In describing the ARS as it existed fifty years ago, the Curmudgeon does not intend to suggest that ego and competition were totally absent from it, even then.  There were regularly scheduled on-air operating contests, there were always a few individuals who could afford to purchase new “Cadillac-grade,” i.e., Collins Radio ham gear (although the average operator’s purchasing budget for his station in those days, calculated in constant-value dollars, was significantly smaller than it is today), and there were certainly individual hams of legendary renown in the Service then.  But all of this occurred within a well-established, larger community context of generally cooperative effort and of work by individuals toward personal self-improvement.

An illustrative, really more of an exemplary example of that period was the late Don Wallace, W6AM.  While the Curmudgeon did not know Wallace personally, no one who did would have ever suggested that Wallace was an excessively humble and modest man.  In his time he developed a very technologically-advanced and truly unrivaled Amateur station and he used it to make hundreds of thousands of contacts with hams in every distant part of the world, to the considerable envy of many other hams.  But Wallace was an excellent on-air operator, he had made very significant technical achievements in which to take pride, he contributed new knowledge to the ARS, and he was well-liked by his fellow hams in return.  This is not necessarily the case with today’s radio “studs.”

QSL card and book about pioneering amateur operator W6AM

Nor was every well-known ham of that era as outgoing as Wallace.  While the Curmudgeon was still a new ham he was privileged to meet the late John Chambers, W6NLZ, the Amateur who made the first series of terrestrial, entirely over-water, direct VHF/UHF radio contacts between the U.S.’s west coast and Hawaii.  And despite his (well-earned) fame and high degree of technical skill, Chambers was an eminently approachable and very helpful ham.  So although it certainly existed in those days, operator ego was not especially dominant in the Service.

Thus it’s not the existence of ego itself which has changed the ARS over the past half-century.  It’s the ascendency of operator ego and its offspring, “uber-competitiveness,” as a principal organizing force that has transformed the Service.  This characteristic, along with weaker technical backgrounds and “consumerism,” certainly doesn’t animate every single one of today’s ARS licensees, rather just too many of them.  These ego-driven operators seemingly have now become the on-air majority, leaving the remaining thoughtful, considerate, and helpful operators in the minority.  Perhaps, given the stridency and shrillness which have overtaken the contemporary national culture, this change in the Service was foreordained.  Today’s overall national culture, like entropy itself, “just isn’t what it used to be!”

Lunar DX on 144 Mc! - W4AO and W3GKP Bounce 2-Meter Signals Off the Moon in 1953

And where might these current trends take the ARS in future years?  That’s a very difficult question, but one well worth pondering.  One could propose a Yogi Berra style of answer: “The future will be much like the present, only more so!”  But Professor Berra might just have a point there: in the absence of an external force, things tend to keep moving on a straight-ahead path (and a tip of the hat to Professor Newton for that principle!).  And “straight-ahead” for the ARS would mean a less-knowledgeable, more “consumerized,” and more ego-driven Service.

The “less-knowledgeable” ARS operator trend parallels the general state of technical education in the US; it would be difficult to envision Amateurs as a group becoming more technically informed about their field without the entire society’s taking a considerably more serious approach to mathematics, science, and engineering education.  “More consumerized” also follows the emerging cultural norms of the general national society which, in the Curmudgeon’s previously-expressed opinion, “is besotted by consumer electronics.”  And even within that area the ARS must operate with a handicap: it alone among all other consumer electronics pastimes still does require a demonstration of the entrant’s basic qualifications, through written examinations.  This, of course, is wholly at variance with the “instant gratification” ethic which underlies most consumer electronics!

The uber-ego is the most troubling future trend.  It could well lead to a long-term debasing of the overall quality of operators within the Service, in a kind of parallel to Gresham’s Law of money: all other things being kept equal, the “bad operators” may systematically drive out the “good operators.”  Older licensees with knowledge and experience (skills that they presumably could share with the larger community) may discontinue operating and leave the air when they perceive that their efforts have been overwhelmed.  Eventually time will claim them all.

Perhaps the most difficult aspect of all to ponder is the identification of a possible future “external force” that might deflect the current ARS path and provide some incentive for improvement of the Service and its operators.  Such a force could come in the form of a significant external threat to the ARS, such as a well-organized and well-funded attempt to de-allocate entire frequency bands from Amateur use, or a significant threat to the nation as a whole, such as from terrorism.

Or such a force, in a positive sense, might be unforeseen technological developments which would provide Amateurs with far more communications capabilities than they currently have and would foster a challenge to put the new capacities to good practical use.  Out of these possibilities might arise a reinvigorated purpose and mission for the ARS, with its operators then refocused on more than just contests and equipment purchasing.  All roads are possible, none are certain, and the old Curmudgeon regrets only that he may not have enough remaining time to see the ultimate outcome.

Finally, let’s make a summarization to this retrospective (and partially prospective) look at the ARS.  Yes, today’s Amateurs can do hugely more than their predecessors could do fifty-years ago, given the exponentially more sophisticated technology now available.  Yes, there still is much good work for today’s Amateurs to do: experimentation and innovation, emergency communications, international good will, etc.  Yes, there are still some good, cooperative, helpful Amateurs on the air.

But the majority of the ARS “brotherhood” of today is more obstreperous, more competitive (even when cooperation would work equally as well), and just generally less accommodating than it was in former days.  Even given this situation, the Curmudgeon most emphatically does NOT assert that the current ARS is either completely evil or totally worthless, but rather that today’s ARS culture is not all that it once was or could (and should!) again be.  The ARS culture of the 1950s-60s was certainly not Nirvana, but it was a distinct improvement over todays.

The ARS is not going to spontaneously and unilaterally change, and the Curmudgeon by himself can’t rebuild what has been torn down.  In the dumbed-down, consumerized, and ego-driven ARS of today, much of the camaraderie, the shared sense of community, the joys of cooperation and of self-discovery that once existed have now mostly passed.  Older hams feel this loss; younger hams will never know and experience what is now gone.  And the Service is the poorer for it.

What do you think?

“Let’s keep the universe safe for RF!”

The Old RF Curmudgeon

cimlay@sbe.org

This isn’t really news.  President Obama signed a Presidential Memorandum on June 8, 2010 entitled Unleashing the Wireless Broadband Revolution.  This committed the federal government to find an available 500 MHz of federal and commercial spectrum over the next 10 years for reallocation to broadband.  The President said that this spectrum will foster investment, economic growth and help create hundreds of thousands of jobs by meeting the “burgeoning demand” for mobile and fixed broadband, other “high-value uses” and benefits for other industries.  Currently, wireless companies have about 534 megahertz allotted to them.  That number will double in the next ten years, apparently.

The FCC’s National Broadband Plan released earlier this year recommended of course the exact same thing.  Of the 500 MHz to be harvested and reallocated to broadband, 300 megahertz must be between 225 MHz and 3.7 GHz for mobile use within five years.  In my last column, I described this as an element of the “Perfect Storm” for the TV broadcast bands.  Since then, the FCC has proposed to revise the rules for Wireless Communications Service (WCS) bands at 2305-2320 and 2345-2360 MHz so that 25 megahertz of that spectrum will be available for mobile use.  The FCC has also already held their controversial “Broadcast Engineering Forum” on June 25, 2010, which explored the cellularization of broadcast architecture; the use of distributed antenna systems, methods for repacking the TV band, “improvements” in VHF reception; and advancements in compression technology.  Cynics among us would suggest that this move on FCC’s part was simply to develop a record that will allow it to do what the Broadband Plan has already established as a goal:  the reallocation of 120 MHz of television core channel spectrum for broadband according to the plan.  So, the bandwagon is picking up speed and everyone, including President Obama, is jumping on.  Having that happen is like adding a supercharger to the bandwagon.  It is soon going to be going too fast to be under control.

I have always thought that spectrum planning should be a lot like land use planning.  Cities and counties have a master plan, developed after hearings and a lot of public input.  It is supposed to be good for a long period of time, because it represents the broad goals the residents and the local government want to achieve, and it paints a “picture” (a big one) of what collectively the people want the city or county to look like twenty years or so later.  Then, after developing, refining, honing and adopting the master plan, you make individual zoning decisions about individual parcels of land that are consistent with and which further that master plan.  Spectrum allocations should be like that as well, I think.  Individual spectrum allocations decisions should be based on a master plan, which paints a “big picture” of spectrum use ten or twenty years hence.  Internationally, that is kind of how it works.  Domestically, well, not so much.

FCC doesn’t have a domestic master plan.  The National Broadband Plan is not a master plan.  It is surely enough a component of a master plan, but only one component.  What we are left to ponder is what the rest of the spectrum landscape is going to look like when the National Broadband Plan is effectuated.  What will traditional, over-the-air broadcast television look like?  We don’t know, because that is not part of the plan.  We thought we knew, since the DTV conversion was a partial spectrum plan as well.  But that partial master plan didn’t last long.  What will private land mobile radio look like?  Broadcast auxiliary and microwave allocations used for video production?  Amateur radio?  We aren’t given that vision by the FCC, and we aren’t being asked to help shape it.  We don’t know what the consequences of the reallocation of the 500 megahertz for broadband will be on the rest of the landscape, partially because we don’t know what the architects of the National Broadband Plan intended for the residual landscape to be after the reallocation, or even whether that mattered to them.  All we are asked to do is to comment on what the effect will be of individual actions taken pursuant to the partial plan favored today, which has a single focus.  We are asked to react, not proact.  it is difficult not to become cynical in a purely reactive spectrum planning environment.

Perhaps the free market model (i.e. no master plan) for spectrum allocations is being relied on here, in which case what television broadcasting and other incumbent radio services look like post-broadband reallocation is whatever the market values most highly.  That indeed seems to be the explanation.  White House officials said the reallocation of spectrum would be voluntary, employing tools such as proceeds of spectrum auctions to compensate those who agree to relinquish their “unused or under-used” spectrum.

Indeed, money seems to be a large underpinning of the National Broadband Plan.  According to the Fact Sheet distributed by the White House about the Memorandum:  “The Administration has no official estimate of the auction revenues from this plan.  The actual amount will depend on effective implementation and additional design details, but based on past auctions, many analysts believe the revenue potential could reach in the tens of billions of dollars.  The proceeds would be invested in public safety, additional job-creating infrastructure investments and deficit reduction.”

But it is overly simplistic, and perhaps overly cynical to think that this is just crass commercialism at work here.  The Presidential Memorandum also recommends that “[t]he FCC, within the next 10 years, should free up a new, contiguous nationwide band for unlicensed use.”  This would provide “new opportunities for innovation through free, unlicensed use of spectrum by technology startups, individual users, and others.”  Furthermore, auction revenues will allow additional investment in public safety and infrastructure that “a critical part of this spectrum initiative” will be to provide funding to help build a nationwide interoperable mobile broadband network for public safety, which would include ‘next generation’ technologies.

The White House praised FCC Chairman Genachowski and his team, who put together the National Broadband Plan.  But that is the problem.  The plan was put together behind closed doors and it is not a comprehensive master plan that addresses the effect of its success on incumbents:  the workhorse services that are potentially profoundly affected by the success of the Plan.  Now, according to the Memorandum, the government is “pursuing a separate fast-track process to identify a down payment of specific bands of spectrum that could be freed up.”

Whatever the model, the National Broadband Plan looks a lot like a bandwagon that is being jumped on by everyone in Washington, regardless of political party, and regardless of the effect of the reallocation of spectrum (the volume of which has already been decided as a matter of policy), on incumbent services.  The bandwagon has no brakes, folks, and it is picking up speed.  The sad part is that we can’t really get out of the way.

by Cris Imlay

SBE General Counsel

LBA is a sustaining SBE member and proves a variety of services and equipment for the broadcast industry.

This other change, the Curmudgeon suggests, is the ascendency of ARS operators’ ego as a principal organizing force. It has changed the Service during the past half-century, and not for the better.  There are several ways in which this trend manifests itself today.

The first way, and perhaps the hardest one to describe, is simply on-air courtesy among operators.  Basic operating courtesy, over the fifty year period, seems to be a diminishing quality.  This is seen most readily in the “use of the frequency” area.  Unlike all other licensed radio services, the FCC does not assign Amateurs fixed frequencies on which to operate.  By virtue of the Rules, each operator can use any frequency (as long as it is authorized to him by his individual grade of license) among the thousands of frequencies contained in a given ARS band.  There is no long-term primacy of frequency use accorded to any individual or group (there are some voluntary frequency reservations, however).  And so at any point in time the use of any individual frequency depends on cooperation and coordination among all those who would like to use it.

Generally the individual who first operates on a previously unused frequency is considered by most operators to be the one who controls it, for however long (within reason!) he wishes.  Fifty years ago it was very rare for one operator to deliberately “invade” someone else’s frequency-in-use.  In that era if someone did accidentally access an active frequency and was then notified of the fact, his typical response was to apologize and then quickly to move to an unused frequency.  Today, in too many instances (often during contests, see below) and especially if competition is involved, an invading operator may decide just to ignore the established operator and to force his way onto the frequency.  If the invader is utilizing high transmitter power and large antennas (see below), he and his dominating signal can very well drive the established operator out.

Second, compared to a half-century ago, the Amateur Radio Service has many more, as well as more frequent, competitive on-air operating “contests.” The stated goal of the contests is to make on-air contact with as many different stations in as many different (pre-specified) land locations as is possible during the published contest operating hours, and the winner is the operator who makes the most contacts.  However each contact is fleeting (perhaps ten seconds in length), human interactions are minimal and nothing new is learned from the contact.  When contests occur, large portions of some frequency bands may be taken over for the event, and those operators who have no interest in competing may be driven, in whole or in part, from those portions.

The ultimate ham contester’s antenna!

And what is gained from these frequent contests?  Their major function seems to be to bolster the egos of those who choose to compete in them.  The specialized skills that are developed through participation in contests, in the Curmudgeon’s opinion, are not particularly useful for or transferrable to broader communications contexts!  There is little recognized need in the general telecommunications universe for skilled human operators who have been trained to make large numbers of short, rapid contacts with random network nodes, each of which contact produces almost no useful information!

Long hours of intense on-air competition are rewarded solely with ego-stroking and paper certificates; this is almost entirely “competition for competition’s sake.”  To satisfy increasing operator ego, contests beget both more contests and more “wallpaper” certificates, and truly cooperative work among ARS operators continues to decrease.  Historically the ARS has always sponsored a basic roster of contests, but it is the relative increase in their numbers and the consequent increased attention and resources focused upon them which have shifted greatly during the past half century.

Third, the increases in levels of ARS RF transmitting power during the past half century also give testament to the rise of operator ego.  At the beginning of the period most Amateur transmitters (then, of course, vacuum tube designs) provided at most 100 watts, and often less, of “transmitting power” for the High Frequency (“shortwave”) ARS bands.  At the end of the period the equivalent solid-state transmitters provide a minimum of 100 watts, and often more.  But even this is not an accurate comparison.  The former 100 watts figure was for d.c. power to the final amplifier stage, with the actual RF output from the transmitter being less, perhaps 65 watts.  The 100 watt figure for today’s equipment is for RF output power.  Thus there has been a subtle escalation even in basic power levels.

Today’s US ARS licensees are allowed by FCC Rules to use up to 1500 watts of “peak RF output power” for their stations.  The equivalent figure for most of the rest of the world is considerably lower, often around 400 watts maximum.  And today’s operators have abundant access to commercially-manufactured high power RF amplifiers, some of which can provide the 1500 watts of output power (and more), as well as to commercially-manufactured large antennas to boost transmitted “effective radiated power” levels by additional factors of from 2 to 10 times.  These “power-booster” items were much less available and less often used in 1960.  Thus increasing licensee ego has been paralleled by increasing operating power levels, and vice versa.

Fourth, operator ego has asserted itself even in the area of station call signs.  Fifty years ago the FCC had a systematic program of issuing Amateur station call signs when new operators first qualified for licenses.  The call signs were assigned in a strict alphabetical sequence, with each new operator receiving the next incremental call sign.   Thus the most-recently issued call sign in a region might be W8ABB, with the next one to be issued being W8ABC.

The practice was fair, uniform, and informative; a call sign would convey both information about the geographical region within which its authorized station was located and some rough indication of the time period during which the license was first issued.  And a call sign, once obtained, would generally remain with an operator for life and would become his personal identification among other operators.  An operator might be “Jim” to his business associates and family, but he would be forever known to his ham buddies as “GJF” or the “giant jumping frog” (from W8GJF)!

Today, an Amateur can select and purchase the “call sign of his choice” from the FCC, and then change it at will.  And this ego-driven practice has resulted in “instant gratification” situations in which a new operator with perhaps just half a year’s experience purchases one from an historic format of Amateur call signs, of the kind identified with those operators first licensed fifty to seventy five years ago.  Most call signs are now “prestige” to suit their owner’s ego, and they no longer convey any meaning or significance.

Fifth, there is the increased use of inappropriate and inflammatory language on the air.  Half a century ago almost all Amateur operators maintained voluntary “standards of conduct” about language and content to be transmitted on the air.   (This practice in today’s freewheeling society might now be labeled “internal censorship.”)  Most operators then well understood that their transmissions could easily be monitored and identified by the general public as well as by the FCC, and they did not wish to jeopardize their license privileges.  The on-air use of profanity and obscenity, as they were then commonly recognized, was almost non-existent, and certain potentially inflammatory topics, such as religion and politics, were routinely avoided.

Today, with more lax societal standards, the old “taboos” are largely gone.  Individual operators’ egos seemingly can now be directly modulated onto their radio carriers, and too many licensees consciously operate to proclaim to the world, directly or indirectly, that they are “the biggest damn stud on the air!”  The level of language that is more typically heard in athletic locker rooms and saloons now goes out over the air in complacent disregard of whoever might inadvertently receive the transmission.  And highly-biased and inflammatory political, racial, or gender slurs emanate daily from a minority of organized groups, making some Amateur bands all but unusable at times.

Sixth, deliberate, willful jamming of operational stations, not totally unknown fifty years ago, has also increased considerably today.  Especially distressing is the willful interference to long-established disaster nets carrying well-identified emergency traffic.

All of these trends have increased since the beginning of the 1960s.  They are driven primarily by operator ego, which itself seemingly has become an on-air contestable quality.  The negative trends are making ARS on-air operations increasingly less appealing and the Amateur bands less hospitable.   Kind, thoughtful, and considerate Amateur licensees do still operate on-air, but the long term outlook is not encouraging.

Next time we will conclude the series with a summary look at where the ARS has been and where it might be going.

What do you think?

“Let’s keep the universe safe for RF!”

The Old RF Curmudgeon

Zombie Satellite Galaxy 15

We reported in a previous post on the zombie satellite Galaxy 15 that went rogue on April 5th about the potential interference this “zombie satellite” could cause, at the time with AMC 11.

This time, roughly 35,000 people in rural Alaska may experience problems caused by the zombie satellite.  They may lose Internet access, long-distance phone service or both for periods of 90 minutes to as long as 5.5 hours between Wednesday August 11th and Saturday August 14th. “Almost every single person out in rural Alaska uses one of those services somehow,” said General Communications Inc. (GCI) spokesman David Morris.  In an effort to warn people in nearly 100 communities of the problems that could occur while it still has a signal, GCI is airing radio ads, posting fliers and hopes to send text messages to cell phone customers.

GCI estimates that 4,000 residential customers, about 1,000 businesses, 78 village clinics and 49 schools could lose Internet access.  As it stands, neither ATMs nor credit card processors will work. GCI is unsure if the zombie satellite will affect 911 service in the affected areas.

The estimated outages are:

Wednesday: 7 to 8:30 a.m.; 6 to 10 p.m.

Thursday: 6 to 10:30 a.m.; 5 to 10:30 p.m.

Friday: 5 to 10 a.m.; 5:30 to 9:30 p.m.

Saturday: 5 to 9:30 a.m.

Chris Horne

Read the full story:

Christopher K. Horne returns to LBA Group as new chief technical officer

Prompted by these two events, the Curmudgeon took a nostalgic look back at the changes in the Service (within the United States) over the past half-century and more.  And the following three posts are the result.  This series is a thoughtful reflection from someone who has “lived it!” and who has been on the air continuously (though not necessarily daily) for all that time.  These very personal views will probably not reflect the thoughts of, and may not necessarily please, today’s recently-minted hams who don’t have this length of background.  YMMV!

The conclusions from this review can be summarized as:  “Today’s ARS is certainly not your Grandpa’s ARS.  But in comparison with today’s, Grandpa’s was arguably more interesting, more personally rewarding, and perhaps a better experience, overall!”

Predictably, five decades have brought an enormous amount of change to the ARS.  The communications technology in routine use today would have been barely recognizable in 1960.  But technology is neutral, and in the Curmudgeon’s opinion it’s within the sociology of the ARS that much has been lost.  Today’s disturbing negative trends affecting the Service lie within two general areas:  “The Dumbing-down and Consumerization of the ARS” and “The Ascendency of ARS Licensee Ego as a Principal Organizing Force.”  We’ll look at the first trend in this post, the second trend in the following piece, and conclude in the third post with a general look both backward and forward.

Antique Homebrew Ham Station – ca. 1920

It’s arguably the case that today’s ARS, as reflected particularly by its licensing structure and secondarily by increasing “consumerization” (see below), has been “dumbed down” compared to yesteryear’s.  This deliberate change is probably intended to maintain the total number of licensed US operators at current levels or even to increase the number, as a forward-looking defense against possible future loss of allocated spectrum because of “low user numbers.”  And the results have been predictable: the Service now has a larger but a less knowledgeable and less motivated group of cohorts than it did in earlier times.

Two major licensing exam changes highlight this dumbing down.  First, fifty years ago every applicant for an ARS license had to demonstrate some proficiency in the Morse (more accurately, the International) Code and, second, as a standard practice in that earlier period the verbatim questions (and answers) for the written examinations were never published in advance.  Thus an applicant in those earlier days had to devote a sustained period of time to studying and learning, as there was no way of finessing the Morse Code exam.  And at least some basic understanding of radio fundamentals was necessary to correctly answer the unfamiliar exam questions. Failure of either part of the examination was a quite real possibility for the poorly-prepared, and weekend “exam-cram” classes didn’t exist then as they do today.

Today the Morse Code has been eliminated from the examination process, and those individuals with good memory retention and possession of openly-published copies of the verbatim exam question pools can obtain licenses without understanding much, if indeed anything, about the basic engineering, operating, and legal principles underlying the Service.  Licensing is now perfectly set-up for the casual, lightly-interested hobbyist.

This is NOT to assert that use of operator-generated Morse Code, with an information transmission rate for a moderately skilled operator equivalent to about 17 Baud, is the only or even the best means of wireless message transmission.  There are other, technologically superior character transmission methods in use now; neither is “CW” the Curmudgeon’s most favored operating mode.

Or to assert that being able to correctly calculate “how close in operating frequency just above the 7000 kc/sec Amateur band edge could a quartz crystal with a frequency tolerance of 0.005% be ordered with the expectation that it would operate within the band?” is a highly useful skill in today’s telecommunications industry!  No, rather the salient point here is that these earlier requirements did provide verification that the successful applicant had mastered new skills and might — just might — continue to do so after receiving a license!

Paralleling and complementing this devolutionary licensing change, the explosion of the market for commercially manufactured, made-for-purpose Amateur radio equipment has turned today’s Service into a hobbyist-consumer’s paradise!  To some extent this trend was inevitable, as circuit complexity in the era of integrated circuit electronics long ago moved past the point where most Amateurs could design, build, and test-and-align major radio systems at home.  And in truth, fifty years ago (and even earlier) most Amateurs used commercially-manufactured receivers, typically containing a minimum of eight vacuum tubes and often with significantly more.

But the QST magazines of the time demonstrated that there was lively activity in home-designed and/or -built transmitters, power supplies, antennas, and other necessary bits of Amateur stations.  A newly-minted Amateur might purchase (or even be given) his first Novice CW transmitter (often, a previously-owned one), but then he could move up to other possibilities. Transmitter kits were offered by such familiar (and long-gone) companies as Heath, EICO, E. F. Johnson, Knight, and others. Military and commercial surplus electronics was converted to Amateur operation by enterprising hams.  And “home brew” construction-from-scratch was much in evidence.  By these means the early licensees learned and increased their understanding and skills.

Today almost all this is gone.  It is not possible for most Amateurs (including the Curmudgeon) to home-build the equivalent of the sophisticated, manufactured solid-state transceivers (i.e., integrated transmitter-receiver packages) now in general use.  The “top end” of the ARS equipment market has been captured by the manufacturers, as it has in other areas of consumer electronics.  But the bottom end is still available for home construction and experimentation: small accessories, necessary and simple radio test systems, almost all antennas, antenna tuners, power supplies, etc.

Modern, consumerized amateur transmitter – receiver

However, many newly-minted Amateurs will not attempt even this much, preferring to purchase everything deemed necessary and to just “plug it in.”  It is likely that a significant number of today’s licensees, as part of our contemporary US “plug-in culture,” do not own soldering irons, and that some cannot even solder necessary RF connectors to antenna transmission lines!  [Of interest, the British explicitly test their Amateur Service applicants for this exact connector-soldering ability in their intermediate-level (equivalent to the U.S. General Class) licensing exams!  The same UK exam requires an applicant to home-construct and then to demonstrate a functional radio-electronics project.]

Thus over the last half-century Amateurs and their culture have moved from a Service comprised of a significant number of knowledgeable home experimenters who could, and did, make contributions to “the radio art,” to a Service wherein the idea of home experimentation and striving for personal improvement has essentially vanished for most licensees.  A thin veneer of professionally-qualified ham-engineers still carries on some very advanced ARS developmental work at home, but they are a minuscule minority.  Rather, for most of today’s ARS licensees “Bigger transmitters, bigger antennas” are the chief order of the day, these items are readily available for purchase in the manufactured-equipment market, and the cost be damned!  The “consumerization” of the Service has triumphed.

What do you think?

“Let’s keep the universe safe for RF!”

The Old RF Curmudgeon

Comments are now closed on the FCC Notice of Proposed Rulemaking (NPRM) to overhaul antenna-related rules, which covers Part 17 on construction, lighting, and marking. Comments were due by July 20th and the deadline for replies is August 19th.  A lot of our readers and clients already own AM broadcast antennas or if you own any kind of antenna structure or are expecting to build one, hopefully you have already contacted the FCC and made your suggestions, as this opportunity does not come along often.

In the past, most of these standards were set by the FAA (because of their focus on aviation), but enforced by the FCC.  The lack of communication between the two agencies has caused many discrepancies in the rules; the rules that are made to keep pilots and passengers from flying into the antenna structures.

If adopted, the proposed changes would remove outdated and competing guidelines, leaving antenna structure owners with clearer guidelines.

Summary: Antenna Structure Registration and Marking and Lighting Specifications

Specification of Marking and Lighting

• Eliminate references to the FAA’s Advisory Circulars.  The particular one mentioned was superseded more than six years ago.  Their proposed solution is to eliminate all references to the circulars and instead antenna structure owners should comply with the FAA’s determination of no hazard and associated study for each new or altered antenna structure.  Each antenna structure owner is clearly notified of the marking and lighting requirements for each particular structure through the ASR process.
• Clarify that lighting and marking requirements won’t change unless new specifications for a particular structure are recommended by the FAA.  A revised FAA Advisory Circular would not impose new obligations on approved antenna structures.  An alternate proposal would leave the FCC with the flexibility to apply new FAA standards retroactively.
• FAA recommended specifications become mandatory, but the FCC can specify additional or different requirements.
• No changes will be made to the lighting or marking specifications on the ASR without FAA and FCC approval.

Accuracy of Location and Height Data

• Changes in height of an existing antenna structure of one foot or greater or changes in coordinates of one second or greater will require prior approval from the FAA and the FCC. Currently, the rules do require that alteration of an existing antenna structure requires a new registration, but the rules do not say specifically what constitutes an alteration.
• Height information provided on FCC Form 854 of the ASR application must be accurate within one foot and the coordinates provided on FCC Form 854 must be accurate within one second of longitude and latitude.
• Antenna structure owners must use the most accurate data they can when they report height and coordinate information.  They also wanted comments on if a particular method of surveying a site should be used to determine height and coordinate information.

Structures Requiring FAA Notification

• Delete areas where the FCC simply restates FAA rules and instead reference the FAA rules.  Two particular sections are on antenna structures requiring notification to the FAA and certain antenna structures exempt from notification to the FAA.  The purpose of this would be to always have the latest FAA rules, for instance if the FAA changed a rule and the FCC did not update their rules, this could cause confusion.

Pending FAA Rulemaking on Notice and Obstruction Standards

• Comments on how the outcome of an FAA proceeding proposed in 2006 could affect any of the other matters in the document.  The proposed proceeding was to expand FAA notification rules to require notice for any new or modified antenna structure ( in certain frequency bands), including some used for land mobile, microwave, and multiple address system operations, and any modifications to a system operating in those frequency bands, including the addition of new frequencies, increases in effective radiated power (ERP) and certain antenna modifications.

Maintenance of Marking and Lighting

Inspection and Maintenance of Lighting

• Two alternatives for the section that requires antenna structure owners to observe the antenna structure’s lights at least once every 24 hours and make quarterly inspections of their lighting alarm systems. The first option is to eliminate inspection requirements but maintain the obligation to have proper lighting at all times, also keeping in place penalties.  The second proposal is to amend the section to exempt certain systems using network operations control (NOC) center-based monitoring systems from the requirement to quarterly inspect all automatic or mechanical systems associated with antenna structure lighting.
• Change the section that requires antenna structure owners to immediately report outages of top steady burning lights or flashing antenna structure lights to the FAA.  When this notification occurs, the FAA issues a Notice to Airmen (NOTAM) to warn aircraft of the outage; this notification is deleted after 15 days.  If the lighting cannot be repaired in 15 days, the new proposal would instead have the antenna structure owners notify the FAA to extend the outage date and to report when service is returned In the event the lighting outage cannot be repaired within 15 days, the FCC proposes requiring antenna structure owners to notify the FAA to extend the outage date and report a return to service date; this process to be repeated every 15 days until the lights are repaired.  Another update to this rule would allow antenna structure owners to notify the FAA by any method acceptable to them, which is currently a toll-free number.
• Delete the section that requires antenna structure owners to replace or repair lights “as soon as practicable” or “as soon as possible” and whether or not the FCC should include specific time frames.

Elimination of Unnecessary Provisions

• Deleting the sections on types of temporary warning lights (red obstruction lights) to be used during construction of antenna structures and the time when lights should be exhibited and when flash tubes in a high intensity obstruction lighting system must be replaced, since the requirements are already specified in the FAA determination of no hazard and associated study for each tower.

Records of Extinguishment or Improper Functioning of Lights

• Require antenna structure owners to keep a record of observed or otherwise known extinguishments or improper functioning of structure lights for two years and to provide the records to the FCC upon request.

Maintenance of Painting

• Amend the section that requires antenna structures to be cleaned or repainted as often as necessary to maintain good visibility.  Should the FCC establish a standard for measuring “good visibility” based on the FAA’s “In Service Aviation Orange Tolerance Chart?” If so, would the antenna structure owners compare the FAA’s chart to the tower at a distance of 1/4 mile or at the base of the tower, as is the current practice of the FCC’s Enforcement Bureau.

Other Matters

Voluntarily Registered Structures

• Should rules concerning antenna structures should be enforced against antenna structure owners who voluntarily registered their towers, when they were not required to do so?  Should owners of antenna structures that do not require registration be prohibited from registering their towers, and should owners who have voluntarily registered be required to withdraw their registrations from the FCC’s database?

Definitions

• Clarify that the “antenna structure owner” is the owner of the “underlying structure that supports or is intended to support antennas or other appurtenances” in order to clarify that registration responsibilities are those of antenna structure owners, not licensees or permittees that are tenants on the structure.
• Clarify that a structure is considered an “antenna structure” if the primary purpose of the construction is to support antennas to transmit / receive radio energy.

Posting of ASR Number

• Require that antenna structure owners display the ASR number so that it is visible to the general public who reaches the closest publicly accessible location near the base of the antenna structure (such as a gate or fence on the path leading to the structure.) If two locations exist, the ASR number must be posted at each location, however, it would not be necessary to post the ASR number at the tower base and at the point visible to the general public.  The FCC wanted comments on how to handle situations where multiple towers are in the same fenced in areas and when the antenna structure is on a building.

Provision of ASR to Tenants

• Allow antenna structure owners additional methods of notifying tenant licensees and permittees via e-mail or regular mail that the structure has been registered and to give the tenant licensees and permittees the ASR number along with a link for the FCC’s ASR website.

Notification of Construction or Dismantlement

• The FCC wants to stick by the 24 hour notification for construction or dismantling of an antenna structure, whereas the FAA requires notification within 5 days.

Facilities on Federal Land

• There is an amusing case here where Section 17.58 requires compliance with Section 1.70 of the FCC’s rules, however, Section 1.70 was deleted back in 1977!  They propose to delete this section finally, after 33 years!

Be sure to read the entire Notice (linked at the top of the post) for complete information.  The FCC comments may be closed but ours are not.  Let us know what you think about the proposed changes below.