ARRL General Bulletin ARLB016 (2004)

ARLB016 ARRL supports FCC's cognitive radio technology proposals
with reservations

QST de W1AW  
ARRL Bulletin 16  ARLB016
From ARRL Headquarters  
Newington CT  May 12, 2004
To all radio amateurs 

ARLB016 ARRL supports FCC's cognitive radio technology proposals 
with reservations

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 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 and
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 NPRMO 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

''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.''
The ARRL also urged the FCC to avoid creating regulatory obstacles
that would hamper ''experimentation and flexibility in conducting
amateur operations.''

''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