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The FCC’s Part 74 License

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Jim Van Winkle, general manager of Professional Wireless Systems (PWS), wrote this article about navigating the new live event workflow. -ed.

Earlier this year, the Federal Communications Commission (FCC) announced it would soon be taking steps to “recognize the important social, cultural and economic benefits of low-power auxiliary station operations, including wireless microphones, by expanding license eligibility for qualifying users.”

Immediately after, Professional Wireless Systems — a Masque Sound Company that specializes in supplying and supporting wireless systems for live and broadcast events — was on-board to determine what this would mean for frequency coordination experts operating in the broadcast and entertainment industries. PWS also began working to develop solutions to help companies take advantage of the opportunities offered by these new regulations. As the FCC readies to implement these new measures — which are designed to further enhance protection from interference — the industry and PWS find themselves on the cusp of new live workflow innovation.

According to the impending FCC rules, users who routinely work with 50 or more frequencies will be eligible to apply for and be protected under the FCC’s Low Power Broadcast Auxiliary (LPBA), Part 74 License. With this upcoming amendment, the FCC will now recognize that Broadway productions, church services and national tours deserve the same rights to frequency interference safeguards as Television Program Producers and Motion Picture Producers (TPP/MPP) for their content creation. Part 74 will prove imperative for companies like PWS, as our team is continually coordinating frequencies for a wide range of live and broadcast events throughout the year.

Keep in mind that the FCC is not intent on creating a future in which wireless microphone operation is impossible. Quite the opposite: These changes will ensure the future use of wireless mics across the industry in the UHF and VHF bands. Companies that routinely use less than 50 channels of wireless mics do not face exclusion from the spectrum; they face the same new hurdles that licensed users will face, albeit with less powerful tools to help them with their workflow. At this time, there are no requirements for unlicensed users to operate wireless mics in the reserved channel of each TV market, or any of the existing white space within their UHF spectrum.

These new licensing measures were designed to strike an appropriate balance in providing the benefits of a license for entities and events that have a demonstrated need, while ensuring that the spectrum is shared effectively with existing Part 74 operations and remains available for other uses, including TV-Band Devices (TVBDs). It is important to note that parts of the spectrum will be unavailable to users who do not file for a Part 74 License because they will have to contend with TVBDs. It is imperative to reserve spectrum. This presents a different way of working in our industry, hence the new live event workflow.

Licensed vs. Unlicensed

So, what exactly are the benefits for a company, or individual user, to go ahead and get its license versus remaining unlicensed? First and foremost, time is money. Being licensed provides immediate access to the white space database and offers companies the right to reserve the necessary frequencies for their production or event. Unlicensed companies, by contrast, have to undergo an extensive 30-day waiting period once their channel request is submitted. In addition, the community is allowed the right to comment on that request during the 30-day waiting period, raising the potential for an even lengthier wait or to be denied altogether.

Aside from avoiding lengthy waiting periods, there is also the matter of status. Holding a valid Part 74 License elevates a company’s status with the FCC, so that it will be recognized as a Broadcast Auxiliary and Low Power station. Unlicensed users and TVBDs have the lowest priority. The UHF band ranking is as follows, from highest to lowest: Public Safety and Broadcast television, licensed wireless equipment, unlicensed wireless equipment and then TVBDs. Users cannot cause interference to those higher in the ranking, but in turn, have to also be prepared to accept interference from them.

Another benefit? Obtaining a license gives you the ability to raise the bar in terms of being able to use the highest quality wireless equipment available. A licensed company has instant access to the transmission power level that today’s level of productions need. If the company is operating within a licensed range, it helps protect the production from known sources of interference and roaming TVBDs, which is critical in today’s competitive broadcast market.

Not only are licensed companies offered the right to reserve frequencies; they are, perhaps more importantly, given priority access to these frequencies. If granted a Part 74 License, a company will have complete jurisdiction over all unlicensed users within the operating range, including TVBDs. The Part 74 License gives licensees the legal right to tell unlicensed users to turn off their equipment. This is due to the fact that they no longer need to accept unlicensed interference. Multiple licensed users operating in the same area are now required to coordinate amongst themselves in order for everyone to work effectively. In addition to the aforementioned perks, licensed workers are also granted the right by the FCC to transmit up to 250 mW, whereas unlicensed users cannot transmit over 50 mW.

The Licensing Procedure

Keeping in mind the benefits, let’s examine the application process itself. What does actually applying for the Part 74 License entail, and is it challenging? It is definitely a cumbersome process, and it is important to properly navigate the filing of applications.

To more efficiently navigate the application process, the FCC offers a Universal Licensing System (ULS), which allows for the electronic filing of applications processed by the Commission. Yet, despite the FCC’s ULS system, the application process is very time-consuming and can be overwhelming for companies to successfully complete. Filling out the application form is fairly complex, and companies need to ensure that there are no errors within the application in order for it to be processed by the FCC. Even one small typo can lead to a long and lengthy delay.

As specialists in the industry, PWS constantly provides solutions designed to improve its clients’ workflows and streamline processes. Additionally, it assists customers who are interested in receiving a Part 74 license, enabling them to successfully and efficiently complete the application process and meet FCC approval. With the FCC’s announcement looming overhead, ready to impact the industry and introduce this new live event workflow at any given moment, it is important for companies and individual users interested in receiving a license to consider their needs and prepare ahead of time.

For more information on PWS, go to www.professionalwireless.com.

The homepage for the FCC’s Universal Licensing System (ULS) seems outwardly quite simple, yet the application contains numerous odd quirks that make the submission process complex.Getting a Part 74 License: The DIY Method

By George Petersen

The FCC maintains an online Universal Licensing System (ULS) at http://wireless.fcc.gov/uls, which consolidates the database and application filing system for most wireless radio services. Alternatively, forms can be downloaded in PDF form and once completed, mailed to the FCC, although this hard copy approach is not highly recommended.

The first step in the application process is obtaining an FCC Registration Number (FRN). This 10-digit number is assigned to all entities (individual and corporate) and becomes your specific ID used in all of your communications with the FCC, now and in the future, including the application process.

Once you have received an FRN, you can dive into the application. The text of the required Form 601 instructions is 127 pages, and although only a portion of that applies to getting a Part 74 License, there is no “wireless mic users click here” button. Instead you should look for the “Land Mobile — Broadcast Auxiliary Low Power” — the so-designated “LP” section, in Form 601 Schedule H. Unfortunately, audio wireless mic/IEM users are currently lumped in with the “authorization to operate a radio station in the Private Land Mobile and Land Mobile Broadcast Auxiliary Radio Services,” so it’s an odd pairing. Hopefully, the FCC will come up with some sound company-friendly version of the application at some future date.

Meanwhile, in true bureaucratic fashion, few of the Form 601 questions are straightforward and most appear like they were written by the people who designed the IRS forms. So, as with IRS filings, it can be done by yourself, but many wireless users requiring a license go to third-party firms (such as PWS) to handle the paperwork. Either way, you pay the fee (filing is about $150, plus any preparers’ fees, if applicable). Assuming it’s all filled out correctly and with a little luck — and there are no typos or omissions that greatly delay the process — you should have your license about four months later.