Subject: [NEXTEL-1] N3NL Amateur Radio OperatorInterference Immunity & DTV

From: [email-masked]
Date: Fri, 08 Aug 2003 04:16:28 -0400

Reply Comments Nickolaus E. Leggett 1 ET Docket No. 03-65
Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC. 20554
In the Matter of

Interference Immunity  ET Docket No. 03-65
Performance Specifications
for Radio Receivers

Review of the Commission MM Docket No. 00-39
Rules and Policies Affecting the
Conversion to Digital Television

To: The Commission
REPLY COMMENTS of Nickolaus E. Leggett
N3NL Amateur Radio Operator to the Comments Submitted by the American Radio Relay
League

The following is a set of comments from Nickolaus E. Leggett, an amateur radio
operator (Extra Class licensee  call sign N3NL), inventor (U.S. Patents #
3,280,929 and
3,280,930 and one electronics invention patent application pending), and a
certified
electronics technician (ISCET and NARTE).  I also have a Master of Arts degree in
Political Science from the Johns Hopkins University (May 1970).

My comments are a reply to the comments submitted by the American Radio
Relay League, Inc (ARRL).

Background on Receiver Immunity Standards

The ARRL comments provide an excellent background on the history of receiver
immunity standards legislation (Reference 1).  Of particular interest is Senator
Barry
Goldwaters position that the regulation of these standards could not be left to
the
marketplace because of the lack of progress with attempts at voluntary standards
(Reference 2).

Consumer Electronics Immunity Standards

The ARRL correctly states that it would be very useful to establish stricter
immunity standards for consumer electronic devices.  This would limit the
fundamental
overload interference to consumer electronics from amateur radio, Citizens Band,
cellular
phones, and wireless systems.  The current practice of providing just 1 Volt/meter

protection is not adequate even in the case of low-power radio frequency (RF)
sources.
The current situation results in many amateur radio operators staying off the air
to
keep the peace in their neighborhoods.  The neighbors view the amateur radio
operators
as the ?source? of the interference even though the interference is actually due
to the
design of the consumer electronics equipment itself.  The design of the consumer
electronics devices and legal liability issues prevent the amateur radio operators
from
attempting to modify the consumer electronics devices to correct the problems.
Any standards applied to consumer electronics should also encourage the design
of products that are field repairable by suitably trained electronics technicians.

Receivers that Should Not be Governed by Interference Immunity Standards
The following types of receivers should not be subject to interference immunity
standards:

1.  As indicated by the ARRL, amateur radio is a basically experimental service
that should not be restricted by receiver immunity standards.  Amateur radio
operators are capable of building and modifying receivers that are not
susceptible to interference.  Therefore, amateur radio receiver design should
not be regulated, in order to encourage amateur radio experimentation.

2.  There should be no attempt to regulate the design of homemade radio
receivers.  This freedom encourages learning, experimentation, and the
making of various projects presented in radio magazines.

3.  Educational receiver kits are widely available for building receivers for AM,
FM, and short-wave broadcast reception.  These kits should not be required to
conform to interference immunity standards.  As a result of this freedom, the
kits will continue to be simple in design allowing students to learn the details
of component-level electronics theory, schematic diagram reading, circuit
assembly, and soldering.

I discuss the details of these important educational types of receivers in my
comments previously filed in this docket.
Poor People and Broadcast Receivers

A critical issue in this proceeding is its potential impact on poor people and
their
access to AM and FM broadcasts.  We all tend to forget that there are numerous
Americans who live in poverty or near poverty.  These people have a difficult time

affording ten dollars for a simple AM broadcast band pocket radio.  This problem
is made
more severe by the frequent thefts of property in poor neighborhoods.
We must make sure that receiver design standards or regulations allow very
inexpensive radio receivers to be manufactured and marketed.  This is especially
important as analog AM and FM broadcasts are eventually phased out in favor of
digital
broadcasting.

From a social science standpoint, it is vital for the poor to remain connected to
their communities by means of AM and FM radio broadcasts.  If new standards or
regulations increase the complexity and cost of all radio receivers, poor people
will be
shut off from access to community events.  This would create an underclass of
communications-disadvantaged people who would drift away from the American
mainstream community and values.

As a result of this basic social concern, the Commission should consider
modifying the ARRL request for consumer electronics receiver standards to allow
the
poor to have a chance to purchase very inexpensive receivers.
Broadband over Power Line and Receiver Standards
Any receiver standards established will have to include the operation of the
receiver under the influence of Broadband over Power Line (BPL) Internet service.
BPL
emits radio noise over a wide spectrum including much of the short-wave spectrum
(high
frequency).  Future receivers will need to be designed for this RF environment.
This will
be a significant engineering challenge.  Further information on BPL can be found
in ET

Suggested Actions

Educational receiver kits and homebuilt projects should be exempt from receiver
standards.  Any standards that are established should provide for the manufacture
and
sale of very inexpensive radio receivers.

Respectfully submitted,
Nickolaus E. Leggett, N3NL
Amateur Radio Operator ? Extra Class
1432 Northgate Square, Apt. 2A
Reston, VA 20190-3748
(703) 709-0752
[email-masked]
August 5, 2003

Reference 1: Comments from the ARRL submitted on July 21, 2003 (pages 3 through
9).
Reference 2: Comments from the ARRL submitted on July 21, 2003 (page 8).
Reply Comments  Nickolaus E. Leggett 6 ET Docket No. 03-65
Statement of Service
A copy of this reply comment has been sent to the American Radio Relay League
(ARRL) by USPS First Class Mail.

Mr. Christopher D. Imlay
Booth, Freret, Imlay, & Tepper, P.C.
14356 Cape May Road
Silver Spring, Md. 20904-6011
A copy has also been sent to the ARRL by electronic means.

http://svartifoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6514382294

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