QRZ! Ham Radio 4/QRZ Ham Radio Callsign Database - Volume 4.iso/files/arrl/hiram/ltr12n5.txt

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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