In the Matter of AMENDMENT OF PARTS 2, 81, AND 83 --REDUCTION OF CHANNEL SPACING TO 25 KC/S, ALLOTMENT OF CHANNELS, ESTABLISHMENT OF REVISED TECHNICAL CRITERIA AND CATEGORIES OF COMMUNICATION IN THE MARITIME MOBILE SERVICE BAND 156-162 MC/S FOR VHF RADIOTELEPHONY
Docket No. 17295
FEDERAL COMMUNICATIONS COMMISSION
13 F.C.C.2d 874; 13 Rad. Reg. 2d (P & F) 1691
RELEASE-NUMBER: FCC 68-740
July 17, 1968 Adopted
REPORT AND ORDER
BY THE COMMISSION: COMMISSIONER JOHNSON CONCURRING AND ISSUING A STATEMENT.
[*874] 1. A Notice of Proposed Rulemaking in the above-captioned matter was released on March 20, 1967, and was published in the Federal Register on March 24, 1967 (FCC 67-320, 32 F.R. 4501). By its Order, released April 25, 1967, the Commission granted an extension of time in which to file comments. In the Notice, the Commission proposed to amend its rules governing stations in the Maritime Services to provide, in the band 156-162 Mc/s, for the transition from a channel spacing of 50 kc/s to 25 kc/s, including changes in technical standards, allotment of available channels, modification of existing or establishment of new definitions of types of communication, establishment of dates for effecting the changeover, and for availability of the new channels.
2. Comments were filed by: American Merchant Marine
Institute, Inc. (AMMI), American Telephone & Telegraph Co. (A.T. & T.),
Bendix Marine Division (Bendix), F. Ritter Shumway, Harbor Carriers of the
3. In the Notice the Commission set forth the objectives of its two-part program to effect improvement in radiotelephony and safety communications in the maritime mobile service. This two-part program involves substantial changes in the rules in regard to, as the first part, the band 156-162 Mc/s to which this Report and Order relates; and, as the second part, the band 2000-2850 kc/s. The nature of the maritime mobile service communication problem and the method of use of the frequencies in the two bands make it necessary to jointly consider the two bands. This is briefly amplified in paragraph 5, below.
4. Changes in the rules relating to use of VHF are set forth in the following paragraphs; the proposals applicable to the band 2000-2850 kc/s will be treated in a separate proceeding.
5. In brief, the number of frequencies at 2 Mc/s, even after conversion to single sideband are and will be insufficient to handle the quantity of communication generated by vessels presently equipped with radio. Further deterioration of this situation is inevitable due to the rapid growth in number of recreational vessels; the number of licensed vessels is increasing at the rate of 1,000 per month. Many of these vessels confine their operations to within VHF range of shore and do not require communications over distances as great as that obtainable from 2 Mc/s, under conditions where interference and congestion are not controlling. With respect to the useful communication range of VHF as compared to 2 Mc/s, it has been shown n1 that the normal communications range of 2 Mc/s, in the absence of congestion and interference, is substantially greater than that of VHF. There, relative wave propagation characteristics in no way detract from satisfaction of the communication needs of recreational vessels. To the contrary, these characteristics can and should be employed to provide relief to the current congestion and interference on 2-Mc/s frequencies. The Commission is, therefore, specifying the following order of priority in availability of VHF and 2 Mc/s: Shorter distance communication may be satisfied through use of VHF; and longer distance communication, beyond the useful range of VHF, may be satisfied through use of 2 Mc/s. In the view of the Commission, considering the complex nature of the problem here involved, the application of this order of priority is essential to improvement and future development of maritime mobile service communications and the radio safety system of that service.
n1 "Comparison of the Theoretical Range of 2182 kc/s and 156 MHz Voice Communication Over Sea Water and Fresh Water," by George W. Haydon, ESSA.
6. Two of the comments, one filed by F. Ritter
Shumway, who represented himself as the operator of a 55-foot motor sailer
operating entirely in the Great Lakes, and the second filed by the River
Operations Committee, composed of operating personnel from the major common
carriers on the Mississippi River system and tributaries, expressed objections
to the Commission's proposals. Sumway presented as his primary objection the
date of January 1, 1971, when the new regulations would be mandatory for all
VHF-FM transmitters in the maritime mobile service. He stated as an opinion that it would seem [*876]
advisable to require all equipment sold after 1970 to be capable of
conversion to narrow band operation but that conversion should not be required
until a date "well in the future," such as 1977. Shumway also had reservations concerning the
ability of the pleasure boatman to keep highly sophisticated equipment in
operation. Thirdly, he was concerned that the
7. The rationale followed by the Commission in developing the technical specifications for the VHF-FM 25-kc/s channeling system, including the dates for implementation, are developed elsewhere in this Report. One additional objection presented by Shumway, however, has been treated implicitly; i.e., channel spacing of 30 kc/s should be adopted rather than 25 kc/s. Shumway stated from the viewpoint of cost it is essential to use land mobile equipment which has the 30-kc/s channel spacing. He stated further his understanding that reduction of spacing from 30 kc/s to 25 kc/s involves substantial technical problems including circuits and components which, in his language, "will defeat a part of the very stated purpose of the FCC * * *." The possibility of using 30-kc/s channeling was considered, and a 30-kc/s channeling system would work. The loss of new channels at 30 kc/s would not alone have caused the Commission to decide in favor of 25-kc/s channels; however, international agreement has been reached on 25kc/s channeling. In addition, the transitional period with 50- and 30-kc/s operation in the band would have posed very serious operational problems which are avoided by the program adopted. Our understanding of the position presented by the manufacturers also does not indicate unreasonable problems in developing and marketing 25-kc/s transmitting equipment. With respect to Shumway's concern about the more sophisticated equipment necessary for 25-kc/s channels, we note that satisfactory narrow band equipment has been available on the market for some time and that the industry is generally considered to be capable of producing satisfactory marine equipment.
8. The River Operations Committee feels that
river operations on the
9. It is recognized that all operational
requirements are not identical. The needs in the rivers are not the same as in
10. Several of the comments (AMMI, A.T. &
T., International, LCA,
11. The NPBOA requested the Commission to amend the rules to facilitate use of VHF by a category of vessels which carry passengers for hire, the area of operation of which is restricted by the U.S. Coast Guard to within 20 miles from a harbor or refuge, and whose communications come under part III of title III of the Communications Act of 1934, as amended. No opposing views were filed. These communications come under part III of title III of the Communications Act of 1934, as amended. No opposing views were filed. These vessels currently employ double sideband (DSB) radiotelephony on frequencies of 2 Mc/s. Their communication requirement could be satisfied through use of VHF and, at such time as conversion of 2 Mc/s to single sideband (SSB) becomes mandatory, would prefer to employ VHF. In this comment it was pointed out that the shift of these vessels to VHF, when conversion to SSB becomes mandatory, would contribute to the reduction of congestion on 2-Mc/s frequencies. Additionally, it was pointed out that by converting from DSB to VHF, on or about January 1, 1971, this category of vessel could eliminate many of the complications arising from the conversion from DSB to SSB.
12. The Commission concurs that the shift of these vessels to VHF, instead of to SSB, would have the stated effect of reducing congestion and would reduce the complications of the vessel operators during the period of conversion. In addition, the communications service obtained by the vessel operators on VHF would probably be improved over that obtained with DSB at 2 Mc/s. Such vessels, when carrying passengers for hire, would meet the criteria contained in the definition on "Commercial Communications" and would, therefore, employ the [*878] frequencies allotted for "Commercial Communications." The use of VHF by these vessels is currently permitted by section 83.514(a) of the rules, where they are never more than 20 miles from a public coast station. This limitation in the current rules was adopted prior to implementation by the U.S. Coast Guard of its nationwide system of VHF. Inasmuch as the intent of section 83.514(a) can be equally fulfilled by communication capability with these U.S. Coast Guard stations, the Commission has adopted the amendment of section 83.514(a).
13. In connection with establishing 156.80 Mc/s as the VHF distress, safety, and calling channel, the NPMRC recommended that the rules be amended to:
(a) Require that all VHF limited coast stations, other than Marine Utility stations, maintain, transmit and receive capability on 156.80 Mc/s; and
(b) Prohibit calling on any frequency available for internship working unless it is known that the called ship maintains a simultaneous watch on such internship working frequency and on 156.80 Mc/s. In the view of the Commission, such action is in accord with the objective of establishing 156.80 Mc/s as a national distress frequency. This comment is, thus, directly responsive to the Notice. No opposing comments were filed. The consequence of amendment of the rules as proposed, relative to vessels which use VHF, will be to minimize the number which do not guard 156.80 Mc/s, increase the guard on 156.80 Mc/s, reduce the probability that calls will go unheard, and, thus, improve the effectiveness of 156.80 Mc/s as the national VHF distress frequency. Further, amendment of the rules as recommended will be in accord with the Commission's decision (docket No. 16082) to support the ITU principles of a compatible system and the "calling-working" frequency concept of communications in the VHF maritime mobile service band. The recommendation, when implemented, will provide needed improvement in the maritime radio safety system.
14. It is apparent that the first recommended rule change will have impact upon those VHF limited coast station licensees currently authorized to operate on VHF frequencies, but which do not now provide transmit and receive capability on 156.80 Mc/s. The second recommended rule change is procedural insofar as it applies to vessels equipped with multi-channel VHF transmitters and receivers, since it is believed all multi-channel VHF equipment includes the frequency 156.80 Mc/s.
15. For the above reasons, the Commission is adopting these two recommendations and has amended the rules to impose these requirements effective March 1, 1969.
16. In the Notice the Commission proposed that the channel designators for the new interspaced channels (intermediate between existing 50-kc/s channels) be composed of (a) the number of the next lower channel, followed by (b) the letter "A" or "B." Thus, the interspaced channel between channels 5 and 6 was designated channel "5A"; the [*879] interspaced channel between channels 6 and 7 was designated "6A," etc.
17. The WARC, on the other hand, agreed to a different system of channel designators in which the interspaced channels start, at the low frequency end of the band, with the channel designator 60 and stop, at the high frequency end of the band, with channel designator 88. The two new channels at 156.75 and 156.85 Mc/s, derived from reduction of the guard bands on either side of 156.80 Mc/s were designated as channels 15 and 17, respectively. The reduced guard bands on either side of 156.80 Mc/s were designated as 75 and 76.
18. From the point of view of
19. In regard to the frequency tolerance, in the band 156-162 Mc/s, to be applied to ship station VHF transmitters for operation with a channel spacing of 25 kc/s, the Commission proposed in its Notice a tolerance of 0.001 percent (10 parts per million), or one-half of the tolerance currently applicable for a channel spacing of 50 kc/s. Of the 28 comments filed, only seven parties n2 directed comments to the value of tolerance to be applied. Of the seven commenting, five n3 supported the Commission's proposal. Two n4 expressed the view that a tolerance of 0.0005 percent (five parts per million) should be applicable, paralleling the tolerance of 0.0005 percent which is currently applicable to the land mobile service.
n2 A.T. & T., AWO, Konel, Kaar,
n3 AWO Kaar Konel,
n4 A.T. & T., Tug Com.
20. As between a tolerance of 0.001 percent and that of 0.0005 percent, the requirement in the VHF maritime services is for an equipment that has multi-channel capability. In the land mobile service, the majority of current equipment is single frequency. While it is technically possible and within the state of the art to produce a multi-channel equipment which will maintain a tolerance which is equal to, or which is substantially "tighter" than 0.0005 percent, no information is available to indicate this is economically feasible for practical equipments in the maritime mobile service. On the basis of information available to the Commission, there would be economic hardship from the requirement that multi-channel ship station equipment in the VHF maritime mobile service conform to the same frequency stability as single frequency equipment in the land mobile service. Since a major objective of this rulemaking is to facilitate increased usage of VHF by both commercial and noncommercial vessels, the Commission is amending its rules to provide for ship stations operating in this band a frequency stability of 0.001 percent (10 parts per million).
21. In regard to the frequency tolerance, in the band 156-162 Mc/s, to be applied to coast station VHF transmitters for operation with a channel spacing of 25 kc/s, the Commission proposed in its NPRM a [*880] tolerance of 0.00025 percent (2.5 parts per million). Of the 28 comments filed, only five n5 parties directed comments to the value of tolerance to be applied to coast station transmitters. Of the five parties commenting, one n6 supported 0.00025 percent, two suggested n7 0.0005 percent, and two n8 suggested 0.001 percent. Of these five companies, two n9 were operating licensees (one favored 0.0005 percent and the other 0.00025 percent) and three n10 were manufacturers (two favored 0.001 percent and the other 0.0005 percent).
n5 Kaar, Konel,
n7 Kaar, Tug Com.
n8 Konel, RCA.
n10 Kaar, Konel, RCA.
22. With increased usage of VHF, a large number of current and future short-distance communication requirements can and should be fulfilled with a coast station transmitter output power of 3 w or less. Since the interference-creating capability at this power level is low, a tolerance of 0.001 percent is adopted. On the other hand, the interference-creating capability will be maximum at output power levels above 100 w. The Commission is, therefore, adopting a tolerance of 0.00025 percent for coast station transmitter output powers above 100 w. For the remaining transmitters, operating with output powers between 3 and 100 w, inclusive, the Commission is adopting a tolerance of 0.0005 percent. The adopted frequency tolerance versus output power are set forth in the following table.
Frequency tolerance Transmitter output power (watts) Percent Parts per million (10 n6)
Below 3 0.001 10
3 to 100 .0005 5
Above 100 .00025 2.5
23. In regard to the dates on which the above ship and coast station frequency tolerances become effective, the Commission proposed in the Notice that the new tolerances be brought into force, applicable to all VHF ship and coast station transmitters, on January 1, 1971. In the comments filed, it was argued that a longer period should be provided. Accordingly, the requested adjustment has been made, as follows:
VHF Ship Stations. -- The tolerance of 0.001 percent is applicable to types of transmitters type accepted after March 1, 1969, and to all ship station VHF transmitters after January 1, 1974. A tolerance of 0.002 percent is applicable until January 1, 1974, to types of VHF ship station transmitters type accepted prior to March 1, 1969. The Commission intends to withdraw type acceptance for all VHF ship station transmitters which are not type accepted for a tolerance of 0.001 percent on January 1, 1974.
[*881] Frequency Deviation
24. The Commission proposed that on January 1, 1968, all VHF radiotelephony transmitters, operated in the band 156-162 Mc/s in the maritime mobile service, reduce the (modulation) frequency deviation from +-15 kc/s to +-5 kc/s. A substantial number of the comments filed urged that a decision be postponed until the results of consideration at the WARC were available. In view of the reasonable nature of the request, no action was taken to implement this proposed requirement and the date of January 1, 1968, has passed.
25. The results of the WARC in regard to the integral steps for transition from a channel spacing of 50 kc/s to 25 kc/s are now available. These integral steps include:
(a) Increase ("tightening") of frequency tolerance from 20 parts to 10 parts per million;
(b) Improved receiver selectivity for operation with a channel spacing of 25 kc/s; and
(c) Reduction of (modulation frequency deviation from +-15 kc/s to +-5 kc/s .
26. The matter of "tightening" of frequency tolerance is treated separately in other paragraphs in this Report and Order.
27. Many of the comments filed discussed various difficulties with VHF receiving equipment during the transition period. In that regard, the situation existing nationally closely parallels the international situation. The WARC discussed in detail the various conditions which will arise during the transition in frequency deviation from +-15 kc/s to +-5 kc/s. The WARC recognized that the wide latitude of different operational conditions could not be adequately satisfied by a single solution. It, therefore, did not develop a specific procedure for effecting the reduction of frequency deviation; it left open the matter of whether the reduction would be effected in a single step or in multiple steps; it recognized that administrations having a pressing need for an increased number of channels may effect the transition to a channel spacing of 25 kc/s in advance of the dates adopted. In consequence, the WARC decided to provide a period of 1 year in which to complete the transition to +-5 kc/s. The WARC accepted that there would be an intermixture of +-15 kc/s and +-5 kc/s frequency deviation during the transition period.
28. In paragraph 44 of the Notice the statement was included that a receiver the detector of which was adjusted for a frequency deviation of +-5 kc/s will not satisfactorily demodulate a frequency deviation of +-15 kc/s. Since that time, one manufacturer n11 of marine VHF equipment conducted comparative tests regarding reception of "wide-band" frequency deviation transmissions, first, on a "wide-band" receiver and, second, on a "narrow-band" receiver to ascertain the relative intelligibility, tape recorded the results, and (informally) supplied a copy of the tape to the Commission. No other operating agency or manufacturer has submitted test information bearing on this subject. Based on available information, it is concluded that a "narrow-band" receiver will acceptably receive a frequency deviation of +-15 kc/s. [*882] Inasmuch as (1) was are only concerned with this technical point for the duration of the transition period, where an intermixture of +-5 kc/s and +-15 kc/s frequency deviation would exist, and (2) the duration of the intermixture period for most vessels, in regard to stations with which they routinely communicate, will vary from location to location, no further or exhaustive study of this point is considered necessary.
29. In regard to VHF receiving equipment, paragraphs 39 through 44 were included in the Notice to assure that appropriate consideration was given to the impact of the proposed rule amendments upon VHF receiving equipment. The attitude of the Commission relative to modification of existing VHF receiving equipment was expressed in paragraph 42 of the Notice, as follows:
42. In the view of the Commission, it will be desirable for the licensees to modify their VHF receiving equipment for "narrow-band" operation. The decision to modify receiving equipment is at the option of the licensee. However, it must be recognized that failure to modify could result in the reception of unwanted signals on the adjacent 25-kc/s channels, when implemented in the area of concern.
30. This continues to be the view of the Commission. Solution to the difficulties with VHF receiving equipment can best be overcome by the licensee, since he is in a position to determine the nature of the problem and the corrective action which introduces the least adverse impact upon his system. However, appendix 19 to the ITU Radio Regulations sets forth general requirements for VHF receiving equipment.
31. The comments filed indicated no particular difficulty in regard to modifying ship and coast station transmitters to reduce the (modulation) frequency deviation from +-15 kc/s to +-5 kc/s. In reference to he conversion to +-5 kc/s frequency deviation of transmitters aboard U.S. vessels in advance of other administrations, one of the comments called attention to the circumstance that: (a) For internship communications, U.S. vessels would employ +-5 kc/s and foreign registry vessels would employ +-15 kc/s; and (b) for ship to coast communications, U.S. vessels would transmit to foreign coast stations with +-5 kc/s, while foreign registry vessels would transmit to the same coast (stations) with +-15 kc/s.
32. In view of the foregoing and based on the
need to increase the number of VHF channels available in the United States at
the earliest practicable date, the Commission has adopted rule amendments. As adopted, a period ending March 1, 1969,
is provided in which to complete adjustment of transmitters used aboard ship
and at coast stations to reduce the frequency deviation from +-15 kc/s to +-5
kc/s. Further, in regard to internship
communications, the Commission does not foresee the development of a mandatory
requirement, during the transition period, that
[*883] VHF Transmitter Power Ship Stations
33. Bendix suggested that a maximum output power limit of 35 w be established for VHF transmitters to be operated in the band 156-162 Mc/s. No opposing views were expressed. In that regard, the WARC adopted a common worldwide maximum carrier power limit of 25 w, which is applicable to equipment to be brought into service after January 1, 1970. Since a maximum power limit is an essential element to the design and development of new transmitters, the Commission is adopting 25 w.
34. To minimize harmful interference in areas of high density shipping, such as in harbors, ports, canals, and rivers, or inland waters, the WARC adopted the additional mandatory provision that ship station VHF transmitters have the capability to reduce, readily, the effective radiated power (ERP) to 1 w or less. The inclusion of this capability in new equipment has been recommended by the Intergovernmental Maritime Consultative Organization. The Canadian and other administrations have urged early provision of this capability in their respective waters. Since the term "effective radiated power" includes system elements which are in addition to the power of the transmitter, a more readily usable designation of power is required for type acceptance purposes. Inasmuch as the intent of the WARC is fulfilled by use of an output power of 1 w (or an input power of 2 w), that value is adopted.
35. The benefits of the lower power include reduction of inter-modulation interference, receiver detuning, and receiver desensitization arising from excessive RF input levels. By limiting the requirement that this capability be included in all future ship station transmitting equipment, type accepted after September 3, 1968, no adverse impact is imposed on existing licensees. On the other hand, as a technical characteristic applicable to new equipment, manufacturers should be apprised, at the earliest practicable date, of the requirement that such capability is to be incorporated into future equipment. Since this Report and Order sets forth other technical characteristics applicable to new VHF equipments, it is appropriate and timely to include the foregoing technical requirement. Accordingly, rule amendments appropriate thereto are adopted. Coast Stations
36. The rules presently permit public coast stations to use up to 250 w input in the band 156.765-161.625 Mc/s and up to 1,000 w input in the band 161.775-162.025 Mc/s. In other bands, VHF limited coast stations are permitted up to 100 w input. Several of the comments filed expressed concern in regard to the increase in inter-modulation interference which will accompany the reduction in channel spacing from 50 to 25 kc/s. The severity and scope of this type interference is made worse by use of higher power. As outlined under "ship stations," above, this matter was deemed to be of sufficient importance by the IMCO and WARC to require that new ship station transmitters have a maximum output power limit of 25 w, and include the capability to reduce this power to an effective radiated power of 1 w or less.
[*884] 37. The use of higher power is desirable, necessary, and can be justified where it is intended that communication be provided over the maximum possible distance, for example, in the case where the tropospheric propagation mode is to be employed. While the Commission will consider and, where justified, will grant authorization to use tropospheric techniques in the VHF maritime mobile band, it is not the intent of these rules to provide for use of such techniques on a routine basis. As between the two terminals, the coast station and the ship station, the coast station is in the advantageous position in regard to height and gain of transmitting and receiving antennas, use of specialized receiving equipment, selection of site to minimize local noise, use of receivers at multiple locations, and availability and regulation of primary power. In regard to recreational boats and smaller commercial transport vessels, the choices regarding antenna location, height, and directivity are limited, use of separate receiving and transmitting antennas and specialized receiving equipment is not practicable, the level of local noise is higher, primary power regulation is less than optimum, and use of multiple receivers is unlikely to be feasible. In regard to larger commercial transport vessels, the situation will be improved, but will be less advantageous than can be provided at coast stations.
38. As between the coast station and ship station, for equal power at the transmitter output terminals, the coast station can place a higher signal level at the ship station, and, for the above reasons, the coast station can satisfactorily receive a signal below the level which can be satisfactorily received aboard ship. Because of the lesser receiving capability at the ship station terminal, the signal provided to the ship station from the coast station must be higher than that in the opposite direction. While higher transmitter power at the coast station provides a simple solution, the situation in regard to inter-modulation interference in and to receivers in the vicinity of the coast station is worsened. The proper solution for coast station transmitter power lies in the use of the minimum power necessary to provide the required service, after the other factors have been applied, that is, the area to be covered has been determined, selection of site, height, and gain of receiving and transmitting antennas, and type of receiving equipment.
39. Turning now to the provisions of section 81.134(d) and the transmitter power permitted public coast stations, it will be noted that, in the band 156.675-161.625 Mc/s, a maximum input power of 250 w is permitted and, in the band 161.775-162.025 Mc/s, a maximum input power of 1,000 w is permitted. With the output power of ship stations limited to 25 w (50 w input power), a ratio of public coast station to ship station power of 5 to 1 and 20 to 1 respectively, is permitted. As outlined in paragraphs 37 and 38, above, it is possible for the coast station to employ techniques and equipment not readily applicable to ship stations. The Commission is of the view that the practical requirements are adequately fulfilled by a ratio of coast station to ship station power of 2 to 1. This ratio is subject to the conditions that the power used by coast stations shall be the minimum necessary for the service to be provided, and, further, that higher power may be authorized [*885] to coast stations where a satisfactory showing of need has been made.
40. For the foregoing reasons, the Commission is amending section 81.134 of the rules to limit the output power of coast stations to 50 w or less. All licenses granted after the effective date of this Report and Order will be issued with a power limitation of 50 w or less, unless a satisfactory showing of need for power in excess of 50 w has been made.
Postlimiter Audio Rolloff Filter
41. The Commission proposed in this docket that, in the band 156-162 Mc/s, all radiotelephony transmitters in the maritime mobile service be provided with a postlimiter audio rolloff filter. Of the 28 comments filed, only five n12 parties directed comments to the matter of including the postlimiter audio rolloff filter in vhf/ radiotelephony transmitters. Three n13 of the five comments supported inclusion of the filter; however, one of the comments, n14 additionally, recommended the value of attenuation be the same as that applied to other services; and one of the comments, n15 additionally, recommended that the filter be required in new equipment only. Two of the five comments n16 offered no objection to including the filter, but recommended that the Commission indicate the desired technical specifications rather than a specific electronic circuit.
n13 AWO, RCA, AMMI.
n16 RCA, Raytheon.
42. As concerns the comment n14 that the value of attenuation called for by the postlimiter audio rolloff filter should be the same for all services, it is correct that the value proposed for parts 81 and 83 is higher than the value currently appearing elsewhere in the rules. The Commission concurs that where the channel spacing and method of deployment of channels is the same, the value of attenuation should be the same for all parts of the rules. In the land mobile services in the bands at 150 Mc/s, the channel spacing is 30 kc/s, whereas, in the marine services, the channel spacing will be 25 kc/s.
43. With respect to the comment n15 that the addition of the postlimiter audio rolloff filter should be limited to new equipment, the Commission is unable to agree that current equipment should be exempt from inclusion of this filter. The Commission believes, however, that a transition period should be provided and, accordingly, is specifying a date by which this filter must be included in current equipment. The requirement that a postlimiter audio rolloff filter be included in radiotelephone transmitters operating in the band 156-162 Mc/s was based on tests conducted in the land mobile service, where it was shown that noise spectra (splatter) of FM transmitters was substantially reduced by the addition of the proposed filter. The filter minimizes unauthorized radiations beyond the authorized channel and into both adjacent channels. Reduction of these radiations makes the adjacent channels more usable, practically, by permitting reception of "weaker" signals, which is interpreted in terms of increased communications [*886] range. The benefit from inclusion of this filter is to the users of the adjacent 25-kc/s channels; no benefit accrues to the same channel user. In the view of the Commission, the minimization of extra-channel radiation is an essential element in its program to reduce the channel spacing in the band 156-162 Mc/s from 50 to 25 kc/s. Accordingly, the rules as adopted provide a transition period of 5 years for ship stations and 2 years for coast stations during which current equipment may be modified.
44. The recommendation n17 that the Commission indicate the desired technical specification, rather than a specific electronic circuit, is based on two points:
(a) The Commission does not have requisite authority under the Communications Act of 1934, as amended, citing section 303(e); and
(b) The effect of the proposed amendment "* * * could well be to prevent improvement in such equipment in keeping with advancement in the art."
45. With respect to (a) in the preceding paragraph, RCA maintains that the Commission's authority is limited to the regulation of the kind of apparatus to be used with respect to its external effects and the purity and sharpness of the emissions. Accordingly, the commentator concludes that the requirement with respect to the postlimiter audio rolloff filter is beyond the statutory authority of the Commission. The main thrust of this rulemaking is to implement those portions of WARC applicable to the maritime mobile service band 156-162 Mc/s. For the reasons stated below the filter requirement is considered necessary to carry out the provisions of WARC. The statutory authority for this requirement, therefore, is section 303(r). In addition, we feel that the proposed amendment does not require a "specific electronic circuit." The amendment specifies (1) the characteristics of a filter; and (2) where in the transmitter the filter shall be placed.
46. In regard to (1), RCA offered no objection to the values which the Commission has specified for the filter and it, therefore, is concluded that these values are acceptable, and that the specification of values for a filter is not outside of Commission authority.
47. In regard to (2), RCA and Raytheon do not state: (i) The filter should or could be located at another point in the transmitter; (ii) if located elsewhere, the filter would be equally effective; and (iii) if set forth as a technical specification, the manufacturer would place the filter at some other point in the transmitter. Further to (2), attention is called to the following rule sections: 21.508(f), 21.605(e), 21.704(b), 81.111(h), 87.73(g), 89.109(d), 91.105(g), and 93.105(g). These sections specify the point in the transmitter at which a filter shall be placed.
48. In regard to the phenomenon here involved, the Commission has no information which supports a technical view that the required attenuation may be obtained by locating the postlimiter filter elsewhere in the transmitter. The comments submitted are silent in that regard. While it is possible to include in the rules a technical specification applicable to the spectrum radiated at the transmitter output, there are practical reasons which indicate the "technical specification" approach [*887] is less desirable than that proposed by the Commission. Such technical specification would go far beyond the simple preventative measure proposed by the Commission; it would involve the whole of the radiated signal; the cost of associated measurements would exceed the cost of the postlimiter filter; and it is difficult to see how such a technical
specification could, as a practical matter, be applied to current equipment -- short of retype acceptance of that equipment. The increased cost would not be limited to higher priced VHF equipment; it would also apply to the lower cost VHF equipment. This increased cost would not encourage the use of VHF, which is a stated Commission objective.
49. In view of the foregoing, the Commission finds that it is necessary to specify where the filter shall be placed if the required attenuation is to be obtained. The statutory authority for making such a requirement may be found in section 303(r) of the Communications Act of 1934, as amended.
50. Returning now to point (b), and the potential of the proposed amendment to prevent improvement in equipment in keeping with advancement in the art. The development or evolution of a new technique, such that the proposed filter would not be required or would be located at another point in the transmitter, would be applicable to many radio services. To facilitate the application of that new technique, when available, to the concerned radio services, it will be necessary to amend the above listed sections of the rules. In that regard, the Commission foresees no difficulty in amending the rules to provide for technical improvements or advances in the state of the art, where a showing of need has been made. It was not claimed, however, that the inclusion of the postlimiter filter would affect application of a known new technique.
51. Taking into account that the new technique is not available and that the Commission must base its actions on information available to it, noting that the benefits accruing from inclusion of this filter are substantial and that the techniques are available and well known, it is the view of the Commission that the requirements for inclusion of the filter must be overriding. Accordingly, the rules are amended to include the poslimiter audio rolloff filter. The Commission will withdraw type acceptance of transmitters not having the specified audio rolloff filter effective January 1, 1974.
Allotment of Channels
52. In regard to the definition of "Noncommercial Communications," one comment n18 called attention to the phrase, included therein, "* * * limited to those pertaining to the purposes for which the ship is used * * *" and has pointed out that this could be misinterpreted on the basis that if the purpose of a vessel is recreation or pleasure, the communications on the allotted frequencies would be for that purpose. It was recommended that this phrase be amended to "* * * limited to the needs of the vessel, * * *." No opposing views were filed. The argument presented is sound and is in full accord with the Commission's [*888] intent. Accordingly, the definition of "Noncommercial Communications" is amended.
53. In this proceeding the Commission is
establishing 156,80 Mc/s as the national VHF distress frequency. As stated in the Notice, there will be many
vessels with only VHF aboard. These
vessels will be able to communicate on VHF, but which will be unable to employ
500 or 2182 kc/s, the radiotelegraph and radiotelephone distress frequencies,
respectively. No VHF frequency in the
band 156-162 Mc/s is currently designated by the rules for distress purposes,
although provision is included, on a permissive basis, for the use of 156.80
Mc/s for the handling of distress messages.
The large number of VHF facilities which have been, and are continuing
to be, installed by the U.S. Coast Guard, the
54. As proposed in the Notice, 156.65 Mc/s is
available only for "Navigational Communication," except on the
55. The basic requirement to establish navigational communications, that is, to provide the capability for near instantaneous communication from the bridge of one ship to the bridge of another ship(s), has been considered in detail by various groups, including the Radio Technical Commission for Marine Services (RTCM), the Intergovernmental Maritime Consultative Organization (IMCO), the International Telecommunication Union (ITU), numerous U.S. groups in preparation for various international conferences, and Commission docket No. 15035. As discussed at the WARC, there is near worldwide agreement that such capability is desirable and will substantially enhance the safety of life and property at sea. There is divergence as to the frequency which should be used. In consequence of the discussions at the WARC, it was decided that in the international system, the frequency 156.80 Mc/s should be used to establish communications, followed by a shift to a working frequency, such as 156.30 Mc/s. This decision was taken notwithstanidng the argument that application of the "calling-working" frequency concept could inject serious and possibly dangerous delays in the bridge-to-Bridge communication, particularly in high density areas where there is a concentration of vessels.
56. Further, on the basis of the anticipated
future high usage of VHF in
57. In regard to the frequency to be used for
bridge-to-bridge communication on the
58. In regard to the definition of Port Operations Service, the WARC adopted an amendment which expands the communications which may be handled on frequencies allotted for port operations. In addition, in consequence of the exchange of views at the WARC, the intent and scope of No. 287, a footnote to the Table of Frequency Allocations (see sec. 2.106) applicable to the band 156-162 Mc/s was clarified. The general effect of this clarification is to increase the uniformity of application by administrations of the provisions of appendix 18 to the ITU Radio Regulations. Thus, the impact of these WARC actions upon the Port Operations Service is such that various frequency shifts proposed in the NPRM are no longer necessary. Accordingly, the definition of Port Operation Service and No. 287 of the rules are amended to conform to the WARC Agreement and are adopted.
5. The Commission proposed in the Notice, footnotes 10 through 13, inclusive, page 4o of appendix 1, that the current operations on frequencies 156.35, 156.45, 156.50, and 156.55 Mc/s be shifted to replacement frequencies (156.275, 156.325, 156.675, and 156.725 Md/s, respectively) in order to more closely align national usage with the international allotment plan appearing in appendix 18 to the ITU Radio Regulations. It now develops, in consequence of actions by the WARC, that there no longer is need to shift these existing operations to the replacement frequencies proposed. Accordingly, the proposed shifts set forth in footnotes 10 through 13, inclusive, are not adopted.
60. With retention of current usage on 156.35 156.45, 156.50, and 156.55 Mc/s, there remains the matter of allotment of the proposed replacements, as follows, 156.275, 156.325, 156.675, and 156.725 Mc/s. In respect to the Notice of Proposed Rulemaking, it is noted that the balance in number of channels allotted for the various types of communication can be maintained by a simple exchange of allotments between these two groups of frequencies. Accordingly, that procedure [*890] is being followed and the consequential changes in allotments are adopted.
61. The Commission also proposed in this docket
that the frequency 156.875 Mc/s be allotted for ship and coast use for
noncommercial communications, and that the frequency 156.925 Mc/s be allotted
for intership use for commercial communications. The WARC, on the other hand, allotted 156.875 Mc/s for intership
and 156.925 Mc/s for port operations.
Since neither 156.875 nor 156.925 Mc/s is in current use, the exchange
of these two allotments would impose no hardship on existing licensees. Further, where use of this intership
frequency is required, the exchange in allotments would reduce the number of
frequencies which had to be carried by foreign ships in
Assignment of Channels
62. Parts 81 and 83 are amended to permit assignment of channels in accordance with the following:
(a) The frequencies 156.75 and 156.85 Mc/s (channel designators 15 and 17) are available for assignment on the effective date of this Report and Order. The (modulation) frequency deviation is limited to +-5 kc/s.
(b) The channels adjacent to 156.300 Mc/s (channel designators 65 and 66) will not be available for assignment prior to January 1, 1971, and will be available on a restricted basis during the period from January 1, 1971, to January 1, 1973.
(c) In regard to VHF channels for public coast stations, the 50-kc/s frequencies (channel designators 24-28, inclusive) will be assigned in advance of the 25-kc/s frequencies (channel designators 84-87, inclusive). Except for channel 28, the order of assignment of both 50-and 25-kc/s frequencies will be in accord with the priority numbering adopted by the WARC. Channel 28 will be assigned interchangeably with channel 26 as the first priority number.
(d) In regard to the 25-kc/s frequencies (channel designators 67-74, 77-80, and 88, inclusive):
(i) During the period prior to March 1, 1969, these channels will not be available for assignment to either ship or coast stations;
(ii) During the period March 1, 1969, to January 1, 1971, these channels will be available for assignment to coast stations in areas where harmful interference will not result to assignments on 50-kc/s frequencies (channel designators 07-20, inclusive); Provided, however, That the Commission will process reports of harmful interference by licensees on 50-kc/s channels on the basis of the facts then existing, with particular attention to the technical measures applied by the respective licensees in cooperation with the Commission 's program to reduce the channel spacing from 50 to 25 kc/s; and
(iii) Effective January 1, 1971, these channels will be available for assignment on the same basis as the 50-kc/s frequencies (channel designators 07-20, inclusive).
63. Consistent with the amendments being made to
parts 81 and 83, section 2.106 of part 2, the Table of Frequency Allocations,
in regard to the maritime mobile service in the band 156-162 Mc/s is being amended
to include therein: The new 25-kc/s channels and the deletion of footnote NG34
from this band; redesignation of the frequency 156.8 Mc/s as the national
distress, safety, and calling frequency, and the addition of the related new
footnote, U.S. 107; the modification of
64. In addition to the comments which are treated in detail in this Report and Order, there are other matters which were raised outside the scope of this rulemaking or were considered as not germane to any issue in the proceeding. For example, a request was received which asked that the channels 1 through 5 (156.025-156.275 Mc/s) be made available to public coast stations. These channels are presently allocated to the land mobile service. To make them a available to public coast stations would require a reallocation, and the scope of this rulemaking does not extend to a reallocation of frequencies.
65. In view of the foregoing, It is ordered, That, pursuant to the authority contained in sections 4(i) and 303 (a), (b), (c), (e), (f), (g), and (r) of the Communications Act of 1934, as amended, parts 2, 81, and 83 of the Commission's rules Are amended, effective September 3, 1968.
66. It is further ordered, That the proceeding in docket No. 17295 Is terminated.
FEDERAL COMMUNICATIONS COMMISSION, BEN F. WAPLE, Secretary.
CONCURRING STATEMENT OF COMMISSIONER NICHOLAS JOHNSON
Channel-Splitting in the Maritime Band (In the Matter of Amendment of Parts 2, 81, and 83, Reduction of Channel Spacing -- Docket No. 17295)
The Commission today takes "frequency management" actions with regard to the maritime communications in the 156-162-MHz band -- mainly the splitting of channels to provide additional and more intensive spectrum utilization in this band. I concur in the action that the staff recommends to us, but I do so hesitantly because of what I believe to be the inadequate measures this Commission uses in making frequency management decisions.
Today's decision may be a wise one -- I simply have no way of knowing. There is no mechanism in the Commission's decision making process which systematically presents alternative choices in any meaningful way so that action by Commissioners could truly be called decision making. We are more like editors, correcting punctuation and spelling or infelicitous choice of words. I have expressed my concern for what the Commission is or (perhaps more importantly) is not doing in previous opinions (see Channel Splitting in the 450-470- Mc/s Band, 8 P&F Radio Reg. 2d 1629, 1633; Frequency Allocations -- 450-470- Mc/s Band, 10 F.C.C. 2d 885, 897; Frequency Allocations -- 450-470- Mc/s Band, 11 F.C.C. 2d 648, 665; Channel Splitting in the 450-470-Mc/s Band, FCC 68-243). I reiterate those concerns today.