Posts Tagged ‘FCC’
U.S. LF Bands – Rulemaking Ruminations (Part 2)
June 4th, 2015 | 
Author: 
(...cont'd)* TWO: We need more technical showings this time, with as many solid
details as possible. I hope the Part 5 licensees are prepared to crunch
numbers, but those of us who only monitored are also able to contribute.
(Much more on this in future correspondence, I expect.) In par. 169. the FCC enquires: "to meet our goal of providing for the coexistence of amateur services and PLC systems in these bands, we seek detailed comment on the technical characteristics of both the PLC systems and the amateur stations.
This information will allow us to set an appropriate separation distance."
The very next sentence, though, I recognize as a somewhat worrisome bit of FCC-speak: "Although the Commission in the WRC-07 NPRM inquired into the technical rules and methods that would assure coexistence, commenters provided little in the way of concrete information." Read that as said with a slightly scolding tone, but with a facial expression that says they're keeping an open mind.
The utilities, IMO, provided no concrete technical information at all. ARRL
cited the 1985 NTIA study on which the 1 W EIRP and 1 km separation idea is based, but the FCC is concerned whether that's still valid. Well, one would hope that any changes made to PLCs over the past 30 years would be toward making the system more robust, not more vulnerable to evildoers, accidents, and natural disasters, but this could prove an area of contention. That may be something the big guys have to fight out; I don't know how much we as individual licensees or observers can contribute. But there ARE other technical matters the FCC needs and wants to know, which we may be able to furnish.
For instance, what sort of PLC signal levels have we actually experienced in the proposed bands? How serious were their impact on licensed activity, and how have PLCs been coped with in actual operation? Also at paragraphs 171, 178, and 178, the FCC is asking for some really fundamental, crucial data.
Namely: What sort of power levels have the Part 5 licensees actually
radiated, and at what actual separations from transmission lines? What
maximum size should an amateur antenna be, and--the biggie, in my view--what is the efficiency of both "typical" and potential amateur antenna systems?
(The Commission would like us to include information from Canadian and
European hams on these issues as well. Details of amateur practice in the
rest of the world could be very helpful in formulating rules here.)
Those operators who have the capability of measuring their true field
strength are in an especially excellent position to help quantify current
practice. Those who can't do that, but are able to measure their ground
losses accurately, can make reasonable calculations to show the maximum
efficiency possible with antennas of various heights. That's likely
preferable to doing it all in NEC modeling, since not all such software is
really good at predicting ground system losses, especially at LF. I'll
gladly offer my own ground system's resistance numbers to anyone who wants to do the math, for instance, as its 32 radials of 104 to 135 ft length in 15 mS/m soil are probably representative of a fairly decent ground for
antennas up to 100 feet high...and I'll be doing another set of readings
very soon, which can include measurements at 2200 m this year in addition to the runs I routinely do at 1750 m.
* THREE: At 172, the FCC observes: "If we were to adopt our proposal to
permit amateur operations only when separated by a specified distance from transmission lines, when a new transmission line is built close by an
amateur station, the station either would have to relocate farther away from the transmission line or cease operating." Scary, huh. But they go on to ask: "How should our rules address the potential for new transmission lines to be constructed closer than the specified distance to pre-existing amateur stations? We do not want to inhibit the ability of either PLC systems or amateur services to grow and expand without imposing unnecessary burdens on either. Is it possible for utilities to refrain from geographically expanding their PLC operations within the relatively small portion of the 9-490 kHz band that we are making available for amateur operations, and is this something utilities would do on their own accord, given the Part 15 status of PLC systems? Should our rules explicitly prohibit utilities from deploying new PLC systems in these bands?"
My answer: yes, please. Look back at par. 26, in the WRC-07 R&O section
where the Commission explains their basis for adding the 2200 m allocation:
"We intend to structure these service rules to promote shared use of the
band among amateurs and PLC systems. Amateurs will not be able to use their allocation status to force unlicensed PLC operations out of the band, and utilities will have no cause to abandon or incur large costs to modify
existing PLC systems." Read that again: "Amateurs will not be able to use
their allocation status to force unlicensed PLC operations out of the band."
That's the reality of the matter, and yet I think it also works in our
favor.
So far as I know, this situation is unique in the history of radio regulation. I can't think of another example where an incumbent, but unlicensed and unallocated, user of radio spectrum has been afforded such protection from any allocated and licensed service. However, most of us who commented in the 2013 proceeding DID AGREE with the Commission that PLC technology has been a special case for a long time, and most recognized that acceptance of its existence was the only way to move the discussion off dead center and get to the point where we are now.
But I maintain this coin has two sides. If we in a licensed, allocated service are willing to accept that we cannot displace existing PLCs now or in the future, then it is ONLY FAIR that the unlicensed, unallocated users should not be able to displace the licensed users, either, now or in the future. Otherwise, it is not truly sharing.
The only way I can see to guarantee protection to licensed users, comparable to what the unlicensed ones will have, is to incorporate within Part 15 a prohibition on any changes in power, transmission mode, and route of existing PLC systems, or installation of new ones, within a reasonable band centered on the new amateur allocations. That achieves the stated goal of not displacing existing systems or burdening the utlities by forcing any changes to them, while only removing two small slices of spectrum from consideration for future installations. That seems an entirely reasonable compromise to me.
Your comments are welcome--and essential!
73
John Davis
You can view comments as well as file your own, via the link from this page:
http://apps.fcc.gov/ecfs/proceeding/view?name=15-99
U.S. LF Bands – Rulemaking Ruminations (Part 1)
John Davis of the Longwave Club of America has been doing a good job of keeping us informed of the present 2200/630m application status for U.S. amateurs. It seems that although the NPRM has not yet been published in the Federal Register, the FCC website is open for comments on this issue. I would urge all amateurs with an interest in LF operation to file comments that address the FCC's Notice Of Inquiry (NOI), particularly if you have been operating an experimental station. As well, Canadian LFers operating on either band should consider filing comments as well, describing your system and overall operating results. You can read a full review of the FCC's concerns in three of my earlier blogs:
http://ve7sl.blogspot.ca/2015/04/lf-mf-next-step-for-us-amateurs-part-1.html
http://ve7sl.blogspot.ca/2015/05/lf-mf-next-step-for-us-amateurs-part-2.html
http://ve7sl.blogspot.ca/2015/05/lf-mf-next-step-for-us-amateurs-part-3.html
John's latest information points out what he believes are three crucial points that deserve serious thought. As he indicates, if we don't 'get it right' the first time, it might be very difficult to make any changes after the fact. Please give serious thought to John's information and to filing your own comments at the link provided.
In John's own words:
Rulemaking Ruminations
This is probably a good time to get discussion reactivated on the MF and LF ham proposals. Although I continue not to see publication of the NPRM in the Federal Register as yet, the FCC EFCS Web page for the proceeding is open and accepting filings. Until FR publication, we won't know the closing dates for comments and replies, but you can see what's already been going on at:
http://apps.fcc.gov/ecfs/proceeding/view?name=15-99
While I've been awfully tied up with other things recently, my reading of
the proposal thus far brings to mind three points I believe we earnestly
need to address with the Commission. This proceeding will set the exact US
rules for 2200 m, and very probably also 630 m, so it behooves us to make
the best case we can, now, right up front. If the initial rules are too
restrictive on amateur activity, it could be very difficult and time
consuming to get them changed. Here are my present concerns.
* ONE: In paragraph 168, the FCC states that in addition to separation
distances and power limits, "we propose to limit amateur stations to
operations at fixed locations only to ensure that this separation distance
can be maintained reliably." That's stricter than it may first sound. The
FCC's actual proposed wording for § 97.303(g)(1), for both 2200 and 630 m,
is: "Amateur stations are restricted to use at permanent fixed locations."
Permanent fixed locations. That goes way beyond my suggestion that mobile operation be prohibited. It precludes temporary fixed operation, such as Field Day activities, or tests of ground characteristics for future potential antenna sites, or other legitimate short-term experiments. In my view, this is needlessly restrictive, and could also open the door to more rigid coordination requirements that might paint us into a corner, figuratively and literally, at our original QTHes.
We need to make a strong case that hams are able to identify electric
transmission lines and maintain 1 km separation (or other specified
distance) from them. This further relates to comments the FCC seeks in par. 176: "Amateur licensees will have to determine the location of transmission lines in their vicinity to determine if they are permitted to operate stations using these frequency bands. .... High voltage transmission lines are typically attached to large steel towers that are easy to identity.
However, lower voltage transmission lines are typically attached to wooden poles. Although the wooden poles used for transmission lines are usually taller than the wooden poles used for distribution lines, we recognize that distinguishing the two types may not always be straightforward. We seek comment on whether amateur licensees will be able to identify the transmission lines in their locality."
Obviously, just glancing around a proposed operating site and saying "nope, I don't see a transmission line" is not enough. But I think we're smart enough to do responsible surveys of all lines within a mile or so in all directions, identify any substation locations, and determine which sets of poles have customer connections (practically the definition of distribution lines) and which don't (therefore assumed to be transmission lines). We need to convince the FCC that we can tell the difference.
... to be cont'd
FCC Eliminates Amateur Radio Vanity Call Sign Regulatory Fee
05/22/2015
The FCC is eliminating the regulatory fee to apply for an Amateur Radio vanity call sign. The change will not go into effect, however, until required congressional notice has been given. This will take at least 90 days. As the Commission explained in a Notice of Proposed Rulemaking, Report and Order, and Order (MD Docket 14-92 and others), released May 21, it’s a matter of simple economics.
“The Commission spends more resources on processing the regulatory fees and issuing refunds than the amount of the regulatory fee payment,” the FCC said. “As our costs now exceed the regulatory fee, we are eliminating this regulatory fee category.” The current vanity call sign regulatory fee is $21.40, the highest in several years. The FCC reported there were 11,500 “payment units” in FY 2014 and estimated that it would collect nearly $246,100.
In its 2014 Notice of Proposed Rule Making (NPRM) regarding the assessment and collection of regulatory fees for FY 2014, the FCC had sought comment on eliminating several smaller regulatory fee categories, such as those for vanity call signs and GMRS. It concluded in the subsequent Report and Order (R&O) last summer, however, that it did not have “adequate support to determine whether the cost of recovery and burden on small entities outweighed the collected revenue or whether eliminating the fee would adversely affect the licensing process.”
The FCC said it has since had an opportunity to obtain and analyze support concerning the collection of the regulatory fees for Amateur Vanity and GMRS, which the FCC said comprise, on average, more than 20,000 licenses that are newly obtained or renewed, every 10 and 5 years, respectively.
“The Commission often receives multiple applications for the same vanity call sign, but only one applicant can be issued that call sign,” the FCC explained. “In such cases, the Commission issues refunds for all the remaining applicants. In addition to staff and computer time to process payments and issue refunds, there is an additional expense to issue checks for the applicants who cannot be refunded electronically.”
The Commission said that after it provides the required congressional notification, Amateur Radio vanity program applicants “will no longer be financially burdened with such payments, and the Commission will no longer incur these administrative costs that exceed the fee payments. The revenue that the Commission would otherwise collect from these regulatory fee categories will be proportionally assessed on other wireless fee categories.”
The FCC said it would not issue refunds to licensees who paid the regulatory fee prior to its official elimination.
----------------------------------------------------------------------
So basically the FCC is saying, it costs more to process the fees and refunds of fees than it's worth. I am going to assume (a dangerous thing), or at least hope that this also applies to the renewal as well as the initial application.
72 de Larry W2LJ
QRP - When you care to send the very least!
Can I Use My Ham Radio on Public Safety Frequencies? Updated
This is an update to one of my most popular posts.
We have quite a few licensed radio amateurs that are members of public safety agencies, including fire departments, law enforcement agencies and search and rescue. Since they are authorized users of those public safety channels, they often ask this question:
Can I use my VHF/UHF ham radio on the fire, police or SAR channel?
It is widely known that many amateur radios can be modified to transmit outside the ham bands. The answer to this question used to be that amateur radio equipment cannot be used legally on public safety channels because it is not approved for use under Part 90 of the FCC Rules. (Part 90 covers the Private Land Mobile Radio Services.) The only option was to buy a commercial radio with Part 90 approval and a frequency range that covered the desired amateur band. Some commercial radios tune easily to the adjacent ham band but some do not. The commercial gear is usually two to three times as expensive as the amateur gear, and just as important, does not have the features and controls that ham operators expect. Usually, the commercial radios do not have a VFO and are completely channelized, typically changeable only with the required programming software.
The situation has changed dramatically in the past few years. Several wireless manufacturers in China (Wouxun, Baofeng, Anytone, etc.) have introduced low cost handheld transceivers into the US amateur market that are approved for Part 90 use. These radios offer keypad frequency entry and all of the usual features of a ham radio. It seems that these radios are a viable option for dual use: public safety and amateur radio, with some caveats.
New radios are being introduced frequently, so I won’t try to list them here. However, you might want to do a search on Wouxun, Baofeng and Anytone for the latest models. I will highlight the Anytone NSTIG-8R radio which I have been using. It seems to be a well-designed but still affordable (<$75) handheld radio. See the review by PD0AC.
Some Things to Consider When Buying These Radios
- The manufacturers offer several different radios under the same model number. Also, they are improving the radios every few months with firmware changes and feature updates. This causes confusion in the marketplace, so buy carefully.
- Make sure the vendor selling the radio indicates that the radio is approved for Part 90 use. I have seen some radios show up in the US without an FCC Part 90 label.
- Make sure the radio is specified to tune to the channels that you need.
- The 2.5-kHz tuning step is required for some public safety channels. For example, a 5-kHz frequency step can be used to select frequencies such as 155.1600 MHz and 154.2650 MHz. However, a 2.5 kHz step size is needed to select frequencies such as 155.7525 MHz. There are a number of Public Safety Interoperability Channels that require the 2.5-kHz step (e.g., VCALL10 155.7525 MHz, VCALL11 151.1375 MHz, VFIRE24 154.2725). The best thing to do for public safety use is to get a radio that tunes the 2.5-kHz steps.
- Many of these radios have two frequencies in the display, but only have one receiver, which scans back and forth between the two selected frequencies. This can be confusing when the radio locks onto a signal on one of the frequencies and ignores the other. Read the radio specifications carefully.
Recommendation
There are a number of reasonably good radios out there from various manufacturers. My favorite right now is the Anytone NSTIG-8R but I also like the Wouxun KG-UV6D. The Baofeng UV-5R continues to be popular in the amateur community as the low cost leader. However if you show up at an incident with the Baofeng, your fellow first responders will think it is a toy. Which leads to a really important point: the established commercial radio manufacturers such as Motorola, Vertex, etc. build very rugged radios. They are made for frequent, heavy use by people whose main job is putting out fires, rescuing people in trouble and dealing with criminals. These low cost radios from China are not in the same league. However, they can still serve in a less demanding physical environment while covering the Amateur Radio Service (FCC Part 97) and the Private Land Mobile Radio Services (FCC Part 90).
73, Bob K0NR
The post Can I Use My Ham Radio on Public Safety Frequencies? Updated appeared first on The KØNR Radio Site.
Amateur Radio Newsline Report 1954 February 27 2015
- Ham radio responds as a pair of tropical cyclones hit Australia
- The FCC and the FDA look the future of medical remote electronics
- Printed FCC issued ham licenses come to an end
- Stunning images received from the latest ISS slow-scan television experiment
- And the nominating period opens for the 2015 Amateur Radio Newsline Young Ham of the Year Award
THIS WEEK'S NEWSCAST
Yaesu FT 991 – all mode, all band transceiver
This rig does look like it will be popular, although at a stated UK price of £999 I have my doubts. This seems VERY high to me when the FT840D now sells for £619 before negotiation for a cash deal. UK exchange rates with Japan (£-Yen) have greatly improved, so rig prices should be falling dramatically. At £699, rather than £999 I can see it doing very well. Far less well at £999. In the USA expect to pay $999.
See http://qrznow.com/yaesu-ft-991/ for pictures and a video. I see the rig has now passed FCC testing . I have no news of CE approvals in Europe. Don’t expect we’ll see it in Europe before spring 2015.
I do hope dealers in the UK offer it at a sensible price. Get the price right and you deserve to sell lots of these units. Personally, I’d like to see a 10W or 30W version but doubt this will come in Europe or the USA. Of course, an FT817 replacement might be on the cards? We live in eternal hope.
LHS Episode #133: We’re Baaack!
Hello again! Linux in the Ham Shack is back online after a three-month absence. Thank you all for sticking out our downtime with us. We’ve retooled the show a little bit, added some segments, and tightened up the format. But all the fun, information and Linux and hammy stuff remains! Looking forward to many more years of our show. Sit tight, strap in–we’re just getting started. Again.
73 de The LHS Guys
