FCC Seeks Comments for Blanket Waiver to Allow Amateur Radio in Hospital Emergency Dr

Well I will be commenting on it. If the FCC is going to grant them a blanket waiver then they might as well just issue a total blanket waiver for the entire field of Ham Radio Operators and every single company. This is just going to open up a virtual pandora's box that is going to be hard to close.
Essentially it would be like taking an entire school into a candy shop and saying nobody is allowed to buy any candy....one student walks up and the Principal says go ahead and by that candy bar. Now you are going to have a flood of students walking up and actually wanting to buy candy. So where does it stop.

If the hospital wants to run a drill then they need to organize it ahead of time to allow time for someone to volunteer to operate the radios. If they want an employee to do it, then he can't get paid or compensated for it (other then maybe a free lunch and drinks) so if the employee is on salary then he can't function as a radio operator...he can do other things like take notes, but can't be on the radio. If he gets paid an hourly wage then during that time he has to be clocked out with NO pay.

Now here is the only catch that I can see. If someone from outside the hospital decides to take a vacation day to help the hospital do a drill, because in a real emergency he is not going to be at work anyways, then technically he is getting paid to operate....but not by the same employer. So it's hard to say.

But I have to agree....no to the blanket coverage...unless they just do the entire population under the blanket coverage.

 

Save the trees!

In my opinion, the issue is that the recent admonishment excluded participation in drills by any amatuer radio operator that happened to be employed by the hospital participating in the drill. The waiver simply allows them to practice for the real thing, which, if it was a real emergency, they would be allowed to participate. They can still participate if the hospital requests it, but it seems that approval in a case by case basis is time consuming and costly. Having a waiver simplifies this process. I'm currently a member of such a group that supports 35 hospitals in Orange county, California. And I can tell you that when we participate in drills, actual disasters or phone outages, communications are kept to patient care and safety. Before you decide on wether or not this should be allowed, you might want to take a look at our website at http://www.hdscs.org.

 

If their primary system is not an amateur radio system (which it's not), then why would their backup system be amateur radio? Why shouldn't they pay for a backup system that runs on the same type of hardware, the same frequency ranges as their primary system?

Certainly do think they should have a backup?

The difference is price, plain and simple. And that's the wrong reason to use amateur radio... ESPECIALLY as a backup for any sort of safety-of-life scenario.

You did read the FCC's statement recently, when they told us this exact thing... that amateur radio is not a safety-of-life service, didn't you?

 

Yup. That's about it.

I'm sorry if some don't see ham radio as a hobby. Maybe that's part of the problem. We are not allowed to be paid, and each of us, individually, has always been free to choose how we use our transmitting privilages within the framework of the law. No ham has ever been obligated to perform any sort of direct public service.

But now, under this propsal, Nancy Nurse's boss tells her to get a Tech license so she can do whatever during drills, and maybe he pays her for her study time and lets her expense the cost of the handheld she buys. Is she an amateur radio op? I think not.

Before the FCC's great Dumbing Down, this wasn't a problem. I don't think we need to go back to a code requirement, but maybe one should actually have to learn something about electronics and radio to get a license. That might put the brakes on this sort of nonsense. But what are the odds?

 

Okay, I took a look. So....These 35 hospitals in Orange Country are so debt-ridden and poor that they can't afford to build a communications network and hire professionals to run it? Orange Country is too poor to build a resiliant county communications network? I'm sorry, but I've been to Orange County and I don't buy it. If you folks want to do emergency communications work, that's great. I applaud you. But when you want to expedite your special mission by corrupting the legal status and historical precedent of the entire amateur service, I'll oppose you all the way.

 

It seems to me that requesting a waiver is using the system, not corrupting it.

This is not a money issue.

Plus, it looks like the comments are dramatically in favor at this point, unlike the viewpoint we get on this thread.

73,
Chip W1YW

 

"Participate" and "operate the transmitter" aren't necessarily the same thing.

Current rules DO NOT prohibit a hospital or other agency from participating in a drill.
There's a great deal of difference between participating in a drill, which could take
many. many forms not including operating a transmitter, and actually pushing the PTT,
and being responsible for those emissions.

There is no reason whatsoever an agency or organizer of any drill couldn't place
a licensed volunteer amateur from outside the agency to operate the transmitter
during a drill.
The paid people can "participate" by handling any and all other tasks
associated with the event.

For some reason some agencies simply don't wish to bend
in order to comply with existing rules.

Could that be because many of those in favor are being PAID to comment?
(scribbling documents in support, on-the-clock, with their bosses blessing)

 

Blanket Waiver for Amateur Radio in Hospital Emergency Drill

Let's read the rule book, Part 97 anyone since the operation of an amateur station is understood as a privilege and not an ownership just because you paid some money for an examination and license.

Sec. 97.1 Basis and purpose.

The rules and regulations in this part are designed to provide an
amateur radio service having a fundamental purpose as expressed in the
following principles:

(a) Recognition and enhancement of the value of the amateur service to the public as a voluntary noncommercial communication service, particularly with respect to providing emergency communications.

(b) Continuation and extension of the amateur's proven ability to contribute to the advancement of the radio art.

(c) Encouragement and improvement of the amateur service through rules which provide for advancing skills in both the communication and technical phases of the art.

(d) Expansion of the existing reservoir within the amateur radio service of trained operators, technicians, and electronics experts.

(e) Continuation and extension of the amateur's unique ability to enhance international goodwill.

Does those who are either for or against forget there are still rules and they do apply until your license expires deciding amateur radio isn't for you? We amateur radio operators should have at the least respect for their fellow amateur operator but do they? These days we do not as listened to the local repeaters and conversations. Are there those who should kicked out of our amateur community? Yes, as it plainly states in the rules that some in the older generation and those who are brought into the hobby is taught disrespectful behaviors. These types of people forget there is consequences for their actions as shown in the enforcement logs and such behavior should not either be tolerated or overlooked. At any other non-emergency situation it's generally great to join in these conversations and learn or teach each other about the hobby we collectively enjoy. But the hobby/service we enjoy is a privilege and not a right to do anything we want not expecting consequences for any action. In time of great need, amateur radio operations provide a life line in an emergency where general communications are not available. But with the invention of cellular communications until that form of communication if available is not used while accessible amateur radio should be the backup when all else fails as the motto of ours is expressed. In the time when the rules of our privileges were written we didn't have cellular or most of the communications ready at the moment requiring the use of teletype over wire and the early use of wired telephone systems. And for us operators having skill of communications and the basic is available at the moment required is a great asset for emergency communications. We, the amateur radio community are team with the ability to work together toward a common vision which is spelled out in the rules and this ability to direct an individual accomplishment..an emergency with organization objective to provide emergency communications when all else have failed or on the brink of failure and the fuel which drives those interested in emergency communications helping foster goodwill among our community is to help each other. In closing, if those not interested in these activities need to give respect for those who choose to offer assistance but unfortunately there are those who forget the privilege of being an amateur radio operator has rules even tho their ego or childish behavior overlaps their judgment.

 

You like that word "SERVICE?" Try Citizen's Radio SERVICE. (CB) Or Multi Use Radio SERVICE (MURS) Or Family Radio SERVICE.

We are a 'service' the FCC regulates, like GMRS (General Mobile Radio SERVICE.") or Broadcast Radio SERVICE. Or LMRS (Land Mobile Radio SERVICE.) NONE of those are mandated to provide a public service. Broadcast used to be, but the minimum requirements of Public Service have fallen down to an occasional church broadast at 6 am on Sunday morning.

It does not in any way denote a requirement for SERVICE, except as ONE of FIVE purposes listed in the FCC Part 97 Rules.

Read the other four.

Happy Hamming!

Ed

 

When we perform professional communications for a business entity, whether it's police, fire, hospital, ambulance, taxi, fuel delivery trucks, or anything else, we are performing as professionals, paid or not. We are doing a "JOB." We cease to be 'amateurs,' and our radios cease to be amateur radio.

There are already radio services for that JOB. In particular, Part 90. Why do people insist we hams duplicate Part 90 systems? Spend the tax dollars where they are supposed to be, in professional communications systems, operated by professional, trained operators.

Leave ham radio out of the picture!

Did I mention this is AMATEUR RADIO? Not police, fire or medic radio. AMATEUR RADIO.

Ed

 

That paragraph should be included in the:
ARRL Operating Manual for Radio Amateurs

 

Drills not Jobs

Remember this is a wavier for 'Drills'. It only lists 'Drills' and nothing else. As for Hospitals buying their own backup communications they usually do. Amateur Radio is as an ARRL slogan once suggest, "When all else fails". In an true emergency nobody can predict what will happen or what form of communications will be necessary. Why not let people who would be part of the true emergency pool practice while on the job? They aren't getting paid that day to run their radio they are getting paid because the drill happens while they are working. When I go out on a storm watch I'm still being paid by my employer. Does that mean I'm breaking the rules? Sounds to me to be a lot of ticky tack.

The future of Amateur Radio is not in how many people we can exclude but in how many people we can include.

 

I have some misgivings about Hospitals, etc, having integral amateur radio stations. If they have a number of employees or interested persons who want to form a club or provide a service, good. But the very presence of amateur radio equipment installed at such a facility puts the amateur radio community a risk of a compromise of their frequency allocations and operating freedom. I am a county emergency coordinator for the amateur radio community, and I cannot find sufficient volunteers to man the EMA/HSA radio room. It would be nice to have some employees of hospitals licensed, but to mandate that employees have amateur licenses is pushing the envelope. I know of one county that has three hospitals with radio rooms fully equipped with amateur radio gear, and not a single active ham in the county. Amateur radio should be used only when all else fails; to use Amateur radio to facilitate communications between facilities should not be necessary. Amateur radio should not be used as a substitute, or an alternative to good commercial communications. Amateur radio should be used only for communications with field services when no other alternative is available. Hospitals who set up amateur radio with the expectation of point-to-point communications with each other or passing traffic with emergency agencies would be well advised to set up radio communications on frequencies available to them. The unique thing about amateur radio is not its frequency allocations; the unique thing about amateur radio is its ability to operate sans infrastructure. If the local telephone network becomes overloaded, disrupted, or inaccessible to the facility, then hams can step in to fill the gap. But the hospital should be prepared to communicate through other channels to other facilities. No, the FCC should not issue "blanket" exemptions for "drills".

 

Yea or Nay...That is the Question

Hi All

Please do not misinterpret my understandings of the importance and contributions that this hobby has made for the past 100 years. The countless lives saved and the property rescued or persons helped out of harms way. It is very important from a technological standpoint that we inventors, scientists, and amateur experimenters continue to make the breakthroughs that have made this country what it is today and have allowed future generations of mankind and womankind the ability to have a better life.

I know this will shock some of you whose life revolves around a radio, volunteer organization, or participation in drills, training, etc. It is a fine thing we do for our communities and our country; but……

As a group, we MUST understand that:

1. Ham Radio is a hobby, first and foremost.
2. Ham Radio is NOT a “Public Safety Entity” and in our zeal to make our communities better; it is NOT an alternative to Wireless Land / Mobile Service or a more economical alternative for a Part 90 communications solution.

Please take the time to read the AHA request under the WP Docket # 10-54; because there is an implied assumption that the communications on Amateur Frequencies by a commercial interest is NOT in question…SAY WHAT!… commercializing of Amateur Frequencies! It is implied in their request that they are entitled under the current rules to use your granted and protected frequency allocations to benefit a commercial entity and that the waiver in it’s current form and rule would simply make it an “administrative burden” upon the hospital to file in advance as “Governmental Agencies” are now required to do for drills, training, etc. In other words they are… ASKING THE FCC FOR USE OF THE AMATEUR BANDS TO BENEFIT A COMMERCIAL ENTERPRISE IN PLACE OF THE PART 90 WIRELESS LAND / MOBILE SERVICE SYSTEMS IN ORDER THAT THEY ATTAIN / MAINTAIN ACCREDITATION, I.E. STAY IN BUSINESS!

Should we ignore the request made to the FCC to allow this and other exemptions? Be very careful what you ask for. Again, this is in some circles an attempt, whether conscience or not, for Commercial Enterprises, Industry, and Public Safety / Service to use ‘Amateur Radio’ as ‘Public Radio’.

We are treading on thin ice from the standpoint of Band Encroachment and unfavorable rule making by the FCC. It is hard to find a 2M repeater on the weekend in some areas that is not being used for some event. Many of the control operators are actually paid employees of the event sponsors; just not ‘on duty’ or ‘assigned to work’ that day. It was pointed out by Laura Smith on a conference call last year, “….the amateur community could be headed for a slippery slope, and once you allow your bands to be opened up for commercial use, the amateur community will be relegated to complaining about it in the forums and once they are gone….they are gone.”

On one hand we all enjoy our hobby granted to us by Federal Law. We do not like the occasional restriction(s) placed on operations that are imposed at times on a few that hamper the ability to utilize the privileges we are granted. Emphasis on ‘privileges granted’. We use the, “….when all else fails” concept to argue for protection of these privileges. But remember this can be a compromise of sorts.

There could possibly be a loss or further restriction of operating privileges. It is a double edged sword we swing and it can cut both ways. We may very well gain protection from land use, HOA’s, etc.; but could be forced to give up something in return.

Will that be frequency allocations / bands, will that be restricted operations at certain times, distances, or power? Will that mean that most 2M and 70CM Repeaters might be off limits during special situations, weekend events, or gone completely? What about those precious HF frequencies?

We should also ask, ‘Will there now be new repeaters appearing across the landscape and who will operate and maintain these ‘Emergency Backup Systems’? Do the current Amateur Systems actually all have redundant backup and emergency power…if they are supposed to be an ‘Emergency Backup’? What entity will certify these ‘Emergency Backup Systems’ and what will be the new rules and requirements? Will there be new repeater / frequency coordination issues and conflicts? Who will now be the primary service and who is the secondary? Can we envision School Systems using 2M or 70CM for communicating with their busses or facilities maintenance? How about the delivery vehicles that transport supplies? What about outside contractors, consultants or secondary service providers to these entities?

These are all avoidable issues and WE decide how far this type of encroachment is allowed to go. One thing is for certain. Our Legislators, Private Industry; including Hospitals, Government Entities, Public Safety, and Relief Organizations all agree to the benefits of Amateur Radio and its precious band allotments. We should then take great care and use prudent vigilance when determining our course of action. Again a reminder, it might warrant us to be cautious what we ask for or ignore….because we may very well get it and the outcome will more than likely not be reversible.

73’s
Foy

 

All amateurs have a dog in this hunt. Hospitals are overwhelmingly "for profit" organizations. Although there are some exceptions, the employees are still paid.

One of the hams commenting was a NASA "volunteer" and explains how it effected him. He's against the proposal by the way.

Commenting against this waiver does not change the rules. It keeps them as they are and with a strong statement, don't sell out ham radio. Just Say No!!