As volunteer rescue professionals, we provide an essential public service and mission readiness that requires a great deal of training and personal preparations. Underpinning this capability is communications. One of the most important, yet often overlooked, aspects of communications is maintaining Federal Communications Commission (FCC) compliance to use the Mountain Rescue Association licensed frequency, 155.160 MHz, for operations. A majority of MRA teams have never requested or received a Frequency Authorization Letter (FAL) from the MRA and may be out of federal compliance. Historically, many MRA teams operated without formal authorization letters simply because the system was informal. Frequencies were shared in good faith, and there were few enforcement issues. As public-safety communications have become more regulated, and as the FCC and state agencies have tightened oversight, the need for proper documentation has grown.
Although it may seem like a minor administrative task, the authorization letter has major implications for legal compliance, operational reliability, and interagency coordination. Under federal law, radio frequencies for state and local government agencies and the private sector in the United States are regulated by the FCC. Federal agencies to include all components of the Department of Defense are regulated by the National Telecommunications and Information Administration (NTIA) and do not fall under the jurisdiction of the FCC. Typically, individual state or county agencies hold the licenses that cover operational use, for example, a fire department’s channel. When a team operates directly under one of those agencies during a mission or joint training, they’re covered by that agency’s authorization, if they have a Frequency Authorization Letter in place with the FCC licensed agency.
However, if a team uses the frequency independently and without a FAL from the license holder, they are technically operating without a valid license. The letter formally documents that the team has been granted permission to use specific frequencies under the licensee’s authority. If your team is using a frequency authorized for use (licensed to) by the MRA without an authorization letter, you may or may not be covered under an authorized (licensed) agency, depending on the specifics of the team, mission, and state/federal involvement. Each licensed frequency must be used only by those who are specifically authorized to do so. According to 47 CFR § 1.903, stations in the Wireless Radio Services “must be used and operated only in accordance with a valid authorization granted by the Commission.”
While the FCC generally acts only if there is a complaint or a report of interference from another licensed user, the risk remains. At the national level, the MRA acts as a license holder and provides authorization to its affiliated teams to use frequencies for which it is licensed. This means that any MRA team transmitting on a licensed frequency without documentation or formal permission is out of compliance. There is a potential risk of action from the FCC if a formal complaint is filed. Although enforcement is unlikely under normal circumstances and given the MRA’s role in public safety, the technical risk remains real. Teams can hold multiple authorizations for spectrum access. Frequency permissions can also be granted by local, state and at times federal agencies but this typically applies only when teams are operating under that agency’s direction, such as during coordinated mutual-aid missions. Teams operating independently, or through direct arrangements with other organizations, are not covered by those permissions and must have their own authorization in place.
The MRA FAL confirms that each team operates on authorized frequencies, with equipment that is authorized to operate under Part 90, prevents interference with partner agencies, and demonstrates to regulators and funders that the MRA upholds the highest standards of compliance. Most importantly, it protects our ability to communicate. Multiple authorizations can be managed by obtaining an FCC Registration Number (FRN). The FRN allows the FCC to recognize a team’s compliance and link it to the appropriate authorizations at no cost while providing lasting administrative clarity. Obtaining an FRN is free and easy.
Teams should understand that certain assumptions do not provide legal authorization. You are not covered if:
- You rely directly on NIFOG VSAR16, which does not give blanket authorization for SAR teams using 155.160 MHz.
- You rely on state guidelines (e.g., CAL I-FOG, CAL SARMARS) that do not convey authority, some systems require their own letter license.
- There is no licensed authority in your area granting permission.
- You operate within a state but without federal involvement (FEMA, CISA, DHS, etc.).
- You operate out of state without federal involvement.
- Complex federal authorization areas (including FCC federal or Tribal/Indian Lands).
Teams who think they are automatically covered should carefully review references such as NIFOG, state-level guides, and/or tribal law. For example, the NIFOG and the CALI-FOG do not convey authority to operate, and systems like SARMARS or VSAR16 may require separate authorization letters. Relying solely on these references does not guarantee legal coverage on a frequency authorized for use by the MRA. If in doubt, every team is encouraged to contact the MRA and fill out a FAL.
If an MRA team operates without authorization and a complaint is filed, the FCC could impose penalties such as fines, cease-and-desist orders, and, worst case, equipment seizure or license restrictions to both the MRA or the member team. Beyond these consequences, non-compliance can erode trust and interoperability with partner agencies. For example, law enforcement or emergency management partners might be hesitant to include non-authorized teams in coordinated communications if their compliance status is unclear. In other words, the FAL also protects both the team and the mission of the MRA.
Even if your team operates under state or federal frameworks, it is crucial to verify coverage. Guides such as NIFOG do not grant nationwide authorization, and state-level systems may still require a formal FAL from the MRA or the appropriate licensing authority.
The MRA strongly encourages all member teams to complete and return a Frequency Authorization Letter at their earliest convenience. Templates and instructions will be provided to the MRA regions. If you have any questions, please contact your MRA team representative or Region Chair. Once received, the MRA will maintain a central record and manage renewals or updates to ensure every team remains current and compliant. Teams operating under state or federal agencies should verify coverage and provide documentation. If you work with an independent advance using MRA frequencies please feel free to notify them of potentially needed action.
This article was written by Mark McClernan, Noam Shendar, E. Wolff, J. Lehman, Ryan Jenkins, and Devin Lozano.
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