Revised CAPR 100-1 Open for Review - Comm Folks: Please Read

[desertengineer1]

All,

NHQ Comm staff recently updated and reviewed CAPR 100-1 among the DC's.  The revised regulation is now released for review IAW CAPR 5-4.  Comments to this document go through your wing commanders for formal review.

I highly encourage Communications Officers to take advantage of this process.  Take some time to review the document, record any concerns you may have (even grammar and descriptive concerns), pass them through your wing DC, and to the Wing CC.

Out of curiosity, I reveiwed the original draft a few months ago and provided a large number of general comments.  (Sadly, I do this kind of thing in the working life so I couldn't help it).  Most of them were general comments like use of slang terms, enigmatic descriptions, run-on sentences, ect..

Surprizingly, almost all of my comments were incorporated in the release for formal 5-4 review!!!   

So, this is a great opportunity for YOU Comm staffers to be part of the process.  OK, you were always part of the process - but this is unique.  You have a direct opportunity to be part of policy, and to help maximize its quality.

The regulation is here: 

http://members.gocivilairpatrol.com/forms_publications__regulations/publications_for_comment.cfm

[argentip]

Does anyone know why the "talkaround" has been removed on the repeater output freqs?  I see this as causing quite a bit of confusing especially for missions when you have various people on both simplex and repeater and limited comm equipment at the base.  I realize that you can scan on the new Johnson radios, but the operator will now have to pay much closer attention to either what channel is listed on the display and/or if you hear the repeater trailer.

[Ricochet13]

Have read through the current DRAFT of the 100-1.  Much better document than previous DRAFTs.

Still have a problem with philosophy behind the changes in CAP communications though, so won't comment further.  It will take a breakdown in communications in an actual SAR/DR situation to get the philosophy changed.

I do however, hope I am wrong and that the new direction of CAP communications succeeds.

"If it works, it's right" and I'll just continue on participating as best I can.

[♠SARKID♠]

I'm kind of annoyed that packet has been banned.  I had some great ideas that I wanted to try out using digital and now they're out the window.

[arajca]

One interesting issue is with planning:

Plans need to support the next higher echelon's plan, but that plan is made up of the lower echelons' plans. i.e. COWG plan needs to support RMR plan, but the RMR plan is made from the COWG, UTWG, WYWG, IDWG, and MTWG plans. Which gets developed first?

[JoeTomasone]

Filed 10 comments with my Wing/DC this afternoon.

[cap235629]

Filed 10 comments with my Wing/DC this afternoon.

Care to share?

[RADIOMAN015]

Does anyone know why the "talkaround" has been removed on the repeater output freqs?  I see this as causing quite a bit of confusing especially for missions when you have various people on both simplex and repeater and limited comm equipment at the base.  I realize that you can scan on the new Johnson radios, but the operator will now have to pay much closer attention to either what channel is listed on the display and/or if you hear the repeater trailer.

The regulation addresses this issues, e.g. it will be prohibited; however, there will be a new "guard" channel that everyone can monitor, etc.  Read the new regulation for the particulars.
RM

[JoeTomasone]

Filed 10 comments with my Wing/DC this afternoon.

Care to share?

1.  Section 9-15 should include language advising that use of Amateur Radio frequencies requires an Amateur Radio license.

2. Section 1-7(i) should indicate who authorized ANCS as (h) does for NCS.

3. Section 1-10 should include guidance surrounding releasing frequency data to organizations/individuals for the purpose of programming member-owned radios when the member lacks the ability to do so.   It is a matter of conjecture if this is a legitimate "need to know".

4.  Section 8-3(a) is ludicrous on its face for day-to-day CAP activities when repeater monitoring/usage is more practical.   Should be reworded to include language suggesting that the Guard frequency be used when simplex operations are established as the primary operational mode of the communications plan for the activity in question.    If I had to contact every station on simplex even during a UDF mission, I may as well not even turn the radio on.

5. Section 8-4(b)(b):  Could use language to indicate that inability to field program the tone is essentially equivalent to being incapable of operating on it.

6. Section 10-1(a):  Strongly disagree and suggest that this section be re-written to authorize use of equipment that is close enough to compliance that the delta is functionally insignificant and to require strict compliance only in cases where interference is demonstrated with a given transmitter.    It should be noted that CAP is the ONLY Federal agency to require strict compliance with the NTIA specification and that NTIA themselves has said that interference resolution is the governing principle.

7. Section 11-2(a)'s assertion that "Under federal law and regulation, instrumentalities of the United States and federal frequency users are prohibited from encroaching on civilian frequencies regulated by the Federal Communications Commission, including amateur radio frequencies." is completely erroneous and directly contradicts Section 9-12 which explicitly states that "the use of FRS radios is authorized IAW NTIA Regulations section 7.5.8.".    The NTIA themselves says in their Federal Long-Range Spectrum Plan, "As is current practice, there is and will be a limited amount of Federal use of non-government frequency bands, as well as non-government use of Federal frequency bands. The use of shared bands will continue to require coordination between NTIA and the FCC.".    Further, several Amateur Radio bands are shared with or co-located on those of Federal Government users.  FCC Amateur Rules specifically PERMIT communications with US Government stations necessary to providing communications with stations in RACES operations.

8. Section 11-2(b) contradicts both the definition of and FCC guidance on the concept of pecuniary interest.  Indeed, the FCC has stated in opinions going back almost a decade that law enforcement personnel who engage in disaster relief communications in the Amateur Service while in a paid duty status do NOT violate FCC rules:

"With regard to the specific request that we amend Section 97.113 of the Rules to clarify that amateur radio operators who are emergency personnel engaged in disaster relief are permitted to use the amateur service bands while in a paid duty status, we believe that such clarification is not necessary because these two-way communications are permitted within the existing rules.[1]  In this regard, we note that amateur radio operators who also are emergency personnel engaged in disaster relief do not appear to be receiving compensation for transmitting communications.  Rather, we believe that these individuals are receiving compensation for services related to their disaster relief duties and in their capacities as emergency personnel, and the fact they also are amateur radio operators is incidental to these functions.  Further, we note that under the Rules, if the control operator of an amateur service station, who also is an emergency services provider engaged in disaster relief, questions whether a particular message in support of disaster relief should be transmitted on amateur service frequencies, he or she is under no obligation to transmit the message.  If the control operator decides that a particular message is not appropriate for transmission on amateur service frequencies, we note that the message can be transmitted on frequencies allocated to other radio services, because disaster relief organizations are eligible for and have been assigned numerous radio channels in other radio services to meet their communication needs.[2]"
(FCC Order 99-2694)

Further, RACES Operation is done at the behest of the local government (OEM) IAW FCC Rules and this obviously cannot violate the rule that permits it.

9.  Section 11-2(c) is overly vague (whom, exactly, is a "CAP communication manager"?) and restrictive in that the only manner in which CAP traffic could be introduced into the Amateur Radio network for third-party transmission is by a CAP member signed into the mission.  This section would effectively require said CAP member to locate another CAP/Amateur member who is NOT signed into the mission to accept the traffic on CAP frequencies and retransmit it directly or to another Amateur for processing.   This is contrary to the interests of CAP in that it is both inefficient and slows down traffic processing by requiring more steps to complete the communication, and in that it encourages CAP members who are Amateurs to NOT sign in to the mission in order that they may facilitate third-party communications if required.

10.  Section 11-2(d) could also be considered to be not in the best interests of CAP communications as the sudden need for third-party handling could require a lengthy period to both locate and install a  member-owned Amateur Radio.   As the regulations already prohibit direct use of Amateur frequencies for CAP business and there is no FCC rule prohibiting the use of a CAP radio in the Amateur Service, it is recommended to permit such programming.   It should be noted that there are no directives prohibiting the programming of frequencies from other services (such as Maritime).