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Excerpts of his remarks are given below:
"Frequency coordination in the amateur service is voluntary. Always has been. In 1987, in PR Docket No. 85-22, Report and Order Memorandum and Opinion and Order, the Commission on decided to continue relying on voluntary coordination of amateur service repeater stations. There is no Commission rule requiring approval of a frequency coordinator before a repeater goes on the air. This is what the letter said.
Frequency coordinators are entities that are recognized in a local or regional area by amateur radio operators whose stations are eligible to be auxiliary or repeater stations. Frequency coordinators may be individuals, clubs, or informal groups. They don't have to be hams, but they usually are.
Frequency coordinators derive their recognition from the voluntary participation of the local or regional amateur service community. We do not tell you who your frequency coordinator is. The frequency coordinator is responsible to you - it is not responsible to the FCC. In a system where you voluntarily choose to put up a repeater and voluntarily recognize the coordinator, a coordinator not considering the concerns of all users of spectrum affected by repeater operation can be replaced by local amateurs choosing another frequency coordination entity. Changing coordinators is the mechanism that we anticipated you
would use to replace a frequency coordinator that was not representative of all or otherwise meeting your needs.
This process does not involve the FCC. The FCC does not recognize or regulate local or regional frequency coordinators, per se. The list of coordinators in the ARRL Repeater Directory is there for whatever editorial or informational purpose the ARRL decided this list would serve. Complaining to us about them isn't going to do you much good -- we aren't going to send Riley after an entity we don't recognize in the first place.
The function of an amateur service frequency coordinator is recommending transmit/receive channels and associated operating and technical parameters in order to avoid or minimize potential interference. The action word is recommend. You may go to your local frequency coordinator and ask about getting coordinated. The coordinator can tell you that its database shows no available channels. Or that it cannot recommend transmit/receive channels or associated operating and technical parameters for your station. There are a multitude of reasons they may not be able to. As long as you do not cause harmful interference to another station, however, you can put your repeater on the air. Section 97.205 provides the authority. The licensee of the repeater station is responsible for that station.
It may be that the standards the coordinator is using do not fit your area or that there are facts about local conditions that are
not known to the coordinator, or that the database is out of date. A frequency coordinator does not have the authority tell any licensee that he or she may not put a repeater on the air. Telling you that would in essence, restrict what your license authorizes. Only the Commission can do that. The coordinator's decision is to coordinate your station or to not coordinate your station.
The FCC's longstanding policy of permitting amateur radio operators to collectively self-regulate your repeater coordinators has generally been a resounding success. This policy has allowed you determine for yourself how to meet your needs. There are no Commission rules governing the selection of a coordinator or the procedures for coordination. The technical standards a coordinator uses such as distance separation, propagation models, channels spacing etc are not FCC standards are not in the rules. If the standards a coordinator is using are "wrong" in some sense, tell the coordinator.
I assure you that different coordinators around the country use different standards. Amateur radio operators and coordinators have the flexibility to make and change these standards at the local and regional level. If the coordinator doesn't listen, find someone to better perform this function. Coordination is an option to serve your needs. Voluntary coordination and the flexibility that goes with it has allowed you to respond to local situations in a manner that meets your needs. For example, a coordinator in the New York City area folded up his tent some years ago. Amateur service repeaters continued to operate. Later, licensees in the Tri-State area decided they wanted to try coordination again, but they carved up the area differently: a new coordinator did
some of the area and a coordinator in Connecticut does some of the Long Island counties, as I recall. Some areas have no coordination entity.
The local hams can do this because the rules do not hamper them. The process need not involve us, does not involve us, and it should not involve us. I have the greatest confidence that you can do a better job collectively solving your local or regional problem than the FCC ever could.
Frequency coordination is taken without the involvement of the FCC. This approach keeps coordination at the local level, where people who more readily have knowledge of the facts can respond to the situations expeditiously and where the coordinator is directly answerable to the local amateur community.
If you want, you can have multiple coordinators in a state or on a band, part of a state coordinated (like the urban parts) and other parts not, some bands coordinated (the congested ones I suppose) and some bands not coordinated. If one of these models fits your needs, then use it. There are a lot of other models, too.
The Commission has never selected or approved any entity as a local or regional amateur service frequency coordinator, or reviewed the coordination decisions of a particular amateur service frequency coordinator. In the few geographical areas where the local or regional amateur service community has decided to have multiple frequency coordinators, we expect that the coordinators will cooperate with each other.
If they don't, you the users will not be able to use your channels. The requirement that licensees may make the most effective use of amateur service frequencies, is still there and the fact that multiple coordinators may be involved does not absolve licensees of this responsibility."
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