**Before the**

**Federal Communications Commission**

**Washington, D.C. 20554**

+----------------------------------+---+------------------------------+
| In the Matter of Licenses of     | * | Call Sign No. KNNR223        |
|                                  | * |                              |
| RURAL METRO CORPORATION          | ) | File No.018704               |
|                                  | * |                              |
| To operate a Conventional        | * | File No. A018705             |
| Business                         |   |                              |
|                                  | * | File No. A018706             |
| Radio Service Station in         | * |                              |
| Maricopa County, Arizona         | ) | File No. A018707             |
|                                  | * |                              |
| AMY ZAK & ASSOCIATES             | * | File No. A018708             |
|                                  |   |                              |
| To operate Business Radio        | * | File No. A018709             |
| Service Trunked Station WPM777   | * |                              |
| on Frequency 936.6625 MHz at     | ) | File No. A018689             |
| Litchfield, Arizona              | * |                              |
|                                  | * | File No. A018690             |
| AMERICAN INDUSTRIAL MAINTENANCE  |   |                              |
|                                  | * | File No. A018691             |
| To operate Business Radio        | * |                              |
| Service Trunked Station call     | ) | File No. A018693             |
| sign WPMF782 on Frequency        | * |                              |
| 936.6625 MHz at Litchfield,      | * | File No. A018693             |
| Arizona                          |   |                              |
|                                  | * | File No. A018694             |
| ACE REPROGRAPHICS, INC.,         | * |                              |
|                                  | ) | File No. A018695             |
| To operate Business Radio        | * |                              |
| Service Trunked Station call     | * | File No. A018696             |
| sign WPMF786 on Frequency        |   |                              |
| 936.6625 MHz at Litchfield,      | * | File No. A018697             |
| Arizona                          | * |                              |
|                                  | ) | File No. A018697             |
| CAREFREE HOMES                   | * |                              |
|                                  | * | File No. A018699             |
| To operate Business Radio        |   |                              |
| Service Trunked Station call     | * | File No. A018700             |
| sign WPMF791 on Frequency        | * |                              |
| 936.6625 MHz at Litchfield,      | ) | File No. A018701             |
| Arizona                          | * |                              |
|                                  | * | File No. A018702             |
| CEI-CLOLA ENTERPRISES, INC.      |   |                              |
|                                  | * | File No. A018703             |
| To operate Business Radio        | * |                              |
| Service Trunked Station call     | ) | File No. A018712             |
| sign WPMF793 on Frequency        | * |                              |
| 936.6625 MHz at Litchfield,      | * | File No. A018711             |
| Arizona                          |   |                              |
|                                  | * | File No. A018639             |
| BLUCOR CONTRACTING, INC.         | * |                              |
|                                  | ) | File No. A018710             |
| To operate Business Radio        | * |                              |
| Service Trunked Station call     | * | File No. A018716             |
| sign WPMF800 on Frequency        |   |                              |
| 936.6625 MHz at Litchfield,      | * | File No. A018713             |
| Arizona                          | * |                              |
|                                  | ) | File No. A018714             |
| NORTHLAND TRUCKING               | * |                              |
|                                  | * | File No. A019839             |
| To operate a Business Radio      |   |                              |
| Service Trunked Station WPMF901  | * | File No. A018715             |
| on Frequency 936.6625 MHz at     | * |                              |
| Litchfield, Arizona              | ) | File No. A023559             |
|                                  | * |                              |
| NOAH WEBSTER BASIC SCHOOL        | * | File No. A023560             |
|                                  |   |                              |
| To operate a Business Radio      | * | File No. A023561             |
| Service Trunked Station WPMF907  | * |                              |
| on Frequency 936.6625 MHz at     | ) | D111794                      |
| Litchfield, Arizona              | * |                              |
|                                  | * | D111791                      |
| MESA VERDE LANDSCAPE CO.         |   |                              |
|                                  | * | D111792                      |
| To operate a Business Radio      | * |                              |
| Service Trunked Station WPMF922  | ) |                              |
| on Frequency 936.6625 MHz at     | * |                              |
| Litchfield, Arizona              | * |                              |
|                                  |   |                              |
| MAGNA ELECTRIC CONTRACTING CO.   | * |                              |
|                                  | * |                              |
| To operate a Business Radio      | ) |                              |
| Service Trunked Station WPMF923  | * |                              |
| on Frequency 936.6625 MHz at     | * |                              |
| Litchfield, Arizona              |   |                              |
|                                  | * |                              |
| LUCAS OJEDA                      | * |                              |
|                                  | ) |                              |
| To operate a Business Radio      | * |                              |
| Service Trunked Station WPMF924  | * |                              |
| on Frequency 936.6625 MHz at     |   |                              |
| Litchfield, Arizona              | * |                              |
|                                  | * |                              |
| HUNTWOOD INDUSTRIES              | ) |                              |
|                                  | * |                              |
| To operate a Business Radio      | * |                              |
| Service Trunked Station WPMF925  |   |                              |
| on Frequency 936.6625 MHz at     | * |                              |
| Litchfield, Arizona              | * |                              |
|                                  | ) |                              |
| HEALTHCOR                        | * |                              |
|                                  | * |                              |
| To operate a Business Radio      |   |                              |
| Service Trunked Station WPMF928  | * |                              |
| on Frequency 936.6625 MHz at     | * |                              |
| Litchfield, Arizona              | ) |                              |
|                                  | * |                              |
| DVC CONSTRUCTION                 | * |                              |
|                                  |   |                              |
| To operate a Business Radio      | * |                              |
| Service Trunked Station WPMF929  | * |                              |
| on Frequency 936.6625 MHz at     | ) |                              |
| Litchfield, Arizona              | * |                              |
|                                  | * |                              |
| DIAMOND MECHANICAL CO            |   |                              |
|                                  | * |                              |
| To operate a Business Radio      | * |                              |
| Service Trunked Station WPMF930  | ) |                              |
| on Frequency 936.6625 MHz at     | * |                              |
| Litchfield, Arizona              | * |                              |
|                                  |   |                              |
| DIAMOND BACK YARD DESIGN         | * |                              |
|                                  | * |                              |
| To operate a Business Radio      | ) |                              |
| Service Trunked Station WPMF933  | * |                              |
| on Frequency 936.6625 MHz at     | * |                              |
| Litchfield, Arizona              |   |                              |
|                                  | * |                              |
| DAVID FRANK COMPANY, INC.        | * |                              |
|                                  | ) |                              |
| To operate a Business Radio      | * |                              |
| Service Trunked Station WPMF937  | * |                              |
| on Frequency 936.6625 MHz at     |   |                              |
| Litchfield, Arizona              | * |                              |
|                                  | * |                              |
| CROMALLOY OF ARIZONA, INC.       | ) |                              |
|                                  | * |                              |
| To operate a Business Radio      | * |                              |
| Service Trunked Station, WPMF941 |   |                              |
| on Frequency 936.6625 MHz at     | * |                              |
| Litchfield, Arizona              | * |                              |
|                                  | ) |                              |
| BLACK ROSE INVESTIGATIONS,       | * |                              |
|                                  | * |                              |
| To operate a Business Radio      |   |                              |
| Service Trunked Station WMPF943  | * |                              |
| on Frequency 936.6625 MHz at     | * |                              |
| Litchfield, Arizona              | ) |                              |
|                                  | * |                              |
| BILL LUKE DODGE, INC.            | * |                              |
|                                  |   |                              |
| To operate a Business Radio      | * |                              |
| Service Trunked Station WMPF946  | * |                              |
| on Frequency 936.6625 MHz at     | ) |                              |
| Litchfield, Arizona              | * |                              |
|                                  | * |                              |
| ARIZONA CAREER & TECHNOLOGY      |   |                              |
|                                  | * |                              |
| To operate a Business Radio      | * |                              |
| Service Trunked Station WMPF948  | ) |                              |
| on Frequency 936.6625 MHz at     | * |                              |
| Litchfield, Arizona              | * |                              |
|                                  |   |                              |
| SATURN OF GLENDALE               | * |                              |
|                                  | * |                              |
| To operate a Business Radio      | ) |                              |
| Service Trunked Station WMPF981  | * |                              |
| on Frequency 936.6625 MHz at     | * |                              |
| Litchfield, Arizona              |   |                              |
|                                  | * |                              |
| WESTERN AIR CONDITIONING &       | * |                              |
| HEATING                          | ) |                              |
|                                  | * |                              |
| To operate a Business Radio      | * |                              |
| Service Trunked Station WMPF984  |   |                              |
| on Frequency 936.6625 MHz at     | * |                              |
| Litchfield, Arizona              | * |                              |
|                                  | ) |                              |
| VALLEY TOWING & LIMOUSINE        | * |                              |
| SERVICE                          | * |                              |
|                                  |   |                              |
| To operate a Business Radio      | * |                              |
| Service Trunked Station WMPF996  | * |                              |
| on Frequency 936.6625 MHz at     | ) |                              |
| Litchfield, Arizona              | * |                              |
|                                  | * |                              |
| WILMA LOMBARDI                   |   |                              |
|                                  | * |                              |
| To operate a Business Radio      | * |                              |
| Service Trunked Station WMPF997  | ) |                              |
| on Frequency 936.6625 MHz at     | * |                              |
| Litchfield, Arizona              | * |                              |
|                                  |   |                              |
| PHOENIX BAPTIST HOSPITAL &       | * |                              |
| MEDICAL CENTER                   | * |                              |
|                                  | ) |                              |
| To operate a Business Radio      | * |                              |
| Service Trunked Station WMPF998  | * |                              |
| on Frequency 936.6625 MHz at     |   |                              |
| Litchfield, Arizona              | * |                              |
|                                  | * |                              |
| REED EXPRESS DELIVERY            | ) |                              |
|                                  | * |                              |
| To operate a Business Radio      | * |                              |
| Service Trunked Station WMPG202  |   |                              |
| on Frequency 936.6625 MHz at     | * |                              |
| Litchfield, Arizona              | * |                              |
|                                  | ) |                              |
| PRO GRADE SERVICES               | * |                              |
|                                  | * |                              |
| To operate a Business Radio      |   |                              |
| Service Trunked Station WMPG208  | * |                              |
| on Frequency 936.6625 MHz at     | * |                              |
| Litchfield, Arizona              | ) |                              |
|                                  | * |                              |
| EXPEDITE HANDLERS, INC.          | * |                              |
|                                  |   |                              |
| To operate a Business Radio      | * |                              |
| Service Trunked Station WMPI933  | * |                              |
| on Frequency 936.6625 MHz at     | ) |                              |
| Litchfield, Arizona              | * |                              |
|                                  | * |                              |
| PHOENIX ECONOMY SUPPLY OF        |   |                              |
| ARIZONA                          | * |                              |
|                                  | * |                              |
| To operate a Business Radio      | ) |                              |
| Service Trunked Station WMPG209  | * |                              |
| on Frequency 936.6625 MHz at     | * |                              |
| Litchfield, Arizona              |   |                              |
|                                  | * |                              |
| WOUDENBERG ENTERPRISES           | * |                              |
|                                  | ) |                              |
| To operate a Business Radio      | * |                              |
| Service Trunked Station WPML205  | * |                              |
| on Frequency 936.6625 MHz at     |   |                              |
| Litchfield, Arizona              | * |                              |
|                                  | * |                              |
| SUPERSHUTTLE OF ARIZONA          | ) |                              |
|                                  | * |                              |
| To operate a Business Radio      | * |                              |
| Service Trunked Station WPML227  |   |                              |
| on Frequency 936.6625 MHz at     | * |                              |
| Litchfield, Arizona              | * |                              |
|                                  | ) |                              |
| SECURITY ROOFING AND             | * |                              |
| CONSTRUCTION                     | * |                              |
|                                  |   |                              |
| To operate a Business Radio      | * |                              |
| Service Trunked Station WPML233  | * |                              |
| on Frequency 936.6625 MHz at     | ) |                              |
| Litchfield, Arizona              | * |                              |
|                                  | * |                              |
| ARROWHEAD TOWING                 |   |                              |
|                                  | * |                              |
| To operate a Business Radio      | * |                              |
| Service Trunked Station WPML558  | ) |                              |
| on Frequency 936.6625 MHz at     | * |                              |
| Litchfield, Arizona              | * |                              |
|                                  |   |                              |
| BOBS BARRICADE, INC.             | * |                              |
|                                  | * |                              |
| To operate a Business Radio      | ) |                              |
| Service Trunked Station WPML562  | * |                              |
| on Frequency 936.6625 MHz at     | * |                              |
| Litchfield, Arizona              |   |                              |
|                                  | * |                              |
| AKAI SECURITY, INC.              | * |                              |
|                                  | ) |                              |
| To operate a Business Radio      | * |                              |
| Service Trunked Station WPML205  | * |                              |
| on Frequency 936.6625 MHz at     |   |                              |
| Litchfield, Arizona              | * |                              |
|                                  | * |                              |
|                                  | ) |                              |
|                                  | * |                              |
|                                  | * |                              |
|                                  |   |                              |
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+----------------------------------+---+------------------------------+

**ORDER ON RECONSIDERATION**

**Adopted:** February 24, 2000 **Released:** February 29, 2000

By the Chief, Public Safety and Private Wireless Division, Wireless
Telecommunications Bureau:

# Introduction

1.  In this *Order on Reconsideration*, we resolve four petitions for
    reconsideration (collectively, petitions) filed by Rural Metro
    Corporation (Rural Metro).[^1] For the following reasons, we deny
    the petitions and affirm the decisions of the Licensing and
    Technical Analysis Branch (Branch) of the Public Safety and Private
    Wireless Division of the Wireless Telecommunications Bureau (Bureau)
    denying Rural Metro's waiver request and granting the
    above-captioned applications.

# background

2.  Rural Metro was granted a new Conventional Business license for
    frequency 936.6625 MHz at Usery Mountain, Arizona on May 10, 1996.
    Rural Metro was assigned call sign KNNR223 for this station. On
    February 24, 1997, the Bureau's Consumer Assistance Branch requested
    information from Rural Metro concerning the construction and
    operational status of Station KNNR223.[^2] On June 24, 1997, Rural
    Metro responded that it constructed and commenced operation of
    station KNNR223 on June 10, 1997.[^3] On July 2, 1997, the Bureau's
    Informal Complaints and Public Inquiry Branch requested confirmation
    that Rural Metro did not place Station KNNR223 in operation until
    June 10, 1997.[^4]

3.  On July 17, 1997, Rural Metro notified the Bureau's Informal
    Complaints and Public Inquiry Branch that Station KNNR223 was placed
    in operation on June 10, 1997.[^5] In addition, Rural Metro
    requested to retain the authorization for Station KNNR223.[^6] Rural
    Metro explained that it was unaware of its authority for Station
    KNNR223 "until well into the term of the license."[^7] Rural Metro
    asserts that although it took immediate steps to construct and
    operate the system, it was unable to complete construction in a
    timely manner.[^8] Rural Metro further stated that it provides
    communications for public safety entities of the City of Scottsdale,
    Arizona.[^9] Specifically, Rural Metro indicates that it provides
    communications for the Scottsdale Fire Department and the Enhanced
    911 center for Maricopa County.[^10]

4.  On October 7, 1997, the Branch notified Rural Metro that it was in
    violation of the Commission's Rules because it failed to place its
    station in operation within eight months from the date of the
    license grant and could not provide a commercial service to third
    parties for profit as a private mobile radio services licensee.[^11]
    On November 14, 1997, Rural Metro requested a waiver of Section
    90.633 of the Commission's Rules.[^12] On February 5, 1998, the
    Branch effectively denied Rural Metro's request by canceling the
    license for Station KNNR223 for failure to construct.[^13] On
    February 12, 1998, the Branch deleted Station KNNR223 from the
    Commission's database.

5.  On March 9, 1998, Rural Metro requested reconsideration of the
    cancellation of its license for Station KNNR223.[^14] In the
    alternative, Rural Metro requested that the effectiveness of the
    Branch's decision be stayed and that it be permitted to assign the
    license for Station KNNR223 to the City of Scottsdale or a related
    entity.[^15] On March 16, 1998, Rural Metro notified the Licensing
    Division that it is a "fire department which serves the fire safety
    needs of the City of Scottsdale."[^16] Rural Metro further stated
    that it was not using its license to "provide service to a third
    party;" rather it was providing emergency services on a contract
    basis to the City of Scottsdale.[^17] As a result, Rural Metro
    requested to retain the license for Station KNNR223.[^18]

6.  On July 9, 1998, eight applications for Business Radio licenses were
    granted for frequency 936.6625 in Litchfield, Arizona.[^19] On
    August 7, 1998, Rural Metro sought reconsideration of the license
    grants and dismissal of the applications.[^20] On July 10, 1998,
    thirteen applications for Business Radio licenses were granted for
    frequency 936.6625 in Litchfield, Arizona.[^21] On July 13, 1998,
    nine applications for Business Radio licenses were granted for
    frequency 936.6625 in Litchfield, Arizona.[^22] On August 7, 1998,
    one application for a Business Radio license was granted for
    frequency 936.6625 in Litchfield, Arizona.[^23] On August 10, 1998,
    Rural Metro sought reconsideration of the grant of licenses for
    frequency 936.6625 MHz in Litchfield, Arizona from July 13, 1998
    through August 10, 1998 and the dismissal of the applications.[^24]
    Between August 31, 1998 and September 4, 1998, six applications were
    granted for frequency 936.6625 in Litchfield, Arizona.[^25] On
    September 30, 1998, Rural sought reconsideration of the grant of
    licenses for frequency 936.6625 in Lichtfield, Arizona between
    August 31, 1998 and September 4, 1998.[^26]

# discussion

7.  Rural Metro requests reconsideration of the Branch determination
    that its license cancelled automatically.[^27] In 1997, section
    90.633(c) of the Commission's Rules required licensees of
    conventional systems to place their authorized facilities in
    operation not later than eight months after the date of grant of the
    license for the system.[^28] The license for Station KNNR223 was
    granted on May 10, 1996, thus the station was required to be placed
    in operation no later than January 10, 1997. Clearly, Rural Metro
    did not place Station KNNR223 into operation within eight months. In
    fact, Rural Metro itself indicates that it did not place Station
    KNNR223 into operation until over a year after the grant of the
    Station's license. When construction is not timely completed, the
    authorization cancels automatically and must be returned to the
    Commission.[^29] Even if the license is not returned, it is still
    cancelled.[^30] Thus, Rural Metro's license cancelled due to its
    failure to timely construct the authorized facilities.

8.  Further, the Commission has determined that a licensee who seeks an
    extension of time to construct must file its waiver request prior to
    the cancellation of its license because the license cancels at the
    end of the original construction deadline.[^31] In this proceeding,
    Rural Metro did not request a waiver of its construction deadline
    until November 14, 1997. By such date, Rural Metro's license already
    had automatically cancelled on January 10, 1997. Consequently, we
    find that the Branch properly denied Rural Metro's waiver request.

9.  In addition, Rural Metro asserts that the public interest will be
    served by allowing it to retain the license for station
    KNNR223.[^32] Although Rural Metro asserts that it provides
    communications for public safety entities of the City of Scottsdale,
    Arizona, Rural Metro fails to demonstrate that unique circumstances
    are involved or that there is no reasonable alternative solution
    within the existing rules in support of its waiver request.[^33]
    Further, the purpose of the eight-month construction requirement is
    to ensure that licensees actually use the spectrum that they are
    assigned.[^34] Based on the record in this proceeding, it appears
    that this spectrum laid fallow from May 10, 1996, when Rural Metro
    received its grant, until June 10, 1997, when Rural Metro finally
    constructed its facilities.

10. Rural Metro also objects to the deletion of Station KNNR223 from the
    licensing database while its petition for reconsideration was
    pending.[^35] We are not persuaded by this argument A stay of an
    action pending the disposition of a petition for reconsideration
    lies within the discretion of the delegated authority.[^36] In this
    context, the Branch decided not to stay the effectiveness of its
    decision. Rural Metro has not persuaded us that the Branch's
    decision was improper.

11. By deleting Station KNNR223 from the licensing database, the subject
    frequencies became available for assignment to other applicants. As
    a result, thirty-seven licenses on the subject frequencies in the
    Lichtfield, Arizona were granted between July 9, 1998 and September
    4, 1998. Rural Metro argues that its petitions should have been
    resolved before the subject frequencies were made available for
    assignment. However, as previously stated, Section 1.102 of the
    Commission's Rules gives the Branch the discretion to stay an
    action. Because the Branch did not order a stay of the denial of
    Rural Metro's waiver request, the deletion of Station KNNR223 from
    the licensing database was proper. Consequently, the grant of the
    licenses was proper. Accordingly, we affirm the grant of the
    licenses issued between July 9, 1998 and September 4, 1998 for
    frequency 936.6625 MHz in Lichtfield, Arizona and deny the
    petitions.

# Ordering clauses

9.  IT IS ORDERED, 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, that the
    petition for reconsideration filed by Rural Metro Corporation on
    March 8, 1998, IS DENIED.

10. IT IS FURTHER ORDERED, 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, that the
    petition for reconsideration filed by Rural Metro Corporation on
    August 7, 1998, IS DENIED.

11. IT IS FURTHER ORDERED, 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, that the
    petition for reconsideration filed by Rural Metro Corporation on
    August 10, 1998, IS DENIED.

12. IT IS FURTHER ORDERED, 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, that the
    petition for reconsideration filed by Rural Metro Corporation on
    September 30, 1998, IS DENIED.

13. 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 {#wireless-telecommunications-bureau .unnumbered}

[^1]: Rural Metro Petition for Reconsideration filed on Mar. 9, 1998
    (Petition I); Rural Metro Petition for Reconsideration filed on Aug.
    7, 1998 (Petition II); Rural Metro Petition for Reconsideration
    filed on Aug. 10, 1998 (Petition III); Rural Metro Petition for
    Reconsideration filed on September 30, 1998 (Petition IV).

[^2]: Letter from Kathryn M. Garland, Chief, Consumer Assistance Branch,
    Customer Service Division to Mike Enos, Rural Metro Corp. on Feb.
    24, 1997 (Status of Operation Inquiry).

[^3]: *Id*. Rural Metro completed the form letter and returned it to the
    Commission, dated June 18, 1997.

[^4]: Letter from Sharon Bowers, Acting Chief, Informal Complaints &
    Public Inquiry Branch, Wireless Telecommunications Bureau to Rural
    Metro Corp., Attn. Mike Enos, July 2, 1997.

[^5]: Letter from Kathleen A. Kaercher, Brown & Schwanninger, counsel to
    Rural Metro Corp to Susan A. Miller, , Informal Complaints & Public
    Inquiry Branch, Wireless Telecommunications Bureau, July 17, 1997
    (July 17 Letter).

[^6]: *Id*. at 1.

[^7]: *Id*. at 2; *see also* Petition I at 2.

[^8]: July 17 Letter at 1; *see also* Petition I at 2. Rural Metro
    states that it was unaware of the licensing of Station KNNR223 until
    after the deadline for constructing the station had passed. Petition
    IV at 2.

[^9]: July 17 Letter at 1.

[^10]: *Id*.

[^11]: Letter from Michael Regiec, Acting Chief, Licensing and Technical
    Branch, to Rural Metro Corp., ATTN: Mike Enos, Oct. 7, 1997.

[^12]: Rural Metro Request for Waiver filed Nov. 14, 1997.

[^13]: Letter from Michael J. Regiec, Acting Chief, Licensing and
    Technical Analysis Branch, Public Safety and Private Wireless
    Division to Kathleen A. Kaercher, Brown and Schwaninger, counsel to
    Rural Metro, dated Feb. 5, 1998.

[^14]: Petition I.

[^15]: *Id*. at 5.

[^16]: Rural Metro Supplement to Petition for Reconsideration filed Mar.
    16, 1998.

[^17]: *Id*. at 2.

[^18]: *Id*.

[^19]: Amy Zak & Associates (ZAK) call sign WPMF777, File No. A018704;
    American Industrial Maintenance (AIM), call sign WPMF782, File No.
    A018705; Ace Reprographics, Inc. (Ace), call sign WPMF786, File No.
    A018706; Carefree Homes (Carefree), call sign WPMF791, File No.
    A018707; CEI-Clola Enterprises, Inc. (CEI-Clola), call sign WPMF793,
    File No. A018708; Blucor Contracting, Inc. (Blucor), call sign
    WPMF800, File No. A018709; Northland Trucking, call sign WPMF901,
    File No. A018689; Noah Webster Basic School, call sign WPMF907, File
    No. A018690.

[^20]: Petition II at 4.

[^21]: Mesa Verde Landscape Co., call sign WPMF922, File No. A018691;
    Magna Electric Contracting Co., call sign WPMF923, File No. A018693;
    Lucas Ojeda, call sign WPMF924, File No. A018693; Huntwood
    Industries, call sign WPMF925, File No. A018694; Healthcor, call
    sign WPMF928, File No. A018695; DVC Construction., call sign
    WPMF929, File No. A018696; Diamond Mechanical Co., call sign
    WPMF930, File No. A018697; Diamond Back Yard Design, call sign
    WPMF933, File No. A018697; David Frank Company, Inc., call sign
    WPMF937, File No. A018699; Cromalloy of Arizona, Inc., call sign
    WPMF941, File No. A018700; Black Rose Investigations, call sign
    WMPF943, File No. A018701; Bill Luke Dodge, Inc., call sign WMPF946,
    File No. A018702, Arizona Career & Technology, call sign WMPF948,
    File No. A018703, Phoenix Economy Supply of Arizona, call sign
    WPMG209, File No. A018715; Phoenix Baptist Hospital & Medical
    Center, call sign WPMF998, File No. A018716.

[^22]: Saturn of Glendale, call sign WMPF981, File No. A018712; Western
    Air Conditioning and Heating, call sign WMPF984, File No. A018711;
    Valley Towing & Limousine Service, call sign WMPF996, File No.
    A018639; Wilma Lombardi, call sign WMPF997, File No. A018710;
    Phoenix Baptist Hospital & Medical Center, call sign WMPF997, File
    No. A018716; Reed Express Delivery, call sign WMPG202, File No.
    A018713; Pro Grade Services, call sign WMPG208, File No. A018714.

[^23]: Expedite Handlers, Inc., call sign WMPI933, File No. A019839.

[^24]: Petition III at 7. An Opposition to Petition III was filed by
    Zak, AIM, Ace, Carefree, CEI-Clola, and Blucor (jointly
    respondents). *See* Respondents Opposition to Petition for
    Reconsideration filed on Aug. 20, 1998.

[^25]: Woudenberg Enterpises, call sign WPML205, File No. A023559;
    Supershuttle of Arizona, call sign WPML227, File No. A023560;
    Security Roofing and Construction, call sign WPML233, File No.
    A023561; Arrowhead Towing, call sign WPML233, File No. D111794; Bobs
    Barricade, Inc., call sign WPML562, File No. D111791; Akai Security,
    Inc., call sign WPML564, File No. D111792.

[^26]: Petition IV.

[^27]: Petition I at 1.

[^28]: 47 C.F.R. § 90.633(c) (1997).

[^29]: *See* Amendment of Part 90 of the Commission\'s Rules Concerning
    the Construction, Licensing, and Operation of Private Land Mobile
    Radio Stations, PR Docket No. 90-481, 5 FCC Rcd. 6401 (1990).

[^30]: *Id*. at 6408 n.10.

[^31]: *Cf.* Daniel R. Goodman, Receiver; Dr. Robert Chan, *Memorandum
    Opinion and Order and Order on Reconsideration*, 13 FCC Rcd. 21,944,
    21,972 & n.185 (1998).

[^32]: July 17 Letter at 1.

[^33]: 47 C.F.R. § 90.151 (1997).

[^34]: See Amendment of Parts 1 and 90 of the Commission\'s Rules
    Concerning the Construction, Licensing, and Operation of Private
    Land Mobile Radio Stations, Report and Order, RM-6910, 6 FCC Rcd.
    7297, 7299 ¶ 8 (1991).

[^35]: Rural Metro Reply to Opposition to Petition II filed on Sept. 2,
    1998.

[^36]: 47 C.F.R. § 1.102(b)(2).