
The ARRL Letter 

Vol. 12, No. 21 

November 10, 1993 


Executive Committee hears status report; 

numerous proposals await action at FCC 






On the burner: 


*  Instant license 

*  Wind profilers 

*  219-220 MHz 

*  Weak sig segment 

*  902 MHz users 

*  Club call signs 

*  Quiet zone 

*  Message content 

*  Automatic control 

*  Digital codes 

*  RF exposure 

*  PRB-1 

*  VEC fees           




	When the ARRL Executive Committee met on October 30 

in Memphis it heard a report from General Counsel Chris 

Imlay, N3AKD, on the status of a number of proposals before 

the Federal Communications Commission. 1993 has been an 

exceptionally busy year for such proposals affecting 

amateurs, who now await the outcome. Here's a rundown of 

just a portion of this lengthy Executive Committee meeting: 




*Wind profiler radars* 


	ET Docket 93-59 is a Notice of Proposed Rule Making, 

issued in April, 1993, to allocate 449 MHz for non-

government wind profiler radar systems; a Notice of Inquiry 

seeks comment as to whether such systems should be 

accommodated at 915 MHz.  

	Imlay told the Executive Committee that the ARRL 

"continues to seek recognition of ongoing amateur 

requirements in any implementation 

of wind profiler radar systems." 


*Allocation at 219-220 MHz* 


	ET Docket 93-40 is an FCC proposal, based on an ARRL 

petition made in 1991, to allocate 219-220 MHz for limited 

amateur operations on a secondary basis. Action on this 

proposal is expected around March 1994, Imlay said. 

	The League has told the FCC that the one MHz of 

spectrum is urgently needed by amateurs for packet radio 

backbone networks and other point-to-point communications, 

which are distressed from the loss two years ago of 220-222 

MHz. The Commission has proposed measures to ensure that 

such amateur operations do not cause interference to primary 

operations in and adjacent to the 219-220 MHz band. 

	The 216-218 and 219-220 MHz bands currently are 

occupied on a primary basis by the maritime mobile service 

for Automated Maritime Telecommunications Systems (AMTS) and 

the 218-219 MHz band is allocated on a primary basis to 

Interactive Video and Data Services (IVDS). 

	In 1991 the ARRL and Waterway Communication Systems 

(Watercom, an AMTS service) had suggested mandatory 

coordination of amateur operations, but the FCC said such an 

arrangement would not be permissible under the 

Communications Act. 

	Since then, the League has held detailed 

consultations with Watercom and is confident as a result 

that amateur point-to-point operations can be "engineered 

in" the 219-220 band without harmful interference to AMTS 

operations. 

	While the FCC has concluded that amateur access to 

the 216-219 MHz range is not feasible because of potential 

interference to other point-to-point services, and to TV 

channel 13, it does support amateur use of 219-220, saying 

it believes amateurs have the technical expertise to design 

their packet systems to operate in the 219-220 MHz band 

without interference to other services. 

	In reply comments to this NPRM filed in July, the 

League said that it hoped that experience in the new 219-220 

band, should it be allocated to amateurs, might lead to the 

consideration of additional frequency sharing by amateurs in 

the remainder of the 216-220 MHz range in certain geographic 

areas, depending on the development of IVDS and other 

advanced television systems. 

	The Executive Committee agreed to support an effort 

to plan a high speed, nationwide digital communications 

network that would use this band where it is available, and 

other connections where it is not (e.g., in the area of the 

Mississippi River and its tributaries). 

	Because FCC action on the new band is expected next 

year, amateur planning would have to begin immediately, so 

the EC instructed President Wilson to appoint an ad hoc 

committee to develop and recommend such a plan. The 

committee will be asked to give an interim report to the 

Board at its January, 1994 meeting, and a final report to 

the EC at its first meeting in 1994 (after the board 

meeting). 


*Threat to 902 MHz band* 


	In May 1993, the FCC issued a Notice of Proposed 

Rule Making to allow the  expansion of automotive vehicle 

monitoring (AVM) systems by creating a new location and 

monitoring service (LMS) in the 902-928 MHz band. Amateurs 

currently share this band with government radiolocation, 

fixed, mobile, and other services, and the FCC said in 

making its proposal that AVMs could "lead to rapid 

congestion of available spectrum." 

	The FCC asked potential LMS users whether "they 

believe it possible to establish reliable LMS systems 

considering the number and diversity of other users of this 

band," and if not, it asked for possible solutions "short of 

removing Part 15 users and amateur operations from the 

band." 

	In comments made in July the ARRL said more study 

was needed to determine if the already-crowded 902-928 MHz 

band could accommodate yet another service, namely AVM, when 

the Commission already was proposing to add wind profiler 

radars there. 

	Expansion of AVM/LMS in the band would 

"significantly reduce" its utility for amateurs at a time 

when they are increasingly looking to the band in the face 

of "intense growth" of Amateur Radio licensees and the 

"concurrent saturation" of the lower UHF and VHF amateur 

allocations," the League said in reply comments made in 

July. 

	General Counsel Imlay told the EC that this proposal 

had "encountered opposition from a number of other sources 

in addition to the ARRL."  

	The ARRL plans to file a petition seeking a primary 

allocation for the Amateur Service in a portion of the 902-

MHz band, as authorized by the board of directors. 


*Club call sign program* 


	Last July the FCC began accepting applications for 

"Club and Military Recreation Station Call Sign 

Administrators," after a change in Commission rules allowed 

it to use qualified volunteer organizations as 

administrators of the new program. 

	Several groups applied, including the ARRL. The 

League gave the FCC several reasons why it felt only one 

administrator of the program should be appointed, and why 

the ARRL was the logical choice for the job. The League 

later said that the applications of several groups were 

defective. 

	Complaints -- "motions to strike" -- against the 

ARRL were filed by the W5YI-VEC Inc. and the National 

Amateur Radio Association. The League challenged those 

motions to strike, and continued to urge the FCC to name an 

administrator for the program. 

	Meanwhile, the FCC's Order, enabling the acceptance 

of applications and the program itself, was questioned in a 

petition for reconsideration filed by David Popkin, W2CC. 

Popkin argued that the Commission erred in not providing an 

opportunity for public comment before amending its rules. 

	The issue now has been further complicated by the 

possibility that the FCC may soon be able to institute a 

"vanity call sign" program, enabling the Commission to 

charge a fee for the issuance of specific call signs -- 

which could include clubs and military stations. 

	Imlay told the EC that the Popkin petition will 

likely delay implementation of the call sign administrator 

program for some time. 


*Puerto Rico "quiet zone"* 


	In November 1992, Cornell University filed a 

Petition for Rule Making that would create a radio "quiet 

zone" around its Arecibo Observatory in Puerto Rico. 

	The ARRL opposed the petition, saying that the 

petition was vague in a number of aspects; that no technical 

criteria were proposed for the evaluation of possible 

interference to the observatory by amateur repeaters, and 

that no basis for what Cornell's petition called 

"appropriate action" was specified. 

	The League also said that the Cornell petition 

failed to address what degree of protection should be 

accorded, made no distinction about what radio services 

might or might not be potential sources of interference, and 

did not take into account that planned upgrades to the 

antenna at Arecibo would tend to *reduce* received 

interference. 

	The League said that the nature of amateur repeater 

stations made it highly unlikely that they would interfere 

with a radiotelescope, at any rate, and suggested that 

Cornell work with local repeater or frequency coordinators 

to obtain information concerning amateur repeaters. 

	Imlay reported to the Executive Committee that 

Cornell has now filed reply comments to its own petition, 

suggesting that the University has worked out an informal 

arrangement with Puerto Rico amateurs. To date, the FCC has 

taken no action on the Cornell petition. 


*Message content responsibility* 


	August 1 was the deadline for reply comments to an 

FCC NPRM issued in March that would change the 

responsibility for the content of amateur messages relayed 

by high-speed networks. 

	The action, in PR Docket 93-85, came in response to 

a number of petitions for rule making, and would establish 

"a compliance policy for amateur stations participating in 

automatic message forwarding systems, to hold the licensee 

of the station originating a message and the licensee of the 

first forwarding station primarily accountable for violative 

communications." 

	The ARRL supported the proposal as an improvement on 

the present situation, saying only that better definitions 

of "first forwarder" and of "repeater station" were needed. 

	No action has been taken on this proposal. 


*HF automatic control* 


	There also has been no FCC action with regard to 

petitions concerning automatic control on HF, RM-8218 and 

RM-8280. 


*RF exposure guidelines* 


	Earlier this year the FCC proposed changing its 

guidelines for evaluating environmental RF radiation, to 

reflect the guidelines adopted in 1992 by the American 

National Standards Institute (ANSI) and the Institute of 

Electrical and Electronic Engineers, Inc. (IEEE).  

	The new ANSI guidelines were more specific about 

proximity to RF fields and placed stricter limitations on 

automatic exclusions for low-power devices, such as hand-

held radios and telephones, based on operating power. 

	At its meeting the Executive Committee authorized 

General Counsel Imlay to file comments in ET Docket 93-62, 

the FCC Notice of Proposed Rule Making to implement the ANSI 

guidelines. 

	The Executive Committee expressed concern over the 

lack of specific text in the NPRM and guidelines for 

commenting on it. The League will argue that while the 

subject deserves serious attention, it has always been ARRL 

policy to urge "prudent avoidance of prolonged exposure to 

unnecessarily high levels of RF energy." 

	The League will argue for a categorical exemption of 

amateur stations. 


*Licensing of foreigners* 


	Imlay told the EC that an FCC proposal for the 

temporary licensing of foreign radio amateurs on the basis 

of an examination of their qualifications by Volunteer 

Examiners (PR Docket 92-167), is still pending but is 

"expected to be dismissed without action." 

	The League had responded to this proposal by saying 

it believed an "International Amateur Radio Permit," similar 

to that already in effect in much of Europe, would be more 

desirable. International Affairs Vice President Larry Price, 

W4RA, reported to the EC that an initiative drafted for the 

International Amateur Radio Union by ARRL staff is working 

its way through CITEL, the organization of 

telecommunications administrations in the western 

hemisphere; once adopted by CITEL it could be placed on the 

agenda of a future World Radiocommunication Conference. 


*More teeth to PRB-1* 


	President Wilson, at the direction of the EC, 

appointed a committee to examine how best to pursue an 

expansion and clarification of PRB-1, the preemption of 

state and local regulations by federal (FCC) law. First Vice 

President Rod Stafford, KB6ZV, and Rocky Mountain Division 

Director Marshall Quiat, AG0X, were named to the committee. 

Both are lawyers. 


*Lifetime operator license* 


	At its July 1993 meeting, the Board directed the 

General Counsel to file a petition seeking a lifetime 

operator's license for radio amateurs. Imlay said that 

filing will be made soon. 


*Concerns about enforcement* 


	Imlay said he will meet with FCC staff concerning 

enforcement cases in the Amateur Service, to express the 

concerns of amateur volunteers who play an active role in 

assisting the FCC in locating offenders on the amateur 

bands. 


*VEC fees* 


	The ARRL has received an FCC request for financial 

details of its VEC program, as have other VECs. Executive 

Vice President David Sumner, K1ZZ, confirmed for the EC that 

the cost of administration of the ARRL VEC program 

significantly exceeds the amount of examination fees 

collected, and would still exceed the fees collected even if 

fees were charged for examination elements 1(A) and 2 

(Novice exam elements). 

	This stems from a complaint filed with the FCC by 

the W5YI Volunteer Examiner Coordinator (VEC), asking that 

the ARRL-VEC be forced to change its policy and begin 

charging for administering Novice class examinations. The 

W5YI-VEC argued that the issue is one of "uniformity," 

claiming that ARRL benefits financially from giving free 

exams. 

	The League responded that "VECs have always had the 

latitude to set their own fees. We see no compelling federal 

interest in whether or not a class of nine year olds ought 

to be charged for taking an entry-level exam." 


*Shortage of call signs* 


	Available preferred call signs for Amateur Extra 

Class licensees ("Group A") have run out in Puerto Rico, 

Alaska, and Hawaii, and such call signs are about to run out 

for Advanced class ("Group B") in Hawaii. 

	The EC authorized the General Counsel to present a 

proposal to the FCC that would make more preferred call 

signs available in these areas. The letter was sent November 

4. In short, it suggest making numerals other than "7" 

available for Alaska call signs, the numeral 3 available for 

Puerto Rico ("3" was originally allocated for Serrana Bank 

and Roncador Cay but is no longer needed), and the numeral 7 

for Hawaii (with a distinctive suffix for Kure Island). 

	

STATION LOCATION DROPPED 

FROM FCC LICENSE FORMS 


	Effective November 15, 1993, the FCC will no longer 

require that a station location be shown on amateur license 

applications, nor on applications for reciprocal operating 

permits. 

	The Commission, in an Order adopted September 24, 

said that because portable and mobile equipment is now so 

often used by amateurs, a station's location often changes, 

sometimes even daily. 

	The FCC also said that deleting the station location 

requirement would expedite the processing of license 

applications. They said that since this rule amendment is 

not likely to be controversial and that it is a 

"nonsubstantive" change in licensing procedures, no notice 

and comment period was needed. 

	The amended FCC Rule "Section 97.21 Mailing Address" 

will be: 

	"Each application for an amateur service license and 

each application for a reciprocal permit for alien amateur 

licensee must show a mailing address in an area where the 

amateur service is regulated by the FCC. The mailing address 

must be one where the licensee can receive mail delivery by 

the United States Postal Service." 


FCC OKs ANNUAL CHANGE 

IN ALLOWABLE TEST FEE 


	The FCC has announced that effective January 1, 

1994, the maximum allowable reimbursement fee for an amateur 

operator license examination will be $5.75, up from the 

current $5.60. 

	As before, volunteer examiners and volunteer 

examiner coordinators may charge examinees for out-of-pocket 

expenses incurred in preparing, processing, administering, 

or coordinating examinations for amateur operator licenses.  

The amount of any such reimbursement fee from any one 

examinee for any one examination session, regardless of the 

number of elements administered, must not exceed the maximum 

allowable fee. 

	Where the VE and the VEC both wish to be reimbursed, 

they jointly decide on a fair distribution of the fee. 

	The ARRL VEC will begin charging $5.75 after the new 

FCC allowable fee becomes effective. 


REPEATER TRUSTEE FINED; 

AWAITS OUTCOME OF APPEAL	


	The FCC has issued a Notice of Apparent Liability to 

William A. Krause, WA2HDE, the trustee of a 220 MHz repeater 

in New York City.  The repeater was found to be transmitting 

for several days in August on 243 MHz, a Federal Aviation 

Administration frequency used for emergency locator 

transmitters. 

	The FCC's NAL called the violation "willful and 

repeated."  Krause, an engineer, said that the repeater, a 

10-year-old commercial unit, developed a malfunction that 

caused it to emit a very weak signal on 243 MHz when its 

transmitter was unkeyed.  He said the repeater was checked 

out on a regular basis. 

	The FCC said that the violation was "minimally 

occurring" on three days, August 30, 31, and September 1, 

and that the FAA had said the "unauthorized signal" also had 

occurred on August 26-29. 

	The NAL was issued September 30; Krause responded on 

October 21, saying "I at no time willfully transmitted on 

any frequency that I am not authorized for. I was shocked to 

hear that there was any problem at all, much less one of 

such a nature." 

	Krause told the FCC "I have always made measurements 

of the transmitter in the transmitting mode and would never 

have found this problem unless pointed out" (the spurious 

signals were present only when the repeater was in *receive* 

mode -- ed). 

	Krause pointed out that this was his first offense 

and asked the FCC not to impose the fine. 


SHUTTLE HAMS CONGRATULATE 

COUNTERPARTS ON THE GROUND 


	SAREX space shuttle flight STS-58 landed November 1 

after a shuttle record-breaking 13 days in orbit. All 17 

scheduled contacts with schools -- via Amateur Radio -- were 

completed, with 15 successful on the first try. ARRL 

Headquarters had received 162 QSLs for the flight before it 

even landed! 

	Near the end of the flight those hams tuning in to 

the shuttle's robot packet beacon found the following 

message from the crew:  

	"W5RRR-1*>QST  We are in the middle of Flight Day 

13. Tomorrow we will begin preparation for deorbit, entry, 

and landing.  

	"To those of you who have attempted a QSO, the STS-

58 crew is eternally grateful. Congratulations to those who 

have succeeded.  To those who were not successful, thanks 

for trying and better luck during a future mission. The 

Shuttle Amateur Radio Experiment is successful only due to 

your efforts. 

	"... Flying in space is truly an honor and I am 

pleased and proud that amateur radio is part of the human 

exploration of space. 73, KC5ACR (Bill McArthur), KC5AXA 

(Martin Fettman), KC5CKM (Richard Searfoss)." 


DALLAS HAM PLEADS GUILTY 

TO INTERFERENCE CHARGES 


	A Technician Class licensee has admitted to 

interfering with a restaurant's wireless intercom. 

	On October 27 Terry Van Sickle, WB5WXI, of Dallas, 

entered a plea bargain in U.S. District Court in Dallas, 

saying that between January, 1992 and at least August 22, 

1993, he would "broadcast his voice over the drive-thru 

speaker and interrupt the customer's order and willfully 

interfere with the authorized and licensed radio 

communications of the restaurant on its assigned frequency." 

	Van Sickle, 34 and a TV news photographer, admitted 

to at times being "accompanied and aided by an 

acquaintance," who was not identified in court papers and 

has not been charged. 

	The investigation was conducted by the Federal 

Bureau of Investigation on a complaint from a McDonald's 

eatery in suburban Dallas. Van Sickle agreed to the 

surrender of evidence seized by the FBI, which included 

radio equipment from his vehicle. 

	Van Sickle is scheduled for sentencing January 12, 

and could face a year in prison and a fine of up to 

$100,000. 



Temporary operating authority plan detailed


	The Executive Committee awaited the issuance by the 

FCC of a Notice of Proposed Rule Making, to grant temporary 

operating authority to unlicensed persons who pass the 

examination for a new amateur operator license. 

         A few days after the meeting, on November 4, the 

NPRM surfaced -- PR 93-267. 

	The temporary authorization would begin when the 

exam is passed and an application for a license is filed, 

and last until a full-term license is received from the FCC 

(but not more than 120 days), provided that the person is 

not a previous licensee whose license was revoked or 

suspended for less than the balance of the license term and 

is not subject to an active Amateur Radio-related cease-and-

desist order. 

	The temporary authority would cease immediately if 

the application is returned without action, and no temporary 

authority would be granted if the operation of the station 

might have a "significant environmental effect." 

	Those operating under the proposed new rules would 

use call signs determined by the initials of their name and 

by their mailing address.  The prefix for each such call 

sign would be WZ followed by a number indicating the 

appropriate Volunteer Examiner Coordinator region, the 

person's initials, and a two-letter indicator of the class 

of license being exercised. For example, WZ12ABC/KT. 

	The Commission said it believes this system would 

reduce the approximately 11,000 inquiries it receives each 

year from amateur license applicants about the status of 

their application. 

	Imlay told the EC (before the NPRM) that it is not 

known how the Commission proposes to minimize the obvious 

opportunities for abuse of such a system. The NPRM when it 

appeared did not mention this subject. 

	The League is on record as preferring to see 

Commission resources devoted to the implementation of 

electronic filing and other measures to minimize the 

turnaround time for the processing of applications. 

	The comment deadline for this NPRM is January 10, 

1994; reply comment deadline is February 10, 1994. 

	For the full text of this NPRM send an SASE to the 

Regulatory Information Branch at ARRL Headquarters and ask 

for PR Docket 93-267.  ARRL members are encouraged to 

express their views on this proposal to their division 

director. 

	More on this subject was in the last *The ARRL 

Letter*. 



*10 years ago in *The ARRL Letter* 


	The historic space shuttle flight of Owen Garriott, 

W5LFL, topped the news as amateurs awaited the first ham 

radio from space. STS-9's launch was delayed until November 

28 and because many of the times when Amateur Radio was 

scheduled coincided with the shuttle's ham antenna's 

pointing away from the earth, there was some trepidation 

that two-way contacts would be few. 

	*The ARRL Letter* co-editors Pete O'Dell, KB1N, and 

Wayne Yoshida, KH6WZ, announced they would be in Houston at 

the Johnson Space Center during the flight to provide 

information for W1AW bulletins. 

	The *Letter* also reported on mop-up operations 

following the U.S. invasion of Grenada, saying that a 

replacement for a repeater on the island (destroyed during 

the military operation) had been procured and sent through 

ARRL efforts. And Arizona Senator Barry Goldwater, K7UGA, 

mentioned Amateur Radio's role in communications out of 

Grenada in the Senate. 

	Sen. Goldwater also introduced legislation that 

would permit recovery of out-of-pocket expenses by volunteer 

examiners; the VE program was not yet in place, and ARRL 

representatives were meeting with the FCC to iron out VE 

question pools and other details. 

	About the same time, the FCC announced its 1984 

examination schedule for amateurs. The *Letter* called the 

schedule "bad news" for amateurs looking to upgrade; FCC 

field offices would give exams only quarterly, and there 

would be no walk-ins or late filers, the FCC requiring 

appointments be made a month before the scheduled exam date. 

	
