Connecting the Dots: Protecting and Improving Amateur Radio Access to 219-220 MHz

Introduction

The 219-220 MHz band represents both a challenge and an opportunity for the amateur radio community. Recent events highlighted in the Convair/220 Amateur Radio Club’s newsletter “Contrails” and the DR0NK Radio Network’s report demonstrate how vigilance is essential for protecting our spectrum rights. While our ongoing work at Open Research Institute (ORI) focuses on removing unnecessary regulatory barriers to make this valuable spectrum more accessible, it took boots on the ground to defend the 220 band from unexpected and harmful interference.

The Twin Challenges: Interference and Regulatory Burden

The amateur radio community currently faces two related challenges in the 220 MHz vicinity. First, external threats. As documented by the DR0NK Radio Network (https://k1ct.freeshell.org/c220.html), experimental licenses granted without proper consideration of existing amateur services have caused significant interference to operations in the 222-225 MHz band (see the April 2025 newsletter – we have a copy of it here). This experience serves as a warning about potential threats to adjacent frequencies. In addition, regulatory barriers still exist. Our work at ORI has identified that the 219-220 MHz band is hampered by outdated notification requirements that create unnecessary administrative burdens without providing meaningful interference protection.

Our Regulatory Approach

ORI has been actively participating in the FCC regulatory process with proposals that would streamline operations while maintaining necessary technical safeguards. We have spoken up about removing the outdated and burdensom notification and permissions requirements for amateur radio stations operating on 219 MHz. See https://www.openresearch.institute/2025/04/01/fcc-filing-for-219-mhz-rules-changes-from-ori/

Our most recent comments go further than this, and support removing regulations requiring interference studies to protect television channels 10 and 13 (this is also supported by AAR and WISPA) along with reiterating the elimination of all of the outdated notification requirements in Part 80 and Part 97.

REPLY COMMENTS OF OPEN RESEARCH INSTITUTE, INC
Open Research Institute, Inc replies in support of certain comments filed by the Association of American Railroads (AAR) [1], WISPA [2], and Steven K. Stroh [3].
Specifically, we support section II of the AAR comments requesting the removal of regulations requiring interference studies to protect television stations using Channel 10 and Channel 13.
We also support WISPA’s comments regarding Part 80 of the Commission’s regulations requesting the same removal of interference studies. These regulations are outdated and based
on a coast station use of AMTS that was never widely deployed. Furthermore, we support Steven K. Stroh’s recommendation to delete 97.307(f)(13) which restricts amateur station emissions
in 219-220 MHz (hereafter “219”) from using more than 100 kHz of bandwidth. We take no position on other comments made by the AAR, WISPA, or Steven K. Stroh.
We believe that our comments [4] serve to encourage wider use of AMTS spectrum by removing other burdensome notification regulations in Part 80
that require AMTS licensees to notify the American Radio Relay League and Interactive Systems of station locations. Our proposed removal of notification requirements for
219 in Part 97 serve the same purpose.
The AAR observes that most Positive Train Control deployments are “[…] primarily located within railroad rights-of-way and generally away from households […]”.
This necessarily limits the potential for harmful interference given we do not advocate for mobile use of 219 by amateur stations.
Beyond documented Amateur Radio Service history in coexisting with primary users, we believe our proposed retention of many of the restrictions on amateur use (secondary status, reduced power levels, fixed stations, and digital emissions) will sufficiently reduce the possibility of harmful interference with AMTS licensees. In sum, we believe that our proposals, combined with those of AAR, WISPA, and Steven K. Stroh will lead to more efficient commercial and amateur use of 219-220 MHz. In keeping with the Commission’s goal of removing regulations, all of these
proposals can be implemented solely as rule deletions.
[1] https://www.fcc.gov/ecfs/search/search-filings/filing/10412030480052
[2] https://www.fcc.gov/ecfs/search/search-filings/filing/104111661931041
[3] https://www.fcc.gov/ecfs/search/search-filings/filing/10412237159703
[4] https://www.fcc.gov/ecfs/search/search-filings/filing/10329271641887

In the past, we have supported the removal of the 100 kHz bandwidth restriction for amateur stations in the 219-220 MHz band, and continue to do so now. 

The Connection to Recent Interference Cases

The DR0NK Radio Network’s experience with interference from improperly granted experimental licenses offers valuable lessons for our regulatory advocacy. Documentation is critical. Success came through “coordinating efforts” and “documenting and communicating real issues.”

Technical arguments prevaied. Successful spectrum defense relied on demonstrating actual harmful interference through technical measurements, not administrative formalities.

Community vigilance works. As DR0NK notes, “the price of freedom, and of spectrum, is eternal vigilance.” This vigilance allowed them to detect and address interference that administrative processes failed to prevent.

Conclusion

ORI’s approach balances regulatory streamlining with responsible spectrum sharing. By eliminating outdated administrative barriers while maintaining secondary status and technical safeguards, we can make the 219-220 MHz band more accessible to amateurs while protecting primary users. The recent experiences documented by the DR0NK Radio Network demonstrate that our community can effectively protect spectrum through technical vigilance rather than bureaucratic procedures. Removing unnecessary and outdated bureaucratic procedures clears the way for operators and enthusiasts to effectively and efficiently police the bands. 

FCC Filing for 219 MHz Rules Changes from ORI

Thank you to the many people that have helped with this effort. Open Research Institute (ORI) has filed the first of what might be several comments and proposed rules making efforts to the FCC about reforming amateur radio use of the 219 MHz band.

https://www.fcc.gov/ecfs/search/search-filings/filing/10329271641887

The list of folks that have contributed and supported this effort to renovate 219 MHz for actual amateur radio use is quite long. This filing and any that follow are the result of over a year of work. Thank you especially to Mike McGinty, ARRL advisors, and Justin Overfelt. 

If you would like to help? 

1) Please use this comment to make your own similar request under this particular proceeding. This is a “what regulations do you want to delete?” type of call. As with many FCC calls for comment, it will be dominated by commercial interests. Anything from amateur radio will stand out. The deadline for comments is 11 April 2025. Speak simply and directly. We’d like to use this band without unnecessary and burdensome requirements. 

2) Please be ready to file a “reply” comment after the 11 April 2025 deadline. This is a chance for you to say “I agree with this and support this.”

We are not asking to change the fundamental nature of the band. Fixed digital messaging forwarding is super exciting these days because of SDRs, mesh networking, and all sorts of amazing protocol work available to us. We decided to simply ask for removal of the notification and permissions requirements. These requirements have resulted in zero use of this band for over two decades. 

The primary service back in the late 1990s when these rules came out was maritime (AMTS). Those licenses were never fully deployed and have now been leased out by railroads. This means, to us, that the permissions requirements now make no sense at all for secondary licensees. 

ORI is tired of this and is working to make this situation better. This is a great band with huge, innovative, digital promise. We deserve to have a seat at this table and that means the chair has to actually exist and the door to the room the table is located within has to actually be something we can open.