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ARRL General Bulletin ARLB018 (2009)

ARLB018 FCC Clarifies What Constitutes an Amateur Radio Repeater

QST de W1AW  
ARRL Bulletin 18  ARLB018
From ARRL Headquarters  
Newington CT  March 24, 2009
To all radio amateurs 

ARLB018 FCC Clarifies What Constitutes an Amateur Radio Repeater

In December 2007, Gary Mitchell, WB6YRU, President of the Northern
California Packet Association (NCPA), filed a Petition with the FCC,
asking for the Commission to clarify the definition of a repeater.
According to Part 97, Section 3(a)(39), A repeater in the amateur
service is "[a]n amateur station that simultaneously retransmits the
transmission of another amateur station on a different channel or

Mitchell sought clarification on the word "simultaneously," asking
if it referred to the signal information being retransmitted, or to
the fact that the receiver and transmitter must both be active at
the same time while acting on the same signal information. On March
23, 2009, the Commission clarified that even if there is a slight
delay between what is received and what it transmits (as in the case
of D-STAR and other digital repeaters), it is considered
simultaneous if the receiver and transmitter are both active at the
same time.

Mitchell pointed out in his petition that while the Commission's
Rules specify on which bands amateur repeaters may operate, "some
amateur repeaters are operating on bands other than set forth in
Section 97.205(b) with systems that are essentially voice repeater
stations, but that digitize and retransmit the user's voice, on the
theory that because there is a small delay in retransmitting the
signal of another amateur station, the signal is not
'simultaneously' retransmitted and, therefore, the system is not a

In its reply, the Commission pointed out that prior to 1994, a
repeater was defined as "[a]n amateur station that automatically
retransmits the signals of other stations." This, the Commission
told Mitchell, was revised to clarify "that certain accommodations
for message forwarding systems do not apply to other operating
activities such as repeaters and auxiliary stations." The Commission
proposed to define a repeater as "[a]n amateur station that
instantaneously retransmits the transmission of another amateur
station on a different channel or channels," but ultimately replaced
"instantaneously" with "simultaneously" because commenters noted
that there is always a small propagation delay through a repeater.
As one commenter explained, "The word 'simultaneously' in this case
means that the repeater is receiving and transmitting concurrently,
whereas each signal might be slightly displaced in time between
receive and transmit."

To be able to repeat another station's transmission, the Commission
said that a repeater "must be able to receive a transmission from
another station and retransmit it. Because the word 'simultaneously'
in the definition is used to modify 'retransmit,' we believe it
refers to a repeater station's transmitter being active when
retransmitting the signal received by the repeater station's
receiver from another amateur station. We conclude, therefore, that
'simultaneously' as used in the definition of a repeater refers to
the receiver and transmitter both being active at the same time."


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