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RE: [WWARA-Members] comments on band plan changes?

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  • Stephen Kangas
    As I understand it, a lawsuit would likely have no basis as there is no FCC allocation of frequencies re use and therefore WWARA could not enforce their
    Message 1 of 10 , Jul 8, 2012
      As I understand it, a lawsuit would likely have no basis as there is no FCC
      allocation of frequencies re use and therefore WWARA could not enforce their
      exclusive use of frequencies anymore than simplex users can. Certainly the
      FCC encourages bandplan usage via local groups like WWARA, but it seems that
      it is not legally pursuable unless the FCC were to issue a ruling on a
      complaint filing that is in conflict with federal law, in which case it
      would be the FCC that would be sued. As NM7R points out below, the fed law
      clearly states that no one, including WWARA, can make exclusive use of one
      or more frequencies, thus the stage is set for conflict among those who
      choose not to "cooperate". Some of you lawyers out there correct me if I'm
      wrong.

      With that said, there may be an increased risk of conflict between repeater
      and simplex users particularly in rural mountainous areas, such as E King
      Co, where there is significant regular simplex usage due to topography that
      prevents reliable repeater coverage, "frequent" power outages affecting
      repeaters, RC vehicles, and informal local groups of hams on 2m/70cm. My
      bet is that you may not hear complaints until after such time that repeater
      owners make their investment into equipment to expand into "new" frequencies
      and simplex users begin experiencing "infringement" that interferes both
      ways. Ie, simplex users are not likely aware of your new plans yet...which
      begs the question of "what has been done to widely and effectively publicize
      new WWARA repeater frequency plans?" Suggestions there: ARRL email news (WA
      group); QST on repeater networks re new plan & where to learn more; notices
      at all WA hamfests & clubs (PNWVHFS, SeaPac, M&KARC, etc etc), not just an
      insular group as the emcomm guys attending Communications Academy; posting
      on Yahoo/Google/Facebook ham groups. (Note: I personally have not heard
      about this new plan via any of those common ham communications forums...only
      heard about it here on the WWARA forum, which of course is an insular and
      small group).

      Therefore, I submit that unless you have done a reasonable attempt to
      effectively communicate in advance the new bandplan among as many licensed
      hams as possible, you will become the primary party setting the stage for a
      conflict that has the potential of becoming a larger firestorm than any that
      might come up before it's implementation. As those among us who have
      experience as project managers know, getting stakeholder buy-in on a project
      plan is key to seeing a smooth successful execution of the plan.

      73, Stephen W9SK

      -----Original Message-----
      From: WWARA-Members@yahoogroups.com [mailto:WWARA-Members@yahoogroups.com]
      On Behalf Of NM7R
      Sent: Sunday, July 08, 2012 10:17 AM
      To: WWARA-Members@yahoogroups.com
      Subject: [WWARA-Members] comments on band plan changes?

      Frank,
      Have you received any cards, letters, phone calls or emails from folks
      having varying opinions on the recently adopted band plan changes? Since we
      (the board) has heard nothing from you lately can we assume that you are
      not hearing much of anything from our "clients" or those who feel that the
      simplex frequencies belong to them?
      At lunch today with a bunch of ham friends was one of the other folks
      who had been at field day with John Hays when Grant Hopper visited. This
      person repeated some of the stuff that John reported including Grant's
      mentioning that he had been contacted by folks who may be contemplating some
      sort of law suit because of the new band plan adoption. Have you heard
      anything about such a thing?

      Peter

      ----

      Peter,

      I have received one (1) email regarding the recent Band Plan revision. I
      will append it and my response, to this email as "Appendix A". I think it
      outlines my view of the issue fairly well.

      In April 2011, I made a presentation at Communications Academy about this
      proposal for creating 2-meter narrow-band/digital (NBD) pairs. The proposal
      as presented was almost identical to what was adopted. The Power Point
      presentation was available on the Communications Academy "presentations"
      distribution. The Power Point presentation is also available on the WWARA
      Members Group, in the Files section.

      Arguably, Communications Academy is the largest gathering of Amateur Radio
      Emergency Communications (EmComm) leadership in Western Washington.
      Virtually every "main stream" WWa group engaged in EmComm activities has at
      least one member attending that conference each year. I know of no other
      forum where EmComm personnel can be as effectively addressed. My intention
      was specifically to "warn" the EmComm community that adoption of this
      proposal was a real possibility in the near future.

      This year, April 2012, I gave a presentation at Communications Academy on
      "Nets". The establishment of a logistics Net is a cornerstone of our Amateur
      EmComm response in most situations. During that presentation I went into
      some detail about looking for "non-standard" simplex frequencies in order to
      avoid crowding on the traditional channels, and stated quite clearly that
      the "traditional channels" were presently being shared by VoIP (EchoLink and
      IRLP) stations and would probably be under pressure for other activities.
      One such activity specifically mentioned was our proposal for 2-meter NBD
      pairs.

      I am satisfied this good-faith outreach to the Amateur operators most
      affected by the proposal was well received. As part of these presentations,
      I specifically made a point of inviting any interested Amateurs to join
      WWARA, either as an individual or organization, so they would have voting
      input to the process.

      I would like to note that Grant Hopper has not contacted me, either as WWARA
      Chair or as Western Washington SEC, about this matter. I would welcome any
      feedback from him or anyone else.

      I am not a lawyer, but frankly, I don't see where any Amateur radio
      individual or group has "standing" to bring a law suit. They would have to
      show that WWARA has caused them "harm".

      Part 97.101(b) states: "(b) Each station licensee and each control operator
      must cooperate in selecting transmitting channels and in making the most
      effective use of the amateur service frequencies. No frequency will be
      assigned for the exclusive use of any station."

      As far as I can see, "assigned" simplex channels were self-assigned by the
      EmComm entities themselves, in clear contradiction to this passage. It can
      be argued that this same passage promotes our action as part of "…making the
      most effective use of the amateur service frequencies." Holding a group of
      frequencies inactive to be used for EmComm is not effective use.

      A repeater owner/licensee clearly has the authority to establish a repeater
      on these new frequencies, as stated in Part 97.205(a) and (b) [here edited
      for brevity, complete text follows as "Appendix B"]: "(a) Any amateur
      station ... may be a repeater…"

      "(b) A repeater may receive and retransmit only on the 10 m and shorter
      wavelength frequency bands except the … 144.0-144.5 MHz, 145.5-146.0 MHz, …
      segments."

      So, I can't see any "harm" in the legal sense, and can read the Rules in
      such a way that we almost have a mandate to move forward with this. Part
      97.205( c) which covers coordination, only mentions interference between
      repeaters. Simplex or other modes of operation are not mentioned. It would
      appear to be assumed that simplex stations can move to avoid interference.

      I will post this email to the Members' Remailer, as I am sure there is a
      wider interest in this issue. As we move forward with this NBD build-out, I
      hope all of our members participating will be sensitive to the present users
      of these frequencies, and try to minimize their impact as far as
      practicable. While I am confident this WWARA policy change is within the
      scope of our authority, there is no point in causing anyone unnecessary
      grief.

      73, Frank, NM7R


      -----

      "Appendix A"


      From: <name redacted>
      To: chair@...
      Sent: Tuesday, June 12, 2012 3:53 PM
      Subject: Revision to 2m Band Plan

      Hi - Frank,
      I have mapped out the proposed changes in the 2 meter band; however, I
      do have some serious concerns about the simplex frequencies being reduced to
      a mere 5% of the band. It looks like there is hardly any room for simple one
      to one contacts or for RACES groups to talk to their teams with out
      interfering with others.
      Could you please clarify the specific frequencies that would be used for
      the repeaters in the simplex area? Would 146.500 & 147.500 MHz still be
      simplex channels?
      I have attached a PDF with the proposed changes highlighted in bright
      yellow. Could you please confirm that this is correct? Changes to the 2m
      simplex will specifically affect some of the following groups: Renton, Red
      Cross, Mercer Island, PSE, Mercury NW, Bellevue, Redmond, Camp Murray, and
      King Co. Search and Rescue as well as other non ARES/RACES groups. If
      146.5 & 147.5 are included as repeater frequencies, then add the King Co.
      ECC, Shoreline and Vashon Island. In the end all teams will be affected.
      Sincerely,
      <name redacted>

      -----

      <Reply>

      Thank you for contacting me about the recent WWARA policy change affecting
      the lower half of the traditional simplex bands.

      You say that the simplex frequencies have been reduced to 5% of the 2-meter
      band. This is not entirely correct. A large percentage of the band is
      potentially available for simplex use. In fact, there is a problem that
      commonly comes up using the traditional simplex frequencies in that every
      jurisdiction is trying to use the same handful of frequencies, causing lots
      of mutual interference.

      The only portion of the band specifically excluded by the FCC is 144.0 to
      144.1 MHz. The rest is available on a not-to-interfere basis. While I know
      that sounds overly simplistic, in any given area of Western Washington
      (WWa), there are repeater output frequencies, input frequencies and
      non-repeater frequencies, not used locally, and therefore available for
      tactical simplex communications. It takes some effort to compile a list, but
      many jurisdictions have done just this. The comments from those who have
      gone through this exercise usually express amazement at how many are
      actually available.

      There are 59 repeater output frequencies in the 2-meter band. Certainly not
      all of them are used for "local" repeaters in any given area. As long as the
      signal from your local simplex partner is stronger than that from the
      distant repeater, you can probably use that for local simplex. Using PL
      encode/decode can allow you to not hear the distant machine. The input
      frequency of a distant repeater will also work well. Make sure you are not
      transmitting the PL tone it uses.

      There are two areas of the 2-meter band where repeaters are prohibited;
      144.000 to 144.500, and 145.500 to 146.000. Using 144.300 to 144.500 would
      still allow room for CW and SSB operations. Using 145.500 to 145.800, would
      stay clear of the OSCAR sub-band. This provides 500 kHz (25 channels) of
      potential EmComm FM simplex operating room. And, don't forget the other
      bands we have available, 220- and 440-MHz offer lots of room for simplex
      operations.

      Any Amateur radio less than 35-years old is synthesized, and can operate on
      any frequency in the band. Forty years ago, most radios were crystal
      controlled, and an operator might only have 12 channels from which to
      choose. In that environment, a handful of "reserved" simplex channels made
      sense.

      Most Emergency Communications (EmComm) today use repeaters, because they
      support longer range and allow better coordination. If a repeater goes off
      the air during an incident, the logical simplex frequency to use is the
      repeater output frequency. It is now available, everyone is listening to it
      already, and if the repeater comes back on the air, everyone will know about
      it. When a repeater is off the air, its input frequency is also available.

      In fact, the new, Narrow-Band/Digital (NBD) repeaters that the new channel
      scheme is to serve, are largely owned and sponsored by EmComm organizations.
      Attempting to accommodate them in the traditional (analog FM) repeater
      channel pairs has been unsatisfactory. There are few if any open slots for
      new repeaters in WWa on 2-meters, and there are compatibility issues when
      operating the new NBD and older analog FM in the same environment. WWARA has
      been studying and discussing alternative methods of incorporating these new
      relay devices for 2 years. This is the "least worst" answer.

      Note: The Highline Repeater Group was the first to file an application for
      one of these "NBD Pairs".

      73,
      Frank Wolfe, NM7R
      Chair, WWARA


      -----
      -----

      "Appendix B"

      Part 97 FCC Regulations excerpts:

      §97.101 General standards. -

      (a) In all respects not specifically covered by FCC Rules each amateur
      station must be operated in accordance with good engineering and good
      amateur practice.

      (b) Each station licensee and each control operator must cooperate in
      selecting transmitting channels and in making the most effective use of the
      amateur service frequencies. No frequency will be assigned for the exclusive
      use of any station.

      (c) At all times and on all frequencies, each control operator must give
      priority to stations providing emergency communications, except to stations
      transmitting communications for training drills and tests in RACES.

      (d) No amateur operator shall willfully or maliciously interfere with or
      cause interference to any radio communication or signal.



      §97.205 Repeater station. -

      (a) Any amateur station licensed to a holder of a Technician, General,
      Advanced or Amateur Extra Class operator license may be a repeater. A holder
      of a Technician, General, Advanced or Amateur Extra Class operator license
      may be the control operator of a repeater, subject to the privileges of the
      class of operator license held.

      (b) A repeater may receive and retransmit only on the 10 m and shorter
      wavelength frequency bands except the 28.0-29.5 MHz, 50.0-51.0 MHz,
      144.0-144.5 MHz, 145.5-146.0 MHz, 222.00-222.15 MHz, 431.0-433.0 MHz and
      435.0-438.0 MHz segments.

      (c) Where the transmissions of a repeater cause harmful interference to
      another repeater, the two station licensees are equally and fully
      responsible for resolving the interference unless the operation of one
      station is recommended by a frequency coordinator and the operation of the
      other station is not. In that case, the licensee of the noncoordinated
      repeater has primary responsibility to resolve the interference.

      (d) A repeater may be automatically controlled.

      (e) Ancillary functions of a repeater that are available to users on the
      input channel are not considered remotely controlled functions of the
      station. Limiting the use of a repeater to only certain user stations is
      permissible.

      (f) [Reserved]

      (g) The control operator of a repeater that retransmits inadvertently
      communications that violate the rules in this Part is not accountable for
      the violative communications.

      (h) The provisions of this paragraph do not apply to repeaters that transmit
      on the 1.2 cm or shorter wavelength bands. Before establishing a repeater
      within 16 km (10 miles) of the Arecibo Observatory or before changing the
      transmitting frequency, transmitter power, antenna height or directivity of
      an existing repeater, the station licensee must give written notification
      thereof to the Interference Office, Arecibo Observatory, HC3 Box 53995,
      Arecibo, Puerto Rico 00612, in writing or electronically, of the technical
      parameters of the proposal. Licensees who choose to transmit information
      electronically should e-mail to: prcz@....

      <end>





      ------------------------------------

      Yahoo! Groups Links
    • pingster74
      Stephen summed it up pretty well and I applaud him taking the time to post. Although the WWARA has been hashing this out internally for a few years and there
      Message 2 of 10 , Jul 27, 2012
        Stephen summed it up pretty well and I applaud him taking the time to post.

        Although the WWARA has been hashing this out internally for a few years and there were several proposals which none were good. It was a rather sudden move voted on by a majority of those present which was ramrodded to a vote by a few that had a vested interest in creating new repeater pairs to serve their interests instead of working within the system like everyone else wishing to be coordinated. In fact this topic wasn't scheduled business for this meeting and not even mentioned in the previous meetings minutes. After the vote was completed a question was asked how many will be going home and filing tech data sheets and applying for these new frequencies that day and six people raised their hands. One person even said they already had theirs already filled in and ready to be turned in when the meeting was over. In my opinion it is hard to justify this take over when so many repeaters sit idle for weeks on end doing nothing except for the occasional IDing, somehow these systems seemed to have more merit than the frequencies used by simplex users on a regular basis. Holding a group of inactive frequencies to be used for whatever purpose is not effective use.

        There clearly was not enough effort put into widely publicizing the plan of taking over of more spectrum for repeaters. You likely would not have ever heard about the plan to consume more frequencies unless you were a member of the WWARA. A presentation at Comm Academy might have been one of many steps in the right direction for getting the information out but is much too little effort. It is arguably not representative of the majority of the ham community. EmComm folks are a small slice of the community. I went to Comm Academy and estimate that there were about 200 people in attendance. With several classes being held at the same time at different locations I wonder how many people attended this particular presentation. It is also a bad business to require people to become members of the WWARA to be able to have a vote on something that impacts them when they aren't interested in repeaters in the first place. Being able to "read the rules in such a way that we almost have a mandate to move forward with this" is a creative interpretation of the rules and the same thought process could be used against this move.

        In reality the FCC doesn't even recognize or regulate repeater coordinators and gives them zero authority. It is the FCC's stance that if the existing coordination body doesn't work for you or meet your needs that you are encouraged to find one that will. Create one if you need to, others have. Coordination is an option not a requirement. Because of this it is important that the WWARA not make themselves irrelevant to the community by not getting buy in of those who use the frequencies impacted. Frequency coordination can be a good thing and should be embraced by the community but only if there is mutual respect. It's up to the individual licensee to choose to recognize the frequency coordinator.

        I can't see a lawsuit actually surfacing from the decision recently made mainly because there are no requirements or obligation for any simplex user to move. The licensee of the repeater is equally responsible for not causing interference to the simplex user whether or not they are coordinated. The FCC only addresses interference between two repeaters not a repeater vs a simplex user. This is why there is a generally accepted ARRL band plan, it's a gentlemans agreement and seems to have worked pretty well.

        A repeater is a repeater and should not be given any preference or special treatment due to its mode or bandwidth.

        Was this change to the WWARA band plan good for ham radio or was it good for a select few?

        Mike
        N3KPU

        --- In WWARA-Members@yahoogroups.com, "Stephen Kangas" <stephen@...> wrote:
        >
        > As I understand it, a lawsuit would likely have no basis as there is no FCC
        > allocation of frequencies re use and therefore WWARA could not enforce their
        > exclusive use of frequencies anymore than simplex users can. Certainly the
        > FCC encourages bandplan usage via local groups like WWARA, but it seems that
        > it is not legally pursuable unless the FCC were to issue a ruling on a
        > complaint filing that is in conflict with federal law, in which case it
        > would be the FCC that would be sued. As NM7R points out below, the fed law
        > clearly states that no one, including WWARA, can make exclusive use of one
        > or more frequencies, thus the stage is set for conflict among those who
        > choose not to "cooperate". Some of you lawyers out there correct me if I'm
        > wrong.
        >
        > With that said, there may be an increased risk of conflict between repeater
        > and simplex users particularly in rural mountainous areas, such as E King
        > Co, where there is significant regular simplex usage due to topography that
        > prevents reliable repeater coverage, "frequent" power outages affecting
        > repeaters, RC vehicles, and informal local groups of hams on 2m/70cm. My
        > bet is that you may not hear complaints until after such time that repeater
        > owners make their investment into equipment to expand into "new" frequencies
        > and simplex users begin experiencing "infringement" that interferes both
        > ways. Ie, simplex users are not likely aware of your new plans yet...which
        > begs the question of "what has been done to widely and effectively publicize
        > new WWARA repeater frequency plans?" Suggestions there: ARRL email news (WA
        > group); QST on repeater networks re new plan & where to learn more; notices
        > at all WA hamfests & clubs (PNWVHFS, SeaPac, M&KARC, etc etc), not just an
        > insular group as the emcomm guys attending Communications Academy; posting
        > on Yahoo/Google/Facebook ham groups. (Note: I personally have not heard
        > about this new plan via any of those common ham communications forums...only
        > heard about it here on the WWARA forum, which of course is an insular and
        > small group).
        >
        > Therefore, I submit that unless you have done a reasonable attempt to
        > effectively communicate in advance the new bandplan among as many licensed
        > hams as possible, you will become the primary party setting the stage for a
        > conflict that has the potential of becoming a larger firestorm than any that
        > might come up before it's implementation. As those among us who have
        > experience as project managers know, getting stakeholder buy-in on a project
        > plan is key to seeing a smooth successful execution of the plan.
        >
        > 73, Stephen W9SK
        >
        > -----Original Message-----
        > From: WWARA-Members@yahoogroups.com [mailto:WWARA-Members@yahoogroups.com]
        > On Behalf Of NM7R
        > Sent: Sunday, July 08, 2012 10:17 AM
        > To: WWARA-Members@yahoogroups.com
        > Subject: [WWARA-Members] comments on band plan changes?
        >
        > Frank,
        > Have you received any cards, letters, phone calls or emails from folks
        > having varying opinions on the recently adopted band plan changes? Since we
        > (the board) has heard nothing from you lately can we assume that you are
        > not hearing much of anything from our "clients" or those who feel that the
        > simplex frequencies belong to them?
        > At lunch today with a bunch of ham friends was one of the other folks
        > who had been at field day with John Hays when Grant Hopper visited. This
        > person repeated some of the stuff that John reported including Grant's
        > mentioning that he had been contacted by folks who may be contemplating some
        > sort of law suit because of the new band plan adoption. Have you heard
        > anything about such a thing?
        >
        > Peter
        >
        > ----
        >
        > Peter,
        >
        > I have received one (1) email regarding the recent Band Plan revision. I
        > will append it and my response, to this email as "Appendix A". I think it
        > outlines my view of the issue fairly well.
        >
        > In April 2011, I made a presentation at Communications Academy about this
        > proposal for creating 2-meter narrow-band/digital (NBD) pairs. The proposal
        > as presented was almost identical to what was adopted. The Power Point
        > presentation was available on the Communications Academy "presentations"
        > distribution. The Power Point presentation is also available on the WWARA
        > Members Group, in the Files section.
        >
        > Arguably, Communications Academy is the largest gathering of Amateur Radio
        > Emergency Communications (EmComm) leadership in Western Washington.
        > Virtually every "main stream" WWa group engaged in EmComm activities has at
        > least one member attending that conference each year. I know of no other
        > forum where EmComm personnel can be as effectively addressed. My intention
        > was specifically to "warn" the EmComm community that adoption of this
        > proposal was a real possibility in the near future.
        >
        > This year, April 2012, I gave a presentation at Communications Academy on
        > "Nets". The establishment of a logistics Net is a cornerstone of our Amateur
        > EmComm response in most situations. During that presentation I went into
        > some detail about looking for "non-standard" simplex frequencies in order to
        > avoid crowding on the traditional channels, and stated quite clearly that
        > the "traditional channels" were presently being shared by VoIP (EchoLink and
        > IRLP) stations and would probably be under pressure for other activities.
        > One such activity specifically mentioned was our proposal for 2-meter NBD
        > pairs.
        >
        > I am satisfied this good-faith outreach to the Amateur operators most
        > affected by the proposal was well received. As part of these presentations,
        > I specifically made a point of inviting any interested Amateurs to join
        > WWARA, either as an individual or organization, so they would have voting
        > input to the process.
        >
        > I would like to note that Grant Hopper has not contacted me, either as WWARA
        > Chair or as Western Washington SEC, about this matter. I would welcome any
        > feedback from him or anyone else.
        >
        > I am not a lawyer, but frankly, I don't see where any Amateur radio
        > individual or group has "standing" to bring a law suit. They would have to
        > show that WWARA has caused them "harm".
        >
        > Part 97.101(b) states: "(b) Each station licensee and each control operator
        > must cooperate in selecting transmitting channels and in making the most
        > effective use of the amateur service frequencies. No frequency will be
        > assigned for the exclusive use of any station."
        >
        > As far as I can see, "assigned" simplex channels were self-assigned by the
        > EmComm entities themselves, in clear contradiction to this passage. It can
        > be argued that this same passage promotes our action as part of "…making the
        > most effective use of the amateur service frequencies." Holding a group of
        > frequencies inactive to be used for EmComm is not effective use.
        >
        > A repeater owner/licensee clearly has the authority to establish a repeater
        > on these new frequencies, as stated in Part 97.205(a) and (b) [here edited
        > for brevity, complete text follows as "Appendix B"]: "(a) Any amateur
        > station ... may be a repeater…"
        >
        > "(b) A repeater may receive and retransmit only on the 10 m and shorter
        > wavelength frequency bands except the … 144.0-144.5 MHz, 145.5-146.0 MHz, …
        > segments."
        >
        > So, I can't see any "harm" in the legal sense, and can read the Rules in
        > such a way that we almost have a mandate to move forward with this. Part
        > 97.205( c) which covers coordination, only mentions interference between
        > repeaters. Simplex or other modes of operation are not mentioned. It would
        > appear to be assumed that simplex stations can move to avoid interference.
        >
        > I will post this email to the Members' Remailer, as I am sure there is a
        > wider interest in this issue. As we move forward with this NBD build-out, I
        > hope all of our members participating will be sensitive to the present users
        > of these frequencies, and try to minimize their impact as far as
        > practicable. While I am confident this WWARA policy change is within the
        > scope of our authority, there is no point in causing anyone unnecessary
        > grief.
        >
        > 73, Frank, NM7R
        >
        >
        > -----
        >
        > "Appendix A"
        >
        >
        > From: <name redacted>
        > To: chair@...
        > Sent: Tuesday, June 12, 2012 3:53 PM
        > Subject: Revision to 2m Band Plan
        >
        > Hi - Frank,
        > I have mapped out the proposed changes in the 2 meter band; however, I
        > do have some serious concerns about the simplex frequencies being reduced to
        > a mere 5% of the band. It looks like there is hardly any room for simple one
        > to one contacts or for RACES groups to talk to their teams with out
        > interfering with others.
        > Could you please clarify the specific frequencies that would be used for
        > the repeaters in the simplex area? Would 146.500 & 147.500 MHz still be
        > simplex channels?
        > I have attached a PDF with the proposed changes highlighted in bright
        > yellow. Could you please confirm that this is correct? Changes to the 2m
        > simplex will specifically affect some of the following groups: Renton, Red
        > Cross, Mercer Island, PSE, Mercury NW, Bellevue, Redmond, Camp Murray, and
        > King Co. Search and Rescue as well as other non ARES/RACES groups. If
        > 146.5 & 147.5 are included as repeater frequencies, then add the King Co.
        > ECC, Shoreline and Vashon Island. In the end all teams will be affected.
        > Sincerely,
        > <name redacted>
        >
        > -----
        >
        > <Reply>
        >
        > Thank you for contacting me about the recent WWARA policy change affecting
        > the lower half of the traditional simplex bands.
        >
        > You say that the simplex frequencies have been reduced to 5% of the 2-meter
        > band. This is not entirely correct. A large percentage of the band is
        > potentially available for simplex use. In fact, there is a problem that
        > commonly comes up using the traditional simplex frequencies in that every
        > jurisdiction is trying to use the same handful of frequencies, causing lots
        > of mutual interference.
        >
        > The only portion of the band specifically excluded by the FCC is 144.0 to
        > 144.1 MHz. The rest is available on a not-to-interfere basis. While I know
        > that sounds overly simplistic, in any given area of Western Washington
        > (WWa), there are repeater output frequencies, input frequencies and
        > non-repeater frequencies, not used locally, and therefore available for
        > tactical simplex communications. It takes some effort to compile a list, but
        > many jurisdictions have done just this. The comments from those who have
        > gone through this exercise usually express amazement at how many are
        > actually available.
        >
        > There are 59 repeater output frequencies in the 2-meter band. Certainly not
        > all of them are used for "local" repeaters in any given area. As long as the
        > signal from your local simplex partner is stronger than that from the
        > distant repeater, you can probably use that for local simplex. Using PL
        > encode/decode can allow you to not hear the distant machine. The input
        > frequency of a distant repeater will also work well. Make sure you are not
        > transmitting the PL tone it uses.
        >
        > There are two areas of the 2-meter band where repeaters are prohibited;
        > 144.000 to 144.500, and 145.500 to 146.000. Using 144.300 to 144.500 would
        > still allow room for CW and SSB operations. Using 145.500 to 145.800, would
        > stay clear of the OSCAR sub-band. This provides 500 kHz (25 channels) of
        > potential EmComm FM simplex operating room. And, don't forget the other
        > bands we have available, 220- and 440-MHz offer lots of room for simplex
        > operations.
        >
        > Any Amateur radio less than 35-years old is synthesized, and can operate on
        > any frequency in the band. Forty years ago, most radios were crystal
        > controlled, and an operator might only have 12 channels from which to
        > choose. In that environment, a handful of "reserved" simplex channels made
        > sense.
        >
        > Most Emergency Communications (EmComm) today use repeaters, because they
        > support longer range and allow better coordination. If a repeater goes off
        > the air during an incident, the logical simplex frequency to use is the
        > repeater output frequency. It is now available, everyone is listening to it
        > already, and if the repeater comes back on the air, everyone will know about
        > it. When a repeater is off the air, its input frequency is also available.
        >
        > In fact, the new, Narrow-Band/Digital (NBD) repeaters that the new channel
        > scheme is to serve, are largely owned and sponsored by EmComm organizations.
        > Attempting to accommodate them in the traditional (analog FM) repeater
        > channel pairs has been unsatisfactory. There are few if any open slots for
        > new repeaters in WWa on 2-meters, and there are compatibility issues when
        > operating the new NBD and older analog FM in the same environment. WWARA has
        > been studying and discussing alternative methods of incorporating these new
        > relay devices for 2 years. This is the "least worst" answer.
        >
        > Note: The Highline Repeater Group was the first to file an application for
        > one of these "NBD Pairs".
        >
        > 73,
        > Frank Wolfe, NM7R
        > Chair, WWARA
        >
        >
        > -----
        > -----
        >
        > "Appendix B"
        >
        > Part 97 FCC Regulations excerpts:
        >
        > §97.101 General standards. -
        >
        > (a) In all respects not specifically covered by FCC Rules each amateur
        > station must be operated in accordance with good engineering and good
        > amateur practice.
        >
        > (b) Each station licensee and each control operator must cooperate in
        > selecting transmitting channels and in making the most effective use of the
        > amateur service frequencies. No frequency will be assigned for the exclusive
        > use of any station.
        >
        > (c) At all times and on all frequencies, each control operator must give
        > priority to stations providing emergency communications, except to stations
        > transmitting communications for training drills and tests in RACES.
        >
        > (d) No amateur operator shall willfully or maliciously interfere with or
        > cause interference to any radio communication or signal.
        >
        >
        >
        > §97.205 Repeater station. -
        >
        > (a) Any amateur station licensed to a holder of a Technician, General,
        > Advanced or Amateur Extra Class operator license may be a repeater. A holder
        > of a Technician, General, Advanced or Amateur Extra Class operator license
        > may be the control operator of a repeater, subject to the privileges of the
        > class of operator license held.
        >
        > (b) A repeater may receive and retransmit only on the 10 m and shorter
        > wavelength frequency bands except the 28.0-29.5 MHz, 50.0-51.0 MHz,
        > 144.0-144.5 MHz, 145.5-146.0 MHz, 222.00-222.15 MHz, 431.0-433.0 MHz and
        > 435.0-438.0 MHz segments.
        >
        > (c) Where the transmissions of a repeater cause harmful interference to
        > another repeater, the two station licensees are equally and fully
        > responsible for resolving the interference unless the operation of one
        > station is recommended by a frequency coordinator and the operation of the
        > other station is not. In that case, the licensee of the noncoordinated
        > repeater has primary responsibility to resolve the interference.
        >
        > (d) A repeater may be automatically controlled.
        >
        > (e) Ancillary functions of a repeater that are available to users on the
        > input channel are not considered remotely controlled functions of the
        > station. Limiting the use of a repeater to only certain user stations is
        > permissible.
        >
        > (f) [Reserved]
        >
        > (g) The control operator of a repeater that retransmits inadvertently
        > communications that violate the rules in this Part is not accountable for
        > the violative communications.
        >
        > (h) The provisions of this paragraph do not apply to repeaters that transmit
        > on the 1.2 cm or shorter wavelength bands. Before establishing a repeater
        > within 16 km (10 miles) of the Arecibo Observatory or before changing the
        > transmitting frequency, transmitter power, antenna height or directivity of
        > an existing repeater, the station licensee must give written notification
        > thereof to the Interference Office, Arecibo Observatory, HC3 Box 53995,
        > Arecibo, Puerto Rico 00612, in writing or electronically, of the technical
        > parameters of the proposal. Licensees who choose to transmit information
        > electronically should e-mail to: prcz@...
        >
        > <end>
        >
        >
        >
        >
        >
        > ------------------------------------
        >
        > Yahoo! Groups Links
        >
      • NM7R
        Mike has raised several good points. We have been discussing this issue (accommodating Narrow-Band/Digital (NBD), D-Star and similar) for more than two years.
        Message 3 of 10 , Jul 27, 2012
          Mike has raised several good points.

          We have been discussing this issue (accommodating Narrow-Band/Digital (NBD), D-Star and similar) for more than two years. During that time, the 440 Band Chair has enlisted the help of several applicants to give "splinter" operation a try. This solution to the accommodation problem, in the context of our existing 440 Band Plan seems to be a good one. It provides a home for some NBD machines without dislocating or compromising the existing users. But once the NBD systems had shown this scheme to work satisfactorily, our Band Plan didn't allow for them to be coordinated, leaving them in a permanent state of "Pending".

          I felt it only fair to request a motion that we amend our Band Plan to allow for the inclusion of these repeaters under our coordination policy. This recognizes not only the success of Steve Szombathy's, W7UDI, initiative and effort, but the willingness of the few pioneers to spend the extra time and dollars to give this a try, with no guarantee that they would be able to continue to operate. I want to thank Steve for carrying this forward, and the pioneers for their willingness to participate.

          The 70-cm band is different in several ways from the 2-meter band, and this "splinter" scheme will not work on 2-meters, due to the closer spacing of the existing repeaters, and to some extent also to the heavier loading of the band.

          Several plans for accommodation of NBD machines on 2-meters have been put forward. Only one met the twin criteria of (1) not dislocating or compromising existing coordinations, and (2) providing a home for a significant number of repeaters. Why are these points important? Let me digress a moment to look at the legal side.


          The FCC doesn't recognize or "license" coordinators. They do mention them in Part 97 as "recommending" a particular frequency for a particular repeater. The reason for this is that the Amateur Radio Service is built upon the foundation of the individual Operator/Station License. The only license necessary to establish an Amateur station is the one you carry in your pocket, and that station may be a repeater. The authority to operate a repeater rests with the individual Amateur licensee, as a co-equal with all other licensees.

          If an individual Amateur licensee decides to set up a repeater, he or she has the authority to do so. The WWARA has no authority to prohibit, or in fact to authorize this. The authority rests entirely with the individual Amateur licensee. The function of WWARA is advisory in nature. In essence, we are a forum in which Amateurs may choose to participate, towards the goal of minimizing mutual interference between systems. This is in everyone's best interest, because all licensees have an obligation to minimize interference under all circumstances.

          We can argue about what a coordinator may and may not do, but the bottom line is, the authority to coordinate is an extension of the collective authority of the members' licenses. We are in effect, pooling our individual authorities to operate, and meeting as equal partners in the enterprise of coordination. WWARA has only the authority it is granted by the members.

          We have established By-laws, Policies and Band Plans, all approved in open meetings. To say that it is unfair to follow these by making a decision based on a motion from the floor, with a vote of the members present is out of order. This is basic Democracy in action. If this is not the way business should be conducted, then change the rules. Those who, for whatever reason, choose not to participate have implicitly "oped out" of the decisions.

          The plan adopted to accommodate 2-meter NBD repeaters had been around for 2-years. It had been discussed on a number of occasions. I did an outreach to EmComm folks, because I have the ability to do that and they are heavy simplex users. I had not anticipated this would be brought up at the meeting, but once it had, as Chair, I saw no choice but to allow it on the floor. We are a member-driven organization, and such action is clearly spelled out in the By-laws. The Chair is charged with following the will of the membership.


          We have a large "installed base" of conventional 2-meter analog repeaters and a vast constellation of compatible user equipment in Western Washington. Over decades, this has all been built and coordinated according to our existing Band Plan. When the rest of the country changed from 30-kHz spacing to 15-kHz spacing on 2-meters, we in the Northwest adopted 20-kHz spacing instead. This has proven to be the better choice. Watching the struggles of 15-kHz operations in California, with its requirement for geographic separation, inverted pairs, and other methods to overcome the signal overlap is enough to make a prudent coordinator want to run the other way. The 20-kHz choice was the better option.

          Having gone down the 20 kHz road, should we now decide to shift to a 15-kHz (or some other) scheme for our existing analog repeaters, a few things will happen. First, nearly every one of these will have to change frequency. Because we have never had to do a lot of "geographic separation", and now will have given up the guard bands, just cramming everything closer together won't work in many cases.

          Think of it this way; I have a parking lot, striped at 6.5 foot intervals. All cars are 6-feet wide. I now re-stripe the lot at 5.5-feet. Will I be able to park more cars? Will all the original cars still fit in the lot?

          That means nearly everyone will have to change frequency. Some won't work any more on the closest new pair and will have to find a new pair "geographically separated" from the newly interfering neighbor. Some may not be able to find an acceptable spot at all. While this hunt for a new home is on, on a large scale, all the other repeaters will be moving, in a giant game of "musical chairs". So this problem becomes many times more difficult than it would at first appear.

          Second problem, our neighbors, BC and OR would not necessarily be keen on following our lead. In the "border areas", the interference issues would be compounded. Our Band Plan and theirs would no longer line up, and we aren't talking about the overlap area being the crest of the Siskiyou Mountains or sparsely populated southeastern-Oregon/northeastern-California. No the overlap would be much of Puget Sound and southern BC. If you want good neighbors, you have to be a good neighbor.

          The third, and I think biggest problem, grows out of the authority issue we talked about above. WWARA has no authority to "order" a repeater to move. This wholesale relocation of nearly every 2-meter repeater in Western Washington would have to be VOLUNTARY. In the case where a particular repeater owner refused to move, and was de-coordinated because of it, when another repeater began interfering with their operation, they minght have good grounds, in my (not a lawyer) opinion, for legal action.

          The last time this was done was in the late 1970's/early 1980's. We moved from 30-kHz spacing to 20-kHz spacing. It took 5-years for everyone to agree to move, and 10-years before the last system had actually accomplished the move. There were far fewer than half the number of repeaters, and everyone got a new pair with no interference.

          In this case, as soon as one repeater moved, it would be interfering with its neighbors, and the interference would not end until the last machine was settled on its new pair. Numbers on a spreadsheet look neat and clean, but reality is far messier. I have yet to see anything like a real-world plan on how to get from what we have, to any other scheme.

          So, as I see it, any plan that requires moving a lot of repeaters around, especially one involving changing to 15-kHz spacing is a bad idea. One day, the conventional 5-kHz deviation repeater will be a thing of the past, but for now, the vast majority of our infrastructure is built on these and we need to protect them.


          As for the large number of "unused" repeaters, that is the nature of the beast, and has always been so. Thirty or forty years ago, there were fewer repeaters, and no cell phones. For many, 2-meter repeaters were THE way they kept in touch. Even then, most repeaters sat idle most of the time. Times change. Our repeater infrastructure is less used now, and there are more repeaters than before. We could certainly pack them a little more tightly if we wanted to. That would be a matter of advocacy on the part of the Band Chairs, "selling" it to the membership, and a higher threshold of tolerance for neighboring signals.

          Our Policies do not address "usage" or "desirability" of repeaters as a criteria upon which they can be evaluated. WWARA leaves the issues of desirability or necessity up to the repeater owner. That is probably where they should rest. Remembering that the authority to coordinate originates with the licensees, who better to make this determination than the person who is footing the bill. We have the authority to not hold coordinations for "paper repeaters" that are not actually on the air.

          The idea that large areas of the repeater spectrum are "unused" much of the time begs the question, why would we then hold another portion of the spectrum "unused" much of the time on the off chance someone would want to use it for simplex contacts? Sure, 146.52 should remain open as a calling frequency, but once a contact has been made, why not move off to one of the large number of "unused" repeater frequencies to carry on the QSO?

          73,

          Frank Wolfe, NM7R
          Chair WWARA









          --- In WWARA-Members@yahoogroups.com, "pingster74" <2mband@...> wrote:
          >
          > Stephen summed it up pretty well and I applaud him taking the time to post.
          >
          > Although the WWARA has been hashing this out internally for a few years and there were several proposals which none were good. It was a rather sudden move voted on by a majority of those present which was ramrodded to a vote by a few that had a vested interest in creating new repeater pairs to serve their interests instead of working within the system like everyone else wishing to be coordinated. In fact this topic wasn't scheduled business for this meeting and not even mentioned in the previous meetings minutes. After the vote was completed a question was asked how many will be going home and filing tech data sheets and applying for these new frequencies that day and six people raised their hands. One person even said they already had theirs already filled in and ready to be turned in when the meeting was over. In my opinion it is hard to justify this take over when so many repeaters sit idle for weeks on end doing nothing except for the occasional IDing, somehow these systems seemed to have more merit than the frequencies used by simplex users on a regular basis. Holding a group of inactive frequencies to be used for whatever purpose is not effective use.
          >
          > There clearly was not enough effort put into widely publicizing the plan of taking over of more spectrum for repeaters. You likely would not have ever heard about the plan to consume more frequencies unless you were a member of the WWARA. A presentation at Comm Academy might have been one of many steps in the right direction for getting the information out but is much too little effort. It is arguably not representative of the majority of the ham community. EmComm folks are a small slice of the community. I went to Comm Academy and estimate that there were about 200 people in attendance. With several classes being held at the same time at different locations I wonder how many people attended this particular presentation. It is also a bad business to require people to become members of the WWARA to be able to have a vote on something that impacts them when they aren't interested in repeaters in the first place. Being able to "read the rules in such a way that we almost have a mandate to move forward with this" is a creative interpretation of the rules and the same thought process could be used against this move.
          >
          > In reality the FCC doesn't even recognize or regulate repeater coordinators and gives them zero authority. It is the FCC's stance that if the existing coordination body doesn't work for you or meet your needs that you are encouraged to find one that will. Create one if you need to, others have. Coordination is an option not a requirement. Because of this it is important that the WWARA not make themselves irrelevant to the community by not getting buy in of those who use the frequencies impacted. Frequency coordination can be a good thing and should be embraced by the community but only if there is mutual respect. It's up to the individual licensee to choose to recognize the frequency coordinator.
          >
          > I can't see a lawsuit actually surfacing from the decision recently made mainly because there are no requirements or obligation for any simplex user to move. The licensee of the repeater is equally responsible for not causing interference to the simplex user whether or not they are coordinated. The FCC only addresses interference between two repeaters not a repeater vs a simplex user. This is why there is a generally accepted ARRL band plan, it's a gentlemans agreement and seems to have worked pretty well.
          >
          > A repeater is a repeater and should not be given any preference or special treatment due to its mode or bandwidth.
          >
          > Was this change to the WWARA band plan good for ham radio or was it good for a select few?
          >
          > Mike
          > N3KPU
          >
          > --- In WWARA-Members@yahoogroups.com, "Stephen Kangas" <stephen@> wrote:
          > >
          > > As I understand it, a lawsuit would likely have no basis as there is no FCC
          > > allocation of frequencies re use and therefore WWARA could not enforce their
          > > exclusive use of frequencies anymore than simplex users can. Certainly the
          > > FCC encourages bandplan usage via local groups like WWARA, but it seems that
          > > it is not legally pursuable unless the FCC were to issue a ruling on a
          > > complaint filing that is in conflict with federal law, in which case it
          > > would be the FCC that would be sued. As NM7R points out below, the fed law
          > > clearly states that no one, including WWARA, can make exclusive use of one
          > > or more frequencies, thus the stage is set for conflict among those who
          > > choose not to "cooperate". Some of you lawyers out there correct me if I'm
          > > wrong.
          > >
          > > With that said, there may be an increased risk of conflict between repeater
          > > and simplex users particularly in rural mountainous areas, such as E King
          > > Co, where there is significant regular simplex usage due to topography that
          > > prevents reliable repeater coverage, "frequent" power outages affecting
          > > repeaters, RC vehicles, and informal local groups of hams on 2m/70cm. My
          > > bet is that you may not hear complaints until after such time that repeater
          > > owners make their investment into equipment to expand into "new" frequencies
          > > and simplex users begin experiencing "infringement" that interferes both
          > > ways. Ie, simplex users are not likely aware of your new plans yet...which
          > > begs the question of "what has been done to widely and effectively publicize
          > > new WWARA repeater frequency plans?" Suggestions there: ARRL email news (WA
          > > group); QST on repeater networks re new plan & where to learn more; notices
          > > at all WA hamfests & clubs (PNWVHFS, SeaPac, M&KARC, etc etc), not just an
          > > insular group as the emcomm guys attending Communications Academy; posting
          > > on Yahoo/Google/Facebook ham groups. (Note: I personally have not heard
          > > about this new plan via any of those common ham communications forums...only
          > > heard about it here on the WWARA forum, which of course is an insular and
          > > small group).
          > >
          > > Therefore, I submit that unless you have done a reasonable attempt to
          > > effectively communicate in advance the new bandplan among as many licensed
          > > hams as possible, you will become the primary party setting the stage for a
          > > conflict that has the potential of becoming a larger firestorm than any that
          > > might come up before it's implementation. As those among us who have
          > > experience as project managers know, getting stakeholder buy-in on a project
          > > plan is key to seeing a smooth successful execution of the plan.
          > >
          > > 73, Stephen W9SK
          > >
          > > -----Original Message-----
          > > From: WWARA-Members@yahoogroups.com [mailto:WWARA-Members@yahoogroups.com]
          > > On Behalf Of NM7R
          > > Sent: Sunday, July 08, 2012 10:17 AM
          > > To: WWARA-Members@yahoogroups.com
          > > Subject: [WWARA-Members] comments on band plan changes?
          > >
          > > Frank,
          > > Have you received any cards, letters, phone calls or emails from folks
          > > having varying opinions on the recently adopted band plan changes? Since we
          > > (the board) has heard nothing from you lately can we assume that you are
          > > not hearing much of anything from our "clients" or those who feel that the
          > > simplex frequencies belong to them?
          > > At lunch today with a bunch of ham friends was one of the other folks
          > > who had been at field day with John Hays when Grant Hopper visited. This
          > > person repeated some of the stuff that John reported including Grant's
          > > mentioning that he had been contacted by folks who may be contemplating some
          > > sort of law suit because of the new band plan adoption. Have you heard
          > > anything about such a thing?
          > >
          > > Peter
          > >
          > > ----
          > >
          > > Peter,
          > >
          > > I have received one (1) email regarding the recent Band Plan revision. I
          > > will append it and my response, to this email as "Appendix A". I think it
          > > outlines my view of the issue fairly well.
          > >
          > > In April 2011, I made a presentation at Communications Academy about this
          > > proposal for creating 2-meter narrow-band/digital (NBD) pairs. The proposal
          > > as presented was almost identical to what was adopted. The Power Point
          > > presentation was available on the Communications Academy "presentations"
          > > distribution. The Power Point presentation is also available on the WWARA
          > > Members Group, in the Files section.
          > >
          > > Arguably, Communications Academy is the largest gathering of Amateur Radio
          > > Emergency Communications (EmComm) leadership in Western Washington.
          > > Virtually every "main stream" WWa group engaged in EmComm activities has at
          > > least one member attending that conference each year. I know of no other
          > > forum where EmComm personnel can be as effectively addressed. My intention
          > > was specifically to "warn" the EmComm community that adoption of this
          > > proposal was a real possibility in the near future.
          > >
          > > This year, April 2012, I gave a presentation at Communications Academy on
          > > "Nets". The establishment of a logistics Net is a cornerstone of our Amateur
          > > EmComm response in most situations. During that presentation I went into
          > > some detail about looking for "non-standard" simplex frequencies in order to
          > > avoid crowding on the traditional channels, and stated quite clearly that
          > > the "traditional channels" were presently being shared by VoIP (EchoLink and
          > > IRLP) stations and would probably be under pressure for other activities.
          > > One such activity specifically mentioned was our proposal for 2-meter NBD
          > > pairs.
          > >
          > > I am satisfied this good-faith outreach to the Amateur operators most
          > > affected by the proposal was well received. As part of these presentations,
          > > I specifically made a point of inviting any interested Amateurs to join
          > > WWARA, either as an individual or organization, so they would have voting
          > > input to the process.
          > >
          > > I would like to note that Grant Hopper has not contacted me, either as WWARA
          > > Chair or as Western Washington SEC, about this matter. I would welcome any
          > > feedback from him or anyone else.
          > >
          > > I am not a lawyer, but frankly, I don't see where any Amateur radio
          > > individual or group has "standing" to bring a law suit. They would have to
          > > show that WWARA has caused them "harm".
          > >
          > > Part 97.101(b) states: "(b) Each station licensee and each control operator
          > > must cooperate in selecting transmitting channels and in making the most
          > > effective use of the amateur service frequencies. No frequency will be
          > > assigned for the exclusive use of any station."
          > >
          > > As far as I can see, "assigned" simplex channels were self-assigned by the
          > > EmComm entities themselves, in clear contradiction to this passage. It can
          > > be argued that this same passage promotes our action as part of "…making the
          > > most effective use of the amateur service frequencies." Holding a group of
          > > frequencies inactive to be used for EmComm is not effective use.
          > >
          > > A repeater owner/licensee clearly has the authority to establish a repeater
          > > on these new frequencies, as stated in Part 97.205(a) and (b) [here edited
          > > for brevity, complete text follows as "Appendix B"]: "(a) Any amateur
          > > station ... may be a repeater…"
          > >
          > > "(b) A repeater may receive and retransmit only on the 10 m and shorter
          > > wavelength frequency bands except the … 144.0-144.5 MHz, 145.5-146.0 MHz, …
          > > segments."
          > >
          > > So, I can't see any "harm" in the legal sense, and can read the Rules in
          > > such a way that we almost have a mandate to move forward with this. Part
          > > 97.205( c) which covers coordination, only mentions interference between
          > > repeaters. Simplex or other modes of operation are not mentioned. It would
          > > appear to be assumed that simplex stations can move to avoid interference.
          > >
          > > I will post this email to the Members' Remailer, as I am sure there is a
          > > wider interest in this issue. As we move forward with this NBD build-out, I
          > > hope all of our members participating will be sensitive to the present users
          > > of these frequencies, and try to minimize their impact as far as
          > > practicable. While I am confident this WWARA policy change is within the
          > > scope of our authority, there is no point in causing anyone unnecessary
          > > grief.
          > >
          > > 73, Frank, NM7R
          > >
          > >
          > > -----
          > >
          > > "Appendix A"
          > >
          > >
          > > From: <name redacted>
          > > To: chair@
          > > Sent: Tuesday, June 12, 2012 3:53 PM
          > > Subject: Revision to 2m Band Plan
          > >
          > > Hi - Frank,
          > > I have mapped out the proposed changes in the 2 meter band; however, I
          > > do have some serious concerns about the simplex frequencies being reduced to
          > > a mere 5% of the band. It looks like there is hardly any room for simple one
          > > to one contacts or for RACES groups to talk to their teams with out
          > > interfering with others.
          > > Could you please clarify the specific frequencies that would be used for
          > > the repeaters in the simplex area? Would 146.500 & 147.500 MHz still be
          > > simplex channels?
          > > I have attached a PDF with the proposed changes highlighted in bright
          > > yellow. Could you please confirm that this is correct? Changes to the 2m
          > > simplex will specifically affect some of the following groups: Renton, Red
          > > Cross, Mercer Island, PSE, Mercury NW, Bellevue, Redmond, Camp Murray, and
          > > King Co. Search and Rescue as well as other non ARES/RACES groups. If
          > > 146.5 & 147.5 are included as repeater frequencies, then add the King Co.
          > > ECC, Shoreline and Vashon Island. In the end all teams will be affected.
          > > Sincerely,
          > > <name redacted>
          > >
          > > -----
          > >
          > > <Reply>
          > >
          > > Thank you for contacting me about the recent WWARA policy change affecting
          > > the lower half of the traditional simplex bands.
          > >
          > > You say that the simplex frequencies have been reduced to 5% of the 2-meter
          > > band. This is not entirely correct. A large percentage of the band is
          > > potentially available for simplex use. In fact, there is a problem that
          > > commonly comes up using the traditional simplex frequencies in that every
          > > jurisdiction is trying to use the same handful of frequencies, causing lots
          > > of mutual interference.
          > >
          > > The only portion of the band specifically excluded by the FCC is 144.0 to
          > > 144.1 MHz. The rest is available on a not-to-interfere basis. While I know
          > > that sounds overly simplistic, in any given area of Western Washington
          > > (WWa), there are repeater output frequencies, input frequencies and
          > > non-repeater frequencies, not used locally, and therefore available for
          > > tactical simplex communications. It takes some effort to compile a list, but
          > > many jurisdictions have done just this. The comments from those who have
          > > gone through this exercise usually express amazement at how many are
          > > actually available.
          > >
          > > There are 59 repeater output frequencies in the 2-meter band. Certainly not
          > > all of them are used for "local" repeaters in any given area. As long as the
          > > signal from your local simplex partner is stronger than that from the
          > > distant repeater, you can probably use that for local simplex. Using PL
          > > encode/decode can allow you to not hear the distant machine. The input
          > > frequency of a distant repeater will also work well. Make sure you are not
          > > transmitting the PL tone it uses.
          > >
          > > There are two areas of the 2-meter band where repeaters are prohibited;
          > > 144.000 to 144.500, and 145.500 to 146.000. Using 144.300 to 144.500 would
          > > still allow room for CW and SSB operations. Using 145.500 to 145.800, would
          > > stay clear of the OSCAR sub-band. This provides 500 kHz (25 channels) of
          > > potential EmComm FM simplex operating room. And, don't forget the other
          > > bands we have available, 220- and 440-MHz offer lots of room for simplex
          > > operations.
          > >
          > > Any Amateur radio less than 35-years old is synthesized, and can operate on
          > > any frequency in the band. Forty years ago, most radios were crystal
          > > controlled, and an operator might only have 12 channels from which to
          > > choose. In that environment, a handful of "reserved" simplex channels made
          > > sense.
          > >
          > > Most Emergency Communications (EmComm) today use repeaters, because they
          > > support longer range and allow better coordination. If a repeater goes off
          > > the air during an incident, the logical simplex frequency to use is the
          > > repeater output frequency. It is now available, everyone is listening to it
          > > already, and if the repeater comes back on the air, everyone will know about
          > > it. When a repeater is off the air, its input frequency is also available.
          > >
          > > In fact, the new, Narrow-Band/Digital (NBD) repeaters that the new channel
          > > scheme is to serve, are largely owned and sponsored by EmComm organizations.
          > > Attempting to accommodate them in the traditional (analog FM) repeater
          > > channel pairs has been unsatisfactory. There are few if any open slots for
          > > new repeaters in WWa on 2-meters, and there are compatibility issues when
          > > operating the new NBD and older analog FM in the same environment. WWARA has
          > > been studying and discussing alternative methods of incorporating these new
          > > relay devices for 2 years. This is the "least worst" answer.
          > >
          > > Note: The Highline Repeater Group was the first to file an application for
          > > one of these "NBD Pairs".
          > >
          > > 73,
          > > Frank Wolfe, NM7R
          > > Chair, WWARA
          > >
          > >
          > > -----
          > > -----
          > >
          > > "Appendix B"
          > >
          > > Part 97 FCC Regulations excerpts:
          > >
          > > §97.101 General standards. -
          > >
          > > (a) In all respects not specifically covered by FCC Rules each amateur
          > > station must be operated in accordance with good engineering and good
          > > amateur practice.
          > >
          > > (b) Each station licensee and each control operator must cooperate in
          > > selecting transmitting channels and in making the most effective use of the
          > > amateur service frequencies. No frequency will be assigned for the exclusive
          > > use of any station.
          > >
          > > (c) At all times and on all frequencies, each control operator must give
          > > priority to stations providing emergency communications, except to stations
          > > transmitting communications for training drills and tests in RACES.
          > >
          > > (d) No amateur operator shall willfully or maliciously interfere with or
          > > cause interference to any radio communication or signal.
          > >
          > >
          > >
          > > §97.205 Repeater station. -
          > >
          > > (a) Any amateur station licensed to a holder of a Technician, General,
          > > Advanced or Amateur Extra Class operator license may be a repeater. A holder
          > > of a Technician, General, Advanced or Amateur Extra Class operator license
          > > may be the control operator of a repeater, subject to the privileges of the
          > > class of operator license held.
          > >
          > > (b) A repeater may receive and retransmit only on the 10 m and shorter
          > > wavelength frequency bands except the 28.0-29.5 MHz, 50.0-51.0 MHz,
          > > 144.0-144.5 MHz, 145.5-146.0 MHz, 222.00-222.15 MHz, 431.0-433.0 MHz and
          > > 435.0-438.0 MHz segments.
          > >
          > > (c) Where the transmissions of a repeater cause harmful interference to
          > > another repeater, the two station licensees are equally and fully
          > > responsible for resolving the interference unless the operation of one
          > > station is recommended by a frequency coordinator and the operation of the
          > > other station is not. In that case, the licensee of the noncoordinated
          > > repeater has primary responsibility to resolve the interference.
          > >
          > > (d) A repeater may be automatically controlled.
          > >
          > > (e) Ancillary functions of a repeater that are available to users on the
          > > input channel are not considered remotely controlled functions of the
          > > station. Limiting the use of a repeater to only certain user stations is
          > > permissible.
          > >
          > > (f) [Reserved]
          > >
          > > (g) The control operator of a repeater that retransmits inadvertently
          > > communications that violate the rules in this Part is not accountable for
          > > the violative communications.
          > >
          > > (h) The provisions of this paragraph do not apply to repeaters that transmit
          > > on the 1.2 cm or shorter wavelength bands. Before establishing a repeater
          > > within 16 km (10 miles) of the Arecibo Observatory or before changing the
          > > transmitting frequency, transmitter power, antenna height or directivity of
          > > an existing repeater, the station licensee must give written notification
          > > thereof to the Interference Office, Arecibo Observatory, HC3 Box 53995,
          > > Arecibo, Puerto Rico 00612, in writing or electronically, of the technical
          > > parameters of the proposal. Licensees who choose to transmit information
          > > electronically should e-mail to: prcz@
          > >
          > > <end>
          > >
          > >
          > >
          > >
          > >
          > > ------------------------------------
          > >
          > > Yahoo! Groups Links
          > >
          >
        • Bill Vodall
          ... There s an assumption that every repeater gets clear un-interfered access to its own channel. Why can t they share channels? Two or more seldom used
          Message 4 of 10 , Jul 27, 2012
            > In this case, as soon as one repeater moved, it would be interfering with
            > its neighbors, and the interference would not end until the last machine was
            > settled on its new pair.

            There's an assumption that every repeater gets clear 'un-interfered'
            access to its own channel. Why can't they share channels? Two or
            more seldom used machines can easily 'seldom use' a channel at the
            same time. Wouldn't interference be minimal through use of tone or
            other modern technologies?

            > As for the large number of "unused" repeaters, that is the nature of the
            > beast, and has always been so. Thirty or forty years ago, there were fewer
            > repeaters, and no cell phones. For many, 2-meter repeaters were THE way they
            > kept in touch. Even then, most repeaters sat idle most of the time. Times
            > change. Our repeater infrastructure is less used now, and there are more
            > repeaters than before. We could certainly pack them a little more tightly if
            > we wanted to. That would be a matter of advocacy on the part of the Band
            > Chairs, "selling" it to the membership, and a higher threshold of tolerance
            > for neighboring signals.

            ... and sharing channels... Idle channels and spectrum is one of
            the great challenges we face.

            > The idea that large areas of the repeater spectrum are "unused" much of
            > the time begs the question, why would we then hold another portion of the
            > spectrum "unused" much of the time on the off chance someone would want to
            > use it for simplex contacts?

            Was there any data gathered on just how unused the non-repeater
            spectrum was? How can it be claimed to be unused without data?

            I monitor both the 59 repeater channels and many of the simplex
            channels in the heart of the usage region for about an hour daily. I
            would throw out the unscientific observation that the simplex channels
            being redistributed have more use, percentage wise, than the existing
            59 repeater channels.

            Of course usage per channel calculations would get interesting when
            considering that X narrow-band repeater channels are using Y*2
            conventional simplex channels.

            > Frank Wolfe, NM7R
            > Chair WWARA

            73
            Bill, WA7NWP
            User of Simplex and Repeaters...
          • NM7R
            Bill, We have over 90 repeaters on the 59 2-meter pairs. That doesn t include the Canadian or Oregon co-channel stations, the SNP channels or the several
            Message 5 of 10 , Jul 27, 2012
              Bill,

              We have over 90 repeaters on the 59 2-meter pairs. That doesn't include the Canadian or Oregon co-channel stations, the SNP channels or the several repeaters that are not coordinated. No one has a clear channel now.

              The threshold for how close you can space two repeaters is the point where their "intended user coverage areas" begin to overlap. Defining this coverage area is one of the issues. If everyone did an honest assessment of the area they need to cover, we could probably stack machines much closer. It would also help if everyone turned down their transmit power. Ten watts is usually plenty for a well placed repeater on 2-m.

              The problem is, even though many of our repeaters are "seldom used", they are seldom used at the same times. If they are to operate successfully, they need to deliver a stronger signal to their users than any other co-channel repeater. Tone squelch won't help this. The "capture effect" with FM requires that the desired signal be several dB stronger than the undesired signal if you are going to be able to hear your desired repeater.

              We could place repeaters closer together, however this is complicated by the twin facts that (1) there are limited numbers of sites available, and (2) several repeaters are trying to cover similar areas. There has to be some degree of geographic separation, and co-channeling works best where there is a "wall" (hill, ridge or other natural divider) between the two coverage areas. This provides the several dB of attenuation without resorting to lots of distance instead.

              The point regarding simplex use is not that the "simplex reservation" is unused. The point is that simplex operation is the most flexible operation, and can easily move to any frequency, including the output (or input) frequencies of the "seldom used" repeaters, or areas of the spectrum not allowed for repeaters. Using 146.52 as a calling channel works fine, and then, once in contact, you move off to a "working channel". This would be different in different areas, depending on band usage.

              Once upon a time, we all had crystal controlled radios, with a dozen or fewer fixed channels. In that context we needed a few common simplex channels so we would all have them in common. Nowadays we use synthesized radios with the capability of operating anywhere in the band. We can pick a frequency and go there. If it is busy, we can step up 20 kHz until we find an open one. It works on HF, why not VHF?

              The point is, in order to be of any use at all, a repeater must operate on a fixed pair of frequencies. Users need to know how to find it and what it covers. It cannot easily move, and the coverage area must not have on-channel signals above a certain level. Simplex on the other hand, with modern radios, can operate on nearly any single frequency, including those also (seldom) used by a repeater.

              In the EmComm arena, all the several jurisdictions were trying to use the same handful of simplex frequencies. In any given area, there are many frequencies that can be used for simplex, including outputs (and inputs) of repeaters that aren't close enough to interfere. This affords not only a larger stable of frequencies, but they are spread out over the band, so to interfere with each other less, and they tend to be different in different areas, allowing each area a set of "unique" simplex frequencies.

              That leaves 146.52 as a common calling frequency for interoperability. So, far from being a "stop gap" answer to the simplex question, this represents better spectrum use with better operating characteristics.

              So, I'll turn your question around. There's an assumption that everyone has to use the same group of reserved simplex frequencies. Why can't we share simplex channels (with under-used repeaters)?

              73, Frank, NM7R






              --- In WWARA-Members@yahoogroups.com, Bill Vodall <wa7nwp@...> wrote:
              >
              > > In this case, as soon as one repeater moved, it would be interfering with
              > > its neighbors, and the interference would not end until the last machine was
              > > settled on its new pair.
              >
              > There's an assumption that every repeater gets clear 'un-interfered'
              > access to its own channel. Why can't they share channels? Two or
              > more seldom used machines can easily 'seldom use' a channel at the
              > same time. Wouldn't interference be minimal through use of tone or
              > other modern technologies?
              >
              > > As for the large number of "unused" repeaters, that is the nature of the
              > > beast, and has always been so. Thirty or forty years ago, there were fewer
              > > repeaters, and no cell phones. For many, 2-meter repeaters were THE way they
              > > kept in touch. Even then, most repeaters sat idle most of the time. Times
              > > change. Our repeater infrastructure is less used now, and there are more
              > > repeaters than before. We could certainly pack them a little more tightly if
              > > we wanted to. That would be a matter of advocacy on the part of the Band
              > > Chairs, "selling" it to the membership, and a higher threshold of tolerance
              > > for neighboring signals.
              >
              > ... and sharing channels... Idle channels and spectrum is one of
              > the great challenges we face.
              >
              > > The idea that large areas of the repeater spectrum are "unused" much of
              > > the time begs the question, why would we then hold another portion of the
              > > spectrum "unused" much of the time on the off chance someone would want to
              > > use it for simplex contacts?
              >
              > Was there any data gathered on just how unused the non-repeater
              > spectrum was? How can it be claimed to be unused without data?
              >
              > I monitor both the 59 repeater channels and many of the simplex
              > channels in the heart of the usage region for about an hour daily. I
              > would throw out the unscientific observation that the simplex channels
              > being redistributed have more use, percentage wise, than the existing
              > 59 repeater channels.
              >
              > Of course usage per channel calculations would get interesting when
              > considering that X narrow-band repeater channels are using Y*2
              > conventional simplex channels.
              >
              > > Frank Wolfe, NM7R
              > > Chair WWARA
              >
              > 73
              > Bill, WA7NWP
              > User of Simplex and Repeaters...
              >
            • pingster74
              I think it is in order to say this vote was unfair. The decision was made by members present of a group that only stood to benefit from the outcome. To say
              Message 6 of 10 , Aug 3, 2012
                I think it is in order to say this vote was unfair. The decision was made by members present of a group that only stood to benefit from the outcome. To say the simplex users by default opted out because they didn't participate in an unannounced vote by a special interest group that requires membership as a basis to vote is ludicrous. In other words they were "squelched." Why would someone not interested in repeaters even come to a WWARA meeting?

                Hams generally respected the ARRL band plan aka "gentleman's agreement" and have mostly stayed out of the repeater sub-band preventing interference complaints, now recently it has been encouraged to operate simplex in the repeater band as a concession to a "land grab" of simplex frequencies. Previously if a simplex user was to use a repeater input/output and it caused interference to the repeater then we could educate the simplex users and suggest that they check the ARRL band plan for a better choice of frequencies. Are we expected to now entertain interference complaints from repeater owners on the new repeater frequencies? FCC rules only address interference issues between repeaters and who is responsible for the resolution, otherwise a simplex user is on the same playing ground as a repeater. As I see it, if there is an ongoing conversation on the output of one of the new repeater frequencies the new repeater will have to refrain from keying up until the simplex users are finished otherwise it is considered interference. Another probable situation could be that a group of simplex users have a strong signal on the input of one of the new repeater frequencies rendering the repeater useless on occasion. There is no requirement for them to move simply because they have a VFO they have equal right to tell the repeater to move.


                --- In WWARA-Members@yahoogroups.com, "NM7R" <nm7r@...> wrote:
                >
                > Mike has raised several good points.
                >
                > We have been discussing this issue (accommodating Narrow-Band/Digital (NBD), D-Star and similar) for more than two years. During that time, the 440 Band Chair has enlisted the help of several applicants to give "splinter" operation a try. This solution to the accommodation problem, in the context of our existing 440 Band Plan seems to be a good one. It provides a home for some NBD machines without dislocating or compromising the existing users. But once the NBD systems had shown this scheme to work satisfactorily, our Band Plan didn't allow for them to be coordinated, leaving them in a permanent state of "Pending".
                >
                > I felt it only fair to request a motion that we amend our Band Plan to allow for the inclusion of these repeaters under our coordination policy. This recognizes not only the success of Steve Szombathy's, W7UDI, initiative and effort, but the willingness of the few pioneers to spend the extra time and dollars to give this a try, with no guarantee that they would be able to continue to operate. I want to thank Steve for carrying this forward, and the pioneers for their willingness to participate.
                >
                > The 70-cm band is different in several ways from the 2-meter band, and this "splinter" scheme will not work on 2-meters, due to the closer spacing of the existing repeaters, and to some extent also to the heavier loading of the band.
                >
                > Several plans for accommodation of NBD machines on 2-meters have been put forward. Only one met the twin criteria of (1) not dislocating or compromising existing coordinations, and (2) providing a home for a significant number of repeaters. Why are these points important? Let me digress a moment to look at the legal side.
                >
                >
                > The FCC doesn't recognize or "license" coordinators. They do mention them in Part 97 as "recommending" a particular frequency for a particular repeater. The reason for this is that the Amateur Radio Service is built upon the foundation of the individual Operator/Station License. The only license necessary to establish an Amateur station is the one you carry in your pocket, and that station may be a repeater. The authority to operate a repeater rests with the individual Amateur licensee, as a co-equal with all other licensees.
                >
                > If an individual Amateur licensee decides to set up a repeater, he or she has the authority to do so. The WWARA has no authority to prohibit, or in fact to authorize this. The authority rests entirely with the individual Amateur licensee. The function of WWARA is advisory in nature. In essence, we are a forum in which Amateurs may choose to participate, towards the goal of minimizing mutual interference between systems. This is in everyone's best interest, because all licensees have an obligation to minimize interference under all circumstances.
                >
                > We can argue about what a coordinator may and may not do, but the bottom line is, the authority to coordinate is an extension of the collective authority of the members' licenses. We are in effect, pooling our individual authorities to operate, and meeting as equal partners in the enterprise of coordination. WWARA has only the authority it is granted by the members.
                >
                > We have established By-laws, Policies and Band Plans, all approved in open meetings. To say that it is unfair to follow these by making a decision based on a motion from the floor, with a vote of the members present is out of order. This is basic Democracy in action. If this is not the way business should be conducted, then change the rules. Those who, for whatever reason, choose not to participate have implicitly "oped out" of the decisions.
                >
                > The plan adopted to accommodate 2-meter NBD repeaters had been around for 2-years. It had been discussed on a number of occasions. I did an outreach to EmComm folks, because I have the ability to do that and they are heavy simplex users. I had not anticipated this would be brought up at the meeting, but once it had, as Chair, I saw no choice but to allow it on the floor. We are a member-driven organization, and such action is clearly spelled out in the By-laws. The Chair is charged with following the will of the membership.
                >
                >
                > We have a large "installed base" of conventional 2-meter analog repeaters and a vast constellation of compatible user equipment in Western Washington. Over decades, this has all been built and coordinated according to our existing Band Plan. When the rest of the country changed from 30-kHz spacing to 15-kHz spacing on 2-meters, we in the Northwest adopted 20-kHz spacing instead. This has proven to be the better choice. Watching the struggles of 15-kHz operations in California, with its requirement for geographic separation, inverted pairs, and other methods to overcome the signal overlap is enough to make a prudent coordinator want to run the other way. The 20-kHz choice was the better option.
                >
                > Having gone down the 20 kHz road, should we now decide to shift to a 15-kHz (or some other) scheme for our existing analog repeaters, a few things will happen. First, nearly every one of these will have to change frequency. Because we have never had to do a lot of "geographic separation", and now will have given up the guard bands, just cramming everything closer together won't work in many cases.
                >
                > Think of it this way; I have a parking lot, striped at 6.5 foot intervals. All cars are 6-feet wide. I now re-stripe the lot at 5.5-feet. Will I be able to park more cars? Will all the original cars still fit in the lot?
                >
                > That means nearly everyone will have to change frequency. Some won't work any more on the closest new pair and will have to find a new pair "geographically separated" from the newly interfering neighbor. Some may not be able to find an acceptable spot at all. While this hunt for a new home is on, on a large scale, all the other repeaters will be moving, in a giant game of "musical chairs". So this problem becomes many times more difficult than it would at first appear.
                >
                > Second problem, our neighbors, BC and OR would not necessarily be keen on following our lead. In the "border areas", the interference issues would be compounded. Our Band Plan and theirs would no longer line up, and we aren't talking about the overlap area being the crest of the Siskiyou Mountains or sparsely populated southeastern-Oregon/northeastern-California. No the overlap would be much of Puget Sound and southern BC. If you want good neighbors, you have to be a good neighbor.
                >
                > The third, and I think biggest problem, grows out of the authority issue we talked about above. WWARA has no authority to "order" a repeater to move. This wholesale relocation of nearly every 2-meter repeater in Western Washington would have to be VOLUNTARY. In the case where a particular repeater owner refused to move, and was de-coordinated because of it, when another repeater began interfering with their operation, they minght have good grounds, in my (not a lawyer) opinion, for legal action.
                >
                > The last time this was done was in the late 1970's/early 1980's. We moved from 30-kHz spacing to 20-kHz spacing. It took 5-years for everyone to agree to move, and 10-years before the last system had actually accomplished the move. There were far fewer than half the number of repeaters, and everyone got a new pair with no interference.
                >
                > In this case, as soon as one repeater moved, it would be interfering with its neighbors, and the interference would not end until the last machine was settled on its new pair. Numbers on a spreadsheet look neat and clean, but reality is far messier. I have yet to see anything like a real-world plan on how to get from what we have, to any other scheme.
                >
                > So, as I see it, any plan that requires moving a lot of repeaters around, especially one involving changing to 15-kHz spacing is a bad idea. One day, the conventional 5-kHz deviation repeater will be a thing of the past, but for now, the vast majority of our infrastructure is built on these and we need to protect them.
                >
                >
                > As for the large number of "unused" repeaters, that is the nature of the beast, and has always been so. Thirty or forty years ago, there were fewer repeaters, and no cell phones. For many, 2-meter repeaters were THE way they kept in touch. Even then, most repeaters sat idle most of the time. Times change. Our repeater infrastructure is less used now, and there are more repeaters than before. We could certainly pack them a little more tightly if we wanted to. That would be a matter of advocacy on the part of the Band Chairs, "selling" it to the membership, and a higher threshold of tolerance for neighboring signals.
                >
                > Our Policies do not address "usage" or "desirability" of repeaters as a criteria upon which they can be evaluated. WWARA leaves the issues of desirability or necessity up to the repeater owner. That is probably where they should rest. Remembering that the authority to coordinate originates with the licensees, who better to make this determination than the person who is footing the bill. We have the authority to not hold coordinations for "paper repeaters" that are not actually on the air.
                >
                > The idea that large areas of the repeater spectrum are "unused" much of the time begs the question, why would we then hold another portion of the spectrum "unused" much of the time on the off chance someone would want to use it for simplex contacts? Sure, 146.52 should remain open as a calling frequency, but once a contact has been made, why not move off to one of the large number of "unused" repeater frequencies to carry on the QSO?
                >
                > 73,
                >
                > Frank Wolfe, NM7R
                > Chair WWARA
                >
                >
                >
                >
                >
                >
                >
                >
                >
                > --- In WWARA-Members@yahoogroups.com, "pingster74" <2mband@> wrote:
                > >
                > > Stephen summed it up pretty well and I applaud him taking the time to post.
                > >
                > > Although the WWARA has been hashing this out internally for a few years and there were several proposals which none were good. It was a rather sudden move voted on by a majority of those present which was ramrodded to a vote by a few that had a vested interest in creating new repeater pairs to serve their interests instead of working within the system like everyone else wishing to be coordinated. In fact this topic wasn't scheduled business for this meeting and not even mentioned in the previous meetings minutes. After the vote was completed a question was asked how many will be going home and filing tech data sheets and applying for these new frequencies that day and six people raised their hands. One person even said they already had theirs already filled in and ready to be turned in when the meeting was over. In my opinion it is hard to justify this take over when so many repeaters sit idle for weeks on end doing nothing except for the occasional IDing, somehow these systems seemed to have more merit than the frequencies used by simplex users on a regular basis. Holding a group of inactive frequencies to be used for whatever purpose is not effective use.
                > >
                > > There clearly was not enough effort put into widely publicizing the plan of taking over of more spectrum for repeaters. You likely would not have ever heard about the plan to consume more frequencies unless you were a member of the WWARA. A presentation at Comm Academy might have been one of many steps in the right direction for getting the information out but is much too little effort. It is arguably not representative of the majority of the ham community. EmComm folks are a small slice of the community. I went to Comm Academy and estimate that there were about 200 people in attendance. With several classes being held at the same time at different locations I wonder how many people attended this particular presentation. It is also a bad business to require people to become members of the WWARA to be able to have a vote on something that impacts them when they aren't interested in repeaters in the first place. Being able to "read the rules in such a way that we almost have a mandate to move forward with this" is a creative interpretation of the rules and the same thought process could be used against this move.
                > >
                > > In reality the FCC doesn't even recognize or regulate repeater coordinators and gives them zero authority. It is the FCC's stance that if the existing coordination body doesn't work for you or meet your needs that you are encouraged to find one that will. Create one if you need to, others have. Coordination is an option not a requirement. Because of this it is important that the WWARA not make themselves irrelevant to the community by not getting buy in of those who use the frequencies impacted. Frequency coordination can be a good thing and should be embraced by the community but only if there is mutual respect. It's up to the individual licensee to choose to recognize the frequency coordinator.
                > >
                > > I can't see a lawsuit actually surfacing from the decision recently made mainly because there are no requirements or obligation for any simplex user to move. The licensee of the repeater is equally responsible for not causing interference to the simplex user whether or not they are coordinated. The FCC only addresses interference between two repeaters not a repeater vs a simplex user. This is why there is a generally accepted ARRL band plan, it's a gentlemans agreement and seems to have worked pretty well.
                > >
                > > A repeater is a repeater and should not be given any preference or special treatment due to its mode or bandwidth.
                > >
                > > Was this change to the WWARA band plan good for ham radio or was it good for a select few?
                > >
                > > Mike
                > > N3KPU
                > >
                > > --- In WWARA-Members@yahoogroups.com, "Stephen Kangas" <stephen@> wrote:
                > > >
                > > > As I understand it, a lawsuit would likely have no basis as there is no FCC
                > > > allocation of frequencies re use and therefore WWARA could not enforce their
                > > > exclusive use of frequencies anymore than simplex users can. Certainly the
                > > > FCC encourages bandplan usage via local groups like WWARA, but it seems that
                > > > it is not legally pursuable unless the FCC were to issue a ruling on a
                > > > complaint filing that is in conflict with federal law, in which case it
                > > > would be the FCC that would be sued. As NM7R points out below, the fed law
                > > > clearly states that no one, including WWARA, can make exclusive use of one
                > > > or more frequencies, thus the stage is set for conflict among those who
                > > > choose not to "cooperate". Some of you lawyers out there correct me if I'm
                > > > wrong.
                > > >
                > > > With that said, there may be an increased risk of conflict between repeater
                > > > and simplex users particularly in rural mountainous areas, such as E King
                > > > Co, where there is significant regular simplex usage due to topography that
                > > > prevents reliable repeater coverage, "frequent" power outages affecting
                > > > repeaters, RC vehicles, and informal local groups of hams on 2m/70cm. My
                > > > bet is that you may not hear complaints until after such time that repeater
                > > > owners make their investment into equipment to expand into "new" frequencies
                > > > and simplex users begin experiencing "infringement" that interferes both
                > > > ways. Ie, simplex users are not likely aware of your new plans yet...which
                > > > begs the question of "what has been done to widely and effectively publicize
                > > > new WWARA repeater frequency plans?" Suggestions there: ARRL email news (WA
                > > > group); QST on repeater networks re new plan & where to learn more; notices
                > > > at all WA hamfests & clubs (PNWVHFS, SeaPac, M&KARC, etc etc), not just an
                > > > insular group as the emcomm guys attending Communications Academy; posting
                > > > on Yahoo/Google/Facebook ham groups. (Note: I personally have not heard
                > > > about this new plan via any of those common ham communications forums...only
                > > > heard about it here on the WWARA forum, which of course is an insular and
                > > > small group).
                > > >
                > > > Therefore, I submit that unless you have done a reasonable attempt to
                > > > effectively communicate in advance the new bandplan among as many licensed
                > > > hams as possible, you will become the primary party setting the stage for a
                > > > conflict that has the potential of becoming a larger firestorm than any that
                > > > might come up before it's implementation. As those among us who have
                > > > experience as project managers know, getting stakeholder buy-in on a project
                > > > plan is key to seeing a smooth successful execution of the plan.
                > > >
                > > > 73, Stephen W9SK
                > > >
                > > > -----Original Message-----
                > > > From: WWARA-Members@yahoogroups.com [mailto:WWARA-Members@yahoogroups.com]
                > > > On Behalf Of NM7R
                > > > Sent: Sunday, July 08, 2012 10:17 AM
                > > > To: WWARA-Members@yahoogroups.com
                > > > Subject: [WWARA-Members] comments on band plan changes?
                > > >
                > > > Frank,
                > > > Have you received any cards, letters, phone calls or emails from folks
                > > > having varying opinions on the recently adopted band plan changes? Since we
                > > > (the board) has heard nothing from you lately can we assume that you are
                > > > not hearing much of anything from our "clients" or those who feel that the
                > > > simplex frequencies belong to them?
                > > > At lunch today with a bunch of ham friends was one of the other folks
                > > > who had been at field day with John Hays when Grant Hopper visited. This
                > > > person repeated some of the stuff that John reported including Grant's
                > > > mentioning that he had been contacted by folks who may be contemplating some
                > > > sort of law suit because of the new band plan adoption. Have you heard
                > > > anything about such a thing?
                > > >
                > > > Peter
                > > >
                > > > ----
                > > >
                > > > Peter,
                > > >
                > > > I have received one (1) email regarding the recent Band Plan revision. I
                > > > will append it and my response, to this email as "Appendix A". I think it
                > > > outlines my view of the issue fairly well.
                > > >
                > > > In April 2011, I made a presentation at Communications Academy about this
                > > > proposal for creating 2-meter narrow-band/digital (NBD) pairs. The proposal
                > > > as presented was almost identical to what was adopted. The Power Point
                > > > presentation was available on the Communications Academy "presentations"
                > > > distribution. The Power Point presentation is also available on the WWARA
                > > > Members Group, in the Files section.
                > > >
                > > > Arguably, Communications Academy is the largest gathering of Amateur Radio
                > > > Emergency Communications (EmComm) leadership in Western Washington.
                > > > Virtually every "main stream" WWa group engaged in EmComm activities has at
                > > > least one member attending that conference each year. I know of no other
                > > > forum where EmComm personnel can be as effectively addressed. My intention
                > > > was specifically to "warn" the EmComm community that adoption of this
                > > > proposal was a real possibility in the near future.
                > > >
                > > > This year, April 2012, I gave a presentation at Communications Academy on
                > > > "Nets". The establishment of a logistics Net is a cornerstone of our Amateur
                > > > EmComm response in most situations. During that presentation I went into
                > > > some detail about looking for "non-standard" simplex frequencies in order to
                > > > avoid crowding on the traditional channels, and stated quite clearly that
                > > > the "traditional channels" were presently being shared by VoIP (EchoLink and
                > > > IRLP) stations and would probably be under pressure for other activities.
                > > > One such activity specifically mentioned was our proposal for 2-meter NBD
                > > > pairs.
                > > >
                > > > I am satisfied this good-faith outreach to the Amateur operators most
                > > > affected by the proposal was well received. As part of these presentations,
                > > > I specifically made a point of inviting any interested Amateurs to join
                > > > WWARA, either as an individual or organization, so they would have voting
                > > > input to the process.
                > > >
                > > > I would like to note that Grant Hopper has not contacted me, either as WWARA
                > > > Chair or as Western Washington SEC, about this matter. I would welcome any
                > > > feedback from him or anyone else.
                > > >
                > > > I am not a lawyer, but frankly, I don't see where any Amateur radio
                > > > individual or group has "standing" to bring a law suit. They would have to
                > > > show that WWARA has caused them "harm".
                > > >
                > > > Part 97.101(b) states: "(b) Each station licensee and each control operator
                > > > must cooperate in selecting transmitting channels and in making the most
                > > > effective use of the amateur service frequencies. No frequency will be
                > > > assigned for the exclusive use of any station."
                > > >
                > > > As far as I can see, "assigned" simplex channels were self-assigned by the
                > > > EmComm entities themselves, in clear contradiction to this passage. It can
                > > > be argued that this same passage promotes our action as part of "…making the
                > > > most effective use of the amateur service frequencies." Holding a group of
                > > > frequencies inactive to be used for EmComm is not effective use.
                > > >
                > > > A repeater owner/licensee clearly has the authority to establish a repeater
                > > > on these new frequencies, as stated in Part 97.205(a) and (b) [here edited
                > > > for brevity, complete text follows as "Appendix B"]: "(a) Any amateur
                > > > station ... may be a repeater…"
                > > >
                > > > "(b) A repeater may receive and retransmit only on the 10 m and shorter
                > > > wavelength frequency bands except the … 144.0-144.5 MHz, 145.5-146.0 MHz, …
                > > > segments."
                > > >
                > > > So, I can't see any "harm" in the legal sense, and can read the Rules in
                > > > such a way that we almost have a mandate to move forward with this. Part
                > > > 97.205( c) which covers coordination, only mentions interference between
                > > > repeaters. Simplex or other modes of operation are not mentioned. It would
                > > > appear to be assumed that simplex stations can move to avoid interference.
                > > >
                > > > I will post this email to the Members' Remailer, as I am sure there is a
                > > > wider interest in this issue. As we move forward with this NBD build-out, I
                > > > hope all of our members participating will be sensitive to the present users
                > > > of these frequencies, and try to minimize their impact as far as
                > > > practicable. While I am confident this WWARA policy change is within the
                > > > scope of our authority, there is no point in causing anyone unnecessary
                > > > grief.
                > > >
                > > > 73, Frank, NM7R
                > > >
                > > >
                > > > -----
                > > >
                > > > "Appendix A"
                > > >
                > > >
                > > > From: <name redacted>
                > > > To: chair@
                > > > Sent: Tuesday, June 12, 2012 3:53 PM
                > > > Subject: Revision to 2m Band Plan
                > > >
                > > > Hi - Frank,
                > > > I have mapped out the proposed changes in the 2 meter band; however, I
                > > > do have some serious concerns about the simplex frequencies being reduced to
                > > > a mere 5% of the band. It looks like there is hardly any room for simple one
                > > > to one contacts or for RACES groups to talk to their teams with out
                > > > interfering with others.
                > > > Could you please clarify the specific frequencies that would be used for
                > > > the repeaters in the simplex area? Would 146.500 & 147.500 MHz still be
                > > > simplex channels?
                > > > I have attached a PDF with the proposed changes highlighted in bright
                > > > yellow. Could you please confirm that this is correct? Changes to the 2m
                > > > simplex will specifically affect some of the following groups: Renton, Red
                > > > Cross, Mercer Island, PSE, Mercury NW, Bellevue, Redmond, Camp Murray, and
                > > > King Co. Search and Rescue as well as other non ARES/RACES groups. If
                > > > 146.5 & 147.5 are included as repeater frequencies, then add the King Co.
                > > > ECC, Shoreline and Vashon Island. In the end all teams will be affected.
                > > > Sincerely,
                > > > <name redacted>
                > > >
                > > > -----
                > > >
                > > > <Reply>
                > > >
                > > > Thank you for contacting me about the recent WWARA policy change affecting
                > > > the lower half of the traditional simplex bands.
                > > >
                > > > You say that the simplex frequencies have been reduced to 5% of the 2-meter
                > > > band. This is not entirely correct. A large percentage of the band is
                > > > potentially available for simplex use. In fact, there is a problem that
                > > > commonly comes up using the traditional simplex frequencies in that every
                > > > jurisdiction is trying to use the same handful of frequencies, causing lots
                > > > of mutual interference.
                > > >
                > > > The only portion of the band specifically excluded by the FCC is 144.0 to
                > > > 144.1 MHz. The rest is available on a not-to-interfere basis. While I know
                > > > that sounds overly simplistic, in any given area of Western Washington
                > > > (WWa), there are repeater output frequencies, input frequencies and
                > > > non-repeater frequencies, not used locally, and therefore available for
                > > > tactical simplex communications. It takes some effort to compile a list, but
                > > > many jurisdictions have done just this. The comments from those who have
                > > > gone through this exercise usually express amazement at how many are
                > > > actually available.
                > > >
                > > > There are 59 repeater output frequencies in the 2-meter band. Certainly not
                > > > all of them are used for "local" repeaters in any given area. As long as the
                > > > signal from your local simplex partner is stronger than that from the
                > > > distant repeater, you can probably use that for local simplex. Using PL
                > > > encode/decode can allow you to not hear the distant machine. The input
                > > > frequency of a distant repeater will also work well. Make sure you are not
                > > > transmitting the PL tone it uses.
                > > >
                > > > There are two areas of the 2-meter band where repeaters are prohibited;
                > > > 144.000 to 144.500, and 145.500 to 146.000. Using 144.300 to 144.500 would
                > > > still allow room for CW and SSB operations. Using 145.500 to 145.800, would
                > > > stay clear of the OSCAR sub-band. This provides 500 kHz (25 channels) of
                > > > potential EmComm FM simplex operating room. And, don't forget the other
                > > > bands we have available, 220- and 440-MHz offer lots of room for simplex
                > > > operations.
                > > >
                > > > Any Amateur radio less than 35-years old is synthesized, and can operate on
                > > > any frequency in the band. Forty years ago, most radios were crystal
                > > > controlled, and an operator might only have 12 channels from which to
                > > > choose. In that environment, a handful of "reserved" simplex channels made
                > > > sense.
                > > >
                > > > Most Emergency Communications (EmComm) today use repeaters, because they
                > > > support longer range and allow better coordination. If a repeater goes off
                > > > the air during an incident, the logical simplex frequency to use is the
                > > > repeater output frequency. It is now available, everyone is listening to it
                > > > already, and if the repeater comes back on the air, everyone will know about
                > > > it. When a repeater is off the air, its input frequency is also available.
                > > >
                > > > In fact, the new, Narrow-Band/Digital (NBD) repeaters that the new channel
                > > > scheme is to serve, are largely owned and sponsored by EmComm organizations.
                > > > Attempting to accommodate them in the traditional (analog FM) repeater
                > > > channel pairs has been unsatisfactory. There are few if any open slots for
                > > > new repeaters in WWa on 2-meters, and there are compatibility issues when
                > > > operating the new NBD and older analog FM in the same environment. WWARA has
                > > > been studying and discussing alternative methods of incorporating these new
                > > > relay devices for 2 years. This is the "least worst" answer.
                > > >
                > > > Note: The Highline Repeater Group was the first to file an application for
                > > > one of these "NBD Pairs".
                > > >
                > > > 73,
                > > > Frank Wolfe, NM7R
                > > > Chair, WWARA
                > > >
                > > >
                > > > -----
                > > > -----
                > > >
                > > > "Appendix B"
                > > >
                > > > Part 97 FCC Regulations excerpts:
                > > >
                > > > §97.101 General standards. -
                > > >
                > > > (a) In all respects not specifically covered by FCC Rules each amateur
                > > > station must be operated in accordance with good engineering and good
                > > > amateur practice.
                > > >
                > > > (b) Each station licensee and each control operator must cooperate in
                > > > selecting transmitting channels and in making the most effective use of the
                > > > amateur service frequencies. No frequency will be assigned for the exclusive
                > > > use of any station.
                > > >
                > > > (c) At all times and on all frequencies, each control operator must give
                > > > priority to stations providing emergency communications, except to stations
                > > > transmitting communications for training drills and tests in RACES.
                > > >
                > > > (d) No amateur operator shall willfully or maliciously interfere with or
                > > > cause interference to any radio communication or signal.
                > > >
                > > >
                > > >
                > > > §97.205 Repeater station. -
                > > >
                > > > (a) Any amateur station licensed to a holder of a Technician, General,
                > > > Advanced or Amateur Extra Class operator license may be a repeater. A holder
                > > > of a Technician, General, Advanced or Amateur Extra Class operator license
                > > > may be the control operator of a repeater, subject to the privileges of the
                > > > class of operator license held.
                > > >
                > > > (b) A repeater may receive and retransmit only on the 10 m and shorter
                > > > wavelength frequency bands except the 28.0-29.5 MHz, 50.0-51.0 MHz,
                > > > 144.0-144.5 MHz, 145.5-146.0 MHz, 222.00-222.15 MHz, 431.0-433.0 MHz and
                > > > 435.0-438.0 MHz segments.
                > > >
                > > > (c) Where the transmissions of a repeater cause harmful interference to
                > > > another repeater, the two station licensees are equally and fully
                > > > responsible for resolving the interference unless the operation of one
                > > > station is recommended by a frequency coordinator and the operation of the
                > > > other station is not. In that case, the licensee of the noncoordinated
                > > > repeater has primary responsibility to resolve the interference.
                > > >
                > > > (d) A repeater may be automatically controlled.
                > > >
                > > > (e) Ancillary functions of a repeater that are available to users on the
                > > > input channel are not considered remotely controlled functions of the
                > > > station. Limiting the use of a repeater to only certain user stations is
                > > > permissible.
                > > >
                > > > (f) [Reserved]
                > > >
                > > > (g) The control operator of a repeater that retransmits inadvertently
                > > > communications that violate the rules in this Part is not accountable for
                > > > the violative communications.
                > > >
                > > > (h) The provisions of this paragraph do not apply to repeaters that transmit
                > > > on the 1.2 cm or shorter wavelength bands. Before establishing a repeater
                > > > within 16 km (10 miles) of the Arecibo Observatory or before changing the
                > > > transmitting frequency, transmitter power, antenna height or directivity of
                > > > an existing repeater, the station licensee must give written notification
                > > > thereof to the Interference Office, Arecibo Observatory, HC3 Box 53995,
                > > > Arecibo, Puerto Rico 00612, in writing or electronically, of the technical
                > > > parameters of the proposal. Licensees who choose to transmit information
                > > > electronically should e-mail to: prcz@
                > > >
                > > > <end>
                > > >
                > > >
                > > >
                > > >
                > > >
                > > > ------------------------------------
                > > >
                > > > Yahoo! Groups Links
                > > >
                > >
                >
              • NM7R
                Mike, The decision taken by the WWARA membership was to change our Band Plan. The WWARA Band Plan already differed significantly from the ARRL Band Plan, as do
                Message 7 of 10 , Aug 4, 2012
                  Mike,

                  The decision taken by the WWARA membership was to change our Band Plan. The WWARA Band Plan already differed significantly from the ARRL Band Plan, as do the band plans of virtually every other coordinator in one way or another. I would hope that WWARA members would have referred inquiries to OUR band plan and not ARRL's.

                  Yes, the vote was unannounced. According to our Bylaws, which govern the operation of our organization, this was perfectly acceptable. We can argue all day about how fair or unfair the action was, but the bottom line is, a motion was brought from the floor, and our Bylaws require us to act on it. So we did. The officers of WWARA are required, by the Bylaws, to follow the will of the membership. The vote was to change our Band Plan.

                  I would have preferred it were announced ahead of time, to as many spectrum users as possible, but in what arena would you suggest this have been done? As far as I know there is no "Simplex group" to contact. As ARES Section Emergency Coordinator, I see a lot of simplex use by those involved in Emergency Communications (EmComm). They have already had problems trying to run numerous diverse simplex operations on the handful of reserved frequencies. I have encouraged them to look for other frequencies they can use instead, and this has turned out successfully.

                  I made two presentations, a year apart, that discussed this and the possibility of "invasion" of the simplex bands. I received comments of interest, but nothing strongly against it. I did receive several comments remarking on how plentiful potential simplex channels are in any given region once you go looking for them.

                  It is my observation that EmComm is one of the larger periodic users of simplex, and Communications Academy is the largest conference of these folks in WWa. In addition, most major clubs have a member attend the Academy, and information gets back to a large portion of the organized Amateur community. What other simplex groups should have been targeted?

                  Your assertion that the use of simplex on repeater frequencies is "new" is incorrect. In the days of crystal control, pre-1980's, it was common to use 146.940 and/or 146.760 simplex. These were the two most common repeater output frequencies, and they could be used simplex by buying only one additional crystal each. In fact the use of these two simplex frequencies was far more popular than 146.52 in many places. Going back at least as long, the general concept of using simplex-on-the-output in case of repeater failure has been a part of most EmComm training programs.

                  You are the one who keeps talking about all the "unused" repeaters that "sit silent" most of the time. Why not use those frequencies for simplex? Simplex contacts tend to be transient, short range and flexible. If the frequency is chosen well, if a repeater comes up, the simplex signal will cover it satisfactorily. They can easily adapt to a stronger repeater coming up by moving to another spot. Instead, you seem to be advocating for reserving a block of simplex frequencies, which also sit idle much of the time, but are not to be put to any other use.

                  Far from a "land grab", these have been "repeater frequencies" for a long time. Would you have fought so hard against the "land-grab" of the 147's, or the 145's? Originally, repeaters were only allowed between 146-147. What we are doing is nothing new. A case could be made that simplex users have already lost almost 2-MHz to repeaters.

                  Technically, as the rules presently exist, a simplex station and a repeater have equal right to operate on a given frequency. All frequencies are shared and no one, not even a coordinated repeater owner, has an exclusive right to operate. No one, not even a coordinated repeater owner, has any more right on a given frequency than any other licensee. This applies to 146.94 as well as 146.44. Just because you have a "lunch hour group" that has always met on 146.46, "for years", doesn't mean that you have a right to boot me off if I happen to be holding a QSO when you come up for your net. First-come, first-served. In fact, according to Part 97, in the strictest reading, yes, we do have an obligation not to key up a repeater on top of an on-going simplex conversation. That has always been there. We are also supposed to ensure no one is operating on the input before keying up on top of them, as well. How quickly we take our operating "normal" for "legal". And how many of us drive a few miles an hour over the posted limit?

                  I suggest, we stop debating as to how "fair" or "morally correct" this is, and we all do our best to make this work. That means the repeater operators on these 10 new pairs should adopt a bit of humility. Try as far as possible to minimize impact until everyone gets used to the change.

                  As far as WWARA is concerned, this change was moved-seconded-passed, in a regular business meeting, by a majority of those members present. I would have preferred a unanimous vote, but the Bylaws give the Chair no authority to require one. I would have preferred more members to have been present. We only have 4 meetings a year. I realize not everyone can make every meeting. It is certainly not easy for me to attend. But all should realize that if you don't attend a meeting, and you don't assign a proxy, then you won't be part of the decision. But the decision, once made, is still binding on the organization.

                  73, Frank Wolfe, NM7R
                  Chair, WWARA



                  --- In WWARA-Members@yahoogroups.com, "pingster74" <2mband@...> wrote:
                  >
                  > I think it is in order to say this vote was unfair. The decision was made by members present of a group that only stood to benefit from the outcome. To say the simplex users by default opted out because they didn't participate in an unannounced vote by a special interest group that requires membership as a basis to vote is ludicrous. In other words they were "squelched." Why would someone not interested in repeaters even come to a WWARA meeting?
                  >
                  > Hams generally respected the ARRL band plan aka "gentleman's agreement" and have mostly stayed out of the repeater sub-band preventing interference complaints, now recently it has been encouraged to operate simplex in the repeater band as a concession to a "land grab" of simplex frequencies. Previously if a simplex user was to use a repeater input/output and it caused interference to the repeater then we could educate the simplex users and suggest that they check the ARRL band plan for a better choice of frequencies. Are we expected to now entertain interference complaints from repeater owners on the new repeater frequencies? FCC rules only address interference issues between repeaters and who is responsible for the resolution, otherwise a simplex user is on the same playing ground as a repeater. As I see it, if there is an ongoing conversation on the output of one of the new repeater frequencies the new repeater will have to refrain from keying up until the simplex users are finished otherwise it is considered interference. Another probable situation could be that a group of simplex users have a strong signal on the input of one of the new repeater frequencies rendering the repeater useless on occasion. There is no requirement for them to move simply because they have a VFO they have equal right to tell the repeater to move.
                  >
                  >
                • Steve VanWambeck
                  Frank, It is just this sort of thing that really keeps me from wanting to get to involved in doing the 440 Band Chair assistant thing. Part of me would be
                  Message 8 of 10 , Aug 4, 2012
                    Frank,
                    It is just this sort of thing that really keeps me from wanting to get to involved in doing the 440 Band Chair assistant thing.  Part of me would be interested but I am not really sure I want to get all wrapped up in the controversy.  I haven’t seen any communications between you and W7UDI concerning the proposal so I am not sure how he feels about it either.
                     
                    73 de N9VW, Steve
                  • Steve
                    Steve, The change in the 440 band did not involve displacing any current users. All the simplex frequencies within the 440 band stayed the same. What was done
                    Message 9 of 10 , Aug 4, 2012

                      Steve,

                       

                      The change in the 440 band did not involve displacing any current users. All the simplex frequencies within the 440 band stayed the same. What was done was to change the channel spacing from 25Khz to 12.5Khz. The normal 25Khz channel to be the standard 16F3 analog, and the 12.5Khz for 11F3 for narrowband type operations.  The issue at hand is with the two meter band plan. Below Frank addressed the 440 band plan and the Two Meter band plan in a note dated 7-27-12.

                       

                      In June I made some comments in regards to the Two Meter TX/RX, high/low issue. Do we need to go over the 440 band plan? Is there a issue that I don't know or see. I was unable to attend the June meeting. So I was not present. The membership voted, and I will perform my duties as directed with the band plan change.

                       

                       

                       

                      Mike has raised several good points.

                       

                      We have been discussing this issue (accommodating Narrow-Band/Digital (NBD), D-Star and similar) for more than two years. During that time, the 440 Band Chair has enlisted the help of several applicants to give "splinter" operation a try. This solution to the accommodation problem, in the context of our existing 440 Band Plan seems to be a good one. It provides a home for some NBD machines without dislocating or compromising the existing users. But once the NBD systems had shown this scheme to work satisfactorily, our Band Plan didn't allow for them to be coordinated, leaving them in a permanent state of "Pending".

                       

                      I felt it only fair to request a motion that we amend our Band Plan to allow for the inclusion of these repeaters under our coordination policy. This recognizes not only the success of Steve Szombathy's, W7UDI, initiative and effort, but the willingness of the few pioneers to spend the extra time and dollars to give this a try, with no guarantee that they would be able to continue to operate. I want to thank Steve for carrying this forward, and the pioneers for their willingness to participate.

                       

                      The 70-cm band is different in several ways from the 2-meter band, and this "splinter" scheme will not work on 2-meters, due to the closer spacing of the existing repeaters, and to some extent also to the heavier loading of the band.

                       

                      Several plans for accommodation of NBD machines on 2-meters have been put forward. Only one met the twin criteria of (1) not dislocating or compromising existing coordinations, and (2) providing a home for a significant number of repeaters. Why are these points important? Let me digress a moment to look at the legal side.

                       

                       

                      The FCC doesn't recognize or "license" coordinators. They do mention them in Part 97 as "recommending" a particular frequency for a particular repeater. The reason for this is that the Amateur Radio Service is built upon the foundation of the individual Operator/Station License. The only license necessary to establish an Amateur station is the one you carry in your pocket, and that station may be a repeater. The authority to operate a repeater rests with the individual Amateur licensee, as a co-equal with all other licensees.

                       

                      If an individual Amateur licensee decides to set up a repeater, he or she has the authority to do so. The WWARA has no authority to prohibit, or in fact to authorize this. The authority rests entirely with the individual Amateur licensee. The function of WWARA is advisory in nature. In essence, we are a forum in which Amateurs may choose to participate, towards the goal of minimizing mutual interference between systems. This is in everyone's best interest, because all licensees have an obligation to minimize interference under all circumstances.

                       

                      We can argue about what a coordinator may and may not do, but the bottom line is, the authority to coordinate is an extension of the collective authority of the members' licenses. We are in effect, pooling our individual authorities to operate, and meeting as equal partners in the enterprise of coordination. WWARA has only the authority it is granted by the members.

                       

                      We have established By-laws, Policies and Band Plans, all approved in open meetings. To say that it is unfair to follow these by making a decision based on a motion from the floor, with a vote of the members present is out of order. This is basic Democracy in action. If this is not the way business should be conducted, then change the rules. Those who, for whatever reason, choose not to participate have implicitly "oped out" of the decisions.

                       

                      The plan adopted to accommodate 2-meter NBD repeaters had been around for 2-years. It had been discussed on a number of occasions. I did an outreach to EmComm folks, because I have the ability to do that and they are heavy simplex users. I had not anticipated this would be brought up at the meeting, but once it had, as Chair, I saw no choice but to allow it on the floor. We are a member-driven organization, and such action is clearly spelled out in the By-laws. The Chair is charged with following the will of the membership.

                       

                       

                      We have a large "installed base" of conventional 2-meter analog repeaters and a vast constellation of compatible user equipment in Western Washington. Over decades, this has all been built and coordinated according to our existing Band Plan. When the rest of the country changed from 30-kHz spacing to 15-kHz spacing on 2-meters, we in the Northwest adopted 20-kHz spacing instead. This has proven to be the better choice. Watching the struggles of 15-kHz operations in California, with its requirement for geographic separation, inverted pairs, and other methods to overcome the signal overlap is enough to make a prudent coordinator want to run the other way. The 20-kHz choice was the better option.

                       

                      Having gone down the 20 kHz road, should we now decide to shift to a 15-kHz (or some other) scheme for our existing analog repeaters, a few things will happen. First, nearly every one of these will have to change frequency. Because we have never had to do a lot of "geographic separation", and now will have given up the guard bands, just cramming everything closer together won't work in many cases.

                       

                      Think of it this way; I have a parking lot, striped at 6.5 foot intervals. All cars are 6-feet wide. I now re-stripe the lot at 5.5-feet. Will I be able to park more cars? Will all the original cars still fit in the lot?

                       

                      That means nearly everyone will have to change frequency. Some won't work any more on the closest new pair and will have to find a new pair "geographically separated" from the newly interfering neighbor. Some may not be able to find an acceptable spot at all. While this hunt for a new home is on, on a large scale, all the other repeaters will be moving, in a giant game of "musical chairs". So this problem becomes many times more difficult than it would at first appear.

                       

                      Second problem, our neighbors, BC and OR would not necessarily be keen on following our lead. In the "border areas", the interference issues would be compounded. Our Band Plan and theirs would no longer line up, and we aren't talking about the overlap area being the crest of the Siskiyou Mountains or sparsely populated southeastern-Oregon/northeastern-California. No the overlap would be much of Puget Sound and southern BC. If you want good neighbors, you have to be a good neighbor.

                       

                      The third, and I think biggest problem, grows out of the authority issue we talked about above. WWARA has no authority to "order" a repeater to move. This wholesale relocation of nearly every 2-meter repeater in Western Washington would have to be VOLUNTARY. In the case where a particular repeater owner refused to move, and was de-coordinated because of it, when another repeater began interfering with their operation, they minght have good grounds, in my (not a lawyer) opinion, for legal action.

                       

                      The last time this was done was in the late 1970's/early 1980's. We moved from 30-kHz spacing to 20-kHz spacing. It took 5-years for everyone to agree to move, and 10-years before the last system had actually accomplished the move. There were far fewer than half the number of repeaters, and everyone got a new pair with no interference.

                       

                      In this case, as soon as one repeater moved, it would be interfering with its neighbors, and the interference would not end until the last machine was settled on its new pair. Numbers on a spreadsheet look neat and clean, but reality is far messier. I have yet to see anything like a real-world plan on how to get from what we have, to any other scheme.

                       

                      So, as I see it, any plan that requires moving a lot of repeaters around, especially one involving changing to 15-kHz spacing is a bad idea. One day, the conventional 5-kHz deviation repeater will be a thing of the past, but for now, the vast majority of our infrastructure is built on these and we need to protect them.

                       

                       

                      As for the large number of "unused" repeaters, that is the nature of the beast, and has always been so. Thirty or forty years ago, there were fewer repeaters, and no cell phones. For many, 2-meter repeaters were THE way they kept in touch. Even then, most repeaters sat idle most of the time. Times change. Our repeater infrastructure is less used now, and there are more repeaters than before. We could certainly pack them a little more tightly if we wanted to. That would be a matter of advocacy on the part of the Band Chairs, "selling" it to the membership, and a higher threshold of tolerance for neighboring signals.

                       

                      Our Policies do not address "usage" or "desirability" of repeaters as a criteria upon which they can be evaluated. WWARA leaves the issues of desirability or necessity up to the repeater owner. That is probably where they should rest. Remembering that the authority to coordinate originates with the licensees, who better to make this determination than the person who is footing the bill. We have the authority to not hold coordinations for "paper repeaters" that are not actually on the air.

                       

                      The idea that large areas of the repeater spectrum are "unused" much of the time begs the question, why would we then hold another portion of the spectrum "unused" much of the time on the off chance someone would want to use it for simplex contacts? Sure, 146.52 should remain open as a calling frequency, but once a contact has been made, why not move off to one of the large number of "unused" repeater frequencies to carry on the QSO?

                       

                      73,

                       

                      Frank Wolfe, NM7R

                      Chair WWARA

                       

                      Hope this helps.

                       

                      73

                      Steve

                      W7UDI

                       

                       

                      From: Steve VanWambeck [mailto:steve@...]
                      Sent: Saturday, August 04, 2012 8:57 PM
                      To: WWARA-Members@yahoogroups.com
                      Subject: Re: [WWARA-Members] Re: comments on band plan changes?

                       




                      Frank,

                      It is just this sort of thing that really keeps me from wanting to get to involved in doing the 440 Band Chair assistant thing.  Part of me would be interested but I am not really sure I want to get all wrapped up in the controversy.  I haven’t seen any communications between you and W7UDI concerning the proposal so I am not sure how he feels about it either.

                       

                      73 de N9VW, Steve




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