Slightly OT: Narrowband license modification

[kb9mqu]

Hello everyone,

In addition to being a ham radio operator, I'm also a member of a SAR group that has a public safety license for a single VHF frequency. We're starting to look at transitioning to narrowband.

We found the following document that describes the process of adding narrowband to the FCC license: http://vcomm.vermont.gov/sites/vcomm/fi ... 07_10_.pdf

We have an FRN already and we know our password. Our current (wideband) license is valid until 2012. A few questions:

1) Any problems with adding the narrowband emission designator to our license now? We probably won't make the switch for another year or so, but we'd like to start programming both wide and narrow channels into our radios and begin testing.

2) At what point should we remove wideband from our license? Immediately when we stop using it, or wait until it's time to renew the license?

3) We are a 501c3 organization. What do we answer to the application fees and regulatory fees questions? How much will we end up paying if we file online (we're not a government agency)?

Sorry if this is off-topic, but I wasn't sure where else to post. We're a volunteer organization so we can't afford to pay a frequency coordinator a lot of money if we don't need to.

Thanks!

Kevin

[k2hz]

You don't say what service you are licensed in but you will probably have to file through a frequency coordinator who can provide some guidance. If you have an "itinerant' license, frequency coordination may not be needed.

You can add narrow band now and keep your wide band untill the FCC automatically deletes it after the conversion deadline.

As a non-profit you have to pay the application fee but can request exemption from the regulatory fee. Personally, I find it not worth the extra paperwork to avoid the nominal regulatory fee. If you have to file through a coordinator, you generally pay both the FCC and coordination fees to the coordinator who actually files the application with the FCC.

I beleive the regulatory fee does not apply for a simple modification so the FCC fee will be $60 for the application. Coordination fees vary but are usually about $100 to just add narrow band with no other changes. If you give up wide band now and simply change to narrow band, coordination may not be required but that means you have to immediately convert which you probably do not want to do.

I suggest you check the FCC website for a list of coordinators for your radio service and contact the one you want to work with ASAP for further info. The coordinator can tell you if their services are required and what the fees will be.

[resqroz]

I am also in a Search and Rescue group and we used IMSA to do our coordination and license filing. It wasn't terribly expensive. We are currently licensed both narrow band and wide band. In 2013 we will drop the wide band designator. The link to IMSA is at the bottom of your attachment.

[HumHead]

As of the 3/11/2010 NPRM in 10-36 ( http://hraunfoss.fcc.gov/edocs_public/a ... 0-36A1.pdf ), the FCC has removed the requirement for frequency coordination when the only change to a license is the addition of a narrow band emission designator.

You can simply open an application in ULS, add the appropriate designator to each frequency, and submit it. Even if you have other license "housekeeping" to do, I would strongly advise against doing anything else except adding the narrow band emissions. Submit anything else on a subsequent application after narrow banding is taken care of.

If you have dual wide and narrow emission designators on your license, there is no need to go back and file again to remove wide band. The FCC will automatically remove the wide band designator once the deadline arrives.

A variety of entities and organizations are exempt from the filing fees. If you indicate that you are exempt from fees on the application, ULS will not accept the submission without some form of attachment explaining the grounds for claiming the exemption. For government entities, I will usually attach a letter on letterhead explaining that I am claiming exemption as a governmental entity. For charitable non-profits, I usually attach a copy of the organization's Determination of Status letter from the IRS.

Bottom line- the regulatory end of this can now probably be handled in under an hour online at little to no expense.

[kb9mqu]

You don't say what service you are licensed in but you will probably have to file through a frequency coordinator who can provide some guidance. If you have an "itinerant' license, frequency coordination may not be needed.

Sorry, I should have mentioned that. It's Part 90, eligibility 90.37A, for statewide operation in Indiana.

You can add narrow band now and keep your wide band untill the FCC automatically deletes it after the conversion deadline.

Great, that's what I was hoping was the case.

As a non-profit you have to pay the application fee but can request exemption from the regulatory fee. Personally, I find it not worth the extra paperwork to avoid the nominal regulatory fee. If you have to file through a coordinator, you generally pay both the FCC and coordination fees to the coordinator who actually files the application with the FCC.

I beleive the regulatory fee does not apply for a simple modification so the FCC fee will be $60 for the application. Coordination fees vary but are usually about $100 to just add narrow band with no other changes. If you give up wide band now and simply change to narrow band, coordination may not be required but that means you have to immediately convert which you probably do not want to do.

I read on a few web sites that frequency coordination wasn't required for adding narrowband, but they didn't cite a source. Finally found it: http://www.npstc.org/documents/07-100%2 ... -11-10.pdf. To quote from that PDF:

"As a result, we amend our rules to provide an exemption from the frequency coordination requirement for modification applications that only reduce authorized bandwidth while remaining on the original center frequencies, and do not seek any other changes in technical parameters."

So it appears to me (I'm not a lawyer) that if we don't change anything but the emission bandwidth to narrow we won't need a coordinator. But I could be mistaken.

I suggest you check the FCC website for a list of coordinators for your radio service and contact the one you want to work with ASAP for further info. The coordinator can tell you if their services are required and what the fees will be.

Thanks for the advice! We'll do that and see what they say. I will report back when I find out from them whether we need frequency coordination or not. I'm hoping not ($100 may not sound like a lot of money, but every penny counts these days!).

Kevin

[kb9mqu]

Thanks HumHead, I replied to k2hz before I read your message, but it looks like we found the same information.

Kevin

As of the 3/11/2010 NPRM in 10-36 ( http://hraunfoss.fcc.gov/edocs_public/a ... 0-36A1.pdf ), the FCC has removed the requirement for frequency coordination when the only change to a license is the addition of a narrow band emission designator.

You can simply open an application in ULS, add the appropriate designator to each frequency, and submit it. Even if you have other license "housekeeping" to do, I would strongly advise against doing anything else except adding the narrow band emissions. Submit anything else on a subsequent application after narrow banding is taken care of.

If you have dual wide and narrow emission designators on your license, there is no need to go back and file again to remove wide band. The FCC will automatically remove the wide band designator once the deadline arrives.

A variety of entities and organizations are exempt from the filing fees. If you indicate that you are exempt from fees on the application, ULS will not accept the submission without some form of attachment explaining the grounds for claiming the exemption. For government entities, I will usually attach a letter on letterhead explaining that I am claiming exemption as a governmental entity. For charitable non-profits, I usually attach a copy of the organization's Determination of Status letter from the IRS.

Bottom line- the regulatory end of this can now probably be handled in under an hour online at little to no expense.

[k2hz]

The interpretation I got from a frequency coordinator is that "only reduce bandwidth" means to
substitute narrow band for wide band, not to add narrow band as a second emission type.

It was a moot issue on an application I have pending in coordination now which also added a new frequency. I would be interested to see an "official" interpretation of the FCC policy.

[RKG]

I wouldn't make any license change until you have cutover to your narrowband channel/system.

The emission designator is a maximum; emitting narrowband under a wideband license (assuming no other changes) is perfectly OK.

I agree with the suggestion that any amendment applications submitted to change the emission should be limited to that; any other changes should be on separate application, either filed and approved before you submit the narrowband application or held off (if possible) until the narrowband application has been granted.

[com501]

Ahh well. Licenses are over rated anyway. Half of Nevada public safety isn't licensed, or the license they have is for frequencies they don't operate on....