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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