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 Previous: In Brief |  Next: Congressman Weighs In on CC&R Effort |
NEWINGTON, CT, Oct 18, 2000--FCC Special Counsel for Amateur Radio Enforcement Riley Hollingsworth used the occasion of an enforcement letter to commend the value of band plans. "Although band plans are not mandatory, they exist to enhance the required cooperation and sharing of frequencies in the Amateur Service," Hollingsworth said in an enforcement inquiry to a Connecticut ham.
The FCC wrote Advanced licensee Alan J. Koepke, K1JCL, on October 11, 2000, citing complaints received by the Commission alleging that Koepke was operating an uncoordinated AM-mode repeater on 144.65 MHz that was causing interference to coordinated repeaters in Massachusetts and New York using that frequency as an input. "Evidence indicates that you have been coordinated, but not for that frequency configuration," Hollingsworth wrote.
The ARRL Repeater Directory indicates that the Connecticut Spectrum Management Association coordinated the K1JCL 2-meter machine for output on 145.25 MHz and a 600-kHz negative offset input. The K1JCL 145.25 MHz repeater does not appear in a list of 144-MHz repeaters on the CSMA Web site, although a K1JCL machine is shown at 147.375 MHz.
Hollingsworth says Koepke apparently has flipped the input and output frequencies for which his 2-meter repeater was coordinated, contrary to the prevailing band plan. In addition, Hollingsworth said, Koepke has been using a non-standard spacing that may be contrary to its coordination. He has asked Koepke to explain.
"A repeater operating contrary to coordination is an uncoordinated repeater," Hollingsworth told Koepke. Citing §97.205 of the rules, Hollingsworth said that where there is interference between a coordinated and an uncoordinated repeater, "the licensee of the uncoordinated repeater has the responsibility to resolve the interference." According to reports filed with the FCC, Koepke has been made aware of the conflict but has declined to resolve it, Hollingsworth said.
"Band plans minimize the necessity for Commission intervention in Amateur operations and the use of Commission resources to resolve amateur interference problems," Hollingsworth wrote in expressing the FCC's position on band plans. "When such plans are not followed and harmful interference results, we expect very substantial justification to be provided, and we expect that justification to be consistent with Section 97.101."
Hollingsworth said he included the statement to reiterate where the FCC stands on the question of band plans. "You can't possibly have a rule for every circumstance," he said. Operating in according with prevailing band plans "minimizes the necessity of the Commission to get involved in these situations" where interference results.
Last December the FCC dismissed an ARRL petition calling on the Commission to equate observance of voluntary band plans with "good amateur practice." The FCC declined, suggesting that it was reluctant to expand its regulatory role beyond the existing limits on emission types that may be transmitted within a given subband. The Commission said defining band plans as the ARRL had proposed "would have the effect of transforming voluntary band plans into de facto required mandates," something inconsistent with current FCC policy.
In his October 11 letter, Hollingsworth asked Koepke if his repeater is coordinated and, if so, to furnish a copy of the coordination documentation for his repeater and to explain why his appeared to be operating in a "manner not consistent with the coordination."
He also asked Koepke to justify reversing the input and output frequencies from the band plan, to explain why he's using AM gear "with IF stages wider than the FM repeater channel spacing" the band plan provides, and to detail any interference complaints he's received and what steps he took to resolve them.
Hollingsworth also asked if the repeater identifies itself, and if Koepke operates any other repeater or auxiliary stations and whether they are coordinated. The FCC gave Koepke 20 days to respond. Hollingsworth said he had not heard back from Koepke as of today.
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