02/01/2018 Commenting in response to an FCC Public Notice (DA 17-1180) released last month, ARRL addressed the extent of Amateur Radio’s response to recent hurricane disasters and efforts needed to expand the use of Amateur Radio services when it comes to planning, testing, and providing emergency communication. The comments point out that Amateur Radio not only has been “far more than a hobby;” it is a ubiquitous, infrastructure-independent communication resource that’s always ready to deploy effectively whenever and wherever needed. The League cited the remarks of former FEMA Administrator Craig Fugate, KK4INZ, that Amateur Radio “oftentimes is our last line of defense.” ARRL raised three areas where action by the FCC could ensure and enhance the ability of radio amateurs to provide emergency communication, including the current Amateur Radio Parity Act of 2017 (S. 1534), now in the US Senate. “HOAs can preclude amateur antennas in common areas. HOAs can enact reasonable written rules governing height, location, size and aesthetic impact of, and installation requirements for, outdoor antennas and support structures for amateur communications, but the effective outdoor antenna requirement is paramount,” ARRL noted in its comments. “The bill is currently before the Senate Commerce Committee. If, however, Congress is unable, as has been rumored, to pass any telecommunications legislation this term, it will be incumbent on the Commission to take the action on its own initiative that would be called for by this legislation. The future of Amateur Radio emergency communications is dependent on it.” ARRL asserted that it “is critical to have stations located at one’s residence in order to regularly participate in disaster preparedness training exercises and drills.” Another “noteworthy and urgent need” that might call for some regulatory involvement by the FCC, ARRL said, “relates to an outdated regulation that limits data rates in HF Amateur communications, precluding certain digital emissions that have recently proven extremely important in Amateur Radio hurricane relief efforts.” ARRL noted that the FCC has yet to act on the League’s Petition for Rule Making (RM-1170), filed in November of 2013, proposing to amend the Amateur Service rules to eliminate the symbol rate limit relative to data emissions in allocations below 29.7 MHz. That Petition also called for establishing a 2.8-kHz maximum occupied bandwidth for data emissions in those bands. ARRL has argued that this deregulatory action is necessary to allow the use of PACTOR 4, an effective and efficient digital communication mode that has proven valuable in disaster-relief efforts. In July of 2016, the Commission released a Notice of Proposed Rule Making in WT Docket 16-239, proposing only to remove limitations on the symbol rate applicable to data emissions. “Equipment dispatched with the ‘Force of 50’ [volunteers] to Puerto Rico included data transmission equipment capable of PACTOR 4 operation, but it could not be legally used in the Hurricane Maria disaster relief effort,” ARRL noted. The League prevailed upon the FCC to grant a temporary waiver to permit use of PACTOR 4 by radio amateurs involved in the emergency response. “However, it should not have been necessary to wait more than 4 years for the underlying rulemaking proceeding to have been resolved, and it should not have been necessary to ask for a temporary waiver of a hopelessly outdated rule that limits data speeds for no useful reason,” ARRL added in its comments. The League also called on the FCC to “take the action requested in ARRL’s January 2017 Petition for Rule Making (RM-11785), proposing to allocate the band 5351.5 to 5366.5 kHz to the Amateur Radio Service on a secondary basis, in accordance with the Final Acts of World Radiocommunication Conference 2015. “A contiguous band in the vicinity of 5 MHz will assist in conducting emergency and disaster relief communications in the United States; with the Caribbean basin; with Alaska and with other parts of North, Central and South America,” ARRL told the FCC. ARRL has asked the FCC to permit 100 W, as it does on the five existing 60-meter channels, and to retain the four channels that are not part of the requested contiguous frequency band. .