NEWINGTON, CT, Oct 16, 2002--The ARRL has asked the FCC to deny a petition, filed by a Virginia amateur, that would set aside eight channels in the 70-cm band on which visitors from Europe and the United Kingdom would be permitted to use their Personal Mobile Radio (PMR 446) transceivers while in the US. Authorized earlier this year, PMR 446 is similar to the US Family Radio Service (FRS), which uses frequencies in the 462-467 MHz range.

"ARRL is not unsympathetic to the compatibility concerns of international travelers, but at the same time, there are far less problematic solutions to the problem noted by the petitioner than those contained in the Petition," the League said in its comments. The ARRL recommended that European and UK visitors purchase FRS transceivers to use during US visits.

The FCC put the Petition for Rule Making from Dr Michael Trahos, KB4PGC, on public notice in August and designated it as RM-10521. A physician from Alexandria, Trahos said his proposal would help to promote international goodwill. The General-class licensee asked the FCC to amend its Amateur Service "and/or" Family Radio Service rules to allow "visiting/ transient/tourist non-amateur non-United States resident foreign nationals" unlicensed access to certain frequencies between 446.0 and 446.1 MHz.

The ARRL demurred. "Not all means of fostering international goodwill constitute public interest justifications sufficient to support regulatory changes," the League said. A rule change permitting non-amateurs individuals to operate unlicensed transmitters on amateur bands, it continued, would be contrary to the fundamental regulatory structure of the Amateur Service, the Communications Act of 1934 and the International Radio Regulations. "No one can operate an Amateur Radio Station without a license, or without a licensed control operator present," the ARRL commented, noting that the FCC could not modify its Part 95 rules to permit operation of PMR 446 radios in an amateur band without a reallocation proceeding.

In his Petition, Trahos also asserted that existing Part 97 Amateur Service rules precluding the use of PMR 446 radios in the US were "essentially unenforceable" and that granting his petition would have minimal impact on existing amateur operations. The ARRL contended, however, that there are "obvious" enforcement problems associated with the Petition.

"Non-technical, unlicensed persons operating transceivers in a core portion of one of the most popular and heavily used Amateur Radio allocations is a formula for serious interference," the ARRL. There would not be any way to police the use of the frequencies either, the ARRL continued, because the class of eligible unlicensed users would be "indistinguishable on-air from the remainder of the general population."

Trahos has proposed to permit operation at up to 0.5 W PEP output. The ARRL band plan for 70 cm designates 446.0 MHz as a national calling channel. Other frequencies in the segment are for simplex or repeater use. In the US, government radiolocation services are primary and Amateur Radio is secondary on that portion of the 70-cm band.

"If nothing else, this Petition reveals the problems that arise from the failure to harmonize allocations internationally," the ARRL noted. "Had the United States and CEPT [the European Conference of Postal and Telecommunications Administrations] taken steps to harmonize FRS channels internationally prior to creating the FRS in the first place, the problems reasonably noted by the petitioner might have been avoided."

The ARRL said the fact that European and UK users might be unaware of US communication laws or that they routinely violate them "is not a justification for legalization of that operation or de facto creation of a new service."

The Petition, RM-10521, and filed comments are available via the FCC's Electronic Comment Filing System (ECFS). Click on "Search for Filed Comments" and enter "RM-10521" (the ECFS is case-sensitive) in the "Proceeding" field. The comment period has expired.