To: ALL RADIO AMATEURS DATE: THU AUG 04, 1988 FROM: DAVID SUMNER / MCI ID: 264-6149 SUBJECT: ARRL PRESS RELEASE FCC REALLOCATES 220-222 MHZ; ARRL VOWS TO FIGHT ON IN THE FACE OF OVERWHELMING PUBLIC OPPOSITION, THE FEDERAL COMMUNICATIONS COMMISSION TODAY ADOPTED ITS OWN PROPOSAL TO REALLOCATE THE 220-222 MHZ FREQUENCY BAND FROM THE AMATEUR SERVICE TO PRIVATE LAND MOBILE USE. THE REALLOCATION, PROPOSED BY FCC 18 MONTHS AGO TO ADDRESS WHAT IT SAID WERE CRITICAL LAND MOBILE NEEDS AND A DESIRE TO PROMOTE SPECTRUM-EFFICIENT TECHNOLOGY, ATTRACTED STRONG CRITICISM FROM THE NATION'S 435,000 RADIO AMATEURS AND THE MANY PUBLIC- SAFETY AND DISASTER-RELIEF ORGANIZATIONS WHO RELY ON AMATEURS IN COMMUNICATIONS EMERGENCIES. THE THOUGHTFUL PROTESTS OF MANY THOUSANDS OF CITIZENS BECAME A PART OF THE OFFICIAL RECORD OF THE PROCEEDING. DOZENS OF CONGRESSMEN EXPRESSED THEIR OWN OPPOSITION TO THE COMMISSION, AS DID THE DEPARTMENT OF DEFENSE, ON ITS OWN BEHALF AND THAT OF THE NATIONAL COMMUNICATIONS SYSTEM. YET IT WAS NOT UNTIL UNITED PARCEL SERVICE FILED COMMENTS, SIX MONTHS LATE, THAT A SIGNIFICANT USER OF THE PROPOSED NEW LAND-MOBILE BAND WENT ON RECORD AS DESIRING THE REALLOCATION. DESPITE THIS CLEAR TESTIMONY THAT THE ORIGINAL PROPOSAL WAS NOT IN THE PUBLIC INTEREST, THE COMMISSION'S ACTION APPEARS TO BE IDENTICAL TO ITS FIRST PROPOSAL WITHOUT REFLECTING ANY ADDITIONAL UNDERSTANDING OF AMATEUR SERVICE NEEDS. IN ITS PRESENTATION OF THE ITEM FOR COMMISSION CONSIDERATION, THE STAFF OF THE FCC OFFICE OF ENGINEERING & TECHNOLOGY STATED THAT THE REALLOCATION REPRESENTED JUST 2% OF THE PRESENTLY AVAILABLE AMATEUR SPECTRUM -- A FIGURE THAT WAS ECHOED BY CHAIRMAN DENNIS PATRICK. "WE'RE SHOCKED AND DISAPPOINTED AT THE COMMISSION'S ACTION," SAID LARRY PRICE, PRESIDENT OF THE AMERICAN RADIO RELAY LEAGUE, THE PRIMARY SPOKESMAN FOR AMATEUR RADIO IN THE UNITED STATES. "THE 2% FIGURE HAS NO BASIS IN FACT. AS WE'VE POINTED OUT THROUGHOUT THE PROCEEDING, THE 2 MHZ THE COMMISSION IS INTENT ON TAKING AWAY FROM THE AMATEUR SERVICE REPRESENTS MORE THAN 15% OF OUR INTERNATIONAL PRIMARY ALLOCATIONS BETWEEN 30 AND 24,000 MHZ." FCC TRIED TO SOFTEN THE BLOW BY SAYING THAT THE REMAINING 3 MHZ WOULD BE AVAILABLE TO AMATEURS ON AN EXCLUSIVE BASIS, AND BY EXPRESSING ITS CONTINUED STRONG SUPPORT FOR THE AMATEUR SERVICE. "IT'S NICE THAT THE COMMISSIONERS WANT TO BE SEEN AS SUPPORTERS OF AMATEUR RADIO, BUT ACTIONS SPEAK LOUDER THAN WORDS," OBSERVED ARRL EXECUTIVE VICE PRESIDENT DAVID SUMNER. "THE NOTION THAT EXISTING AMATEUR OPERATIONS BELOW 222 MHZ CAN ALL BE REACCOMMODATED IN THE REMAINING 3 MHZ IS FANCIFUL, AND NOT SUPPORTED BY THE PUBLIC RECORD. ON THE OTHER HAND, THE SPECTRUM EFFICIENCY OF NARROWBAND LAND MOBILE TECHNOLOGY HAS BEEN SERIOUSLY CHALLENGED IN ENGINEERING CIRCLES AND MAY IN FACT BE ILLUSORY. ABOUT ALL THAT CAN BE SAID FOR THE COMMISSION'S ACTION IS THAT IT PROVIDES A FERTILE FIELD FOR ARGUMENTS IN SUPPORT OF RECONSIDERATION OR REVERSAL." "WE'VE LOST A BATTLE, BUT NOT THE WAR," ARRL PRESIDENT PRICE COMMENTED. "THE LEAGUE WILL CONTINUE TO PURSUE EVERY AVAILABLE ADMINISTRATIVE, JUDICIAL, AND LEGISLATIVE REMEDY TO ENSURE THAT RADIO AMATEURS HAVE ACCESS TO THE SPECTRUM THEY NEED TO SERVE THE PUBLIC."