CSAA Signals
Vol. 7 , No. 16  — September 7, 2001
 

Table of Contents

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FCC Conducts a Land Mobile License Audit
Lack of Response by Licensees May Result on License Cancellation and/or Fines

Since August 15, the Federal Communications Commission (FCC) has been sending out a letter to licensees of land mobile radio systems operating on frequencies below 512 MHz asking whether their systems are constructed and operational. 

This audit of land mobile facilities is designed to clear out from the FCC's database licenses for stations that were not constructed or that have been discontinued by the licensee without notification to the FCC. In general, land mobile stations have one year from the date the license is issued to complete construction. Stations that are not operated for one year or more are considered to be permanently discontinued. The FCC indicated that it may take six months to complete sending out the audit letters. The FCC will attempt to include all of the licensee's stations in a single letter, but because of discrepancies in how a licensee's name is listed on various licenses, some licensees may received multiple letters covering different stations. It is important that licensees respond to these letters promptly since failure to do so may result in cancellation of licenses or fines.

The audit letters require licensees to advise the FCC whether the stations listed in the letter are in operation. If not, the licensee has the option of requesting cancellation of the license or including an attachment to the response indicating why the license should not be cancelled. For example, if operation has been temporarily discontinued because of loss of a tower site and the licensee intends to place the station back in service within one year of discontinuance, this would justify keeping the license in force.

However, we must urge that alarm companies use diligence and caution in addressing this audit process.  In particular, we note the following potential pitfalls:

1.     CHECK ULS EVEN IF YOU DO NOT GET A LETTER:  If the FCC sent you an audit letter, you are expected to respond even if you did not receive the letter.  Licensees may check the Commission's web page at http://www.fcc.gov/wtb/plmrs/audit.html to see if the Commission has sent them an audit letter and to determine what call signs those letters include. 

This site also includes a letter that licensees can download, complete and return to the FCC if they did not receive the audit letter that the FCC sent to them. In essence, the FCC expects all licensees to check the Commission’s ULS system to see if a letter was sent to them.  Failure to respond can result in loss of your licenses, even if you are operating!  Given all of the consolidation in the alarm industry, there is a good chance that the contact address on many licenses is now out of date.

2.     YOU MAY GET FINED IF YOU ADMIT RULE VIOLATIONS:  While the FCC invites explanations as to why a license should not be cancelled, licensees must be very careful in providing such explanations.  If the licensee admits a violation in its response, the FCC can and likely will issue a monetary fine for any rule violations.  

  • For instance, a licensee may respond that the license should not be cancelled, even though the station was not built during the one-year construction period, because the station has since been built and is now operating.  This is an admission of unauthorized operation, since the license automatically cancelled at the end of the one-year construction period.  

  • Likewise, a response that the station was timely built, but at a different location is likely to draw a fine and/or license cancellation, because private radio stations cannot be relocated without prior FCC approval.  

Unfortunately, prior to the FCC’s recent spate of fines against private radio licensees, enforcement of these requirements was lax. Consequently, many licensees, radio vendors and installation contractors may have taken a loose approach to compliance, making modifications to stations without filing an FCC application to change the license.  

Licensees should be aware of the consequences of responding to the audit letter, and consult counsel to ensure that they properly report such matters while minimizing any exposure.

 3.     MODIFICATION APPLICATIONS MAY BE REQUIRED:  To the extent that changes in the station’s information are required, it is not enough to simply explain the changes in response to the FCC’s audit letter.  Instead, for most changes (especially technical modifications), it is also necessary to file an application or administrative update in order to change the license.  Any explanation provided in the audit response letter will merely be considered by the FCC in the context of deciding whether to cancel the license.

We strongly urge licensees to consult with counsel if they find that they are operating a station that may be in violation of an FCC rule, OR that requires modifications to the technical parameters shown on the license.

FCC Requires Use of New Federal Registration Number by December 3

On August 31, 2001, the FCC released a Report and Order adopting the use of a mandatory FCC Registration Number (FRN) for persons and entities doing business with the FCC.

This number will be used in place of the 9-digit Taxpayer Identification Number (TIN) for doing business with the FCC. Use of the FRN will become mandatory on December 3, 2001. The FCC said that use of the FRN will help the Commission to more effectively collect regulatory and application fees; track enforcement of fines and forfeitures; monitor and collect penalties; and manage the grant of waivers and exemptions.

In many cases, the FCC has already assigned an FRN to licensees. You may check on whether an FRN has been assigned to your company by accessing the CORES web site at https://svartifoss2.fcc.gov/cores/CoresHome.html . You may search for FRNs by providing your TIN or company name. If an FRN has not been assigned, you may use the same web site to register and obtain an FRN.

We suggest that all central operators verify whether an FRN has been assigned to them. If not, they should immediately register with the FCC and obtain an FRN since they will not be able to file applications with the FCC after December 3 without an FRN.

Dice Corporation Acquires Interstar's Video Monitoring Technology

On August 21, 2,001 DICE Corporation announced the acquisition of InterSTAR's Video Monitoring Technology, which is the foundation for DICE Corporation's new product, Video Stream. InterSTAR has implemented the video monitoring technology successfully at over 2000 locations. 

Video Stream is the only video monitoring software in the world that provides two way video and audio, allowing both the central station operator and the location being monitored to view and communicate with one another simultaneously.  InterStar sold the video monitoring technology to DICE Corporation for an undisclosed price, giving DICE complete rights to manufacture and sell it.

Video Stream can also be used over the Internet through the secure DICE*eLink environment, allowing video to be monitored from virtually anywhere.