SB QST @ ARL $ARLB042<br />ARLB042 ARRL comments on FCC spectrum policy<br /><br />ZCZC AG42<br />QST de W1AW<br />ARRL Bulletin 42 ARLB042<br /> >From ARRL Headquarters<br />Newington CT July 12, 2002<br />To all radio amateurs<br /><br />SB QST ARL ARLB042<br />ARLB042 ARRL comments on FCC spectrum policy<br /><br />The ARRL has told the FCC that marketplace forces should not<br />determine Amateur Radio spectrum allocations and that interference<br />management is a technical, not an economic, issue. Those opinions<br />and others came this week in response to a call in early June from<br />the FCC Spectrum Policy Task Force for comments on various issues<br />related to FCC spectrum policy.<br /><br />''The value to the public of a vital, growing Amateur Radio Service,<br />while perhaps only indirectly measurable in market terms, cannot<br />translate to a marketplace ability to pay for spectrum, no matter<br />what the mechanism,'' the League asserted. ''The non-pecuniary<br />character of Amateur Radio makes it uniquely unsuitable for<br />market-oriented allocation processes.'' Such a policy, the ARRL said,<br />would ''preclude Amateur Radio communications.''<br /><br />The ARRL compared Amateur Radio spectrum to a public park or<br />right-of-way. ''Given the wide availability of Amateur Radio to the<br />general public and its value as an educational and public service<br />resource, the concept fits well,'' the League said.<br /><br />The ARRL said that ''economic balancing'' among parties is not the<br />proper mechanism to resolve interference issues. The League said<br />that many interference issues are dealt with using technical<br />solutions that accommodate both parties. An economic model presumes<br />a preference for one service over another, the ARRL asserted.<br /><br />The ARRL again took advantage of the comment opportunity to<br />reiterate its views on the deployment of unlicensed devices under<br />Part 15 rules. Petitioners seeking authorization for new devices or<br />technology that impacts licensed users should bear the burden of<br />demonstrating the current state of use of the band by its own<br />technical calculations or measurements in certain types of<br />environments, the ARRL said. Noting its own participation in a noise<br />study that will contribute to a better understanding about ambient<br />noise, the ARRL said the FCC should require proponents of new<br />devices or technology to provide ''studies of individual and<br />aggregate interference potential and effect on ambient noise.''<br /><br />The League also restated its view that unlicensed devices cannot be<br />authorized unless the FCC determines that the devices ''do not have<br />a significant interference potential to licensed services.''<br /><br />Petitioners also should provide technical sharing studies every time<br />they propose a new allocation or file a petition for a new<br />unlicensed service, the ARRL said. The League's comments reiterated<br />the goal of the Amateur Radio Spectrum Protection Act, now in<br />Congress as HR 817 and S 549. The measure would provide equivalent<br />replacement spectrum for the Amateur Service just as it typically<br />does for users displaced as a result of spectrum auctions.<br /><br />The full text of the ARRL's comments in this proceeding is available<br />on the ARRL Web site,<br />http://www.arrl.org/announce/regulatory/et02-135/index.html.<br />NNNN<br />/EX