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NEWINGTON, CT, Jan 28, 2003--The ARRL has registered some mixed feelings about the FCC's Spectrum Policy Task Force Report, issued late last November. In comments filed this week with the FCC, the League called the report "a positive first step" in developing a comprehensive national spectrum management approach. At the same time, the ARRL said, the SPTF Report "fails to address the needs and goals" of the Amateur Service and urged the FCC to not abandon longstanding allocation policies based on engineering.
"Overall, ARRL asks that the Commission not adopt the SPTF Report in toto, but rather use it as a basis for future planning on an ongoing basis," the League said January 27 in its comments in ET Docket 02-135. "Spectrum policy reform should be viewed as an ongoing process, not as a wholesale paradigm shift to be accomplished in half a year." Given that most FCC licensees are not commercial service providers, the ARRL said. the report's orientation toward commercial services makes it not wholly applicable to the Amateur Service. Among other factors, the League said, services such as public safety and Amateur Radio cannot pay for spectrum access.
Cautioning the FCC to not continue an apparent "rush to judgment," the ARRL said there's not been enough time to study the report's recommendations thoroughly, much less deploy them immediately. The League also warned against basing allocation policy on anticipated advances in technology, such as software defined radios (SDRs).
The ARRL said it was "encouraged," however, that the FCC had worked to involve all portions of the telecommunications industry in developing a spectrum policy. It again called on the FCC to consider greater use of "negotiated rulemaking" to expedite allocation decisions. "Using negotiated rulemaking, the Commission can fine-tune allocations plans that will obviate the need for anything resembling the pejorative-termed 'command and control' concept, in which the Commission imposes decisions on the industry," the ARRL said. "Instead of acting as the judge and jury, the Commission could act as more of a facilitator among competitors for spectrum."
Amateur Radio as well as government and non-government services that share spectrum require a more traditional approach to spectrum policy, the League said, noting that almost all ham allocations above 420 MHz are shared government allocations. In this regard, the ARRL urged the FCC to establish "a more collegial and closer working relationship" with the National Telecommunications and Information Administration (NTIA) in dealing with spectrum management issues. The NTIA administers spectrum allocated to federal government users.
In an obvious reference to the ARRL's petition for a band at 5 MHz, which the FCC has proposed adopting, the League noted that the NTIA had opposed the allocation "very late in the proceedings" and "for reasons largely left unexplained."
The ARRL suggested that establishing a "public park" concept for Amateur Radio might be the best approach. "Amateur Radio is essentially the public park of the radio spectrum and is as necessary in telecommunications development and advancement as are the national parks to land use in the United States," the League said.
In terms of coming up with sharing schemes, the ARRL said it supports "to a limited extent" the concept of "interference temperature" calculations and measurements. But, it pointed to the 2400-2450 MHz band as "an example of a failing attempt at inter-service sharing" that some predictive calculations might have alleviated. The ARRL said the explosion of Part 15 devices coupled with relaxed rules on power, antenna gain and duty cycles of high-powered unlicensed devices "has rendered the band unusable in some areas" because of interference.
"It is not possible to allow unlimited numbers of unlicensed devices to occupy the same bands, unless the technical standards and etiquettes are appropriately determined in advance," the League said in its comments. Once again asserting that the FCC "has pushed the Part 15 concept beyond the point that it works," the ARRL took advantage of the comment opportunity to again express its view that unlicensed devices "cannot be authorized by the Commission under current statutes" without first determining that they do not pose a significant interference potential to licensed radio services.
In its initial comments to the Spectrum Policy Task Force filed last June, the ARRL told the FCC that marketplace forces should not determine Amateur Radio spectrum allocations and that interference management is a technical, not an economic, issue.
The ARRL's comments on the FCC's Spectrum Policy Task Force Report in ET Docket 02-135 are available on the ARRL Web site.
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