Category Archives: FCC

Reading the Fine Print in Part 97

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The ARRL just filed a Petition for Rule Making with the FCC concerning a specific modulation format called TDMA (Time Division Multiple Access). This issue has been simmering in the community of repeater operators but I suspect that most hams have no idea what this is about. It so happens that the land mobile industry (most notably, Motorola) has developed a very efficient and cost-effective digital standard called DMR (Digital Mobile Radio). Motorola markets this technology under the name MOTOTRBO.

As often happens, some radio amateurs deployed this new Part 90 radio technology on the ham bands. Along the way, people started looking carefully at the emission designator that Motorola was using for MOTOTRBO and began to question whether it was allowed under Part 97. I won’t go into the gory details as it makes my head hurt :-). My brief look at this concluded that there is definitely an issue here but I am not completely convinced that DMR is illegal under Part 97. If you want to dig into this, read the petition in detail with a copy of Part 97 and a few aspirin in hand.

The ARRL probably did the right thing by requesting a very focused rule change which should remove any ambiguity from Part 97. (I know this will disappoint the arm-chair lawyers who make a so-called life out of debating these issues to death.) The ARRL also asked for an immediate temporary waiver from the FCC to allow for DMR operation while the rule making proceeds…another good move.

It is unfortunate that the FCC amateur rules were written in a way that (potentially) disallowed the use of the latest land mobile radio system. This is exactly what we don’t want to have happen in the Amateur Radio Service, as it should be a place for easy adoption of new technology. Future FCC rule making should keep this in mind, always erring on the side of flexibility.

– 73, Bob K0NR

Update on 25 Mar 2011:

The ARRL reports that the FCC is seeking comments on this petition, now designated RM-11625. Comments can be filed electronically here.

FCC Adopts Changes to 97.113

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The FCC has adopted rule changes to Part 97.113, allowing employees to communicate on behalf of an employer during emergency preparedness drills.

I’ve posted several times about this topic, see EmComm Trouble, Time to Change the Rules,  FCC Moving Ahead on the topic.

The new version of the rules are listed here:

§ 97.113 Prohibited transmissions.  
 
(a) * * *
(3) Communications in which the station licensee or control operator has a pecuniary interest, including communications on behalf of an employer, with the following exceptions:
 
(i) A station licensee or control station operator may participate on behalf of an employer in an emergency preparedness or disaster readiness test or drill, limited to the duration and scope of such test or drill, and operational testing immediately prior to such test or drill. Tests or drills that are not government-sponsored are limited to a total time of one hour per week; except that no more than twice in any calendar year, they may be conducted for a period not to exceed 72 hours.
 
(ii) An amateur operator may notify other amateur operators of the availability for sale or trade of apparatus normally used in an amateur station, provided that such activity is not conducted on a regular basis.
 
(iii) A control operator may accept compensation as an incident of a teaching position during periods of time when an amateur station is used by that teacher as a part of classroom instruction at an educational institution.
 
(iv) The control operator of a club station may accept compensation for the periods of time when the station is transmitting telegraphy practice or information bulletins, provided that the station transmits such telegraphy practice and bulletins for at least 40 hours per week; schedules operations on at least six amateur service MF and HF bands using reasonable measures to maximize coverage; where the schedule of normal operating times and frequencies is published at least 30 days in advance of the actual transmissions; and where the control operator does not accept any direct or indirect compensation for any other service as a control operator.

 

The FCC does allow for drills that are not government sponsored, but did include some time limits on these exercises. At first glance, these rules look reasonable to me. What do you think?

        73, Bob K0NR

This Spewed Out of the Internet #15

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It’s time to do one of those miscellaneous collections of drivel that spews forth from the interwebnet pipes. Some of this might even be important!

Some upcoming events: ARRL June VHF QSO Party and the Colorado FM Sprint, on the weekend of June 12th. The FM Sprint runs concurrently with the ARRL contest but only on Sunday afternoon. This is a good chance to get on the air with very basic equipment and have some fun.

The ARRL Field Day is coming up on June 26th and 27th. This is arguably the biggest on-the-air amateur radio event in North America.

I was playing around with setting up an SMS text messaging system for callsign lookup. The idea is that you send a text message (containing an amateur call sign) with your mobile phone and get the FCC or QRZ info back. In the meantime, I found that this problem has been solved by Callsign By Text. Very nice, check it out.

Female radio amateurs should check out Chick Factor International. It looks like a fun group.

I picked up a DV Access Point (DVAP) for D-STAR. This is a neat little device that provides flea-powered D-STAR access on 2 Meters by plugging it into a PC with internet connection. The South Yorkshire Repeater Group has a good description of the product. So far, this thing works really well.

By the way, the South Yorkshire group has a really good web site…interesting and timely information. Although they are in the UK, I find it relevant to US ham radio activity, too.

The Technician Class License question pool will be updated as of July 1, 2010. Our next Tech Class in Monument will be in October, so we’ll be updating the classroom material before teaching that class. It is clear that more technical content is being added to the question pool, which I think is a good thing. See KB6NU’s posting on the topic.

From The Complete Waste of Time Department, the FCC once again dismissed a petition from K9STH to change the amateur radio station identification requirements. Look, the FCC doesn’t see a problem here (and neither do I) so save yourself the trouble.

The FCC is seeking comments on the proposed new rules concerning emergency communications.  I took the time to file a short comment, basically saying that the FCC is on the right track but they should remove the reference to “government-sponsored drills”. Any legitimate emergency communications drill should be included, regardless of who sponsors it. The ARRL made similar but more detailed comments.

– 73, Bob K0NR

FCC Moving Ahead with EmComm Changes

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fcc-1The FCC has released a Notice of Proposed Rule Making (NPRM) concerning use of amateur radio by employees of governmental and other agencies. I had previously posted my thoughts on this topic back in October 2009.  A read of the NPRM on the FCC web site reveals that the FCC clearly sees this as an issue that needs to be addressed.

The tone of the NPRM is “what is the best way to address the problem” rather than “should we address this issue”?  In fact, the FCC went ahead and proposed this specific rule change for Part 97.113:

§ 97.113 Prohibited transmissions.
(a) ***
(3) Communications in which the station licensee or control operator has a pecuniary interest, including communications on behalf of an employer, with the following exceptions:
(i) A control station operator may participate on behalf of an employer in a government-sponsored emergency preparedness or disaster readiness test or drill, limited to the duration and scope of such test or drill, and operational testing immediately prior to such test or drill.
(ii) An amateur operator may notify other amateur operators of the availability for sale or trade of apparatus normally used in an amateur station, provided that such activity is not conducted on a regular basis.

The ARRL article concerning this development provides a good summary of the proposal. N5FDL has a brief discussion of the NPRM on his blog. Comments can be filed electronically on this NPRM on the FCC Electronic Filing Comment System.

I think this is moving in the right direction.

– 73, Bob K0NR

This Spewed Out of the Internet #13

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0511-0701-3118-0930Things have gotten a little busy for me, so sorry about going dark on blog postings. I had several weeks of business travel, followed by a wonderful trip to the Caribbean. Unfortunately, no ham radio action on any of these trips.

As usual, K3NG has posted some interesting stuff on his blog. First, he commented on Amateur Radio Liberation Day, then he had a good post on The Problem of Closed Source and Proprietary Algorithm Modes.

The Fi-Ni report explained the mysterious reappearance of the 15 Meter band.

After pestering hams with announcements that the new ARRL web site is about to be turned on (drum roll please….), the League had to back off and announce that it just wasn’t quite ready yet. It would be a lot more effective to launch the web site, then promote it. That way, when people go to check it out, it is actually there.

The FCC decided that it would be a good idea to allow a remotely-controlled robot to use 430-448 MHz as a radio control link. These robots are intended to be used by law enforcement agencies to enter hazardous areas without endangering personnel. I guessed they missed the fact that the 70 cm ham band is home for thousands of FM repeaters in the U.S. This is yet another lame spectrum management decision by the commission. (See K3NG’s post on this topic.)

– 73, Bob K0NR

Time to Change Part 97?

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when-all-else-fails-logoPart 97.113 has been the topic of much discussion lately, ever since the FCC communicated a rather narrow interpretation of the rules. See my previous post on this topic for more background information. From the ARRL web site, we find that the ARRL Board of Directors has chimed in:

The Board instructed the ARRL staff to seek a change in Section 97.113(a)(3) of the FCC rules to permit amateurs, on behalf of an employer, to participate in emergency preparedness and disaster drills that include Amateur operations.

This is not really a surprise and despite the usual criticism coming from some quarters, I am encouraged that the board sees this as an issue that requires action.

N5FLD lists the specific wording that the ARRL Board has approved, expressing some concern about the particular text chosen. I think we are clearly headed towards the standard FCC rule making process that will give everyone their say and, hopefully, we’ll arrive at a reasonable decision.

The February issue of CQ Magazine, arrived in the mail today, with a W2VU editorial taking on this topic. Rich points out that if you really want to get picky about it, ham radio publications are at risk due to a narrow interpretation of Part 97.113. For example, if an author is getting paid to review a new ham transceiver for publication in CQ, can he actually put it on the air without getting the foul flag thrown for “pecuniary interest”? So CQ wants to broaden the discussion, and has their own proposal for Part 97.113.

My read: stay tuned as we hash through this. There is enough support (based on good reasoning, I think) that this issue will get addressed. But it will take some time.

73, Bob K0NR


Amateur Radio: Not an Emergency Radio Service

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arrlnewlogo-transWell, that’s what the FCC says: the Amateur Radio Service is not an emergency radio service. K1ZZ’s QST editorial quotes the FCC and points out that the mission of the Amateur Radio Service is indeed broader than emergency communications. (The FCC does recognize the role that amateur plays in emergencies — see this web page.)

Lately, I’ve noticed a number of blog postings and other statements from hams that define amateur radio way too narrowly. The common thread is taking the part of ham radio that is most important to them and arguing that Real Ham Radio is focused on that segment of the hobby/radio service.

For some folks, amateur radio is emergency communications (only). Others argue that only technical pursuits are true ham radio and those appliance operators are just holding us back. For others, ham radio is defined by getting on the air and operating (might be QRP, might be contesting, might be something else).

I think K1ZZ got it right….the purpose is broader than that. Just go read Part 97.1 of the FCC rules:

The rules and regulations in this Part are designed to provide an amateur radio service having a fundamental purpose as expressed in the following principles:

(a) Recognition and enhancement of the value of the amateur service to the public as a voluntary noncommercial communication service, particularly with respect to providing emergency communications.

(b) Continuation and extension of the amateur’s proven ability to contribute to the advancement of the radio art.

(c) Encouragement and improvement of the amateur service through rules which provide for advancing skills in both the communications and technical phases of the art.

(d) Expansion of the existing reservoir within the amateur radio service of trained operators, technicians, and electronics experts.

(e) Continuation and extension of the amateur’s unique ability to enhance international goodwill.

Let’s reject the narrow view and think a bit broader.

73, Bob K0NR

This Spewed Out of the Internet #9

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0511-0701-3118-0930I have been traveling quite a bit lately for work, so here’s a catch up on a number of things spewing forth from the interwebnet.

I’ve recently re-discovered High Frequency Electronics Magazine, edited by Gary Breed, K9AY. This is a top quality trade pub that targets RF design engineers. In Gary’s September editorial, he highlighted the environment that the college class of 2013 grew up in….such as “text has always been hyper.”

I came across this summary of Top Ham Radio Blogs. They clearly have excellent judgment, since my blog is listed.  🙂

Computer World published this article,  Want to bone up on wireless tech? Try ham radio, a good read on the experimentation side of amateur radio written by John Edwards, W6JE.

Google’s Eric Schmidt talks about the future of the web…some interesting thoughts.  I hope his prediction of 100MB broadband comes true…but I am not expecting it to come down my road any time soon.

KB9MWR posted an interesting article about the radio range of D-STAR.

Ham radio saves the world (again)…. hams assist rescue on Catalina Island. This reminds me of when  I was out climbing Uncompahgre Peak and radio’d in a fallen hiker report.

Last weekend was the CQ Worldwide DX Contest (SSB version), so I did get on the air for a few hours. Mostly, I got clobbered on 20 Meters with my 100-Watts-to-a-dipole station being overrun by the Big Gun Stations. I did manage to work some DX on both 15M and 20M.

The FCC actions concerning EmComm and Part 97.113 have exposed different views on the role of amateur radio in emergency communications. See the comments on my blog posting, this article by Steve K9ZW and N5FDL’s blog. There seems to be some pent up frustration with ham radio EmComm folks coming from some corners of the ham community.

I encourage everyone to go back and read Part 97.1, the Basis and Purpose of the Amateur Radio Service. It lists five different items as the purpose of amateur radio, all of which are relevant and important. I’d also suggest that everyone lighten up just a bit (and be sure to stay on your meds).

73, Bob K0NR

Time to Change the FCC Rules for EmComm?

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fcc-1The FCC continues to drive out any ambiguity on how it interprets Part 97.113. (See previous post EmComm Trouble From the FCC. ) On October 20th, the FCC released Public Notice DA-09-2259, which reiterates the principle of no amateur radio communication on behalf of an employer, even if the employer is a government agency such as a fire or police department. OK, I think they got that point across.

The FCC also described a process for requesting a waiver of this rule for a specific emergency preparedness drill. A governmental entity, not the amateur radio operators involved, must apply to the FCC for a waiver in advance of the drill. According to N5FDL, the FCC intends these waivers to be for very specific events and not a regularly scheduled activity such as a weekly net. This can help facilitate a major event but is still fairly limited. I wonder how many waiver requests the FCC be receiving? I suspect there will be many.

A group of radio amateurs, The Amateur Radio Policy Committee, consisting of N5GAR, WB6NOA and N5FDL have filed a Petition for Rule Making with the FCC to address this situation. Basically, they propose that an additional item be added to the section of  rules (Part 97.111) that calls out Authorized Transmissions:

(6) Transmissions necessary for disaster relief or emergency response, including training exercises, planning, drills or tests, without regard to whether the amateur operator has related employment, where the transmissions are for the exclusive use of amateur radio operators for noncommercial purposes.

This seems like a reasonable and measured approach to changing the rules to support emergency communications training activities, without opening the door too wide. I am not sure why they proposed to modify Part 97.111 instead of 97.113 where other employment exceptions are handled (e.g., control operator of a club station that sends telegraphy practice, teacher in a classroom setting). The RAIN Report has an interview with N5FDL concerning this petition.

I still believe the FCC could have avoided this ruckus with a slightly more liberal interpretation of the rules. They didn’t do that, so now we will have to go through the rule making process to deal with the situation. I suppose that the FCC could decline to address the issue but this seems unlikely to me given the legitimate public interest in supporting emergency communications. (Anyone remember 9/11 ?) We’ll likely get to a reasonable outcome that protects the amateur radio service from undesirable encroachment while still enabling emergency communications training.

What do you think?

73, Bob K0NR

EmComm Trouble From the FCC

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fcc-1There has been quite a ruckus about the FCC and Part 97.113 concerning emergency communications but I have been taking a wait and see attitude about it.  These FCC Rules say:  No amateur station shall transmit communications in which the station licensee or control operator has a pecuniary interest, including communications on behalf of an employer.

The question on the table is whether this prohibition strictly applies to employees of a public safety organization. For example, is it a violation of the rules for a firefighter or hospital employee to use ham radio as part of a emergency communications practice exercise? Apparently, the answer is yes.

Read this posting on the N5FDL Blog for more details, including some correspondence with the FCC. The ARRL offered this explanation in the September issue of QST. This article reports that W0WLS is withdrawing from ham radio emcomm work after getting a letter from the FCC’s Laura Smith.

The K3NG Report says that The FCC is Throwing the Baby Out With the Bathwater.  I agree.

If you are involved with emergency communciations, you should make sure you understand this latest development.

   73, Bob K0NR

This Spewed Out of the Internet #4

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0511-0701-3118-0930Things have gotten quite busy at work, which is why I haven’t posted anything recently. The spare time I have has gone towards getting ready for Hamcon Colorado, as I have signed up to do two presentations and a few other tasks. Here’s some items that are worth mentioning that spewed out of the internet.

I haven’t seen the new Star Trek movie yet but Saturday Night Live did a skit relating to it. Also, the classic Shatner “Get a Life” skit is out on youtube. Both of these can be viewed here.

Speaking of youtube, the Society for Geek Advancement (huh?) has a video that features all of your favorite geek celebrities. Is “Geek Celebrities” an oxymoron?

The FCC posted some recent enforcement letters concerning amateur radio cases. Go Laura Smith! Included in this list is a nastygram to the idiots at Xcel Energy which is having trouble tracking down power line noise problems in Northglenn, Colorado. As the ARRL section Technical Coordinator, I had some involvement in this incident — all I will say is that it’s difficult to tell whether Xcel is incompetent or just irresponsible. Hard to say.

Speaking of the FCC, they have really gotten caught with their pants down in their analysis and handling of Broadband over Powerline (BPL). Thanks to the ARRL for keeping after them and getting the suppressed FCC documents via the Freedom of Information Act. Here’s a good article about it from an non-ham-radio source, ars technica.

K3NG raised the question of whether it is possible to have a useful amateur radio web site without the trolls and misfits. It seems that qrz.com is attempting to rise to the challenge. Good for them.

I stopped by the DTV.gov site that has information concerning the migration to Digital TV in the US. I was surprised to find that they added quite a bit of detail about when TV stations are switching over. Also, they have an interactive map that gives you estimated TV signal strength in dBm at an arbitrary location.  (Yes, real live technical information !)

From the Amateur Radio Fun in the Mountains Department, there is a group planning to create a packet radio link that extends the length of the Appalachian Trail (The AT Golden Packet Annual Event).  Sounds like fun to me.

73, Bob K0NR