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The FCC's Proposed Reorganization: 

And Why the SET is Irrelevant

By
Ed Mitchell, KF7VY, http://hamradio-online.com, August 13, 1999
Revised 27 August 1999

With the FCC's reorganization plan and new policy goals as a background, I realized that our annual Simulated Emergency Test has become largely pointless. 

Click here to Read or Post Comments on This Column on the Discussion Forum

The FCC has issued its proposed five-year plan for reorganization. Within this document, there is no mention of Amateur Radio, which is to be expected considering its coverage of broad policy issues. However, there are a number of key policy initiatives that the Commission has specified as goals and these can be interpreted in the context of their impact on the Amateur Radio Service.

Key points throughout the Commission's plan are:

  •  The use of competitive market forces to reduce the need for government intervention and regulation, 
  •  The continued deployment of advanced technologies to improve access for all members of society, 
  •  To make available new and advanced services 
  •  And to increase the utilization of radio spectrum.


The key points relevant to Amateur Radio are the deployment of advance technologies, availability of new services, and increasing the utilization of the radio spectrum. The Commission notes that "Since spectrum is a finite public resource, it is important that it be allocated and assigned efficiently to provide the greatest possible benefit to the American public." And most telling of all, "Reallocate spectrum to increase availability for higher value uses, e.g., possibly third generation mobile and new satellite services."

In a previous opinion column (see "Amateur Radio Has Lost Its Uniqueness") I stressed the need for Amateurs to constantly improve their processes, procedures and to adopt new technologies in meeting the needs of today's communications problems. Many Amateurs are unaware that essentially all of our VHF and UHF spectrum allocations (in the U.S.) are heavily shared with other radio services. In effect, these bands have been "junk bands" unsuitable for use by traditional commercial services[1]. However, the change from analog to digital modulation schemes, together with many new applications for radio spectrum, now make it possible to use these frequencies for commercial services. A prime example is vehicle location services operating in the shared 902 to 928 Mhz band. Further, the Commission has set a goal to "Work with industry and the National Telecommunications and Information Administration to promote the use of technologies and approaches to spectrum allocation and assignment that minimize interference and increase coordination between Government and non-Government users."

These are code words that imply that Amateur access to VHF and UHF spectrum will undergo increased sharing requirements, or re-allocation.  Sharing, in the case of the 900 Mhz band, means that other services have the right, which they have already exercised, to request that Amateur operations in the band be terminated.

To illustrate this issue further, the Commission has listed key goals to:

  •  "Reallocate spectrum to increase availability for higher value uses, e.g., possibly third generation mobile and new satellite services."
  •  By Year 1, "Allocate 4 Ghz of spectrum for unlicensed services"; "Develop plan for use of spectrum reallocated pursuant to statutory requirements". "Develop plan for implementation of ultra-wideband radios and software defined radios". 
  •  By the end of Year 2, "Examine management of shared spectrum". 
  •  And over the five year plan, the Commission intends to "increase available spectrum, through reassignment of 300 Mhz", with sub-goals of increasing the capacity for mobile services by 25%.
The Commission is interested in those services and applications that improve spectrum usage, that "add value" to the public, and which further the development and deployment of advanced, efficient technologies. Now, go back and re-read my original "Amateur Radio Has Lost Its Uniqueness" column. As long as we remain stuck and focused on the past, Amateur Radio is no longer serving the public interest goals established by the FCC in 1999. 
 

Why the Simulated Emergency Test is Irrelevant

With this background, I recently reviewed the ARRL's online documents [2] related to their annual "Simulated Emergency Test" program for the ARES/RACES and NTS programs. Unfortunately, as presently implemented, the SET has outlived its usefulness and is an exercise demonstrating that we can use World War II era technologies and procedures to manually deliver a few short written messages between two or more points.

Referring again to "Amateur Radio Has Lost Its Uniqueness", message handling is a commodity. When we run the SET, we focus on providing a communication solution to a decreasingly small niche market that requires the handling of a few short messages via voice or telegraph. We can all point to actual events during the past ten years where this traditional function has proven itself. However, during the past ten years, the communications infrastructure has matured tremendously and continues to explosively grow. The services we provided yesterday are quickly obsolete. 

Over the past 10 years, our society has added about 80 million celphones (operated by multiple service providers, creating redundancy), tens of millions of pagers, including two way pagers, a huge expansion in private "landmobile" and public safety communications networks, plus a 142 million estimated worlwide Internet users. In 1 to 2 years, "third generation" cellular networks begin deployment, increasing wireless data capabilities to hundreds of k bits per second. Cellular phones available for purchase today include direct serial connections to computers or handheld PCs and can be used for 9600 bps wireless messaging, email and Internet access. 

Providing slow speed delivery of a few short messages via voice or telegraph was useful just a few years ago but now is useful to a decreasingly small niche market of situations that need this capability.

The SET is a perfect opportunity to establish "stretch goals" - to innovate and implement new procedures and technologies to deliver the service that today's communications problems demand. Instead, the official SET plans fail to spurn amateurs onward to greater achievements. The main goal, as specified at the ARRL's web site, is the sending of "test messages" and integrating ARES/RACES with NTS. Once upon a time, this was an essential communications service. Today, this is a commodity function available through an enormous supply of communications alternatives. Wireless voice and data options are now available in almost every community, are continuing to expand, and will be enhanced to support hundreds of kbits per second of wireless data in the near future.

Here are some quotes from the ARRL's web site regarding the purpose of the SET [2]:

1. To find out the strengths and weaknesses of ARES and NTS, the Radio Amateur Civil Emergency Service (RACES) and other groups in providing emergency communications. 
2. To provide a public demonstration--to served agencies such as Red Cross, Civil Preparedness, and through the news media--of the value to the public that Amateur Radio provides, particularly in time of need. 
….
"ECs contact served agencies and explain the intent and overall purpose of the SET, offer to send test messages to other branches of their agencies, and invite officials to ARES meetings and SET operating sites."
….
"Test messages may be sent simulating requests for supplies. Simulated emergency messages (just like real emergency messages) should be signed by an authorized official. Tactical communications for served agencies is emphasized. "
Elsewhere, the document emphasizes the purpose of SET to tie together ARES/RACES and NTS for "traffic handling" to points outside the local area. Indeed, the main point of the SET remains one of generating and processing simulated emergency communications for the purpose of relay via NTS. In effect the SET preserves the art of  slow, manually operated, short message "traffic handling", even though customers for this service are declining rapidly.  The customers' needs for NTS traffic handling are declining because other options are available, that handle more traffic, more quickly and without the need for "operators" to handle the messages. As a result, the SET is now largely irrelevant. Our ability to handle a few short messages, slowly, is no longer "hot stuff". A two-way pager can do the same function, only much faster.

Far from "a public demonstration - to served agencies", the SET is a public demonstration that we can slowly deliver a few short messages using old procedures. If we truly wish to remain relevant in the 21st century, our SET should be a demonstration of our ability to build ad hoc packet and wireless TCP/IP radio networks, to relay messages to points outside the emergency area, to interface message delivery into Internet email systems, and to deploy unique technologies such as image communications.

Suffering beneath institutional inertia, the "official" SET serves to preserve historical traditions, regardless of their relevancy to the 21st century. This approach to emergency training is wrongheaded and detrimental to the future of Amateur Radio. If you participate in SET, volunteer to make a difference - design your own SET that is relevant to your community and the 21st century.  Provide solutions delivering what agencies need in the year 2000- don't just deliver a dozen short written messages using old technology and procedures. If you follow the official ground rules for SET, you will be demonstrating to public officials how obsolete the Amateur Radio Service has become. Ignore the official rules and make the SET have a bona fide purpose in creating innovative emergency communications solutions for served agencies.

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References

[1] 50 to 54 Mhz is effectively a "guard" band for high power television broadcasts underway on 54 to 60 Mhz (Channel 2). 420-430 Mhz is lost north of "Line A" and 430-450 Mhz and the 1.3 Ghz band are shared with radiolocation services (radar). 902-928 Mhz, 2.4 Ghz, 3.4 Ghz and 5.7 Ghz are shared with an extremely wide array of services and unlicensed devices. Effectively, 902-928 and 2400 Mhz are nearly lost to Amateur Radio usage (and soon will be with the explosion of cordless phones, wireless LANs, cordless TV systems, and microwave ovens). 5.7 Ghz is earmarked for use by new functions including unlicensed point to point microwave links and communications to and from vehicles as part of a future "intelligent vehicles highway" programs.

[2] http://www.arrl.org/field/pscm/sec1-ch2.html