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1993-03-15
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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 222-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 using specialized
techniques at 222 MHz. 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.
Bus 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."
The League said that certain amateurs 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 incompatible 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 -- the only type of amateur
station to which the coordination process gives a measure of
priority."
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.
The ARRL 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. 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 by the League 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 FCC's scanner proposal
The ARRL 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 privacy 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 902-928 MHz band.
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 seeks 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 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 threaten
harmful interference to the radio astronomy facilities
there. If interference is anticipated, Cornell's 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."
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
currently necessary before a repeater is installed or modified.
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 permanently installed and temporary repeaters are
vital parts of Amateur Radio emergency communications 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,
COULD AFFECT 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 mHz
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 Daniel
Inouye (D-HI), 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 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 with regard to the examinees who
upgraded their license class at the November session in
Newark, California. Action involving the February, 1993
examinees in Stockton also was possible. These actions in
the past have amounted to disallowing the applicant's
Certificate of Successful Completion of Examination.
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
include 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 consensus 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 scheduled an
inaugural meeting for 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
functions 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.
*eof