DMR requires re-coordination, even if someone has an analog license already. The reason for it is the unusual channel occupancy characteristics that many DMR systems have, especially when both timeslots are used and one may be extremely busy or have polling or AVL data on it. That coordination fee is an extra expense and there's no guarantee that the system will pass protecting co-channel and adjacent channel receivers from incumbent licensees (that's about a 0% in NJ without the applicant getting letters from each of the others). That gets a little better when others in the area abandon their conventional licenses for county or NJICS trunked systems. When that happens, theoretically they're supposed to cancel their licenses and give those frequencies back (I kinda laughed a little as I typed that).
I know for a fact that the FCC has fined agencies that just turned up a DMR system without proper coordination, but those were years back when DMR first emerged. The frequency coordinators also had a big problem with integrating the systems into mostly analog frequencies, where many users still monitored in carrier squelch, or where channel occupancy patterned the regular simplex or repeated times rather than possibly stay on the air continuously. My last interaction with the FCC was that they don't like enforcement action on public safety licensees unless there is no other choice. They would rather solve the problem low key and have everyone walk away good. That tactic also involves less energy and resources. So, even though it's illegal, don't expect a swarm of people in FCC windbreakers.
