TI-H: Re: 440 MHz band threat (fwd)


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TI-H: Re: 440 MHz band threat (fwd)




>This forward may apply to some of you who are amaatuer radio operators but
>not members of our local club.

>Below is a message I received from the Northwestern Division ARRL
>director concerning
>a threat to the 440 MHz band.  The Arctic Amateur Radio Club uses this
>band for
>a several of our repeaters and repeater to repeater links.
>
>Keep Smilin'
>Steve
>KL7XO / Assistant ARRL Director
>
>-----------------------------------------------------
>
>May 14, 1998
>To: Northwestern Division Personnel
>From: Mary Lou Brown, NM7N
>             Dir., NW Div. ARRL
>Re: Threat to 440 MHz Band
>
>Below is a message that I have sent out to amateur radio clubs for whom
>I
>have an e-mail address (about 100).  I would appreciate it if you would
>also
>help spread the word in this important matter.  Dave Sumner in his
>material
>mentions two letters that amateurs should write right away.  I would
>like to
>add a third, a letter to ones Congressman in the House asking him to
>co-sponsor HR 3572, the Amateur Radio Spectrum Protection Act of 1998.
>The
>440 MHz band threat should give us all the more reason to make a push
>for
>passage of this bill.
> -----------------------------------------------------
>May 14, 1998
>To: Northwestern Division Clubs
>From: Mary Lou Brown, NM7N
>            Director, NW Div., ARRL
>Re: 440 MHz Band Threat, et al
>
>1. Just before the Executive Committee meeting May 9th we were alerted
>to a
>serious threat to the 440 MHz band.  Information provided us at the
>meeting
>indicated that this request for rulemaking by the Land Mobile
>Communications
>Council (LMCC) had a lot of support from a variety of groups having use
>for
>Private Mobile Radio Services (PMRS).  We asked ARRL HQ to prepare
>information for us that we could pass on to our members.  That
>information
>is attached below.  Please note that the comment deadline is June 1st.
> Because it is uncertain if the FCC is currently accepting electronic
>comments, it is best that you respond through the US mail (original plus
>4
>copies).
>
>2.  The threat from LMCC should give us additional reason to try to get
>our
>representatives in the House of Representatives to co-sponsor HR 3275,
>the
>Amateur Radio Spectrum Protection Act of 1998.  In dealing with the
>Congressmen, please make sure they understand the role Amateur Radio
>plays
>in providing communications during disasters.  Also, that is frequent
>recent
>disaster experience that fother communications system fail or become to
>overloaded that they do not function as needed.    The 440 MHz band is
>the
>second most heavily used VHF/UHF frequency and our repeaters, etc. on
>that
>band are heavily relied on for disaster communications.
>
> -----------------------------------------------
>RM-9267: A Threat to Amateur Radio Interests
>
>On April 22, 1998, the Land Mobile Communications Council (LMCC) filed a
>
>petition for rulemaking with the Federal Communications Commission to
>have
>two-thirds of the 420-450 MHz band (70 cm) reallocated to the Private
>Mobile
>
>Radio Service. The petition is designated RM-9267, and the FCC is
>accepting
>public comment until June 1, 1998. The ARRL opposes the LMCC proposal.
>The
>70 cm band is very popular among radio amateurs, and plays a critical
>role
>in our ability to provide emergency, public service, and public interest
>
>communications. The ARRL believes that the LMCC proposal is incompatible
>
>with continued amateur use of the band. RM-9267 is still only a
>proposal,
>and has not been acted upon by the government. We need your help in
>communicating our concerns to policy makers as they consider how to
>handle
>the LMCC's request.
>
>Frequently Asked Questions About RM-9267
>
>What is the LMCC?
>
>The Land Mobile Communications Council (LMCC) is a non-profit
>association of
>
>organizations representing users of land mobile radio systems, providers
>of
>land mobile services, and manufacturers of land mobile radio equipment.
>The
>user community includes public safety, business, industrial, private,
>common
>
>carrier, and land transportation radio users. The membership of LMCC
>includes the following organizations:
>
>Association of American Railroads (AAR)
>American Association of State Highway and Transportation Officials
>(AASHTO)
>American Automobile Association (AAA)
>American Mobile Telecommunications Association (AMTA)
>American Petroleum Institute (API)
>American Trucking Associations, Inc. (ATA)
>Association of Public Safety Communications Officials - International,
>Inc.
>(APCO)
>Cellular Telecommunications Industry Association (CTIA)
>Central Station Alarm Association (CSAA)
>Forest Industries Telecommunications (FIT)
>Forestry-Conservation Communications Association (FCCA)
>Industrial Telecommunications Association, Inc. (ITA)
>Intelligent Transportation Society of America (ITSA)
>International Association of Fire Chiefs (IAFC)
>International Association of Fish and Wildlife Agencies (IAFWA)
>International Municipal Signal Association (IMSA)
>International Taxicab and Livery Association (ITLA)
>Manufacturers Radio Frequency Advisory Committee (MRFAC)
>National Association of State Foresters (NASF)
>Personal Communications Industry Association (PCIA)
>Telecommunications Industry Association (TIA)
>UTC, The Telecommunications Association (UTC)
>
>
>Why are they seeking more radio spectrum for land mobile radio?
>
>In response to a provision of the 1993 Omnibus Budget Act calling for
>regulatory parity among wireless Common Carriers and certain private
>wireless licensees that were providing service that was substantially
>similar to Common Carrier Service, the FCC developed separate
>definitions
>for Commercial Mobile Radio Services (CMRS) and Private Mobile Radio
>Services (PMRS). LMCC members mainly are interested in PMRS. They claim
>that
>
>the FCC is favoring CMRS over PMRS because CMRS licenses can be
>auctioned,
>generating substantial revenues for the Federal Treasury.
>
>
>What is the actual proposal, and how would it affect Amateur Radio?
>
>Based on its own spectrum requirements analysis, LMCC claims that the
>future
>
>additional spectrum needs of the PMRS community are as follows: 15 MHz
>by
>the year 2000, 44 MHz (i.e., another 29 MHz) by 2004, and 125 MHz (i.e.,
>
>another 81 MHz) by 2010. It proposes:
>
>Immediate needs be satisfied by a reallocation of 420-430 MHz, paired
>with
>440-450 MHz, from Federal use to PMRS;
>
>Immediate/mid-term needs be satisfied by FCC allocation of 1390-1400,
>1427-1432, and 1670-1675 MHz to PMRS, pursuant to its reallocation to
>the
>private sector from the government;
>
>Reallocate 85 MHz of the aeronautical band, 960-1215 MHz, to the PMRS by
>the
>
>year 2010 to satisfy longer term needs, shared with the developing DOD
>JTIDS/MIDS service.
>
>At present in the United States, the Amateur Radio Service is secondary
>to
>military radiolocation (radar) in the 420-450 MHz band. Originally a
>primary
>
>allocation, secondary status came about during the 1950s when Cold War
>concerns made national security a high priority. Limited non-government,
>
>non-amateur use of the band is permitted -- but amateurs have priority
>over
>such use. LMCC misinterprets the significance of amateur secondary
>status
>and states that "Amateur applications in the 420-430/440-450 MHz should
>remain secondary to PMRS." LMCC also suggests the possibility that,
>"recognizing that amateur radio service will see a net constriction by
>the
>recommended reallocation of 420-430/440-450 MHz," 1390-1395/1427-1432
>MHz
>might be allocated to the amateur service to offset this constriction.
>"Constriction" is, of course, a bit of an understatement; LMCC has
>offered
>no ideas as to how amateurs could continue to share the bands.
>
>
>What should amateurs do?
>
>First, what you shouldn't do: Don't complain to your Congressman about
>the
>FCC, or write a nasty letter to the FCC. The LMCC petition is a
>private-sector initiative, not a government proposal. By law, the FCC
>has to
>
>put the petition on public notice and invite comment. That's all the FCC
>has
>
>done with it. Criticizing the FCC at this stage would be inappropriate
>and
>counterproductive.
>
>Here is what you should do.
>
>1. Examine the list of LMCC members. You may be a member of one or more
>of
>these organizations. If you are, write to that organization as a member
>and
>inform them that the LMCC, which has listed them as a member and
>supporter,
>has taken an action that is contrary to your interests. Don't assume
>that
>they know anything about the petition or its implications for Amateur
>Radio,
>
>but do make it clear that as a member, you expect them to disavow the
>LMCC
>petition insofar as it affects Amateur Radio. A sample letter is
>attached.
>
>2. Prepare a comment on RM-9267 and submit it to the FCC. At the top, it
>is
>very important that you clearly indicate the file number: RM-9267. Send
>an
>original and four copies to: Office of the Secretary, Federal
>Communications
>
>Commission, Room 222, 1919 M Street NW, Washington, DC 20554.
>
>In your comment, explain how the loss of access to the 420-430/440-450
>MHz
>band segments would affect you personally, and how it would affect the
>ability of radio amateurs in your community to provide needed public
>service. Even if you do not use these segments yourself, it is likely
>that
>loss of access would result in more crowding and interference in the
>part of
>
>the band, or in another band, that you do use. Don't overlook the fact
>that
>if you use linked voice or packet systems, it is quite likely that some
>of
>the links you rely on are in either or both of these segments.
>
>3. If you are involved in amateur radio public service communications,
>arrange for the government and non-government agencies that you serve
>and
>ask for a written statement of their support.
>
>4. Arrange for any Amateur Radio organizations that you belong to, to
>submit
>
>comments. This is especially important in the case of organizations with
>
>interests in the 420-450 MHz band.
>
>
>What if, in spite of our comments, the FCC decides it likes the idea?
>
>The primary occupant of the 420-450 MHz band is the military. Before the
>FCC
>
>can take the next step toward reallocation, it must first obtain the
>agreement of the federal government. Then it would have to issue a
>Notice of
>
>Proposed Rule Making and must solicit public comments on its proposal.
>In
>other words, nothing is going to happen overnight and there will be at
>least
>
>one more opportunity for public comment.
>
>
>It seems we hear about threats to the amateur bands all the time. How
>serious is this one?
>
>The threat must be regarded as very serious.The LMCC is a bona fide and
>respected organization. We must assume that their proposal will be taken
>
>seriously.
>
>
>Where can I get a copy of the LMCC petition?
>
>The petition, with attachments, is 72 pages. We will have it available
>on
>the ARRL Web site <http://www.arrl.org/news/bandthreat/> as quickly as
>possible.
>
>
>
>[sample letter to LMCC member organization]
>
>
>American Automobile Association
>1000 AAA Drive
>Heathrow, FL 32746
>
>Dear Sirs:
>
>I have been a satisfied member of AAA-Connecticut since 1974. Recently,
>however, I have learned that an organization of which AAA is a member
>has
>taken a position, allegedly with the support of AAA. that is contrary to
>my
>interests.
>
>On April 22, the Land Mobile Communications Council filed a petition
>with
>the Federal Communications Commission (designated RM-9267) that seeks to
>
>reallocate the frequency bands 420-430 and 440-450 MHz for the use of
>the
>Private Mobile Radio Service. These bands are now heavily used by radio
>amateurs, operating in the Amateur Radio Service, for a variety of
>public
>service and public interest communications. The reallocation proposed by
>
>LMCC is incompatible with these operations.
>
>As a licensed radio amateur for 35 years, I am dismayed by the LMCC
>proposal. I am even more dismayed to find that AAA, an organization I
>have
>long supported, is listed as an apparent sponsor of this proposal.
>
>I ask you to determine whether AAA has, in fact, adopted a position in
>support of RM-9267, and if so, what steps can be taken to request
>reconsideration of this position. If AAA has not adopted a position in
>support of RM-9267, I request a written statement to that effect.
>
>Thank you for your attention to this important matter.
>
>Sincerely,
>David Sumner
>
>Prepared May 12, 1998, by the American Radio Relay League, Inc., as an
>information service to members.
>ARRL, 225 Main Street, Newington, CT 06111 USA