W3BE'S BE Informed!
EmComm
 
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BE Informed No. 7.0  

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Providing

Emergency Communications (“EmComm”)

John B. Johnston W3BE

Q. I overhear hams using the word “EmComm.” What does that mean?

A. It is a vernacular for “emergency communications.” In places where the FCC regulates our amateur service, those hams are likely referring to the transmission of uncommon radio communications on our amateur service spectrum with Section 97.101(c) frequency occupancy priority over our normal amateur service radio communications. At all times and on all frequencies, each control operator must give priority to stations providing emergency communications, except to stations transmitting communications for training drills and tests in RACES.

   Our regulator, moreover, has tasked our amateur service with an awesome responsibility. It expects us to provide an alternative to the commercial communications infrastructure impacted by an emergency.

Q. Wow! Providing an alternative to the commercial communications infrastructure impacted by an emergency. That is a tall order! I sure hope it has other contingency plans. How much spectrum has been allocated for this project?

A. Absolutely none. The hams must accomplish it within the radio spectrum already allocated for our normal Section 97.3(a)(4) amateur service communications. Whenever directed to activate their alternative to the commercial communications infrastructure, those communications will have Section 97.101(c) frequency occupancy priority over our normal amateur service radio communications.

Q. The term “auxiliary” might be closer to reality than “alternative.” Amateur radio EmComm is rarely needed beyond a few days. Only a small portion of the VHF/UHF portions, and some HF, is used in the affected areas during and after initial failure of Part 90 systems. Health and Welfare messaging for families is sent primarily via HF. Part 90 systems, towers, and/or repeaters are quickly repaired or temporarily replaced by other equipment such as COLTs or COWs, cached Part 90 radios, or FEMA-loaned equipment. Power failures are the most common occurrences and temporary FEMA generators are usually loaned out to power the Part 90 systems. Telcos normally have only 4 hours to get generator power to their key cell towers.

A. It is difficult to foresee that our eclectic amateur service systems could, even at their very best, provide but a tiny fraction of the communications capabilities that the public and our public safety organizations are accustomed to using.  

Q. What are our normal amateur service communications supposed to be?

A. According to Section 97.3(a)(4), our amateur service communications are supposed to be radio intercommunications carried out by duly authorized persons interested in radio technique solely with a personal aim and without pecuniary interest – i.e., amateurs - for the purpose of self-training, intercommunication and technical investigations. Section 97.111 codifies the types of transmissions authorized to our amateur stations. Section 97.113 codifies the types of transmissions that are prohibited to our amateur stations.

Q. OK. So the rules don’t necessarily apply during an emergency. In this context, what is the meaning of the all-important trigger term emergency?

A. The term emergency is used – but not defined – in Part 97. A common meaning is a condition that requires prompt action. As far as a condition of such importance as to warrant actions inconsistent with the United States Code of Regulations, our regulator provides us with these clues:

1. Section 97.1 says Part 97 is designed to: (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.

2. Part 97 Subpart E codifies the rules for providing communications.

3. In its Report to Congress, our regulator said that it expects us to provide an alternative to the commercial communications infrastructure impacted by an emergency. This alternative infrastructure is the network of amateur radio operators and their stations that relay messages, build and maintain repeater stations and repeater networks, operate HF message networks to send messages greater distances than are practical with mobile or transportable transmitters, and develop new technologies to improve the reliability of these networks.

4. Section 97.113(b)(3)(i) says: A station licensee or station control operator may participate on behalf of an employer in an emergency preparedness or disaster readiness test or drill, limited to the duration and scope of such test or drill, and operational testing immediately prior to such test or drill. Tests or drills that are not government-sponsored are limited to a total time of one hour per week; except that no more than twice in any calendar year, they may be conducted for a period not to exceed 72 hours.  

Q. Do EmComm stations always have frequency occupancy priority over our amateur station transmissions?

A. No. Only during those times while they are actually transmitting Subpart E providing emergency communications. Section 97.101(c) says: At all times and on all frequencies, each control operator must give priority to stations providing emergency communications, except to stations transmitting communications for training drills and tests in RACES.

Q. What sort of emergency situations may trigger a Section 97.101(c) EmComm priority?

A. Here are four such situations.

   Firstly, there is the Section 97.401 operation during a disaster (“EmComm 401”) priority situation. It says: A station in, or within 92.6 km (50 nautical miles) of, Alaska may transmit emissions J3E and R3E on the channel at 5.1675 MHz (assigned frequency 5.1689 MHz) for emergency communications. The channel must be shared with stations licensed in the Alaska-Private Fixed Service. The transmitter power must not exceed 150 W PEP. A station in, or within 92.6 km of, Alaska may transmit communications for tests and training drills necessary to ensure the establishment, operation, and maintenance of emergency communication systems.

   Secondly, there is the Section 97.403 safety of life and protection of property (“EmComm 403”) priority situation. It says: No provision of these rules prevents the use by an amateur station of any means of radiocommunication at its disposal to provide essential communication needs in connection with the immediate safety of human life and immediate protection of property when normal communication systems are not available.

   Thirdly, there is the Section 97.405 station in distress (“EmComm 405”) priority situation. It says: (a) No provision of these rules prevents the use by an amateur station in distress of any means at its disposal to attract attention, make known its condition and location, and obtain assistance. (b) No provision of these rules prevents the use by a station, in the exceptional circumstances described in paragraph (a) of this section, of any means of radio communications at its disposal to assist a station in distress.

   Lastly, there is the Section 97.407 Radio amateur civil emergency service (“EmComm 407”) priority situation. Paragraph (c) therein says: An amateur station registered with a civil defense organization may only communicate with the following stations upon authorization of the responsible civil defense official for the organization with which the amateur station is registered: (more).

   Take note, however, the Section 97.101(c) frequency occupancy priority for EmComm 407 is effective only during periods when the station is actually providing emergency communications during periods of local, regional or national civil emergencies. It is not available to stations transmitting communications for training drills and tests in RACES.

Q. Who should declare and manage an EmComm call up?

A. For an EmComm 401 disaster situation call up, the declaration and management thereof should be made by the Alaska-Private Fixed Service authority.

   For an EmComm 403 safety of life and protection of property situation call up, the declaration and management thereof should be made by the licensees of the amateur stations engaged in that specific EmComm situation. Where the situation is such as to warrant, the Department of Homeland Security, public safety, emergency management, and amateur radio emergency communications associations and groups might take the lead.

   For an EmComm 405 station in distress situation call up, the declaration and management thereof should be made by persons having immediate knowledge of the distressed station’s predicament. Where the situation is such as to warrant, the Department of Homeland Security, public safety, emergency management, and amateur radio emergency communications associations and groups should take the lead.

   For an EmComm 407 RACES situation call up, the declaration and management should be made by the civil defense official for the organization with which the participating amateur stations are registered.

Q. How does an EmComm station make a Section 97.101(c) priority declaration for a channel?

A. One possible good amateur practice might be for the participating EmComm station to make periodic announcements explaining the EmComm Section 97.101(c) frequency occupancy priority and directing stations intending to transmit normal amateur communications to stand down. For more frequent declarations, participating EmComm stations could append a suitable indicator to the call sign at the end of each 10-minute Section 97.119 station identification announcement.

Q. As a ham, could I be called up to provide communications during a civil disturbance?

A. Not under any obligation brought about by having your FCC amateur service license grant. If you are also enrolled in a RACES organization, however, check with the chief officer of that body regarding any commitments to which you may have agreed.

Q. As a FCC-licensed ham, am I under any obligation to provide public service?

A. Yes, by accepting a Section 97.5(b)(1) operator/primary station license grant with the knowledge that in places where the FCC regulates, the rules are designed to provide an amateur radio service having – among five principles – Section 97.1(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. But chances are you are already providing it. Our regulator’s expectations should be being achieved, therefore, so long as our amateur service community is in compliance with the rules codified in Part 97.

Q. Some hams contend that ham radio is primarily for emergencies. That is why they got their call signs.

A. Maybe those hams must view our amateur service spectrum as the most convenient platform for their held-in-reserve backup emergency radio systems. The phrase particularly with respect to providing emergency communications in Section 97.1(a) is often cited when rationalizing a makeover of our amateur service into a low-cost junior alternative to the Part 90 Private Land Mobile Radio Services.

   Public safety entities normally utilize Part 90 radio systems. Part 90 has the public safety radio pool and specifically provides for the licensing of non-federal governmental entities - including law enforcement and fire protection - as well as medical services, rescue organizations, veterinarians, persons with disabilities, disaster relief organizations, school buses, beach patrols, establishments in isolated places, communications standby facilities, and emergency repair of public communications facilities. 

Q. Can I use my amateur station to voluntarily provide emergency communications during public disturbances?

A. Yes, but the Part 90 communication systems and the wireline and cellular common carrier communication systems that are normally accessible would have to become unusable in order for your amateur station to have Section 97.101(c) frequency occupancy priority over our normal

self-training, intercommunications, and technical investigations carried out by duly authorized persons interested in radio technique solely with a personal aim and without pecuniary interest

(“amateurs.”)

Q. Could my amateur station transmit communications for an employer during a civil disturbance?

A. Yes, but only to provide EmComm 403 essential communication needs in connection with the immediate safety of human life and immediate protection of property when normal communication systems are not available.

Q. Don’t stations engaged in a Section 97.113(a)(3)(i) test or drill also have a Section 97.101(c) priority?

A. No, they don’t. Such testing and drilling is not a Subpart E EmComm providing emergency communications response activity. As with normal amateur service communications, whenever a clear channel is desired, a courtesy priority can be requested over-the-air.

Q. Who can declare a Section 97.113(a)(3)(i) test or drill?

A. Anyone for whom some hams are willing to follow.

Q. How long can an EmComm response last?

A. An EmComm response should cease whenever the situational cause is resolved and/or whenever the commercial communications infrastructure impacted by the emergency become available again, whichever comes first.

Q. An effective EmComm response requires the participating stations to be prepared for an unexpected Subpart E event. This requires regular readiness testing and drilling. May the competent authorities declare a Section 97.101(c) EmComm priority and suspend all amateur service intercommunications and technical investigations on the channels?

A. Only for a Section 97.407 RACES call up. Even then, there are time limits imposed. Section 97.407(c) says: Communications for RACES training drills and tests necessary to ensure the establishment and maintenance of orderly and efficient operation of the RACES as ordered by the responsible civil defense organization served. Such drills and tests may not exceed a total time of 1 hour per week. With the approval of the chief officer for emergency planning in the applicable State, Commonwealth, District or territory, however, such tests and drills may be conducted for a period not to exceed 72 hours no more than twice in any calendar year.

Q. Is EmComm international in scope?

A. Not necessarily. International Radio Regulation No. 1.56 still defines our amateur service as a radio-communication service for the purpose of self-training, intercommunication and technical investigations carried out by amateurs, that is, by duly authorized persons interested in radio technique solely with a personal aim and without pecuniary interest. Section 97.117, moreover, still says transmissions to a different country, where permitted, shall be limited to communications incidental to the purposes of the amateur service and to remarks of a personal character.

Q. I read where the NTIA is in the early stages of building a nationwide, hardened, wireless network expressly for the use of first responders in emergencies and disasters.

A. Yes. It is called FirstNet. FirstNet is the acronym for the "First Responder Network Authority," and was created by The Middle Class Tax Relief and Job Creation Act of 2012. It is an independent authority within NTIA, intended to provide emergency responders with the first nationwide, high-speed, broadband network dedicated to public safety. It is supposed to initially focus on providing data and video. Voice capability is to come much later. 

Q. Won’t FirstNet diminish ham radio’s role as a backup to Part 90 public safety systems?

A. Currently, that role is not even within our regulators’ expectations for our participation in EmComm. Hams, however, are still eyes and ears on the ground and may be useful in disaster recovery. We are now expected to provide an alternative to the commercial communications infrastructure impacted by an emergency. But our future role in emergency communications will likely be limited because network failures are supposed to be far less common once FirstNet gets up and going. 

Q. What is NTIA?

A. The National Telecommunications and Information Administration (NTIA), located within the Department of Commerce, is the Executive Branch agency that is principally responsible by law for advising the President on telecommunications and information policy issues.

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October 7, 2017 

Supersedes all prior editions