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. 


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