American Time & Signal’s (ATS) licenses will eventually get squared away with EWA’s unsolicited assistance. Earlier this year, the FCC ruled that ATS would be permitted to license its product - data based clock mechanisms - at customer premises with an MO6 station class (!) on ATS’s authorization to ease their administrative licensing burden. Fortunately, with EWA’s prodding, the FCC subsequently issued a clarification stating that “[N]othing in the Order suggests that the Division intended to waive any operating rules governing ATS’s customer locations or otherwise modify their status. Consequently, all relevant service rules apply to ATS’s operations to the same extent as if no waiver had been granted ....” With that in mind, EWA took the opportunity to suggest to ATS and the FCC that it would appear that these clock installations are subject to FCC Rule Section 90.235 and, therefore like any other Secondary Fixed Signaling operation, must employ system features to prevent inadvertent, continuous transmissions from unattended transmitters that would risk causing interference to co-channel incumbent operations. In other words, ATS’s customer clock installations are authorized on a secondary, non-interference basis to primary co-channel voice operations.
Subsequently, a review of ATS’s license revealed another critical oversight. EWA noted that virtually every MO6 station listed on WQFW336 shows an “11K2F3E” emission designator which informs anyone paying attention that the systems are utilizing analog voice equipment. Recognizing that licensing information is inaccurate, EWA requested that the FCC advise ATS to amend its license to reflect the proper data emission designator for its equipment. We are unsure whether that would be 11K2F1D, 11K2F2D, or a data emission designator that is unique to ATS’s equipment FCC type-acceptance, but it certainly is not 11K2F3E. EWA Comments