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President Rick Roderick, K5UR, Heads ARRL Group on FCC Visits

11/26/2019

President Rick Roderick, K5UR, and members of the ARRL Board’s Executive Committee undertook a round of visits to FCC Headquarters in Washington on November 4 and 5. Topics focused on a number of pressing amateur radio-related issues. In addition to Roderick, members of the ARRL contingent included Atlantic Division Director Tom Abernethy, W3TOM; New England Division Director Fred Hopengarten, K1VR; Roanoke Division Director Bud Hippisley, W2RU; West Gulf Division Director John Robert Stratton, N5AUS, and ARRL Washington Counsel David Siddall, K3ZJ.

Digital Data Symbol Rate Proceeding

The ARRL delegation emphasized the overwhelming support for and need to remove symbol rate limits from the amateur rules, contending that the limits are outdated, no longer serve their original purpose of limiting signal bandwidth, and inhibit experimentation and development of digital communications techniques. Removing these limitations would also allow US radio amateurs to join those in other countries using methods not permitted in the US. This includes some techniques promoted by the International Telecommunication Union (ITU) for emergency communication in the Caribbean.

In 2016, the FCC had responded to ARRL’s petition for rulemaking (RM-11708) by proposing no bandwidth limit. During this month’s visit to the FCC, ARRL reiterated that adopting a 2.8 kHz maximum bandwidth in place of the symbol rate limit would promote sharing and experimentation below 30 MHz. 

The ARRL representatives also discussed issues that some have raised — and on which the FCC did not request comment — alleging that certain types of digital signals are “encrypted” because they are digitally compressed or otherwise can be difficult to receive over the air. The ARRL group pointed out that the FCC addressed the use of new digital techniques in 1995 and amended its rules to specifically authorize radio amateurs to use new digital techniques without prior Commission approval, as long as these techniques were publicly documented consistent with the documentation of the three techniques specifically approved at the time. Since then, multiple digital methods have been developed and deployed on the amateur bands without substantive complaints of insufficient documentation.

Regarding the specific digital techniques that have been the focus of complaints, several radio amateurs have reported to the FCC their success in using the public documentation to decode the signals. In addition, recently available free software, used with a Raspberry Pi, allows real-time monitoring of the same modes on which complaints have centered. The ARRL representatives concluded that the signals cannot be considered encrypted if they are readily decodable.

Some discussion touched on international regulations, because the prohibition on encryption is a provision of the ITU Radio Regulations and apply worldwide. The FCC regulation prohibiting “messages encoded for the purpose of obscuring their meaning” comes directly from the ITU Radio Regulations. This language was adopted at World Radiocommunication Conference 2003 (WRC-03) to replace a provision that limited amateur communications to “plain language.” Adoption of this change made clear that amateur communications encoded for digital transmission are authorized internationally as long as they’re not encrypted. It was noted that techniques some commenters have targeted are widely used by amateurs around the world.

The ARRL delegation emphasized the importance of the discussion in terms of the future of amateur radio. As noted in its September 2019 ex parte filing, the digital revolution in communications technology requires new and different regulation to keep up with the fast-paced and almost constant change. Outside of the symbol rate limit, the FCC addressed these issues decades ago in the Amateur Service rules, and the ITU did so as well in 2003.

 The work of the ARRL Band Planning Committee was also discussed. The FCC is aware that subsequent recommendations will be forthcoming once the Committee completes its study.

ARRL maintained that regulation should continue to encourage amateur radio’s ability to foster innovation through experimentation with new techniques while ensuring that encryption is not used beyond that explicitly authorized — such as the limited exception for satellite control.

60-Meter Band Allocation

ARRL petitioned the FCC in RM-11785 to implement provisions adopted at WRC-15 that provide for a secondary amateur allocation at 5351.5 – 5366.5 kHz. ARRL also proposed that 100 W ERP be permitted on the new band, consistent with that authorized for the current five channels at 60 meters.

Referencing a National Telecommunications and Information Administration (NTIA) letter proposing to delete the existing four channels and substitute a secondary band allocation at a maximum permitted power of 15 W EIRP (9.1 W ERP), as approved at WRC-15, the ARRL delegation expressed concern that adoption of NTIA’s proposal would require relocation of existing channelized amateur activity to a 15 kHz band at a fraction of the power now authorized, despite an absence of any reported interference on the current channels. ARRL also expressed concern that 9.1 W ERP would hamper emergency communication on the band, especially during hurricane season, when noise levels are usually high.

The FCC is expected to issue a Notice of Proposed Rulemaking (NPRM) in December or early next year addressing 60 meters and inviting comments.

Amateur Radio Enforcement

ARRL Executive Committee members met with FCC Enforcement Bureau Chief Rosemary Harold and her senior staff to discuss amateur enforcement. The delegation updated progress in setting up the Volunteer Monitoring Program pursuant to the FCC/ARRL Memorandum of Understanding (MOU) signed last March. The program is in the final stages of training volunteers and is expected to be brought online in early 2020. It is hoped that this program will result in better, more timely enforcement as well as provide a path to correct inadvertent minor infractions on an informal amateur-to-amateur basis more in line with amateur radio’s long tradition of self-enforcement.

ARRL and FCC officials also discussed the problem of uncertified radios being imported into the US and the possible impact for radio amateurs of an FCC Enforcement Advisory issued in September 2018. ARRL officials came away with a better understanding of the FCC’s actions in this matter and of the dangers that uncertified radios capable of transmitting on unapproved spectrum pose to the integrity of commercial and public safety communication. The Amateur Service was not a focus of concern, and ARRL is considering future action.

RF Exposure Regulation

During their FCC visits, the ARRL team expressed concern with changes proposed in ET Docket 13-84 to the Commission’s RF exposure policies that would affect radio amateurs. Currently, amateurs are required to assess their installations if signals exceed levels set forth at Section 97.13(c) of the Commission’s rules. It is ARRL’s understanding that the draft Report and Order now under review at the FCC would eliminate the rule at 97.13(c)(1) that exempts amateurs from the routine evaluation requirements if the transmit power used is below certain levels.

Entry-Level Amateur License

The ARRL team requested prompt consideration of ARRL’s “Technician Enhancement” petition, RM-11828. ARRL pointed out that changes to the amateur entry-level license are needed to provide more meaningful opportunities to new licensees, particularly in the areas of digital technology and emergency preparation that are of continuing interest to new hams. Attempts to slow consideration of these proposals until unrelated issues are resolved are misplaced and contradict the public interest in attracting youth to exciting opportunities in Science, Technology, Engineering, and Math (STEM), the ARRL group asserted.

80-Meter Band Realignment

The ARRL representatives also asked for consideration of its petition, RM-11759, that seeks to update the sub-band divisions in the 80-meter band to make better use of the spectrum based on today’s amateur use patterns and to provide more spectrum suitable for new and innovative experimentation.

Changes to Amplifier Gain Restriction

ARRL also reiterated its support for the proposal in RM-11767 to repeal the 15 dB maximum amplification ratio for amateur radio amplifiers. The rule’s original purpose of enforcing a prohibition on using amplifiers in the Citizens Band at 27 MHz is no longer needed because other FCC rules have proven effective in this regard. New technological means to eliminate misuse of amateur amplifiers, such as in the firmware that controls many of today’s new amplifiers, is also available now, ARRL pointed out to the FCC officials. 



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