Itinerant Licensing Question

[daugherh]

Hi all,

I am in the process of filing an application for Part 90 Itinerant Frequencies for our local CERT Team. I'm using itinerants because we move from site to site depending on our mission(s).

However, I have a few questions before I spend the money only to have the application rejected due to an error I may make, so I figured I would ask for advice first.

I have 3 questions really, and they are as follows.

1) I'm asking for frequencies found on the RR Itinerant article in the wiki, located here, but am confused by the footnotes. (See attached image - RR Itinerant.) For example, 151.625 list (5) and 151.7 list (3) and (5). According to the notes 151.7 is allowed up to 35 watts. What would be the max power on 151.625 as it only says (5): Itinerant use only? Would this rating be the same for say, 151.505, or 151.5125?

2) If I am going to be using portables, I have listed them as follows (example):

Freq: 151.700, Station Class MOI, No. of Units X, Output Power 5 and ERP 5 with Emissions of 11K2F3E, 7K60FXE as we will probably migrate to DMR and I'd rather have it listed already. Thinking of 7K60FXD as well for DMR text messaging on MotoTrbo.

My question here is, if I also plan on having a mobile radio (in our trailer) that will occasionally use the frequency it is more than 5 watts. Would I need to list the frequency a second time as 35 watts on the application, or only list it once for 35 and have that cover the portables as well? Can a mobile be considered itinerant?

3) I currently have listed number of units as 100. We don't have that many currently but will probably very soon. Can I go ahead and list more than we are using to cover expansion, or do I have to wait and then edit the license for more?

I greatly appreciate any advice you can give on this. I'm trying to do this myself to save the money of having to go to the "experts" since its for itinerant only. From what I've read itinerant frequencies do not require coordination.

Thank you again for your help!

 

[nd5y]

As far as I know if the Industrial/Business Pool or Public Safety Pool frequency tables don't show a power limitation in the footnotes for a particular frequency, then the power limits in 90.205 apply.

 

[Rred]

It can be worthwhile to call the FCC's licensing division at 800-322-1117 and ask the questions directly to them. Sometimes, you can reach someone who knows. Sometimes they'll call you back after researching a question. But the phone call is free, so you don't have much to lose.

 

[daugherh]

Thank you both for your assistance so far.

Rred, that number is invalid when I dial. Do you know of another that may have changed?

 

[n3obl]

Technically that not a legal use of iterinant. That's for when you go out of normal area of operation. You really should license to county of operation.

 

[daugherh]

n3obl, I hate to disagree but the purpose of Itinerant frequencies are as follows:

Itinerant licenses use a predefined group of frequencies set aside by the FCC form the purpose of radio users that need their license to travel with them. An example would be a contractor who works on multiple job sites throughout the state or county and they need the location of their license to travel with them. Itinerant licenses can be nationwide, multiple state, statewide, or locally defined. The downside with itinerant frequencies is that they are shared, and there is a high potential for interfere do to the radio traffic on those frequencies by other licensed users.

As CERT, our sites are throughout the county at different times. According to this I do believe that Itinerant licensing would fit our needs perfectly.

 

[jonwienke]

County, or country?

If county, then itinerant is not appropriate.

If country, then it would.

 

[daugherh]

If itinerants can be fine grained as much as locally defined, then how would it not be appropriate. We are not operating out of the same location each and every day. We may be at one site this weekend and another site the next weekend, so filing for a fixed based area of operations doesn't really fit our bill. We occasionally go out of the county to other counties that neighbor us.

 

[jonwienke]

Non-itinerant license covers operation within X number of miles from a geographic location (your HQ). Select a reasonable value of X to cover your county. No reason to do itinerant.

 

[Rred]

While your CERT could, in theory, answer a mutual aid call and be dispatched to LA or Kansas City after the next big quake, in those circumstances I suggest "all bets are off" and the FCC will be the least concerned party.

Applying for a license that is exclusive to your COUNTY, or your STATE (if you anticipate mutual aid to the surrounding counties) may not be out of the question. There are organizations with "industrial and Business" licenses set up precisely that way, exclusive to their home state.

Although personally, I'd argue that a CERT is "public service" and neither an industry or business. Personally.

My Rolodex might need updating.(G) I also have 1-888-225-5322 as the FCC's main consumer number. Their web site should have the most current choices listed, but they're strictly a "bankers' hours" operation, M-F probably 8:30-4:30.

 

[daugherh]

Thanks Red. With the way we're handled in our county we really don't get much help from EM, Sheriff, or any other entity. While we fall under EM, we're also on our own to some degree. I think I'll call the FCC tomorrow morning and get their opinion as well. Ya'll have been very helpful.

 

[Rred]

Good luck with that. The individual flexibility that is allowed to CERTs can certainly make them like a herd of cats, in terms of trying to get more uniformity when it is needed. But since every CERT is sponsored by a public safety agency, and that's a DHS/FEMA requirement, whatever your group is set up as, you are a pubic safety agency, or an auxiliary of that agency. Either way, neither a business entity nor an industry.

Although, supposedly non-profit or not-for-profit companies do exist, which have big chunks of assigned channels that they then rent out to government entities, oddly enough. Whatever keeps everyone happy, right?(G)

 

[KC2zZe]

Russ, don't hold your breath that you'll get an answer beyond "contact your frequency coordinator for further guidance" from the Commission.

Since you are considering taking the steps that you are (and I applaud you for doing so), I presume you've selected one, right? And if you did, why bother with the cesspool that are the itinerants?

 

[n3obl]

probably doesnt have a coordinator as he was trying to license itinerant freqs. I have a business license which covers roughly a good local area plus 4 itinerant frequencies for when i travel out of state.

 

[KC2zZe]

Well then, the time as arrived to hire one. Who'd you use, n3obl? UTC? APCO? IMSA? EWA? Choices abound.

I'm in complete agreement with Jon in post 9 above. Figure out your typical service area (likely Countywide) and stay away from the itinerants. If one's truly worried about what frequencies one'll use when operating well outside of one's normal areas, then load in all five of the M-URS frequencies and go with that.

 

[JRayfield]

From where did you quote that information? From the FCC's website?

John Rayfield, Jr.

n3obl, I hate to disagree but the purpose of Itinerant frequencies are as follows:

Quote:
Itinerant licenses use a predefined group of frequencies set aside by the FCC form the purpose of radio users that need their license to travel with them. An example would be a contractor who works on multiple job sites throughout the state or county and they need the location of their license to travel with them. Itinerant licenses can be nationwide, multiple state, statewide, or locally defined. The downside with itinerant frequencies is that they are shared, and there is a high potential for interfere do to the radio traffic on those frequencies by other licensed users.

As CERT, our sites are throughout the county at different times. According to this I do believe that Itinerant licensing would fit our needs perfectly.

 

[NavyBOFH]

Russell - give me a PM on here and I can try to help you out. I am a tech for the SCHEART Network and have good contacts within the state EMD organization to see what can be done for your needs.

For a CERT team, especially in SC, we have been working (I am an ETV employee) with the other ham clubs to provide ham licensing to those interested and then you have use of all SCHEART networks in an emergency.

But for actual agency use - the state has quite a robust setup of the VTAC/UTAC/8TAC frequencies along with state-specific frequencies and repeaters in each "zone". There's also a statewide lo-band repeater group for EMD use as well. If you are in the situation you are in, I can help you as much as possible get to the right group.

I can tell you now that Pickens County ARES has a GREAT presence on SCHEART and we can get everyone in that direction hopefully.

 

[toastycookies]

Russell - give me a PM on here and I can try to help you out. I am a tech for the SCHEART Network and have good contacts within the state EMD organization to see what can be done for your needs.

For a CERT team, especially in SC, we have been working (I am an ETV employee) with the other ham clubs to provide ham licensing to those interested and then you have use of all SCHEART networks in an emergency.

But for actual agency use - the state has quite a robust setup of the VTAC/UTAC/8TAC frequencies along with state-specific frequencies and repeaters in each "zone". There's also a statewide lo-band repeater group for EMD use as well. If you are in the situation you are in, I can help you as much as possible get to the right group.

I can tell you now that Pickens County ARES has a GREAT presence on SCHEART and we can get everyone in that direction hopefully.

Kind of sad how you feel the need to take that to PM now instead of replying public.

Oh well.

 

[NavyBOFH]

I can reply to everything I can publicly but I was going to give him my work contact information as well as some EMD comms guys info that might be able to help more.

Since this isn't an itinerant issue at this point I can only imagine this being any help to those who are a CERT type organization in SC.

But in this state it's usually that we offer amateur radio licensing to these groups and we have a HUGE microwave linked infrastructure open for ANY Ham to use. Especially in emergencies.

For "official" use though the state has plenty other options to those who qualify. Those being the TAC frequencies I mentioned above. Those are license by-rule to agencies who qualify to use them. I will look later but for SC there's a form that's usually submitted which then covers said organization under the license the state holds for those frequencies. When a disaster occurs it's then usually up to that county's EMD to supply any repeaters for their use. But yet again - amateur radio use is so wide-spread in these instances that we usually go that route.

We have 18 UHF repeaters in a linked system, 13 VHF repeaters linked as well, and up to now 26 DMR repeaters. All served by a public safety grade microwave system. So in the end that system is what most groups try to use and is even in the state EMD's comm plan.


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[Rred]

BOFH, I would gently submit that having CERT members use ham radio for their regular communications, is a substantial violation of Part97. Ham radio is very much not supposed to be used for any other service where regular communications are made, and can be licensed to another more appropriate service.

CERT is a public safety function. There's Part90 for that.

Yes, when there is an unexpected emergency, anything goes. Yes, sure, ARES or RACES members can provide communications for CERTs. But none of that affects the question of what is appropriate for the routine communications of CERT teams. Every drill, every routine deployment, is not a proper place for ham radio unless it is an irregular "test" or drill for the hams as well. Irregular--not routinely done every time.

Yes, the FCC has been very generous about how ham radio is used for anything "emergency" related, but I've also heard speakers from the FCC over the years mentioning that they are cutting ham radio some slack with this--and it really shouldn't be done.

Encouraging CERT members to become hams, great. But the OP has the right idea: Get an appropriate license for Part 90 (whether that's I&B or Public Safety) and as a separate matter, explore the use of hams. Hams don't answer to local government agencies. CERTs do. They have the same choice as all volunteers, i.e. do as they are told or quit. Respond when they are called out--or explain themselves if they have not.

Hams? That's a bigger herd of cats, and entirely private politics, i.e. complying with the ARRL and its appointees.