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 Our work at ORI has identified that the 219-220 MHz band is hampered by outdated notification requirements that create unnecessary administrative burdens without providing meaningful interference protection.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 We have spoken up about removing the outdated and burdensom notification and permissions requirements for amateur radio stations operating on 219 MHz.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channels 10 and 13 (this is also supported by AAR and WISPA) along with reiterating the elimination of all of the outdated notification requirements in Part 80 and Part 97.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.