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Just a few years ago, radio sta-tion license applications were submitted by paper copy to FCC-certified frequency coordinators. Then the coordinators submitted piles of paper applications to the FCC for licens-ing. Weve come a long way in a short time. Today, electronic filing saves time and helps ensure better management of licenses.

But sometimes it seems that the more automated we get, the more work we have to do. Hopefully, this article will ease your mind and help you realize that its not all that complicated.

Keeping CurrentIt is the responsibility of the licensee to keep licenses up to date with renew-als, administrative information, modifica-tions and required notifications. Licenses are typically valid for 10 years. During that time, administrations can change, which can affect the management of the licenses. If administrative informationsuch as mailing addresses, phone num-bers or e-mail addresseschanges, your

agency may not receive important notifications from the FCC.

As we all know, the FCC is famous for changing rules, implementing audits and conducting other mandatory updates. Remember narrowbanding? The FCC has noted that there are still thousands of land mobile licenses that were never updated to show that theyre operating in narrowband mode. These licensees are encouraged to submit applications to the FCC to remove their wideband emission designator and add the nar-rowband emission designator equivalent to what they are currently licensed for. They can submit an application to the FCC directly on the FCCs ULS system at https://wireless2.fcc.gov/narrowband/login.faces. Those licensees who have approved waivers to continue operating in wideband mode need to monitor their authorizations to avoid cancellation of their licenses.

Licenses should be reviewed every year

by the licensee to verify that all technical information matches whats being used. If a transmitter is to be moved or added to a license, the licensee must submit a com-pleted FCC Form 601 with the changes to an FCC-certified frequency coordina-tor. After the coordinator processes the application, it is submitted to the FCC for licensing.

The FCC requires a licensee with new or modified frequencies/sites to notify them within one year of the time of grant of the license that the frequencies are fully constructed and operational. If the licensee does not notify the FCC, the entire license or part of the license could be cancelled.

Keeping track of licenses and managing them can be a tedious project. So mistakes are not made, your agency should desig-nate an employee who is trained in licens-ing to manage them or hire a professional

Going PaperlessFiling Your Radio Station License Application ElectronicallyBy Christine PhelPs

service to do it. Once a license has been cancelled, theres no guarantee that the same frequencies can be reassigned. Not only that, consider the cost to change a system if the frequencies do need to be changed.

Now that its been established how important it is to manage your licenses, read on to find out how you can file appli-cations electronically to save time and keep better records for your agency.

SpeCtrum WatChYour agency should consider filing new station applications and modifications to existing licenses electronically. The pro-grams used by the FCC-certified fre-quency coordinators are user friendly, and you can manage your applications in a private account. Filing electronically helps avoid double data entry for the coordinator and provides more complete information for fre-quency coordination purposes in a more organized manner.

The program that APCO uses for filing electronically is Spec-trum Watch. Users can regis-ter to use the programat no costto submit applications to APCO. All you need to do is go to www.spectrumwatch.com to register. Spectrum Watch will send you an e-mail with a user name and password. You can submit applications for new sta-tion licenses, modifications of licenses, Special Temporary Authorizations (STA) and renewals through APCO for process-ing and submission to the FCC.

If youre applying for a new station license, you will need to fill out the entire application with all required items for the application to be considered for process-ing and frequency coordination. If there are minor errors, APCO will contact you for the information. If the application is incomplete or has information that is questionable, the application may be returned to the sender through Spectrum Watch. The application on your account would show as Returned by Coordina-tor. APCO would send an e-mail to the sender with the information that is

required to process it.If youre proposing to modify your

license to make changes, additions or deletions, you would create an application using the call sign. The Spectrum Watch program will prefill the application with the license data from the FCCs ULS system. You should check the entire appli-cation and make any necessary updates, changes, additions and deletions.

After the application is complete, you can attach documents, such as a payment method, eligibility statement, authoriza-tion letters, letters of concurrence for specific frequencies, waiver letters, engi-neering studies, etc. (click on the paper clip to add files).

If you have information that youd like to pass on to APCO, you can enter a message in the notes field (click on the note pad).

Your application will be screened by the coordinator for content, completeness and compliance with FCC rules and regu-

lations, procedures, required documents and technical information. If additional information is required, you will be con-tacted by phone or e-mail. Due to time restrictions for processing applications mandated by the FCC, its recommended that your agency respond to the coordina-tor with requested information as soon as possible so that the application can be processed in a timely manner. If the infor-mation requested is not received within a reasonable length of time, the application will be moved to an inactive status until the needed information is received.

Normally, applications are coordinated and submitted to the FCC within about 20 business days. However, in cases where the request is in a congested area,

additional engineering is required or waiv-ers are involved, the time to coordinate an application could take much longer.

FrequenCy CoordinationThe fees that you pay to a frequency coor-dinator are for the searches and routine engineering performed on your applica-tion, not for a frequency. Your agency must not request parameters that are more than what is required to properly communicate within your jurisdictional service area.

The frequency coordinators often run routine engineering studies as part of the frequency coordination process; however, if specific studies are required according to FCC rules or Regional Planning for 800 and 700 MHz, there would be additional fees. Your agency would be notified if studies are required.

The public safety coordinators are dedi-cated to protecting licensed users within FCC rules and regulations. If the best fre-

quency available for your appli-cation is one that has co-channel or adjacent channel licensees in the area, your agency might be asked to obtain letters of concurrence. Some rules, such as the ones for trunking or 800 MHz, require the letters of con-currence before a frequency coordinator can approve the frequencies. Again, your agency would be notified if letters of concurrence are required.

After an application is consid-ered approved by a frequency coordinator, the other land

mobile frequency coordinators are noti-fied of the application for their review. The coordinators have an automated notification process. If no objections are received after five business days, the application can be submitted to the FCC for licensing.

If the best frequency available is one that is dedicated to a coordinator other than the home coordinator (coordina-tor processing your application), inter-service approval is required and additional fees apply. If your application requires inter-service fees, your agency would be notified.

After all approvals are received, the application is submitted to the FCC electronically through a batch file for

Radios are essential public safety equipment. Dont let the FCC licensing process trip you up and get your agency fined or knocked off the frequencies you use. APCO-AFC can help. Photo Rick McClure

The FCCs Universal Licensing System (ULS) can be used to obtain license information and submit certain applications such as renewals, buildout notifications and administrative updates.

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licensing. The FCC is generally taking about three months to review and grant a license for a new station or modification requiring frequency coordination.

The FCC may find prob-lems with an application. If the Commission requires clarifica-tion or additional documenta-tion, they will mail out a Return Notice with an explanation of what they need. The notice will state that the applicant has 60 days to respond back to the FCC with the requested infor-mation. If the application is not amended to include what is requested by the FCC, the application is dismissed. Once an application is dismissed by the FCC, the application pro-cess must start over.

If an application does not comply with FCC rules and regulations, the FCC will dismiss it. The FCC may also dismiss an application for lack of justification for the

requested parameters or frequencies.Frequency coordinators receive copies

of the FCC Return Notices. If the FCC requires additional information from the

applicant, the frequency coordinator will contact the applicant or representative for the information. If the information requested by the FCC is related to fre-quency coordination procedures, the

coordinator will provide the information.Next, lets look at some specific exam-

ples of electronic filing.

tin regiStrationSUnder the Debt Collection Improvement Act of 1996, the FCC is required to collect Tax-payer Identification Number (TIN) information to correlate its licensees with any outstand-ing debts owed to the federal government. All applications, notifications and correspon-dence must include an FCC Registration Number (FRN). TIN registrations can be filed on the FCCs website at https://apps.fcc.gov/coresWeb/public Home.do.

reneWalSYou can submit a license renewal to the FCC electronically at https://wireless2.fcc.gov/UlsEntry/licManager/login.jsp. The

going paperless

ULS lists both contact and technical information about the license. Its best to review the information every year to ensure nothing has changed.

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FCC allows licensees to submit renewals within 90 days of the expiration date. You will need the FRN shown on the license and the ULS password that goes with it. If you dont know the password, you will need to contact the FCC at 877-480-3201 to have it reset.

If the license has been expired less than 30 days, you can submit a renewal with a waiver request referring to FCC rule 1.949(a). The waiver letter must explain the reason why the license was not renewed before the expiration date. Describe how the system is used and for what purpose. Attach the letter to the renewal filing.

Buildout notiFiCationS (SChedule K) Licensees must notify the FCC within one year from the date of grant that the frequencies/sites granted are fully operational by submitting an FCC Form 601 Main Form and Schedule K. Your agency can submit the notification

directly on the FCCs ULS website at https://wireless2.fcc.gov/UlsEntry/ licManager/login.jsp. You will need the FRN shown on the license and the ULS password for that FRN to access your account.

On the first page of the application, choose the call sign that you want to work on. Click on Notify FCC, then click on S showing the system is fully constructed and operational. You will also need to enter a date the frequen-cies/sites were fully operational with the month/day/year. The date must be sometime after the First Use date. You cannot enter a future date. This notifica-tion must be submitted before the dead-line date to avoid having the FCC place the frequencies/sites into a Termination Pending status, and eventually cancel or partially cancel the license.

adminiStrative updateS Administrative updates (AU) do not require frequency coordination. Examples

of administrative updates are changes to mailing address, phone numbers, e-mail addresses, control point addresses and phone numbers, or any change that does not require frequency coordination per FCC rules and regulations. Your agency can submit an AU directly on the FCCs website at https://wireless2.fcc.gov/UlsEntry/licManager/login.jsp.

antenna StruCture regiStration (aSr)Structures with heights of more than 60.96 meters or 200 feet, and/or structures posi-tioned less than 8.04 km or 5 miles away from an airport, may require FAA Noti-fication. You can verify if notification is required by entering your structure infor-mation into the FCCs TOWAIR pro-gram at http://wireless2.fcc.gov/UlsApp/AsrSearch/towairSearch.jsp.

If the results show registration not required, indicate that on your applica-tion. If the results show that the param-eters pass slope to the nearest airport,

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