Help request with FCC 601

[sisfs]

I'm currently pulling my hair out dealing with my first 601 application on behalf of a client of our IT company. for background we support their IT infrastructure and a few of us have radio experience from the military and HAM sides of things but... this is my first foray into the Part 90 licensing part of radio comms.

our application was originally returned for a couple of missed items: eligibility statement was missing (hey, it said optional) and we had listed MO instead of MOI for our station class.

the amended app just got returned again with this as an explanation for the return:

"You eligibility indicates that you will use radios in support of daily commercial operations and you are proposing itinerant operations within 1.6 km kilometers of a centerpoint. Such operations would use the frequencies on a regular basis within the operating radius and does not appear to be an itinerant operation in accordance with the definition of itinerant in rule 90.7. Please explain or amend the application accordingly."

now I'm wondering if I'm reading their definition for itinerant wrong or if it doesn't specify their parameters clearly enough and a more seasoned operator could assist in deciphering what I'm missing.

part 90.7 states: Itinerant operation. Operation of a radio station at unspecified locations for varying periods of time.

in my reading of this: since there are no fixed antennas, all transmissions are at unspecified locations... and since the personnel will occasionally use the radio to call for maintenance help etc. they will also be using in for varying periods of time.

my reading of this could very well be a result of my Aspergers but is the 1.6km radius too small to be considered 2 (or more) locations and so it fails on the various locations?

if that's the case what should the application be changed to from Itinerant? I'm available to answer any questions that I haven't provided enough info for.

Seriously, thanks for any help or guidance you can provide!

 

[RaleighGuy]

"You eligibility indicates that you will use radios in support of daily commercial operations and you are proposing itinerant operations within 1.6 km kilometers of a centerpoint. Such operations would use the frequencies on a regular basis within the operating radius and does not appear to be an itinerant operation in accordance with the definition of itinerant in rule 90.7. Please explain or amend the application accordingly."

Let me start by saying there are many who are more experienced than I, but my reading is where there is no center point it would possibly be itinerant, and you are using the radios in a specified area on a regular basis, and would think the FCC opinion is correct.

part 90.7 states: Itinerant operation. Operation of a radio station at unspecified locations for varying periods of time.


Seriously, thanks for any help or guidance you can provide!

You aren't using the radios at unspecified locations or for varying periods of time, you are using them within a defined area with a center point on a regular basis. If you considered not today but maybe tomorrow, or only Monday - Friday (excepted every third Saturday) because we are closed on the weekends, as being varying periods of time, then a large number of commercial entities would be eligible.

What you are proposing, in my mind, is not itinerant and I'd be surprised to see it approved.

 

[mmckenna]

Right, what you are proposing is not itinerant use. You listed a fixed location, which isn't what itinerant frequencies are for.
Using itinerant licensing to bypass the frequency coordination process is what got this kicked back.

To do this correctly, you would need to work with a frequency coordinator and let them pick appropriate frequencies for the location. That'll cost you a few hundred bucks at the most. Usually the frequency coordinator will also file the paperwork for you and save you the headaches.
Frequency coordination is not something you can do on your own, that has to be done by an FCC approved coordinator.

 

[sisfs]

understood... again, I have no grounds to argue with anything, I'm just trying to ascertain the right way to do this. I can easily see my interpretation of it being wrong as I have trouble filling out simple forms, according to my wife, all the time. tanks for the input and i think we will just change it to mobile and call it a day.

I think the reason we thought that itinerant could be around a center point is because they had itinerant KMRA as a selection choice. but I can easily see that they could be referring to multiple locations "within" much larger radius and that being the issue.

 

[sisfs]

Right, what you are proposing is not itinerant use. You listed a fixed location, which isn't what itinerant frequencies are for.
Using itinerant licensing to bypass the frequency coordination process is what got this kicked back.

To do this correctly, you would need to work with a frequency coordinator and let them pick appropriate frequencies for the location. That'll cost you a few hundred bucks at the most. Usually the frequency coordinator will also file the paperwork for you and save you the headaches.
Frequency coordination is not something you can do on your own, that has to be done by an FCC approved coordinator.

ok, with that as a guideline (and since we have already paid the initial application fee) it seems that the business pool of frequencies doesn't list a coordinator for the majority of them. There is a statement that any federal coordinator can coordinate for those freqs (https://www.ecfr.gov/current/title-47/part-90/subpart-C#p-90.35(b)(2)(i)).

are you saying that if we change to mobile (instead of itinerant) that we'll have to eat the cost already paid or will they do the coordination/deconfliction that we could have had a service do if we had started with them?

 

[lenk911]

Usually the frequency coordinator will also file the paperwork for you

Most of the coordinators have an interactive program to builds a form 601 and the required schedules for them to submit. The raw 601 and its schedules are as bad as the IRS 1040 and its schedules! I file 50-100 licenses per year and can't remember when I last used a raw 601.

 

[sisfs]

Most of the coordinators have an interactive program to builds a form 601 and the required schedules for them to submit. The raw 601 and its schedules are as bad as the IRS 1040 and its schedules! I file 50-100 licenses per year and can't remember when I last used a raw 601.

i can see that being the clear way forward if this comes up again

 

[mmckenna]

i can see that being the clear way forward if this comes up again

It'll save you a lot of time, effort and headaches. Plus it will get the customer what they need without delays:

FCC Licensing - RadioSoft

RadioSoft, Inc. is your “One Stop Shop” for all things FCC Licensing and Frequency Coordination. We will prepare, coordinate and file ALL your Part 90 FCC license applications, Low band through Microwave, coordinated by experienced professionals.

www.radiosoft.com

While it's useful to have amateur radio and military radio experience, this is different. Many of us here are hams and have military backgrounds, but we still rely on companies like this.