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 Federal  Communications  Commission  DA  99-  1816 
 Before  the  Federal  Communications  Commission 
 Washington,  D.  C.  20554 


 In  the  Matter  of  the  Application  of  )  ) 
 PLAINCOM,  INC.  )  FCC  File  No:  9507123  ) 
 to  Provide  39  GHz  Point-  to-  Point  Microwave  )  Service  in  Waco,  TX  ) 


 ORDER  ON  RECONSIDERATION 
 Adopted:  October  29,  1999  Released:  October  29,  1999 
 By  the  Chief,  Public  Safety  and  Private  Wireless  Division,  Wireless  Telecommunications  Bureau: 
 I.  INTRODUCTION 
 1.  By  letter  dated  September  22,  1998,  the  Licensing  and  Technical  Analysis  Branch  (Branch)  dismissed  a  February  6,  1998,  amendment  to  the  above-  captioned  application  for  a  39  GHz  station 
 authorization  in  the  Point-  to-  Point  Microwave  Radio  Service  in  the  area  of  Waco,  TX  submitted  by  Plaincom,  Inc.  (Plaincom).  1  On  October  29,  1998,  Plaincom  filed  a  Petition  for  Reconsideration  (Petition)  of 
 the  Branch's  action.  2  For  the  reasons  set  forth  below,  we  affirm  the  Branch's  action  and  deny  Plaincom's  Petition. 
 II.  BACKGROUND 
 2.  On  July  26,  1995,  we  placed  the  above-  referenced  Plaincom  application  on  public  notice.  3  On  November  13,  1995,  the  Wireless  Telecommunications  Bureau  (Bureau)  announced  that  39  GHz 
 applications  would  no  longer  be  accepted  for  filing  in  the  Common  Carrier  or  Operational  Fixed  Point-  to-Point  Microwave  Radio  Services  until  the  Commission  acted  upon  a  pending  petition  for  rulemaking 
 affecting  these  services.  4  On  December  8,  1995,  Plaincom  filed  an  amendment  to  its  application,  reducing 


 1  Letter  from  Mary  M.  Shultz,  Chief,  Licensing  and  Technical  Analysis  Branch,  Public  Safety  and  Private  Wireless 
 Division,  to  Mr.  Ed  Clinton,  President,  PLAINCOM,  INC.  (dated  Sept.  22,  1998)  (Shultz  Letter);  see  also  Public  Notice,  Wireless  Telecommunications  Bureau  Weekly  Receipts  and  Disposals,  Report  No.  2008  (released  Sept.  29, 


 1998). 
 2  Plaincom  Petition  for  Reconsideration  (Oct.  29,  1998). 


 3  Public  Notice,  Wireless  Telecommunications  Bureau  Part  21  Receipts  and  Disposals,  Report  No.  1145  (released 
 July  26,  1995). 
 4  Petition  for  Amendment  of  the  Commission's  Rules  Regarding  the  37.  0-  38.  6  GHz  and  38.  6-  40.  0  GHz  Bands,  RM-8553, 
 Order,  11  FCC  Rcd  1156  (Acting  Chief,  WTB,  Nov.  13,  1995)  (Freeze  Order). 
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 the  proposed  service  area.  5  The  amendment  was  accepted  and  applied  to  Plaincom's  initial  application.  However,  the  amendment  failed  to  resolve  the  mutual  exclusivity  as  to  an  application  filed  by  Astrolink 
 Communications,  Inc.  (Astrolink)  6  and  another  application  filed  by  Biztel,  Inc.  (Biztel).  7 
 3.  On  December  15,  1995,  the  Commission  modified  the  Bureau's  39  GHz  Freeze  Order  by  distinguishing  between  those  pending  39  GHz  applications  that  would  be  processed  and  those  applications 
 that  would  be  held  in  abeyance  pending  the  outcome  of  the  rulemaking  proceeding.  8  On  January  17,  1997,  the  Commission  held  that  it  would  process  all  39  GHz  amendments-  of-  right  filed  on  or  after  November  13, 
 1995,  but  before  December  15,  1995.  9  On  November  3,  1997,  the  Commission  decided  to  dismiss,  without  prejudice,  pending  mutually  exclusive  applications,  unless  the  mutual  exclusivity  was  resolved  by  an 
 amendment-  of-  right  filed  before  December  15,  1995.  10 
 4.  On  February  6,  1998,  Plaincom  filed  a  second  amendment  (February  Amendment)  to  its  initial  application  to  modify  its  coordinates  to  "reduce  the  size  of  its  proposed  service  area."  11  On  September 
 22,  1998,  the  Branch  dismissed  Plaincom's  February  Amendment  in  accordance  with  the  interim  processing  procedures  for  the  39  GHz  service.  12  The  Branch  found  that  the  February  Amendment  was  filed  after 
 December  15,  1995,  when  the  freeze  on  the  acceptance  of  amendments  became  effective. 
 III.  DISCUSSION 
 5.  First,  Plaincom  argues  that  the  coordinates  revised  in  its  December  8,  1995,  amendment  contained  a  clerical  error  and  that  the  February  Amendment  served  as  a  correction  and  was,  therefore,  an 


 5  Plaincom's  original  application  specified  the  coordinates  of  the  proposed  Waco,  TX  service  area  as  30-  45-  00NLAT, 
 96-  00-  00WLONG/  32-  00-  00NLAT,  98-  00-  00WLONG.  On  December  8,  1995  Plaincom  amended  its  applications  and  specified  the  new  coordinates  as  30-  45-  00NLAT,  96-  20-  00WLONG/  32-  00-  00NLAT,  98-  00-  00WLONG. 


 6  FCC  File  No  9506290  appeared  on  Public  Notice,  Wireless  Telecommunications  Bureau  Part  21  Receipts  and 
 Disposals,  Report  No.  1141  (released  June  28,  1995). 
 7  FCC  File  No.  9505595  appeared  on  Public  Notice,  Wireless  Telecommunications  Bureau  Part  21  Receipts  and 
 Disposals,  Report  No.  1139  (released  June  14,  1995). 
 8  Amendment  of  the  Commission's  Rules  Regarding  the  37.0-  38.6  GHz  and  38.6-  40.0  GHz  Bands,  ET  Docket  No. 
 95-  183,  Notice  of  Proposed  Rulemaking  and  Order,  11  FCC  Rcd  4930,  4988-  4989  (1995)  (NPRM  and  Order). 
 9  Amendment  of  the  Commission's  Rules  Regarding  the  37.0-  38.6  GHz  and  38.6-  40.0  GHz  Bands,  ET-  Docket  95- 
 183,  Memorandum  Opinion  and  Order,  12  FCC  Rcd  2910  (1997)  (Jan.  17  MO&  O). 
 10  Amendment  of  the  Commission's  Rules  Regarding  the  37.0-  38.6  GHz  and  38.6-  40.0  GHz  Bands,  ET-  Docket  95- 
 183,  Report  and  Order  and  Second  Notice  of  Proposed  Rulemaking,  12  FCC  Rcd  18600  (1997)  (Report  and  Order  and  Second  NPRM). 


 11  See  FCC  File  No.  9506290.  Plaincom's  February  Amendment  requested  that  the  coordinates  be  changed  to  30-  50- 
 15NLAT,  92-  20-  00WLONG/  32-  00-  00NLAT,  98-  00-  00WLONG. 
 12  Shultz  Letter  at  1. 
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 amendment-  of-  right,  which  is  effective  upon  filing.  13  Thus,  Plaincom  requests  that  the  February  Amendment  be  reinstated.  Pursuant  to  the  Commission's  Rules,  amendments  merely  correcting 
 typographical,  transcription,  or  similar  clerical  errors,  which  are  clearly  demonstrated  to  be  mistakes  by  reference  to  other  parts  of  the  application,  and  whose  discovery  does  not  create  any  new  frequency  conflicts, 
 are  not  considered  to  be  newly  filed  applications.  14  While  we  don't  doubt  Plaincom's  claim  of  clerical  error,  we  are,  nevertheless,  required  to  abide  by  the  requirements  set  out  in  Section  101.45(  f)(  5)  of  the 
 Commission's  Rules.  Upon  further  reexamination  of  Plaincom's  application,  we  find  that  there  was  no  evidence  within  the  four  corners  of  the  application,  either  in  the  form  of  service  area  maps  or  conflicting 
 coordinates,  such  that  the  Branch  would  have  been  alerted  to  a  clerical  error.  Specifically,  the  December  amendment  requested  a  change  in  the  proposed  site's  longitude,  while  the  February  Amendment  reflected  a 
 change  in  latitude.  Furthermore,  even  if  we  accept  the  change  in  latitude  coordinates  found  in  Plaincom's  February  Amendment,  Plaincom's  service  area  would  remain  mutually  exclusive  with  Biztel's  application.  15 


 6.  Plaincom  also  contends  that  the  Commission  is  "without  authority  to  dismiss  Plaincom's  amendment  which  took  effect  when  filed."  16  This  argument  does  not  distinguish  between  amendments  that 
 are  accepted  for  filing  and  amendments  that  are  not  accepted  for  filing  because  of  a  freeze.  17  In  the  Jan  17  MO&  O,  the  Commission  addressed  this  issue  and  concluded  that  the  NPRM  and  Order  suspended 
 acceptance  of  all  amendments-  of-  right  filed  after  December  15,  1995.  18 


 13  Plaincom  Petition  at  1-  2. 
 14  47  C.  F.  R.  §  101.45(  f)(  5).  See  Mobil  Oil  Telecom  LTD,  File  No.  730428,  Order,  13  FCC  Rcd  5169,  5174  (1998) 
 (applicant  miscalculated  ground  elevation  and  center  line  height  figures,  but  staff  was  aware  that  figures  were  incorrect  when  it  returned  application  and  specifically  requested  revised  information).  See  also  Porta-  Phone  Paging  Licensee 


 Corporation,  File  No.  29086-  CD-  P/  ML-  96,  Order  on  Reconsideration,  13  FCC  Rcd  5229,  5230-  5231  (1998)  (applicant  entered  incorrect  site  coordinates,  but  the  application  was  reinstated  because  the  correct  data  was  supplied  multiple 
 times  in  the  description  of  the  proposed  antenna  site). 
 15  See  supra  n.  7.  Although,  Biztel's  application  was  subsequently  dismissed  on  March  11,  1997,  this  application  was 
 mutually  exclusive  with  the  Plaincom  application  at  the  time  Plaincom's  December  amendment  was  filed. 
 16  Plaincom  Petition  2-  7. 


 17  See  Kessler  v.  FCC,  326  F.  2d  673,  684  (D.  C.  Cir.  1963)  (holding  that  Section  309(  a)  and  (e)  of  the 
 Communications  Act  of  1934,  as  amended,  47  U.  S.  C.  §  309(  a),  (e),  which  provide  for  a  hearing  on  certain  applications  "filed  with"  the  Commission,  does  not  apply  to  applications  submitted  but  not  accepted  for  filing  because  of  a  freeze) 


 (Kessler). 
 18  Jan.  17  MO&  O,  12  FCC  Rcd  at  2918;  see  also  Amendment  of  the  Commission's  Rules  Regarding  37.0-  38.6  GHz 
 and  38.6-  40.0  GHz  Bands,  ET-  Docket  95-  183,  Memorandum  Opinion  and  Order,  FCC  99-  179,  ¶  31-  34  (rel.  July  29,  1999). 
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 7.  Plaincom  next  argues  that  the  Commission's  failure  to  process  its  amendment  violates  Section  309(  j)(  7)(  B)  of  the  Communications  Act,  which  prohibits  the  Commission  from  holding  an  auction 
 solely  for  the  purpose  of  raising  funds  for  the  federal  treasury.  19  The  Commission  has  previously  addressed  this  argument.  20  Thus,  Plaincom's  argument  is  dismissed  here  as  repetitious.  21 


 8.  Finally,  Plaincom  asserts  that  the  Commission's  freeze  on  amendments-  of-  right  violates  Congress's  directive  to  the  Commission  to  "continue  to  use  engineering  solutions,  negotiation,  threshold 
 qualifications,  service  regulations  and  other  means  in  order  to  avoid  mutual  exclusivity  in  application  and  licensing  proceedings."  22  We  believe  that  this  directive,  at  a  minimum,  pertains  to  applications  that  meet 
 Commission  filing  requirements.  As  discussed  above,  Plaincom  filed  its  second  amendment  after  the  December  15,  1995,  cut-  off  date  for  filing  amendments-  of-  right.  Consequently,  because  Plaincom's 
 amendment  was  not  an  amendment-  of-  right  filed  before  December  15,  1995,  it  was  not  acceptable  for  filing.  Thus,  we  do  not  believe  that  the  provisions  of  Section  309(  j)(  6)(  E)  of  the  Communications  Act  apply  to  the 
 subject  application  and  amendment.  As  a  result,  Plaincom's  Petition  for  Reconsideration,  filed  on  November  2,  1998,  is  hereby  denied. 


 IV.  ORDERING  CLAUSES 
 9.  Accordingly,  IT  IS  ORDERED  that  pursuant  to  Sections  4(  i)  and  405,  of  the  Communications  Act  of  1934,  as  amended,  47  U.  S.  C.  §§  154(  i),  405  and  Section  1.106  of  the  Commission's 
 Rules,  47  C.  F.  R.  §  1.106,  the  Petition  for  Reconsideration  filed  by  Plaincom,  Inc.  on  November  2,  1998  IS  DENIED. 


 19  47  U.  S.  C.  §  309(  j)(  7)(  B);  Plaincom  Petition  at  7-  8. 
 20  The  Commission  has  previously  explained  that  the  new  licensing  procedures  implemented  in  this  proceeding  will: 
 (a)  better  accommodate  39  GHz  services  which  support  existing  and  emerging  technologies;  and  (b)  provide  for  competitive  bidding  which  will  allow  spectrum  to  be  acquired  by  those  who  value  it  most  highly,  and  increase  the 


 likelihood  that  innovative,  competitive  services  will  be  offered  to  consumers.  See  Jan  17  MO&  O,  12  FCC  Rcd  at  2917;  see  also  Report  and  Order  and  Second  NPRM,  12  FCC  Rcd  at  18642. 


 21  Any  order  disposing  of  a  petition  for  reconsideration  which  modifies  rules  adopted  by  the  original  order  is,  to  the 
 extent  of  such  modification,  subject  to  reconsideration  in  the  same  manner  as  the  original  order.  Except  in  such  circumstances,  a  second  petition  for  reconsideration  may  be  dismissed  by  the  staff  as  repetitious.  47  C.  F.  R.  §  1.429(  i). 


 See,  e.  g.,  Amendment  of  Parts  13  and  80  of  the  Commission's  Rules  to  Implement  the  Global  Maritime  Distress  and  Safety  System  (GMDSS)  to  Improve  the  Safety  of  Life  at  Sea,  PR  Docket  No.  90-  480,  Memorandum  Opinion  and 
 Order,  13  FCC  Rcd  15786,  15790,  15796  (1998);  Amendment  of  Part  69  of  the  Commission's  Rules  Relating  to  the  Creation  of  Access  Charge  Settlements  for  Open  Network  Architecture,  CC  Docket  No.  89-  79,  Memorandum  Opinion 
 and  Order  on  Third  Further  Reconsideration,  10  FCC  Rcd  1570,  1572  (1994);  Waivers  of  Section  90.621(  b)  of  the  Commission's  Rules  for  Applicants  in  the  Specialized  Mobile  Radio  Service,  PR  Docket  No.  90-  34,  Order,  8  FCC  Rcd 
 7619  (1993)  . 
 22  47  U.  S.  C.  §  309(  j)(  6)(  E);  Plaincom  Petition  at  4,  7-  8. 
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 10.  This  action  is  taken  under  delegated  authority  pursuant  to  Sections  0.131  and  0.331  of  the  Commission's  Rules,  47  C.  F.  R.  §§  0.131,  0.331. 
 FEDERAL  COMMUNICATIONS  COMMISSION 


 D'wana  R.  Terry  Chief,  Public  Safety  and  Private  Wireless 
 Division  Wireless  Telecommunications  Bureau 
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