CDE #41534
RADIO
INTERFERENCE
and FCC Enforcement
By Katherine Reynolds
PSC | apcointl.org
hy is it so imperative to maintain your radio system and
FCC license? There are many very important answers to
this question.
40
Maintaining a radio system that is consistent with your FCC authorized licensed
parameters is fundamental to ensuring clear
communication for you and other licensed
operators. Successful and uninterrupted
communications for first responders and
the public safety sector is vital to the safety of
the workforce as well as to the general public.
Radio frequency interference can easily
transform a dangerous situation into a fatal
one. It is important to remember that the FCC
mandates that the spectrum is shared, and
all licensees are expected to work together
to help mitigate any interference, regardless
of whether your radio system is causing the
interference or you are receiving interference
from another source. As outlined in the FCC’s
rule section §90.173(b), “licensees of stations
suffering or causing harmful interference are
Maintaining a radio system
that is consistent with FCC
authorized licensed parameters
is fundamental to ensuring
clear communication.
of generating, and being affected by, radio
frequency interference.
APCO has a Memorandum of
Understanding (MOU) in place with the FCC
to help streamline the resolution process of
interference complaints in the land mobile
communications industry. There are specific
processes in place to handle the resolution
of such interference cases, but if the offending party is non-compliant, the case can
then be referred to the FCC’s Compliance
and Enforcement Bureau for further review
and enforcement action. Its primary role
is to implement the rules and regulations
designated by the FCC, and to protect the
land mobile communications spectrum environment from non-complaint licensees and
unlicensed operators.
According to Public Notice DA 15-967,
the FCC is currently in the process of streamlining its method of handing interference
complaints. One of the goals is to improve
response time and ensure that interference
complaints are handled as quickly and efficiently as possible.
expected to cooperate and resolve this problem by mutually satisfactory arrangements.”
When first responders cannot effectively communicate, conditions can quickly
worsen into hazardous and life-threatening
situations. While safety is a primary concern, there are a number of other factors to
consider. For example, operating outside of
licensed parameters may cause unwanted,
and often harmful, interference. It can also
invite hefty FCC fines and result in unfortunate injuries or fatalities due to the interruptions in communication.
The potential for radio frequency interference is always present. However, by maintaining your system to proper specifications, and
operating within your licensed parameters,
you will significantly reduce the probability
Proper maintenance of your radio system
can provide many benefits for your agency.
These benefits include: avoiding substantial
FCC fines, extending the life of your equipment by keeping it in optimal condition and
minimizing interference to other essential
public safety communication systems. There
are a variety of ways to implement proper
maintenance of your radio system. Some of
these can include completing physical inspections to ensure the equipment is clean and
free of dust and other debris, and ensuring
the correct frequencies, emissions and power
levels are programmed into your equipment.
Preventative maintenance can also alleviate the expense of replacing or repairing
equipment, and avoid the testing that may
be needed to resolve an interference complaint. If your radio system isn’t properly
maintained, there are a wide range of adverse
outcomes. These can include poor system
performance, generating interference for
other licensed agencies, and many more. If
your equipment breaks down during a critical time to communicate, it not only creates
a huge inconvenience but can also reduce the
level of productivity and increase the threat
for devastating incidents. Proper radio system maintenance also includes keeping your
PSC | July/August 2016
MAINTAINING YOUR
RADIO SYSTEM
41
license up to date, even if it is time consuming
or inconvenient for you to do so.
STAYING CURRENT WITH
YOUR FCC LICENSE
Maintenance of your FCC license is also
extremely important if you want to stay in compliance with FCC rules and regulations. If you
make changes to your system and fail to modify
your license to reflect those changes it can open
the door to substantial FCC fines and may contribute to an erroneous database that FCC certified frequency coordinators consistently rely on
for successful coordination of other systems.
When coordinators use a database that
is not completely accurate due to improperly documented system changes, this can
cause coordination results to be flawed.
Consequently, keeping your license up to
date affects not only you and your radio
system, but also affects other licensees and
the integrity of the coordination process.
There is another aspect of properly maintaining your FCC license, of which unfortunately many agencies are unaware. This
involves what is referred to as the FCC’s build
out/construction or coverage requirements.
Under these requirements, licensees must
provide certification to the FCC when they
have become operational on the frequencies
and parameters granted on their license. This
requirement might be applicable whether those
parameters were granted as the result of a new
license or a modification to an existing one.
This “build out” requirement was implemented in an effort to prevent licensees from
hoarding frequencies, which is against FCC
regulations. Generally, you must be operational on the frequencies and parameters
granted on your license within one year of
the license grant date. Otherwise, if you are
not operational and have not filed the required
build out notification by the deadline date,
the license will automatically enter into a
“Termination Pending” status, and will eventually be terminated by the FCC.
If this occurs, you will no longer be authorized to transmit on the frequencies listed on
your terminated license. You will be required
to reapply for the frequencies and complete the
frequency coordination process again. The
risk of another agency taking over those frequencies is also a very real possibility. Should
this occur, you will not only have to apply for
frequency coordination again, but you will also
have to re-program your equipment with the
newly assigned frequencies and new call sign.
This can be a very costly and time-consuming
endeavor and, depending on the size of your
system, can be a substantial setback in your
agency’s budget.
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Nearly 20 years ago, the FCC entered into
an MOU with APCO to provide assistance in
resolving public safety-related interference
complaints. This MOU gives the land mobile
communications industry a sense of ease in
knowing that APCO will work diligently to
ensure that the public safety radio systems
across the nation will be intensely protected
from radio frequency interference that is
caused by unlicensed or non-compliant users.
APCO’s goal is to provide expert assistance
with handling and resolving interference
cases, while mitigating the number of licensees who intentionally or unintentionally corrupt the spectrum environment.
APCO’s local advisors play a vital role in
the research and resolution of an interference complaint. They offer local knowledge
and expertise in public safety communication and are a key part of what we do here
at APCO. While handling an interference
complaint, APCO’s local advisors are tasked
with tracking down the interfering party,
confirming that all parties involved are in
fact operating according to licensed parameters, and offering various recommendations
in an effort to resolve the interference issue.
If APCO’s local advisors are unable to determine the source of interference or if another
radio user is uncooperative, the case can
then be forwarded to the FCC’s Enforcement
Bureau for further review and determination.
APCO’s MOU has proven to be beneficial
to the FCC and the public safety community
because it promotes compliant radio system
operations. It also contributes to the protection of critical radio communications that
are essential to the everyday tasks for which
our public safety agencies are responsible.
FCC ENFORCEMENT BUREAU
The FCC’s Enforcement Bureau implements the rules and regulations outlined in
the Code of Federal Regulations, and they
routinely impose hefty fines for operating
outside of licensed parameters. The bureau
is also responsible for handling interference
complaints within the land mobile communications industry. The issues they handle
can range from complaints regarding the
lighting or marking of antenna structures
to violations of technical rules.
The bureau is currently working on
improvements in the way that they process
and handle an interference complaint. Its
goal is to improve response time and handle
complaints in a more efficient manner, as
well as to provide consistency and transparency in the process.
The bureau is still working out the specifics of how the complaint process will be
implemented. Part of this enhancement will
involve the bureau issuing automatic updates
on the status of an interference complaint, and
allowing the licensee to automatically receive
the most current information on their interference case. Although these enhancements to the
complaint process are still being developed,
the land mobile communications industry can
rest assured in knowing that the bureau is diligently working toward a complaint escalation
process that will streamline the procedure.
This will enable interference complaints to
be handled in a timely manner while keeping
the licensee informed on the progress of the
bureau’s resolution.
The radio frequency spectrum has become
increasingly crowded, resulting in reduced
frequency availability and higher probabilities that interference to your radio system
will occur. Protecting the spectrum environment is extremely important to APCO,
and we do our best to ensure this protection
through very stringent and precise coordination procedures.
To help mitigate interference issues in
the land mobile radio community, please
be attentive to properly maintaining your
radio station license, equipment and system parameters. We all are aware of the
importance of uninterrupted communications for police, fire and other emergency
responders. Please do your part by keeping
your license up to date and ensuring that
you are operating in accordance to your
licensed parameters.
•
Katherine Reynolds is a Licensing Specialist
with APCO-AFC where she is responsible for
handling public safety interference complaints
as well as every aspect of FCC radio licensing.
Her knowledge in FCC rules and regulations,
interference resolution procedures, and universal licensing system features allows her
to provide professional guidance to public
safety agencies.
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820019_Editorial.indd 1
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CDE EXAM #41534
1. What FCC rule section states “licensees
of stations suffering or causing harmful
interference are expected to cooperate
and resolve this problem by mutually
satisfactory arrangements?”
a.§90.162(b)
b.§91.173(b)
c.§90.173(c)
d.§90.173(b)
2. The FCC’s Compliance and Enforcement
Bureau’s primary role is to implement
the rules and regulations designated
by the FCC, and to protect the land
mobile communications spectrum
environment from non-complaint
licensees and unlicensed operators.
a.True
b.False
3. What public notice talks about
the FCC’s plans to streamline the
resolution process for interference
complaints?
a. DA 15-967
b. PN 15-967
c. DA 15-966
d. DA 14-966
4. Benefits of properly maintaining your
radio system can include avoiding
substantial FCC fines, extending the
life of your equipment by keeping it
in optimal condition, and minimizing
USING THE CDE ARTICLES
FOR CREDIT TOWARD APCO
RE-CERTIFICATION(S)
Each CDE article is equal to one credit
hour of continuing education
1.Study the CDE article in this issue.
2.Answer the test questions online
or on the exam page from the
magazine article (photocopies are
not required).
3.List the CDE article information
on the Continuing Education
Reporting form included with your
recertification documents, when
you submit for renewal.
PSC | apcointl.org
Questions? Call us at 1-888-APCO-9-1-1
(1-888-272-6911)
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You can now access the CDE exam online!
To receive a complimentary certificate
of completion, you may take the CDE
exam online. Go to http://apco.remotelearner.net/login/index.php to create
your username and password. Enter “CDE
article” in the search box, and click on
“2016 Public Safety Communications
Magazine Article Exams,” then click
on ”enroll me” and choose “Radio
Interference & FCC Enforcement (41534)”
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of achievement will be available for
download/printing.
interference to other essential public
safety communication systems.
a.True
b.False
5. Proper radio system maintenance includes
keeping your license up to date but only
when you have time or it is convenient for
you to make those changes to your license.
a.True
b.False
6. Hoarding frequencies is allowed by the
FCC.
a.True
b.False
7. Generally, you must be operational on the
frequencies and parameters granted on
your license within______________of the license
grant date.
a. Nine months
b. One year
c. Six months
d. Two years
8. What will happen if your license is fully
terminated due to failure to meet the
required buildout requirement?
a. You will be required to apply for a
license renewal with a waiver request
b. You will be required to apply for a
petition for reconsideration to bring
the license back to an active status
c. You will be required to reapply for
the frequencies and complete the
frequency coordination process
again
d. None of the above
9. While handling an interference
complaint, APCO’s local advisors are
tasked with:
a. Tracking down the interfering party
b. Confirming that all parties involved
are in fact operating according to
licensed parameters
c. Offering various recommendations
in an effort to resolve the
interference issue
d. All of the above
10: The radio frequency spectrum has
become increasingly crowded, resulting
in:
a.Reduced frequency availability and
higher probabilities that interference
to your radio system will occur
b.Reduced frequency availability and
lower probabilities that interference
to your radio system will occur
c.Increased frequency availability and
higher probabilities that interference
to your radio system will occur
d.Increased frequency availability and
lower probabilities that interference
to your radio system will occur
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