Freedom Bands Proposal

Nickolaus Leggett leggett3 at
Wed May 9 16:34:32 CDT 2012


AMRAD may be interested in my Freedom Bands proposals listed below.

73,  Nick Leggett,  N3NL  AMRAD Member

*Before the*

*Federal Communications Commission*

*Washington**, D.C. 20554***

*In the Matter of*

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*Commission Seeks Comment on Emergency Communications by Amateur Radio and
Impediments to Amateur Radio Communications*

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* *

* *

*GN Docket No. 12-91*

* *

* *

* *

* *

*To the Commission:*

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*Third Set of Comments from Nickolaus E. Leggett, N3NL*

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I am a certified electronics technician (ISCET and iNARTE) and an Extra
Class amateur radio operator (call sign N3NL).  I am an inventor holding
three United States Patents.

This is my third set of comments in this docket.  These comments concern
the impact of Commission rules on amateur radio operations.

My first set of comments in this docket was submitted to the Commission on
April 3, 2012.  My second set of comments in this docket was submitted on
April 11, 2012.

*Response to Section 2, Part d, Page 4 of the Public Notice*

The Commission asked the following question of the readers: “Do any
Commission rules create impediments to enhanced Amateur Radio Service
communications?”  This question relates to the Commission’s earlier
question: “Are there any future technical innovations that might further
improve the Amateur Radio Service?” (Section 1, Part g, Page 3 of the
Public Notice).

The answer to these two questions is clearly, yes.  I have suggested in GC
Docket No. 11-199 that the Commission establish special Freedom Bands in
the millimeter wave spectrum and within the amateur radio allocations
themselves where experimenters would have the requisite technical freedom
to develop fundamental new communications technologies.  Refer to Appendix
A for this text.

Amateur radio inventors and innovators can certainly develop new
communications technologies that are more survivable than current solid
state technology and that would be very useful in serious and long-duration
emergencies.  Innovations of direct value to emergency communications could
include the following items:

1.      Balloon and kite supported antennas

2.      Electric power generation using wind and solar energy combined into
portable antenna structures

3.      Inflated antenna structures

4.      Liquid electrolyte antennas (including highly-salted salt water)
(use of insulated channels or pipes filled with electrolyte)

5.      Some circuit components made from liquid electrolytes

6.      Circuit components made from hardware store components

7.      Batteries using agricultural wastes (such as rotting lemons)

8.      Wire antennas launched by model rockets into tall trees

9.      Basic and repairable amplitude modulated (AM) communications
equipment for local communications

10.  Foot-operated generator connected to a bicycle or to a tandem bicycle

11.  Multiple-person hand-cranked generator

12.  Solar-powered soldering station (photovoltaic and/or direct solar

13.  Broadband RF noise generator for emergency signaling to receivers (a
SOS machine)

14.  Tin can microphone and tin can speaker

15.  Induction coupled RF output into building and neighborhood power lines
(for emergency transmission on HF using the lines as an antenna)

16.  Morse code keyed car horns or other loud audio noise source (for short
range signaling such as between the top of a building and the ground)

These innovations and other more major technical advancements would be
assisted by having frequency sub bands where FCC regulations are greatly
relaxed.  In addition, this advancement would be encouraged if amateur
radio operators were permitted to set up antennas on our homes and to
experiment with different antenna designs and technologies.  Most amateur
radio operators cannot afford to rent industrial space to conduct radio and
antenna experiments away from their residences.

*Respectfully submitted,*

*Nickolaus E. Leggett, N3NL*

*1432 Northgate Square, #2A***

*Reston**, VA 20190-3748***

*(703) 709-0752*

*April 17, 2012*

*Appendix A    Freedom Bands for Radio Inventions and Development – My
comments in GC Docket No. 11-199 = submitted on December 26, 2011*

* *

*Subject of My Comments*

My comments are focused on the Commission’s second question on the first
page of the Notice (DA 11-2002):

“2) How can the Commission further reduce burdens on industry and consumers
while fostering competition, diversity and innovation?”

In addition, my comments are in support of the Commission’ request:

“In addition, commenters are encouraged to submit other suggestions that
may help the Commission develop better regulations and processes.”

I am writing from the viewpoint of a licensed radio operator and as an
inventor with several patented and unpatented inventions.

*The Commission’s Rules, Innovation, and Invention*

The Commission’s rules can have a quite negative impact on the process of
invention and innovation in the marketplace.  This happens because the
rules specify the exact emission types used and in many services the actual
engineering designs of the communication devices must be approved by the
Commission’s engineering staff.

While there are reasons that the FCC rules have been established this way,
they create considerable havoc for the inventor and for the inventive
process.  Invention is an iterative and rather playful process where
specific devices are conceived, prototyped, tested, modified, and often
recycled into different devices.  Invention is a tentative and experimental
process where numerous concepts and designs are processed and played with
until a potentially marketable technology is developed.  This is the
opposite of the regulatory world where very specific engineering designs
are approved for the radio and wireless communications markets.

*How to Accommodate Invention in the FCC’s Regulatory Structure*

It is likely that the FCC will not abandon its current regulatory structure
for radio communication.  So how do we accommodate the free wheeling nature
of invention in the FCC’s regulatory system?

My suggestion is to establish some lightly regulated radio frequency bands
where experimenters, both individual and corporate, can experiment with
unusual and even “way out” communications technologies.  These special
radio frequency bands would be called Freedom Bands indicating that the
users of these bands would be free to experiment with whatever
communications technologies they could invent and get on the air.

The Freedom Bands would create an inventing environment similar to that in
the early 20th Century where radio experimenters could do virtually
anything that they could invent and actually get on the air.  The
environment was open and there were few regulatory inhibitions on the
experimenters both amateur and commercial.

We need to create some spectrum bands where this type of inventive freedom
can exist once again.  This freedom will allow numerous new technologies to
be born, prototyped, and tried on the air.  One can imagine some of these
new experimental technologies such as the following:

1.      Parallel transmission of numerous channels of data for the
ultra-rapid transfer of data, audio, and video

2.      Transmitter, receivers, and antennas using liquid-state components
including components that can be made domestically during extended
emergency situations (such as after an intense solar geomagnetic storm

3.      Ultra narrow band transmissions using low keying rates for long
distance interplanetary communications and eventually for interstellar
signaling to Earth-like planets

4.      Power broadcasting using continuous waves (CW) or another mode to
rectifying antennas (rectennas) on remote repeaters and on airborne
repeaters flying “permanently” on station.

5.      Multiple channel holographic three-dimensional still image and
video transmissions

6.      High-resolution synthetic vision radar for blind people and other
visually impaired people (This technology could also be applied to
robot-driven automobiles and other vehicles as well as to military

7.      Prototype natural vacuum electronics technology for eventual
application to space vehicles and space stations. (Initial tests of these
open structures would be conducted in glass bell jars establishing the
requisite vacuum on Earth.)

8.      Wireless bus extended-chassis super computer systems (Refer to U.S.
Patent  # 6,771,935 for an example of this type of technology)

9.      High-power air ionization systems for the electric propulsion of

10.  360-degree view radar for flying vehicles

11.  Backup radio navigation system for GPS in case the GPS system is

12.  Direct brain-to-brain communication via wireless links and suitable
biological-to-radio interfaces

13.  RF-driven illumination devices and systems

14.  Modernized spark-gap communications devices for 21st Century

15.  Direct wind power integrated into antenna structures powering radio
transmissions and aircraft warning lights and bird-warning sounders (You
will get lots of wind power from a 1000-foot tower.)

The new technologies listed above will be useful, but the even more
exciting ones are the ones that we cannot conceive of yet.  We need to
encourage the creation of these not-yet-visible new inventions that will
allow our economy to grow and thrive in the future.

*Regulations for the Freedom Bands*

The whole idea of the Freedom Bands is an inventors’ park where one can go
wild in trying out new and different communications inventions and
innovations.  However, a few basic rules will allow these bands to operate
as we want them to without causing problems for other users of the busy
radio spectrum.

The users of the Freedom Bands should be required to keep their radio
emissions within the band.  Some sort of filtering or suppression of
spurious emissions outside of the Freedom Bands is needed.  My suggestion
is that 60 dB of suppression is probably adequate for most users.  However
some high-power emissions such as power broadcasting may require an even
cleaner signal with a higher level of suppression.

In addition, we probably need a rule stating that all of the experimental
devices set up on the Freedom Bands be established so they don’t expose the
public to dangerously high levels of radiofrequency (RF) exposure.  This
protection should also be applied to various animals that are likely to be
exposed to the RF emissions.

Access to the Freedom Bands should be allowed to any licensed individual
radio operator as well as to small companies, non-profit organizations
(such as universities), large corporations, and government organizations
(such as NASA, NIST, and DOD).  The intention is to open this spectrum to
technical pioneers of all kinds allowing the ideas to be developed to grow
new industries in the radio marketplace.  This system would essentially be
a license-free band where many types of competitors can enter the
competition.  Indeed, it may be preferable to open these Freedom Bands to
any U.S. citizen.  We do not know who or where the next Edisons will be.  They
may be hidden somewhere is the ghettos or barrios of urban America or out
on the tribal reservations of the American West.

The bands would also have a basic rule that they exist for experimenting,
not for the routine transfer of traffic or the broadcasting of program
material.  The bands are strictly for technical experimentation only.  The
only exception would be for communication during a major emergency.

*Where to Establish the Freedom Bands*

As the Commission and the radio interests know well, the electromagnetic
spectrum is a very busy and heavily used place.  For this reason, I
recommend that most of the Freedom Bands be established within radio
frontiers such as the millimeter waves.  Doing this would serve two major
goals: encouraging and enabling invention and encouraging new uses for the
millimeter waves.  An additional advantage to this strategy is that there
is much more frequency space in the millimeter waves as compared with lower
frequency parts of the spectrum.

An additional approach is to establish smaller Freedom Bands restricted to
amateur radio operators that would be set up within carefully selected
sub-bands within the Amateur Radio service allocations.  The Commission
would need to consult in detail with the American Radio Relay League (ARRL)
and other elements of the amateur radio community to explore this
possibility.  Amateur radio operators have the technical background to put
the Freedom Bands to constructive use very rapidly.  Indeed, approximately
18 percent of the amateur radio operators hold the FCC’s Extra Class
license which is the highly demanding technical license.  (Reference One)  Many
amateur radio operators would welcome the wide freedom to experiment with
technology.  You would see many favorable new inventions from them.

Reference One: “US Amateurs Now 700,000 Strong!”, QST magazine, ARRL,
Newington Ct, December 2011, Page 65
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