Please contact Michael Bennet at mbennet@bennetlaw.comor Tara Shostek at tshostek@bennetlaw.comfor more information.
The Wireless Telecommunications Bureau (Bureau) of the Federal Communications Commission (FCC or Bureau) has released a Public Notice[1] reminding Paging and Radiotelephone service licensees of the Part 22 technical and operational rules they are required to follow. The Bureau also seeks comment on whether to change these technical and operational rules to allow greater flexibility in the provision of services on these frequencies.
Bottom Line: The Bureau is contemplating changing its Part 22 rules to allow greater technical and operational flexibility in the Paging and Radiotelephone services to allow for the deployment of new technologies, such as TETRA equipment and to make it easier for licensees operating north of Line A to obtain Canadian clearance by allowing licensees to use offset frequencies.
DISCUSSION
The Bureau reminds Paging and Radiotelephone service licensees of the Part 22 rules they are required to follow, which include, but are not limited to, the following:
- Channel bandwidth. All channels have a bandwidth of 20 kHz and are designated by their center frequencies. While paging channel spacing may be greater than 20 kHz, the authorized channel bandwidth is 20 kHz.[2]
- Emission Limitations. The power of any emission outside the authorized frequency ranges must be attenuated below the transmitting power by at least 43 + 10 log (P) dB.[3] Parties may enter into private agreements allowing for alternative out of band emission limits at band edges in specific geographic areas, provided the agreements include all affected licensees and applicants and the agreements are disclosed to the FCC upon request.
- Effective radiated power (ERP) limits. Paging transmitters must not exceed the ERP limits outlined in section 22.535 of the FCC’s rules.[4]
- Permissible Operations. Channel assignments listed in Section 22.531 are allocated for one-way paging operations. Assignments listed in section 22.561 are for one-way or two-way mobile operations.[5]
- Permissible communications paths. Mobile stations may communicate only with and through base stations and base stations may only communicate with mobile stations and receivers on land or surface vessels.[6]
- Equipment Authorization. All equipment operated under the Part 22 paging rules must be certified by the Commission under the Part 22 paging rules.
- Protection of Existing Services. Sections 22.537 and 22.567 of the FCC’s rules require all paging geographic area licensees to provide co-channel interference protection to all authorized site-based co-channel facilities of exclusive licensees within the paging geographic area.[7][8]
- Canadian Clearance. All licensees planning to operate north of Line A must obtain Canadian clearance by filing a license modification application that includes technical parameters of the planned site so the Bureau can coordinate planned operations with Industry Canada.
COMMENTS SOUGHT ON TECHNICAL AND OPERATIONAL FLEXIBILITY
The Bureau recognizes that additional technical and operational flexibility may promote more intensive use of paging and radiotelephone spectrum. Therefore, the Bureau seeks comment on whether it should update its rules to provide greater flexibility in the types of uses and technologies that can operate on these channels. The Bureau believes that “an update could result in licensees deploying innovative technologies, deploying narrowband equipment, or using offset frequencies if they hold adjacent channel blocks.”[9]
The Bureau notes that in 2012, it changed the Part 90 rules to allow the certification and use of terrestrial trunked radio (TETRA) equipment in the 450-470 MHz portion of the UHF Band and the Business/Industrial Land Transportation 800 MHz band channels (809-824/854-869 MHz) that are not subject to the National Public Safety Planning Advisory Committee (NPSPAC) portion of the band.[10] TETRA equipment is not currently authorized for Part 22 channels because the equipment may exceed the channel bandwidth and emission limitations. The Bureau seeks comment on whether the Part 22 rules should be updated to allow for the use of TETRA.
The Bureau also notes that licensees that want to operate north of Line A must first obtain Canadian clearance using the channel’s center frequency. Some licensees that are unable to get Canadian clearance on the center frequency may want to use offset frequencies to obtain clearance. However, using offset frequencies might violate the FCC’s channel bandwidth and emissions limitations. The Bureau seeks comment on whether to modify its rules to allow greater flexibility in channel bandwidths under these circumstances. The Bureau also seeks comment generally on whether to update and streamline the Part 22 rules.
Comments are due December 17, 2014 and reply comments are due January 19, 2015. If you are interested in filing comments, please let us know.
[1] Wireless Telecommunications Bureau Reminds Paging and Radiotelephone Service Licensees of Certain Technical Rules and Seeks Comment on the Need for Technical Flexibility, DA 14-1508, Public Notice, WT Docket 14-180 (rel. Oct. 17, 2014) (Public Notice).
[2] See 47 C.F.R. §§ 22.531, 22.561.
[3] See 47 C.F.R. § 22.359(a).
[4] See 47 C.F.R. § 22.535.
[5] See 47 C.F.R. §§ 22.531, 22.561, 20.9(a)(6).
[6] See 47 C.F.R. § 22.515.
[7] See 47 C.F.R. §§ 22.537, 22.567.
[8] See 47 C.F.R. § 22.169.
[9] Public Notice at p. 2.
[10] See Amendment of Part 90 of the Commission’s Rules to Permit Terrestrial Trunked Radio (TETRA) Technology, Report and Order, 27 FCC Rcd 11569 (WTB 2012).
