 BH 76. WQMX769 MEA024 BI 77. WQMX770 MEA024 BJ 78. WQMX771 MEA025 AA 79. WQMX772 MEA025 AB 80. WQMX773 MEA025 AC 81. WQMX774 MEA026 AA 82. WQMX775 MEA026 AB 83. WQMX776 MEA026 AG 84. WQMX777 MEA027 AA 85. WQMX778 MEA027 AG 86. WQMX779 MEA027 AJ 87. WQMX780 MEA027 AK 88. WQMX781 MEA028 AA 89. WQMX782 MEA028 AB 90. WQMX783 MEA028 AC 91. WQMX784 MEA028 AG 11 92. WQMX785 MEA029 AA 93. WQMX786 MEA029 AB 94. WQMX787 MEA029 AF 95. WQMX788 MEA030 AA 96. WQMX789 MEA030 AB 97. WQMX790 MEA030 AK 98. WQMX791 MEA031 AA 99. WQMX792 MEA031 AE 100. WQMX793 MEA031 AJ 101. WQMX794 MEA031 AK 102. WQMX795 MEA032 AE 103. WQMX796 MEA032 AG 104. WQMX797 MEA032 AW 105. WQMX798 MEA033 AF 106. WQMX799 MEA033 AZ 107. WQMX800 MEA034 AA 108. WQMX801 MEA034 AB 109. WQMX802 MEA034 AF 110. WQMX803 MEA035 BE 111. WQMX804 MEA035 BI 112. WQMX805 MEA035 BK 113. WQMX806 MEA036 AA 114. WQMX807 MEA036 AB 115. WQMX808 MEA036 AC 116. WQMX809 MEA037 BC 117. WQMX810 MEA037 BD 118. WQMX811 MEA037 BE 119. WQMX812 MEA038 AD 120. WQMX813 MEA038 AE 121. WQMX814 MEA038 AW 122. WQMX815 MEA039 AD 123. WQMX816 MEA039 AI 124. WQMX817 MEA040 AL 125. WQMX818 MEA040 AY 126. WQMX819 MEA040 BC 127. WQMX820 MEA040 BF 128. WQMX821 MEA041 AJ 129. WQMX822 MEA041 AK 130. WQMX823 MEA041 AL 131. WQMX824 MEA041 BK 132. WQMX825 MEA042 AJ 133. WQMX826 MEA042 AM 134. WQMX827 MEA042 BE 135. WQMX828 MEA043 AI 136. WQMX829 MEA043 AJ 137. WQMX830 MEA043 AN 138. WQMX831 MEA043 AW 12 139. WQMX832 MEA044 AD 140. WQMX833 MEA044 AO 141. WQMX834 MEA044 AW 142. WQMX835 MEA045 AV 143. WQMX836 MEA045 AW 144. WQMX837 MEA045 AX 145. WQMX838 MEA046 AT 146. WQMX839 MEA046 AU 147. WQMX840 MEA046 AV 148. WQMX841 MEA047 AA 149. WQMX842 MEA047 AB 150. WQMX843 MEA047 AC 151. WQMX844 MEA048 AF 152. WQMX845 MEA048 AG 153. WQMX846 MEA048 AH 154. WQMX847 MEA050 AA 155. WQMX848 MEA050 AB 13 Attachment 2 List of Spok Part 22 Paging Licenses Call Sign Market Code Channel Block 1. WPQM446 MEA033 AA 2. WPQM447 MEA042 AA 3. WPQM449 MEA044 AA 4. WPQM473 MEA043 AG 5. WPQM474 MEA044 AG 6. WPQM481 MEA028 AI 7. WPQM482 MEA029 AI 8. WPQM483 MEA030 AI 9. WPQM485 MEA032 AI 10. WPQM487 MEA036 AI 11. WPQM488 MEA037 AI 12. WPQM490 MEA045 AI 13. WPQM491 MEA047 AI 14. WPQM507 MEA031 AT 15. WPQM508 MEA032 AT 16. WPQM509 MEA038 AT 17. WPQM510 MEA031 AU 18. WPQM511 MEA032 AU 19. WPQM512 MEA038 AU 20. WPQM513 MEA039 AU 21. WPQM516 MEA043 AV 22. WPQM517 MEA044 AV 23. WPQM518 MEA017 AW 24. WPQM519 MEA018 AW 25. WPQM520 MEA001 AY 26. WPQM521 MEA002 AY 27. WPQM524 MEA043 AY 28. WPQM525 MEA044 AY 29. KNLN884 MEA033 AA 30. KNKE385 MEA020 AB 31. KNKJ371 MEA040, MEA043 & MEA044 AG 32. KNKP278 MEA043 & MEA044 AG 33. KNKF684 MEA036 & MEA037 AI 34. KNKL914 MEA046 AI 35. KNKL939 MEA045 AI 36. KNKO969 MEA029 AI 37. KNKP862 MEA036 AI 38. KTS256 MEA033 AI 39. KWU327 MEA036 & MEA037 AI 40. KNKE387 MEA004, MEA005 & MEA012 AL 41. KNKG839 MEA006 AL 42. KNKM814 MEA005 & MEA006 AL 43. KNKO694 MEA005 & MEA006 AL 44. KNKO735 MEA004 & MEA005 AL 14 45. KNKP215 MEA002 AL 46. KNKO803 MEA004 & MEA005 AO 47. KNKP224 MEA005 & MEA006 AO 48. KNKO564 MEA031, MEA032 & MEA038 AT 49. KNKP213 MEA015 & MEA016 AT 50. KPE466 MEA031, MEA032 & MEA038 AT 51. KNKP212 MEA043 & MEA044 AV 52. KNKS216 MEA043 & MEA044 AV 53. KNKE335 MEA017 & MEA018 AW 54. KNKG834 MEA043, MEA044 & MEA045 AY 55. KNKL939 MEA045 AY 56. KOR233 MEA043 & MEA044 AY 57. KNKE385 MEA020 BB 58. KNKF684 MEA029, MEA035, MEA036 & MEA037 BB 59. KNKM814 MEA005 BB 60. KNKO735 MEA004 & MEA005 BB 61. KNKP215 MEA002 BB 62. KNKJ371 MEA040, MEA043 & MEA044 BC 63. KNKJ205 MEA031, MEA032 & MEA038 BI 64. KNKO386 MEA031, MEA032 & MEA038 BI 65. KNKO927 MEA039 BI 66. KNKO997 MEA018 BI 67. KNKP201 MEA001 & MEA002 BI 68. KNKP275 MEA002 BI 69. KNKM447 NW NW 70. KNKO694 MEA005 & MEA006 AL 71. KNKO735 MEA004 & MEA005 AL 15 Attachment 3 List of Itron Licenses Included in Waiver Call Sign Market Code Channel Block 1. WQMX694 MEA001 AL 2. WQMX695 MEA001 AM 3. WQMX696 MEA001 AN 4. WQMX698 MEA002 AQ 5. WQMX699 MEA002 BK 6. WQMX700 MEA003 AC 7. WQMX701 MEA003 AF 8. WQMX702 MEA003 AG 9. WQMX705 MEA004 BK 10. WQMX706 MEA005 AJ 11. WQMX709 MEA005 BK 12. WQMX711 MEA006 AQ 13. WQMX712 MEA006 BF 14. WQMX713 MEA007 AC 15. WQMX714 MEA007 AG 16. WQMX716 MEA008 AW 17. WQMX717 MEA008 AY 18. WQMX718 MEA008 AZ 19. WQMX719 MEA009 AA 20. WQMX720 MEA009 AB 21. WQMX721 MEA009 AC 22. WQMX722 MEA010 AA 23. WQMX723 MEA010 AB 24. WQMX724 MEA010 AC 25. WQMX725 MEA011 AG 26. WQMX726 MEA011 AM 27. WQMX727 MEA011 BD 28. WQMX728 MEA012 AC 29. WQMX729 MEA012 AJ 30. WQMX732 MEA013 AB 31. WQMX733 MEA013 AC 32. WQMX734 MEA013 AG 33. WQMX735 MEA014 AB 34. WQMX736 MEA014 AC 35. WQMX737 MEA014 AG 36. WQMX738 MEA015 AF 37. WQMX739 MEA015 AG 38. WQMX740 MEA015 AH 39. WQMX741 MEA015 AI 40. WQMX742 MEA016 AB 41. WQMX743 MEA016 AY 42. WQMX744 MEA016 AZ 43. WQMX745 MEA016 BK 44. WQMX746 MEA017 AA 16 45. WQMX747 MEA017 AB 46. WQMX748 MEA017 AC 47. WQMX749 MEA018 AG 48. WQMX751 MEA018 BK 49. WQMX752 MEA019 AP 50. WQMX753 MEA019 BB 51. WQMX754 MEA019 BC 52. WQMX755 MEA020 AF 53. WQMX756 MEA020 AG 54. WQMX757 MEA020 BJ 55. WQMX758 MEA020 BK 56. WQMX759 MEA021 AA 57. WQMX760 MEA021 AB 58. WQMX761 MEA021 AO 59. WQMX762 MEA022 AA 60. WQMX763 MEA022 AB 61. WQMX764 MEA022 AC 62. WQMX765 MEA023 AA 63. WQMX766 MEA023 AB 64. WQMX767 MEA023 AC 65. WQMX768 MEA024 BH 66. WQMX770 MEA024 BJ 67. WQMX771 MEA025 AA 68. WQMX772 MEA025 AB 69. WQMX773 MEA025 AC 70. WQMX774 MEA026 AA 71. WQMX775 MEA026 AB 72. WQMX776 MEA026 AG 73. WQMX777 MEA027 AA 74. WQMX778 MEA027 AG 75. WQMX779 MEA027 AJ 76. WQMX780 MEA027 AK 77. WQMX781 MEA028 AA 78. WQMX782 MEA028 AB 79. WQMX783 MEA028 AC 80. WQMX784 MEA028 AG 81. WQMX785 MEA029 AA 82. WQMX786 MEA029 AB 83. WQMX787 MEA029 AF 84. WQMX788 MEA030 AA 85. WQMX789 MEA030 AB 86. WQMX790 MEA030 AK 87. WQMX791 MEA031 AA 88. WQMX792 MEA031 AE 89. WQMX794 MEA031 AK 90. WQMX795 MEA032 AE 91. WQMX796 MEA032 AG 17 92. WQMX797 MEA032 AW 93. WQMX798 MEA033 AF 94. WQMX799 MEA033 AZ 95. WQMX802 MEA034 AF 96. WQMX803 MEA035 BE 97. WQMX805 MEA035 BK 98. WQMX806 MEA036 AA 99. WQMX807 MEA036 AB 100. WQMX808 MEA036 AC 101. WQMX810 MEA037 BD 102. WQMX811 MEA037 BE 103. WQMX812 MEA038 AD 104. WQMX813 MEA038 AE 105. WQMX814 MEA038 AW 106. WQMX815 MEA039 AD 107. WQMX817 MEA040 AL 108. WQMX819 MEA040 BC 109. WQMX820 MEA040 BF 110. WQMX822 MEA041 AK 111. WQMX823 MEA041 AL 112. WQMX824 MEA041 BK 113. WQMX826 MEA042 AM 114. WQMX827 MEA042 BE 115. WQMX830 MEA043 AN 116. WQMX832 MEA044 AD 117. WQMX833 MEA044 AO 118. WQMX838 MEA046 AT 119. WQMX839 MEA046 AU 120. WQMX840 MEA046 AV 121. WQMX841 MEA047 AA 122. WQMX842 MEA047 AB 123. WQMX843 MEA047 AC 124. WQMX844 MEA048 AF 125. WQMX845 MEA048 AG 126. WQMX846 MEA048 AH 127. WQMX847 MEA050 AA 128. WQMX848 MEA050 AB 18 Attachment 4 List of Itron Licenses Excluded from Waiver Call Sign Market Code Channel Block 1. WQMX697 MEA002 AP 2. WQMX703 MEA004 AP 3. WQMX704 MEA004 AZ 4. WQMX707 MEA005 AM 5. WQMX708 MEA005 AN 6. WQMX710 MEA006 AP 7. WQMX715 MEA007 AM 8. WQMX730 MEA012 AK 9. WQMX731 MEA012 AL 10. WQMX750 MEA018 BI 11. WQMX769 MEA024 BI 12. WQMX793 MEA031 AJ 13. WQMX800 MEA034 AA 14. WQMX801 MEA034 AB 15. WQMX804 MEA035 BI 16. WQMX809 MEA037 BC 17. WQMX816 MEA039 AI 18. WQMX818 MEA040 AY 19. WQMX821 MEA041 AJ 20. WQMX825 MEA042 AJ 21. WQMX828 MEA043 AI 22. WQMX829 MEA043 AJ 23. WQMX831 MEA043 AW 24. WQMX834 MEA044 AW 25. WQMX835 MEA045 AV 26. WQMX836 MEA045 AW 27. WQMX837 MEA045 AX