FCC Clarifies What Constitutes an Amateur Radio Repeater

In December 2007, Gary Mitchell, WB6YRU, President of the NorthernCalifornia Packet Association (NCPA), filed a Petition with the FCC,asking for the Commission to clarify the definition of a repeater.According to Part 97, Section 3(a)(39), A repeater in the amateurservice is "[a]n amateur station that simultaneously retransmits thetransmission of another amateur station on a different channel orchannels."

Mitchell sought clarification on the word "simultaneously," askingif it referred to the signal information being retransmitted, or tothe fact that the receiver and transmitter must both be active atthe same time while acting on the same signal information. On March23, 2009, the Commission clarified that even if there is a slightdelay between what is received and what it transmits (as in the caseof D-STAR and other digital repeaters), it is consideredsimultaneous if the receiver and transmitter are both active at thesame time.

Mitchell pointed out in his petition that while the Commission'sRules specify on which bands amateur repeaters may operate, "someamateur repeaters are operating on bands other than set forth inSection 97.205(b) with systems that are essentially voice repeaterstations, but that digitize and retransmit the user's voice, on thetheory that because there is a small delay in retransmitting thesignal of another amateur station, the signal is not'simultaneously' retransmitted and, therefore, the system is not arepeater.

"In its reply, the Commission pointed out that prior to 1994, arepeater was defined as "[a]n amateur station that automaticallyretransmits the signals of other stations." This, the Commissiontold Mitchell, was revised to clarify "that certain accommodationsfor message forwarding systems do not apply to other operatingactivities such as repeaters and auxiliary stations." The Commissionproposed to define a repeater as "[a]n amateur station thatinstantaneously retransmits the transmission of another amateurstation on a different channel or channels," but ultimately replaced"instantaneously" with "simultaneously" because commenters notedthat there is always a small propagation delay through a repeater.As one commenter explained, "The word 'simultaneously' in this casemeans that the repeater is receiving and transmitting concurrently,whereas each signal might be slightly displaced in time betweenreceive and transmit."To be able to repeat another station's transmission, the Commissionsaid that a repeater "must be able to receive a transmission fromanother station and retransmit it. Because the word 'simultaneously'in the definition is used to modify 'retransmit,' we believe itrefers to a repeater station's transmitter being active whenretransmitting the signal received by the repeater station'sreceiver from another amateur station.

We conclude, therefore, that'simultaneously' as used in the definition of a repeater refers tothe receiver and transmitter both being active at the same time.