**Before the**

**Federal Communications Commission**

**Washington, D.C. 20554**

In the Matter of )

)

BISHOP CLARKSON MEMORIAL HOSPITAL, ) )

DOCTORS HOSPITAL, )

WILLIAM BEAUMONT HOSPITAL, AND )

GOOD SAMARITAN HOSPITAL )

)

Requests for Permanent Waiver For Special )

Emergency Radio Service Paging Facilities on )

certain 453 MHz frequencies in Omaha, Nebraska; )

Columbus, Ohio; Royal Oak and Troy, Michigan; )

and Dayton, Ohio. )

**ORDER**

**Adopted:** April 14, 1999 **Released:** April 14, 1999

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

**I. INTRODUCTION AND EXECUTIVE SUMMARY**

We have before us Requests for Waiver filed by Bishop Clarkson Memorial
Hospital, Doctors Hospital, William Beaumont Hospital, and Good
Samaritan Hospital, asking that the Commission grandfather their
existing Special Emergency Radio Service (SERS)[^1] paging systems
operating on 453.075, 453.175, 453.025 MHz, and 453.075 MHz,
respectively. Each of these four hospitals contends that it meets at
least one criterion required for permanent waiver of such systems. Based
on the record in this proceeding, we conclude that these Requests for
Waiver should be granted.

**II. BACKGROUND**

  *Emergency Medical Radio Service Report and Order.* On January 14,
1993, the Commission established the Emergency Medical Radio Service
(EMRS) as a new Public Safety Radio Service (PSRS).[^2] The EMRS was
created as a discrete radio service to enhance the reliability of
emergency medical radio communications by dedicating specific
frequencies solely to life support related transmissions.[^3] The
Commission reallocated thirty-nine VHF and UHF frequencies for EMRS
use,[^4] and limited eligibility to persons or entities who provide
basic or advanced life support services on an ongoing basis.[^5] Four of
these frequencies, 453.025/.075/.125/.175 MHz, were previously assigned
for one-way paging operations under SERS.[^6]

  In reassigning the four 453 MHz frequencies for EMRS use, the
Commission recognized the concerns of existing SERS licensees on these
channels and acknowledged that in certain situations an accommodation
may be warranted to allow licensees to continue operating.[^7] It,
therefore, provided a process by which one-way medical paging systems
operating on the subject frequencies may permanently remain on their
existing frequencies through waiver of the Commission\'s Rules.[^8]
Under this process, a paging system may be grandfathered if a licensee
currently operating on a one-way paging channel demonstrates that
either: (1) adequate spectrum exists for emergency medical transmissions
in its area of operation; or (2) relocation of its medical paging system
would not serve the public interest;[^9] or

\(3\) relocation would significantly disrupt public safety
communications.[^10] Licensees were provided a five- year period \--
that is, from January 14, 1993, through January 14, 1998, \-- within
which to request that their systems be grandfathered. Otherwise,
licensees operating on these 453 MHz frequencies were required to cease
one-way medical paging operations after January 14, 1998.[^11]

  *Waiver Grants*. On February 8, 1996, the Commission released a
*Memorandum Opinion and Order* reaffirming its decision to establish the
EMRS and reallocate thirty-nine SERS frequencies for emergency medical
communications.[^12] The Commission stated that the record supported the
need for additional spectrum for emergency medical use because the
substantial increase in the demand for emergency medical service
frequencies nationwide significantly overburdened existing
frequencies.[^13] Further, the Commission granted a request by ProNet,
Inc. (ProNet) to permanently waive mandatory reassignment of 453.125 MHz
in the greater Chicago metropolitan area to EMRS.[^14] The Commission
concluded that although ProNet was only required to meet one criterion,
it met all the established criteria.[^15] ProNet demonstrated, with
findings from a study of spectrum usage (Trott Study I), that existing
emergency medical service channels in the Chicago area displayed
virtually no congestion,[^16] and that ProNet\'s SERS system was
intensely utilized.[^17] The Commission noted that ProNet\'s migration
to another channel other than ProNet\'s would involve significant cost,
and, because of ProNet\'s intense use of 453.125 MHz, such migration
would likely cause disruption to public safety communications.[^18]

On March 19, 1998, the Wireless Telecommunications Bureau (Bureau)
granted Petitions for Permanent Waiver filed by Kaiser Foundation
Hospitals/Kaiser Foundation Health Plan, Inc. (*Kaiser*), and New York
Hospital-Cornell Medical Center (*NYH*).[^19] In the *Kaiser* case, the
Bureau concluded that permanently grandfathering Kaiser\'s paging system
on 453.025 MHz would avoid not only a considerable expenditure of
resources, but would prevent interruption of these important
communications.[^20] Further, a spectrum utilization study (Trott Study
II), submitted by Kaiser, demonstrated that without the availability of
453.025 MHz there was sufficient EMRS spectrum in the Southern
California metropolitan area to meet existing needs.[^21] The Bureau
also concluded that considering the significant conversion costs,
relocation of Kaiser\'s system to a new frequency would disserve the
public interest.[^22]

In *NYH,* the Bureau concluded that granting the waiver request would
prevent interruption of important communications because it would avoid
the need to obtain new equipment and implement a process for switching
to a new frequency.[^23] Also, a study of frequency utilization (Trott
Study III) indicated that adequate spectrum remained to meet the needs
of EMRS entities in New York City even with NYH\'s continued use of
453.025 MHz. The study also indicated that usage levels on other SERS
and Business Radio Service frequencies considered as potential
\"replacement\" channels was so high that that spectrum was insufficient
to support the added volume of NYH\'s pagers.[^24] The Bureau held that
both Kaiser and NYH met the requisite showing for grant of their waiver
requests.[^25]

  *Subject Waiver Requests.* Bishop Clarkson Memorial Hospital, Doctors
Hospital, William Beaumont Hospital, and Good Samaritan Hospital filed
waiver requests seeking to continue their medical paging operations on
their respective frequencie.[^26] In support of its request, Bishop
Clarkson Memorial Hospital submits that adequate spectrum is available
for emergency medical transmissions in its service area; whereas,
Doctors Hospital and William Beaumont Hospital assert that relocation of
their paging systems would disrupt public safety communications and that
there are no reasonable alternative frequencies on which to operate. On
the other hand, Good Samaritan Hospital contends that it meets all three
criteria warranting permanent grandfathering of its medical paging
operations.

**III. DISCUSSION**

  To obtain a waiver of the frequency reassignment implemented by the
*EMRS Report and Order*, a petitioner is required to meet any one of
three established criteria.[^27] As discussed below, we conclude that
all four hospitals have met the requisite showing as to whether their
requests should be granted. 

*Bishop Clarkson Memorial Hospital.* On January 9, 1998, Bishop Clarkson
Memorial Hospital (Bishop Hospital) filed a Request for Waiver (Bishop
Hospital Waiver) to continue its medical paging operations on 453.075
MHz.[^28] The hospital has demonstrated that in the Omaha metropolitan
area, emergency medical service transmissions are conducted on MED 9
(462.950/467.950 MHz). In case of failure of the main and standby
stations on MED 9, radio communications facilities are available on MED
10 (462.975\\467.975 MHz).[^29] Bishop Hospital notes that in the event
of a disaster or other emergency situations that would require multiple
simultaneous radio conversations, MED 1 through MED 8 are licensed and
available for use by EMRS agencies in Omaha.[^30] Bishop Hospital
submits a list demonstrating that there is adequate UHF spectrum in the
area. Included in the list is one of the former SERS paging channels
(453.125 MHz), now reassigned for emergency medical radio use, which is
not licensed within 70 miles of Bishop Hospital.[^31]

Bishop Hospital also notes that the City of Omaha and Douglas County are
merging their emergency dispatch operations into a combined facility,
with plans to implement an 800 MHz trunked radio system in the very near
future.[^32] The plans for the new radio system include relocating
emergency medical communications to the 800 MHz band which will
eliminate any need for Bishop Hospital\'s paging frequency.[^33] In
further support of its Waiver Request, Bishop Hospital submits
correspondence from the State of Nebraska\'s Radio Communications
Manager, [^34]and the City of Omaha\'s Chief of Communications,[^35]
attesting to the above facts and favoring the continuation of Bishop
Hospital\'s one-way medical paging operations on 453.075 MHz We,
therefore, conclude that Bishop Hospital has demonstrated that adequate
spectrum remains to meet the communications needs of EMRS entities in
Omaha, Nebraska, even with the hospital\'s continued use of 453.075 MHz.

*Doctors Hospital.* On January 14, 1998, Doctors Hospital filed a
Request for Waiver (Doctors Hospital Waiver) to continue to operate
one-way medical paging operations on a permanent basis on frequency
453.175 MHz.[^36] Doctors Hospital is a regional non-profit hospital
which operates two acute care facilities, Doctors Hospital North and
Doctors Hospital West, which are located approximately twelve miles
apart in Columbus, Ohio.[^37] The licensee notes that it is one of the
leading training institutions for physicians and osteopathy medicine in
the country.[^38] Principal users of the hospital\'s paging system
include attending physicians, physicians-in-training (residents and
interns), medical students and hospital staff (including trauma teams
and nurses). Medical personnel in intensive care units, emergency rooms,
laboratories, and radiology and pharmacy departments also use the
hospital\'s paging system as their primary means of contact.[^39]
Emergency surgical and trauma teams also have been assigned pagers on
the subject system for use during life threatening situations such as
cardiac failures.[^40] Five hundred and twenty (520) pagers are deployed
to staff and physicians at both hospitals.[^41]

Doctors Hospital asserts that relocation of its medical paging
operations would not serve the public interest because there is no
reasonable alternative channel for the subject paging system. It submits
that frequencies are either unavailable or changing to those frequencies
that are available would necessitate costly and unaffordable new
equipment.[^42] For example, 453.400 MHz was considered for use, but
this frequency is currently licensed to the State of Ohio Department of
Transportation for temporary fixed base and mobile repeaters throughout
the state.[^43] As a non-profit entity, the hospital asserts that the
current system represents the most cost effective and efficient
communications means. Doctors Hospital contends that any change in
frequency would produce a significant increase in operational costs,
maintenance and overhead.[^44] It further contends that the cost of
accommodating a change in frequency for Doctors Hospital\'s paging
system would be \$180,240. This amount comprises \$70,000 for two base
transmitters (\$35,000 each), and \$110,240 for 500 new pagers (\$212
per pager).[^45] The hospital contends that it can ill-afford these
costs. We note that the Commission established the EMRS waiver criteria,
in part, to accommodate SERS operations that would otherwise sustain
significant conversion costs.[^46]

According to Doctors Hospital, relocation of its paging operations to a
frequency other than its current one would be an undue hardship for both
the hospital and the community because it would cause disruption of
essential communications services.[^47] Doctors Hospital contends that
no commercial alternatives are available within the immediate vicinity
that meet the coverage needs for communications throughout the
hospital.[^48] We find that Doctors Hospital has demonstrated that the
public interest would not be served by requiring the relocation of its
paging system. In view of the above, we conclude that permanent
grandfathering of the subject medical paging operations would avoid the
impairment of the public safety and well-being of the residents of
Columbus, Ohio.

*William Beaumont Hospital.* On January 28, 1998, William Beaumont
Hospital (Beaumont Hospital) filed a Request for Waiver (Beaumont
Hospital Waiver) to continue to operate its medical paging operations on
frequency 453.025 MHz.[^49] It wishes to do so, however, only on a
limited basis.[^50] Beaumont Hospital has operated a wide-area,
simulcast paging system in Royal Oak, Michigan, and Troy, Michigan.[^51]
Until January of 1998, approximately 4,000 pages per month were
transmitted over the hospital\'s in-house paging system, while 5,000
pages per month were transmitted by the hospital over 931.2875 MHz,
licensed to Paging Network of Michigan Inc. (PageNet).[^52] Since that
time, PageNet \-- at the request of Beaumont Hospital \-- has been
converting the hospital\'s remaining 1000 Motorola in-house pagers to
long-range pagers. Consequently, 453.025 MHz only is needed by Beaumont
Hospital during scheduled down times for system upgrades and
non-scheduled down times for system hardware and software failures.[^53]
According to the hospital, down times can be critical because all the
hospital\'s telemetry monitoring devices, as well as ventilator alarms,
are programmed to automatically broadcast a page when a patient is in
distress.[^54] PageNet has estimated that the cumulative total for down
time in the calendar year 1997 was approximately 15 hours.[^55] Should
the PageNet system experience a long-term outage, Beaumont Hospital
states its intention to use the 453.025 MHz paging system only for
critical life sustaining situations.[^56]

Beaumont Hospital has been advised by its Motorola Maintenance provider,
Comsource, that other frequencies (100 MHz frequency range) available
for the hospital\'s rare emergency back-up use may already be crowded,
which would cause the hospital\'s system to queue pages to transmit when
a channel is available.[^57] Furthermore, other area businesses and
hospitals use the 100 MHz frequency range.[^58] Beaumont Hospital
asserts that Comsource has advised it that the cost to convert to a new
frequency for the rare emergency back-up use would be approximately
\$60,000 to replace the base stations, transmitters and other related
equipment at the two hospital facilities.[^59] Additionally, it would
cost Beaumont \$200,000 to replace 1000 pagers.[^60] Beaumont Hospital
submits that this is not an economically viable option for the
hospital.[^61] Moreover,Beaumont Hospital represents that Comsource does
not believe that 453.025 MHz is used by any entity in Royal Oak and
Troy, Michigan, other than Beaumont Hospital.[^62] Also according to
Beaumont Hospital Comsource does not know of any immediate plans by
emergency medical entities in the subject geographical areas to occupy
453.025 MHz.[^63]

Beaumont Hospital has used substantial financial resources to convert to
a 900 MHz paging system. It requests only to be allowed to maintain the
current 453.025 MHz facilities as a back-up system We agree with the
hospital that the significant costs of converting to a frequency other
than 453.025 MHz for use only as a back-up medical paging system is not
a viable option. Further, we note that failure to receive a waiver would
result in the discontinuance of the hospital\'s back-up system with
potential loss of life. This would be contrary to the public interest.
In view of the above, we conclude that Beaumont Hospital has
demonstrated that its current paging operations on 453.025 MHz should
continue on a back-up basis, otherwise significant public safety
communications would be disrupted.

*Good Samaritan Hospital.* On October 21, 1997, Good Samaritan Hospital
(Samaritan Hospital) filed a Request for Waiver (Samaritan Hospital
Waiver) to continue to operate its medical paging operations on
frequency 453.075 MHz.[^64] Samaritan Hospital\'s paging system \-- with
approximately 2,000 pagers \-- is used often by the hospital staff to
provide vital emergency communications to the physicians, nurses and
technicians who staff the hospital.[^65] Samaritan Hospital employs its
one-way paging system for medical alert operations, *i.e.*, summoning
attending physicians and other \"on-call\" staff to the bedsides of
acute and critical patients.[^66] The hospital submits that conversion
to another frequency would cost it a minimum of \$25,000 in fixed
equipment as well as replacements for 2,000 pagers.[^67] In the interim,
Samaritan Hospital submits that it is the only licensee using the
frequency in the Dayton area.[^68] Further, the hospital has monitored
the various frequencies now available to it under current Commission
rules, and determined that those frequencies are so congested that calls
to Samaritan Hospital\'s ambulances and support staff would result in
delays of up to five minutes. Samaritan Hospital contends that waits of
such duration are impermissible in medical emergencies.[^69] In support
of the waiver request, Samaritan Hospital submitted a letter of
endorsement from the EMS Division of Emergency Medical Services of the
Ohio Department of Public Safety.[^70]

If Samaritan Hospital is required to relocate to another frequency,
public safety communications are likely to be disrupted. We believe that
granting the waiver will permit the hospital to continue to utilize the
frequency efficiently and economically while providing the needed
emergency service. Further, Samaritan Hospital has demonstrated that
adequate spectrum remains to meet the communications needs of EMRS
entities in Dayton, Ohio, even with the hospital\'s continued use of
453.075 MHz. In view of the above, we conclude that permanent
grandfathering of the subject medical paging operations would avoid the
impairment of the public safety and the well-being of the residents of
Dayton, Ohio.[^71]

**IV. CONCLUSION**

  In sum, we conclude that the subject four hospitals have met the
requirements established in the *EMRS Report and Order* for the
permanent grandfathering of their SERS systems. Therefore, we grant
their requests for permanent waiver and permit them to continue
operating their one-way medical paging systems on the subject
frequencies in the 453 MHz band to the extent indicated herein. This
action serves the public interest because the hospitals\' migration to
other paging frequencies would pose unnecessary risks to essential
medical paging communications without significant concomitant public
interest benefits.

**V. ORDERING CLAUSES**

  Accordingly, IT IS ORDERED, pursuant to the authority of Section 4(i)
of the Communications Act of 1934, as amended, 47 U.S.C. § 154(i), and
Sections 1.925, 90.20(d)(60), 90.22 of the Commission\'s Rules, 47
C.F.R. §§ 1.925, 90.20(d)(60), 90.22, that the Requests for Waiver filed
by Bishop Clarkson Memorial Hospital on January 9, 1998, Doctors
Hospital on January 14, 1998, William Beaumont Hospital on January 28,
1998, and Good Samaritan Hospital on October 21, 1997, to continue
operating their paging stations on the subject 453 MHz frequencies ARE
GRANTED.

  This action is taken under delegated authority pursuant to Section
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

[^1]: ^?^ In 1996, twenty private land mobile radio services recently
    were consolidated into two pools \-- one for Public Safety
    (including SERS) and one for Industrial/Business. *See* Replacement
    of Part 90 by Part 88 to Revise the Private Land Mobile Radio
    Services and Modify the Policies Governing Them, PR Docket No.
    92-235, *Second Report and Order*, 12 FCC Rcd 14307 (1997). Prior to
    consolidation, SERS was not a Public Safety service. Rather, SERS
    covered such categories as medical services, rescue organizations,
    veterinarians, persons with disabilities, disaster relief
    organizations, and school buses, and it comprised Subpart C of Part
    90 of the Commission\'s Rules, 47 C.F.R. Part 90, Subpart C (1996).

[^2]: ^?^ Amendment of Part 90 of the Commission\'s Rules to Create the
    Emergency Medical Radio Service, PR Docket No. 91-72, *Report and
    Order*, 8 FCC Rcd 1454, 1455 (1993) (*EMRS Report and Order*).

[^3]: ^?^ The EMRS is no longer a separate private land mobile radio
    service. Rather, emergency medical radio communications are included
    in one of the two pools of private land mobile frequencies, *i.e.,*
    the Public Safety pool *See* para. 2 note 1, *supra*.

[^4]: ^?^ *EMRS Report and Order,* 8 FCC Rcd 1454, 1458-60.

[^5]: ^?^ *Id.* at 1456.

[^6]: ^?^ *Id*. at 1457. These frequencies previously were shared with
    the Local Government Service in the Pubic Safety Radio Services for
    highway call box operation. Highway call box operations existing on
    the adoption date of the *EMRS Report and Order* were indefinitely
    grandfathered. *Id.* at 1457, n.38.

[^7]: ^?^ *Id.* at 1459.

[^8]: ^?^ *Id*.

[^9]: ^?^ One method of meeting this criteria would be to demonstrate
    that there is no reasonable alternative channel for the subject
    paging system. *Id.*

[^10]: ^?^ *Id*.

[^11]: ^?^ *Id.*

[^12]: ^?^ Amendment of Part 90 of the Commission\'s Rules to Create the
    Emergency Medical Radio Service, PR Docket No. 91-72, *Memorandum
    Opinion and Order*, 11 FCC Rcd 1708, 1709 (1996) (*EMRS MO&O*).

[^13]: ^?^ *Id.*

[^14]: ^?^ *Id.* at 1711.

[^15]: ^?^ *Id*.

[^16]: ^?^ *Id.* at 1710.

[^17]: ^?^ *Id.* at 1711.

[^18]: ^?^ *Id*.

[^19]: ^?^ Kaiser Foundation Hospitals and Kaiser Foundation Health
    Plan, Inc., 13 FCC Rcd 5294 (1998) (*Kaiser*); The New York
    Hospital - Cornell Medical Center, 13 FCC Rcd 5301 (1998) (*NYH*).

[^20]: ^?^ *Kaiser*, 13 FCC Rcd at 5298.

[^21]: ^?^ *Id.*

[^22]: ^?^ *Id.* at 5299.

[^23]: ^?^ *NYH,* 13 FCC Rcd at 5304.

[^24]: ^?^ *Id.* at 5305.

[^25]: ^?^ Kaiser,13 FCC Rcd at 5297*; NYH*, 13 FCC Rcd at 5304.

[^26]: ^?^ Licensees who filed timely waiver requests have been
    permitted to continue operations until resolution of their requests.
    Licensees who filed waiver requests after the deadline of January
    14, 1998, were only permitted to continue operations after first
    receiving Special Temporary Authority (STAs).

[^27]: ^?^ *See* para. 3 *supra. See also* Silver Cross Hospital, DA
    99-244 (Jan. 29, 1999); North Broward Medical Center, *et al.,* DA
    99-275 (Feb. 2, 1999); Alvarado Hospital Medical Center *et al.*, DA
    99-356 (Feb. 26, 1999); and Children\'s Medical Center, DA 99-551
    (Mar. 19, 1999). In addition, the Commission has an obligation to
    seek out the public interest in particular matters and
    individualized situations. *See WAIT Radio v. FCC*, 418 F.2d 1153,
    1157 (D.C.Cir. 1969).

[^28]: ^?^ Bishop Waiver at 1. Bishop Hospital\'s authorized base
    station for 453.075 MHz is WNSC745.

[^29]: ^?^ *Id.*

[^30]: ^?^ *Id.*

[^31]: ^?^ *Id.*

[^32]: ^?^ *Id.* at 2.

[^33]: ^?^ *Id.*

[^34]: ^?^ *See* Letter from Michael Jeffres, Radio Communications
    Manager, Division of Communications, State of Nebraska, to Federal
    Communications Commission (Dec. 17, 1997).

[^35]: ^?^ *See* Letter from Mark S. Conrey, Chief of Communications,
    Communications Department, City of Omaha, to Federal Communications
    Commission (Dec. 22, 1997).

[^36]: ^?^ Doctors Hospital Waiver at 1. Doctors Hospital\'s authorized
    base station for 453.175 MHz is WNWY813.

[^37]: ^?^ *Id.*

[^38]: ^?^ *Id.*

[^39]: ^?^ *Id.*

[^40]: ^?^ *Id.*

[^41]: ^?^ *Id.*

[^42]: ^?^ *Id.* at 2.

[^43]: ^?^ *Id.*

[^44]: ^?^ *Id.* at 3.

[^45]: ^?^ *Id*.

[^46]: ^?^ *EMRS MO&O* at 1711.

[^47]: ^?^ Doctors Hospital Waiver at 3.

[^48]: ^?^ *Id.*

[^49]: ^?^ Beaumont Hospital Waiver at 1. Beaumont Hospital\'s
    authorized base stations for 453.025 MHz are KNGA973 and KNGG640.
    The hospital requests that it be permitted to use the two facilities
    on a simulcast basis. *Id.* at 6. Under our current rules, Beaumont
    Hospital may operate on a simulcast basis without having to either
    notify the Commission or modify its license. *See* 47 C.F.R. §§
    90.135(a)(1-7), 90.135(b)(6).

[^50]: ^?^ *Id.* at 1.

[^51]: ^?^ *Id.*

[^52]: ^?^ *Id.* at 4.

[^53]: ^?^ *Id.* at 4-5.

[^54]: ^?^ *Id.* at 5.

[^55]: ^?^ *Id.*

[^56]: ^?^ *Id*.

[^57]: ^?^ *Id.* at 4.

[^58]: ^?^ *Id.*

[^59]: ^?^ *Id.*

[^60]: ^?^ *See also* Letter from Motorola, Central Division, to William
    Beaumont Hospital, Office of Communications (Aug. 29, 1996).

[^61]: ^?^ Beaumont Hospital Waiver at 4.

[^62]: ^?^ *Id.*

[^63]: ^?^ *Id.*

[^64]: ^?^ Samaritan Hospital Waiver at 1. Samaritan Hospital\'s
    authorized base station for 453.075 MHz is WNDL543.

[^65]: ^?^ *Id.* at 2.

[^66]: ^?^ *Id.*

[^67]: ^?^ *Id.*

[^68]: ^?^ *Id.*

[^69]: ^?^ *Id.*

[^70]: ^?^ *See* Letter from Linda C. Ishler, Executive Administrator,
    Division of Emergency Medical Services, Ohio Department of Public
    Safety, to Mary Cottrill, Director of Telecommunications, Good
    Samaritan Hospital & Health Center (Oct. 9, 1997).

[^71]: ^?^ *See* *Kaiser*, 13 FCC Rcd at 5297-99; *NYH*, 13 FCC Rcd at
    5304-06.