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Report of the Ad Hoc Spectrum Strategy Committee
to the
ARRL Board of Directors
January 19, 2001

Table of Contents

Executive Summary*

1. Introduction*

2. Discussion*

3. Strategic Objectives and Guidance for the Future*

4. Conclusions and Recommendations*

And In Conclusion*

Appendices*

Executive Summary

This is the first report of the Ad Hoc Spectrum Strategy Committee. This committee was created in September 2000, at the direction of ARRL President Jim Haynie, W5JBP. Our charge, briefly, was to develop data and strategies for enhancing our ability to use productively our frequency assignments above 30 MHz. Emphasis was to be placed initially on challenges from unlicensed Part 15 devices.

After approximately three months of intensive work, the Committee submits this report for consideration. Contained are an introduction to the challenges facing us (Section 1), expanded discussions of those challenges, both from technical and regulatory standpoints (Section 2), a discussion of strategic objectives and means for achieving those objectives (Section 3), followed by specific recommendations of this Committee (Section 4). Supporting data are included both within the body of the report and in three Appendices.

The Committee believes that the emergence of Part 15 devices in large numbers in the consumer market poses a serious threat to our use of some Amateur bands above 30 MHz. In the past Amateurs have exhibited great ingenuity and resiliency when faced by challenges. We believe that the present challenges to our use of spectrum at VHF and above are surmountable. However, we believe that decisive leadership by ARRL is an important part of the process Amateur Radio should follow in order to meet those challenges.

1. Introduction

   It has become increasingly evident that the explosion of unlicensed consumer wireless devices in the US and elsewhere will ultimately present a very serious challenge to Amateur operations in some bands. As is the case with the well-known fable concerning the camel in the tent, some "sharing partners" have the potential for making our spectral tent very difficult for us to use. Among the more serious of these threats are the various wireless networking protocols that are starting to proliferate on 2.4 GHz. These include the wireless LAN devices specified under the IEEE 802.11 and HomeRF standard and "Bluetooth" devices, a Part 15 system designed to replace cables for interconnecting small computers to their peripheral devices. Although Bluetooth devices generally use lower power than the other specifications, they may represent one of the more serious of these challenges because they are expected to be made by the millions for use in consumer electronic equipment. Bluetooth chips are now being mass-produced, are cheap, and are now on the market. Unfortunately, they operate in the 2400-2383.5 MHz band, a band that is receiving increasing attention from Amateur operators.

   In recent years challenges to Amateur operations have been appearing at an ever-increasing rate. It has become clear that ARRL, as an organization, must improve its performance in recognizing challenges to our use of the RF spectrum and in developing strategies to protect our interests.

   Accordingly, in September 2000, President Haynie created an ad hoc committee, now known as the Ad Hoc Spectrum Strategy Committee, with the following Terms of Reference:

   The Ad Hoc Spectrum Strategy Committee shall

   1. Identify those RF emitters using amateur frequencies and determine their potential for creating harmful interference to amateur operations in the US and its possessions.

   2. Develop both short-term and long-term strategies for mitigating such interference.

   3. Initial emphasis shall be placed on Part 15 devices operating above 30 MHz.

   This document is the committee's initial report in support of the task given to it.

   The complexity of the technological and legal environment in which we find ourselves prevents a purely linear approach when preparing this report. There is therefore some necessary redundancy in this report. With that caveat, in Section 2 we first discuss the threats we face, followed by a discussion of the legal considerations. With these important points covered, in Section 3 we then propose three strategic objectives, followed by a number of actions ARRL might take in order to achieve those objectives. We close, in Section 4, with recommendations for a course of action to be considered by the Board of Directors. In short, we define the problem, we discuss it in some detail, provide objectives and approaches, and then give recommendations for a future course of action.

2. Discussion
   1. The Threat - Status and Trends

      A summary of Amateur Radio allocations above 30 MHz is given in Appendix 1, with a summary of usage patterns given in Appendix 2. We here consider threats to that usage, with emphasis on threats from Part 15 devices.

      The history of Amateur Radio is replete with threats to its well being and ultimately its very existence. Foremost among these threats are those that would diminish or deny Radio Amateurs access to sufficient spectrum to fulfill its basis and purpose as set forth in Part 97 of the FCC Regulations. In recent years our primary focus has been on threats from would-be licensed services, such as Little LEO satellites (2 m and 70 cm), Synthetic Aperture Radar (70 cm), plus radio navigation and land mobile systems, to name a few. Often the threats come to us as a "sharing" proposal. Even the experimental licenses issued by the FCC under Part 5 need to be watched. By way of example, consider the recent Los Angeles City & County attempts to get access to 2.4 GHz (13 cm) by way of an experimental license. In response to these threats, the League has stepped up its Washington presence and has developed a comprehensive legislative agenda, having as its centerpiece the perennial Spectrum Protection Act.

      Suppose the League were to be fully successful in its defense of Amateur Radio spectrum. We were able to maintain all of our current frequency allocations and even have primary status in all. Suppose also that we were able to develop good relationships with our sharing partners such that we were able to coexist without interference to any. What we would gain thereby would be ongoing access to frequency bands, some of which would have steadily rising noise levels due to unlicensed devices in our midst. Although unlicensed devices (Parts 15 and 18 of the FCC Regulations) have been around for many years, their numbers are just now becoming sufficient to impair Amateur Radio operations. (The 902-928 MHz band is an exception; it has been impaired from its beginning.)

      Tables 2.1-1 and 2.1-2 summarize the essential features of unlicensed devices with privileges in our Amateur bands above 30 MHz. The first, Table 2.1-1, presents a listing, by band, of unlicensed devices currently operating in US Amateur bands. The second, Table 2.1-2, presents a more detailed listing by device name. Notes to Table 2.1-2 are given following that table. This narration will pick up again on page 8, following those notes.

      Table 2.1-1 US Unlicensed Device Usage in Amateur Bands above 30 MHz, By Band

      Band	Unlicensed Service/Use
      50 MHz	Intentional Radiators - General Limits
      144 MHz	Intentional Radiators - General Limits, Periodic Radiators
      222 MHz	Intentional Radiators - General Limits, Periodic Radiators
      420 MHz	Intentional Radiators - General Limits, Periodic Radiators
      902 MHz	Industrial Scientific and Medical, High-Power Spread Spectrum, High-Power Intentional Radiators, Location and Monitoring Service, Field Disturbance Sensors, Periodic Radiators, Material measurement systems
      1240 MHz	Intentional Radiators - General Limits, Periodic Radiators, LPI Voice/Data
      2300 MHz	Industrial Scientific and Medical, Microwave Ovens, High-Power Digital Cordless Telephone, High-Power Wireless LAN, Low-Power Wireless LAN (Bluetooth), Field Disturbance Sensors, Unlicensed Personal Communications Service, Intentional Radiators - General Limits, Periodic Radiators
      3300 MHz	Automatic Vehicle Identification System, Intentional Radiators - General Limits, Periodic Radiators
      5650 MHz	Industrial, Scientific and Medical, National Information Infrastructure (NII), High-Power Wireless LAN, Field Disturbance Sensors, Intentional Radiators - General Limits, Periodic Radiators
      10.0 GHz	Intentional Radiators - General Limits, Periodic Radiators, Field Disturbance Sensors

      Table 2.1-1 (Continued) US Unlicensed Device Usage in Amateur Bands above 30 MHz, By Band

      Band	Unlicensed Service/Use
      24.0 GHz	Industrial Scientific and Medical, Field Disturbance Sensors, Intentional Radiators - General Limits, Periodic Radiators
      47.0 GHz	Intentional Radiators - General Limits, Periodic Radiators
      75.5 GHz	Intentional Radiators - General Limits, Periodic Radiators
      119.98 GHz	Intentional Radiators - General Limits, Periodic Radiators
      142.0 GHz	Intentional Radiators - General Limits, Periodic Radiators
      241.0 GHz	Industrial Scientific and Medical, Intentional Radiators - General Limits, Periodic Radiators

      Table 2.1-2 US Unlicensed Device Usage in Amateur Bands above 30 MHz, By Service/Use:

      Service/Use	Standard	Frequency Band	Radiated Limits
      Digital Cordless Telephone (See Note 3.)	Part 15.247	2400-2483.5 MHz	1 W max, using built-in antenna
      General Limits for Intentional Radiators (See note 4.)	Part 15.209	30-88 MHz	100 m V/m at 3 meters distance from the radiating source
      -do-	- do -	88-216 MHz	150 m V/m at 3 meters
      -do-	- do -	216-960 MHz	200 m V/m at 3 meters
      -do-	- do -	Above 960 MHz	500 m V/m at 3 meters
      -do-	- do -	2400-2483.5 MHz	50 millivolts/m at 3 meters
      -do-	- do -	5725-5875 MHz	50 millivolts/m at 3 meters
      -do-	- do -	24.0-24.25 GHz	250 millivolts/m at 3 meters
      Field-Disturbance Sensors and Perimeter Protection Systems (See Note 5.)	Part 15.245	902-928 MHz	500 millivolts/m at 3 meters
      -do-	- do -	2435-2465 MHz	500 millivolts/m at 3 meters
      -do-	- do -	5785-5815 MHz	500 millivolts/m at 3 meters
      -do-	- do -	10.5-10.55 GHz	2500 millivolts/m at 3 meters
      -do-	- do -	24.075-24.175 GHz	2500 millivolts/m at 3 meters
      High-Power Intentional Radiators. (Typically analog/ digital cordless telephone.) (See Note 6.)	Part 15.249	902-925 MHz	50 millivolts/m at 3 meters

      Table 2.1-2 (Continued) US Unlicensed Device Usage in Amateur Bands above 30 MHz, By Service/Use:

      Service/Use	Standard	Frequency Band	Radiated Limits
      High-Power Spread Spectrum Transmitters	Part 15.247	902-925 MHz	1 watt output
      Industrial, Scientific and Medical Devices (See Note 7.)	Part 18.107	902-925 MHz	See note 7.
      -do-	- do -	2400-2500 MHz	-do-
      -do-	- do -	5725-5875 MHz	-do-
      Industrial, Scientific and Medical Devices (continued)	-do-	24.0-24.25 GHz	-do-
      "	"	244-246 GHz	"
      Location and Monitoring Service (See Note 8.)	Part 90.351/90.353	902-928 MHz	Up to 300 W PEP
      LPI Voice/Data	UWB	1200-1800 MHz	1W peak with omni and high gain antenna
      Material Measurement Systems (See Note 9.)	Part 15.243	890-940 MHz	500 m V/m at 30 meters
      Microwave Ovens (See Note 10.)	Part 18 ISM	2450.0 +/- 50 MHz	Up to 1kW (shielded)
      National Information Infrastructure (NII)	Part 15.401, 15.407	5725-5850 MHz	250 mw with 6dBi max gain antenna
      Periodic Radiators (See Note 11)	Part 15.231/15.20	138-149.9 MHz	Formula
      -do-	- do -	216-240 MHz	3,750 m V/m at 3 meters
      -do-	- do -	410-470	Formula
      -do-	- do -	1240-1300 MHz and all higher frequencies	12,500 m V/m at 3 meters
      Personal Communications Service (unlicensed)	Part 15	2390-2400 MHz	12,500 m V/m at 3 meters
      Wireless Data (WAN/LAN) (See Note 12, Note 13.)	Part 15.247 IEEE 802.11	2400-2483.5 MHz	1W hi-gain antenna
      -do-	Part 15.247 IEEE802.11b	2400-2483.5 MHz	1W hi-gain antenna
      -do-	Part 15 Bluetooth	2400-2483.5 MHz	Up to 100 milliwatts
      -do-	Part 15.247	5725-5850 MHz	1W hi-gain antenna

      Note 1: Other Areas of the World: This table is derived from US regulations. It is possible that additional interference to amateurs under the jurisdiction of the FCC could occur from devices operated under the jurisdiction of other nations. For example, 433.05-434.79 MHz is an ISM band in Region 1.

      Note 2: The permitted radiation limits under these rules are high enough that harmful interference to the Amateur Radio Service is possible. As an example, on 144 MHz, the limit for general intentional emitters is 150 microvolts/meter at 3 meters distance from the source. A 2-meter Yagi with 10 dBi gain located 30 meters distant from this source will pick up a signal of -87 dBm (approximately S7). In free space, this would be an S2 signal 1 km away. As another example, the unlicensed PCS devices are permitted 12500 microvolts/meter at 3 meters on 2.4 GHz. A 10 dBi gain antenna located 30 meters away would pick up a signal of -72 dBm, approximately S9. As an extreme example, a 2.4 GHz station with a 20 dBi gain Yagi located a km away would pick up an S6 signal from this single device. The additional provision that Part 15 devices not cause harmful interference also applies.

      Note 3: Digital Cordless Telephones using SS in the 2.4 GHz band are becoming widespread.

      Note 4: General Limits for Intentional Radiators: Part 15.209 permits the operation of intentional radiators on virtually any frequency. All ham bands are potentially affected. These limits are generally enough to cause harmful interference to the ham bands.

      Note 5: Field-Disturbance Sensors and Perimeter Protection Systems: These would include RF-based motion detectors that might be found in residential or industrial environments. ARRL has no reports of harmful interference from these types of devices.

      Note 6: Spread Spectrum devices in the 900 MHz band support a variety of uses, including Internet access and cordless telephones.

      Note 7: Industrial, Scientific and Medical (ISM) Devices are permitted on various frequencies from 6.78 MHz to 246 GHz. On those frequencies, they are permitted unlimited radiated field strengths. In addition, under the rules, Amateur operation is not protected from ISM devices.

      Note 8: Location and Monitoring System (LMS) (formerly known as Automatic Vehicle Monitoring): While technically a licensed Service, this is included here because the individual units installed on vehicles are not specifically licensed. (AVM) equipment has the primary allocation in 902-912 and 918-928 MHz. Amateur Radio is secondary, with all other unlicensed devices below us in priority. AVM systems are intermittent, and there is no known case of an AVM system interfering with an Amateur.

      Note 9: Material Measurement Systems: Used primarily in industrial environments. Not apt to cause harmful interference.

      Note 10: Microwave ovens have been operating in the 2.4 GHz band for decades without significant harmful interference.

      Note 11: Periodic Radiators are unlicensed Part 15 transmitters used primarily for occasional data readout. They are authorized to operate on 40.66-40.70 MHz and on virtually all frequencies above 70 MHz. Most operate near 433.92 MHz, an unlicensed frequency in common use in other parts of the world. They transmit only infrequently, typically either by manual operation such as remote control switches or automatically, such as remote-reading thermometers. They typically transmit only a few milliseconds at a time every few minutes. They are not a particular threat at this time. Their activity deserves to be monitored, however, for remote sensing and data transmittal from remote sites has some potential for increasing as time passes.

      Note 12: Wireless Wide Area and Local Area Networks (WAN. LAN). These represent a major threat to the 2.4 GHz band. At their permitted 1 W levels, the interference from these devices may extend for miles. Although, as Part 15 devices, the operator of the device must correct interference, in practice, it may be difficult to identify a particular operator. In at least one case reported to ARRL, a WAN operator ceased operation upon reports of interference, but resumed operation once it was determined that the interference was to the Amateur Radio Service. Some amateur receiving sites are experiencing tens of dB increase in noise in the Part-15 portion of the 2.4 GHz band, presumably from the aggregate of many Part 15 or ISM devices "visible" from a good RF location.

      Note 13: Bluetooth: The new Bluetooth devices are short-range, Part 15 RF modular devices in one chip, which replace cable connections for digital peripherals. They will be operated at 2400-2483.5 MHz, as Frequency Hopped SS systems at 1600 bps. The first products are already on the market. These utilize 1 MHz bandwidths, at two different power levels. There are two versions of the device, one at 1 mW (Class I devices) and another at 100 mW (Class II devices). The latter have ranges of approximately 100 meters. While they are SS devices, they are estimated to number in the billions in the short term. Present Part 15 rules permit the use of these devices at the power levels and configurations planned for Bluetooth devices.

      Note 14: Licensed Sharing of VHF and Up: Several FCC or NTIA rules sections authorize licensed sharing of spectrum above 30 MHz. Part 90 (Land Mobile) and various military authorizations are two examples.

      At this time, the 2400-2450 MHz Amateur band is the most vulnerable to interference from Part 15 devices. Keep in mind, however, the emergence of Ultra Wide Band (UWB) wherein each emitter may cover more than one band. It should also be noted that Table 2.1-2 was derived from US regulations in Region 2. It is possible that additional interference to Amateurs under the jurisdiction of the FCC in Region 2 or Region 3 could occur from devices operated under the jurisdiction of other nations. This possibility has not been investigated thus far, but is a suitable subject for later study.

   2. Regulatory Considerations

   Part 15 devices are flourishing now for several reasons. First, the speed and reliability of unlicensed devices has improved dramatically in recent years. Additionally, the time and expense associated with obtaining wireless licenses, either in the marketplace, or through auctions, has provided a huge incentive to deploy systems designed for Part 15 unlicensed architecture, rather than on a licensed basis. The non-technical end users are best suited to unlicensed operation, where regulatory compliance is not an issue. There is minimal regulatory oversight. Finally, due to the absence of licensing, the devices can be delivered to a wide market quickly.

   In theory, the radiated emission limitations are set low enough that there will not be interference to licensed radio services, either from individual devices, or in the aggregate. However, there are no regulatory limitations on aggregate noise levels from Part 15 devices. Because of the absence of such limitations there is absolutely nothing that we will be able to do as a regulatory matter to prevent the deployment of these devices, or to prevent the noise levels that will inevitably result in the 2400-2450 MHz band as a result of their use.

   The bands established for higher radiated power Part 15 devices are in the lower, desirable RF spectrum, especially 902-928 MHz, 2400-2483.5 MHz, and 5725-5850 MHz. The 2400-2483.5 MHz band is the band of choice for manufacturers of wireless LANs.

   Interestingly, in the Docket 99-231 proceeding, the concern about the revised SS rules for Part 15 devices was principally focused on interference potential to other Part 15 devices. Indeed, the greatest virtue of Part 15 devices, the accessibility to users, is also the greatest weakness, because there is no limit on the number of devices sharing the spectrum in any given area. Therefore, service quality, not being guaranteed, may not be maintained over time, especially in congested urban areas.

   The problem with 2.4 GHz Part 15 devices is not with unlicensed LAN systems in universities, office parks, or inside buildings where interference levels are predictable and dealt with by standard network design techniques. The problem is where Internet access is the goal, and the system is deployed over a large area, competing with fiber, fixed broadband wireless, DSL, cable modems and satellites. So far, SS has been the only interference-mitigation and frequency reuse technique among Part 15 users in that band. In the future, increases in ambient noise may dictate changes in interference rejection techniques in equipment.

   There is no formal mechanism in place, either at the FCC or in the private sector, for resolving interference disputes among users of Part 15 spectrum. Part of this is essentially definitional: Part 15 devices are not protected from interference at all, whether from a licensed service or from another unlicensed device. However, in the NII proceeding involving the 5 GHz band, WINForum suggested interference mitigation techniques as part of a spectrum sharing proposal, sort of "rules of the road". The FCC refused to accept the suggestion, claiming that such rules would only delay access to the NII bands. There is nothing precluding voluntary coordination programs in the private sector, however, and it's always possible that some organization may decide to implement one.

   There is no instance of Part 15 devices precluding any licensed service, or causing any reallocation of spectrum from a licensed service. There is no doubt, however, that there is a tremendous amount of pressure on the 2.4 GHz band coming up from wireless Internet access users, and wireless peripheral devices such as Bluetooth. Amateur use of the band 2400-2450 MHz will be threatened as a practical matter, though not likely as a regulatory matter.

   Ultra-Wideband is perhaps the newest concept in unlicensed devices receiving regulatory attention. While the Department of Defense has used UWB for some time, the proliferation of such devices for commercial purposes is a potential interference source. There will be some regulatory changes in Part 15 adopted pursuant to the presently open docket proceeding (comments are due September 12, and Ed Hare will be providing material for comments in this proceeding). However, it is not anticipated that there will be substantial impact on the Amateur Service, since virtually all radio services stand to be equally affected by UWB and FCC will likely be concerned with protection of licensed radio services in final rules adopted in the proceeding.

   In conclusion, it is clear that Amateur Radio has significant competitors for use of spectrum that has for long been considered a spectrum reserve for our future use. ARRL needs a clear, decisive strategy for protecting its present and future interests.

3. Strategic Objectives and Guidance for the Future

   Reviewing the material presented thus far one is tempted to throw in the towel. There are a large number of systems using spectrum that we have for many years considered to be ours, and ours alone. These systems are quite legal and there is little likelihood that they will go away of their own accord. Bluetooth is spreading worldwide and will be present in virtually every corner of the nation within a matter of a year or two.

   What's to be done? Can anything be done?

   Surprisingly, there are answers to those two questions, in the opinion of this committee, defined in the paragraphs to follow.

   1. Strategic Objectives

      First of all, we must develop clearly stated objectives. Those objectives must be reasonable and achievable. We have identified the following three strategic objectives.

      O1) - Preserve and protect Amateur access to Amateur frequencies.

      This almost goes without saying, but it is such an important objective that it bears repetition: we must preserve and protect Amateur access to Amateur frequencies! Without frequency allocations and access to them we cannot exist.

      O2) - Continue our productive sharing arrangement with compatible services, such as the military and certain unlicensed (Part 15) devices, and seek out and cooperate with other good sharing partners.

      We do have workable sharing arrangements with others. Government users in the 70 cm band and some periodic radiators, operating under Part 15 are two examples. We should work to ensure that the inevitable sharing partners understand we are there and work to mitigate the mutual interference.

      O3) - Enhance the real and perceived value of the Amateur Radio service to the FCC, to industry and to the public.

      This again is an objective that goes without saying, but we can do better. There are also some specific activities, discussed below, that will contribute the achieving Objective O3.

   2. Guidance for the Future

      A number of recommendations are given in this section. The specific Objective which each recommendation supports is indicated following subsection title.

      0. Monitoring (O1, O2)

         We believe that an ongoing program is needed and should be created to monitor technical and regulatory developments related to the operation of both unlicensed and licensed non-Amateur transmitters in our bands. Such monitoring is presently carried out in a variety of locations within ARRL, primarily the General Counsel's Office, our Washington, DC Office, HQ staff, especially the laboratory, and the RFI Task Group. We believe that some form of coordination of these existing efforts is necessary, and that they be increased in scope by means of additional volunteer personnel. Exactly how that coordination should take place is currently unknown. For the time being, until a long-term solution is defined, we believe that the task could be carried out by this committee, the Ad Hoc Spectrum Strategy Committee.

         Appendix A.2 of this report contains a table listing more of the major industry alliances, trade groups and what (if any) our current relationship is with them.

         In conclusion, this Committee strongly recommends that an activity for monitoring technical developments in the industry be initiated. The first step is to develop a detailed plan of action. The Committee strongly recommends that this plan be developed and that the plan be followed by implementation of the monitoring activity.

      1. Strategic Partnering (O1,O2)

         Sharing of our bands is inevitable. The FCC is convinced that sharing is necessary, and we can therefore expect challenges in the future. We have had a great deal of experience in sharing our bands with others, and it reflects very favorably on Amateur Radio that we can do so. Actually, it may be a double-edged sword for us: our history of successful sharing may itself cause others to seek us out as sharing partners. Our challenge is to find compatible partners rather than let an activity be foisted upon us that we know to be incompatible at best, and possibly completely destructive at worst.

         In addition to seeking out sharing partners, we need to seek out strategic alliances with other Amateur organizations. The work to be done is quite overwhelming, too much for ARRL to carry out alone.

         There exist a variety of amateur organizations that we should seek to maintain a relationship with for the purpose of sharing information, ideas and strategies. The committee has identified these as particularly relevant to our current objectives. Our current relationships with TAPR and AMSAT should be maintained and strengthened from a strategic standpoint. There exists a variety of boutique organizations with more specific interests that would most likely be very helpful to ARRL and Amateur Radio in the long run, not merely as affiliated clubs, but as partners in helping to ward off those who think our spectrum is ripe for the picking. Candidates that should be considered include AMRAD, the Central States VHF Society, Mt Airy VHF Radio Club, North East Weak Signal Society, and the San Bernardino Microwave Society among others. There are other groups who have an awareness of the impact of commercial development on our spectrum including various ATV groups and contest clubs. Liaisons with these organizations can (and should) be pursued at little or no cost to the ARRL and may serve as a tremendous resource of qualified volunteers for such projects as a noise study (that this committee urgently recommends).

      2. Education (O3)

         Although ARRL provides information to its members about sharing partners on the Amateur bands, there nevertheless still is a general lack of knowledge among most Amateurs regarding our true status in many bands above 30 MHz. For example, it is very common to hear Amateurs refer to the 70 cm band as "our" band, even though Amateur Radio not only shares that band with radiolocation services, but even has secondary status and is not protected from interference from radiolocation transmitters. Furthermore, the fact that we also share many of our bands with unlicensed services, is also not well known.

         If we are to enlist Amateurs to help in the protection of Amateur spectrum, those Amateurs need to understand how spectrum is allocated and shared. It is important for amateurs to be reminded that a clear, interference-free channel is never guaranteed. We must tolerate a certain amount of interference from other users and should avoid operating in such a way as to diminish the access by others. We should also bear in mind that if our allocation is secondary and another service has a primary allocation, we should not interfere with the primary user. We believe that ARRL must promote a better understanding of spectrum issues within the amateur community.

         ARRL must also think past amateurs when considering education. It is equally important that we educate the FCC and industry as to the intrinsic value of the Amateur Radio Service. The accomplishments of Amateur Radio should be given wide press, to help ensure that our regulators and those with whom we serve on committees, or those that are on opposite sides of regulatory positions, understand that Amateur Radio is continuing to make contributions to the radio art. It is no longer enough to do good works; in today's information age, it is important that we hold up the light of Amateur Radio, to justify the value of the spectrum we are given.

      3. Increase Amateur Band Occupancy Above 30 MHz (O1)

         Government spectrum managers tend to rely on engineering studies to determine where sharing is possible. They often resist band occupancy measurements as they show only snapshots of usage, do not reveal long-term patterns, fail to reflect receivers guarding emergency channels, and cannot reflect the relative importance of various uses.

         Band occupancy should be regarded in terms of time, bandwidth and location. Because of the growing scarcity of spectrum, those new uses occupying a band most of the time and in most locations may be given more access to spectrum than those who do not.

         ARRL should aggressively pursue means for increasing activity above 30 MHz, and especially above 450 MHz. This must include matters such as conversion of commercially available equipment to Amateur purposes, the promotion of commercially available equipment, the popularization of activities that can be served well on the UHF/SHF bands, such as high speed data links, and support of selected Amateur initiatives.

      4. Compatibility Testing (O1,O2)

         We believe that testing should be encouraged, especially on-air testing of compatibility between Part 15 devices and unlicensed networks and systems and amateur operations and devices.

         Compatibility issues can be best addressed or resolved in certain cases by field or operational tests. Short of actual tests, we should plan to exchange with Part 15 manufacturers or a responsible industry organization the technical characteristics of amateur systems and of Part 15 networks and devices, to determine compatibility without actual testing.

      5. Aggregate Noise Level Study (O1,O2,O3)

It is our understanding that the FCC has no empirical data to determine the appropriate emissions for Part 15 devices, and in general the ambient noise levels in various bands. Knowing whether those noise levels are on the increase, decrease, or that they are stable would help FCC determine whether their regulations governing Part 15 devices are too liberal, too conservative, or appropriate as-is. Such studies have been considered for some time by the FCC's Technological Advisory Council (TAC), and ARRL has been told informally that help from the Amateur community would be welcomed. Such help would require participating Amateurs to have calibrated receivers, and all work would need to be performed in accordance with a carefully prepared test plan, and carefully coordinated by ARRL.

The severity of ambient noise levels caused by Part 15 devices in Amateur bands is an issue of extreme importance. This Committee believes that a cooperative effort with TAC is desirable.

3.2.6Mitigation Techniques (O1,O2,O3)

Amateur microwave allocations are generally shared with other radio services, and applications such as low-power devices and ISM. The trend is toward greater sharing and more intensive use of new applications. Amateurs can improve compatibility between amateur and other systems, and mitigate interference through technical and operational means. Among the approaches that might prove to be useful are frequency separation, spatial separation, time separation, and signal separation. For example,

• Frequency Separation includes techniques as band segmentation, i.e., band planning (to avoid conflicts with other users); dynamic real-time frequency selection; spectrum shaping and bandwidth limitations including control of unwanted emissions; and dynamic bandwidth adjustment according to available spectrum.
• Spatial Separation includes geographical sharing; antenna polarization discrimination; antenna pattern or angle discrimination; and adaptive (smart, beam-forming) antennas. Adaptive antennas could clearly play a role here.
• Time Separation includes consideration of time usage patterns and duty cycle control.

And, finally,

• Signal Separation includes robust signal coding capable of tolerating interference; adaptive signal processing for interference rejection; error control such as forward error correction (FEC) and automatic repeat request (ARQ) techniques; access techniques such as spread spectrum; limiting power to that required for the quality of service, including automatic power control (APC).

In addition, software designed radios may also prove to be useful in mitigating interference.

The above examples are not necessarily comprehensive, but they do suggest that mitigation techniques deserve investigation and may result in the recovery of the use of spectrum that would otherwise be lost.

7. Regulatory Approaches (O1)

   While Part 15 devices have "no vested or recognizable right to continued use of any given frequency by virtue of prior registration or certification of equipment", 47 C.F.R. § 15.5(a), and while any Part 15 device (whether an intentional, unintentional or incidental radiator) is subject to the conditions that no harmful interference is caused and interference to the device must be accepted if caused by operation of an authorized radio station (or another Part 15 or Part 18 device), 47. C.F.R. §15.5(b), the practicalities of interference resolution are such that interaction between amateur stations and Part 15 devices are increasingly prevalent and difficult to resolve after the fact. Section 15.15(c) of the FCC rules acknowledges this:

   Parties responsible for equipment compliance should note that the limits specified in this part will not prevent harmful interference under all circumstances. Since the operators of Part 15 devices are required to cease operation should harmful interference occur to authorized users of the radio frequency spectrum, the parties responsible for equipment compliance are encouraged to employ the minimum field strength necessary for communications, to provide greater attenuation of unwanted emissions than required by these regulations, and to advise the user as to how to resolve harmful interference problems.

   While the foregoing are encouraging admonishments, they are no more than that, and have no practical enforceability. Rather, they have the effect of acknowledging the inevitable interaction between licensed and unlicensed devices in spectrum used by both.

   There is a cautionary instruction to manufacturers in Section 15.17 of the Rules, to the effect that high power Amateur, government, broadcast and other stations operate in certain bands, and that manufacturers should consider this when designing equipment. However, that pertains only to interference susceptibility of Part 15 devices.

   The most utilitarian administrative regulation applicable to Part 15 devices from the Amateur's perspective is the labeling requirement for Part 15 devices. The label, for devices other than receivers, must read as follows:

   This device complies with part 15 of the FCC Rules. Operation is subject to the following two conditions: (1) This device may not cause harmful interference, and (2) this device must accept any interference received, including interference that may cause undesired operation.

   The reason this is useful is because the complaining neighbor of an amateur with an RF-susceptible Part 15 device can be referred to the label of his or her own device for a status report. Because it is not at all intuitively obvious that interference to consumer electronic devices must be accepted, much less that the device cannot be used by the consumer if it causes "harmful interference" to a licensed radio amateur, the label language is the best defense an amateur has in a Part 15 interaction situation.

   Nevertheless, there is no regulatory protection against aggregate noise from Part 15 devices, to the extent that, due to the deployment of large numbers of Part 15 devices, the operating environment is degraded. The only regulatory protection that exists for amateurs is from individual devices. There are no regulatory limitations on aggregate noise levels from Part 15 devices. In theory, the radiated emission limitations are set low enough that there will not be interference to licensed radio services, either from individual devices, or in the aggregate. However, because of the absence of limitations on aggregate noise, there is absolutely nothing that amateurs will be able to do as a regulatory matter to prevent the deployment of large numbers of Part 15 devices, or to prevent the noise levels that will likely result in the 2400-2450 MHz band as a result of their use.

   Part 15 devices enjoy an environment of regulatory accommodation at FCC for several reasons. First and foremost, consumer demand necessitates that the FCC accommodate new electronic devices. If the public demands the products, the FCC must, in order to fulfill its statutory duty, find a way to accommodate them. Demand is also enhanced by the reduced cost of the devices relative to RF products which must be operated by a licensed end user. One major element of the reduced cost is the freedom from the time and expense associated with obtaining wireless licenses, either in the marketplace, or through auctions. This has provided a huge incentive to deploy systems designed for Part 15 unlicensed architecture, rather than on a licensed basis. The non-technical end users are best suited to unlicensed operation, where regulatory compliance is not an issue. There is minimal regulatory oversight. Finally, due to the absence of licensing, the devices can be delivered to a wide market quickly.

   The bands established for higher radiated power Part 15 devices are in the lower, desirable RF spectrum, especially 902-928 MHz, 2400-2483.5 MHz, and 5725-5850 MHz. The 2400-2483.5 MHz band is the band of choice for manufacturers of wireless LANs currently. The focus for the past few years on unlicensed RF products has been in the 902-928 MHz and 2400-2483.5 MHz band, although, as is the case with other radio services, there is an upward migration in frequency for newer products and systems. The majority of new devices operating in the 2400-2450 MHz Amateur band (actually the 2400-2483.5 MHz Part 18 band) are SS devices. For years, these devices have been permitted to operate at up to 1 watt output, with directional antennas and substantial antenna gain. Section 15.247 permits 2.4 GHz band frequency-hopped SS devices to operate at 1 watt output, using a minimum of 75 non-overlapping hopped channels with a 20 dB bandwidth not greater than 1 MHz. Average time of occupancy on any frequency must not exceed 0.4 seconds in any 30-second period. A recent FCC decision permits 3 and 5 MHz bandwidths, with 2.5 hops per second, with power reduced to 0.125 watts.

   The problem with 2.4 GHz Part 15 devices is not with unlicensed LAN systems in universities, office parks, or inside buildings where interference levels are predictable and dealt with by standard network design techniques. The problem is where Internet access is the goal, and the system is deployed over a large area, competing with fiber, fixed broadband wireless, DSL, cable modems and satellites. So far, SS has been the only interference-mitigation and frequency reuse technique among Part 15 users in that band. In the future, increases in ambient noise may dictate changes in interference rejection techniques in equipment.

   FCC is not particularly focused on interference to the Amateur Service from Part 15 devices. There is an unwritten assumption at FCC that there is sufficient compatibility between amateur operation in bands in which Part 15 devices, even relatively high power Part 15 devices, may operate, and any type of Part 15 device, so that no regulatory problems require FCC intervention. This assumption stems from the fact that Amateur frequency use is itinerant, and equipment flexible, and both can be modified to take into account or overcome Part 15 noise in a particular band in a particular geographic area. In the Docket 99-231 proceeding, for example, the concern about the revised SS rules for Part 15 devices was principally focused on interference potential to other Part 15 devices. Indeed, the greatest virtue of Part 15 devices, the accessibility to users, is also the greatest weakness, because there is no limit on the number of devices sharing the spectrum in any given area. Therefore, service quality, not being guaranteed, may not be maintained over time, especially in congested urban areas.

   ARRL is regularly obligated to remind FCC of its statutory (jurisdictional) limitations regarding Part 15 devices. The usual context of the need to remind FCC of its jurisdictional limitations in authorizing Part 15 devices is where some manufacturer urges the Commission to "upgrade the status" of Part 15 devices generally, by means of creating a new rule Part (often conceptually termed "Part 16", which does not exist). It would authorize an actual radio service for unlicensed devices which would have interference-protected status. In the past, the Consumer Electronics Group of the Electronic Industries Association and the Part 15 Coalition (now defunct, apparently) each urged some elevation in the allocation status of unlicensed Part 15 devices. The usual argument urges that there should either be an elevation of unlicensed systems to "co-primary" in allocation status with the Amateur Service, or to redefine the parameters under which unlicensed devices are presumed not to cause interference to any service of a higher priority.

   The fact is, Part 15 devices have no allocation status, and have had none, internationally or domestically. They are permitted on an "at-sufferance" basis: they must, by definition, not cause interference to licensed radio services, and they must tolerate interference received from licensed radio services in the same bands. The Communications Act of 1934 is devoid of any reference to FCC authority to accord Part 15 type devices any allocation status at all; the only authority to permit unlicensed devices under the Act is with respect to radio control and citizen's radio service facilities. 47 U.S.C. §307(e). The only provision for Part 15 devices in the Communications Act is for the Commission to regulate the interference potential of such devices by "reasonable regulation". 47 U.S.C. §302. This the Commission has done by permitting operation of such devices in bands allocated, on a primary basis, to one or more licensed radio services, where the operation of the unlicensed devices have been determined to be unlikely to cause interference to the licensed radio service(s).

   The benefits to the manufacturers of such non-licensed devices under the circumstances are several: their products need not be licensed before they can be used by the purchasers thereof; the equipment itself need only be authorized by the Commission by type, pursuant to Part 2 Equipment Authorization requirements; they can operate with some degree of frequency agility and bandwidth variability; and they can be used for an infinite number of purposes, without any eligibility determinations on the part of the user. The devices can be made less expensively, and operated without regulatory effort by the owner. These benefits are at the cost of an absence of any priority in the subject bands relative to licensed radio services. The suggestion of manufacturers that the status of such devices should be "elevated" would be tantamount to a change in the entire conceptual framework of regulation of Part 15 devices: they would be entitled to the benefits of a licensed radio service but without any of the obligations attendant to shared users in shared bands. This is inequitable and ARRL should continue to oppose any such effort, which will likely arise repeatedly in the future.

   There is no formal mechanism in place, either at the FCC or in the private sector, for resolving interference disputes among users of Part 15 spectrum. Part of this, again, is essentially definitional: Part 15 devices are not protected from interference at all, whether from a licensed service or from another unlicensed device.

   There are no specific regulatory strategies which immediately require implementation. ARRL is actively involved in attempting to upgrade microwave allocations from secondary to primary in view of the surrender of those bands by the Federal Government for private sector use. We are now pursuing the upgrade of 2300-2305 MHz and 2400-2402 MHz. We have recently upgraded 2390-2400 MHz and 2402-2417 MHz to primary status. We have investigated and found impractical the upgrade of 5825-5850 MHz, due to perceived NTIA opposition.

   We should remain vigilant for Ultra-Wideband proposals, and other proceedings which would increase power spectral density of Part 15 device operation, or other proceedings which would liberalize operating parameters of Part 15 devices. Finally, we should pursue a requirement that any liberalization of Part 15 operating parameters be based on the results of an aggregate noise study which would provide empirical evidence of the potential impact of a regulatory change on the noise environment in bands used by authorized radio services.

   Finally, the best regulatory strategy is to work with Part 15 manufacturers to arrive at a mutually agreeable set of operating parameters for devices in Amateur allocations. An extremely successful example of this was the negotiation between ARRL and Apple Computer which resulted in the authorization of some unlicensed PCS systems in the 2390-2400 MHz band and a primary allocation for amateurs in that band. FCC is highly motivated to adopt "consent regulations" in these contexts.

8. Research and Special Projects (O1,O2,O3)

In the past several years, the League has undertaken several studies to provide technical support for our regulatory and spectrum-management efforts. These include:

Studies such as these represent only a portion of the work that could be done in support of ARRL's protection of Amateur spectrum.

This Committee recommends no specific new study at this time, other than the Aggregate Noise Level Study discussed briefly in Section 3.2.5, above.

1. Conclusions and Recommendations

   Based upon the data collected in the performance of the study and extensive discussions among Committee members we offer the following conclusions and recommendations.

   1. Conclusions

      C1. There is no question that our assignments above 30MHz are at risk, especially at 2.4 GHz, in the sense that we may lose effective use of our spectrum due to use and congestion by unlicensed Part 15 devices.

      C2. Inadequate data exists to quantify the severity of the challenge.

      C3. Swift and decisive action is required by ARRL in order to reduce our current risks and to prepare for future challenges.

   2. Recommendations.

And in Conclusion

The Committee believes that the emergence of Part 15 devices in large numbers in the consumer market poses a serious threat to our use of some Amateur bands above 30 MHz. In the past Amateur's have exhibited great ingenuity and resiliency when faced by technical challenges. We believe that the present challenges to our use of spectrum at VHF and above is surmountable. However, we believe that decisive leadership by ARRL is and important part of the process Amateur Radio should follow in order to meet those challenges.

Respectfully Submitted,

Jim Maxwell, W6CF, Chairman

Committee members: Dennis Bodson, W4PWF; Art Goddard, W6XD; Ed Hare, W1RFI; Chris Imlay, W3KD; J. P. Kleinhaus, W2XX; Paul Rinaldo, W4RI.

Appendices

Appendix A1 - Authorized Amateur Frequency Bands in the US above

30 MHz, and US Sharing Requirements

The following data are extracted from §97.301 Authorized frequency bands.

The following transmitting frequency bands are available to an amateur station located within 50 km of the Earth's surface, within the specified ITU Region, and outside any area where the amateur service is regulated by any authority other than the FCC.

(a) For a station having a control operator who has been granted a Technician, Technician Plus, General, Advanced, or Amateur Extra Class operator license or who holds a CEPT radio-amateur license or IARP of any class:

Wavelength band	ITU Region 1	ITU Region 2		ITU Region 3	Sharing requirements, see §97.303, paragraph:
VHF	MHz
6 m	--		50-54	50-54	(a)
2 m	144-146		144-148	144-148	(a)
1.25 m	--		219-220	--	(a), (e)
-do-	--		222-225	--	(a)
UHF	MHz
70 cm	430-440		420-450	420-450	(a), (b), (f)
33 cm	--		902-928	--	(a), (b), (g)
23 cm	1240-1300		1240-1300	1240-1300	(h), (i)
13cm	2300-2310		2300-2310	2300-2310	(a), (b), (j)
-do-	2390-2450		2390-2450	2390-2450	(a), (b), (j)
SHF	GHz
9 cm	--		3.3-3.5	3.3-3.5	(a), (b), (k), (l)
5 cm	5.650-5.850		5.650-5.925	5.650-5.850	(a), (b), (m)
3 cm	10.00-10.50		10.00-10.50	10.00-10.50	(b). (c). (i). (n)
1.2 cm	24.00-24.25		24.00-24.25	24.00-24.25	(a), (b), (h), (o)
EHF	GHz
6 mm	47.0-47.2		47.0-47.2	47.0-47.2
4 mm	75.5-81.0		75.5-81.0	75.5-81.0	(b), (c), (h)
2.5 mm	119.98-120-02		119.98-120.02	119.98-120.02	(k), (p)
2 mm	142-149		142-149	142-149	(b), (c), (h), (k)
1 mm	241-250		241-250	241-250	(b), (c), (h), (q)
--	above 300		above 300	above 300	(k)

§97.303 Frequency sharing requirements.

The following is a summary of the frequency sharing requirements that apply to amateur station transmissions on the frequency bands specified in §97.301 of this Part. (For each ITU Region, each frequency band allocated to the amateur service is designated as either a secondary service or a primary service. A station in a secondary service must not cause harmful interference to, and must accept interference from, stations in a primary service. See §§2.105 and 2.106 of the FCC Rules, United States Table of Frequency Allocations for complete requirements.)

(a) Where, in adjacent ITU Regions or Subregions, a band of frequencies is allocated to different services of the same category, the basic principle is the equality of right to operate. The stations of each service in one region must operate so as not to cause harmful interference to services in the other Regions or Subregions. (See ITU Radio Regulations, No. 346 (Geneva, 1979).)

(b) No amateur station transmitting in the 1900-2000 kHz segment, the 70 cm band, the 33 cm band, the 13 cm band, the 9 cm band, the 5 cm band, the 3 cm band, the 24.05-24.25 GHz segment, the 76-81 GHz segment, the 144-149 GHz segment and the 241-248 GHz segment shall cause harmful interference to, nor is protected from interference due to the operation of, the Government radiolocation service.

(c) No amateur station transmitting in the 1900-2000 kHz segment, the 3 cm band, the 76-81 GHz segment, the 144-149 GHz segment and the 241-248 GHz segment shall cause harmful interference to, nor is protected from interference due to the operation of, stations in the non-Government radiolocation service.

(d) No amateur station transmitting in the 30 meter band shall cause harmful interference to stations authorized by other nations in the fixed service. The licensee of the amateur station must make all necessary adjustments, including termination of transmissions, if harmful interference is caused.

(e) In the 1.25 m band:

(f) In the 70 cm band:

(g) In the 33 cm band:

(h) No amateur station transmitting in the 23 cm band, the 3 cm band, the 24.05-24.25 GHz segment, the 76-81 GHz segment, the 144-149 GHz segment and the 241-248 GHz segment shall cause harmful interference to, nor is protected from interference due to the operation of, stations authorized by other nations in the radiolocation service.

(i) In the 1240-1260 MHz segment, no amateur station shall cause harmful interference to, nor is protected from interference due to the operation of, stations in the radionavigation-satellite service, the aeronautical radio-navigation service, or the radiolocation service.

(j) In the 13 cm band:

(k) No amateur station transmitting in the 3.332-3.339 GHz and 3.3458-3525 GHz segments, the 2.5 mm band, the 144.68-144.98 GHz, 145.45-145.75 GHz and 146.82-147.12 GHz segments and the 343-348 GHz segment shall cause harmful interference to stations in the radio astronomy service. No amateur station transmitting in the 300-302 GHz, 324-326 GHz, 345-347 GHz, 363-365 GHz and 379-381 GHz segments shall cause harmful interference to stations in the space research service (passive) or Earth exploration-satellite service (passive).

(l) In the 9 cm band:

(m) In the 5 cm band:

(n) In the 3 cm band:

(o) No amateur station transmitting in the 1.2 cm band is protected from interference due to the operation of industrial, scientific and medical devices on 24.125 GHz. In the United States, the 24.05-24.25 GHz segment is allocated to the amateur service on a co-secondary basis with the non-government radiolocation and Government and non-government Earth exploration-satellite (active) services.

(p) The 2.5 mm band is allocated to the amateur service on a secondary basis. No amateur station transmitting in this band shall cause harmful interference to, nor is protected from interference due to the operation of, stations in the fixed, inter-satellite and mobile services.

(q) No amateur station transmitting in the 244-246 GHz segment of the 1 mm band is protected from interference due to the operation of industrial, scientific and medical devices on 245 GHz.

Appendix A.2 - Amateur Radio Usage of VHF and Higher Frequency Bands

Through its utilization of allocated frequency bands above 30 MHz, Amateur Radio continues to add to an outstanding record of public service, radio communications training and technical achievement. Beginning as early as 1924, with an equipment construction article in QST, Amateur Radio has led the way in extending our knowledge of the radio spectrum at VHF and above (ref 1). Amateur Radio is unsurpassed in its ability to extend the limits of low-cost, long-distance communications systems using frequency bands originally thought to be limited to local line-of-sight.

Between 1982 and 1988, the FCC reduced the VHF/UHF spectrum available to the Amateur Radio Service by 107 MHz. Amateur Radio user groups scrambled to revise band plans and re-coordinate users within the remaining allocations. This experience demonstrates that, at least in the major metropolitan areas, there is significant utilization of the VHF and lower UHF bands. In the Los Angeles basin, it took more than 5 years to coordinate the existing repeaters into the reduced 222-225 MHz band. Nevertheless, Radio Amateurs maintained a wide variety of uses in the spectrum above 30 MHz, as summarized in Table 3.1-1.

Table A.2-1 Amateur Radio Usage of Frequency Bands above 30 MHz

A more detailed breakout of Amateur utilization by frequency band is listed below. Note that many of the uses depend on relatively low noise levels at the receiving antenna. As noise levels rise, perhaps due to the proliferation of Part 15 devices in the vicinity of the receiving antenna, Amateur band utilization is made more difficult. At best, amateurs will have to use more power or higher-gain antennas to offset the noise levels. At worst, certain Amateur operation may be impossible in the presence of noise levels. A more complete description of each amateur band is found among the files that are at http://www.arrl.org/~ehare/refcir/refcir.zip.

Table A.2-2 Common Amateur Radio Usage of Frequency Bands above 30 MHz, by Band

(Note: Other usage exists, but this represents operation that has been extensively reported or documented.)

Band	SSB	CW	FM	Repeater	Digital	EME	Satellite	ATV	Beacon	Additional Comments
50-54 MHz:	X	X	X	X	X	X			X	Coverage is better in hilly terrain than 2 meters Popular for radio controlled models--commercial equipment is available Very popular for propagation beacons Used lightly for digital operation, although it does have significant advantages for some applications, such as meteor scatter
144-146 MHz:	X	X	X	X	X	X	X		X	Used sporadically for hang-glider communication. Popular for propagation beacons (30 USA beacons are listed on the list maintained by KB2VGH at http://www.qsl.net/kb2vgh/Beacons/144-beacons.txt). Most-used band for foxhunting in the USA
219-220 MHz:					X					18 stations are registered to use this band for high-speed digital backbone connections.
222-225 MHz:	X	X	X	X		X		X	X	About a dozen beacons (10 on kb2vgh list)
420-450 MHz:	X	X	X	X	X	X	X	X	X	Significant SSB and FM activity Some CW activity during band openings and contests This is the most popular ATV band
902-928 MHz:	X	X	X	X	X			X	X	Significant SSB and FM activity Some CW activity during contests Some ATV activity A few stations on EME About a dozen beacons. Usage of this band is hampered by the lack of commercial equipment.

Table A.2-2 (Continued) Common Amateur Radio Usage of Frequency Bands above 30 MHz, by Band

Band	SSB	CW	FM	Repeater	Digital	EME	Satellite	ATV	Beacon	Additional Comments
1240-1300 MHz	X	X	X	X	X	X	X	X	X	Significant SSB and FM activity. CW activity during contests Some ATV activity
2300-2310 MHz 2390-2450 MHz:	X	X	X	X		X	X	X	X	Growing popularity for ATV use, as 70 cm is too crowded in some areas.
3300-3500 MHz:	X	X				X			X	Some SSB and CW activity during contests Occasionally used for EME 4 known beacons
5650-5925 MHz:	X	X					X	X	X
10-10.5 GHz:	X	X	X		X	X	X	X	X	Two affordable SSB/CW transverters in the past year should help even more.
24-24.25 GHz:	X	X	X							A lot of people are working to build SSB/CW equipment for this band using surplus transmit/receive converters that have recently become available. The Packrats have a project to build 30 1-watt amplifiers (they have takers for more, but would need to obtain more gratis parts). Some WBFM activity. Some people are busy attempting to build gear for EME.
47-47.2 GHz	X	X	X							Perhaps the highest band in which you can buy easily useable commercial gear. Mostly Some SSB/CW activity. Some FM activity.
75.5-81 GHz:										[TBD]
119.98-120.02 GHz:
142-149 GHz:
241-250 GHz:
Light:										Somewhat popular, as lasers have gotten to be relatively inexpensive. Some experimentation with cloud scatter (over the horizon work) and non-coherent light sources.

Appendix A.3 - Standards Bodies and Industry Groups

The following represent various standards bodies and industry groups that ARRL should consider maintaining regular contact with. This may require a combination of additional volunteer resources and additional staff time for coordination and staff travel.

Table A3-1 Standards Bodies and Industry Groups

Organization	Description	Present contact	Notes
Alliance for Telecommunications Industry Solutions T1E1.4 http://www.atis.org/ http://www.atis.org/atis/committe.htm http://www.t1.org/html/org.htm	VDSL standards	RFI TG	ARRL has presented papers to this standards process - their present drafts include protection to the HF ham bands.
IEEE/ANSI C63, IEEE C63 - Accredited Standards Committee on Electromagnetic Compatibility http://c63.ieee.org/	RFI standards for consumer equipment, medical equipment, Open-area test site (OATS) standards	RFI TG	ARRL should maintain an active presence on this committee
APCO Project 25 http://www.apcointl.org http://www.apcointl.org/project25/p25.html	Public-service-agency communications		Technical standards for public-service communications specifications
Bluetooth http://www.bluetooth.com	Home consumer equipment interconnectivity	RFI TG	Right now, primarily 2.4 GHz ISM
CISPR	International standards coordination	Technical Relations Office via IARU
Consumer Electronics Association http://www.ce.org/index.asp	(former EIA)	ARRL Lab	This organization concerns themselves with a wide range of issues, but ARRL is primarily concerned with RFI matters
Consumers Union http://www.consumersunion.org/	Consumer Reports		No useful contact established. ARRL has attempted such contact in the past.
FCC TAC	FCC	Dewayne Hendricks	Should ARRL seek formal membership? More reporting of Hendricks' activities recommended.

Table A3-1 (Continued) Standards Bodies and Industry Groups

Organization	Description	Present ARRL contact	Notes
FCC http://www.fcc.gov	FCC	Various	There are many unexplored opportunities for better staff-to-staff contact with the FCC. Examples include more in-person meetings with OET staff and the Call Center in Gettysburg, PA.
Home Phone Networking Alliance http://www.homepna.org/	Home networking using residential telephone wiring.	RFI TG	ARRL very instrumental in persuading them to include protection for 40 M ham band
HomePlug http://www.homeplug.org/	Home networking over power lines	ARRL Lab	They are working with ARRL on the best ways to implement protection for amateur radio into their industry specification.
HomeRF http://www.homerf.org/	RF networking standards	RFI TG
International Telecommunication Union http://www.itu.int/	Numerous international standards and regulations	Technical Relations Office
National Cable Television Association http://www.ncta.com/	Cable TV	ARRL Technial Advisor	Communication with the NCTA needs to be improved
Society of Automotive Engineers EMI Standards Committee and the EMR Standards Committee http://www.sae.org	Automotive RFI	RFI TG	ARRL staff have been "corresponding" members only, in-person attendance of some meetings is recommended. Steffka attends regularly.
Society of Telecommunications Engineers http://www.scte.org/	Cable TV	RFI TG	Cable TV RFI
Wireless Communications Association International http://www.wcai.com/	Wireless Broadband	.	WCAI publishes a number of trade journals. These should be monitored by ARRL HQ staff.

Appendix A.4 - Amateur Radio Organizations

Appendix A.4

Amateur Radio Organizations (Continued)

VHF and up Contest Societies
Delmarva VHF and Microwave Society and the Grid Pirates Contest Group	http://www.k8gp.net/index-gp.html
Mount Greylock Expeditionary Force	http://www.mgef.org/
ATV Societies
Arizona Amateurs on Television	http://www.qsl.net/aatv/
Amateur Television in Southern Ohio	http://www.radio-amateurs.com/
Atlanta Amateur Television Society	http://www.bsrg.org/aatn/aatn1.html
Badgerland Amateur Television Society	http://www.shopstop.net/bats/
Baltimore Radio Amateur Television Society	http://www.bratsatv.org/
Blue Ridge Video and Digital Society	http://www.roava.net/~bvds.org/
Clear Lake Amateur Radio Club	http://www.clarc.org/atv.htm
Coastal Amateur Television Society	http://home.att.net/~g.grady/cats.htm
Detroit Amateur Television Society	http://www.icircuits.com/dats/dats.htm
Houston Amateur Television Society	http://www.hats.stevens.com/
Klamath Amateur Television	http://www.jones-clan.com/amateur_radio/Klamath_Amateur_Televis