RECCO asks FCC for waiver of Location and Monitoring Service rules.
The Location and Monitoring Service (LMS), a somewhat obscure service nestled in Subpart M to Part 90 of the FCC’s rules, is back in the news. This could be of considerable interest to you if you’re a skier who prefers avalanche-prone slopes.
LMS was originally envisioned as a service enabling fleet operators to pinpoint the locations of their vehicles around a city. That was 20 years ago. Since then, GPS has provided a more accurate, more cost effective alternative, leaving LMS without much of a market. In 2006, a company called Progeny LMS, LLC proposed that the FCC broaden the range of services possible under an LMS license. The Commission eventually abandoned that proposal, but in the meantime Progeny managed to obtain – over considerable objections from unlicensed users of the 902-928 MHz band – a waiver permitting it to use its LMS licenses for the location of items other than vehicles, like cell phones.
Now the FCC is considering another request for waiver of the LMS rules, and it has invited public comment.
A company called RECCO AB wants to be able to use LMS spectrum in the 902-904 MHz band to locate skiers, snowboarders and other avalanche victims. The RECCO system consists of two parts: a hand-held detector that transmits a signal, and a passive reflector, integrated into apparel or other gear (helmets, boots, etc.), that reflects the signal, allowing searchers to home in on folks buried in the snow.
The LMS service was created to monitor the location of vehicles, not luckless winter sporting enthusiasts, so a waiver to deploy the avalanche rescue system is necessary. RECCO is also seeking waiver of the LMS antenna height limit, since the RECCO system may be operated from a helicopter considerably higher than the 15-meter antenna height limit in the rules. RECCO will also need a waiver of the site-by-site licensing requirement.
According to RECCO, the odds are low that its system would interfere with other radio systems: RECCO’s system uses a short duty cycle (a 20 milliseconds transmission followed by 80 milliseconds of silence) and directional antenna with a beamwidth of approximately 50 degrees. Plus, the system would ordinarily be used in or near avalanche sites where no other co-channel radio systems are likely to be operating.
In the hotly-contested Progeny proceeding, unlicensed interests had a right to have their systems field tested against Progeny’s gear to ascertain that that gear would not cause “unacceptable levels of interference” to unlicensed devices. But Progeny’s system was a “multilateration” LMS (or M-LMS) system that used multiple transmitters to locate targets through triangulation. Part 90 does not mandate such field testing when it comes to non-multilateration systems such as RECCO’s. Nevertheless, other LMS licensees operating in the 902-904 MHz band may have something to say.
Comments are due November 13, 2014; and reply comments are due November 28 (because nothing says “Happy Thanksgiving” like turkey, football, and putting the finishing touches on a set of reply comments). They can be filed electronically through the FCC’s online filing system. Refer to Proceeding No. 14-176.
We suspect the Commission is looking to move quickly on this, given the near-lightning speed (just over a month) at which it placed the waiver on public notice.