Is your plant radio equipment up to code?

How does a team communicate around an LNG plant or any other type of industrial facility, whether it be a refinery or oil field? The first thought is radios; however, there are stipulations surrounding the microwave and/or land mobile radios. Some plants along the U.S. Gulf Coast also have marine radios to assist with the docking and unloading of vessels. It is understandable, many may think of radios as walkie talkie voice devices; however, there are other avenues (e.g., microwave communications) to transmit data or for video communications, and supervisory control and data acquisition (SCADA) to monitor or measure pressure or control valves. 

Radios are an intricate part of the system and provide—depending on the communication needs—either voice or data operations. However, this equipment requires an authorization from the U.S. Federal Communications Commission (FCC), with various rules and regulations that must be followed. It is not as simple as calling the vendor and asking for equipment to meet specific specifications for the desired use. 

Purchasing equipment seems easy; however, it is the behind the scenes requirements many are not aware of. Most equipment transmitting on radio frequencies requires an authorization by the FCC. Not only is there the hassle of securing an authorization, but the FCC’s issuance of an authorization also brings along certifications and further filings. 

Whether you are looking to implement a new system or upgrading existing equipment, ask your team these questions:

1. What features are needed for the system to meet the desired needs of the project?
2. What various equipment options are needed (simplex, duplex, push-to-talk and conversions)?
3. Is there a desired frequency band (VHF, 220 MHz, UHF, 900 MHz or 1.4 GHz)?
4. Is the ideal primary with some protection or limited where the operations are either co-primary or secondary operations to other uses of the spectrum?
5. Some of the spectrum bands (see question 3) have limitations such as transmitter antenna height, aboveground level or effective radiated power ERP.
6. Is there available spectrum to meet the needs of the new equipment?

One important piece of information for new systems is that operators do not purchase equipment first. It is not uncommon for a plant to talk with a vendor, purchase radios and then start the coordination process to learn there may be limited spectrum or possibly unavailable. This creates many problems as the budget set aside has been spent on something which will never come to fruition.

If one has an authorization and seeks to upgrade the equipment, change the transmit antenna height, relocate the transmitter location within the plant or increase SCADA or land mobile radios. Changes of this nature may generate a requirement for the current license to be modified before implementing changes. Newer equipment (i.e., post January 1, 2013) offer the same reliable service; however, require a change to the emissions designator or power output. 

Unless a vendor specifies the equipment operates on unlicensed frequencies, the aforementioned is not applicable as use of unlicensed spectrum is co-secondary (shared) and is not protected.   

Most equipment requires an authorization from the FCC and frequency coordination to ensure the channel(s)/frequency(ies) programmed into the equipment meet a separation criterion from other licensed users to eliminate potential interference.

Too often, the licensing and frequency coordination attempt are overlooked, creating costly errors on the back end. It sounds simple; however, the FCC does have a very active enforcement bureau and, if the agency chooses to issue a notice of apparent liability, the information becomes very public and often subject to a hefty fine to the company.  

At this point, ask the equipment vendor what kind of radio frequency/spectrum the equipment will employ. If the vendor identifies spread spectrum, it is unlicensed and subject to interference. Much like cybersecurity and relying on a cloud to collect data, the data, if pertinent, is subject to being hacked.

If the equipment is to employ licensed spectrum, there are frequency coordination requirements (depending on the type of radio service), public notice requirements and notifications of construction requirements, as well as renewal submissions to protect the use of the spectrum. All the submissions to the FCC require certification of the use of the spectrum within the authorization. A common error is updating the equipment, where something miniscule as an emissions designator requires a modification application with the FCC. The same goes with land mobile (typically handheld radio units). If the number of units exceeds what is authorized, operations are in violation.

The FCC does permit a licensee to reduce power, number of units, reduce the transmitter antenna height or area of operation under a minor modification; however, these are changes required within 30 d of the change. If not, the FCC has implemented new certifications permitting licensees at the time of a renewal application. This avenue is designed to avoid implications to the certifications on the FCC application to ensure operations are consistent with the authorization. When making decisions for your employer, it is imperative to know beforehand these regulations to avoid costly errors and embarrassment to the company.

First, ask a lot questions. Then, find an industry professional fluent in the intricacies of the FCC and its requirements and/or limitations regarding your company’s visions and needs. GP

 

Elizabeth Buckley is the Owner of FCC-FAA Licensing, LLC, and Director of Marketing for Alligator Communications Inc. She has 32 yr of experience in licensing equipment from SCADA to MAS to Microwave and Land Mobile radios.