Frequency Coordination Issues and Answers

What is a Shared non-protected pair?

  1. On the two meter band we have designated 145.25 MHz for use a shared non-protected pair. To put a repeater on this frequency, you do not go through the normal coordination process. It is wise to apply for the pair.

    This is for low elevation and low power machines; preferably less than 100 feet HAAT, and less than 100 watts ERP.

    By non-protected it means you have no halo around you that someone cannot put a repeater on the same frequency.

    You cannot run carrier squelch. PL (aka CTCSS) tones are strongly recommended on the input and output of the repeater. The frequency coordinator will work with you to determine the best one.

    This is intended for the trustee that just wants to have a repeater to experiment with. It would also be very useful for disaster scenes and public service activities where perhaps a repeater would be useful, one is not readily available. You have one mounted in a vehicle or on a trailer. Pull up on a near by hill run 25 watts into a Ringo-Ranger on a 20-50’ mast and have a repeater while you need it.

    One word of caution in the metro areas you may suffer interference from cable TV leakage. Another reason PL tones are required for these systems.

It was asked about using 145.25 for a network of repeater for disaster work, so one would never be out of range of one.

  1. We never intended 145.25 for this use. There are several wide coverage networks already in place, and the beginning of a state-wide UHF backbone. We have the SWIRA link for SW Oklahoma, and the TARC Super System for Eastern Oklahoma and Western Arkansas. It has made some inroads to central Oklahoma with nodes in Stillwater and eastern Logan County.

    The Logan County machine may be accessible from OKC at least for fixed stations. A group in Ada is thinking about linking to this system, but right now it’s just a thought. It is not believed that they have even contacted TARC concerning this.

    There is the beginning of a link system concept where a few UHF frequencies under the control of a single organization would be used by a series of close spaced repeaters; perhaps reusing the frequencies at 75 miles instead of 90. Therefore by switching between hopefully two or three frequencies you would never be out of range of the system, and be able to communicate with a net control from anywhere in the state.

    Having said all that we must keep in mind that there are other ways of doing this, 3900 kHz LSB is used a lot as the state’s emergency frequency on HF, along with another one on the 40 meter band when 75 meters doesn’t work. Hey, Morse code has gone away, so study a little and get your General class ticket.

    There are also things like repeater linking with Echo link and IRLP. Also D-Star is beginning to make inroads into the state and with the digitized audio; it lends itself very well to dropping into wormholes on the internet and popping up who knows where.

    None of these systems are perfect, so emergency management types should have the capabilities of using all of them.

How or who do we work with in the surrounding states?

  1. ORSI has good working relationships with the Arkansas Repeater Council, Missouri Repeater Council, Kansas Amateur Repeater Council, Texas VHF-FM Society, and have rubbed elbows a bit with coordinators in Colorado and Louisiana.

What if someone puts up a repeater in one of the surrounding states that interferes with my repeater?

  1. Before anyone puts up a repeater in a surrounding state, the frequency coordinator for the state involved contacts me and the coordinators in other affected states and notifies us of the proposed coordination, we call the process need of professional courtesy. So normally this does not happen.

    Now one of the things we get into is the different states have different separation standards, and in the case of two meters and Texas a slightly different band plan. This usually leads to a bit of negotiation among coordinators and we do our best to resolve the issue.

What if the trustee of that repeater says he is coordinated, but it is through a coordination group that we don’t know or recognize?

  1. Therein lays the problem, the FCC’s definition of who a coordinator is rather loose. In fact the FCC even says that the whole coordination process is voluntary (to an extent).

    A coordination body is whoever a majority of hams in a given area recognizes to be the coordinator (again this is the FCC’s policy).

    Now some trustees then take an attitude that they can do what they want to, and stick a repeater up on any frequency they want, anywhere they want and they are within their rights.

    The FCC even calls band plans voluntary right? To some extent this is all true.

    However the FCC has ruled repeatedly that if an uncoordinated repeater interferes with a coordinated repeater then it is incumbent upon the trustee of the uncoordinated repeater to resolve the issue.

If all this is voluntary how can the FCC enforce that?

  1. In part 97, the FCC’s rules and regulations concerning amateur radio, the FCC has a rule that states that an amateur station must be operated at all times using “good operating and engineering practices.” Therefore abiding by a recognized band plan is good operating practice. Getting your repeater coordinated is good operating practice. By not doing these things they (FCC) consider it “not good operating practice” and therefore it is a violation of Part 97.

    Now when they enforce on the “good operating and engineering practice” section of the rules, they start out as being nice guys. They will look at it as perhaps the operator doesn’t realize his mistake, and ask him to get in touch with a frequency coordinator and get his system properly coordinated. In the meantime they will ask that wayward trustee to modify his/her operation to reduce or eliminate the interference to the coordinated repeater.

    If that trustee chooses to ignore the friendly approach, then they will presume he/she is willfully causing harmful interference which makes it malicious in nature and is a direct violation of Part97. At that point no more Mr. Nice Guy, if you catch my drift. Then since they are consistent in this manner, the courts have backed them up.

What if the repeater system in question was coordinated by some “alternate” group that seemingly sprung up out of nowhere?

  1. Yes that happens, and Texas is not the only place where it happens. We had that occur several years ago here in Oklahoma.

    ORSI while still technically in existence was in a state of disarray due to some repeater politics going on. Another group called ORCG sprung up, and started coordinating repeaters at least for the trustees that recognized them. After some time ORSI got our act together, got some folks to calm down a bit, and got back in the business of frequency coordination. The people behind ORCG then decided to shut down, and ORSI is today the recognized coordinator for Oklahoma.

    Now part of the problem is with the FCC’s loose definition of a coordinator and the use of the word “voluntary” in all of this. The FCC views Amateur Radio and Radio Amateurs overall as a self-regulating self–policing entity and they like it that way, and they only want to get involved as a last resort. This approach has been very successful overall for around 100 years, so it’s not time to go messing with it now!

    However, they (FCC) have been quietly at times and at other times not so quietly doing some things to corral the repeater coordination monster just a little. Not quite open range anymore, but it still gets to roam on a 500,000 acre ranch if you understand what I am saying. Some of the things they go by to determine who is really operating a coordinated repeater and who is really a coordinator.

    1. Whether they should or not, they give some credence to the “ARRL Repeater Directory.” This doesn’t have any kind of legal precedence, but the FCC is probably starting down that path through adjudication of case law. In other words the courts haven’t told us not to, so we continue to do this and if we do it enough, then the courts will probably not stop us.
    2. They look and see who the surrounding areas are recognizing as the coordinator for a given area. Usually it’s on the state level, but some states have legitimate recognized multiple coordination bodies, because of having major metropolitan areas, or coordinators that specialize in certain bands or certain operating modes.

      Here in Oklahoma ORSI right now sticks strictly to coordinating FM voice repeaters, and giving some recognition to digital voice repeaters. We leave packet and APRS alone, and we don’t get into doing anything with IRLP and Echolink systems operating on the recognized simplex frequencies.

    3. The FCC gives a lot of weight to band plans, especially the ARRL band plans, but also recognize band plans that deviate a bit from ARRL’s where large groups of amateurs in a given area recognize that band plan. Violating a band plan and causing harmful interference to those observing a band plan is not considered “good operating and engineering practice” and therefore a violation of Part97.
    4. Regional and attempts at some sort of National Coordination organization are another factor. ORSI affiliated with the Mid-America Coordination Council also known as MACC. Arkansas, Kansas, and Missouri were also MACC states. Texas was not.

      MACC grew into a very large body of frequency coordination groups, and attempted to morph into a national organization called the NFCC, National Frequency Coordination Council. I perceive that MACC mainly worked to help its members set relatively uniform technical standards, and make it easier for coordinators to communicate with each other when cross border issues arose.

      The NFCC went further, their goal we to even say who was a coordinator and who wasn’t. They also wanted backing from the FCC. The FCC at first was a backer of the organization, but they mainly desired a “single point of contact” for frequency coordination issues in amateur radio. They have this with other services such as broadcasting and public safety.

      Not all state and regional coordination groups joined the NFCC, a previous ORSI administration was very adamant about not joining the NFCC unless we were forced to in order to be recognized as a coordination body. Present administration took a wait and see attitude.

      I haven’t found any MACC activity since 2005, and the first effort at forming the NFCC failed. The FCC refused to enter into a memorandum of understanding with them based on some legal technicality. One thing was that the FCC also wanted to see the ARRL bless the NFCC, which kind of sort of happened. The last thing I heard about the NFCC the original board disbanded, but a new group took over. Which I believe came out of the mostly successful MACC organization, but I still don’t think it has really gone anywhere.

    5. Where is the ARRL in all of this? Therein lies the truth, the FCC would like a single point of contact for amateur radio frequency coordination, that is true. However, they do not want some organization that might be in some ways implying they are a junior FCC, or Near FCC, or Like the FCC. It is plain from what I see is that the FCC would like for the ARRL to take the ham repeater coordination beast on.

      However, the ARRL does not really want this hot potato dumped in their laps. First of all they say that taking on a part of the amateur radio exam system, cost them money. Then they saw a potential for legal liability in this area.

      Quite frankly repeater club politics get nasty. We’ve had a taste of it here in Oklahoma, and there are even bigger problems in Texas and California.

      The ARRL is asking for some sort of protection from legal liability that Federal agencies have, when in their (ARRL) view that they are performing a governmental function.

      Now I’ve already stated that repeater frequency coordination are privatized in at least the broadcasting industry and public safety. I assume that to be the case for land mobile as well.

      So while I understand the League’s concern on this, I also understand why the FCC and Congress are reluctant to grant this exemption. Although I know at least in some states, many lawsuits have been threatened, and some have actually been filed. Their have been death threats, obscene phone calls, and I have even witnessed one coordinator’s birth legitimacy be publicly questioned in Oklahoma.

      Now I do see the ARRL being pulled into this by the FCC through the back door. With the FCC at least giving the “ARRL Repeater Directory” some recognition as an authoritative document and giving some legal status to band plans. Also the FCC gives some special status to ARRL since the League with the largest membership of any amateur radio organization is said to represent a significant percentage of the amateur community.

      A couple of years ago I did hear something about the ARRL was proposing to create a web-based central repeater database that local frequency coordinators could use as a one stop shop in order to get clearance from surrounding areas. It’s a wonderful idea, and would be a time saver, but it hasn’t happened yet and I’ve heard nothing more about it.

      I do know that the ARRL has toughened their policy on who they will accept listings for the “Repeater Directory” from in the last two or three years.

      So will their ever be a “super-coordinator” like the NFCC or ARRL? Will the definition of a coordinator be tightened up by the FCC? The former I really don’t know, the later I do believe is happening slowly but surely. Not so much with definitive rule makings by the FCC, just their stricter way of interpreting the rules as they stand.

What is the biggest problem we have here in Oklahoma?

  1. Not knowing what’s really on the air and what isn’t. Our district officers will be working on this problem over the next few months.

Speaking of that, “I want a repeater pair for my area; you say there are no pairs available. You guys have one listed, but I have not heard it on the air for a long time. What’s the deal?

  1. Sometimes trustees remove their repeaters from operation and don’t tell us. For this reason, we have what is known as an “abandoned pair procedure” You apply for that pair, and let me know that you are applying for it under the abandoned pair rule. I will attempt to contact that trustee, at first with a request for update of the status of the repeater. I will attempt this at first by email, and if it turns out that I don’t have a valid email address for this trustee, I will send the request by U. S. mail with an SASE. If the letter is returned by the postal service as undeliverable, I will do an internet search to see if I can find any information on this wayward trustee. If I cannot find any new information, then we will decide that the trustee has moved away and most likely taken the repeater with him/her. Then if technical standards are met, you may have the pair.

    In the meantime I will ask you to have at least two other licensed amateurs in the area, send be me a signed statement that they haven’t observed the repeater to be on the air for at least 90 consecutive days.

    If the request for update does not get returned, but no reply is received; then the next step is that I will send out a letter to that trustee advising him that we think the pair is abandoned, and that someone has applied for it under the abandoned pair rule. This letter is sent by Certified Mail, Return Receipt Requested. Meaning the Postal Service will require that someone at that address signs that they received the letter. The Letter Carrier put it tight in someone’s hand at the given address. We, ORSI, will know that it either was or was not delivered. That starts the clock ticking.

    That trustee then has 120 days to get his repeater back on the air, or we will declare the pair abandoned, and award it to the applicant, if his proposed coordinates meet all technical standards. If he sees he can’t get it on the air in 120 days, he may apply to the ORSI board for an extension of time; citing reasons such as inclement weather, or an uncooperative power company, etc. It needs to be fairly legitimate reasons.

    What if the trustee says the machine is on the air, but those of us in the area know it isn’t?

    These things happen, but not too often. In most of the cases, when we’ve contacted the trustee, we find things like equipment has been hit by lightning multiple times and the finances to repair the equipment anymore are just not available. We’ve also ran into cases where the trustee had serious health issues and could not take care of the equipment any more.

    In a case where it gets down to someone being less than honest about a repeater’s status, an ORSI representative, usually the coordinator and/or one or more district officers will quietly come to the area, and observe for themselves whether a repeater is on the air or not, and make the final determination on that basis.