More Narrowbanding FAQs
Tuesday, February 02, 2010 | Comments
 
Editor’s Note: FCC officials have agreed to answer technical questions submitted by MissionCritical Communications readers. Following are questions from readers and answers from Ira Keltz, deputy chief of the FCC’s Office of Engineering and Technology.
 
If you have a technical question regarding VHF or UHF narrowbanding, e-mail editor@RRMediaGroup.com, and we will request an answer from the FCC and run the information as soon as possible.
 
Question: I’m the coordinator for my hospital (WNJH888). We have 163.250 MHz as our in-house pager system. Is 163.250 going narrowband? I’ve seen opinions both ways and somewhat confusing-sounding report and orders (R&Os).
 
Answer: The paging-only frequencies, such as 163.250 MHz, don’t have to narrowband and may continue to operate at 25 kilohertz. This was confirmed in the narrowbanding third memorandum opinion and order (MO&O). See 19 FCC Rcd 24045, 25058-60, paragraphs 31-34 (2004).
 
Question: Has the FCC issued an FCC ID for a 450 Master II modified with the Communication Specialists CF-MST II narrowband conversion kit?
 
Answer: Not to our knowledge. However, when a previously certified device is modified and submitted for a new certification, it’s certified on its own merits. It wouldn’t be certified as a 450 Master II modified by a CF-MST II kit. The recertified radio would get a new FCC ID.
 
Question: I’m making an assumption that once this conversion kit is installed and has been certified on one Master II, the FCC ID issued would apply to all Master IIs modified with this kit.
 
Answer: The assumption isn’t valid. If a radio is modified and then submitted for a new certification, the party that submits the application for equipment approval becomes the responsible party for that radio. That party would be required to place the new FCC ID label on the device. If this party is also a distributor or a manufacturer, they could modify the same radios in a similar manner and place the new FCC ID label on the modified radio. If a different party were to use the same kit to modify a radio, they would need to submit that modified radio for a new certification and become the responsible party for those modified radios.
 
Question: I have some concerns regarding the Jan. 1, 2011, manufacturing restriction for removing 25 kilohertz mandated by the FCC narrowbanding rules defined in Part 90.203. Does the mandate in Section 90.203(j)(10) to stop manufacturing 25-kilohertz-capable equipment (or the configuration software that allows 25-kilohertz configuration of said equipment) apply to field support operations, which build and distribute older hardware/software media with 25-kilohertz capability for defect repair, software upgrade and parts replacement scenarios? Typically, field support operations are contractually obligated to build and ship these items per a service-and-support agreement with the customer.
 
Answer: Defect repairs, software upgrades and parts replacement for 25-kilohertz equipment are permitted, notwithstanding the prohibition on manufacturing after Jan. 1, 2011. There is a request pending for a stay of the 2011 deadlines. Action on that request would obviously change or moot some rules.
 
Question: What is the FCC’s proposal for handling 25-kilohertz equipment replacement scenarios (due to lightning strike, etc.) between 2011 and Jan. 1, 2013? 
 
Answer: We would entertain case-by-case requests for waivers to address unusual circumstances.
 
Question: What is the FCC’s proposal for handling 25-kilohertz equipment shipments for one-way paging application scenarios, which are exempt from the narrowbanding rules [90.203(j)(7)]?
 
Answer: 90.203(j)(7) constitutes an exception from the general prohibition in 90.203(j)(10). Transmitters designed only for one-way paging operations may still be manufactured and imported after Jan. 1, 2011. There is a request pending for a stay of the 2011 deadlines. Action on that request would obviously change or moot some rules.
 
Question: Are manufacturers allowed to build and ship 25-kilohertz equipment within the United States as long as the customer/ship destination is a non-FCC licensee (non-U.S. international customers, U.S. federal, etc.)? If so, are there any detailed labeling or order processing expectations associated with this allowance?
 
Answer: No, there is no exception in the rules for equipment intended for export. The rules contain no special labeling requirement for 25-kilohertz equipment intended for export. But equipment manufactured solely for export is exempt pursuant to Section 2.807 of the Rules and Section 302(c) of the Communications Act. Indeed, the commission specifically stated in the narrowbanding proceeding that the deadline didn’t apply to equipment intended for export. See Implementation of Sections 309(j) and 337 of the Communications Act of 1934 as Amended, report and order and further notice of proposed rulemaking, WT Docket No. 99-87, 15 FCC Rcd 22709, 22773 n.394 (2000).
 
Question: Is it legal to modify a wideband stand-alone receiver (VHF hi band) to narrowband by installing new crystal filters in the IF section? This modification has been accomplished on a test receiver in our shop and because the radio isn’t a transmitter, none of the parameters under Part 90 are applicable. We gained approximately 2.0 dbm signal-to-noise-and-distortion (SINAD) following the modification.
 
Answer: The authorization requirements for receivers are in Section 15.101 – unintentional radiators. They apply to receivers that tune within the range of 30 – 960 MHz and to CB receivers and radar detectors. The receiver in question is described as “VHF hi band” and would fall within this frequency range, so it’s subject to authorization under Part 15. If it’s a scanning receiver, it requires certification. If not, it would fall under the category of “all other receivers subject to Part 15” and would require authorization under either certification or declaration of conformity (DoC).
 
When equipment is modified by a party other than the original grantee or responsible party, the person performing the modifications becomes the new responsible party. Section 2.909 addresses this for both certified equipment (paragraph a) and equipment authorized under DoC (paragraph c). Section 2.1073(d) states that equipment authorized under DoC shall be retested for compliance if any modifications are made by the responsible party that could adversely affect the emanation characteristics of the equipment. DoC testing must be done at an accredited laboratory per Section 2.948(a)(3).
 
Section 2.1043 permits certain changes to be made to certified equipment. However, except for changes to software-defined radio (SDR) software, only the grantee of certification can make these. See Section 2.1043(b)(4). If changes are made by another party, then a new certification would be required.
 
Please note that Section 15.1 prohibits the operation of intentional or unintentional radiators that don’t comply with the administrative and technical requirements of Part 15, including the equipment authorization requirement.
 

 
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