Filed Federal Communications Com mission matter Amendment Part 97 Commissions Rules concerning operator classes privileges requirements Ama teur Radio Service behalf Academy Model Aeronautics 1 On December 16 1974 Commission re leased its Notice Proposed Rule Making above captioned proceeding proposing institute comprehensive revision Amateur Radio Service license classes Academy Model Aeronautics Inc its torneys hereby files its Comment pro ceeding 2 The Academy Model Aeronautics Inc hereinafter Academy Aeromodeling Division National Aeronautic Associa tion governing body aeromodeling activities United States Its current membership stands 54000 3 The Academy has very gratified over years Commission has consistently recognized model aircraft flying scien tific hobby substantial social value public significance has allocated number Citizens Radio Service frequencies important activity frequencies 27 MHz 72 MHz bands suitable modeler use view relatively low cost equipment bands thus making radio controlled aeromodeling activities available young people interests aviation fueled model air craft activities early life Unfortunately 27 MHz band frequencies adjacent used Class D Citizens Radio Service some members use extra unauthorized voice channels few have actually engaged sport shooting down radio controlled model air craft resulting very substantial monetary losses modelers creating potential danger spectators radio control aircraft go out control modelers have both spread Out frequency occupancy avoid above problems turned 72 MHz frequencies inherent limitations band because use adjacent fre quencies television stations channels 4 5 problems have fully explained Academys Comments FCC Docket No 19759 incorporated herein reference 4 In short areas country air craft modelers having increasing difficulty pursuing activities safe manner frequencies now available use practical solution appears access other frequencies subject difficulties now encountered Academy therefore interested Commis sions proposal create Communicator Class operator license having no telegraphy examina tion requirement would allow access Amateur Radio frequencies above 144 MHz 5 The Academy believes new class license offers opportunity radio control modelers qualify such Communicator Class Amateur licenses alleviate problems heretofore mentioned using frequencies above 144 MHz model control purposes Academy also believes such qualification use will lead modelers upgrade skills qualify Tech nician Class license order able use 50-54 MHz Amateur Band Use latter band Technician Class Amateur li censees now widespread practice Academy estimates about ten fifteen percent its membership about 5000 modelers hold Amateur licenses use AMA -FC Frequency Efforts Gntinue Under current leadership John Strong Wheaton Md AMA Frequency Committee continuing its efforts years since 1950s obtain additional frequencies radio control operation protect already use com mittees latest effort conjunction current major exploration Federal Communications Commission involving expansion new areas revision present amateur licensing requirements AMAs officially filed position matters published represents consid erable committee correspondence subject extensive consultation AMAs legal counsel also follows pattern AMAs previously very successful efforts FCC 50-54 MHz band flying activities Most licensees Technician Class 6 The Academy respectfully submits making Communicator Class licensees eligible model radio control activities clearly spirit proceeding con sonance logical relationship between qualification requirements operator privileges authorized license level However written Docket pro posed revisions Part 97 Commissions regulations appearing Appendix provide specifically such activity part Communicator Class licensees Therefore Academy respectfully requests Commission a Expand existing Rule Section 9799 Stations Used Only Radio Control Remote Model Crafts Vehicles add ing new subparagraph e Amateurs holding Communicator Class licenses may operate equipment under provisions Section amateur frequencies above 144 MHz b Expand proposed Rule Section 977g including fourth subsection 4 Emission A-l A-2 solely under provisions Section 9799 7 The Academy also respectfully requests consideration given continuation mail examinations Technician Class license once obtained such examination license renewable Further Academy requests Communicator Class license available mail examination basis renewable Academys reasons such requests stem following considerations a The bulk nations radio control modeling activities carried Academy chartered clubs have least few members higher level Amateur licenses clubs provide classes instruct members appropriate written code require ments Commissions proposed tightening conduct mail exami nations believed Commis sion can assured adequate compe tency part successful candidates two license classes b In case several thousand model radio control flyers have al ready successfully qualified Tech nician Class license Academy sub mits licenses earned good faith require dividuals travel FCC examining location renew class license unwarranted hardship existing licensees 8 In summary Academy recommends proposed rule making adopted Commission modified include following provisions a Permit radio control activities Com municator Class licensees frequencies above 144 MHz b Permit Communicator Technician Class licenses obtained mail exami nation renewable Respectfully submitted Academy Model Aeronautics Inc Jeremiah Court ney Its Attorney Washington DC July 16 1975 AMA Frequency Committee currently consists following John Strong chair man Dr Walter Good Bethesda Md Richard Jansson Wellesley Hills Ma Lt Col C T Williams APO New York Note Bob Aberle Hauppauge NY joined commit tee Julyhis recent individual efforts recognized committee invited join group broaden its representation similarly Jack Albrecht San Francisco replac ing former California member Hugh Stock October1975 45 John Strong RMR s rrequncy Committee chairman has considerable experience moni toring RC frequencies major events Shown Transpo 72 performed similar serv ices 1971 RC World Championships 1974 AerOlympics SPECIAL ORGANIZATIONS CoNT Flight Society would look after FF needs other hand has come light special interest organizations combined encompass minority modelers--approximately 10% AMA membership means about 9 out ten AMA members dont belong such organiza tions unrepresented ex cept geographically elected officers AMA So special interest organizations influential visible serious question concerning much voice AMA affairs should given Until determined AMAs policy cooperate such ex isting organizations encourage formation others Meanwhile much larger block AMA members also members AMA chartered clubs-about 54% suggests clubs somehow should included ideas about improving member representa tion AMA policy making special interest organization picture dramatizes basic difference among two basic groups AMA members Most special interest organ izations competition oriented yet AMA members better represent both basic interests obvious short sighted con clusion might restructure AMA its budget reflect majority members Yet could destroy what has very effective arrangement benefits both groups simple fact both groups need other Practically technological prog ress has come minoritythe com petition enthusiasts constantly seeking performance improvements en gines accessories fuels model design equipment provide Indiana polis Effect--testing proving pro ducts ultimate benefit Yet its dollars Sunday flier provide basis competition programs services result better products enjoy have positive proof benefits --AMA membership model aviation general time high numbers activity would out drive persistance competi tion people telescope development time everything modelers use effect ambition competi tors enables Sunday fliers relax enjoy what doing having get involved rat race competition--the products competition come freely naturally minimum diversion doing thing So status quo pretty good thing can improved no doubt caution seems needed avoid serious disruption what has mutually beneficial balance interests Toward end AMA Executive Council currently reviewing entire struc ture AMA representation see current procedures policies may improved new variations may added FLYING SITES Individual AMA members working through local chartered clubs constitute backbone US aeromodeling club flying site itself forms nucleus club activities steadily growing problem threatening limit curtail such activities Clubs now find more time being spent keeping flying sites have acquiring additional fields membership grows current facility threatened AMA headquarters has spent man hours flying site situation answering inquiries helping solve local problems arise An about to-be printed AMA book called Getting & Keeping Flying Sites concludes group efforts clubs alliances several clubs generally successful acquiring flying sites its relatively easy two outside club deny use field modelport shut existing facility down its neces sary show people would adversely affected order counter threat Continued page 49 46 Model Aviation
Edition: Model Aviation - 1975/10
Page Numbers: 45, 46
Filed Federal Communications Com mission matter Amendment Part 97 Commissions Rules concerning operator classes privileges requirements Ama teur Radio Service behalf Academy Model Aeronautics 1 On December 16 1974 Commission re leased its Notice Proposed Rule Making above captioned proceeding proposing institute comprehensive revision Amateur Radio Service license classes Academy Model Aeronautics Inc its torneys hereby files its Comment pro ceeding 2 The Academy Model Aeronautics Inc hereinafter Academy Aeromodeling Division National Aeronautic Associa tion governing body aeromodeling activities United States Its current membership stands 54000 3 The Academy has very gratified over years Commission has consistently recognized model aircraft flying scien tific hobby substantial social value public significance has allocated number Citizens Radio Service frequencies important activity frequencies 27 MHz 72 MHz bands suitable modeler use view relatively low cost equipment bands thus making radio controlled aeromodeling activities available young people interests aviation fueled model air craft activities early life Unfortunately 27 MHz band frequencies adjacent used Class D Citizens Radio Service some members use extra unauthorized voice channels few have actually engaged sport shooting down radio controlled model air craft resulting very substantial monetary losses modelers creating potential danger spectators radio control aircraft go out control modelers have both spread Out frequency occupancy avoid above problems turned 72 MHz frequencies inherent limitations band because use adjacent fre quencies television stations channels 4 5 problems have fully explained Academys Comments FCC Docket No 19759 incorporated herein reference 4 In short areas country air craft modelers having increasing difficulty pursuing activities safe manner frequencies now available use practical solution appears access other frequencies subject difficulties now encountered Academy therefore interested Commis sions proposal create Communicator Class operator license having no telegraphy examina tion requirement would allow access Amateur Radio frequencies above 144 MHz 5 The Academy believes new class license offers opportunity radio control modelers qualify such Communicator Class Amateur licenses alleviate problems heretofore mentioned using frequencies above 144 MHz model control purposes Academy also believes such qualification use will lead modelers upgrade skills qualify Tech nician Class license order able use 50-54 MHz Amateur Band Use latter band Technician Class Amateur li censees now widespread practice Academy estimates about ten fifteen percent its membership about 5000 modelers hold Amateur licenses use AMA -FC Frequency Efforts Gntinue Under current leadership John Strong Wheaton Md AMA Frequency Committee continuing its efforts years since 1950s obtain additional frequencies radio control operation protect already use com mittees latest effort conjunction current major exploration Federal Communications Commission involving expansion new areas revision present amateur licensing requirements AMAs officially filed position matters published represents consid erable committee correspondence subject extensive consultation AMAs legal counsel also follows pattern AMAs previously very successful efforts FCC 50-54 MHz band flying activities Most licensees Technician Class 6 The Academy respectfully submits making Communicator Class licensees eligible model radio control activities clearly spirit proceeding con sonance logical relationship between qualification requirements operator privileges authorized license level However written Docket pro posed revisions Part 97 Commissions regulations appearing Appendix provide specifically such activity part Communicator Class licensees Therefore Academy respectfully requests Commission a Expand existing Rule Section 9799 Stations Used Only Radio Control Remote Model Crafts Vehicles add ing new subparagraph e Amateurs holding Communicator Class licenses may operate equipment under provisions Section amateur frequencies above 144 MHz b Expand proposed Rule Section 977g including fourth subsection 4 Emission A-l A-2 solely under provisions Section 9799 7 The Academy also respectfully requests consideration given continuation mail examinations Technician Class license once obtained such examination license renewable Further Academy requests Communicator Class license available mail examination basis renewable Academys reasons such requests stem following considerations a The bulk nations radio control modeling activities carried Academy chartered clubs have least few members higher level Amateur licenses clubs provide classes instruct members appropriate written code require ments Commissions proposed tightening conduct mail exami nations believed Commis sion can assured adequate compe tency part successful candidates two license classes b In case several thousand model radio control flyers have al ready successfully qualified Tech nician Class license Academy sub mits licenses earned good faith require dividuals travel FCC examining location renew class license unwarranted hardship existing licensees 8 In summary Academy recommends proposed rule making adopted Commission modified include following provisions a Permit radio control activities Com municator Class licensees frequencies above 144 MHz b Permit Communicator Technician Class licenses obtained mail exami nation renewable Respectfully submitted Academy Model Aeronautics Inc Jeremiah Court ney Its Attorney Washington DC July 16 1975 AMA Frequency Committee currently consists following John Strong chair man Dr Walter Good Bethesda Md Richard Jansson Wellesley Hills Ma Lt Col C T Williams APO New York Note Bob Aberle Hauppauge NY joined commit tee Julyhis recent individual efforts recognized committee invited join group broaden its representation similarly Jack Albrecht San Francisco replac ing former California member Hugh Stock October1975 45 John Strong RMR s rrequncy Committee chairman has considerable experience moni toring RC frequencies major events Shown Transpo 72 performed similar serv ices 1971 RC World Championships 1974 AerOlympics SPECIAL ORGANIZATIONS CoNT Flight Society would look after FF needs other hand has come light special interest organizations combined encompass minority modelers--approximately 10% AMA membership means about 9 out ten AMA members dont belong such organiza tions unrepresented ex cept geographically elected officers AMA So special interest organizations influential visible serious question concerning much voice AMA affairs should given Until determined AMAs policy cooperate such ex isting organizations encourage formation others Meanwhile much larger block AMA members also members AMA chartered clubs-about 54% suggests clubs somehow should included ideas about improving member representa tion AMA policy making special interest organization picture dramatizes basic difference among two basic groups AMA members Most special interest organ izations competition oriented yet AMA members better represent both basic interests obvious short sighted con clusion might restructure AMA its budget reflect majority members Yet could destroy what has very effective arrangement benefits both groups simple fact both groups need other Practically technological prog ress has come minoritythe com petition enthusiasts constantly seeking performance improvements en gines accessories fuels model design equipment provide Indiana polis Effect--testing proving pro ducts ultimate benefit Yet its dollars Sunday flier provide basis competition programs services result better products enjoy have positive proof benefits --AMA membership model aviation general time high numbers activity would out drive persistance competi tion people telescope development time everything modelers use effect ambition competi tors enables Sunday fliers relax enjoy what doing having get involved rat race competition--the products competition come freely naturally minimum diversion doing thing So status quo pretty good thing can improved no doubt caution seems needed avoid serious disruption what has mutually beneficial balance interests Toward end AMA Executive Council currently reviewing entire struc ture AMA representation see current procedures policies may improved new variations may added FLYING SITES Individual AMA members working through local chartered clubs constitute backbone US aeromodeling club flying site itself forms nucleus club activities steadily growing problem threatening limit curtail such activities Clubs now find more time being spent keeping flying sites have acquiring additional fields membership grows current facility threatened AMA headquarters has spent man hours flying site situation answering inquiries helping solve local problems arise An about to-be printed AMA book called Getting & Keeping Flying Sites concludes group efforts clubs alliances several clubs generally successful acquiring flying sites its relatively easy two outside club deny use field modelport shut existing facility down its neces sary show people would adversely affected order counter threat Continued page 49 46 Model Aviation