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 Previous: A QRP Christmas |  Next: Live SSTV Transmitted From Mir |
NEWINGTON, CT, Dec 16, 1998--The ARRL has filed comments with the FCC in two proceedings that it says could lead to greater interference to amateurs.
The League expressed "continued strenuous opposition" to an FCC proposal to revise Part 15 of the rules to permit unlicensed, point-to-point transmitters in the 24.05 to 24.25 GHz band at field strengths of up to 2.5 V per meter, measured at 3 meters. Amateur Radio has an allocation at 24.0 to 24.25 GHz.
In September, the FCC released a Notice of Proposed Rule Making in ET Docket 98-156, in response to a petition from Sierra Digital Communications Inc. The company wants to market point-to-point microwave devices. The ARRL already had commented on the Sierra Digital Petition for Rule Making. It called the FCC's proposed rules changes "entirely inappropriate for Part 15 unlicensed facilities."
The League said the Commission considered and denied a petition in 1983 to permit unlicensed, uncoordinated, point-to-point microwave operation in the 24-GHz band. The recent petition amounts to "the exact same proposal," the League said. At the time, the League said, the FCC "realized that licensing was necessary for such devices; no unlicensed operation was permitted at 24 GHz, due to interference potential." The current proposal offers nothing to depart from that position, the League concluded.
The ARRL also said the FCC is "without jurisdiction" to allow operation of unlicensed, point-to-point microwave devices that have "significant interference potential to licensed services in the same band." Such Part 15 devices have "no allocation status, internationally or domestically." Part 15 devices may not cause interference to other, licensed services and must accept interference from licensed band occupants.
The League said that a substantial amount of terrestrial amateur weak-signal activity centered around 24.192 GHz utilizes sensitive receivers. "This microwave band, and the 10-GHz band, are the two most heavily utilized amateur microwave bands above 2.5 GHz," the ARRL said. The League pointed out that the Phase 3D satellite, which plans to make use of the satellite band (24.0 to 24.05 GHz), requires extremely sensitive receivers. Sierra wants access to that band, but the FCC has not proposed authorizing them to use it.
The League said it's obvious that "there are substantial interference contours created by the proposed Part 15 devices, and there has not been stated any means of avoiding interference, or resolving it when it is experienced."
If the proposal goes forward, the League asked the FCC to require extensive record keeping of purchasers, locations, frequencies, emissions, bandwidths, path lengths and azimuths, antenna gain and height, and to furnish the lists to the League periodically for coordination purposes. The ARRL asked that require the frequency of a device to be changed to resolve interference incidents or to terminate the path when interference cannot be resolved. The League also asked the FCC to assure that it will act on complaints that cannot be easily resolved by shutting down the device.
The League also commented in response to a Notice of Inquiry, in ET Docket 98-153, about whether the FCC should revise Part 15 to allow ultra-wideband (UWB) transmission systems. Such systems, operating in the VHF and UHF spectrum, include applications like radar, voice, data, and control communications devices. The League expressed concerns that Amateur Radio and home entertainment devices, including TV sets, could be subjected to interference from the Part 15 UWB devices.
The League proposed that the Commission ask manufacturers of UWB devices to develop and circulate technical standards "in support of a unified, comprehensive plan." The League also offered its services to help determine proper technical regulations.
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