(We're going to have to keep this short, since this is an International
list, and many people here simply aren't interested in FCC rules.  Been
there, done that, on the IRLP list in the past, and it's now a banned topic,
because of the misinformation and flame-fests that started up.  Folks
hopefully will be more CIVIL here.  I'm not good at "short", 'cause I hate
misunderstandings, and I type fast.  GRIN.  As a part-time list moderator
here, I can see this getting WAY out of control real fast. so people .
PLEASE be rational about this and not emotional.  Drop any emotional baggage
you have about "coordination" at the door, or at least discuss without
insulting others as much as possible.  Thank you!.)

 

Hi Scott, 

 

I'll start with direct answers to your direct questions and then explain my
thought process, below.

 

1) As a repeater owner, would you rather be coordinated?

 

It's not a repeater.  But yes, for non-agile infrastructure systems I always
prefer working with the other Amateurs in the area IN WRITING to determine
good frequency allocations.  See below.

2) Is there a reasonable alternative to coordination?

 

Yes, documentation of a refusal to coordinate should still hold some legal
clout if ever needed.  The whole idea of the coordination process is as a
LAST DITCH EFFORT to resolve conflicts, so other means should be attempted
to mitigate unintentional interference prior to whipping out the
coordination documentation.  Intentional interference is already well
covered in Part 97, and is 100% illegal, period.

3) Should this be something we pursue with the FCC?

 

Probably not necessary at this time, especially if local coordination bodies
are willing to issue coordinations anyway.

 

----

Okay, thoughts.

 

I'll point out some things that you might be missing in your request about
coordinations in the U.S., perhaps they'll help you with your concerns about
your system.

 

A local coordination body can coordinate ANYTHING they want to here in the
U.S.  -- You appear to be making a easy but erroneous assumption that the
FCC regulates what they can and can't coordinate, and also that you think
they CAN'T coordinate your DD system.  They can.  

 

ANY coordinated system still gets the recognition of the FCC, no matter if
duplex or simplex, if you read it carefully -- they're just giving examples
specific to duplex repeaters because those have always been the "problem"
systems for the FCC in the past.

 

Basically it comes down to this:  

 

If you want your DD system coordinated, ask your local coordinators to issue
a coordination.  Simple as that.

 

You should get a response one way or the other.  And if they don't want to
coordinate the system, make them reply in WRITING with a date, if they
refuse to do so for ANY reason.  

 

Make reasonable arguments in your initial request in writing about why you
feel that it deserves to be coordinated.  Good points include that it's an
infrastructure system, and not easy to move in frequency to the point of
almost being non-frequency-agile, and that like a repeater, once users know
where it "lives" in the band they tend to expect to find it there.

 

If you get a rejection, just file away a copy so your back-side is covered
later when someone pops up and interferes with your system.  You have a
signed request from you, and a signed REFUSAL from them. or you might have a
coordination. either way, you have written proof of the DATE your system was
first on-air.

 

Either way, coordinated or not, you've now got documented 3rd party proof
that your relatively non-frequency-agile, infrastructure system was there
FIRST, via the date on the letter(s).  If they later try to issue a
coordination for something else on top of you, you have a reasonable
grievance.  If someone else plops down on top of you, you're documented as
being there first.

 

That level of documentation is likely enough to be PLENTY for the FCC to
rule in your favor in a worst-case scenario.   They are reasonable people,
and they'd see that you'd been there a long time before the next system
arrived.  

 

Simple enough.  No need for the FCC to be involved at all.

 

LOCAL INFO:

 

Here in Colorado, we set aside spectrum in the BAND PLAN for 1.2 GHz for
things like DD, and it's quite a large chunk of spectrum, if you look at how
many "channels" of DD could be supported (or anything else).  Band-plans are
also an important part of this overall picture.  If there aren't local
band-plans, work to get some made and published.  (This can sometimes take
YEARS.  Sometimes it can be done quickly.  I didn't look up where you live,
but most of 7 land isn't that densely populated that a good band plan can't
be made without huge amounts of bickering and grumbling.  Break it up into
chunks that are easily digestible if you can't do it all in one swoop and
have consensus. how do you eat the Elephant?  One bite at a time.)

 

For a real-world example. One of the reasons a coordinating body might NOT
coordinate you, is if they feel it's not a repeater and it "steps on the
toes" of a different coordination body. examples might include highly dense
population areas where simplex data systems have been traditionally been
coordinated by the "packet" group, and the duplex repeater coordinated by a
"repeater" coordination group.  

 

In that case, you could take your refusal letter from the "repeater"
organization and use it as a segway to approach the "packet" group.

 

But keep going.  It's up to you to document your system.  Never trust anyone
or any other organization to do it for you.  If you want it coordinated,
keep asking.  Politely.  But insistently.

 

BAND PLANS don't carry the regulatory "weight" of a coordination, but if
you're following one and can document that you willfully chose to do so
in-writing, you're again -- a leg up on the doofus who plopped something
down on top of you.  Remember, the reality is this is all about how a
reasonable 3rd party would view your activities, if you're ever forced to
have someone adjudicate a problem with interference.

 

 

PESRONAL NOTES: 

 

Now with ALL of the above in mind, remember that coordinations are NEVER
required.  Highly recommended, backed by the FCC and law when needed, but
you can run your system uncoordinated as long as you like, and at 1.2 Ghz.
it's very unlikely that you'll EVER have any trouble.   Or if trouble is
brewing (some new broadband gear/mode up there in the future), you'll have
your letters and documentation that your system was where it is, first.

 

Like all volunteer activities -- it helps a hell of a lot to have your voice
heard, if you're willing to step up and volunteer to work on the
coordination body in your area for a while.  It gives your voice a little
more credence if you've also been involved with helping the organization out
with their day-to-day business, and have a few years of listening to typical
grievances, etc.  In other words, you've been around that block a few times.


 

Frankly, some coordination groups aren't run well enough that they allow
"outsiders" to volunteer to fill positions, etc.  Or they're not very
objective about coordinations they issue.  I can't really speak for that,
but if you're in that situation, contact me off-list and I'll share some
additional information about how that type of situation is SUPPOSED to get
handled. but that'd be WAY off into the weeds for this list. 

 

Around here, we almost always have a few positions open that need people
every couple of years.   We'd be happy to have new clueful volunteers who
aren't out just for their own gain, but who truly desire to help the local
Amateur community.  The meetings are open to the public, and well run.  I
KNOW this is not always how it works everywhere, but it requires good people
and a lot of time to hash out the details to get it there and keep it there.
all I can say is "keep trying". 

 

Realistically now, not speaking from a coordination volunteer's standpoint. 

 

1.2 GHz just isn't "full" enough just about anywhere to worry about it.  If
someone plops down on your frequency with something analog-based or another
DD system, it's very likely to be an accident, and shouldn't take more than
ten minutes to resolve amongst reasonable Amateurs once you ID the
interfering system. 

 

Of course, having seen some very UN-reasonable Amateurs over the years, I
understand your desire to have that piece of paper.

 

Hope that helps. 

 

Nate WY0X



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