BREAKING NEWS FROM AMATEUR RADIO NEWSLINE FCC RULES THAT DIGITAL VOICE REPEATERS ARE REPEATERS
The FCC has ruled that the claim by some owners of digital repeaters and some frequency coordinators that digital voice repeaters are not actually repeaters due to the time delay inherent in digital to analog and analog to digital conversions is erroneous. In response to a request for a Declaratory Ruling on this issue from the Northern California Packet Association the FCC says that when a receiver and transmitter are tied together as a repeater it is a repeater. The full text of the FCC response to Gary R. Mitchell, President of the Northern California Packet Association is reprinted below. ARNewsline will have more on this issue in our next newscast to be released on Friday, March 27th. ARNewsline ** Text of FCC Digital Voice Repeater Decision Mr. Gary R. Mitchell President, Northern California Packet Association P.O. Box K Sunnyvale, CA 94087 Re: Petition for Declaratory Ruling filed December 5, 2007 Dear Mr. Mitchell: This is in response to the petition for declaratory ruling that you filed on December 5, 2007, requesting that the Commission clarify the definition of a repeater in the amateur service rules. A repeater in the amateur service is defined as "[a]n amateur station that simultaneously retransmits the transmission of another amateur station on a different channel or channels." You seek clarification of whether the word "simultaneously" in the definition refers to the signal information being retransmitted, or to the fact that the receiver and transmitter must both be active at the same time while acting on the same signal information. Section 97.205(b) of the Commission's Rules specifies the bands on which amateur repeater stations may operate. You state that some amateur radio operators are operating on bands other than those set forth in Section 97.205(b) with systems that are essentially voice repeater stations, but that digitize and retransmit the user's voice, on the theory that because there is a small delay in retransmitting the signal of another amateur station, the signal is not "simultaneously" retransmitted and, therefore, the system is not a repeater. Prior to 1994, a repeater was defined as "[a]n amateur station that automatically retransmits the signals of other stations." The Commission revised the definition in order to clarify that certain accommodations for message forwarding systems do not apply to other operating activities such as repeaters and auxiliary stations. The Commission proposed to define a repeater as "[a]n amateur station that instantaneously retransmits the transmission of another amateur station on a different channel or channels," but ultimately replaced "instantaneously" with "simultaneously" because commenters noted that there is always a small propagation delay through a repeater. As one commenter explained, "The word `simultaneously' in this case means that the repeater is receiving and transmitting concurrently, whereas each signal might be slightly displaced in time between receive and transmit." To be able to repeat another station's transmission, a repeater must be able to receive a transmission from another station and retransmit it. Because the word "simultaneously" in the definition is used to modify "retransmit," we believe it refers to a repeater station's transmitter being active when retransmitting the signal received by the repeater station's receiver from another amateur station. We conclude, therefore, that "simultaneously" as used in the definition of a repeater refers to the receiver and transmitter both being active at the same time. Accordingly, IT IS ORDERED that, pursuant to Section 4(i) of the Communications Act of 1934, as amended, 47 U.S.C. § 154(i), and Section 1.2 of the Commission's Rules, 47 C.F.R. § 1.2, the Petition for Declaratory Ruling filed on December 5, 2007 by Gary R. Mitchell IS GRANTED to the extent indicated above. This action is taken under delegated authority pursuant to Sections 0.131 and 0.331 of the Commission's Rules, 47 C.F.R. §§ 0.131 and 0.331. FEDERAL COMMUNICATIONS COMMISSION Scot Stone Deputy Chief, Mobility Division Wireless Telecommunications Bureau James KB7TBT www.kb7tbt.com