The ARRL Needs Your Help to Protect Our Amateur Radio Spectrum
The third edition for 2011 of Spectrum Defense Matters -- a newsletter aimed at keeping ARRL members updated on issues related to the protection of Amateur Radio frequencies -- was recently released on the ARRL website. This newsletter covers both domestic and international topics related to the Amateur Radio spectrum. Your financial support is vital to continue the ARRL’s work to protect your operating privileges. You can help protect these privileges by contributing generously to the 2011 ARRL Spectrum Defense Fund.
Defending spectrum means protecting the way each of us chooses to enjoy Amateur Radio. It is important to have VHF/UHF allocations when radio amateurs are called upon to provide support during communications emergencies. But Amateur Radio is primarily a personal radio service where licensees have great latitude to develop their skills, experiment to broaden their knowledge base, serve their communities and to simply have fun.
Below are some of the Spectrum Defense items that the ARRL is working on and that are featured in this issue of Spectrum Defense Matters:
WRC-12 Is Just Weeks Away
In the final weeks and months before WRC-12 -- scheduled for January 23-February 17 in Geneva, Switzerland -- countries and regional telecommunications organizations around the globe will submit proposals for the work of the conference. These proposals suggest outcomes for the 35 items on WRC-12’s agenda and will serve as the starting point for negotiations.
For Agenda Item 1.23 -- which will consider a secondary allocation to the Amateur Radio Service of about 15 kilohertz in the range 415-526.5 kHz -- three regions have made affirmative proposals as of press time: CITEL, representing the Americas; ATU, representing Africa, and CEPT, representing Europe. Conversely, at least two regional organizations --ASMG, representing several Middle Eastern countries, and RCC, representing several nations of the former Soviet Union -- are recommending no change, as is the International Maritime Organization. While the affirmative proposals differ somewhat, they do overlap in the frequency range considered, and provide a welcome counterweight to the opposition of maritime interests.
Some proposals are much more mundane, but are welcome nonetheless. For example, Agenda Item 1.1 invites countries to delete their names from various footnotes in the Table of Allocations in the ITU Radio Regulations. A number of countries permit operation of other services on Amateur Radio frequencies by an applicable footnote. Moldova has asked to be removed from footnotes 5.93, 5.98 and 5.277, permitting radio amateurs freer use of 1800-1830 kHz and 430- 440 MHz by removing authorization to the fixed and mobile services.
As the last weeks before WRC-12 pass, the number of proposals submitted to the ITU will increase significantly, requiring ARRL staff and IARU volunteer analysis.
Looking Ahead to WRC-15
According to ARRL Chief Executive Officer David Sumner, K1ZZ, WRCs require a continuous cycle of preparation. “One of the tasks facing the delegates to WRC-12, now just weeks away, is to develop the recommended agenda for the next WRC that may be held in the fourth quarter of 2015. While the agenda is not formally adopted until the ITU Council approves the recommendation, preparatory work will begin as soon as WRC-12 concludes on February 17.”
The first step will be to organize the preparatory work by assigning it to the appropriate Working Parties of the ITU Radiocommunication Sector Study Groups. This will be done at a short Conference Preparatory Meeting (CPM) held before the delegates depart from Geneva after WRC-12. The Working Parties will meet to begin their work later in 2012 and will continue to meet two or three times a year through 2014. A “big” CPM will be held, probably in early 2015, to finalize the technical report that will serve as the basis for the proposals to be considered at WRC-15.
“It is impossible to predict all of the issues that will make it onto the WRC-15 agenda, but one that is certain to be there is further expansion of spectrum for mobile broadband applications, between approximately 500 MHz and 4 GHz,” Sumner explained. “Tablets such as the iPad are driving demand for bandwidth through the roof. Not all of the other agenda items will be of concern to the Amateur and Amateur-Satellite Services, but there are bound to be some that threaten our allocations. Whether there also will be an opportunity to expand amateur allocations remains to be seen; most administrations, as well as the ITU itself, are faced with diminishing resources and there is likely to be pressure to limit the number of agenda items that do not promise significant and immediate economic benefits.
Like all WRC issues, the content of the next conference’s agenda is difficult to predict in advance. In fact, WRC-12 Agenda Item 1.23 -- which will consider a secondary allocation to Amateur Radio at 415-526.5 kHz -- was added almost at the last minute and somewhat unexpectedly at WRC-07. Nevertheless, at least three proposals of possible concern to Amateur Radio have already been put forth:
- The preliminary agenda for WRC-15 -- adopted at WRC-07 -- includes consideration of “spectrum requirements and possible additional spectrum to the radiodetermination service to support the operation of unmanned aerial systems (UAS) in non-segregated airspace.” Already the topic of WRC-12 Agenda Item 1.3, UAS may ultimately require up to 100 megahertz for terrestrial and satellite-based command, control, and sense-and-avoid operations.
- Japan has proposed to the Asia-Pacific Telecommunity that the 77.5-78 GHz band be allocated to the radiolocation service on a primary basis for shortrange vehicular radar applications. This band is presently allocated to the Amateur and Amateur Satellite Services on a primary basis, with radiolocation permitted on a secondary basis in the band and on a primary basis on adjacent bands.
- A number of countries have informally suggested that reallocations for wireless broadband applications be considered. CITEL has already adopted an Inter-American Proposal to that end, “to consider spectrum requirements and possible regulatory actions, including additional spectrum allocations to the mobile service on a primary basis to accommodate the development of IMT and other mobile broadband applications and technologies.” IMT, an acronym for International Mobile Telecommunications, is an ITU term encompassing mobile telephony and telecommunication services.
“Once the WRC-15 agenda is known and the assignments to the Working Parties have been made, the IARU and its Member-Societies -- including, of course, the ARRL -- will plan the necessary meeting coverage,” Sumner said.
The FCC, BPL and the Amateur Radio Service
In October, the FCC released a Second Report and Order in its proceeding -- now in its ninth year -- to adopt rules for Access Broadband over Power Line (BPL) systems. The Second Report and Order is the final step in the Commission’s effort to comply with the directives of the United States Court of Appeals for the District of Columbia Circuit, which in 2008 ordered the FCC to correct errors it had committed in the course of adopting rules in 2004. The Court acted in response to a Petition for Review by the ARRL.
Responding to the Court’s directive, the FCC proposed a slight modification of measurement standards for determining whether a BPL system is in compliance with the maximum allowable levels of radiated emissions. In return, the ARRL argued that coupled with a scientifically valid extrapolation factor for determining those levels, there should be mandatory notching of the amateur bands to a level 35 dB below the general emission limit. This action would reduce the likelihood of harmful interference to amateur stations to a level that would permit any remaining harmful interference to be remedied on a case-by-case basis. The ARRL noted that mandatory notching simply reflected the best practices of the BPL industry.
In the Second Report and Order, the Commission decided not to adopt its own proposal and also declined to adopt ARRL’s request for mandatory notching. Instead, the Commission has increased the requirement for BPL systems to be able to notch frequency bands to at least 25 dB, an increase of 5 dB from the prior requirement of 20 dB. The Commission also made technical adjustments to its rules for determining the distance between a power line and a measurement antenna and for determining site-specific extrapolation factors.
“We were prepared to be disappointed, and we were,” Sumner said, after reviewing the 76 page Second Report and Order. “The increase in notch depth is a step in the right direction, but the value of the change is greatly diminished by the notches not being mandatory. The FCC acknowledges that a compliant BPL system will increase the noise floor below 30 MHz at distances of up to 400 meters from a power line, but characterizes that as ‘a relatively short distance.’ How many amateur stations are located more than a quarter-mile from the nearest power line?”
It is likely that ARRL will file a Petition for Reconsideration at an appropriate time: “While BPL has failed in the marketplace as a medium for delivering broadband connectivity to consumers, the technology is perceived to have some ‘smart grid’ applications,” Sumner explained. “Now is the time to fix the rules, principally by mandatory notching, so that any new entrants will be competing on a level playing field with the existing BPL firms that have recognized the need for notching of the amateur bands.”
You and the ARRL -- Helping to Protect Our Amateur Radio Spectrum
According to Sumner, the ARRL is one of the few IARU Member-Societies that is able to devote professional staff to defending our Amateur Radio spectrum on the world stage -- such as the WRCs -- thanks in large part to the generous financial support of contributors to the Spectrum Defense Fund. “The IARU team is almost entirely volunteer,” he explained. “Staff or volunteer, attending international meetings is an expensive undertaking -- and the ARRL as the IARU International Secretariat picks up the lion’s share of the cost. The amateur community does not have taxes or corporate profits to fund its representation, and must instead rely on the voluntary dues and contributions of individuals who understand the need for us to be at the table when issues affecting our allocations are being considered.”
For 2011, the ARRL set a goal of raising $350,000 to support its efforts to defend Amateur Radio frequencies and operating privileges. So far, members have donated $292,000, but the Spectrum Defense Fund needs another $58,000 to reach its goal by December 31.
“The World Radiocommunication Conference in 2012 will focus on many Agenda Items related to our Amateur Radio spectrum and, in fact, could affect our radio frequencies,” said ARRL Chief Development Officer Mary Hobart, K1MMH. “Having ARRL Chief Executive Officer David Sumner, K1ZZ, and ARRL Chief Technology Officer Brennan Price, N4QX, attend WRC-12 is imperative. Through their personal representation, both David and Brennan work to ensure that Amateur Radio spectrum and other critical concerns are addressed rigorously. Furthermore, ARRL officers continue to be an active voice for spectrum protection within the United States year-round. But this continuous vigilance comes at a cost. Without these crucial dollars, ARRL staff cannot represent Amateur Radio and constantly hold the line on available frequencies. Every day there is more and more demand from wireless technology companies to usurp that most valuable of our commodities -- the radio spectrum.”
If you have already contributed to the Spectrum Defense Fund this year, thank you. Your generosity is making possible our vigilance to protect defend Amateur Radio spectrum. If you have not yet made a donation to this important fund, now is the time to do so. For a $50 contribution to the Spectrum Defense Fund, you will receive a beautiful 2011 Spectrum Defense pin that you can wear with pride, knowing you are doing your part to help to protect your on-air privileges. With a donation of $100, you will not only receive the pin, but also a 2011 Spectrum Defense mug.
“Please make a generous contribution to the Spectrum Defense Fund by mail, on the web or by phone,” Hobart said. “Perhaps you’ll consider a very easy way to contribute by pledging $10 or $20 or $100 a month. Your financial commitment, over and above your annual dues, will ensure that the ARRL has the resources to represent you and protect your operating frequencies.” To make a donation via mail, please send it to Spectrum Defense Fund, ARRL, 225 Main St, Newington, CT 06111. To make a contribution over the phone, or to discuss other giving options, please call 860-594-0397.