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ARRL General Bulletin ARLB008 (2000)

ARLB008 ARRL Asks FCC to Deny Kenwood Sky Command Petition

QST de W1AW  
ARRL Bulletin 8  ARLB008
From ARRL Headquarters  
Newington CT  February 4, 2000
To all radio amateurs 

ARLB008 ARRL Asks FCC to Deny Kenwood Sky Command Petition

The League says the FCC should deny a request by the Kenwood
Communications Corporation to permit operation of its ''Sky Command''
system in the 2-meter band. In December, Kenwood asked the FCC
either to declare that Sky Command complies with Commission rules or
to waive applicable sections of the rules to make it legal. The ARRL
filed comments on Kenwood's petition, DA 99-2805, on January 31.

Sky Command, which lets the user control a fixed HF station via a
pair of dual-band transceivers, has been on the market for more than
two years. Sky Command operates in full duplex, using a 70-cm
frequency to transmit audio and control commands to a dualband
transceiver at the remote station and a 2-meter frequency to
transmit received audio via the remote station's Sky Command
transceiver to the operator's transceiver.

The League maintains that Kenwood's use of a 2-meter frequency would
cause amateurs using the system to violate Section 97.201(b), which
limits auxiliary operation to certain frequencies above 222.15 MHz.

In its comments to the FCC, the League said the type of operation
employed by the Sky Command System is ''clearly auxiliary operation,
and as such is not permitted in the 144-148 MHz band.'' Kenwood had
asserted in its petition that the 2-meter link constitutes
third-party communications under the immediate monitoring and
supervision of a control operator. The League says the rules
governing third-party communications in the Amateur Radio Service
''relate to the content of messages, not to the technical
configuration of the amateur stations.''

Citing an already densely populated 2-meter band, the ARRL contends
that selection of appropriate frequencies for auxiliary operation is
essential to efficient use of the limited frequencies shared by
amateur stations.

In addition, the ARRL said carving out an exemption by waiving the
rules for Kenwood's product, would amount to ''inappropriate

In 1986, the FCC turned down a petition to remove frequency
restrictions on auxiliary operation. In its comments on the Kenwood
petition, the ARRL said the FCC's 1986 rationale for keeping the
restriction in effect remains, and nothing has occurred to make 2
meters any more appropriate now.

Comments on the Kenwood petition were due by January 31, 2000. Reply
comments are due by February 14, 2000. Commenters should reference
DA 99-2805. The full text of the ARRL comments are available off the
ARRL web site, in PDF


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