EWA helps an airline navigate the FCC's narrowbanding mandate, by taking on the necessary license investigation, interpreting the findings and devising a course of action.
Early in the spring of 2013, a major U.S. airline signed up for’s Total License Management service. The company, familiar with rules because of its EWA membership, had requested and been awarded a waiver from the commission to extend the of its licenses—converting them from 25 kHz-wide channels to 12.5 kHz-wide channels—past the mandated January 1, 2013, deadline.
But with close to 500 licenses, and with the extended deadline looming, the company wasn’t sure which call signs already had been narrowbanded and which ones still needed attention. As with many EWA member companies, the employees at the airline were extremely busy with other tasks and didn’t have the time (or knowledge) to keep track of their radio licenses. So, the airline turned to EWA for help.
Immediately after doing the initial research on the airline’s licenses, EWA alerted the company to an 800 MHz trunked system with 10 repeater pairs on which the construction deadline was only one month away. EWA’s research also revealed that a license that was due for renewal should not even have been active. With further investigation, EWA discovered that an application had been filed to “system license,” i.e., combine, this particular license, along with two others, onto another license—but somehow the FCC neglected to cancel the three call signs upon granting the request.
It is certain that the airline would have spent extra money unknowingly—and unnecessarily—to renew what essentially was now a duplicate license, and probably would have done the same with the other two call signs once they came up for renewal.
In addition, even though the system-added frequencies had been licensed to this company (and constructed) for quite some time, the FCC viewed them as having been newly added, which requires a Schedule K Notice of Construction. The airline had not been aware of this construction requirement until they were informed of it by EWA. Ultimately, EWA was able to assist the company in cancelling the three licenses that were unnecessary and filing the construction notification for the “newly added” frequencies.
The airline saved time and money because it did not have to dedicate staff time to learning the rules, doing the necessary license investigation, interpreting the findings and devising a course of action.
In addition to reminders about upcoming renewals and construction notifications, EWA’s Total License Management service provides vital information about a licensee’s obligations and call-sign parameters, of which they often are unaware. For example, many license holders still are not aware of the FCC’s requirement to switch to narrowband operations, despite the January 2013 deadline.
If you happen to have one of these licenses and did not file a waiver prior to the narrowbanding deadline, you may be wondering what to do at this point. Continuing to operate on wideband emissions is in violation of the FCC’s current rules and regulations and such actions expose licensees to the risk of possible enforcement action, including public admonishments, 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 (per the FCC’s Public Notice DA 13-376; March 14, 2013).
The FCC does eventually intend on taking steps to verify the status of active licenses that still reflect wideband emissions, in order to confirm that the systems are still in operation and that they are in compliance with the narrowbanding rules. And even though it is nearly one year past the deadline, EWA still is receiving and filing modifications to migrate frequencies over to narrowband operations. Better late than never!
Judy Wilson is manager of license management for the Enterprise Wireless Alliance