wheatley@inuxi.UUCP (Steven Wheatley) (11/15/85)
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THE / R R \ LETTER
VOLUME 4 \ / NUMBER 23
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November 11, 1985
The ARRL Letter is published bi-weekly by the Information
Services Department of the American Radio Relay League, 225 Main
St., Newington, CT, 06111; (203) 666-1541. Larry E. Price, W4RA,
President; David Sumner, K1ZZ, Executive Vice President; Dave
Newkirk, AK7M, Editor; Debra Chapor, Circulation Manager.
Information from The ARRL Letter may be reproduced in whole
or part in any form including photoreproduction and electronic
databanks, providing credit is given to The ARRL Letter and to
the American Radio Relay League.
The ARRL Letter is available in printed form from ARRL.
Subscriptions, limited to ARRL Members, are $19.50 (U.S. funds)
per year for First-Class Mailing to the U.S., Canada, and
Mexico. Overseas air mail subscriptions are available at $31
(U.S. funds) per year. Sample copies are available for an
s.a.s.e.
In this issue:
o Electronic Communications Privacy Act of 1985
o QCWA to File Comments
o ARRL Speaks on Auxiliary Operation
o ...and much more!
WE'LL SHARE 1900-2000 kHz WITH RADIOLOCATION: FCC
By FCC Report and Order released October 31, non-government
radiolocation has been given primary status at 1900-2000 kHz.
FCC believes this action in PR Docket 84-874 is a necessary
prerequisite to future displacement of radiodetermination now at
1605-1705 kHz, a position ARRL disputes. A future proceeding
will address possible expansion of standard broadcasting at 1605-
1705 kHz in the Western Hemisphere. ARRL's fight against this
reallocation had been in the works for many months; see
Happenings, November 1984 QST. Effective December 9, 1985,
amateur stations in the 1900-2000 kHz range must not cause
harmful interference to the radiolocation services and are
afforded no protection from interference arising from
radiolocation operations. Though FCC will not accept
applications from 1605-1705 kHz radiodetermination stations for
moves to 160 until July 1, 1987, plans are afoot to allow new
spread-spectrum radiolocation stations access to 1900-2000 kHz as
early as December 9 of this year. FCC claims that amateurs will
still have "virtually exclusive non-government use of 1900-2000
kHz until private radiolocation transmitters become operational."
ARRL may file for reconsideration; watch the Letter for details.
January QST will cover more of the 1900-2000 kHz reallocation and
resultant changes to Part 97.
WHAT THE LEAGUE HAD TO SAY ON "AUXILIARY OPERATION 'EVERYWHERE'"
In the July 18 Letter, we detailed an FCC proposal (in PR
Docket 85-215) to allow auxiliary operation on all amateur
frequencies with the exception of 431-433 and 435-438 MHz.
Auxiliary operation is defined in Part 97.3 of the Rules as
"radio communication for remotely controlling other amateur radio
stations, for automatically relaying the radio signals of other
amateur radio stations in a system of stations, or for
interconnecting with other amateur radio stations in a system of
amateur radio stations." Currently, auxiliary operation is
allowed only on frequencies above 220.5 MHz. Here are the
highlights of the League's comments in 85-215.
The Quarter Century Wireless Association had petitioned FCC
to delete the frequency restriction ("all amateur frequency bands
above 220.5 MHz, except 431-435 and 435-438 MHz") from Part 97
because "the technological state of the art has made restrictions
on auxiliary operation unnecessary." The League sees that the
FCC proposal does not deal with spectrum management issues,
however. How has technological development had any effect on the
need to limit auxiliary operation to certain VHF and UHF
frequencies? How will such expansion permit increased
flexibility in auxiliary operations? It appears that the
proposal would have the effect of shifting auxiliary operations
to lower, more congested frequencies.
ARRL comments continue with a discussion of how crowding on
the medium- and high-frequency bands makes them unsuitable for
auxiliary operation, with the added headache of MF/HF propagation
disallowing local frequency coordination of links on those
frequencies. Many auxiliary operations, such as remote control
of an HF station, require a high duty-cycle, which could only
make interference worse in the more crowded bands. Why use long-
haul frequencies for short-haul auxiliary links? 2 meters is
another bad candidate for auxiliary work; it is fully loaded in
many areas of the country. ARRL comments that the Commission is
correct in protecting the weak-signal and satellite bands at 431-
433 and 435-438 MHz, but similar segments should be protected on
all bands.
For these reasons, ARRL has requested that the Commission
not permit auxiliary operation on frequencies below 220.5 MHz,
that Section 97.86 of the Rules not be modified as proposed, and
that the proceeding be terminated without further action.
QCWA REQUESTS EXTENSION OF TIME TO FILE COMMENT IN DOCKET 85-215
The Quarter Century Wireless Association (QCWA), has asked
FCC to extend the time in which to file comment in Docket 85-215
(see "What the League Had to Say . . . " above). QCWA said that
detailed comment in 85-215 will require time-consuming analysis,
and that the Association does not feel it can respond
meaningfully within 30 days, and requests an extension of time to
file of 60 days. If granted, this would mean a new Reply Comment
deadline of December 24, 1985.
NEW ORLEANS FCC DISTRICT OFFICE MOVES
Effective October 18, the new address for the New Orleans
District office is 800 West Commerce, Room 505, New Orleans LA
70123; telephone 504-589-2095. Public inquiries concerning
telecommunications matters, complaints of electronic interference
and schedules of commercial radio operator examinations should be
directed to this address.
1986 CHARGE FOR ARRL/VEC EXAMS
FCC announced on October 31 that effective January 1, 1986,
the maximum allowable test fee will be $4.29 for a Volunteer-
Examiner-administered Amateur Radio examination. The ARRL/VEC
will charge $4.25 per candidate for tests taken in 1986 through
Volunteer Examiner Teams working directly with the ARRL/VEC. The
ARRL/VEC coordinates test sessions in all fifty states plus many
locations overseas. Send an s.a.s.e. to Hq. for an updated
printout of the test sessions in your area.
YOU CAN'T TAKE THE SAME TEST THE NEXT TIME
Effective November 8, FCC lifted Rule 97.26(h) requiring a
candidate to wait thirty days before being retested on a failed
exam element. The Commission now requires that a candidate being
retested not take exactly the same test that was failed
previously. FCC also directs that the VE Teams have the right
not to retest anyone at the same session. Under the ARRL/VEC
procedure, a candidate who fails may not be retested at the same
test session. Once the candidate fails a written element, his or
her participation at a session has ended. Subsequent retesting
will occur only when the candidate submits a new Form 6l0
application and an additional test fee.
ARRL ON VEC MAINTENANCE OF EXAM QUESTION POOLS
If the Notice of Proposed Rulemaking in PR Docket 85-196 is
adopted as proposed, Volunteer-Examiner Coordinators would be
allowed to maintain their own question pools used to create
examinations for amateur licenses. This maintenance is presently
performed by the FCC, and VECs design written examinations by
choosing questions from the FCC-issued pool.
ARRL adheres to the principle that the Commission, and not
Volunteer-Examiner Coordinators, should retain responsibility for
all Amateur Radio examination question pools. " . . . It appears
that it was intended by Congress that the Commission should be
the entity which is responsible for maintenance of the question
pools. It is questionable whether the delegation of authority to
maintain question pools -- the most basic level of Commission
supervision over examination quality -- is statutorially
permitted . . . as recently as July 20, 1984, the Commission
specifically clarified the rules to require 'that questions
chosen for written examinations must be taken verbatim from FCC-
approved lists.' Nothing has changed since then to moot that
laudatory objective."
The opportunity for Commission review of questions submitted
for inclusion in the question pool provides an undeniably
beneficial filtering process for the varied type and quality of
questions. Since FCC itself has stated that its maintenance of
the pools is now mainly a custodial function, it cannot be argued
that Commission maintenance of question pools is a significant
regulatory burden. Assigning VECs the responsibility for
maintaining question pools would be a step away from uniform
standards and fairness; it would be a step toward allowing
"shopping for the easiest examination."
The second proposal contained in the NPRM is the
acceleration of the authority for Volunteer Examiners to design
individual examinations for each examination element. While the
preparation of individual examinations by VECs has worked out
well, it is neither necessary nor desirable to permit individual
examiners to prepare examinations from the question pools. If
VEs are permitted to create the examinations, it would be
possible for them to "teach to the test." VEs would not even
have to divulge the contents of an upcoming examination -- they
would be authorized to create the same. VECs must erect a
"Chinese Wall" between
trainer and examiner functions. This principle would be
impossible to enforce at the local club level. The advantage of
the present system is that no one in the field knows the contents
of a particular examination until shortly before the test date.
There is no unreasonable delay in obtaining examinations;
there is an ample number of VECs to create them from the question
pool. Paperwork is already time-consuming for Volunteer
Examiners. Asking them to prepare examinations on top of this is
more of a burden than is advisable. Overall, the League adheres
to the principle that VECs, but not VEs, should be authorized to
prepare individual examinations from the Commission-maintained
question pool.
THE ELECTRONIC COMMUNICATIONS PRIVACY ACT OF 1985
As of mid-September, the Electronic Communications Privacy
Act of 1985 (S. 1667 and H.R. 3378) is pending in Congress. The
bill would amend Title 18 of the U.S. Code with respect to
unlawful interception of wire and wireless electronic
communication, authorizing the recovery of civil damages from and
introducing stiff penalties for computer crimes and destructive
"hacking." The intent is a broadening of the definitions both of
protected communications ("any transmission of signs, signals,
writing, images, sounds, data or intelligence of any nature in
whole or in part by a wire, radio, electromagnetic, or
photoelectric system that affects foreign or interstate
commerce") and prohibited practices. Licensed Amateur Radio and
CB transmissions are listed among "unprotected" communications
(students of double negatives will appreciate that interception
of our transmissions would continue to be "not unlawful"), but
the progress and evolution of the Act will bear close watching.
902-928 MHZ ACCESS ASKED FOR LOW-POWER VIDEO LINKS
Jerry Iggulden of Valencia, California, has petitioned the
FCC for a rulemaking in amendment of Part 15 of the Commission's
rules to allow unlicensed operation of low-power video
transmitters at 902-928 MHz. "The rules and regulations
currently don't allow for the non-licensed, low power
transmission in any band suitable for video," Iggulden wrote in
his September 11 petition. " . . . The proposed rule changes
would allow for a video transmitter and receiver/converter
operating at 902 to 928 MHz. It is the perception that these
devices would serve the public interest by offering the benefit
of broadcasting a video signal from the home video cassette
recorder (VCR) to a TV in a remote location(s) (i.e., another
room). It is virtually certain that the cost to the consumer for
this benefit would be significantly less than a second VCR."
Iggulden, whose interest in the proposed rules changes is in
"potential involvement with a company whose business would be to
market the proposed devices," notes that the field strength
presently allowed by the applicable subpart of Part 15 would be
more than adequate for transmission over a short range or within
a single-family dwelling. "In fact," he continues, "the
Commission may wish to impose a lower field strength limit on the
proposed devices in order to prevent interference problems.
What might this mean to amateur operations at 902 MHz?
Iggulden's petition, designated as RM-5193 by FCC, appears to
have been written without knowledge of the then-impending
occupancy of 902-928 MHz by the Amateur Radio Service. Though
our amateur allocation at 902 MHz is secondary, we're not
secondary to the unlicensed emissions of devices operating under
Part 15 -- so any such video links would have to suffer our
interference and would be proscribed from interfering with us.
And if you think that some of those second-harmonic cordless
phone conversations polluting the low end of 80 meters are spicy,
what of some of the video we might run into if low-power video
links opened up at 902?
WA8AJN LICENSE SUSPENDED; REVOCATION PROCEEDING INITIATED
An Order to Show Cause and Suspension Order has been issued
to J. Fred Riley, WA8AJN, of Kenova, West Virginia. Riley, an
Extra Class licensee, is charged with violating Section 97.125 of
the Amateur Rules -- the rule prohibiting "malicious
interference," or jamming of radio communications of others.
Also alleged were violations of Sections 97.84 and 97.123, which
are station identification rules. The Commission's September 23
Order requires Riley to show cause why his amateur station
license should not be revoked and suspends his amateur operator
license, based on these rule violations. Riley had 30 days to
request a hearing or a written statement concerning the matter.
His request for an extension of the reply period to October 31
was granted; no further news was available to press time.
YOUNG ASTRONAUT COUNCIL VOLUNTEERS SOUGHT
The Young Astronaut Council and ARRL are looking for radio
amateur volunteers to provide space communications experiences
for young people in YAC chapters around the nation. Think you're
ready? Requirements for amateur volunteers are a willingness to
devote a substantial amount of time to working with local
chapters on a long term basis, and the ability to provide space
communications activities such as OSCAR, earth-moon-earth and
ham-in-space activities, including monitoring shuttle audio
transmissions. Volunteers will be listed as resources in the
Young Astronauts Program Chapter Leaders' handbook, and would be
contacted directly by local chapter leaders seeking space
communications activities. What say? Leave your phone number
with the Development Office, ARRL Hq.
MARCE IN SPACE NEXT MONTH
The Marshall Amateur Radio Club Experiment (MARCE) will fly
on space shuttle Mission STS-61C, scheduled for launch on
December 18. The experiment will transmit telemetry in
synthesized speech directly on 435.003 MHz FM and via AMSAT-OSCAR
10 relay on 145.972 MHz FM. Though the experiment may be audible
mainly in the southern hemisphere, amateurs in the southern
portion of the U.S. may have a shot at taking part in taping
MARCE's telemetry. For more details, contact the Development
Office, ARRL Hq.
INTERFERENCE FROM ULTRASONIC PEST CONTROL DEVICES
Ultrasonic pest control devices are advertised to repel pests
(i.e., mice, rats, roaches, etc.) through the emission of
acoustic noise that cannot be heard by people. These devices
have been found to cause electromagnetic interference to televi
sions, as well as other types of equipment. Frequencies at which
interference has been reported range from 20 to 470 MHz. Though
pest control devices are not normally subject to FCC controls,
ultrasonic devices of this type are subject to the technical and
noninterference requirements of Part 18 of the FCC Rules. FCC
staff have determined that a minor technical change to ultrasonic
pest control devices would substantially reduce their
electromagnetic emissions, hence reducing their RF interference
potential. Additional information about this matter may be
obtained by contacting Joe Husnay at (301) 725-1585 at the FCC
Laboratory.
JOB OPENING IN DXCC
The DX Century Club Branch has an opening for an Assistant
DXCC Manager. Primary responsibility is checking QSL cards and
making proper DXCC record entries. The Assistant Manager is
responsible for managing the DXCC Desk in the absence of the
Manager. Applicants for this position should have a General
Class (or higher) Amateur Radio license. A high degree of
neatness and accuracy in record keeping is essential. Some
interest in DXing and DX call signs helpful. Anyone interested
in this position should contact Don Search, W3AZD, DXCC Branch
Manager, ARRL Hq.
ARRL'S NEW REPEATER DIRECTORY EDITOR: BART J. JAHNKE, KB9NM
Bart comes to the Hq. staff from the Great State of
Wisconsin. [He's also writing this -- Editor] He was born and
raised near the city of Wausau (the other Insurance City) where
his family still operates a 280-acre dairy farm. First licensed
as KA9DLH in early 1979, rapid upgrades followed, and he now
operates as Extra Class KB9NM [KB9 "Nature Man"]. Back in
Wisconsin, Bart operated the VHF/UHF bands exclusively -- mainly
on 144 MHz SSB and CW via tropo, meteor scatter, aurora,
sporadic-E and EME, with those EME exploits having all been "on
the horizon" with fixed-elevation long Yagis. Bart is also a
VUCC Awards Manager. These days, Bart can be found below the
horizon -- behind the stacks of CD-240 repeater registration
cards and computer printouts in Membership Communications
Services. [Editor's query: wouldn't EME from a dairy farm be
earth-moo-earth?]
*eof