[BCVHFA] FCC Clarifies What Constitutes an Amateur Radio Repeater

[Carl Morgan]

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SB QST @ ARL $ARLB018
ARLB018 FCC Clarifies What Constitutes an Amateur Radio Repeater

ZCZC AG18
QST de W1AW
ARRL Bulletin 18  ARLB018
 From ARRL Headquarters
Newington CT  March 24, 2009
To all radio amateurs

SB QST ARL ARLB018
ARLB018 FCC Clarifies What Constitutes an Amateur Radio Repeater

In December 2007, Gary Mitchell, WB6YRU, President of the Northern 
California Packet Association (NCPA), filed a Petition with the FCC, 
asking for the Commission to clarify the definition of a repeater. 
According to Part 97, Section 3(a)(39), A repeater in the amateur 
service is "[a]n amateur station that simultaneously retransmits the 
transmission of another amateur station on a different channel or channels."

Mitchell sought clarification on the word "simultaneously," asking if 
it referred 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. On March 23, 
2009, the Commission clarified that even if there is a slight delay 
between what is received and what it transmits (as in the case of 
D-STAR and other digital repeaters), it is considered simultaneous if 
the receiver and transmitter are both active at the same time.

Mitchell pointed out in his petition that while the Commission's 
Rules specify on which bands amateur repeaters may operate, "some 
amateur repeaters are operating on bands other than set forth in 
Section 97.205(b) with systems that are essentially voice repeater 
stations, but that digitize and retransmit the user's voice, on the 
theory that because there is a small delay in retransmitting the 
signal of another amateur station, the signal is not 'simultaneously' 
retransmitted and, therefore, the system is not a repeater."

In its reply, the Commission pointed out that prior to 1994, a 
repeater was defined as "[a]n amateur station that automatically 
retransmits the signals of other stations." This, the Commission told 
Mitchell, was revised to clarify "that certain accommodations for 
message forwarding systems do not apply to other operating activities 
such as repeaters and auxiliary stations." The Commission proposed to 
define a repeater as "[a]n amateur station that instantaneously 
retransmits the transmission of another amateur station on a 
different channel or channels," but ultimately replaced 
"instantaneously" with "simultaneously" because commenters noted that 
there is always a small propagation delay through a repeater.

As one commenter explained, "The word 'simultaneously' in this case 
means that the repeater is receiving and transmitting concurrently, 
whereas each signal might be slightly displaced in time between 
receive and transmit."

To be able to repeat another station's transmission, the Commission 
said that a repeater "must be able to receive a transmission from 
another station and retransmit it. Because the word 'simultaneously' 
in the definition is used to modify 'retransmit,' we believe it 
refers to a repeater station's transmitter being active when 
retransmitting the signal received by the repeater station's receiver 
from another amateur station. We conclude, therefore, that 
'simultaneously' as used in the definition of a repeater refers to 
the receiver and transmitter both being active at the same time."
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