AMA-FCC Frequency Efforts Continue

Edition: Model Aviation - 1975/10
Page Numbers: 45, 46

AMA-FCC Frequency Efforts Continue

Filed with the Federal Communications Commission in the matter of Amendment of Part 97 of the Commission's Rules concerning operator classes, privileges and requirements in the Amateur Radio Service, on behalf of the Academy of Model Aeronautics:

On December 16, 1974 the Commission released its Notice of Proposed Rule Making in the above captioned proceeding proposing to institute a comprehensive revision of the Amateur Radio Service license classes. The Academy of Model Aeronautics, Inc., by its attorneys, hereby files its Comment in this proceeding.
The Academy of Model Aeronautics, Inc. (hereinafter, the Academy), the Aeromodeling Division of the National Aeronautic Association, is the governing body for aeromodeling activities in the United States. Its current membership stands at 54,000.
The Academy has been very gratified over the years that the Commission has consistently recognized that model aircraft flying is a scientific hobby of substantial social value and public significance, and has allocated a number of Citizens Radio Service frequencies for this important activity. These frequencies, in the 27 MHz and 72 MHz bands, are the most suitable for modeler use in view of the relatively low cost of the equipment for these bands, thus making radio controlled aeromodeling activities available to the many young people whose interests in aviation are fueled by model aircraft activities early in life. Unfortunately, the 27 MHz band frequencies are adjacent to those used by the Class D Citizens Radio Service, some of whose members use them as "extra," unauthorized voice channels, and a few have actually engaged in the sport of "shooting down" radio controlled model aircraft, resulting in very substantial monetary losses for the modelers and creating a potential danger to spectators when radio control aircraft go out of control. The modelers have, both to spread out frequency occupancy, and to avoid the above problems, turned to the 72 MHz frequencies, but there are inherent limitations in that band because of the use of adjacent frequencies by television stations on channels 4 and 5. These problems have been fully explained in the Academy's Comments in FCC Docket No. 19759 and are incorporated herein by reference.
In short, in many areas of the country aeromodelers are having increasing difficulty in pursuing their activities in a safe manner on the frequencies now available for their use and the only practical solution appears to be access to other frequencies which are not subject to the difficulties now encountered. The Academy was therefore most interested in the Commission's proposal to create a Communicator Class operator license, having no telegraphy examination requirement, which would allow access to the Amateur Radio frequencies above 144 MHz. The Academy believes that this new class of license offers an opportunity for radio control modelers to qualify for such Communicator Class Amateur licenses and to alleviate the problems heretofore mentioned by their using frequencies above 144 MHz for model control purposes. The Academy also believes that such qualification and use will lead many modelers to upgrade their skills to qualify for the Technician Class license in order to be able to use the 50-54 MHz Amateur Band. Use of this latter band by the Technician Class Amateur licensees is now a widespread practice. The Academy estimates that about ten to fifteen percent of its membership, or about 5,000 modelers, hold Amateur licenses and use the 50-54 MHz band for their flying activities. Most of these licensees are of the Technician Class.
The Academy respectfully submits that making Communicator Class licensees eligible for model radio control activities is clearly in the spirit of this proceeding in that it is in consonance with the "logical relationship between the qualification requirements and the operator privileges authorized at each license level." However, as written, the proposed regulations appearing in the Appendix do not provide specifically for such activity on the part of Communicator Class licensees. Therefore, the Academy respectfully requests that the Commission:

a. Expand existing Rule Section 97.99 (Stations Used Only for Radio Control of Remote Model Craft and Vehicles) by adding a new subparagraph:

"e. Amateurs holding Communicator Class licenses may operate model radio control equipment under the provisions of this Section on amateur frequencies above 144 MHz."

b. Expand the proposed Rule Section 97.79 by including a fourth subsection:

"(4) Emission A-1 or A-2 solely under the provisions of Section 97.99."

The Academy also respectfully requests that consideration be given to continuation of the present Communicator Class license examinations and that the license, once obtained by such examination, be renewable. Further, the Academy requests that the Communicator Class license examinations be available from qualified retailsuppliers of model radio control equipment and that acceptance requirements for tests and renewals be reasonable. The Academy's reasons for such proposals include the following:

The bulk of the nation's radio control modeling activities are carried on by AMA affiliated clubs, most of whom have at least a few members with higher level Amateur licenses. These clubs provide classes to instruct members in the appropriate written and code requirements. With the Commission's proposed tightening of the conduct of mail examinations, it is believed that the Commission can be assured of adequate competency on the part of the successful candidates for the two license classes.
In the case of the several thousand model radio control flyers who have already successfully qualified for the Technician Class license, the Academy submits that those licenses were issued in good faith and that to require these individuals to travel to an FCC examining location in order to renew this class of license is an unwarranted hardship on the existing licensees.

In summary, the Academy recommends that, if the proposed rule making is adopted by the Commission, it be modified to include the following provisions:

a. Permit radio control activities by Communicator Class licensees on frequencies above 144 MHz.

b. Permit Communicator and Technician Class licenses to be obtained by mail examination, and to be renewable.

Respectfully submitted, The Academy of Model Aeronautics, Inc. By Jeremiah Courtney, Its Attorney, Washington, D.C., July 16, 1975.

The AMA Frequency Committee currently consists of the following: John Strong, chairman; Dr. Walter A. Good, Bethesda, Md.; Richard Jansson, Wellesley Hills, Mass.; Lt. Col. C. T. Williams, APO New York. Note: Bob Abele, Hauppauge, N.Y., joined the committee in July—his recent individual efforts were recognized by the committee and he was invited to join the group to broaden its representation; similarly, Jack Albrecht, San Francisco, replaced former California member Hugh Stock.

AMA-FCC Frequency Efforts Continue

The Academy of Model Aeronautics, Inc. (hereinafter, the Academy), the Aeromodeling Division of the National Aeronautic Association, is the governing body for aeromodeling activities in the United States. Its current membership stands at 54,000. The Academy has been very gratified over the years that the Commission has consistently recognized that model aircraft flying is a scientific hobby of substantial social value and public significance, and has allocated a number of Citizens Radio Service frequencies for this important activity.

These frequencies, in the 27 MHz and 72 MHz bands, are the most suitable for modeler use in view of the relatively low cost of the equipment for these bands, thus making radio controlled aeromodeling activities available to the many young people whose interests in aviation are fueled by model aircraft activities early in life. Unfortunately, the 27 MHz band frequencies are adjacent to those used by the Class D Citizens Radio Service, some of whose members use them as "extra", unauthorized voice channels, and a few have actually engaged in the sport of "shooting down" radio controlled model aircraft, resulting in very substantial monetary losses for the modelers and creating a potential danger to spectators when radio control aircraft go out of control.

The modelers have, both to spread out frequency occupancy, and to avoid the above problems, turned to the 72 MHz frequencies, but there are inherent limitations in that band because of the use of adjacent frequencies by television stations on channels 4 and 5. These problems have been fully explained in the Academy's Comments in FCC Docket No. 19759 and are incorporated herein by reference. In short, in many areas of the country aircraft modelers are having increasing difficulty in pursuing their activities in a safe manner on the frequencies now available for their use and the only practical solution appears to be access to other frequencies which are not subject to the difficulties now encountered.

The Academy was therefore most interested in the Commission's proposal to create a Communicator Class operator license, having no telegraphy examination requirement, which would allow access to the Amateur Radio frequencies above 144 MHz. The Academy believes that this new class of license offers an opportunity for radio control modelers to qualify for such Communicator Class Amateur licenses and to alleviate the problems heretofore mentioned by their using frequencies above 144 MHz for model control purposes. The Academy also believes that such qualification and use will lead many modelers to upgrade their skills to qualify for the Technician Class license in order to be able to use the 50-54 MHz Amateur Band.

Use of this latter band by the Technician Class Amateur licensees is now a widespread practice. The Academy estimates that about ten to fifteen percent of its membership, or about 5,000 modelers, hold Amateur licenses and use the 50-54 MHz band for their flying activities. Most of these licensees are of the Technician Class.

The Academy respectfully submits that making Communicator Class licensees eligible for model radio control activities is clearly in the spirit of this proceeding in that it is in consonance with the "logical relationship between the qualification requirements and the operator privileges authorized at each license level." However, as written, the proposed rules do not specifically authorize such use for model radio control and should be modified to expressly permit Communicator Class licensees to engage in radio control activities on Amateur frequencies above 144 MHz.

In summary, the Academy recommends that, if the proposed rule making is adopted by the Commission, it be modified to include the following provisions: a. Permit radio control activities by Communicator Class licensees on frequencies above 144 MHz. b. Permit Communicator and Technician Class licenses to be obtained by mail examination, and to be renewable.

Respectfully submitted,

The Academy of Model Aeronautics, Inc. By Jeremiah Courtney, Its Attorney, Washington, D.C., July 16, 1975.

Note: Bob Abele, Hauppauge, N.Y., joined the committee in July—his recent individual efforts were recognized by the committee and he was invited to join the group to broaden its representation; similarly, Jack Albrecht, San Francisco, replaced former California member Hugh Stock.

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