The ARRL Letter Vol. 12, No. 5 March 10, 1993 FCC Plan Would Create New Band The FCC has proposed a new shared band for amateurs at 219- 220 MHz. In response to a request by the ARRL, the FCC made the proposal in ET Docket 93-40, to establish a secondary allocation for the amateur service to be used for amateur auxiliary station (point-to-point) packet backbone networks and other amateur point-to-point fixed communications. The Commission also proposed operating limits and other measures to ensure that such amateur operations do not cause interference to primary operations in and adjacent to the 219-220 MHz band. The FCC noted that these Amateur Radio systems can be used in times of emergency -- when other communications facilities are out of service or overloaded -- to efficiently carry a large volume of messages, and that amateurs plan to use wideband backbone packet radio networks to provide intercity links of their local packet radio systems. In its petition, the ARRL had asked the Commission to authorize access by amateurs on a secondary basis to 216 to 220 MHz for amateur wideband packet networks and other point-to-point fixed communications services. The League argued that crowded conditions on the existing bands, particularly in urban areas, prevented completion of a nationwide backbone packet network following the loss of the 220-222 MHz band. The Commission proposes to authorize amateur wideband packet point-to-point communications and other point-to-point fixed communications on a secondary basis in the new band. The Commission said it believes this will foster technological experimentation and innovation, particularly with higher data rates, and facilitate the construction of a nationwide packet data backbone network. The Commission says it expects that this action will relieve congestion in the 222-225 MHz band in certain geographic areas. The Commission also said amateurs' ability to perform interference analysis, the directional nature of the proposed services, and the secondary status of this proposed allocation, should adequately protect all primary and existing secondary operations in and adjacent to the 219-220 MHz band. The comment deadline on the FCC proposal will be announced later, when the complete text of the notice of proposed rule making is available. League Supports 220-MHz Weak Signal Subband The League has filed comments on an FCC proposal to make changes in the 222-MHz band and to expand certain Novice Class operating privileges, in FCC PR Docket 92-289. Following the reallocation of 220-222 MHz to the land mobile services in 1991, the League proposed to the Commission establishing a small weak signal subband to restore a small portion of a formerly 500 kHz-wide subband for such operation which was lost in the reallocation. The League made its proposal in a Petition for Rule Making, RM-7869, filed November 12, 1991. Commenters on the Petition were of two minds; weak signal users supported the proposal as a necessary means of protecting their non-repeater, non-auxiliary operations from interference, saying that volunteer band planning and repeater were insufficient to protect against repeater operation. Weak signal operators said repeater operation on a co- channel or adjacent channel basis can and does cause interference to their SSB and CW operation at 222 MHz using specialized techniques. In one case in southern California an uncoordinated repeater on 222.050 MHz was said to be completely incompatible with weak signal operators, in fact disrupting their operations. Some repeater users, the League said in its comments, "view the matter as a challenge to the basic concept of voluntary local and regional band planning, and to the coordination process. They claim that certain repeater stations, principally in southern California, will be displaced by the creation of a weak signal subband 150 kHz wide." Problems already apparent The League said that certain commenters from Northern California have claimed in comments already filed that a digital link which presently apparently operates in an auxiliary mode at 222.140 MHz, and which connects packet stations in Nevada and Northern California, "will be displaced and cannot, because of its path length and dependence on knife-edge refraction over mountainous terrain, be replaced in a higher frequency band." "The League ... remains persuaded that the issue reflects not any one group of amateurs refusing to accommodate another, but rather of the difficulty of reaccommodating amateur users displaced from the 220-222 MHz segment. "There appears no dispute that the weak signal operators are entitled to pursue a variety of weak signal operations in some segment of the 222 MHz band, nor is there any disagreement that such operations are incompatable with repeater and auxiliary link operations on the same frequencies." The League said it is necessary to create a weak-signal subband by FCC rule rather than to rely on voluntary repeater coordination because of the need for uniformity of the segment nationwide, and because there is no enforcement authority for the band planning decisions of the volunteer amateur coordinating body with respect to interference to incompatible modes. "In fact," the League said, "there is *an incentive* for uncoordinated repeater operators to locate in a voluntarily established weak signal band, because such would assure that the uncoordinated repeater would not interfere with coordinated repeaters. Benefits to FCC cited The League also noted that current FCC staffing limitations allow for little assistance from the Commission in resolving amateur-to-amateur interference situations, and stressed that the League's support for a weak-signal subband should not be interpreted as a lack of support for local band planning efforts or local frequency coordination. "Quite the contrary," the League said. "Generally, deference should be accorded regional variations from the League's national band plans, and such should be left to the amateur community to develop without regulatory intervention. National voluntary band planning, to the extent dictated by the environment, local or regional variations thereon, are critical for efficient spectrum utilization. "The process works well generally," the League said. "Repeater coordinators have done a creditable job, faced with a very bad situation, in reaccommodating displaced repeater and auxiliary stations from the 220-222 MHz segment. The League does not minimize the difficulties faced in Southern California and elsewhere in dealing with the reaccommodation of displaced repeaters at 222-225 MHz. The alternative, however, is clearly to disenfranchise those who would use operating modes other than repeaters in any segment of the 222-225 MHz band, as the result of exposure to interference. "Such is neither fair, nor a reasonable accommodation for those who use other than FM repeaters in the residual band," the League said. Novice enhancement supported The League in its comments also supported access to the entire 222-225 MHz band for Novices, as the League proposed in its 1991 Petition for Rule Making, RM-7868. In that petition the League noted that the current Novice Class privileges in the 222-225 MHz band were created in 1987 in Docket 86-161, the so-called "Novice Enhancement" proceeding. While the League at that time sought full access to the (then) 220-225 MHz band, with the only proposed limitations a 25 watt power limit and not to permit Novices to be the control operators of repeaters. The FCC's Report and Order, however, limited Novices to 222.10 - 223.91 MHz, which at the time corresponded to the frequencies specified in the League's band plan for repeater input frequencies, ostensibly to focus attention on FM repeater operation by Novices in the 220-225 MHz band. The League said that it continues to support expanding Novice frequency privileges to include the entire 1.25 meter band, since Novices already are permitted to use SSB and CW on portions of the HF bands, and there is no reason why they should not be permitted to utilize those same modes in the entirety of the 222-225 MHz band where other licensees operate using those modes. Finally, the League reiterated its opposition to the FCC's final proposal, to permit Novices to act as licensees and control operators of repeater stations on both the 222-225 MHz and 1270- 1295 MHz bands, an opposition first expressed in the "Novice Enhancement" proceeding in 1987. Novice class licensees are not tested on the specialized repeater maintenance and operation techniques necessary for control operators, the League said, nor on such matters as remote control functions, ancillary functions, or interference resolution techniques and requirements. Saying that since another entry-level license -- the Technician Class -- is readily available to those desiring greater privileges, including repeater control operator, it is not desirable to change the entry-level character of the Novice class license at the present time, the League said. And "there is a delicate balance between offering Novice Class licensees sufficient privileges to promote retention of the licensee's interest on the one hand, and maintaining the character of the Novice license as an entry level license class so as to encourage upgrading of one's license class and technical achievement on the other hand." League Seeks Fine Tuning of Scanner Proposal The League has filed comments in an FCC proposal to limit the receiving capabilities of scanner radios. The FCC's Notice of Proposed Rule Making in ET Docket 93-1, released January 13, 1993, proposes to amend Parts 2 and 15 of the FCC Rules to prohibit the manufacture or importation of radio scanners capable of receiving frequencies allocated to the Domestic Public Cellular Radio Telecommunications Service. The League's comments noted that the proposed rules are intended to increase the privary protection of cellular telephone users without unduly restricting legitimate use of scanning receivers and do not have any direct bearing on bona fide use of Amateur Radio transmitting or receiving, with one possible exception. That exception is the proposed Section 15.121, addressing "scanning receivers and frequency converters used with scanning receivers," which could be interpreted to restrict receiving converters legitimately intended for use with amateur transceivers, and for routine operation in the Amateur Radio Service in the band 902-928 MHz Such converters, the League said, incorporate reasonably broad bandwidth circuitry, and typically are used to translate frequencies in the 902-928 MHz amateur allocation to frequencies in lower bands such as 144-148 MHz. There is a small percentage difference between 902 MHz at the bottom of the amateur band and 894 MHz at the top of the 869- 894 MHz domestic cellular band, the League said, and the nature of broadband receiving converters is that some frequencies outside their nominal bandwidth, albeit attenuated, could conceivably be translated along with the frequencies of interest. This is an inherent characteristic of a broadband converter which would receive frequencies throughout the 902-928 MHz band, owing to the characteristics of practical filters. "However, it does not necessarily follow that the receiver following the receiving converter would actually tune to the frequencies to which the cellular telephone signals were translated," the League said. "In the case of amateur radio converters for 902-928 MHz, the clear function thereof is for amateur radio communications. "It is understood that the Commission has no intention in this proceeding of restricting legitimate amateur radio operation at 902-928 MHz, and the League's concern herein is simply to guard against an overbroad interpretation of the proposed rule," the League said. The ARRL, in its comments, calls for clarification of the proposed rule "to assure that amateur access to the 902-928 MHz band is not unintentionally restricted by the unavailablity of converter equipment." The League suggested that Section 15.121 might be modified with the addition of the following: *Receiving converters designed for use by Commission licensees on frequency bands allocated for their use above 900 MHz shall not be deemed "capable of operating or readily being altered by the user" to operate within the Domestic Public Cellular Telecommunications Service.* League Files In Opposition to Quiet Zone The League has opposed a Petition for Rulemaking filed in November 1992 by Cornell University that would create a radio "quiet zone" in Puerto Rico. Cornell, operator of the Arecibo (Puerto Rico) Observatory under an agreement with the National Science Foundation, would have the FCC amend its rules to to require that all applicants for new communications facilities, and all modifications of existing authorizations anywhere in Puerto Rico or the surrounding US islands, provide written notification to the Arecibo Observatory. The Cornell petition would allow the Arecibo Observatory to determine whether applications might cause harmful interference to the radio astronomy facilities there. If interference is anticipated, the proposed rule changes would permit Arecibo to file objections with the Commission. As applied to the Amateur Radio Service, the notification procedure would permit the Observatory to determine, within 20 days of notification of the proposed installation of an amateur radio repeater or automatic beacon station (on frequencies allocated to the Amateur Radio Service), whether the repeater or beacon, at the location and operating parameters proposed, should be opposed. If an opposition is filed, the Commission would "review the objection" and take "appropriate action." There are no technical criteria proposed for such evaluation, the League noted, nor is the basis for a determination of "appropriate action" specified. The League did note its support for the work at Arecibo, in particular its affinity with experimental work done by Amateur Radio operators. "The League does not dispute the need to protect the observatory from actual harmful interference within radio astronomy frequency allocations," the League said, and "furthermore, to the extent consistent with reasonable, efficient operation of radio stations operating in their own frequency allocations, the observatory should be accommodated in conducting passive experiments in the radio spectrum generally." "Mature" systems at risk The League said, however, that the research at Arecibo "should not be permitted to disrupt mature telecommunications systems in a highly populated area, or deter or inhibit the modification of communications facilities with newer technologies. "Nor, from the League's point of view, should a valuable emergency communications system in a hurricane-susceptible area be restricted, based on an inchoate, unquantified fear of possible future interference," the League said. The League also said that the Cornell petition fails to address what degree of protection should be accorded, makes no distinction about what radio services might or might not be potential sources of interference, and does not take into account that planned upgrades to the antenna at Arecibo will tend to *reduce* received interference. "Though it is impossible to determine from the petition," the League said, "because the petition does not contain sufficient engineering to determine the extent of any potential conflict, the League believes that amateur repeater facilities and beacon facilities are not likely to cause any interference whatsoever to the Observatory. Amateur radio repeater stations principally utilize omnidirectional antennas, and operate at transmitter powers typically between 25 and 150 watts. They are installed and modified routinely by radio amateurs, and no FCC approval is necessary before a repeater is installed or modified now. The League also pointed out that beacon stations, used by radio amateurs for propagation research and frequency selection, are for a number of reasons unlikely potential sources of interference to the Observatory, and that both repeaters and plans. Finally, the League pointed out that the Observatory can be exposed to radio transmissions from shipboard stations in the Caribbean sea, protection from which the FCC could not provide under any circumstances. As an alternative to the Cornell petition, the League suggested that Cornell work with local database administrators, i.e., repeater or frequency coordinators, to obtain information concerning amateur repeaters, avoiding unnecessary notification, and delay of installation of new amateur repeater and beacon facilities. "If there is a role for the Commission in the protection of the Arecibo Observatory," the League said, "it comes into play only after the parties have attempted cooperatively to resolve an actual, harmful interference problem. The Amateur Radio Service has the ability to cooperatively resolve any such complaints, and that mechanism should be utilized. "Cornell thus has much to gain from a cooperative approach to interference resolution with the amateur community, as opposed to the adversarial procedure suggested in the petition, the League said. "It is thus suggested that the Amateur Radio Service be viewed as an ally, and that its volunteer coordination and interference resolution resources be utilized cooperatively." HOUSE BILL PASSES, MENTIONS AMATEURS On Tuesday, March 2, the U.S. House of Representatives adopted H.R. 707, the Emerging Telecommunications Technologies Act of 1993. The legislation had been reported out, without amendment, by the House Committee on Energy and Commerce. The bill requires the federal government to release 200 MHz of frequency spectrum for commercial use to foster new technologies in the private sector, with at least 180 MHz to be below 5 GHz. It is virtually identical to legislation that was adopted by the House in 1991, but that did not make its way through the Senate during the 102nd Congress. In recommending adoption, the Committee report said "An example of the dilemma that spectrum managers must face due to spectrum congestion was provided several years ago, when the Commission was forced to reallocate two megaHertz of spectrum that had been utilized, on a secondary basis, by the Amateur Radio Service. "The Amateur Service has established an impressive record of providing life-saving emergency communications during natural disasters and accidents, when more conventional methods of communications were rendered inoperable. "Yet because of the lack of alternative, the Commission was forced to take away these two MHz in return for giving the Service 'primary' access to an adjacent three MHz band. Passage of H.R. 707 will alleviate the pressure to take more spectrum from the Amateur Service by providing frequencies for new technologies in other bands." The House bill differs somewhat from similar legislation introduced in the Senate by Senator Inouye, S. 335, which includes authority for the FCC to assign spectrum in certain services by auction and also includes specific protections for the Amateur Service that were sought by the League during the previous session of Congress. As yet, there has been no action in the Senate on S. 335. If the Senate adopts the Inouye bill in something resembling its present form, the ARRL will encourage the Conference Committee that resolves the differences between the bills to include those protections. More information on S.335 will appear in April QST. ACCREDITATION OF 11 ARRL VEs SUSPENDED The ARRL Volunteer Examiner Coordinator has temporarily suspended the accreditations of 11 volunteer examiners pending an investigation of apparent irregularities at two testing sessions. The 11 VEs were involved in part in testing sessions in Newark and Stockton, California, in February, 1993 and November, 1992 respectively, as well as in earlier sessions in Union City, Stockton, and San Jose, California. According to ARRL/VEC Manager Bart Jahnke, KB9NM, the irregularities in the exams in question involve the Morse code testing. The two latest test sessions, in Newark and Stockton, involved 46 individuals and 46 upgrades. At presstime an FCC spokesman said he expected that action would be taken shortly against the examinees who upgraded their license class at the November session in Newark, California. Action against the February, 1993 examinees in Stockton also was possible. BRIEFS * Three new members of the ARRL Headquarters 10-Year Club were inducted March 4: Assistant Technical Editor Bob Schetgen, KU7G; Senior Technical Illustrator David Pingree, N1NAS; and Production Assistant Jean Wilson, N1OJS. * Following evaluation of a loaner unit the Headquarters Technical Department has ordered a Hewlett-Packard spectrum analyzer with continuous coverage from 30 Hz to 26.5 GHz. The new unit will be used for more sophisticated measurements of equipment for Product Review as well as in design work in the Lab. * The FCC has abandoned a 1986 proposal to require that all radio transmissions be encoded for identification purposes. The proposal, in an August, 1986 NPRM, originally focused on satellite uplink signals, and later grew to other radio services. The Commission now has said that the private development of automatic transmitter identification systems (ATIS) for video satellite uplinks has removed the need for rule making in the matter. So far as other radio services were concerned, commenters on the proposal had no concensus on how to proceed and "the record is now stale," the FCC said. * Canadian amateurs are soon to unite in the Radio Amateurs of Canada. The Canadian Radio Relay League and the Canadian Amateur Radio Federation have announced an inaugural meeting on May 3, 1993, following the ironing out in late February of final details of their merger. The two groups will hold their final individual meetings on May 1. Their respective publications, *QST Canada* and *The Canadian Amateur*, will both publish in May and June, followed by their new joint magazine, *The Canadian Amateur*, in July. * The US Environmental Protection Agency has called for "vast research on potential dangers from electromagnetic fields," according to the Associated Press. "[The EPA] said too little is known to gauge risks from exposure to sources ranging from power lines to such everyday items as TV sets and hair dryers," the AP reported on March 2. Both human and animal studies were recommended "to try to determine just how much impact electromagnetic fields have on human biological systems. Top priority should be given to possible cancer effects and changes in the body's functins as well as an assessment of how much human exposure is potentially harmful," EPA's Office of Research and Development said. The report said there is insufficient data so far on the relation between the length of time a person lived near or was exposed to an electromagnetic source and health effects. * *Pushing the envelope.* We are now mailing *The ARRL Letter* in envelopes for three reasons: Better and faster treatment by the US Postal Service, and to enable us to occasionally stuff additional material into the envelope. No increase in subscription rates for the *Letter* is planned. *eof