Frequency Coordination Games and Excessive Fees – Warning for New Private Land Mobile Applicants (Part 90)

[K2SMT_Sonja]

Hello all,
Sonja Thomas here (SLT Design Creations, LLC – Midwest City, OK).

I'm posting today to bring attention to some troubling experiences I'm encountering while trying to secure frequency coordination for a new low-power Part 90 Industrial/Business Pool license.

---

📌 Summary of My Situation:​

• I am filing my own FCC Form 601 independently through the ULS portal, as permitted by 47 CFR § 1.913(a)(5).
• I only requested frequency coordination services (i.e., certified frequency certification letters) — not application preparation or filing.
• Multiple coordinators either:
  • Refused coordination-only services without bundling their FCC filing services;
  • Quoted FCC filing fees grossly above the legal $50 (pre-May 23, 2025) or $105 (post-May 23) amounts listed in the FCC 23-112 Report and Order and Federal Register Vol. 89, No. 30 (February 13, 2024);
  • Demanded FCC filing fees exceeding $200+, while claiming there is "no other way" for applicants to proceed.
• In some cases, even antenna coordinates were incorrect on returned documentation, raising serious concerns about their attention to technical detail.

---

⚡ Major Concerns I’m Raising:​

• Misrepresentation of FCC rules — Coordinators telling small business applicants that self-filing is "impossible" or "not allowed," which is false.
• Artificial bundling of services — forcing unnecessary application handling and inflated charges on filers who are capable of navigating the ULS themselves.
• Unexplained markup of FCC fees — quoting double, triple, or more for what should legally be $50 (until May 23, 2025).
• Exploitation of system complexity — counting on small businesses being overwhelmed by the process and just "paying to make it go away."

---

🛡 Why This Should Matter to Everyone Here:​

Even if you’re an established shop, system integrator, or longtime user of Part 90 services — if certified coordinators normalize these practices unchecked, it drives up everyone’s costs, especially for:

• Small fleets
• Event organizers
• Volunteer organizations
• Rural and community networks
• Private system upgrades

More gatekeeping = fewer applicants = weaker Part 90 protection = more spectrum erosion over time.

---

🔥 My Ask to the Community:​

• Has anyone else here recently filed for Part 90 coordination independently?
• Are there certified coordinators who still offer coordination-only services at fair rates?
• What has been your experience with pricing, timelines, and cooperation lately?

I'm collecting documentation and will escalate appropriately if needed, but would appreciate any real-world feedback or recommendations from others who've walked this road recently.

Thank you for your time — and hopefully this saves someone else from being blindsided like I nearly was.

Respectfully,
Sonja Michelle Lina Thomas
SLT Design Creations, LLC
Midwest City, OK


📚 Additional References:
While preparing this post, I also located historical discussions that validate the persistence of these issues:

• FWIW Licensing Part 90 Itinerants as an Individual is Tough – RadioReference, 2023 Update
  This thread illustrates similar coordination resistance issues dating back to 2006, showing that applicants have historically faced unnecessary barriers when trying to self-file Part 90 applications. Persistence, familiarity with FCC regulations, and a firm stance have proven successful strategies for others in comparable situations.

 

[kf8yk]

I am filing my own FCC Form 601 independently through the ULS portal, as permitted by 47 CFR § 1.913(a)(5).

1.913(a)(5) Only applies to spectrum leasing, not for a standard Part 90 site based license.

1.913(e) Is important to review as it specifies that frequency coordination is required for your application. The specific coordination requirements for Part 90 are here: 90.175

Quoted FCC filing fees grossly above the legal $50 (pre-May 23, 2025) or $105 (post-May 23) amounts listed in the FCC 23-112 Report and Order and Federal Register Vol. 89, No. 30 (February 13, 2024)

Demanded FCC filing fees exceeding $200+, while claiming there is "no other way" for applicants to proceed.

The R&O and FR quoted is for the broadcast service, they don't apply to land mobile licenses.

Part 90 fees can be found here: FCC Site Based Fees A typical new FCC LMR application & regulatory fee is $ 205, the coordinator then adds their fees on top of the FCC fees.

The FCC has info on the process & fees for business licensing here: Industrial / Business Licensing

 

[alcahuete]

As a business owner, you should understand better than anybody that the frequency coordinators are not running a charity. They too are trying to run a business and make money. Do you, for example, honestly think that you are only going to be charged the FCC filing fee for the application? They're just supposed to do all the work for free and charge you what the FCC charges them?

• Has anyone else here recently filed for Part 90 coordination independently?

Not recently, but I have many times in the past.

• Are there certified coordinators who still offer coordination-only services at fair rates?

Yes.

• What has been your experience with pricing, timelines, and cooperation lately?

Pricing has never been super cheap, but I have never felt they are gouging me. Timelines were very quick, and cooperation was great.

 

[mmckenna]

• What has been your experience with pricing, timelines, and cooperation lately?

Pricing has never been super cheap, but I have never felt they are gouging me. Timelines were very quick, and cooperation was great.

I had 2 VHF pairs and a couple of UHF pairs coordinated in the last year or so. I agree. It's was a very reasonable price and was processed quickly, both by the frequency coordinator and the FCC.

And profit is not a four letter word.

 

[davidgcet]

as someone who has filed a LOT of licenses with various coordinators, both business and government related, i can tell you the reputable ones make the process easy and are willing to help you on the phone. you will pay them the filing fee and the coordination fee. how much that is depends entirely on what you are filing. do not take this the wrong way, but it is obvious you have no clue what you are doing, which rule sections to list, nor any number of other things that can add FCC fees up quickly. add several freqs, that is more fees, add several bases, could be more fees. bite the bullet and go to a local radio shop and have them do it for you, some will waive their own portion of the fees (not the coordination or fcc side) if you purchase the system from them. not all do this, and probably fewer than ever due to cost of business the last few years, but some will.

i honestly do not know what real coordinators will deal direct with the end user. those scammers that send mailers appearing to be from the FCC will file a license for you, but they charge an arm and a leg...

 

[AM909]

I can imagine that coordinating for an individual (or business) that wants to do their own filing can be as difficult as supporting an individual that wants to buy complicated programming software – there's more to it than just the initial sale. When there's any kind of issue with it getting kicked back by the FCC, the coordinator will often need to be involved and spend more time than they would in dealing with a more experienced licensing provider. See the well-intentioned but apparently wrong cites above for example. At today's prices, a couple hundred bucks added to just handle it is not a bad value for what amounts to a fairly rare and specialized skill. For something you don't have to do again for 10 years.

Is it possible to represent yourself in court, pro per? Sure. Will and should some courts insist on you having an attorney's help because of the mountain of procedural code you have to follow to avoid wasting everyone's time? Will they be hating life? You betcha.

 

[2wayfreq]

At our shop, we get pummeled with Wireless Applications Corp and Business Radio Licensing mail to the point where its quite annoying.

 

[nd5y]

Looks like the OP was successful.

ULS Application - Industrial/Business Pool, Conventional - 0011547296 - SLT Design Creations LLC

 

[mmckenna]

Looks like the OP was successful.

ULS Application - Industrial/Business Pool, Conventional - 0011547296 - SLT Design Creations LLC

And those are all itinerant frequencies that don't require coordination.

 

[RAD_Kat]

And those are all itinerant frequencies that don't require coordination.

Yes but it has been returned because there are frequencies listed that are not for IT use and there is a question on the request for waiver of fees. All offers of assistance have been rudely declined.

 

[AM909]

464.325 looks like one of those complications I mentioned.

 

[AM909]

Looks like the OP was successful.

ULS Application - Industrial/Business Pool, Conventional - 0011547296 - SLT Design Creations LLC

Not so much:

Application Status

R - Returned

 

[tweiss3]

Not so much:

Application Status

R - Returned

Yea, you don't get itinerant for 10 mile radius around a point......

 

[nd5y]

Not so much:

This morning it was Pending.

 

[mmckenna]

464.325 looks like one of those complications I mentioned.

Yeah, I missed that one. Probably issue #1

Not sure the request for fee waiver worked, either. FCC may or may not reply to that. While the justification is a good one, I'm not sure if the FCC is bound to honor it.

 

[mmckenna]

Yea, you don't get itinerant for 10 mile radius around a point......

It doesn't appear to be centered on a specific center point.


464.325 is in the business industrial pool, but not for itinerant use. In fact, it specifically says:
This frequency may be assigned to fixed stations in the Industrial/Business Pool in accordance with the provisions of § 90.261.
Replace it with 469.550, and it'll probably go through, not counting the fee waiver request.

 

[Project25_MASTR]

Yea, you don't get itinerant for 10 mile radius around a point......

Typically statewide or multi-state at a bare minimum.

 

[tweiss3]

It doesn't appear to be centered on a specific center point.

If you look at service specific, the description for eligibility indicates 10 miles around a specific point

Typically statewide or multi-state at a bare minimum.

Correct, but it could be county wide as well.

 

[mmckenna]

If you look at service specific, the description for eligibility indicates 10 miles around a specific point

Wow, sure does. Strike 2.

Seems like the goal of avoiding paying for frequency coordination and filing fees didn't quite work out so well. Almost like frequency coordinators know what they are doing, or something….

 

[RAD_Kat]

And, unfortunately, the recently filed amendment will also be returned or even dismissed if she refuses to comply with the items stated in the notice of return. I agree the coordinators know what they're doing, or something...