4 RD1000™ Operation Manual
that these devices often are not operated by the users listed in
the regulations but are operated under contract by personnel
specifically trained in the operation of these devices. We do not
believe that the recent adoption of the UWB rules should disrupt
the critical safety services that can be performed effectively only
through the use of GPRs and wall imaging systems. We viewed
these operating restrictions in the broadest of terms. For example,
we believe that the limitation on the use of GPRs and wall imaging
systems by construction companies encompasses the inspection
of buildings, roadways, bridges and runways even if the inspection
finds no damage to the structure and construction does not actually
result from the inspection; the intended purpose of the operation
of the UWB device is to determine if construction is required.
We also believe that the GPRs and wall imaging systems may be
operated for one of the purposes described in the regulations but
need not be operated directly by one of the described parties.
For example, a GPR may be operated by a private company
investigating forensic evidence for a local police department.
FCC Permitted Mode of Usage
The GPR antenna must be kept on the surface to be in compliance
with FCC regulations. Use of the antenna is not permitted if it is
lifted off the surface. Use as a through-the-wall imaging device is
prohibited.
GPR Use Coordination
FCC regulation 15.55(c) (updated in February 007) requires
users of GPR equipment to coordinate the use of their GPR
equipment as described below:
(a) UWB imaging systems require coordination through the FCC
before the equipment may be used. The operator shall comply
with any constraints on equipment usage resulting from this
coordination.
(b) The users of UWB imaging devices shall supply operational
areas to the FCC Office of Engineering and Technology, which shall
coordinate this information with the Federal Government through
the National Telecommunications and Information Administration.
The information provided by the UWB operator shall include the
