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BE INFORMED NO. 66 Is My Remote Base OK?
Q.
Is it OK to have a remote base with its output on HF? A. Possibly so. Part 97 doesn’t even mention the term remote base.
The answer to your question, therefore, depends upon just what you mean by that expression. BE Informed No. 31 Hamslanguage describes a remote base as a remotely controlled
amateur station having a radio or wireline control link between the station and its distant control point. If, therefore,
should you have in mind an HF station located at a distance from its control point such that it cannot function properly under
local control, note that Section 97.109 says that any station may be remotely controlled.
The accommodations for such telecommand of an amateur station are in Section 97.213. Otherwise, if you mean by the term remote
base some arrangement whereby your station simultaneously retransmits the transmissions of another amateur station on a different
channel or channels, you have yourself a repeater. Read Section 97.3(a)(39). The special accommodations for
repeaters are in Section 97.205. Note that paragraph (b) authorizes a repeater
to receive and retransmit HF only in the 10 meter band, except for 28.0-29.5 MHZ. As Bill Cross has observed: If it looks like a duck and quacks
like a duck, it probably is a duck – or at least a domesticated bird of the family Anatidae. Q.
What is telecommand? A. Section 97.3(a)(43) defines telecommand as a one-way transmission
to initiate, modify, or terminate functions of a device at a distance. Section 97.213 authorizes an amateur station on or within 50 km
of the Earth's surface to be under telecommand where: (a) There is a radio or wireline control link between the control point and the station
sufficient for the control operator to perform his/her duties. If radio, the control link must use an auxiliary station. A
control link using a fiber optic cable or another telecommunication service is considered wireline. (b) Provisions are incorporated to limit transmission by the station to a period of
no more than 3 minutes in the event of malfunction in the control link.
(c) The station is protected against making, willfully or negligently, unauthorized transmissions. (d) A photocopy of the station license and a label with the name, address, and telephone
number of the station licensee and at least one designated control operator is posted in a conspicuous place at the station
location.
Q. Can I use the Internet from my home
to remotely control my remote base in a distant city? A. Yes, provided, of course, that you comply with the
FCC rules, in particular Section 97.213, Telecommand of an amateur station.
Q. What is a control link?
A. Hamslanguage describes a control link as a radio or wireline connection between the control point and
a remotely controlled station for the purpose of enabling the control operator to perform his/her duties.
Section 97.3(a)(38) employs that term
in the definition of remote control as the use of a control operator who indirectly manipulates the operating adjustments
in the station through a control link to achieve compliance with the FCC Rules. Section 97.213(a) says that if by
radio, the control link must use an auxiliary station.
Section 97.3(a)(7) says an auxiliary
station is an amateur station, other than in a message forwarding
system,
that is transmitting communications point-to-point within a system of cooperating amateur stations.
Q. What frequencies can be used for my
radio control link? A. Section 97.213(b) authorizes an auxiliary station to transmit on at
least one segment of all VHF and shorter wavelength bands except 6 meters. To minimize potential interference, seek from your local frequency coordinator a recommendation for a channel
and associated operating and technical parameters.
Q. Can my repeater be a remote
base? A. Yes, in that a repeater –
as well as any other FCC-licensed amateur station – is authorized to be remotely controlled. Read
Section 97.109. Past rulemaking proceedings would indicate that our amateur service community does not favor
HF repeaters other than at the highest end of the 10 meter band. It does, however, support authorizing
amateur stations to be under telecommand, although it is apparently unconvinced that auxiliary stations should be allowed
to transmit on channels in bands below 2 meters.
Q. Could another ham use my remotely controlled 40 meter base
station via the VHF uplink and UHF downlink with his auxiliary station? A. He could, provided that you - the
40 meter station licensee - designated him as the control operator of your remotely controlled station. Heed Section 97.103(b). You also have the option of transferring physical
control of your station apparatus to him. Heed Section 97.5(a). In which case the call sign transmitted in
the station identification announcement would be that assigned to his station. Read BE Informed No. 4 Which Call Sign? He would have to hold the
class of operator license required to be the control operator of an amateur station transmitting on the segment of the 40
meter band on which your station transmits. Read Section 97.301.
Q.
Would the repeater rules apply to my 40 meter remote base? A. No. Your 40 meter station is not eligible for
the special operation accommodations for a repeater station, as codified in Section 97.205, because it transmits and receives outside
of the bands authorized for such. Paragraph (b) says that a repeater may receive and retransmit only on the 10 m and
shorter wavelength frequency bands except the 28.0-29.5 MHz, 50.0-51.0 MHz, 144.0-144.5 MHz, 145.5-146.0 MHz, 222.00-222.15
MHz, 431.0-433.0 MHz, and 435.0-438.0 MHz segments. The special accommodations for
auxiliary stations in Section 97.201, however, are available for your VHF uplink and downlink
stations. Paragraph (b) says that an auxiliary station may transmit only on the 2 m and shorter wavelength bands, except
the 144.0-144.5 MHz, 145.8-146.0 MHz, 219-220 MHz, 222.00-222.15 MHz, 431-433 MHz, and 435-438 MHz segments. Q. Would the repeater rules apply for a 2 meter remote base
with UHF an uplink and a downlink? A. Not unless your 2 meter station simultaneously retransmits
the transmissions of another amateur station on a different channel or channels (other than a system point-to-point downlink.)
Read Section 97.3(a)(39). Then it would be required to comply with the
repeater rules in Section 97.205.
Q.
But it would be simultaneously retransmitting the transmissions of another amateur station on the UHF downlink.
A. Assuming your downlink consists of an auxiliary station transmitting point-to-point communications received at your remotely
control station - including possibly telemetry - back to its control point, it could not also be
a repeater that qualifies for the special accommodations in Section 97.205. Q. Can the downlink auxiliary station be under automatic
control? A. Yes, provided it does the job properly. Section 97.201(d) specifically authorizes an auxiliary station to be
automatically controlled. It is one of four such authorizations. The others are: certain beacons, Section 97.203(d); repeaters, Section 97.205(d); and certain digital stations, with restrictions,
Section 97.221(c).
Q. A friend has asked if a variance from our normal routine
would be permitted. We use D-Star, radio-to-radio. He is a US citizen with a FCC license and resides, temporarily,
in Japan. He is licensed there also. Can he route a call to me via his computer to the Internet to a gateway stateside
that routes his call to me? He'd in effect be operating remotely through the gateway and a repeater local to me.
A. There is no specific rule for that question. So, it must be analyzed in the context of the rules that do exist
and the information presented in your question. Firstly, the FCC has declared that D-Star fits the
definition of a repeater. The significance of the word simultaneous in the definition of a repeater was addressed by
the FCC in Amendment of Part 97 of the Commission's Rules Concerning Message Forwarding Systems in the Amateur Service, Report
and Order, PR Docket No. 93-85, 9 FCC Rcd 1786, 1788 ¶ 6 (1994). Thus, it is eligible for the special operations
accommodations for repeater stations. Repeaters enjoy frequency coordination protection and are authorized to be under
automatic control. Read Sections 97.205(c) and (d). Our amateur service community, moreover,
has implemented effective channelization band plans for repeaters. Some stations that digitize
and retransmit the user's voice reportedly had been transmitting on channels in band segments other than those authorized
for repeaters. Their rationalization was that in the definition of a repeater, it is only an amateur station that simultaneously
retransmits the transmission of another amateur station on a different channel or channels. Read Section 97.3(a)(40). The digitizing process, in the D-Star example, can add a slight delay. The issue, therefore, was
whether the word simultaneously 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. The FCC declared that
the word simultaneously is used to modify the word retransmit. Referring to comments it received when it adopted the
current definition of a repeater, it concluded that simultaneously as used in the definition refers to the receiver
and transmitter both being active at the same time. So, there is no issue there.
Secondly, your friend does not appear to be causing or allowing an amateur station to transmit in Japan. So, it is beside
the point that he has authority to do so. Thirdly, his communications passes between Japan and
the United States via the internet, not amateur radio. So, there is no issue there.
Fourthly, there is the assumption that he is not the station licensee of the repeater that is at a location where the FCC
regulates our amateur service. If so, that is another non-issue. Fifthly, there is the
matter of whether or not he is the control operator of the repeater. That must be decided by the station licensee.
Read Section 97.103(b). Presumably, he is not the control operator;
he is a user. Lastly, there is the matter of whether or not the station is actually a repeater
during those instances his communications - as received via the internet - are being retransmitted. A repeater, by definition,
is an amateur station that simultaneously retransmits the transmissions of another amateur station on a different channel
or channels. Read Section 97.3(a)(40). During those times when it is transmitting something other than the transmissions of another amateur
station, obviously the station is not being a repeater. It does not, therefore, qualify for the special operations privileges
afforded repeaters. This point has been raised previously in the context of communications via auto-patch
and communications directly from the control operator. Our amateur service community, at least, seems to accept that doing all of the things that a repeater
does some of the time, or doing some of the things a repeater does all of the time, somehow entitles a station to enjoy some
or all of the special operations accommodations for repeaters any old time.
Q. Could we consider my friend as being the control operator
in a foreign country for a remote base in the United States? A. Yes, but the remote base may not be
a suitable option. It would not qualify the station for the special operations privileges of a repeater. Under
that configuration, your friend in Japan would be the control operator of the remote base. The issue of whether or not
the control point of a station that is transmitting from a place where the FCC regulates the amateur service can be located
in another country, however, is not specifically addressed in our rules. If it ever is, the decision could be
negatively influenced by a specific situation - an international crisis, perhaps - prevailing at the time. Section 97.213(a) authorizes telecommand of an amateur station in places where it regulates the amateur service.
Among other requirements, the wireline control link between the control point and the station must be sufficient for the control
operator to perform his/her duties. A control link using another telecommunication service is considered wireline. So,
the Internet can serve as a wireline control link between a station transmitting from a place where the FCC regulates and
its control point wherever it is situated. Section 97.109(a) says that each amateur station must have at least
one control point. So there exists the basis for eventually declaring that the control point is part of the station
and, as such, must also be at a place where the FCC regulates the amateur service. Our security authorities may not always appreciate our tolerance
for there being amateur stations transmitting in our United States that are licensed and controlled by persons who are beyond
their reach in other countries. Most hams probably prefer that the current permissive arrangement be codified before
some over-imaginative ham becomes way too clever for our own good.
Q. In a remotely controlled station using a computer and the
Internet, does the FCC require the control operator of the station through which the computer is operating to be
present at the station? A. No, not under our amateur service community’s presumption that
the control point is not a part of the station. Each station must have at least one control point. Read Section 97.109(a). The control point is the location at which
the control operator function is performed. Read Section 97.(3)(a)(14). When the station is being locally or remotely controlled, the control operator must be at the control point.
Read Sections 97.109(b)
and (c). The control operator must ensure the immediate
proper operation of the station. Read Section 97.105. Telecommand of an amateur station is
addressed in Section 97.213. Our FCC rules regulate our stations, not our systems.
This approach works in our favor, as it makes us free to design and implement all sorts of new systems as ideas and technology
appear. We are allowed to configure and operate our stations depending upon our interests, our resources, our ingenuity
and our good judgment. For systems that make use of our repeaters, including the various
over-the-Internet configurations, repeater station licensees are under no FCC obligation to incorporate their usage into their
repeaters. Considering the rules, the assumptions, the configurations,
and what ifs, it is obvious why Part 97 does not – and why we do not want it to - regulate our systems.
March 8, 2011 Supersedes all prior versions
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