RM-9267: AAA's Response to Member Complaints

Note: In a letter dated June 11, 1998, AAA has responded to the issues raised by ARRL.

The following letter from the American Automobile Association was sent to members who wrote expressing concerns about RM-9287. It contains a number of inaccuracies, the most important of which have been challenged by the ARRL in a letter dated June 1, 1998.

Letter from AAA

1000 AAA Drive
Heathrow, FL 32746-5063
407/444-7000
Fax 407/444-7380

Dear :

Thank you for writing concerning AAA's support of the Land Mobile Communications Council (LMCC) petition, RM-9267. AAA is a member of the LMCC as are 22 other associations that are heavily involved in mobile radio communications. LMCC members want to acquire additional radio spectrum to alleviate overcrowding in the private wireless community. This includes emergency road service communications between AAA clubs and service vehicles for 28 million member calls annually.

In the Balanced Budget Act of 1997, House and Senate conferees recognized this need and directed the Federal Communications Commission (FCC) and National Telecommunications and Information Administration (NTIA) to consider the allocation of radio spectrum for shared or exclusive use by private wireless services. A committee of industry and government agency leaders was established. Called, "Spectrum Planning and Policy Advisory Committee" (SPAC), this committee made recommendations for the reallocation of some government radio spectrum. In cooperation with NTIA, SPAC developed a plan that included changes to spectrum that amateur radio operators now share with the government. The LMCC adopted the SPAC proposal and the petition includes the SPAC recommendations.

Recent FCC policies have focused on commercial spectrum users. It is unknown if the government spectrum allocation will include private uses beyond public safety. It is probable that some of the spectrum will be reallocated to commercial purposes either by auction or assignment. AAA believes it would be better for amateur radio operators to share the spectrum with private wireless rather than commercial users. Private wireless users are accustomed to sharing spectrum whereas most commercial users have exclusive use. If appropriated for commercial purposes, amateur radio operators would probably lose the use of the frequencies altogether, or find it impossible to communicate on them due to heavy commercial traffic.

The LMCC petition is only a recommendation and does not mean the plan will be adopted. AAA contacted the LMCC secretary, Mark Crosby. He is aware of amateur radio's concerns and has scheduled a meeting between the Amateur Radio Relay League (ARRL) and the LMCC. It is our hope that this meeting will result in a mutually satisfactory resolution between the groups.

Sincerely,

Gary Ruark
AAA Telecommunications Technical Specialist

Response Letter from ARRL to AAA

June 1, 1998

Mr. Gary Ruark
AAA Communications Technical Specialist
1000 AAA Drive
Heathrow, FL 32746-5063

Dear Mr. Ruark:

Several ARRL members who are also AAA members have shared with me letters that you have written to them, explaining AAA's position with regard to the Land Mobile Communications Council (LMCC) petition to the Federal Communications Commission, RM-9267. The LMCC petition includes a recommendation that the frequency bands 420-430 and 440-450 MHz be reallocated. This has our members understandably upset, because these frequency ranges are heavily used by amateur radio operators for public service communications.

Your letter contains several statements that I must question. You state:

In the Balanced Budget Act of 1997, House and Senate conferees recognized this need and directed the Federal Communications Commission (FCC) and National Telecommunications and Information Administration (NTIA) to consider the allocation of radio spectrum for shared and exclusive use by private wireless services. A committee of industry and government agency leaders was established. Called, "Spectrum Planning and Policy Advisory Committee" (SPAC), this committee made recommendations for the reallocation of some government radio spectrum. In cooperation with NTIA, SPAC developed a plan that included changes to spectrum that amateur radio operators now share with the government. The LMCC adopted the SPAC proposal and the petition includes the SPAC recommendations.

This is a complete mischaracterization of the nature of SPAC and of the positions of both NTIA and SPAC. Your letter implies that SPAC was established specifically as a result of a provision of the Balanced Budget Act of 1997. This is simply not true. The following is taken from the SPAC Web page, http://www.ntia.doc.gov/osmhome/spacdesc.html:

The former Frequency Management Advisory Council (FMAC) was established on July 19, 1965, and provided advice to the Director of the Office of Telecommunications Policy (OTP), Executive Office of the President. On March 27, 1978, Executive Order 12046 transferred certain functions of OTP to the Department of Commerce, National Telecommunications and Information Administration (NTIA). The FMAC provided advice on frequency management matters and was rechartered continually through April 1991 at which time, with the increased interest in spectrum planning, the FMAC was renamed the Spectrum Planning Advisory Committee, or SPAC. In 1993, due to increased interest in policy matters, the committee was renamed again to the current Spectrum Planning and Policy Advisory Committee, still called the SPAC.

The Committee consists of 15 non-Federal members and 4 Federal members to be appointed by the Secretary of Commerce. The non-Federal members are appointed as to ensure balanced representation of such interests and areas as manufacturing, analysis and planning, commercial and other operational spectrum use, research, academia, and international negotiations, as well as of individuals expert in spectrum use. The Federal members are appointed to ensure a balanced representation.

I must insist that you correct the impression that your letter has left on those to whom it has been sent. As a AAA member myself since 1974, I join those from whom you have already heard in requesting that AAA represent my interests and disassociate itself from the portion of the LMCC petition that deals with the 420-450 MHz band.

Sincerely,

David Sumner
Executive Vice President

cc: Mark Crosby

AAA Response of June 11, 1998

June 11, 1998

Mr. David Sumner
American Radio Relay League
225 Main Street

Newington, Connecticut 06111

Dear Mr. Sumner:

Thank you for contacting AAA about the information in our reply letter to amateur radio operators. We appreciate your input regarding the Spectrum Planning and Policy Advisory Committee (SPAC) and the National Telecommunications and Information Administration (NTIA) actions. We thought from information obtained from the Land Mobile Communications Council (LMCC) that SPAC had identified the amateur frequencies for reallocation. We now know that was incorrect and that it was the LMCC that initiated the plan without support from either SPAC or NTIA. Future correspondence from AAA concerning this matter will reflect the correct information.

AAA will contact the LMCC Secretary and other LMCC members during the week of June 14, 1998 to discuss the status of the petition. We are aware that the Association of Public Safety Communications Officials (APCO) has withdrawn its support and that may have a bearing on how the remaining LMCC members perceive the value of the petition. When AAA determines how to proceed it will notify the American Radio Relay League.

We appreciate the opportunity to address this matter with the amateur operators and ask that the ARRL post this information at their Internet site. Please contact me if you have any questions.

Sincerely,

Gary Ruark
AAA Emergency Road Service,
Technical Communications Specialist