FCC May Revise Rules Concerning Disruption to Comms During Disasters

I was pretty much on board with the rest of the post, but this part had me somewhat perplexed. The biggest thing I have seen in my experience that causes the generator not to function is either bad battery, overcrank, fuel issues, or something else relating to getting the generator to actually run. The transfer switch is usually way down that list of possible failure points, but it is an issue, just not like the others (IMO).

Also, the way this is worded makes it seem like you think the communications should run on batteries for a few hours before the generator starts. I have never seen this at all. Usually the generator will start within seconds of an outage, maybe with a diesel it might be a minute. And, I don't think it's practical to put all communications at 10' above flood level, that just doesn't make sense in areas where the biggest flood might be six inches of water. One size doesn't fit all situations.

 

The transfer switch is usually not operated in most generator start/run tests. If so, very infrequently. Therein lies the problem. Clients don't want to see momentary interruptions since transfer apparatus isn't typically synchronous, so that step is omitted. That mode of failure was cited at one time as most problematic across DOE's multiple facilities that employ hundreds of machines.

Ever heard of a "common battery?" More typically called a central office battery by telcos. The oldest form of UPS. Perhaps about the same age as a power substation's battery. Telcos use gen sets as second level e-power to recharge the CO batteries.

Areas prone to flooding, like NO, need such restraints. I doubt you'd have a flood plain of any significance in Aridzona. No flood plain, no need to elevate. Lots of room for improvement in public safety radio control as well. Food for thought.

 

Yes, I suppose if the transfer switch isn't being tested, then it is subject to not working when you need it.

Sure. But my question is that it seems from your post that you are saying that the comms should work on the batteries for a few hours during a mains failure, then the generator should be started. I've never seen that. What I have seen is that the generator is designed to start immediately, or within a few seconds. The batteries are kind of a last ditch effort, the third level of power, used only if the mains and the backup generator have both failed. When on batteries, the clock is ticking.

 

Interesting topic. Last month I received an official ARRL Monitoring Advisory Notice in the mail informing me I was operating on 7150 kHz which at the time was an IARU requested clear frequency for Haitian earthquake communications. My operation consisted of an approximate 2 minute QSO in response to an Italian station calling CQ DX on the frequency. The IARU declaration, was disseminated by the ARRL one week earlier on the ARRL Web Site and also via email, which I in fact received and read because I am subscribed to receive such communications from the League.

At the time of my noted violation of the emergency frequency, I was mobile and had forgotten about the declaration. The Italian station was apparently not in violation of the IARU request because the request was only placed in effect for IARU Region 2. There were no apparent emergency communications underway that I could hear on the frequency, and the Italian station was making a steady string of contacts.

I was informed that while no further action was required in response to the advisory letter, i should in the future carefully monitor for media announcement of emergency frequency reservation declarations during times of emergencies.

I contacted Riley Hollingsworth, whose signature the ARRL letter was issued under to discuss my violation. Riley himself was not the actual monitor, apparently all such letters are now issued by him as head of the ARRL Volunteer Monitoring Program.

I admitted to him that I actually had been aware of the declaration and one week after reading about it, and after a week simply forgotten about it.

I discussed with him the following points with him regarding the issue, which he said he would take up with the League.

1. If a request for clear emergency frequencies is declared, it needs to be followed up with an all clear announcement returning the requested frequencies to normal unrestricted use. I have not yet seen any such notifications for the Haitian earthquake emergency or for subsequent other earthquake and hurricane emergency clear frequency requests.

2. If a frequency is declared to be kept clear for emergency use, real time on frequency announcements and warnings should be made by guard stations who observe and can engage operators who most likely are unaware of the emergency clear frequency declaration. I made the analogy that simply putting out an emergency clear frequency request in an ARRL web page announcement and via email and then issuing Official Advisory Notices to violators via snail mail is like a town changing a four way intersection with only two stop signs to one in which stopping is required at all four directions, not installing the additional two stop signs, only informing the public of the two way to four way stop change via a legal notice in the classified section of the local newspaper, placing an unmarked police car at the intersection to note violators, and then sending the violators failure to stop at an intersection traffic tickets.

3. The declarations only state a specific operating frequency. To prevent interference on the requested clear frequency, operation should be be cleared both above and below the noted frequency to prevent interference from the sideband energy of off frequency stations operating in close proximity to the emergency frequency. For example for a frequency 0f 7150 kHz, a guard band exclusion zone should be requested between 7145 and 7155 kHz.

4. When declaring an emergency HF frequency reservation, consideration should be given to the effects of long distance propagation. In the case of the 7150 kHz request for Haiti, no request was made for IARU Region I Europe, in spite of the fact that European stations would be heard very well in Haiti and would likely interfere with emergency communications there during nighttime propagation conditions.

 

8/14/21
In a statement received by ARRL on August 14, 2021, Region 2 of the International Amateur Radio Union (IARU-R2) has requested that radio amateurs in the Americas keep the following frequencies clear to support emergency communications in Haiti following an earthquake this morning: 3750 kHz, 7150 kHz, and 14330 kHz. The statement came from IARU-R2 Emergency Coordinator (EMCOR) Carlos Alberto Santamaría González, CO2JC.

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09/22/2021
IARU Region 2 Emergency Coordinator Carlos Alberto Santamaría González, CO2JC, has requested that radio amateurs in Central America avoid 7098 and 7198 kHz in the wake of an earthquake at 0957 UTC this morning (September 22) in Nicaragua.

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Interesting. Perhaps someone should try to clarify this matter in the new FCC NPRM.

Did the VM letter specify which rule, in which part of the Communications Act, was allegedly repeatedly violated by your two minute transmission on 7150?

Hopefully, it was just a friendly heads up that there may have been some emcomm related to an earthquake and your cooperation would be appreciated, in case you didn't memorize the ARRL missive, with which you're not required to read, or comply.

When last checked, US Amateurs don't fall under the authority of the non-governmental organization (NGO) IARU, or their Region 2 Coordinator, in Havana Cuba, or the ARRL. I would wager 80% of hams don't monitor ARRL comms, or care about them, and even fewer are aware of the non-binding viewpoints of the IARU, etc.

Congress makes laws. Congress then delegates rule-making to five Commissioners. The Commissioners delegate rules monitoring to the EB. The EB can then note an "apparent violation," which may or may not be passed to the courts to decide upon. The EB has delegated an advisory function to ARRL (or any other ham, or group, meeting VM criteria).

ARRL has in turn, delegated writing these advisories (strictly about the Communications Act and Part 97) to a group of anonymouse monitors. Apparently, Riley compiles and signs the advisories, which under the ARRL/FCC MoU are supposed to be written and sent by numbered, anonymouse volunteers, as follows:

(iii) The functions of individuals recruited and trained under this subparagraph shall be limited to —

(I) the detection of improper amateur radio transmissions;

(II) the conveyance to Commission personnel of information which is essential to the enforcement of this Act (or regulations prescribed by the Commission under this Act) relating to the amateur radio service; and

(III) issuing advisory notices, under the general direction of the Commission, to persons who apparently have violated any provision of this Act (or regulations prescribed by the Commission under this Act) relating to the amateur radio service.

Nothing in this clause shall be construed to grant individuals recruited and trained under this subparagraph any authority to issue sanctions to violators or to take any enforcement action other than any action which the Commission may prescribe by rule.

VI. ARRL’s Role

(c) to coordinate the efforts of the Volunteer Monitors in detecting repeated, potentially actionable, and unlawful transmissions made by Amateur Radio Service operators;

(d) to train Volunteer Monitors to issue advisory notices, under the general direction of EB, to Amateur Radio Service operators who apparently have violated any provision of the Communications Act or the FCC Amateur Rules, provided that such advisory notices

(1) shall only be issued in a standard format, the form of which has been pre-approved by EB;

(2) shall not include any representation that the Volunteer Monitor is acting for or on behalf of EB or the FCC; and

(3) shall exclusively identify the issuing Volunteer Monitor by a unique, anonymous identifier assigned to the Volunteer Monitor by ARRL.

 

Perhaps, indeed, Mr. Hollingsworth needs some refresher training. Or, did I miss something? What's synonymous with anonymous?

 

Yes, precisely. We are well beyond the days of lead acid battery technology and batteries should be required in order to provide the primary means of emergency power for important public safety radio systems for extended periods. There are many reasons why generators fail. Transfer switches are but one issue. Control of trunked systems is another issue. Antenna and structure wind loading yet another. Lots of room for improvement.

 

Elmer was one of the hams on the ground during IDA, his Experiences are not unusual for what happened during IDA. Tom, Parishes are synonymous with Counties in the other 48 states with Alaska having Boroughs with a few exceptions.! Louisiana has different types of local organization at the Parish Level, Some parishes have a council Matic form of government, some have a municipal form of government and then the original Louisiana jurisdiction was and is the police jury.

Emergency management normally comes under department of homeland security which at the state level is called GOHSEP (Governors office Of homeland security and emergency preparedness) which is a function of the state police. LWIN (Louisiana Wireless Infrastructure Network) is the Communication Arm.

On The local level emergency management is usually handled but two different agencies, The local emergency management office which is under the civil parish government and the local Sheriff’s Office which requires some “handling” and “coordination” between the two officials. In most cases this is not a problem and the system basically works real well.

OEP Will have hams in government to man there EOC’s, LawEnforcement on the other hand kind of wants to downplay any auxiliary help and without any AuxComm they are left in a lurch when LWIN craters.

When things go wrong, they go really wrong.

 

Even the best organized emergency communications cannot be effective if we cant do anything about the rogue operator who is fascinated with disrupting the operation with his intentional jamming interference.

Do any of you remember October of 1983 when the Island of Granada was being invaded? I listened intently for hours on 20 meters as Mark Baratella, KA2ORK, who was one of the medical students living on campus at the medical school there, was able to keep up communications with the state department as gunfire could be heard in the background. Even while vital life saving information was being sent back and forth there was at least one or more individuals who kept throwing in interference in an effort to disrupt the operation. Luckily Mark and fellow students were able to keep a small generator fed with fuel so the radio would continue to work and the state department operator was able to get vital information back to the students in between jamming transmissions. This was a clearly English speaking jammer (or jammers) deliberately trying to interfere and give false information. The students were rescued by the Army Rangers but with some difficulty due to the interference in communications.
https://www.reddit.com/r/amateurradio/comments/1n4fvm/ham_radio_and_the_invasion_of_grenada/

 

I know that in our area, the state gives them a better cut of the government funding if they can say they had amateur radio involved in their exercises. They don't want us to communicate, we're just a check in a box to get more funding. Just stand there and don't say anything, we are using our cell phones. Must have worked, cause now they have thier own cell tower and backup diesel generator in the parking lot.
73, Chuck
N0NC

 

I high lighted the part I take issue with. Batteries are, and always will be, the last backup for communications equipment. AC mains will be primary, emergency generator will be secondary, and batteries will be the final option. The reason for this is because there is no backup to the batteries. If you have an emergency generator, and your mains power is down, you should be running on that emergency generator. You shouldn't run on batteries, and leave the generator off. There is no sense to doing that, and can only create trouble.

 

Still waiting for that data Martin -- check with your chain of command and get back to us!

Well known tactic for obtaining grant funding. Also "testimonial letters" and other worthless endorsements, without accompanying data.

 

That's exactly it, they want the MONEY, but not the hams.
73, Chuck
N0NC

 

The truth from a former volunteer firefighter officer is that EMAs are more interested in pushing their authority and don't like anyone that could grab any of their glory. If they do want any help, it is usually the least that they need, no more....

 

Then, you'll never own an electric vehicle. As time progresses, we rely more and more on batteries not as just to ride through momentary power outages, but as primary means of power. Did I say, "leave the generator off?" No, I did not. Batteries provide uninterruptible service, whereas generators have start and transfer delay times. Maybe that's fine for hamster repeaters, but there are many applications that can't have 10 to 40 seconds of drop/disable time, even if the machine starts on AC failure and transfers properly. Engine or fuel cell driven generation is now typically third level. If not, whoever designed the system is inept. Generator failure should not mean system disabled. At least not for a long while.