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Comment Sought on 4RF Ltd. Request for Waiver of Part 90 Emissions

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Released: July 29, 2013


Federal Communications Commission
445 12th St., S.W.

News Media Information 202 / 418-0500


Washington, D.C. 20554

TTY: 1-888-835-5322

DA 13-1659
Released: July 29, 2013




WT Docket No. 13-188

Comment Date: August 28, 2013

Reply Comment Date: September 12, 2013

By this Public Notice, comment is sought on a request for waiver filed by 4RF Limited (4RF)
concerning use of additional emission designators for Supervisory Control and Data Acquisition
(SCADA) telemetry radios.1 Section 90.207(i) of the Commission's Rules specifies emission designators
A1D, A2D, F1D, or F2D for telemetry operations.2 4RF seeks a waiver of Section 90.207(i) to allow
deployment of telemetry radios using emission designators G1D and D1D. In the alternative, 4RF
requests clarification that these emissions already are permitted for Part 90 telemetry.
4RF Limited designs and manufactures radio equipment for infrastructure application for radio
systems. It has developed narrowband high-efficiency point-to-multipoint SCADA telemetry radio
equipment that complies with the Part 90 emission mask but uses D1D and G1D emissions. 4RF notes
that Section 90.207(i) limits licensees' ability to use the radio system for high-speed telemetry
applications for which it was designed and that are available to users of the system outside the United
States. It states that use of this equipment would facilitate critical infrastructure companies' migration to
IP-enabled technologies for remote monitoring and control applications. As a result, 4RF requests a
blanket waiver of Section 90.207(i) to allow certification, licensing, and use of telemetry radios with G1D
and D1D digital emissions.

Procedural Matters

Interested parties may file comments and reply comments in response to the waiver request on or
before the dates listed on the first page of this Public Notice. All pleadings must reference WT Docket

1 See Letter dated July 18, 2013 from Greg Kunkle, counsel for 4RF Limited, to Ruth Milkman, Chief, Wireless
Telecommunications Bureau.
2 See 47 C.F.R. 90.207(i). 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). D1D is a digital emission that is amplitude- and angle-
modulated, and G1D is a type of phase-modulated digital emission.

No. 13-188. Parties may file comments using (1) the Commission's Electronic Comment Filing System
(ECFS), (2) the Federal Government's eRulemaking Portal, or (3) by filing paper copies.3

Electronic Filers: File comments electronically using the Internet by accessing the ECFS: or the Federal eRulemaking Portal:
Filers should follow the instructions provided on the website for submitting comments.

In completing the transmittal screen, filers should include their full name, U.S. Postal Service
mailing address, and the applicable docket or rulemaking number. Parties may also submit an
electronic comment by Internet e-mail. To get filing instructions, filers should send an e-mail to, and include the following words in the body of the message, "get form." A sample
form and directions will be sent in response.

Paper Filers: Parties who choose to file by paper must file an original and two copies of each
Send filings by hand or messenger delivery, by commercial overnight courier, or by first-class or
overnight U.S. Postal Service mail (although we continue to experience delays in receiving U.S. Postal
Service mail). Address filings to the Commission's Secretary, Office of the Secretary, Federal
Communications Commission.

Deliver hand-delivered or messenger-delivered paper filings to FCC Headquarters at 445
12th St., SW, Room TW-A325, Washington, DC 20554 between 8:00 AM and 7:00 PM.
Use rubber bands or fasteners to hold deliveries together. Dispose of all envelopes before
entering the building.

Send commercial overnight mail (other than U.S. Postal Service Express Mail and
Priority Mail) to 9300 East Hampton Drive, Capitol Heights, MD 20743.

Send U.S. Postal Service first-class, Express, and Priority mail to 445 12th Street, SW,
Washington DC 20554.
Parties are requested to send one copy of their comments and reply comments to Best Copy and
Printing, Inc., Portals II, 445 12th Street, S.W., Room CY-B402, Washington, D.C. 20554, (800) 378-
3160, e-mail
The request, and comments and reply comments filed in response to this Public Notice are
available for viewing via the Commission's Electronic Comment Filing System (ECFS),, by entering the docket number, WT 13-188. The documents also will be
available for public inspection and copying during business hours in the FCC Reference Information
Center, Portals II, 445 12th Street S.W., Room CY-A257, Washington, D.C. 20554. They may also be
purchased from Best Copy and Printing, Inc., telephone (800) 378-3160, facsimile (202) 488-5563, TTY
(202) 488-5562, e-mail
Alternate formats of this Public Notice (computer diskette, large print, audio recording, and
Braille) are available to persons with disabilities by contacting the Consumer & Governmental Affairs
Bureau at (202) 418-0530 (voice), (202) 418-0432 (TTY), or send an e-mail to
This proceeding has been designated as a "permit-but-disclose" proceeding in accordance with
the Commission's ex parte rules.4 Persons making ex parte presentations must file a copy of any written

3 See Electronic Filing of Documents in Rulemaking Proceedings, Report and Order, GC Docket No. 97-
113, 13 FCC Rcd 11322 (1998).

presentation or a memorandum summarizing any oral presentation within two business days after the
presentation (unless a different deadline applicable to the Sunshine period applies). Persons making oral
ex parte presentations are reminded that memoranda summarizing the presentation must (1) list all
persons attending or otherwise participating in the meeting at which the ex parte presentation was made,
and (2) summarize all data presented and arguments made during the presentation. If the presentation
consisted in whole or in part of the presentation of data or arguments already reflected in the presenter's
written comments, memoranda or other filings in the proceeding, the presenter may provide citations to
such data or arguments in his or her prior comments, memoranda, or other filings (specifying the relevant
page and/or paragraph numbers where such data or arguments can be found) in lieu of summarizing them
in the memorandum. Documents shown or given to Commission staff during ex parte meetings are
deemed to be written ex parte presentations and must be filed consistent with rule 1.1206(b). In
proceedings governed by rule 1.49(f) or for which the Commission has made available a method of
electronic filing, written ex parte presentations and memoranda summarizing oral ex parte presentations,
and all attachments thereto, must be filed through the electronic comment filing system available for that
proceeding, and must be filed in their native format (e.g., .doc, .xml, .ppt, searchable .pdf). Participants in
this proceeding should familiarize themselves with the Commission's ex parte rules.
For further information, contact Rodney Conway, Mobility Division, Wireless
Telecommunications Bureau at (202) 418-2904 or via email at
By the Deputy Chief, Mobility Division, Wireless Telecommunications Bureau.

4 See 47 C.F.R. 1.1200(a), 1.1206.

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