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 Previous: Wisconsin Ham Takes BPL Concerns to President Bush |  Next: Ham Radio-Carrying Rocket Hopes to Reach Space |
NEWINGTON, CT, May 11, 2004--The ARRL says it generally supports the proposals contained in an FCC Notice of Proposed Rule Making and Order (NPRM&O), ET Docket 03-108 (Part 1; Part 2), relating to so-called cognitive radio (CR) technology. But the League urged the FCC to avoid large-scale deployment of CR technology--and especially of unlicensed devices in spectrum regularly used by licensed services--"until further experience with the technology is obtained." The ARRL also strenuously objected to a proposal to allow cognitive radio technology devices to operate under Part 15 in "rural areas" at up to a sixfold increase in the currently permitted power level in several UHF bands that include amateur allocations.
"ARRL opposes increases of power levels for undefined and undefinable 'rural areas,'" the League's comments said, "because the practical radio horizon at higher Part 15 power levels makes interference with the Amateur and Amateur-Satellite service operations in many frequency bands inevitable." The FCC seeks to allow a transmitter power increase of up to six times (approximately 8 dB) higher than current Part 15 limits in the 902-928, 2400-2483.5 and 5725-5825 MHz band and in the 24 GHz band.
The League said the Commission should not view cognitive radio as an opportunity to increase permissible Part 15 power levels, which ARRL called already substantial enough "to make a mockery of" the Communication Act's licensing requirements. The ARRL questioned why the FCC was willing to put forth such proposals "without the slightest real-world test deployment" of the systems it wants to authorize.
A "cognitive radio" is one that "can change its transmitter parameters based on interaction with the environment in which it operates," the FCC's NPRM&O says. "This interaction may involve active negotiation or communications with other spectrum users and/or passive sensing and decision making within the radio." Most cognitive radios will be software defined radios (SDRs), the League predicted.
"There is no need for separate rules regarding cognitive and software defined radios," the ARRL said, calling both "an excellent opportunity" to drive technological advancement within Amateur Radio. "They should and can be regulated within the existing rules."
While cognitive radio technology is "likely to enhance spectrum efficiency," the ARRL urged the FCC to avoid creating regulatory obstacles that would hamper "experimentation and flexibility in conducting amateur operations." It asked the FCC not to impose equipment authorization requirements on cognitive radio technology hardware or software used for amateur communications on Amateur Service frequencies. The League also suggested that the FCC require cognitive radio technology software intended for other services be configured to block amateur allocations.
The FCC has proposed permitting higher power operation by "unlicensed devices in any area that has limited spectrum use, provided the device has capabilities to determine whether it is in an area with limited spectrum use." It wants to add a new rule section applying specifically to CR devices operating in the industrial, scientific and medical (ISM) bands.
"This proposed rule section would permit higher power operation for cognitive devices than these sections currently allow, provided that the devices meet all the other requirements of §15.247 and §15 249, and that the devices incorporate certain features to determine that they are in an area with limited spectrum use." The FCC said it was not proposing to change the rules as they apply to non-cognitive radio devices.
The ARRL called the Amateur Radio Service "fertile testing and development ground for SDR and CR technologies," now the subjects of experimentation and hardware and software development. "In particular, such technology would be useful in Amateur Radio disaster relief and emergency communications."
"These technologies will allow ever-greater participation by amateurs in restoration of communications systems following a wide-area emergency or disaster and in conducting disaster relief efforts on site in coordination with served agencies," the League predicted.
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