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From: dhammill@smtplink.tvcom.com
Subject: Re[4]: My Spread Spectrum Letter to FCC
Date: Wed, 11 Dec 96 10:08:50 PDT

I think you got it backwards. ISM devices/Government services and Part 15 devices are NOT one and the same. Unlicensed Part 15 devices enjoy NO protection against interference from ANY source in ANY band.

73, Dan KB5MY

`______________________________ Reply Separator _________________________________ Subject: Re: Re[2]: My Spread Spectrum Letter to FCC Author: Bernie Doehner at TVCOMinternet Date: 12/10/96 9:47 PM

`Hi Art:


> Hey Bernie, are you a ham or a comm'l interest who is subscribed to our
> list? Don't see your callsign in the message, but your address is
> ''uhf.wireless.net". Interesting....

I am a ham. My call is NU1S.


> If 900 Mhz is to be considered a 'wasteland', then lets get ALL the part
> 15 devices and all the wideband SS stuff put on that band, that way we
> can protect our OTHER bands.

With all this talk about part 15 interference to ham operations I have to smile a little. I was in Germany in February. The German Telekom in their infinite wisdom allocated 430-440 MHz. to low power car lock remotes. I heard some interesting stories about ham transceivers interfering with car locks :)

Also.. I'd be interested in hearing from active 900 MHz. users in areas where there are active vehicle location systems (like Lojack). These systems operate in at least southern California with high power SS emitters on mountaintops (to fire off a UHF transmitter inside the stolen vehicle).

With all this talk about part 15 devices, we seem to be forgetting about the fact that the Amateur Radio Service is ONLY a secondary allocation in the 902-928 MHz, 2.4 Ghz., and 5.7 Ghz. bands and that ham radio operations are NOT allowed to cause harmful interference to part 15 devices and that ham radio operations are NOT protected from interference by part 15 devices. (part of the reason for the Amateur Radio Service not being protected from ISM devices is that they include things like microwave ovens, but I don't really understand why the converse applies too).

For your reference (from the FCC rules book): -------------------------- 97.303 (g) In the 33 cm band: (1) No amateur station shall transmit from within the States of Colorado and Wyoming, bounded on the south by latitude 39 N, on the north by latitude 42 N, on the east by longitude 105 W, and on the west by longitude 108 W.1 This band is allocated on a secondary basis to the amateur service subject to not causing harmful interference to, and not receiving protection from any interference due to the operation of, industrial, scientific and medical devices, automatic vehicle monitoring systems or Government stations authorized in this band. [ARRL Note: 97.303(g)(1) was waived in part by the FCC on July 2, 1990 to permit amateurs in the restricted areas to transmit on the following segments: 902.0-902.4, 902.6-904.3, 904.7-925.3, 925.7-927.3, and 927.7-928.0 MHz.]

(i) In the 13 cm. band: (2) In the United States, the 2300-2310 MHz segment is allocated to the amateur service on a co-secondary basis with the Government fixed and mobile services. In this segment, the fixed and mobile services must not cause harmful interference to the amateur service. No amateur station transmitting in the 2400-2450 MHz segment is protected from interference due to the operation of industrial, scientific and medical devices on 2450 MHz.

(m) In the 5 cm band: (3) No amateur station transmitting in the 5.725-5.875 GHz segment is protected from interference due to the operation of industrial, scientific and medical devices operating on 5.8 GHz. harmful interference to, nor is protected from interference due to the operation of, stations authorized by other nations in the radiolocation service. -------------------------- Many of you might not have noticed, but a lot of the bands allocated to the Amateur Radio Service are only secondary allocations.

`
> Even if done at ham power levels and with REAL antennas, the part 15 user
> is not provided with any protection because hams have the primary use of
> the band.

Incorrect, see above. Furthermore, please note that the highest primary allocation in the Amateur Radio Service is 222-225 MHz.!


> >> Obviously, 50 or 100 part 15 devices operating within a mile or 2 of
> >the
> >> weak signal user is going to create probs (whether ists SS or not).

Yes, and you won't be able to do a darn things about it.


> >So how much money are you prepared to pay to the FCC for exclusive
> >access to
> >902-928 MHz?
> >

(deep sarcasm was implied).


> Bernie OB, you missed the point-hams are a non-comm'l interest and cannot
> pay for spectrum. By expecting hams to compete for spectrum with the
> comm'l boys, well, obviously it can't happen. I hope the ARRL is working
> on this angle...we need special protection due to the non-$$$ limitations
> placed on us.

Agreed.


> Also, 902-928? I think you would find that part 15 devices are allowed to
> operate on ANY ham band, (not just UHF). A single video signal from your
> neighbors video baby monitor would wipe out 3.5 and 7.0 mhz bands in a
> single shot. Its not just 900 mhz that has a problem with part 15
> devices.

Right. Intentional and unintentional radiatiors. :(.

73

Bernie nu1s

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