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Grant of 4RF Ltd Request to Permit Certain Telemetry Emissions

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Released: March 19, 2014

Federal Communications Commission

DA 14-368

Before the

Federal Communications Commission

Washington, D.C. 20554

In the Matter of
)
)

4RF LIMITED
)
WT Docket No. 13-188
)
Request for Waiver of Part 90 Rules to Permit Use )
of Certain Emission Designators for Telemetry
)
Radios
)

ORDER

Adopted: March 19, 2014

Released: March 19, 2014

By the Deputy Chief, Mobility Division, Wireless Telecommunications Bureau:
1. Introduction. We have before us a request for a blanket waiver or, in the alternative,
clarification of Section 90.207(i) of the Commission’s Rules1 filed by 4RF Limited (“4RF”) to allow use
of G1D and D1D emission designators2 for telemetry operations.3 For the reasons discussed herein, we
grant 4RF’s request in part. Specifically, we clarify that G1D emissions are permitted for Part 90
telemetry, but we grant the request for a waiver to permit D1D emissions only with respect to 4RF’s
Aprisa SR+ equipment rather than for all telemetry equipment.
2. Background. Section 90.207 sets forth the emissions that may be authorized under Part 90 of
the Commission’s Rules and references the types of operations in which they may be utilized.4 Section
90.207(i) provides, “For telemetry operations, when specifically authorized under this part, only A1D,
A2D, F1D, or F2D will be authorized.”5
3. 4RF, a radio equipment designer/manufacturer, has developed a narrowband high-efficiency
point-to-multipoint telemetry radio system, the Aprisa SR+, that provides a capacity of up to 60 kbps in
12.5 kilohertz channels and 120 kbps in 25 kilohertz channels. 4RF states that Aprisa SR+ equipment
complies with the Part 90 emission mask but, because it utilizes linear modulation methods to address
spectrum efficiency, uses D1D and G1D emissions. 4RF states that permitting Aprisa SR+ use in the


1 47 C.F.R. § 90.207(i).
2 The emission designator is a series of alphanumeric characters that denotes the necessary bandwidth, type of
modulation, nature of the signal modulating the main carrier, and type of information to be transmitted. See 47
C.F.R. §§ 2.201(b), 2.202(b). G1D is a type of phase-modulated digital emission, and D1D is a digital emission that
is amplitude- and angle-modulated.
3 See Request for Waiver of Section 90.207(i) of the Commission’s Rules filed by 4RF Limited on July 18, 2013
(Request). The Wireless Telecommunications Bureau’s Mobility Division sought comment on the Request. See
Wireless Telecommunications Bureau Seeks Comment on Request by 4RF Limited for Waiver of Certain Part 90
Rules to Permit Use of Certain Emission Designators for Telemetry Radios, Public Notice, WT Docket 13-188, 28
FCC Rcd 11022 (WTB MD 2013). One comment and one reply comment, both supporting the Request, were filed.
4 Amendment of the Commission’s Rules governing the Private Land Mobile Radio Service to provide a new Part
90 that reregulates and consolidates Parts 89, 91, and 93, Report and Order, Docket No. 21348, 29 F.C.C. 2d 1612,
1616 ¶ 11 (1978).
5 See 47 C.F.R. § 90.207(i).

Federal Communications Commission

DA 14-368

United States would facilitate critical infrastructure companies’ migration to IP-enabled technologies for
remote monitoring and control applications, and high-speed telemetry applications for which the
equipment is available to users in other countries.6 4RF requests a blanket waiver of Section 90.207(i) to
allow certification, licensing, and use of telemetry radios with G1D and D1D emissions or, in the
alternative, a clarification that the rule permits such emissions.
4. Discussion. G1D. As noted by 4RF,7 Section 2.201(c)(3) of the Commission’s Rules was
amended subsequently to the enactment of Section 90.207(i) to state that whenever frequency modulation
“F” is indicated, phase modulation “G” is also acceptable.8 Consequently, we hereby clarify that Section
90.207(i) should be read to permit G1D (and G2D) emissions for Part 90 telemetry operations.
5. D1D. To obtain a waiver of the Commission's Rules, a petitioner must demonstrate either
that the underlying purpose of the rule(s) would not be served or would be frustrated by application to the
present case and that grant of the waiver would be in the public interest; or that, in view of unique or
unusual factual circumstances of the instant case, application of the rule(s) would be inequitable, unduly
burdensome, or contrary to the public interest, or the applicant has no reasonable alternative.9 We
conclude that grant of a waiver to permit certification, licensing, and use of 4RF’s Aprisa SR+ equipment
is warranted. Allowing licensees to utilize the D1D emissions will promote the efficient use of limited
spectrum resources, and can improve the effectiveness of critical infrastructure operations that protect
life, property, and the environment.10 Based on the record before us, we conclude that grant of 4RF’s
request would not frustrate the underlying purposes of the emission designator rules and would serve the
public interest.11
6. We grant the waiver only with respect to 4RF’s Aprisa SR+ equipment. 4RF has not made a
showing that warrants grant of a blanket waiver of Section 90.207(i) for any telemetry equipment from
any manufacturer used for any purpose. If 4RF believes that a wholesale modification of Section
90.207(i) is in order, it should file an appropriate petition for rulemaking.12
7. Conclusion. We grant 4RF’s request as set forth above. We agree with 4RF that Section
90.207(i) already permits G1D emissions for telemetry operations. With respect to D1D emissions, we
grant a waiver of the rule to permit certification, licensing, and use of 4RF’s Aprisa SR+ equipment. A
copy of this Order shall be submitted with the equipment authorization application. License applications


6 See Request at 1-2.
7 See id. at 5-6.
8 See 47 C.F.R. § 2.201(c)(3) note 2; see also Provision for New System of Emission Designators Described in
Article 4 of the International Telecommunication Union Radio Regulations, Gen. Docket No. 80-739, 49 Fed. Reg.
48694 (1984). As one commenter explains, “Whenever the frequency of RF waves change, so does the phase and
vice versa, so while there are some minor academic differences in the [F1D and G1D] emissions, they are for all
intents and purposes one and the same.” Comments of James E. Whedbee at 1.
9 See 47 C.F.R. § 1.925(b)(3).
10 See Request at 7.
11 See Lojack Corporation, Order, 20 FCC Rcd 20497, 20499 ¶ 7 (WTB PSCID 2005) (granting waiver to permit
D1D emission on frequency on which 47 C.F.R. § 90.20(e)(6) permitted only F1D and F2D, on the grounds that
allowing greater efficiency was in the public interest and would not frustrate the rule's underlying purpose).
12 See, e.g., Rangemaster Golf Enterprises dba ProShot Golf, Order, 10 FCC Rcd 5043, 5044 ¶ 7 (WTB 1995)
(denying a request for blanket waiver of Section 90.207 to permit a non-standard emission in any location, rather
than proceeding by rulemaking), on reconsideration, Memorandum Opinion and Order, DA 95-1259 (WTB rel.
June 8, 1995) (granting a more limited waiver request).
2

Federal Communications Commission

DA 14-368

must reference this Order by the DA number set forth above. No license applications will be granted until
4RF obtains equipment authorization.
8. Accordingly, IT IS ORDERED, pursuant to Section 4(i) of the Communications Act of 1934,
as amended, 47 U.S.C. § 154(i), and Section 1.925 of the Commission’s Rules, 47 C.F.R. § 1.925, that the
waiver request filed by 4RF Limited, on March 14, 2011 IS GRANTED IN PART as set forth herein.
9. This action is taken under delegated authority pursuant to Sections 0.131 and 0.331 of the
Commission’s Rules, 47 C.F.R. §§ 0.131, 0.331.
FEDERAL COMMUNICATIONS COMMISSION
Scot Stone
Deputy Chief, Mobility Division
Wireless Telecommunications Bureau
3

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