FCC Licensing for Part 90 Land Mobile Radio (LMR) Systems

Recommended Reading: FCC for Beginners – Plain-English Overview

FCC’s Role in LMR Spectrum Management

The Federal Communications Commission (FCC) regulates and licenses radio spectrum in the United States, including Land Mobile Radio (LMR) services. Under Title III of the Communications Act, the FCC assigns radio frequencies and issues station licenses (ecfr.gov). Rules in 47 CFR Part 90 (Private Land Mobile Radio Services) govern how systems may be licensed in the Public Safety and Industrial/Business pools (ecfr.gov). The FCC allocates bands, sets technical limits (power, emissions, permissible use) and enforces compliance to prevent interference.

Frequency Coordinators and Their Authority (e.g., EWA)

Most Part 90 applications must be reviewed by an FCC-certified frequency coordinator (law.cornell.edu). Coordinators analyse licensing data and recommend the best channel for a given site and technical profile. The Enterprise Wireless Alliance (EWA) handles VHF, UHF, T-Band, 800 MHz and 900 MHz industrial/business channels (enterprisewireless.org), while APCO International serves many public-safety pools. A coordination letter is mandatory before the FCC will grant a new licence or major modification.

Application Process and Requirements

Preparing the Application:

• Form 601 & Coordination Letter — filed through the FCC Universal Licensing System (ULS).
• Exact Transmitter Location — latitude/longitude for each base or repeater site.
• Antenna Height — height above ground level or above average terrain (law.cornell.edu).
• Power Output — ERP or transmitter power within Part 90 limits (law.cornell.edu).
• Frequencies & Emissions — channel pair and emission designator certified by the coordinator.
• Area of Operation — radius or defined geographic footprint for mobiles.
• Number of Units — total mobiles/portables and any itinerant usage.

Fees: FCC filing fee (≈ $205) plus coordinator charges (forums.radioreference.com). Routine applications are often granted within a few days to a few weeks once coordination is complete.

Licensing Timeline and Conditional Operation

Normal Timeline: Applications appear on FCC public notice; most uncontested filings are granted in 1–2 weeks.

Conditional Authority (10-Day Rule): Under 47 CFR § 90.159 you may begin operating 10 business days after submitting a fully coordinated application and may continue up to 180 days if:

• The site is outside Canadian or Mexican border coordination zones.
• No rule waivers are requested.
• The antenna complies with FAA and environmental rules (law.cornell.edu).

If the FCC dismisses or denies the filing, conditional authority ends immediately. For urgent deployments, an STA (Special Temporary Authority) can be requested (hitechwireless.com).

License Duration and Renewal

Part 90 licences are valid for 10 years (law.cornell.edu). Renewal may be filed up to 90 days prior to expiration (apcointl.org). A 30-day grace period allows late filing, but transmit authority lapses until renewal is issued. New site-based systems must be constructed and on-air within 12 months, or the licence cancels automatically (hitechwireless.com).

Legal Obligations and Penalties for Unlicensed Operation

FCC rule § 90.403(a) requires a valid licence for any Part 90 transmission (law.cornell.edu). Fines start at $10 000 per day of unlicensed operation and can include equipment seizure (docs.fcc.gov).

Frequency Sharing and Geographic Considerations

Part 90 channels are shared spectrum. Coordinators apply distance-separation or contour-overlap rules (docs.fcc.gov). Most Industrial/Business Pool frequencies are shared, and itinerant channels carry no interference protection (govinfo.gov). Terrain, urban density, and international borders (north of Line A) further influence channel reuse.

Preventing Interference: PSI’s On-the-Ground Spectrum Analysis

Database coordination is not fool-proof; Part 90 licensees must monitor channels to avoid harmful interference (law.cornell.edu). PSI performs field surveys and spectrum scans before ordering frequencies. These scans detect hidden interferers—e.g., a 100-watt transmitter one mile away on a “clear” channel—allowing PSI to choose alternate channels or adjust system parameters and ensure reliable communications from day one.

Sources

• 47 CFR Part 90 – Private Land Mobile Radio Services (ecfr.gov)
• § 90.175, § 90.159, § 90.403 – Frequency coordination, conditional licensing, operating rules (law.cornell.edu)
• Enterprise Wireless Alliance – Frequency Coordination (enterprisewireless.org)
• APCO International – Renewal Guidance (apcointl.org)
• FCC Enforcement Bureau – Unlicensed Operation Fine (docs.fcc.gov)
• HiTech Wireless – Licensing Steps & Construction Deadlines (hitechwireless.com)
• RadioReference Forum – Part 90 Fee Info (forums.radioreference.com)