FCC Licensing and Drones

Many commercially available drones operate at 2.4 GHz / 5.8 GHz. This is covered under part 15. General rule of thumb if they operate at less than half a watt, no license is required. The same is not true for the drones that are operating at 400 MHz. For more information about licensing contact dave@landmobile.com

Below is information regarding part 15 drones. (Its important to note that these unmanned vehicles will need to be cleared with the FAA - stayed tuned for FAA drone registration article)

FCC Rules for Unlicensed Wireless Equipment

The ISM radio bands were originally set aside for electromagnetic radiation produced by industrial, scientific and medical (ISM) equipment.  In the early 1990's the Federal Communcations Commission (FCC) allowed using three of the ISM bands for unlicensed communication equipment.  These three ISM bands are:

• 902 to 928 MHz
• 2.400 to 2.4835 GHz
• 5.725 to 5.875 GHz

In the United States the use of these bands for communication purposes is regulated by part 15 of the FCC rules.

Maximum Transmit Output Power in the ISM bands

Several of the FCC part 15 rules govern the transmit power permitted in the ISM bands.  Here is a summary of those rules:

1. Maximum transmitter output power, fed into the antenna, is 30 dBm (1 watt).
   
2. Maximum Effective Isotropic Radiated Power (EIRP) is 36 dBm (4 watt).
   You can obtain the EIRP by simply adding the transmit output power, in dBm, to the antenna gain in dBi  (if there is loss in the cable feeding the antenna you may subtract that loss).
   
3. If your equipment is used in a fixed point-to-point link, there are two exceptions to the maximum EIRP rule above:
   
   • In the 5.8 GHz band the rule is less restrictive. The maximum EIRP allowed is 53 dBm (30 dBm plus 23 dBi of antenna gain).
     
   • In the 2.4 GHz band you can increase the antenna gain to get an EIRP above 36 dBm but for every 3dBi increase of antenna gain you must reduce the transmit power by 1 dBm. The table below shows the combinations of allowed transmit power / antenna gain and the resulting EIRP.



Transmit Power (dBm)	Antenna Gain  (dBi)	EIRP      (dBm)
30	6	36
29	9	38
28	12	40
27	15	42
26	18	44
25	21	46
24	24	48
23	27	50
22	30	52

Applicable FCC Rules
The FCC regulates not only the "intentional radiation" of radio transmitters, but also the "unintentional radiation" of noise from all sorts of electrical equipment. The FCC regulations appear under part 15. The rules that affect operation of communication equipment in the ISM bands are listed below:

 

FCC 15.107	Conducted Emissions including AC Line
FCC 15.109	Unintentional radiation from ITE
FCC 15.205	Restricted bands of operation
FCC 15.207	Conducted emissions from intentional radiators
FCC 15.209	Radiated emission limits, general requirements
FCC 15.247	ISM Band Communication Equipment

Motorola to cancel certain two-way radio models

Popular CP200 Model going away soon

By David Smith
August 26th, 2014

Motorola just released to its dealers, "its intent to cancel VHF and UHF versions of the following analog radios. CP200, CP200XLS and PR400 portables CM200, CM300 and PM400 mobiles. The last day to order these models is November 22, 2014, and the last ship date is December 22, 2014."

The company is paving the way for its new digital radios like its new DTR series pictured below.

 

Company fined $30,000 for unlincesed GMRS operation.

Remel, Inc. and its corporate parent, Thermo Fisher Scientific, Inc were fined $30,000 by the Federal Comunications Commission this past week for operating a base repeater on 462.575 MHz. This frequency is part of the General Mobile Radios Service (GMRS) and licensed under part 95. The company admitted that the frequency was in use without a license since 2002. However, Remel, Inc. had apparently ceased operation sometime in 2012 due to enforcement notice of inquiry. This prompted the company to file for a Special Temporary Authorization.

In determining the amount in fines to be levied the Commission states, "Given the totality of the circumstances, ...., we conclude that a significant upward adjustment of the base forfeiture is warranted. In this regard, we are particularly mindful that the apparent unlawful operation in this case continued for more than nine years... In fact, the duration of the unauthorized operation is almost double the relevant five - year license term, and under current rules, the Companies were not even eligible to obtain a GMRS license." The FCC also took into consideration "Thermo Fisher’s status as a multi-billion dollar global enterprise".

Thermo Fisher's has a reported revenue of over $12.5 billion for the fiscal year ending December 31, 2012, and has 39,000 employees.

Narrowbanding Update - FCC Action

December 21st, 2012 came and the world did not come to end. Take that Mayan calendar!!!

The FCC's January 1st, 2013 narrowbanding deadline has also come and gone. The world may not have come to an end, but that does not mean the FCC is finished yet. The Commission has promised to release a public notice in April that will detail their enforcement plans. We have been told that this will include an audit letter to all existing licensees who do not appear to have complied with this mandate. By way of background, the mandate stated that operators whose frequencies fall between 150- 470 MHz are required to convert their wideband equipment over to 11.25 KHz equivalent technology.

Below are a list of frequently asked questions about the migration to this new narrowband technology and what were up against:

Q: What if I did not convert my radios over to 11.25 KHz equivalent technology?
A: The FCC will expect you to cease operations or be covered by a granted waiver.

Q: Can I get into trouble if I am still operating above 11.25 KHz bandwidth?
A: Yes, the FCC has already released an enforcement advisory detailing fines of up to $112,500 (see DA 12-1386 8-22-12)

Q: Can I still modify my license?
A: Yes, the FCC is still allowing these modifications, but its not clear for how long.

Q: Will the FCC reimburs the cost of buying new radios?
A: No, but there were a few grants that were offered to public safety entities early on.

Q: Are all licenses or services included in this requirement.
A: No, GMRS, FRS, MURS and the Amateur Ham bands are all exempt. This covers only part 90. Some paging frequencies are also exempted.

Q: How many licenses are still not narrowbanded?
A: Close to 30% at least on paper, appear to be non-compliant

Q: Is there an easy way to modify my license?
A: Yes, the Commission modified the Universal License System (ULS) to allow licensees to easily access and make fee exempt modifications for narrowbanding. Look for the Narrowband only login. If you have your FCC Registration Number (FRN) and your password, its a snap!

Stay tuned for more information about this and more about the FCC or contact

David Smith
FCC FORMS
david@fccforms.com

Narrowbanding Deadline Post Mortem

Now that the narrowbanding deadline has come and gone many are asking "What now?". We contacted Mr. Roberto Mussenden of the Public Safety and Homeland Security Bureau, and Mr. Andy Leimer of the Office of Engineering and Technology for answers. Our inquiry was then forwarded to Scott Stone, Deputy Chief, Mobility Division. According to Stone the FCC will not be cancelling licenses anytime soon. The Commission is in fact allowing applications for the narrowband conversions to still be filed, even at this late date. One word of warning however, If the FCC later determines that the licensee did not actually narrowband until after January 1, the licensee could be subject to enforcement action for improper wideband operation.

Rest assured that there will be some "sacrificial lambs" for those who have not complied. The Commission is likely to take action to determine the narrowbanding status of stations that do not appear to be narrowband-compliant. The exact process and timing has not yet been decided.

.....More to come

FCC Fines - Where does the FCC come up with their fine amounts

If your willing to risk not complying with the FCC's rules and regulations, know the penalties. Operating without a license or transmit a false distress call, you could be hit with fines that total many thousands of dollars. There are a lot of cheap radios that operate in the GMRS bands. Did you know that those radios require and FCC license. The fines are not arbitrary at all. Section 1.80 covers what the penalties. Below is an excerpt:

 [From CFR 47 section 1.80]

**Fines can be levied on a per day basis and/or per violation** 

 
   Construction and/or operation without an instrument of authorization
   for the service $10,000
   Failure to comply with prescribed lighting and/or marking 10,000
   Violation of public file rules 10,000
   Violation of political rules: reasonable access, lowest unit charge,
   equal opportunity, and discrimination 9,000
   Unauthorized substantial transfer of control 8,000
   Violation of children's television commercialization or programming
   requirements 8,000
   Violations of rules relating to distress and safety frequencies 8,000
   False distress communications 8,000
   EAS equipment not installed or operational 8,000
   Alien ownership violation 8,000
   Failure to permit inspection 7,000
   Transmission of indecent/obscene materials 7,000
   Interference 7,000
   Importation or marketing of unauthorized equipment 7,000
   Exceeding of authorized antenna height 5,000
   Fraud by wire, radio or television 5,000
   Unauthorized discontinuance of service 5,000
   Use of unauthorized equipment 5,000
   Exceeding power limits 4,000
   Failure to respond to Commission communications 4,000
   Violation of sponsorship ID requirements 4,000
   Unauthorized emissions 4,000
   Using unauthorized frequency 4,000
   Failure to engage in required frequency coordination 4,000
   Construction or operation at unauthorized location 4,000
   Violation of requirements pertaining to broadcasting of lotteries or
   contests 4,000
   Violation of transmitter control and metering requirements 3,000
   Failure to file required forms or information 3,000
   Failure to make required measurements or conduct required monitoring
   2,000
   Failure to provide station ID 1,000
   Unauthorized pro forma transfer of control 1,000
   Failure to maintain required records 1,000

   ^1Statutory Maximum for each Service.

   Violations Unique to the Service
   Violation Services affected Amount
   Unauthorized conversion of long distance telephone service Common
   Carrier $40,000
   Violation of operator services requirements Common Carrier 7,000
   Violation of pay-per-call requirements Common Carrier 7,000
   Failure to implement rate reduction or refund order Cable 7,500
   Violation of cable program access rules Cable 7,500
   Violation of cable leased access rules Cable 7,500
   Violation of cable cross-ownership rules Cable 7,500
   Violation of cable broadcast carriage rules Cable 7,500
   Violation of pole attachment rules Cable 7,500
   Failure to maintain directional pattern within prescribed parameters
   Broadcast 7,000
   Violation of main studio rule Broadcast 7,000
   Violation of broadcast hoax rule Broadcast 7,000
   AM tower fencing Broadcast 7,000
   Broadcasting telephone conversations without authorization Broadcast
   4,000
   Violation of enhanced underwriting requirements Broadcast 2,000

FCC may fine up to $112,500 for narrowband violations

In a two page release the Commission detailed their plans for imposing steep fines to radio licensees that fail to comply with the January 1st narrowbanding mandate. The FCC says that "Enforcement Bureau is committed to aggressively enforcing the narrowbanding transition deadline and violators may be subject to enforcement action. Penalties for non-compliance may include license revocation, and/or monetary forfeitures of up to $16,000 for each such violation or each day of a continuing violation, and up to $112,500 for any single act or failure to act."

The narrowbanding mandate calls for licensees operating between 150 - 470 MHz to reduce their effective bandwidth down to 12.5 KHz by January 1st, 2013.

For more information about the this release or how to become compliant you can contact David Smith at FIT. dave@landmobile.com or 541-485-8441