Practice ELT Beacon: Licensing

[wuzafuzz]

I'm searching for info regarding licensing requirements for practice beacons on 121.775 MHz.  CAP is properly authorized via NTIA, but I'm trying to find answers for a local SAR team.  NTIA doesn't cover them.

A review of the CFR's (I'm no expert on those) suggests 121.775 MHz is not an authorized frequency for practice beacons.  See pertinent excerpts below:

Subpart Q--STATIONS IN THE RADIODETERMINATION SERVICE
Title 47
§ 87.475   Frequencies.
(d) Frequencies available for ELT test stations. The frequencies available for assignment to ELT test stations are 121.600, 121.650, 121.700, 121.750, 121.800, 121.850, and 121.900 MHz. Licensees must:
(1) Not cause harmful interference to voice communications on these frequencies or any harmonically related frequency.

(2) Coordinate with the appropriate FAA Regional Spectrum Management Office prior to each activation of the transmitter.

No mention of 121.775 MHz.

Title 47: Telecommunication
PART 87—AVIATION SERVICES
Subpart E—Frequencies
§ 87.173   Frequencies.
121.600-121.925 MHz   O, L, Q   MA, FAC, MOU, RLT, GCO, RCO, RPC   25 kHz channel spacing.

Although 25 kHz spacing can land someone on 121.775 MHz, none of the station types mentioned there would cover a SAR team.  Plus I would think the specific authorizations for ELT test stations in § 87.475 would take precedence over § 87.173.

So, CAP is legit on 121.775 MHz, but I don't see how non-federal users are legal there.  Does anyone else know more about this?  Hopefully someone here has been this route in the past.

I want to get good solid info for the local SAR team.

[bflynn]

FCC - Part 87 of CFR 47:

Section 87.145  Acceptability of transmitters for licensing.

   (a) Each transmitter must be certificated for use in these services, except as listed in
paragraph (c) of this section.

...

(c) The equipment listed below is exempted from certification. The operation of
transmitters which have not been certificated must not result in harmful interference due to the
failure of those transmitters to comply with technical standards of this subpart.
   (1) Development or Civil Air Patrol transmitters.
   (2) Flight test station transmitters for limited periods where justified.
   (3) U.S. Government transmitters furnished in the performance of a U.S. Government
contract if the use of certificated equipment would increase the cost of the contract or if the
transmitter will be incorporated in the finished product. However, such equipment must meet the
technical standards contained in this subpart.
   (4) ELTs verified in accordance with  87.147(e).

I'd verify this through another means, but I believe either (c)(1) or (c)(4) is your answer.

[sardak]

^^^You need to update your copy of the FCC regs.

(1) Development of Civil Air Patrol transmitters.

This section refers to flight test stations and Civil Air Patrol is no longer mentioned anywhere in Part 87.

(4) ELTs verified in accordance with  87.147(e).

This section only pertains to 406 MHz ELTs.

Besides, neither of these answered the question. A practice beacon is an "ELT test station" which not the same as an "ELT," and the question was in regards to non-CAP equipment.

Mike

[bflynn]

Yes, I don't exactly keep a copy of the CFRs on my computer, so there's not really anything to update.  I pulled that from the FCC's website.

Maybe 87.475 (c)? 

121.775 is not an authorized frequency, but 121.750 is.

[lordmonar]

Is this a CFR or and FCC issue?

Either way.....if you are using commercial off the shelf practice beacons......the manufacturer would have to make sure that they were okay IAW the applicable laws I would think.

So....unless you were building your own beacon or modifying a 121.5 to work on a 121.775 I don't see any need to license.

[ol'fido]

You could contact LtCol Jim Weiland at jweiland2@juno.com.  He is the IL wing licensing officer, a fifty year member, and has forgot more about CAP comms than most people will ever know.

[wuzafuzz]

Another point of interest, a quick search of the FCC ULS shows no licenses granted for 121.775 MHz.  There are licenses in effect for 121.5, 121.6, and all the other frequencies listed in § 87.475.  121.775?  Zero licenses.  Perhaps there is a license by rule provision I'm not finding.

I'm starting to wonder if they were just happy to get CAP off of 121.6 and didn't worry about the other users out there. 

Licensing would appear to be required for the designated frequencies.  The applicable CFR refers to responsibilities of licensees for ELT test stations.  See below, emphasis mine.

Subpart Q--STATIONS IN THE RADIODETERMINATION SERVICE
Title 47
§ 87.475   Frequencies.
(d) Frequencies available for ELT test stations. The frequencies available for assignment to ELT test stations are 121.600, 121.650, 121.700, 121.750, 121.800, 121.850, and 121.900 MHz. Licensees must:
(1) Not cause harmful interference to voice communications on these frequencies or any harmonically related frequency.

(2) Coordinate with the appropriate FAA Regional Spectrum Management Office prior to each activation of the transmitter.

This is not a CAP issue.  We are covered by NTIA.  I'm asking these questions because a local SAR team asked for advice.  The NTIA rules don't cover them.  They want to be legal and have to work with FCC.

[a2capt]

Speaking of Practice Beacons ..

.. what is the availability of them? The Pointer web site is a half baked mess.

I know there's been bits about converting live ELTs being prohibited due to the 243 function. But if the unit does not broadcast on 243 .. (or for that matter, do any doubling)

[wuzafuzz]

Speaking of Practice Beacons ..

.. what is the availability of them?

You can buy them here:
http://www.skygeek.com/trainer-6000.html

Or here:
http://www.budgetpilot.com/model-6000-trainer-elt-121-775-1/

Google will probably find some other sources as well.

[Spaceman3750]

You can call Pointer as well. The guy that answers the phone is the same guy that engineered and builds them.

[Eclipse]

You can call Pointer as well. The guy that answers the phone is the same guy that engineered and builds them.

Is he the guy that puts the stickers on crooked as well?

[a2capt]

LOL, I thought I was the only one that had a crooked sticker.

[Eclipse]

[SarDragon]

It's interesting that the section of the CFR cited on the big sticker (47 CFR 87.521(e)) appears to have been rescinded.

[vento]

That's exactly how mine looks like! Maybe it was intentionally crooked, by design. 

[Woodsy]

I've seen a few like this.  Maybe a sort of "artist's signature?"

[PHall]

I'm thinking the holes for the switch, antenna and light on the unit don't match the holes on the sticker.
But it works if you angle the sticker.

[sardak]

It's interesting that the section of the CFR cited on the big sticker (47 CFR 87.521(e)) appears to have been rescinded.

That section wasn't rescinded, just renumbered to 47 CFR 87.475(d). Wuzafuzz quotes the wording in a previous post in this thread.

I've got one of the old black Pointer 6000 practice beacons and the label is on straight.

Mike

[Brad]

I did some googling, found this on ALWG's site from back in 1999 from Malcom Kyser, NHQ/DOK:

I apologize for the delay in answering this one. I had promised at least one DC that I would set the record
straight on this and then lost the original message. It took a DC researching the CAP-Comm Digest
Archives to find it for me and I appreciate the help.

Here's what we need to highlight. My comments are imbedded below.

Heath wrote:
>Before anyone else strikes this down or flames me, a correction is in order: voice is not authorized on 121.775.
>This from a failure to closely read the 100-1. Everyone makes a mistake now and then, but not everyone takes
time to admit they have made one even after someone points it out to them.
>Thanks for the correction here.

Heath, you are correct and for those who don't know the FCC, not CAP has the regs that we must follow on this
one. As an educational point from a General Radiotelephone Operator and Pilot From what I have been told, the
FCC only authorized CAP the use of 121.775 as a practice ELT with an Emissions Type of 3K20A3X (ELT
wavering tone) and not 6K00A3E (AM Voice).

[mkyser] This statement is partially correct. It is true that we are only authorized ELT wavering tone
(3K20A3X) on 121.775 but this is per our NTIA frequency assignment, not the FCC or the FAA.
Looking at CFR 47 Part 87
Please note per CFR 47 Sec. 87.171 , 121.775 is authorized by the FCC for FAS--Aviation support and MA--
Aircraft (Air carrier and Private) for properly licensed stations on AM Voice.
and CFR 47 Sec. 87.323

(c) The frequency 122.775 MHz and, secondary to aeronautical multicom stations, the frequency 122.850 MHz
are available for assignment to aviation support stations. These frequencies may be used for communications
between aviation service organizations and aircraft in the airport area. These frequencies must not be used for
air traffic control purposes or to transmit information pertaining to runway, wind or weather conditions.
CAP SAR stations (e.g. AC handhelds and mobiles are only licensed by the FCC on 6K00A3E (A3E - AM Voice
for short) on 122.9 practice/actual SAR and 123.1 actual SAR at 10 watts maximum.

[mkyser] CAP SAR stations are authorized A3E on the two SAR frequencies but, again, this is per NTIA
frequency assignment and not the FCC or FAA.

See
CFR 47 Part 87 Subpart M--Aeronautical Search and Rescue Stations CFR 47 Sec. 87.375 Frequencies.
(a) The frequency 123.100 MHz is available for assignment to aeronautical search and rescue stations for actual
search and rescue missions. Each search and rescue station must be equipped to operate on this frequency.
(b) The frequency 122.900 MHz is available for assignment to aeronautical search and rescue stations for
organized search and rescue training and for practice search and rescue missions.

Note: Said SAR stations must posses an FCC SAR license (Contact you Wing DC to register your SAR station).
[mkyser] This is incorrect. CAP SAR stations do not carry FCC licenses any longer. If you have one of the
old ones, throw it away; it's worthless. CAP no longer carries any FCC licenses with one exception. Our
aircraft fleet manager does have a fleet license for the radios in the aircraft but even that is only required if
you are going to fly outside the country. So, if a foreign official wanted to see your radio license you could
show them that one because they've probably never heard of NTIA and NTIA doesn't produce pretty little
certificates. Other than that, CAP should not be using FCC anything whether it be licenses or callsigns.
We are not governed by the FCC.

I hope this answers the questions and clears things up. I know most of us are accustomed to civil rules and
regulations, but for the purposes of CAP communications management they don't apply to us. It may take
some getting used to but we're NTIA now. Sorry for the confusion.

http://www.alwg.cap.gov/sups_forms/policy/av_band_radio_use.pdf

I checked the current CFR 47 and it says this:

§ 87.319   Scope of service.

Aviation support stations are used for the following types of operations:

(a) Pilot training;

(b) Coordination of soaring activities between gliders, tow aircraft and land stations;

(c) Coordination of activities between free balloons or lighter-than-air aircraft and ground stations;

(d) Coordination between aircraft and aviation service organizations located on an airport concerning the safe and efficient portal-to-portal transit of the aircraft, such as the types of fuel and ground services available; and

(e) Promotion of safety of life and property

CAP qualifies as an aviation support station under item e.

§ 87.323   Frequencies.

(a) 121.500 MHz: Emergency and distress only.

(b) The frequencies 121.950, 123.300 and 123.500 MHz are available for assignment to aviation support stations used for pilot training, coordination of lighter-than-air aircraft operations, or coordination of soaring or free ballooning activities. Applicants for 121.950 MHz must coordinate their proposal with the appropriate FAA Regional Spectrum Management Office. The application must specify the FAA Region notified and the date notified. Applicants for aviation support land stations may request frequency(ies) based upon their eligibility although the Commission reserves the right to specify the frequency of assignment. Aviation support mobile stations will be assigned 123.300 and 123.500 MHz. However, aviation support mobile stations must operate only on a noninterference basis to communications between aircraft and aviation support land stations.

(c) The frequency 122.775 MHz and, secondary to aeronautical multicom stations, the frequency 122.850 MHz are available for assignment to aviation support stations. These frequencies may be used for communications between aviation service organizations and aircraft in the airport area. These frequencies must not be used for air traffic control purposes or to transmit information pertaining to runway, wind or weather conditions.

(d) The frequency 3281.0 kHz is available for assignment to aviation support stations used for coordination of lighter-than-air aircraft operations.

So it comes down to is it a SAR organization with a definite aviation mission, or a general SAR group that a lot of county fire/ems agencies have?

[sardak]

^^^Brad, Thanks for the long post, which contains the answer, but your last statement is irrelevant.

So it comes down to is it a SAR organization with a definite aviation mission, or a general SAR group that a lot of county fire/ems agencies have?

Practice beacons are licensed as "ELT test stations" as posted earlier in the thread. This organization holds such a license from the FCC on 121.6. The Pointer test beacons sold today are on 121.775. This is not an authorized frequency by the FCC for "ELT test stations," as discussed in the thread. This group was curious how CAP licenses its practice beacons on this frequency.

The answer is that CAP doesn't. Here is the key sentence in your post, from Malcom Kyser: "It is true that we are only authorized ELT wavering tone (3K20A3X) on 121.775 but this is per our NTIA frequency assignment, not the FCC or the FAA." per the J/F-12 number issued for the Pointer 6000.

So, this organization will not be able to license a practice beacon on 121.775. It will have to use one of CAP's with CAP involved in the training or exercise. It can however, legally continue to use its 121.6 beacon(s).

Mike