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FCC Reminds 2-Way Radio Licenses of Narrowbanding Requirements

The FCC issued a Public Notice providing guidance on compliance with narrowband requirements for land-mobile operations in the 150-174 MHz and 421-470 MHz bands.

As of Jan. 1, 2013, all VHF/UHF Industrial/Business and Public Safety Radio Pool licensees must “operate 12.5 kHz (11.12.5 kHz occupied bandwidth) or narrow channels or employ a technology that achieves the narrowband equivalent of at least one channel per 12.5 kHz of channel bandwidth for voice, and transmission rates of at least 4800 bits per second per 6.5 kHz for data systems operating with bandwidth greater than 12.5 kHz (narrowband-equivalent technology).”

It’s important to note that the narrowbanding requirement does not apply to Part 74 licensees with operations in these bands. I've heard of some uninformed two-way shops telling broadcasters they have to narrowband their 450 MHz systems and urging them to spend money to update their radio systems to comply with FCC rules. That is not true if the systems are licensed under Part 74 rules, and narrowbanding would be a waste of money. However, broadcasters may find it more difficult to obtain new or replacement equipment that isn't narrowband.

The Public Notice states: “Equipment manufacturers should be aware that, as of Jan. 1, 2013, they may no longer manufacture or import equipment that includes a 25 kHz mode. Manufacturers may still manufacture or import equipment that was certified to include wideband capability only if the modes of operation are enabled through software rather than firmware or hardware and the manufacturer disables the wideband mode and does not provide users with the software necessary to access the wideband mode. As of Jan. 1, 2013, the Commission will no longer certify equipment that is inherently wideband-capable even if the modes of operation are enabled through software.”

Wideband modes should be able to be certified under Part 74, but given the small percentage of radios used under Part 74, will manufacturers make the effort even if it is possible?

Larger stations are likely to have Private Land Mobile Radio (PLMR) systems for security, building maintenance or other communications not directly related to the production of broadcast programming. Wideband operation of these radios is only permitted with a valid waiver grant from the FCC. PLMR licensees that have not obtained a waiver must indicate that they are operating in compliance with the narrowband requirement by listing a narrowband emission designator on each of their licenses.

The FCC also requires PLMR licensees remove wideband emission designators from their licenses in accordance with the procedures outlined in the Public Notice. The Notice says:

“We advise licensees that where a license contains a wideband emission designator, the reviewing Bureau may return an application for modification or renewal of that license if the application does not include a modification request to remove the wideband designator and the reviewing Bureau determines that the wideband designator is impermissible. To avoid the risk of a future modification or renewal application being returned, we encourage licensees that do not anticipate making any other changes to their authorization in the near future to file a simple narrowbanding modification application.”

The FCC provided this guidance for licensees seeking a waiver for wideband operation:

“A licensee requesting a post-deadline waiver should not assume that the waiver request will be granted, and grant of a waiver request does not insulate a licensee from possible enforcement action for the period of unauthorized wideband operation after Jan. 1, 2013. However, the Enforcement Bureau may consider the length of unauthorized operation when evaluating the severity of the violation of the Commission’s rules as well as the appropriate sanction. Therefore, we advise any licensee seeking a post-deadline waiver to take action to migrate to narrowband technology as soon as possible to minimize the period of unauthorized wideband operation. We also note that licensees operating pursuant to a waiver are still required to take reasonable precautions to avoid causing harmful interference as well as to cooperate with other licensees to reduce and resolve harmful interference. Failure to abide by either of these provisions may result in Enforcement action.”

PLMR licensees that operate wideband systems after Jan. 1, 2013 without a waiver are subject to FCC enforcement action: “Such enforcement action may include 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.”

If a two-way radio dealer or service shop uses the fear of FCC enforcement to coerce your station into upgrading Part 74 remote pickup gear for narrowband operation and cites fines as the reason to do it, show them the Public Notice and ask them to show you where the FCC has required broadcast auxiliary service licensees to narrowband. They won't be able to do it.

If you have any questions about what bandwidths are legal under Part 74, I recommend consulting the Government Printing Office's Electronic Code of Federal Regulations, available at Select “Title 47” from the drop-down menu for FCC regulations.