CDE #44541
PROTECTING YOUR
AGENCY AND ITS
EMPLOYEES WITH
RADIO
RULES
By Michael Scales
PSC | apcointl.org
re you familiar with the rules surrounding the radio you operate? Whether you
are a telecommunicator, law enforcement officer, firefighter, EMS provider, public safety officer, supervisor or technician
who works on the system, if you use a radio, you
should be aware of the rules governing its use.
42
The radio is the lifeline of every field responder — and its failure
could result in serious injury to the responder or public.
AVAILABLE RESOURCES
In recent months, several questions have
popped up on APCO’s forums pertaining to
protocols, standards and rules—specifically
on the use of the term “dispatch” as a station
identifier when communicating with field
units. FCC rules are specific about broadcasting FCC call signs (for public safety, this
is to occur by voice or Morse code every 30
minutes), but what an agency chooses to call
its dispatch is specific to each agency. Be sure
to review Part 90 of the CFR for details on
these rules.
Other questions have come up regarding interference and licensing. If you don’t
understand what a specific rule means to
you, don’t feel bashful about contacting
your local frequency advisor or calling the
AFC, APCO’s spectrum management division, which provides comprehensive radio
frequency coordination for public safety
agencies. APCO forums also are valuable
places to ask questions and find answers.
Years ago, there was a technical requirement from the FCC for every radio to be
tested and tuned annually. While this
requirement is no longer stated in the rules,
if your transmitter (base/repeater, mobile
or portable) is off-frequency or creating
spurious emissions, your agency could be
responsible for associated penalties. Best
practices include checking your equipment
regularly to ensure that the system is operating properly and within specifications.
The radio is the lifeline of every field
responder — and its failure could result in
serious injury to the responder or public. As
a communicator, supervisor, technician or
field responder, do you know who is responsible for your radio system, what the FCC call
sign is for your radio system and where the
license for the radio system is located? All
of these are important questions, and as a
user, you are required to know the answers.
It is the technician’s responsibility to know
what frequency and call guard tone to use,
but everyone should be able to answer the
previous questions.
INTERFERENCE
Your radio system is subject to weather
conditions and human error on a daily basis.
Wind can move dishes and antennas, changing coverage. Water can invade the feed line or
coax, causing signal loss. Someone may crossthread the antenna on their vehicle, causing
signal loss. The batteries on dispatchers’ portable radio or wireless headsets could fail and
messages could be missed — and all of these
issues could be a matter of life and death.
Aside from the FCC’s concerns, consider the safety issues that arise for officers
and firefighters. Today, most of your field
responders can identify areas where their
radios do not work for one reason or another.
Is this information listed and flagged in dispatch so your team is aware of the trouble
beforehand, or do you play the guessing game
when you do not hear from the field unit?
The FCC’s rules and general best practices
are meant to keep systems at their best. Those
of you who are “hams” (amateur radio operators) or CBers will remember “skip,” as well as
what it can do to radio transmissions: cause
signals from many miles away to show up
on your channel and cause interference with
local conversations. There is little that can
be done about this type of interference, but
users should be aware of the fact it can occur.
Several levels of interference exist, from
low-level noise to malicious harmful interference. Accidents occur on a daily basis
for interference; however, there have been
attempts to interfere or “jam” frequencies
to prevent messages from being transmitted.
Sections 15.5(b) and 90.187(b) of the rules
define harmful interference.
You may also have issues where agencies interfere by transmitting on the same
or nearby frequency, either by accident or
— in the worse cases — on purpose. Most
of the time, these issues are handled locally
and without a lot of pain, while other times
an outsider is needed to help work out the
details and get everyone back to “normal.”
Frequencies under the control of the
Federal Communications Commission are
issued under the design of “shared environment.” Several agencies within a state
or geographical area could share a common
frequency. Coordination by AFC and other
coordinators helps to keep interference to a
minimum.
There is currently a memorandum of
understanding between the FCC and the
AFC allowing APCO to receive complaints
of interference, review them and forward
the results to the FCC Enforcement Bureau.
Local advisors are assigned by AFC to contact the complainant, review the issue and,
if an agreement between the parties cannot
be reached, advise the home office to forward the complaint to the FCC Enforcement
Bureau for action. A majority of complaints
are settled prior to the bureau’s involvement.
IDENTIFICATION
As discussed above, telecommunicators
should be aware of Section 90.425 of the FCC’s
rules, which requires that an assigned FCC
call sign be broadcast on a regular basis
— either by voice or Morse code every 30
minutes. This requirement includes a clause
for emergencies and large amounts of radio
traffic that employees should review for
PSC | March/April 2017
The Federal Communications Commission (FCC) has a set of rules and regulations
covering private land mobile radio services
in Title 47, Part 90 of the Code of Federal
Regulations (CFR). These rules have been
around for many years and have been modified as needed.
Those in public safety are responsible for
the proper use of their assigned radios. Though
most people in our profession are certified to
use the tools of their trade, the radio is not typically included in certification requirements.
Most public safety employees have only had
brief exposure to radio regulations, such as
learning where to locate the on/off switch,
volume control and the channel selector.
Yet standards are in place for radio operation, technology and installation. And failure
to maintain federal regulations could result
in penalties as mild as a warning, or as severe
as a fine, seizure of offending equipment or
cancellation of an agency’s operating license.
There is also the possibility that the operator
of an offending radio could be held personally accountable for a mistake. It all depends
on the violation, as well as the employee’s
attitude while working with the inspector.
43
compliance. Morse code is a great option for
agencies that do not use tone paging. While
there have been instances where the Morse
code identification interfered with two-tone
or long-tone paging, today’s radios are programmable based on when the identification
should occur.
If you have “skip,” identifying your call
sign will help you determine where interference is coming from and whether it is local.
You may be causing interference and not be
aware of it. The idea that “if they listen to
our traffic, they will know who we are” is
short-sighted at best. You could be causing an
issue, and the time it takes to find you could
result in loss of life or property. If this occurs,
in addition to the FCC penalty, your agency
(and potentially individual employees) could
be held liable in court.
OPERATIONS
In your day-to-day activities you may
have to either respond as a mutual aid unit or
have another agency respond to your needs.
Communication is vital between agencies,
and most agency “neighbors” have programmed each other’s’ frequencies in their
radios. While this helps ease interagency
communications, don’t forget the paperwork.
Your license is limited to your agency, unless
you have written agreements with other agencies and individuals. These agreements allow
joint agency cooperation and ensure compliance with the FCC. The AFC can provide templates for these letters, which both agencies
need to sign and keep on file.
Permissible communications are covered
in Section 90.205 and prohibited uses are
specified in Section 90.415. General operating requirements are covered under Section
90.403. When in doubt, check the rules.
PSC | apcointl.org
SPECIAL EVENTS
44
Special events and disaster-level incidents
have always been a challenge for communication centers. Agencies that use a field-deployable communications support team (COMU
or AUXCOMM) have had good results. These
teams allow the PSAP to maintain a staffing
level in-house to continue with the day-today emergencies that still arise while these
other activities are in play. The field team
isolates the traffic for the activity on local
tactical or interop tactical channels and relays
any resource request from the incident commanders back to the PSAP, as required. This
maintains local control of the incident and
prioritizes the needs of the incident commander. Any “man down” situations are
heard locally, and the quality of communications improves with local support. A mobile
communications center, portable repeaters or
other support can be deployed as required.
Mutual aid agencies with access to interop
channels can readily access incident traffic
without reprogramming radios on the scene.
Additional frequencies may be required
during extremely large events and incidents.
If a local government makes a state of emergency declaration, local agencies will have
the ability to request a Special Temporary
Authority (STA) from the FCC. The emergency management staff (local, county or
state) normally has an Emergency Support
Function (ESF) 2 component that has access
to the FCC and can assist in obtaining STAs.
An STA includes a limit on use and time
when issued, allowing agencies to use additional frequencies during the event to coordinate activities with other agencies. Your
AFC local advisor can assist in these matters
should there be a delay in ESF 2 support.
YOUR LICENSE
How long has it been since you reviewed
your license? If your system was licensed a
while back and you have simply renewed it
every ten years, there is a possibility that
your radio sites may have incorrect latitudes
and longitudes. Before GPS became commonplace, sites were identified by interpreting topological maps. You may find that
the actual location is substantially different
from the coordinates listed on the license.
The FCC is somewhat understanding about
this, and would like to have the licensee
update the location when they perform any
modification to their license. When frequencies are coordinated, existing systems are
prioritized by location. If your location is
incorrect on your license, you could receive
unexpected interference. Section 90.305 of
the FCC rule addresses this issue.
Is a copy of your license on the wall in
dispatch? Is there a copy at every repeater
and base radio? These are requirements
under Section 90.437. When you apply
for new frequencies or a modification of
your existing frequencies, there is a good
chance that there will be a construction
buildout requirement. You will have one
year from the date of the license issue to
complete your construction notice and
return it to the FCC. The APCO AFC and
several associate coordinating agencies will
send you emails and snail mail notices about
this requirement. Several agencies have lost
part of their license approvals by failing to
complete this simple notification process.
If you are not sure if your license has this
requirement, please call the AFC office and
our friendly staff will be ready to assist you
in this matter.
Here’s another major issue to consider: Is
the contact information on the license current? If not, you can update it on the ULS
for free. The FCC needs to be able to contact
your agency by phone, mail and email. If the
information is incorrect, you could have your
license cancelled. CFR47 part 1, Sub part F,
1.923i lists the application requirement in
order for the FCC to contact the licensee.
OTHER ISSUES
Most agencies keep a copy or time-stamp
recording of their radio logs. They should
be maintained per your local regulations on
public documents, but there also is a requirement under Section 90.443 regarding the contents of the logs. Section 90.215 has further
requirements regarding logs of equipment
maintenance and of visitors to equipment
rooms and repeater sites.
Did you know an FCC inspector could
request all these logs and access to the radio
equipment, as covered in Section 90.441?
Failure to allow the inspector to do his or
her job could cost you your radio license.
APCO AFC
If you need assistance obtaining new
frequencies or modifying your license, AFC
has staff on hand to assist you. Please visit
apcointl.org/afc to find contact information
for your local advisor or the home office. At
the home office, you will find many resources
to assist you in completing the necessary
paperwork for your agency.
•
Michael Scales is the Communications
Administrator and Communications Unit
Leader (COML) for Sandoval County in New
Mexico. He is the AFC Local Advisor for New
Mexico, a member of the APCO AFC Advisory
Committee and was the 2016 AFC Advisor of
the Year. He currently serves as the Chairman
for the New Mexico Department of Homeland
Security and Emergency Management’s
Statewide Interoperable Communications
Working Group (SICWG) and is a New Mexico
Certified Emergency Manager and COML.
CDE EXAM #44541
Of the many sections of the FCC
rules, what section specifically
applies to public safety?
a. 97
b. 11
c. 90
d. 45
2. Name the two types of identification
that properly announce call signs:
a. Driver’s license or registration
b. Voice or Morse
c. Morse or Davis
d. Typewritten or doorbell
3. How often is the call sign required to
be broadcast?
a. Every 10 minutes
b. Every 15 minutes
c. Every 30 minutes
d. At the end of major radio traffic
USING THE CDE ARTICLES
FOR CREDIT TOWARD APCO
RE-CERTIFICATION(S)
Each CDE article is equal to one credit
hour of continuing education
1. Study the CDE article in this issue.
2. Answer the test questions online or
on the exam page from the magazine
article (photocopies are not
required).
3. List the CDE article information
on the Continuing Education
Reporting form included with your
recertification documents, when you
submit for renewal.
4. Every operator in the
communications center needs an FCC
license.
a. True
b. False
5. A copy of the Federal
Communications Commission
License should be available in the
communications center.
a. True
b. False
8. Hearing another licensed agency
on your radio frequency is
considered interference.
a. True
b. False
c. Maybe
d. Could be a switch in the wrong
place on your radio
9. During a “declared emergency,”
the FCC can waive certain rules and
regulation to accommodate the needs
of the emergency.
a. True
b. False
6. Harmful radio interference is:
a. Noisy
b. Music
c. A violation of the rules
d. Hurts your ears
7. FCC rules state that radio frequencies
are a “shared environment.”
a. True
b. False
10. An FCC inspector may request access
to your facility at any time.
a. True
b. False
IF YOU WOULD LIKE TO USE THE CDE ARTICLES FOR ANYTHING OTHER THAN
APCO RE-CERTIFICATIONS AND NEED A PRINTED COPY OF THE CERTIFICATE:
Complete the written exam and submit the following:
1. Answer the exam questions online, and fill out the form below.
Photocopies are acceptable, but please don’t enlarge them.
2. Mail to:
APCO Institute
351 N. Williamson Blvd.
Daytona Beach, FL 32114
3. Payment of $15
Name:
Organization:
Questions? Call us at 1-888-APCO-9-1-1
(1-888-272-6911)
Address:
You can access the CDE exam online! To
receive a complimentary certificate of
completion, you may take the CDE exam
online. Go to http://apco.remote-learner.
net/login/index.php to create your
username and password. Enter “CDE
article” in the search box, and click on
the “2017 Public Safety Communications
Magazine Article Exams,” then click on
“enroll me” and choose “Radio Rules
(44541)” to begin the exam. Upon
successful completion of the quiz,
a certificate of achievement will be
available for download/printing.
Phone:
Email:
Method of Payment (US funds only) ❒ Check ❒ Purchase Order (attach copy)
New Jersey – Original Purchase Order Only
❒ Credit Card (circle one) VISA MASTERCARD DISCOVER AMEX
Card #:
Name on Card:
Cardholder’s Address:
Cardholder’s Email Address:
Expiration Date:
PSC | March/April 2017
1.
45