Is your spectrum protected?

A major automobile manufacturer recently discovered by chance that its FCC radio licenses no longer were being properly maintained.  The person who had been handling this work for the manufacturer retired earlier in 2012 and, since that time, no one had taken on that responsibility.  Consequently, a number of valuable licenses held by the manufacturer expired. In addition, the FCC’s narrowband deadline had come and gone by January 2013. 

Yet this large company still held a considerable number of licenses with frequencies operating on now-disallowed wideband emissions.  It unknowingly had left itself open to the possibility of incurring hefty monetary fines from the FCC as a result of operating illegally on licenses that had expired. 

Moreover, failure to migrate frequencies over to narrowband operations resulted in many of their licenses being in violation of the FCC’s rules which, as per the Commission’s Public Notice DA 12-1914(11/30/12), could subject them to enforcement action—including admonishments, license revocation, and/or monetary forfeitures of up to $16,000 for each such violation, or up to $112,500 for each day of a continuing violation—for any single act or failure to act.

The economic downturn that afflicted the U.S. several years back hit the automobile business quite hard, causing many of this company’s facilities to be shut down. Even though the radio licenses were valuable assets—similar to tooling or other machinery held by the company—the company was unaware which licenses were still in use and which ones required narrowbanding.  This is where EWA stepped in.

 Specifically, our license-management team did the necessary research to create a complete listing of all the licenses, active and inactive, held by the company.  The effort was conducted under the auspices of EWA’s Total License Management service, which can be leveraged when companies do not have the properly trained personnel, or the budget to hire such personnel, to safeguard valuable spectrum licenses. 

After the auto manufacturer signed up for the service, it received a spreadsheet that provided vital details for each of the licenses it held.  With that tool, the individual assigned to license maintenance did the necessary internal research to compare license locations to facilities that had been shut down.  That way, they could determine which licenses were still needed.

The next job was to tackle the recently expired, but still necessary, licenses. For some, the date of expiration was within 30 days, and EWA was able to submit late-filed renewals with waiver requests to salvage the licenses. For those call signs with expiration dates beyond 30 days, applications were immediately processed and filed to replace those licenses.

As the list became complete about what facilities had been shut down and what licenses needed to be cancelled due to those shut downs, EWA was called upon to file cancellations. On those licenses affiliated with active facilities, EWA filed modifications to migrate the frequencies to narrowband operations where necessary.  All of this was completed very quickly, in order to preserve the company’s spectrum holdings and enable it to continue operating its two-way radio systems and associated equipment.

With EWA’s assistance, this company was able to get back licenses originally thought lost. The company now has a clear picture of its entire portfolio of valuable spectrum.  At present, EWA is working to bring each of the company’s licenses into compliance with current FCC rules and regulations.  To this end, EWA’s Total License Management service automatically sends multiple notifications far in advance of any approaching renewal dates, and identifies any call signs that have upcoming construction deadline dates, to ensure that this company’s licenses are well-protected.

EWA’s customer, upon reaching this milestone, said, “Thank you for your emails—you’re extremely thorough and that’s great! I’m very impressed so far. … Thanks again for your work!”

Judy Wilson is manager of license management for the Enterprise Wireless Alliance.