SB QST @ ARL $ARLB042
ARLB042 ARRL comments on FCC spectrum policy

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ARRL Bulletin 42  ARLB042
From ARRL Headquarters  
Newington CT  July 12, 2002
To all radio amateurs 

SB QST ARL ARLB042
ARLB042 ARRL comments on FCC spectrum policy

The ARRL has told the FCC that marketplace forces should not
determine Amateur Radio spectrum allocations and that interference
management is a technical, not an economic, issue. Those opinions
and others came this week in response to a call in early June from
the FCC Spectrum Policy Task Force for comments on various issues
related to FCC spectrum policy.

''The value to the public of a vital, growing Amateur Radio Service,
while perhaps only indirectly measurable in market terms, cannot
translate to a marketplace ability to pay for spectrum, no matter
what the mechanism,'' the League asserted. ''The non-pecuniary
character of Amateur Radio makes it uniquely unsuitable for
market-oriented allocation processes.'' Such a policy, the ARRL said,
would ''preclude Amateur Radio communications.''

The ARRL compared Amateur Radio spectrum to a public park or
right-of-way. ''Given the wide availability of Amateur Radio to the
general public and its value as an educational and public service
resource, the concept fits well,'' the League said.

The ARRL said that ''economic balancing'' among parties is not the
proper mechanism to resolve interference issues. The League said
that many interference issues are dealt with using technical
solutions that accommodate both parties. An economic model presumes
a preference for one service over another, the ARRL asserted.

The ARRL again took advantage of the comment opportunity to
reiterate its views on the deployment of unlicensed devices under
Part 15 rules. Petitioners seeking authorization for new devices or
technology that impacts licensed users should bear the burden of
demonstrating the current state of use of the band by its own
technical calculations or measurements in certain types of
environments, the ARRL said. Noting its own participation in a noise
study that will contribute to a better understanding about ambient
noise, the ARRL said the FCC should require proponents of new
devices or technology to provide ''studies of individual and
aggregate interference potential and effect on ambient noise.''

The League also restated its view that unlicensed devices cannot be
authorized unless the FCC determines that the devices ''do not have
a significant interference potential to licensed services.''

Petitioners also should provide technical sharing studies every time
they propose a new allocation or file a petition for a new
unlicensed service, the ARRL said. The League's comments reiterated
the goal of the Amateur Radio Spectrum Protection Act, now in
Congress as HR 817 and S 549. The measure would provide equivalent
replacement spectrum for the Amateur Service just as it typically
does for users displaced as a result of spectrum auctions.

The full text of the ARRL's comments in this proceeding is available
on the ARRL Web site,
http://www.arrl.org/announce/regulatory/et02-135/index.html.
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