On April 22, 1998, the Land Mobile Communications Council (LMCC) filed a petition for rulemaking with the Federal Communications Commission to have two-thirds of the 420-450 MHz band (70 cm) reallocated to the Private Mobile Radio Service. The petition is designated RM-9267, and the FCC is accepting public comment until June 1, 1998. The ARRL opposes the LMCC proposal. The 70 cm band is very popular among radio amateurs, and plays a critical role in our ability to provide emergency, public service, and public interest communications. The ARRL believes that the LMCC proposal is incompatible with continued amateur use of the band. RM-9267 is still only a proposal, and has not been acted upon by the government. We need your help in communicating our concerns to policy makers as they consider how to handle the LMCC's request.
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RM-9267 News and Background Information
RM-9267 Resources
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The Land Mobile Communications Council (LMCC) is a non-profit association of organizations representing users of land mobile radio systems, providers of land mobile services, and manufacturers of land mobile radio equipment. The user community includes public safety, business, industrial, private, common carrier, and land transportation radio users. The membership of LMCC includes the following organizations:
Association of American Railroads (AAR)
American Association of State Highway and Transportation Officials (AASHTO)
American Automobile Association (AAA)
American Mobile Telecommunications Association (AMTA)
American Petroleum Institute (API)
American Trucking Associations, Inc. (ATA)
Association of Public Safety Communications Officials - International, Inc. (APCO)
Cellular Telecommunications Industry Association (CTIA)
Central Station Alarm Association (CSAA)
Forest Industries Telecommunications (FIT)
Forestry-Conservation Communications Association (FCCA)
Industrial Telecommunications Association, Inc. (ITA)
Intelligent Transportation Society of America (ITSA)
International Association of Fire Chiefs (IAFC)
International Association of Fish and Wildlife Agencies (IAFWA)
International Municipal Signal Association (IMSA)
International Taxicab and Livery Association (ITLA)
Manufacturers Radio Frequency Advisory Committee (MRFAC)
National Association of State Foresters (NASF)
Personal Communications Industry Association (PCIA)
Telecommunications Industry Association (TIA)
UTC, The Telecommunications Association (UTC)
List of LMCC member organization addresses
In response to a provision of the 1993 Omnibus Budget Act calling for regulatory parity among wireless Common Carriers and certain private wireless licensees that were providing service that was substantially similar to Common Carrier Service, the FCC developed separate definitions for Commercial Mobile Radio Services (CMRS) and Private Mobile Radio Services (PMRS). LMCC members mainly are interested in PMRS. They claim that the FCC is favoring CMRS over PMRS because CMRS licenses can be auctioned, generating substantial revenues for the Federal Treasury.
Based on its own spectrum requirements analysis, LMCC claims that the future additional spectrum needs of the PMRS community are as follows: 15 MHz by the year 2000, 44 MHz (i.e., another 29 MHz) by 2004, and 125 MHz (i.e., another 81 MHz) by 2010. It proposes:
Immediate needs be satisfied by a reallocation of 420-430 MHz, paired with 440-450 MHz, from Federal use to PMRS;
Immediate/mid-term needs be satisfied by FCC allocation of 1390-1400, 1427-1432, and 1670-1675 MHz to PMRS, pursuant to its reallocation to the private sector from the government;
Reallocate 85 MHz of the aeronautical band, 960-1215 MHz, to the PMRS by the year 2010 to satisfy longer term needs, shared with the developing DOD JTIDS/MIDS service.
At present in the United States, the Amateur Radio Service is secondary to military radiolocation (radar) in the 420-450 MHz band. Originally a primary allocation, secondary status came about during the 1950s when Cold War concerns made national security a high priority. Limited non-government, non-amateur use of the band is permitted -- but amateurs have priority over such use. LMCC misinterprets the significance of amateur secondary status and states that "Amateur applications in the 420-430/440-450 MHz should remain secondary to PMRS." LMCC also suggests the possibility that, "recognizing that amateur radio service will see a net constriction by the recommended reallocation of 420-430/440-450 MHz," 1390-1395/1427-1432 MHz might be allocated to the amateur service to offset this constriction. "Constriction" is, of course, a bit of an understatement; LMCC has offered no ideas as to how amateurs could continue to share the bands.
First, what you shouldn't do: Don't complain to your Congressman about the FCC, or write a nasty letter to the FCC. The LMCC petition is a private-sector initiative, not a government proposal. By law, the FCC has to put the petition on public notice and invite comment. That's all the FCC has done with it. Criticizing the FCC at this stage would be inappropriate and counterproductive.
Here is what you should do.
1. Examine the list of LMCC members. You may be a member of one or more of these organizations. If you are, write to that organization as a member and inform them that the LMCC, which has listed them as a member and supporter, has taken an action that is contrary to your interests. Don't assume that they know anything about the petition or its implications for Amateur Radio, but do make it clear that as a member, you expect them to disavow the LMCC petition insofar as it affects Amateur Radio. A sample letter is attached.
2. Prepare a comment on RM-9267 and submit it to the FCC. At the top, it is very important that you clearly indicate the file number: RM-9267. Send an original and four copies to: Office of the Secretary, Federal Communications Commission, Room 222, 1919 M Street NW, Washington, DC 20554.
In your comment, explain how the loss of access to the 420-430/440-450 MHz band segments would affect you personally, and how it would affect the ability of radio amateurs in your community to provide needed public service. Even if you do not use these segments yourself, it is likely that loss of access would result in more crowding and interference in the part of the band, or in another band, that you do use. Don't overlook the fact that if you use linked voice or packet systems, it is quite likely that some of the links you rely on are in either or both of these segments.
3. If you are involved in amateur radio public service communications, arrange for the government and non-government agencies that you serve and ask for a written statement of their support.
4. Arrange for any Amateur Radio organizations that you belong to, to submit comments. This is especially important in the case of organizations with interests in the 420-450 MHz band.
The primary occupant of the 420-450 MHz band is the military. Before the FCC can take the next step toward reallocation, it must first obtain the agreement of the federal government. Then it would have to issue a Notice of Proposed Rule Making and must solicit public comments on its proposal. In other words, nothing is going to happen overnight and there will be at least one more opportunity for public comment.
The threat must be regarded as very serious. The LMCC is a bona fide and respected organization. We must assume that their proposal will be taken seriously.
The petition, with attachments, is 72 pages. It is available here as an Adobe Portable Document Format (PDF) file.
ARRL, 225 Main Street, Newington, CT 06111 USA