Remote base stations on a two meter repeater and the FCC rules
| Letter from the OO | Question to ARRL | Response from ARRL |
| Conclusion | Response to OO | FCC rules part 97 PDF / Text |
In a letter from the official observer:
Dear Fellow Amateur,
It is with great reluctance that I send this to you because I do not wish to stifle traffic net operation and net operators are becoming more difficult to find, but better a notice from an OO then a notice of apparent liability from the FCC.
Please read the following carefully:
Remote base stations are officially classed as an Auxiliary Station in accordance with 97.3a(7).
Part 97.201(b) states that auxiliary stations may transmit only on frequencies starting in the 1.25 meter band and shorter.
97.205 stipulates that a repeater may receive and transmit on specific FM frequencies. The frequency 3.9725, I am sorry to say, is not one of them.
If you use a two-meter frequency to control a remote base, (auxiliary station) you are in violation of 97.201(b). If you are using a two-meter FM to 75-meter SSB cross band repeater, you are in violation of 97.205.
Please refer to the "ARRL's FCC Rule Book", 12th addition pages 3-4, 3-5, 3-6, and 9-22 for further explanation.
Unless you have received a Special Temporary Authorization from the FCC for this type of operation it should be terminated.
If I have overlooked something please advise me.
Fraternally,
Rick, W8AIT (Note: Rick became KK8O just a few days after this letter was sent)
My question sent to [email protected]:
--------- Forwarded message ---------- From: [email protected] To: [email protected] Date: Mon, 4 Dec 2000 01:06:29 EST Subject: 2 meter to hf link Message-ID: <[email protected]> X-Mailer: Juno 4.0.11 MIME-Version: 1.0 Content-Type: text/plain Content-Transfer-Encoding: 7bit
Hi John, In the case of the 2 meter repeater using a HF remote base for two way communications, the repeater AND the HF radio can be controlled either from the repeater input or from the control link on 70 cm. Only the voice signals to and from the repeater are passed to the HF radio. Control of the HF radio is an ancillary function of the repeater for the users. The remotely controlled HF station in this case is NOT an auxiliary station, it's an ordinary station under remote control from the repeater OR an auxiliary station on 70 cm. It's voice communications are done under the rules for third party communications through the repeater since a repeater may automatically retransmit the signals of other amateur stations.
There is a question and answer in the section of the Rule book under third party traffic that says:
Q. I have a General class license. I'd like to retransmit a Technician licensee's 2 meter signal in the 20 meter General phone band. Is this legal? A. When a Technician's signals enter the 14 MHz band at a General class license's station, the operation involves third party traffic to the General class licensee. Such operation is permitted under the Rules, which do not specify the manner in which the third party traffic is received for relay: by mail, telephone, in person or by 2 meters.
There is no auxiliary station during this third party traffic operation, simply a repeater and a remotely controlled HF base station relaying third party traffic. In this case, the repeater control operator(s) is (are) also the control operator(s) of the HF station.
From your previous mailing I find:
"ANCILLARY" FUNCTIONS [1]
The FCC makes a distinction between functions which the repeater
users can perform (activating a crossband link, getting a weather or
time-of-day report, or making a phone call via the autopatch, for
example),
and those primary control functions reserved exclusively for the control
operators in effecting basic control of the station. The rules state
that "ancillary (which also means "secondary") functions of a repeater
that are available to users on the input channel are not considered
remotely controlled functions of the station" [97.205(e)]. These "user"
functions are conducted on the repeater's input frequency. However,
the primary control functions (turning the repeater on or off, for
example)
must be performed via the repeater's primary control system which is
separate from the input frequency. By the way, there is nothing to
prevent implementing some form of "emergency backup" means to shut down
a repeater via its regular input frequency, as long as the turn-on
function
can only be performed via the primary control system.
This distinction applies to crossband links and other functions. If the control operator enables a crossband link for use by a user by changing the repeater's command state through the control link, then users, including Technicians on a 2-meter repeater, may turn on and use the crossband link on the repeater input frequency to communicate with other hams on 10-meters. Changing the command state to allow users access to the crossband link is a "primary" control function. The user accessing the crossband link on the repeater input frequency is an "ancillary" function.
Below are the excerpts from Part 97 that I believe permit operation of a HF radio with a 2 meter repeater:
§97.3 Definitions.
(31) Message forwarding system. A group of amateur
stations participating in a voluntary, cooperative,
interactive arrangement where communications are sent
from the control operator of an originating station
to the control operator of one or more destination
stations by one or more forwarding stations.
(39) Repeater. An amateur station that simultaneously
retransmits the transmission of another amateur
station on a different channel or channels.
(46) Third-party communications. A message from the
control operator (first party) of an amateur station
to another amateur station control operator (second
party) on behalf of another person (third party).
§97.109 Station control.
(c) When a station is being remotely controlled, the
control operator must be at the control point. Any
station may be remotely controlled.
(e) No station may be automatically controlled while
transmitting third party communications, except a
station transmitting a RTTY or data emission. All
messages that are retransmitted must originate at a
station that is being locally or remotely controlled.
§97.113 Prohibited transmissions.
5(f) No amateur station, except an auxiliary, repeater or
space station, may automatically retransmit the radio
signals of other amateur stations.
§97.115 Third party communications.
(a) An amateur station may transmit messages for a third
party to:
(1) Any station within the jurisdiction of the United
States.
2(b) The third party may participate in stating the
message where:
(1) The control operator is present at the control
point and is continuously monitoring and supervising
the third party's participation; and
(2) The third party is not a prior amateur service
licensee whose license was revoked; suspended for
less than the balance of the license term and the
suspension is still in effect; suspended for the
balance of the license term and relicensing has not
taken place; or surrendered for cancellation
following notice of revocation, suspension or
monetary forfeiture proceedings. The third party may
not be the subject of a cease and desist order which
relates to amateur service operation and which is
still in effect.
§97.205 Repeater stations.
(e) Ancillary functions of a repeater that are available
to users on the input channel are not considered
remotely controlled functions of the station. Limiting
the use of a repeater to only certain user stations is
permissible.
§97.219 Message forwarding system.
(a) Any amateur station may participate in a message
forwarding system, subject to the privileges of the
class of operator license held.
If in fact this type of operation of a 2 meter repeater is not allowed under the Rules, I would have to assume that it is also not allowed for a 2 meter repeater to use a remotely controlled 2 meter radio to establish a link to another 2 meter repeater either. This ancillary function is common place in the amateur community today. I believe this information to be correct as stated in the FCC rules and it's discussion. If I've missed something, please help me find it.
Thanks again John for your time in this matter,
Tom Bert ARS KB8MFV [email protected]
Response received from the ARRL:
--------- Forwarded message ---------- From: "Price, Brennan, N4QX" <[email protected]> To: 'Tom D Bert' <[email protected]>, "Hennessee, John, N1KB" <[email protected]> Cc: "Race, George(Dir, Great Lakes)" <[email protected]> Date: Tue, 2 Jan 2001 15:02:35 -0500 Subject: RE: 2 meter to hf link Message-ID: <[email protected]> Received: from mx7.boston.juno.com (mx7.boston.juno.com [63.211.172.129]) by m2.boston.juno.com with SMTP id AAA7FEPJZAJTJ39S for <[email protected]> (sender <[email protected]>); Tue, 2 Jan 2001 15:07:51 -0500 (EST) Received: from kahless.arrl.org (mgate.arrl.org [209.140.206.214]) by mx7.boston.juno.com with SMTP id AAA7FEPJZAEHGHQS for <[email protected]> (sender <[email protected]>); Tue, 2 Jan 2001 15:07:51 -0500 (EST) Received: by kahless.arrl.org with Internet Mail Service (5.5.2650.21) id <ZF27LK3L>; Tue, 2 Jan 2001 15:02:43 -0500 X-Mailer: Internet Mail Service (5.5.2650.21) MIME-Version: 1.0 Content-Type: text/plain; charset="iso-8859-1" Return-Path: <[email protected]>
Tom,
It's important to differentiate among the three types of station control: local, remote, and automatic.
Under local control, there is an operator physically present at the station being controlled.
Under remote control (also referred to as telecommand in the commission's rules), the operator is at a remote point and executes control functions via some type of link, perhaps wireless, perhaps not.
Automatic control is allowed under very specific types of operations, and requires some type of automatic procedures to assure compliance with the Commission's rules.
If an amateur station--ANY amateur station--and I mean ANY amateur station--is to be contolled via radio-based REMOTE control, then such control MUST be carried out by an auxilliary station. The plain language of the second sentence of 97.213(a) clearly specifies this. Auxiliary stations are plainly limited to certain frequencies by 97.201(b).
Ancillary functions are non-control functions, such as autopatch, echo test, and SINAD. Under no circumstances can the remote control of an amateur station be an ancillary function of a repeater, regardless of whether the station to be remotely controlled is the repeater itself or some other station. Radio-based remote control of an amateur station, by the plain language of the second sentence of 97.213(a), must be carried out by an auxiliary station, not a repeater station.
Regarding the question you cite from the FCC rule book:
> Q. I have a General class license. I'd like to >retransmit a Technician licensee's 2 meter signal in >the 20 meter General phone band. Is this legal? > A. When a Technician's signals enter the 14 MHz >band at a General class license's station, the operation >involves third party traffic to the General class licensee. >Such operation is permitted under the Rules, which do not >specify the manner in which the third party traffic is >received for relay: by mail, telephone, in person or by >2 meters.
Notice that the HF station must operate under the call sign of the General Class operator (Technicians can't operate HF). The HF station must be under the control of General Class operator in one of two ways:
Under local control, the General Class operator is physically present at the HF rig and passes the Technician's VHF signal through. The remote control rules don't apply, because there is no remote control. The control operator is right there.
Under remote control, the General Class operator may remotely enable his station to retransmit the Technician's VHF sigs. The Technician Class operator is not in control of the HF station, because he's not allowed by virtue of his license class. The General Class operator is required to control his station, and if he utilizes radio to do so, he must use an auxiliary station.
Automatic control is not allowed here. It is only permitted for the control of auxiliary, repeater, and, with restrictions, beacon and digital stations. The HF station does not fall into any of these categories. The General Class operator must be actively controlling the station, either remotely or at site.
In summary, remote control of an HF station via a two meter repeater falls short of regulatory muster on several counts:
* Radio-based remote control must utilize an auxiliary station, not a repeater station. * Auxiliary stations may not operate on two meters. * While two meter signals may be passed as third party traffic, this must be done by an active, not automatic, controller of the HF station.
73, Brennan Price, N4QX Field and Regulatory Correspondent American Radio Relay League 860 594-0272 (work)
Since KB8MFV/R and the HF remote base radio can both be controlled locally or by remote control on frequencies above 222.15 MHz, and there is always a control operator present at the control point during the net, the operation is permitted. A lot of hoops to jump through... but it can be done!
From: Tom D Bert <[email protected]> To: [email protected] Subject: OO letter about HF remote MIME-Version: 1.0 Full-Name: Tom D Bert X-Status: New X-Juno-Att: 0 X-Juno-RefParts: 0
Hi Rick, I wanted to take a moment to thank you for your concern about my HF remote base operation on the repeater. It's good to know that there are people out there watching to keep us all legal. However, I think this whole situation could have been avoided if you would have asked me how I was controlling the HF rig. I'd have been more than happy to explain it to you. You mentioned in your letter that you had tried to get the operation stopped by contacting the individuals on the air several times... I had not heard your call or knew who you were until I received your letter. This kind of missed communication causes a lot of misunderstanding and unnecessary problems and delays for almost everyone. A few simple questions over the air might have avoided this whole scenario. I believe you are mistaken as to what an auxillary station is used for. From the FCC rules I find:
§97.109 Station control. (a) Each amateur station must have at least one control point. (b) When a station is being locally controlled, the control operator must be at the control point. Any station may be locally controlled. (c) When a station is being remotely controlled, the control operator must be at the control point. Any station may be remotely controlled.
Subpart C- Special Operations §97.201 Auxiliary station. (a) Any amateur station licensed to a holder of a Technician, Technician Plus, General, Advanced or Amateur Extra Class operator license may be an auxiliary station. A holder of a Technician, Technician Plus, General, Advanced or Amateur Extra Class operator license may be the control operator of an auxiliary station, subject to the privileges of the class of operator license held. (b) An auxiliary station may transmit only on the 1.25 m and shorter wavelength bands, except the 219-220 MHz, 222.000-222.150 MHz, 431-433 MHz and 435-438 MHz segments. (d) An auxiliary station may be automatically controlled. (e) An auxiliary station may transmit one-way communications.
ANY station may be remotely controlled, (the HF rig in this case). The radio that I use to control the HF rig is the auxillary station. When a station is remotely controlled, the controlling station is called an auxillary station... NOT the remotely controlled station. Again, if you would have asked me about it, this could have all been avoided. There is a silver lining to the story tho... I my efforts to find the definitive answer to the HF remote base on a 2 meter repeater question, I ran into two other repeater owners in my area that had gone through the same thing many years ago. Unfortunately, they were not able to provide me with the documentation that I needed to come to a conclusion. The Christmas/New year holiday caused about two weeks delay in getting an answer from the ARRL, but I now have the documentation I need. You should have received a copy of it about a week ago. According to the ARRL, there are several conditions that must be met to use a HF remote base on a 2 meter repeater, so it is possible that the rules COULD be violated. However, since I am able to locally or remotely control the rig on a radio channel above 222.15 MHz, it is legal. You should know that my repeater has been coordinated for several years now, and I was pretty sure that the HF remote base was being controlled properly. Now that the issue has been questioned, I am absolutely positive that what I am doing is legal and provided for in part 97 of the FCC rules. To ensure that other operators who may face this issue in the future have the resources they need to defend themselves, I have started a web page. Part of that page will be for the repeater, and in that area will be all the information on this subject that anyone would need to make sure they are operating within the rules. So again, a silver lining. I was looking for a good reason to start a web page about the repeater... you have given me the reason, and now any ham that wants to benefit from it can.
Thanks and 73, Tom Bert ARS KB8MFV
http://www.qsl.net/kb8mfv