QRZ! Ham Radio 4/QRZ Ham Radio Callsign Database - Volume 4.iso/files/arrl/hiram/ltr12n13.txt

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The ARRL Letter
Vol. 12, No. 13
July 10, 1993

ARRL moves on three Washington fronts in protection of amateur
privileges

     In a blizzard of comments to the Federal Communications
Commission the ARRL has:

     * Supported, in principle, an FCC proposal to place the
responsibility for the content of messages on their originator
and their "first forwarder" in an amateur network;

     * Opposed a proposal to allocate the frequency 449 MHz to
future wind profiler radar systems; and

     * Opposed a proposal to include yet another service,
Automatic Vehicle Monitoring, in the 902-928 MHz band.

     In all three cases the League filed initial comments; reply
comments will follow.

AMATEURS' RESPONSIBILITY FOR CONTENT OF MESSAGES

     On July 1, 1993, the ARRL filed comments with the FCC on
their proposal to change the responsibility for the content of
amateur messages relayed by high-speed networks.
     The FCC's proposal, in PR Docket 93-85, was in response to a
number of petitions for rule making, and would establish "a
compliance policy for amateur stations participating in automatic
message forwarding systems, to hold the licensee of the station
originating a message and the licensee of the first forwarding
station primarily accountable for violative communications."
     The petitions were filed following an incident in early
1991, when the operators of several amateur packet bulletin
boards were cited by the Commission for forwarding what was
characterized as a "commercial" message.
     The proposal would modify current FCC rules, which provide
accountability of each licensee for every transmission from the
licensee's station, regardless of the configuration of the system
of     stations in a data network or whether the station is in
repeater operation.
     "The League supports the Commission's proposal to more
specifically define the proper limits of accountability for both
repeaters and message forwarding systems," the ARRL filing said.
"This proceeding is timely, and is aimed at facilitating the
development of rapid data networks and other systems in the
Amateur Radio Service. The proposed rules, if modified slightly
... will remedy the lack of clarity in the degree of
accountability of amateur stations
in repeater operation and those participating in message
forwarding systems.
     "The League believes that the Commission has arrived at the
proper policy limitation on liability of individual amateur
stations for inadvertent retransmission of messages which may
violate Commission content regulations. It has placed the
repeater owners, and the participants in a message forwarrding
system, in the proper positions relative to the prevention and
elimination of improper messages, according to their actual
ability to prevent or eliminate an offending message.
     "The Commission should clarify," the League said, "the
nature of the obligation of the first forwarder in a message
forwarding system, so as to permit either an authentication
arrangement with respect to the originator of the message, or a
message screening provision. Either should be deemed sufficient
to discharge the control operator's obligation to exercise
control as a 'first forwarder.'
     "Also, the definition of 'repeater' and the identification
of the 'first-forwarder' bear some modification as well," the
League said.

*A varied history*

     The League's lengthy and comprehensive comments note that
before the establishment of automatically controlled packet radio
networks in the Amateur Service, the Commission had faced the
development of voice repeaters. These were well-suited to
automatic control, which the FCC authorized in 1975. The
Commission ultimately was persuaded to change its initial plan
for recording and monitoring of repeater transmissions (for
enforcement purposes), saying that amateurs' long history of self
policing would be expected to suffice.
     Thus, "closed" repeaters were allowed to operate under
automatic control without a monitoring requirement and "open"
repeaters were required to have real-time monitoring or recording
for later review. In 1978 this policy was re-emphasized, when the
FCC simplified licensing requirements for complex amateur
systems, including repeaters.
     But in 1982 the allocation of accountability for message
content changed abruptly, when James C. McKinney, chief of the
Private Radio Bureau, held that an amateur who operated a voice
repeater would be considered just as accountable for a content
violation as the originator of the message.
     This holding was in response to a petition two years earlier
seeking to change the amateur rules to exactly the opposite --
that the repeater operator would *not* be held responsible.
     When asked to reconsider, McKinney went further, saying that
since the licensee of an amateur station is responsible for its
proper operation, then a "necessary corollary" to the FCC rules
is that "if one is responsible for something, it must be under
one's control."
     McKinney concluded that "control" is not severable into
technical control, content control of messages the repeater
licensee originates, and content control of messages originated
by repeater users.
     In an FCC Order released April 23, 1982, McKinney said that
violations of FCC rules on repeaters should be countered by the
repeater licensee, to prevent them from happening again, and said
that might even involve shutting down the repeater.
     "We are not persuaded that repeater operation is sacrosanct
and that it needs to be kept open at all costs, when to do so is
to allow the retransmission of violative communications," the FCC
order said.

*New problems with packet*

     When the development of extensive packet radio networks
accelerated in the mid-1980s     the FCC adopted a Report and
Order (in Docket 85-105) to permit amateur digital communications
under automatic control on VHF frequencies. But local control was
required for third party traffic, a requirement to which the ARRL
took exception in the case of packet radio, since it would not
allow for digipeaters and other intermediate relay stations.
     The FCC then agreed to a temporary waiver of its rules to
eliminate the local or remote control requirement for packet
communications only when the ARRL AX.25 protocol was used.
     The League now points out that with this 1986 action the FCC
"understood that only after-the-fact screening of messages is
possible since the control operator of a given station can only
indirectly supervise the station transmissions."
     The FCC's 1986 action seemed, the League said, to revert to
the Commission's policy on voice repeaters *before* the changes
instituted by     the Private Radio Bureau in 1982.     But it
was a brief reversal, however, because in 1990 an ARRL request to
allow automatic control of *all* third party VHF communications
(rather than only AX.25) was denied by the FCC.
     The League asked in a petition for rule making that the
responsibility for message content be solely that of the
originating station, but the FCC would not propose such a rule,
saying that "all rules apply idividually to each amateur station
in [a] system, not to the resulting system. Each station licensee
and each station control operator is as responsible for the
messages transmitted as those retransmitted by the station."
     Now the League, suggesting that policies have been "uneven"
over the years, has called for a "zero-based review" of amateurs'
accountability for message content.

*Enforcement issues*

     The League listed several matters "not subject to
significant debate":
     * While the originator is the root cause of a violative
message, it can be difficult to identify that station within a
messsage forwarding system. In the past there has been a burden
of proof on the FCC to make that identification, and that same
difficulty stifles amateurs' ability to police themselves, always
a plus.
     * Data messages, unlike voice repeater transmissions, tend
to take on a life of their own as they propagate through a
system; the violation continues.
     The League agrees with the FCC that holding accountable
station licensees beyond the originating station is justified,
but that the methods used must be fair and not stifle the
development of future, more advanced amateur systems.
     But the nature of the accountability of the "first
forwarding station" should be revised, the League said. It should
be to "establish with reasonable certainty the identity of the
amateur station originating a particular message." In other
words, the first-forwarder should be responsible for message
content only if the originator cannot be identified.
     The definition of "first-forwarder" also needs to be
clarified; it should be, the League suggested, the first upstream
store and forward system in the message forwarding network (and
not, for example, a digipeater located between the message
originator and the first BBS-typs station).
     Finally, the definition of a "repeater" in the new rules
should distinguish between traditional repeaters, which receive
and transmit simultaneously, on separate receive and transmit
frequencies, and automatic message forwarding systems.

FCC AIRS PLAN TO RELOCATE WIND PROFILER RADAR SYSTEMS

     The League has told the FCC that a proposal to allocate the
frequency 449 MHz for wind profiler radar systems should be based
only on careful coordination processes and site selection, to
avoid interference to amateurs, who share on a secondary basis
the band 420-450 MHz with government (military) radiolocation
operations.
     On April 1, 1993, the FCC issued an Notice of Proposed Rule
Making (in ET Docket 93-59) to make the allocation, and  asked
for comments on whether wind profilers should also be
accommodated in the 915 MHz band or elsewhere.
     The League told the FCC that the 420-450 MHz band is heavily
used by the Amateur Radio Service, especially for FM repeaters,
it being the second most popular VHF/UHF amateur allocation;
5,159 repeaters in the band are listed in the latest *ARRL
Repeater Directory*.
     These repeaters are used for public service communications,
especially in metropolitan areas, and are important in the
connection between Amateur Radio and the
SKYWARN severe weather warning system, the League said.
     The League said that it appears possible that government
wind profilers could be used in this band without disrupting
existing amateur operations, but only with proper coordination.
The League noted that it already has an agreement with the
National Weather Service, the government agency that would
operate wind profilers, covering support of emergency
communications.
     In order to provide both public service communications and
to assist agencies like the NWS, amateurs have invested large
sums of time and money in equipment for the 420-450 MHz band, the
League said. "There is therefore an apparent need to include
interference protection criteria for amateur stations in the 440-
450 MHz band in any site selection plan for wind profilers, so
that individual repeater stations are not driven off the air,"
the League said.

*Siting is critical*

     On the other hand, non-government profilers should not be
permitted to operate on 449 MHz, the League said, since while
government profilers likely would be located away from
metropolitan areas, that would not be true of profilers operated
by universities or other non-government licensees, thus greatly
increasing the possibility of interference to existing amateur
repeater and other operations.
     The League cited its assistance to both domestic and
international allocations committees that deal with wind
profilers, noting that there are currently no allocations for
them. It is arguable, the League said, that profilers should
logically be operated within radio bands allocated to the
meterological aids service, since that is what they are. But
profilers now operating experimentally at 404.37 MHz have proven
unacceptable since they interfere with earth-to-space satellite
links at 406 MHz.
     The U.S. government advisory groups decided to recommend
allocating 449 MHz to wind profilers, since that was at the upper
band edge of a current allocation for government radiolocation
services, "clearly not a good choice" from the viewpoint of the
Amateur Radio Service, the League said.
     Assuming that it is necessary for economic reasons or
otherwise to choose a single frequency for wind profilers, the
League said, it would have suggested a more thorough study of
alternative frequencies within the 440-450 MHz band.
     For example, the League said, 446 MHz might have been a
better choice from amateurs' point of view, that being in the
middle of the 445-447 MHz "gap" between repeater inputs and
outputs.
     The League said that if existing 404 MHz experimental wind
profilers were to move to 449 MHz,
interference to amateur repeaters in certain locations will
result. But by site selection, coordination of which is being
developed between the League and the government, such interacton
with amateur repeaters can be avoided.
     On the other hand, the League said that such coordination
might not be possible with non-government profilers, and that if
they are permitted at 449 MHz they should be prohibited in
metropolitan or suburban areas, where disruption of amateur
public servide and emergency communications "is a virtual
certainty."
     The League also pointed out that technical standards for
wind profilers, including bandwidth,      have not yet been
completely specified, making it unfair for the public to be asked
to comment on their allocations. The League requested that the
Commission issue a "Further Notice" to provide such information.

*Profilers at 915 MHz*

     In addition to the proposal for a wind profiler allocation
at 449 MHz, the FCC's NPRM also announced a Notice of Inquiry for
input regarding an allocation in the range 902-928 MHz.
     The League said that adding a 12.5-MHz wide channel centered
on 915 MHz for profilers to the services already there would add
to an "already uncomfortable melting pot of uses." Adding
profilers to a proposed AVM addition to the band (see
accompanying story) would "bring the band closer to 'gridlock'
status," the League said.
     For this reason, the League said, the FCC should not act on
wind profiler radars at 915 MHz without taking into account the
possible impact of its proposal to allocate AVM systems there.
"The allocation of both would work a distinct hardship on the
Amateur Radio Service," the League said.

     (More information on wind profiler radar systems appears in
*QST* for March 1992, page 20; April 1992, page 22; and June
1992, page 48).

ADDING ANOTHER SERVICE TO CROWDED 902-928 MHZ

     "Adopt no rules without further study," the ARRL has
recommended to the FCC, in a Commission proposal to expand the
use of Automatic Vehicle Monitoring (AVM) systems in the 902-928
MHz band.
     The proposal, in PR Docket 93-61, would allow the  expansion
of AVM systems through the creation of a new location and
monitoring service (LMS) in the 902-928 MHz band. Amateurs
already share this band with government radiolocation, fixed, and
mobile services, in addition to industrial, scientific, and
medical (ISM) equipment and various non-licensed, low-power "Part
15" devices.
     The FCC said in its Notice of Proposed Rule Making that such
an expansion of AVM in this frequency range "could
lead to rapid congestion of available spectrum" and asked current
users of the band if they could handle any increased congestion.
     "If not," the FCC said, "commenters should offer potential
solutions, short of removing Part 15 users and amateur operations
from the band, restricting where such users could operate in the
band, or placing stricter limitations on the operations in this
band."
     The League said that no action should be taken until the FCC
has studied the potential for interaction between AVM and wind
profiler radar systems, the suitabliity of AVM operations for
highway safety sytems in a crowded RF environment, and the
alternative technologies available for the same purpose served by
AVM and Location and Monitoring Services.
     In order to protect other users of this crowded allocation,
the League said, the Commission should not expand the frequencies
available for AVM/LMS at 902-928 MHz but rather continue to limit
such operation to 903-912 and 918-927 MHz.
     And "in addition to [a] vast array of different users of the
902-928 MHz band," the League said, "the Commission is currently
considering yet another user," namely wind profiler radars (see
accompanying story).

*Band use on increase*

     The League said that although amateurs have been able to
share the band with AVM stations operating under interim rules
since 1985 (when U.S. and other ITU Region 2 amateurs gained
access to the band), since that time both amateur and AVM use of
the band has grown.
     Expansion of AVM/LMS in the band would "significantly
reduce" its utility for amateurs at a time when they are
increasingly looking to the band in the face of "intense growth"
of Amateur Radio licensees and the "concurrent saturation" of the
lower UHF and VHF amateur allocations.
     "The continued availability of the entire band for amateur
use is critical," the League said, especially in accommodating
weak-signal propagation experiments and the development of
amateur television.
     The League noted that when the FCC reallocated 220-222 MHz
from the Amateur Service to commercial users in 1991, it, the
FCC, emphasized the continued availability of 902-928 MHz to
amateurs. To significantly reduce the utility of 902-928 to
amateurs by adding yet another service within it "would
constitute a breach of the Commission's previous assurances to
the Amateur Radio Service" and would "ill serve the public who
benefit from amateur radio," the League said.
     Saying that the Commission in its proposal already had
established an intention not to place stricter limitations on
current users of the band, "the Commission must, by the same
token, avoid rules which would, *de
facto*, reduce the availability of the band for those users, or
to make sharing significantly more difficult than it is at
present."
     Finally, the League said that while amateurs (and others as
well) have been able to share the 902-928 MHz band it is obvious
that all services in a frequency-sharing environment must be
"extremely robust" in order to survive. The League said that the
constitution of the 902-928 MHz band had been essentially
unplanned, and that its users must be able to accept significant
amounts of interference and to "operate with the flexibility that
such an interactive RF environment demands."
     The League said it appears unclear that AVM technology is
suited to such an environment.
     The reply comment date for this NPRM was July 14, 1993.

TEACHERS, INSTRUCTORS TO MEET IN HUNTSVILLE

     This year's ARRL National Educational Workshop at the ARRL
1993 National Convention, the fifth such workshop, will be
Friday, August 13, 1993, from noon to 5 p.m. at the Von Braun
Civic Center in Huntsville, Alabama. Speakers at the workshop,
sponsored by ARRL's Educational Activities Department, will each
present a 20 minute talk on Amateur Radio education and
recruitment.
     Speakers tentatively scheduled are:
     Tony Lux, KC4MI (Huntsville) -- "Successful Practical
Teaching Techniques."
     Loraine McCarthy, N6CIO (Costa Mesa, Calif.) -- "Teaching
Morse Code and Theory."
     Harley Cutchens, KD4ONQ (Gadsden, Alabama) -- "Recruiting
New Hams."
     Rosalie White, WA1STO (ARRL HQ) -- "ARRL Teaching Materials
to Help You."
     Jim Stafford (Roswell, Georgia) -- "Teaching Amateur Radio
to All Ages."
     Jo Ann Tunstill, WB4QOS (Huntsville) -- "Recruitment
Programs that Work."
     Lymon Jones, KD4FJB (Huntsville) -- "ATV Excitement with
School Kids."
     Those attending the entire session will receive a
certificate for 0.5 Continuing Education Units.

AMATEUR RADIO SERVICE JOINT RESOLUTION UPDATE

     Six more U.S. representatives and one U.S. senator have
joined as co-sponsors of the Amateur Radio Joint Resolution (S.J.
Resolution 90 and H.J. Resolution 199); they are: Reps. John
Bryant (D-TX); Ike Skelton (D-MO); Floyd Spence (R-SC); Dick
Swett (D-NH); Terry Everett (R-AL); Edward Royce (R-CA); and Sen.
Judd Gregg (R-NH).
     Nine senators and 47 representatives are now co-
sponsors.

BRIEFS

     * Len Chertok, W3GRF, died on June 24. He was 71 years old.
W3GRF was one of the all-time great contest operators. Some of
the greatest DX contest battles of the 1950s and 60s were between
him and former ARRL President Vic Clark, W4KFC.
     In his later years, despite poor health, Lenny opened his
station as a training ground for neophyte contesters.
     W3GRF was a long-time member and former president of the
Potomac Valley Radio Club. He was an ARRL life member.
     The funeral and burial were June 28 in Cheltenham, MD.

     * The first of a series of New Section Manager Motivation
and Training Workshops will be held August 7 and 8 in Denver.
Planning to attend are new section managers Randy Wendel, N0FKU
(MN); Robert Adler, NZ2T (NTX); Warren Morton, WS7W (WY);
Clifford Hauser, KD6XH (AR); and Harry Hodges, WA6YOO (SDGO).
     The workshop will be hosted by Rocky Mountain Division
Director Marshall Quiat, AG0X, and Colorado Section Manager Tim
Armagost, WB0TUB.
     The day-and-a-half course is geared to *new* SMs, and will
cover topics such as the SM's job description, administration of
ARRL programs, management theory, ARRL organizational structure,
and Headquarters support services.

     * The FCC has begun preparations for the 1993 International
Telecommunication Union (ITU) World Radiocommunication Conference
(WRC-93). WRC-93 is the first conference under a new plan for
scheduling WRCs biennially and will be held November 15-19, 1993,
in Geneva.
      The Commission is seeking input in order to determine the
U.S.'s position at WRC-93, which is primarily a meeting to set
agendas for meetings in 1995 and 1997; two issues, a review of
the Radio Regulations and facilitating use of frequency bands
allocated to the mobile-satellite service, already have been
recommended for WRC-95.
     WRC-93 also will consider: satellite digital audio
broadcasting; wind profiler radar systems; space sciences
services; and HF broadcasting.
     The FCC also has invited comment on resolutions and
recommendations from past World Administrative Radio Conferences,
extending back to 1979, which have yet to be acted upon.

     * Radio Free Europe is set to terminate most of its foreign
language transmissions, according to *The New York Times*.
Broadcasts from Munich to Poland, Hungary, the Czech Republic and
Slovakia, and to the three Baltic countries will be halted. RFE
will continue broadcasts in Bulgarian
and Romanian. Also, some Voice of America broadcasts to the
successor states of the former Soviet Union are slated to stop.
About 600 employees each of RFE and the VOA will be affected, the
*Times* reported.

     * According to KD2BD, operation by Russian cosmonauts aboard
the MIR space station has shifted to 145.850. Caution is advised
since this frequency is within several OSCAR satellite uplink and
downlink passbands.
     G3RWL reports that tape recordings made aboard MIR of
Amateur Radio contacts with ground stations have been replayed
over Radio Moscow.

     * ARRL Midwest Division Director Bill McGranahan, K0ORB, has
been appointed to the board of directors of the ARRL Foundation.

     * FCC officials on June 29 heard presentations on current
Amateur Radio topics by ARRL and AMSAT officials. ARRL Senior
Engineer Jon Bloom, KE3Z, discussed experiments in digital
communications, recent advances in RF equipment for amateurs,
application of digital signal processing to amateur systems, and
the growth of modes such as image communications and spread
spectrum.
     AMSAT's Dick Daniels, W4PUJ, summarized the history of the
amateur satellite program with emphasis on recent, imminent and
planned satellite launches. The meeting, organized by ARRL
Manager of Technical Relations Paul Rinaldo, W4RI, was videotaped
for future viewing.

     * SAREX shuttle flight STS-57 returned July 1. A post-flight
press briefing is scheduled for July 13 at 1900 UTC on NASA
Select Television (SATCOM F2R, transponder 13).
     STS-58 on September 10 also will carry SAREX; Payload
Specialist Martin Fettman has received his amateur call sign:
KC5AXA, and STS-58 pilot Rick Searfoss has taken his amateur
license exam. SAREX flight STS-60 is scheduled for a November 10
launch.

     * The FCC has denied a complaint of discrimination by
Leonidas Moten, WD8POF. Moten, who is visually impaired, alleged
he was improperly excluded from acting as a volunteer examiner by
a local VE team. In April the FCC found that Moten did not meet
the requirements to be a VE, and thus no improper discrimination
occurred. Moten appealed that decision to the FCC, which on June
25 denied the appeal.

     * The FCC's 58th annual report, for Fiscal Year 1992, is now
available from the U.S. Government Printing Office, Washington
D.C. 20402. The price is $3.75, stock number 004-000-00494-9.

Still active

     In the lobby of ARRL Hedquarters is a December 16, 1901
issue of the *New York Journal* proclaiming Marconi's first
transatlantic radio message (which actually took place on
December 12, 1901). When that historic paper hit the streets of
New York the gentleman shown above, Hal Campbell, W2IP, had
already come into the world, on November 27, 1901, to be exact.
He recently made a return visit to Headquarters and to W1AW.
     The first *QST* in Hal's collection is from December, 1916,
and he's been an ARRL member continuously ever since (put away
your calculators -- that's nearly 77 years!).
     Hal was first licensed as 1ABW for a few weeks in 1917,
before amateurs were taken off the air for the First World War.
He used a spark coil and galena detector. He was issued 1IV after
the war, and signed that and later W1IV until moving to New York
and becoming W2IP in 1931. "Someone already had W2IV, so the
radio inspector gave me the closest thing he had."
      Hal attended Trinity College in Hartford in 1925 and '26,
"but I spent more time at ARRL Headquarters than in class," he
admits. Of course he knew ARRL founder Hiram Maxim, W1AW, and the
other early staff. In fact, Hal interviewed for a job at ARRL.
     After helping build an early AM station in Bridgeport,
Connecticut, Hal went to work for NBC in 1928, a company he
retired from in 1966.
     On May 5, 1962, when Navy Cmdr. Alan B. Shephard Jr. landed
in the Atlantic after becoming the U.S.'s first spaceman, Hal
Campbell, working the NASA beat for NBC, was on board to welcome
him back to earth.
     Hal lives in Mount Vernon, New York, and is still active on
the air, especially on the Russian RS-10 satellite. (K1TN photo)

902 MHz sharing threatened Instructors to gather Congressional
update

*eof