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FCC Application (IG) Returned

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alcahuete

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Attempted to license a few itinerant frequencies, but my application was returned. The FCC claims there are supposed to be reasons why. Any idea where to find those reasons? LOL! Nothing was emailed to me.

I'm guessing it might have something to do with a bunch of the illegal alien/foreign corporation questions being omitted, but I don't know. They are omitted because I cannot answer "No." Their unbelievably ridiculous and antiquated JAVA application system doesn't even let me choose yes or no, except for the first question.

I ran the error checker on the application multiple times, and it came up with nothing.

Any ideas? Yes, I do have a support ticket opened, but that takes forever...especially being the weekend. Just figured somebody here might have some first hand experience.
 

alcahuete

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If you don't complete the application they will return it, unapproved.

Right...I understand that. As I mentioned, their own application software does not allow answers to those questions to be selected. And they do not take paper applications, which would have been a TON easier. That's why I'm kinda lost here. It's not like I'm just leaving them blank intentionally.

As well, their application software does not allow the application to be submitted if a required piece of information is left blank. Yet it allowed me to submit the application. So I'm not sure if those questions are just not required or if something else was messed up. No clue.
 

AK9R

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Or, call the FCC licensing division on Monday and ask them. Speculating all weekend on the Internet probably won't answer your question.
 

Thunderknight

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Using your ham call sign in your avatar, I searched by your last name and found the returned IG application. The reason is at the very bottom of the return letter:

"Please provide justification for use of itinerant frequencies as well as large number of frequencies."
 

BigLebowski

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I have gone through this process.. they will return it for any little reason.

First of all.. looking at your application I feel like it is going to be difficult for you to justify that many frequencies to the FCC. Do you think you'll actually use all of these? If not (and I suspect you will not) I would pick 15-20 and delete the rest.

There is also a section where you need to specify why you want to use the itinerant frequencies. Are you engaged in a business? Do you travel nationwide and and need to use these frequencies for business purposes nationwide? You can get by with being vague but you must specify a reason and obviously don't lie to them.
 

mmckenna

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"Please provide justification for use of itinerant frequencies as well as large number of frequencies."

There ya go.

Trying to grab a whole bunch of itinerant frequencies with no good reason will raise red flags. Also, as stated, you need to have a really good reason for using itinerants rather than coordinated frequencies.
If your business (this is for business use, right?) works over a very wide range of areas, then you might have a case for itinerants, but if you can't justify that, they'll kick it out.

Try resubmitting with a clear justification and apply for less frequencies and see how it goes.
 

alcahuete

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Thanks guys,

Just got the letter this morning. Apparently it takes a few days for the letter to be sent electronically.

MMckenna, yes, it is for business use, CONUS wide, where coordinated frequencies will not work, due to the huge number of different locations throughout the year.

Thanks guys....I'll give it another go in a bit.

On a side note...where exactly do I submit my justification? Would that just go under the "type of activity engaged in" area? Nowhere in their automated system did it ask for a justification...just type of activity, and then the location, i.e. nationwide including Hawaii, Alaska, annd US territories.
 

alcahuete

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There IS a RED FLAG.

Well I certainly don't need Guam or American Samoa, but I need Puerto Rico. Also don't need Alaska.

But of course, on their 8 year old Java application, it's impossible to differentiate. I guess the actual paper 601 is the same, but still. If they don't want you putting CONUS, or US Territories, then the FCC should allow you to select exactly what you need. Hell, I don't need all 50 states either, but I can't select say 35.
 
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mmckenna

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MMckenna, yes, it is for business use, CONUS wide, where coordinated frequencies will not work, due to the huge number of different locations throughout the year.

OK, looking at the application now.

You requested 135 separate frequencies for 1000 units, nationwide. Your request shows analog and DMR.

I really think you are going to have a hard time getting all those frequencies for that many radios across the entire country.
Do you really have a need for 27MHz, 43MHz, VHF and UHF Part 90 frequencies? I think limiting it to a few VHF and UHF frequencies would improve your chances.
And 1000 radios? Not sure what kind of business you are in, but when you are looking at that many radios, that many frequencies across that much spectrum, they are no doubt wondering what you are up to. Looks, at least on the surface, like a major business operation, and they are probably wondering why you cannot use coordinated frequencies for that. The thought of 1000 users showing up in a random location and occupying a bunch of frequencies puts all the other itinerant users in a rough place. I'd kind of agree with the FCC for kicking this back.

I suspect if you call the FCC on Monday and if you can find a knowledgeable person to talk to, they are going to ask you pretty much the same thing.



On a side note...where exactly do I submit my justification? Would that just go under the "type of activity engaged in" area? Nowhere in their automated system did it ask for a justification...just type of activity, and then the location, i.e. nationwide including Hawaii, Alaska, annd US territories.

Yes. It would also help to have something more than just "Part 90". Finding the exact section of Part 90 that covers your type of use will probably help things.
Say something like "itinerant operations for oil well services across the USA" or something similar. Being able to back your request up with something that shows you are running a company with a 1000 radios across the USA will be helpful.

Also, the "Internal On-Site and Mobile Communications" part needs to be clarified. If you are doing "internal on site", you might need to clarify if that is at a fixed location (corporate headquarters). If that's the case, you may need to get a coordinated frequency if you are operating in a fixed location. "Mobile communications" also raises some questions. That's pretty generic. Are you a trucking company? If not, then you need to be more specific.

Seriously, 1000 radios on that many frequencies, what the heck are you up to?:confused:
 

mmckenna

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Looking on Google Maps at the address you used on the application as the "Control Point" brings up even more questions. I think the residential address and "1000 radios, 135 frequencies" isn't helping your case.

Getting this out form under your personal FRN that's got amateur and GMRS on it would probably be a good step, too. If this is a business, get a separate FRN for your business, using the business name and at least a PO Box.

Honestly, on the surface just looking at the information you've provided and what the application shows, it's a red flag. Looks like a frequency grab with no justification. I think you really need to figure out how to make this look like a business rather than a guy with an amateur and GMRS license looking for more spectrum access.
 

mmckenna

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OK, and a a few more things…

On the 27 MHz, 35 MHz and 43 MHz frequencies, you requested emission designators that include SSB, AM and FM.

Stick to FM. Ditch the SSB and AM. If you need HF capability, then that's a whole different animal.

Looking at a few of the other frequencies, it looks like you requested just about every emission designator under the sun. Pick a digital mode and FM analog.

Honestly, and I'm not trying to be negative here, just trying to give you an alternate point of view, but your application is baffling. It's not clear what your business case is, nothing you've provided backs up your requests. The sheer number of radios without any signs of being a legitimate business doesn't add up. The wide range of emission designators makes it look like you don't have a plan for what you are going to do with the frequencies once you get them.

If you really do have a need for all this, and can back it up with a business license, business plan, and some additional proof, get a frequency coordinator involved. Why you may not need to coordinate the frequencies, you do need some serious assistance getting this sorted out. You are not going to get all you are asking for the way you've done it.
 
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It's not nice to try and fool the FCC, they have been at this a long time. By submitting the application you are swearing everything you have submitted is true and factual and can be verified. I would withdraw your application and start over and do it right, listen to what others have posted.
 

alcahuete

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Thanks MMckenna for the input.

I think there is some confusion, and to be honest, a lot of this stems from their absolutely stupid and antiquated Java platform.

As far as the emissions are concerned, I submitted FM analog, DMR, and NXDN (the NXDN is for potential future expansion). I'm not really sure where the others came from, to be perfectly honest. Looking at the application now, I do see like 5 or 6. Some have even more than that!

It would also help to have something more than just "Part 90"

Again, that is not something that was put in by me. I've seen 90.35, 90.4, etc. on various licenses. I'm guessing this is something put in by the FCC? No clue, but I didn't enter it anywhere. The "Internal On-Site and Mobile Communications" was the begining of several lines of description as far as what we do. Not sure if it doesn't like line breaks or too many characters or what the deal is, but the entire description is showing up in their java program. The rest does not appear on the application, or apparently on the PDF 601 that was created.

As far as the control point (which is indeed my house), it is using the mailing address from my application, as since I'm sure you are aware, there is no such thing as a control point for itinerant use, as fixed operations are [generally] not permitted. In fact, the control point was greyed out on the application, I'm assuming because of that very reason.

As far as registering under my own name, trust me, I tried doing it under the business name a dozen times. We're a registered C Corporation, but the stupid java application will not accept or verify the company's EIN, straight from the IRS. I've seen at least a few dozen posts on the internet stating this exact same problem with the FCC's site. When I called to talk to a "technician" they had no idea and could not help me. So I gave up and put it under my own name. It was either that or not be able to submit an application at all.

Seriously, 1000 radios on that many frequencies, what the heck are you up to?

The 1000 radios is a tiny exaggeration for future growth. When I go 1 radio over what we currently have, for example, I'm not really in the mood for paying the FCC more money to update the application. But it isn't uncommon to to have 800+ radios in use for what we do.

We are involved with setting up data networks and communications at extremely large events, i.e. the 200,000 person march the person referenced in the other thread, state fairs, county fairs, large national events, etc. It is not uncommon for us to have 300-400 security personnel alone at some of the events, each with at least one radio, sometimes 2, for communications between themselves and others. That doesn't include any other personnel, a fairly decent amount of frequency pairs for repeaters, etc. At the end of the day, yes, it is a crapload of radios and a crapload of frequencies. :D

We currently accomplish this task through various rental agencies and *gasp* FRS and MURS. I know...scares me just thinking about it. :) :) We have the means, know-how, and equipment to do it ourselves, and cut out the extremely expensive middle man, and actually move to a more robust system.

...they are probably wondering why you cannot use coordinated frequencies for that.

From the coordinators I've talked to, outside of a federal government agency, it is near impossible for a decent number of frequencies (or even a single frequency for that matter) to be coordinated on a national level. What we do is the very definition of itinerant use.

The thought of 1000 users showing up in a random location and occupying a bunch of frequencies puts all the other itinerant users in a rough place.

And that's one of my reasons for requesting the number of frequencies I requested. When our people show up a couple weeks before an event to monitor, and itinerant frequencies are getting heavy use in an area, we're F'ed and so are the other itinerant users, if we say only have 8 or 10 frequencies to use. It would make sense (to me anyway) to have other frequencies to switch to so that we are not causing interference, and the other itinerant users are not causing interference to us. Do we absolutely need 135 frequencies? Probably not. Are those 135 frequencies going to be used at once? No. But when we need them, we need them. If we show up to an event and our say 20 frequencies are being heavily used, then what? Yes, we could probably just move to other itinerant frequencies anyway, like 99% of the businesses do out there, but we want to do this the right way and actually be licensed properly. There are plenty of other applicants (I found dozens) with the entire itinerant spectrum on their licenses, so this is not an unprecedented request by any means.

Thanks again for the input!
 
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alcahuete

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It's not nice to try and fool the FCC, they have been at this a long time. By submitting the application you are swearing everything you have submitted is true and factual and can be verified. I would withdraw your application and start over and do it right, listen to what others have posted.

And what exactly are you suggesting is not factual about the application that was submitted? I'm more than happy to verify anything the FCC would like verified.

Anytime I call the FCC and talk to their knowledgeable "technicians" they just chuckle when I talk about their almost decade old means of submitting the application. To be perfectly honest, I don't think they want individuals or businesses submitting applications, if you really want to know the truth. They want you to go through frequency coordinators (good old boy's club?) and pay them obscene amounts of money to perform an incredibly simple task. It should not be that way.
 

mmckenna

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Yeah, the people at the FCC can be a problem. Getting to someone that knows what they are doing is difficult.

Here's some suggestions:

Ditch the low band stuff. That won't do you any good. If you really do need them, put the power at 100 watts. Get rid of the SSB and AM, just ask for FM.

Consider using Special Temporary Authorizations for big events, That's what the NFL does for the superbowl. It takes some planning, but it's the right tool for doing large events.

Not sure what to do about the issues with the FCC form.

I understand your needs, but I think you need to find a way to fix some of those issues. You'll need to get an FRN under your business name. Focus on that first. Get that done before trying to get the license.
 
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