******************************************************** NOTICE ******************************************************** This document was converted from WordPerfect to ASCII Text format. Content from the original version of the document such as headers, footers, footnotes, endnotes, graphics, and page numbers will not show up in this text version. All text attributes such as bold, italic, underlining, etc. from the original document will not show up in this text version. Features of the original document layout such as columns, tables, line and letter spacing, pagination, and margins will not be preserved in the text version. If you need the complete document, download the WordPerfect version or Adobe Acrobat version, if available. ***************************************************************** Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Flash Comm, Inc. Request for Waiver of the Commission's Rules Regarding Its Application for Authorization in the High Frequency Band ) ) ) ) ) ) ORDER Adopted: July 10, 1997 Released: July 10, 1997 By the Deputy Chief, Wireless Telecommunications Bureau and the Chief, Office of Engineering and Technology; I. INTRODUCTION 1. The Wireless Telecommunications Bureau ("the Bureau") hereby conditionally grants authority to Flash Comm, Inc. ("Flash Comm") to construct and operate, on a secondary basis, a nationwide, commercial, two-way short-data messaging system in the high frequency ("HF") range of the electromagnetic spectrum (3 to 30 MHz), subject to certain technical and operational limitations set forth herein. The Bureau believes this action will substantially benefit the public by allowing Flash Comm to offer, without further regulatory delay, a ubiquitous, technically novel service providing economical locating, monitoring and telemetering of private and public assets and infrastructure. Authorization of this system will also provide valuable technical operational data to assist the Commission in evaluating proposals to establish rules permitting permanent operations of this type in the HF band. II. BACKGROUND 2. Flash Comm describes itself as "an information products and services company recently formed to serve the specialized wide-area messaging needs of various sectors of the business, transportation and public safety communities." Flash Comm seeks to provide this service using a unique HF technology that was developed by Harris Corporation for military purposes. The Flash Comm system will provide a two-way data messaging capability by employing this HF technology for the reverse link, and using existing one-way commercial telecommunications channels, such as the leased subcarriers of FM broadcast stations, to provide the forward link. 3. In the Flash Comm system, transponders will be installed on or near customer- owned "assets", including mobile vehicles such as trucks and railroad rolling stock, as well as fixed infrastructure such as warehouses, railroad crossings, or highway bridges. These transponders, which Flash Comm calls "Intelligent Transceiver Units", will make it possible to track the location or monitor the status of the vehicles and infrastructure, no matter where in the United States they are located. Each transponder will transmit only when directed to by the Flash Comm system. When so commanded, it will transmit a short digital "burst," less than 2 seconds in duration on average, on an unoccupied (at that moment in time) HF channel selected automatically by the Flash Comm system. The Flash Comm system will choose an optimal HF channel for the transponder to use based on ionospheric propagation algorithms and a clear channel assessment process involving six geographically diverse scanning receivers. 4. Initially, Flash Comm explored the possibility of designing its system to operate on an unlicensed basis under the provisions of Part 15 of the Commission's rules. However, after consultation with Commission staff in late 1995, it was determined that this option would not be technically feasible. 5. On February 9, 1996, Flash Comm filed an application for authorization of its system in the Business Radio Service under Part 90 of the Commission's rules. As filed, the application included a request that the Commission waive three minor technical Part 90 rules. First, the Flash Comm application requested that Section 90.266(f) be waived to allow the use of a narrow phase modulated digital emission type originally described as a "stealth" waveform developed for military applications. Second, the application requested that the station identification requirements of Section 90.425 be waived to avoid extending the length of transmissions. Flash Comm suggested that a recordkeeping requirement could serve in lieu of station identification to assist in identifying Flash Comm transmissions in the event of interference. Finally, the Flash Comm application sought a waiver of the type acceptance requirement of Section 90.203, recognizing that the Commission's equipment authorization process is structured for services regularly authorized by rules, rather than systems authorized by waiver of the rules. 6. The application also contains a narrative exhibit expressing the view that authorization of the type of system contemplated by Flash Comm is consistent with existing Part 90 rules and Commission policy. Flash Comm explains that its system will be used for monitoring and telemetering purposes that, while vitally important to public and private interests, currently are economically infeasible because of the lack of a cost-effective data return link. Additionally, the exhibit offers justification for the requested minor rule waivers. 7. On May 12, 1997, Flash Comm filed a petition requesting that the Commission initiate a rule making proceeding to adopt rules for the regular authorization of this type of system. This petition has been assigned the number RM-9104. III. SUMMARY OF THE COMMENTS 8. Comments received. The Bureau released a Public Notice on March 8, 1996, inviting comments on the Flash Comm waiver request. Comments were filed by five entities that represent current primary users of the HF spectrum. The commenters are Globe Wireless ("Globe"), Mobile Marine Radio, Inc., ("MMR") and Aeronautical Radio, Inc. ("ARINC"), who are licensees in the maritime and aviation services, the American Radio Relay League, Inc. ("ARRL"), a national organization representing amateur radio operators, the Federal Aviation Administration ("FAA") and the Defense Information Systems Agency ("DISA") on behalf of the Department of Defense ("DoD")., Replies were filed by Flash Comm and MobileMedia Communications, Inc. ("MMCI"). 9. Interference potential. All of the commenters oppose a Commission grant of the Flash Comm application and waiver request. While noting that they object to the Commission granting a waiver of one or more of the minor rules cited by Flash Comm, the commenters also make it clear that their principal concern is not these minor rule waivers, but rather the authorization of the Flash Comm system at all. These commenters point out that the proposed Flash Comm system appears to be significantly different from any other HF system that has ever been authorized for use under Part 90, both in technical operation and in scope. Most of the commenters are concerned that operation of the Flash Comm system could pose an unacceptable risk of harmful interference to their present or future HF operations. 10. For example, ARINC argues that the Flash Comm system could adversely affect systems using the International Fixed and Aeronautical Mobile bands. ARINC notes that it often obtains Special Temporary Authority to use the portions of the HF bands for which Flash Comm seeks frequency assignments, during emergencies such as hurricanes, floods and other situations that interrupt normal communications paths. ARINC also believes that the Flash Comm HF transponders could cause interference to land receivers in the adjacent aeronautical mobile service bands. ARINC states that Flash Comm has mischaracterized its system as "frequency hopping", implying that it has the undetectable characteristics of a spread spectrum system. ARINC observes that the Flash Comm system would not merely increase the noise floor, but would be detectable by conventional receiving equipment. 11. The FAA offers similar objections in regard to the potential for interference to Aeronautical Mobile (Route) Service ("AM(R)S"). The FAA states that any license for Flash Comm's proposed operation must specifically exclude channels within the AM(R)S bands. FAA notes that only by such an exclusion, "assurance can continue to be provided that the AM(R)S frequency bands will be protected from potentially harmful interference." 12. Globe agrees with ARINC and expresses concern that granting Flash Comm's request could lead to similar requests by other Part 90 eligibles and could eventually result in "undisciplined use" of the HF spectrum for land mobile and Business radio applications. MMR, which provides public coast station service, notes that the Flash Comm's proposed use of some of the HF channels listed in its application would conflict with existing use provided for these channels in the regulations governing maritime communications in Part 80 of the Commission's rules. 13. Although Flash Comm has not proposed operation in the portions of the HF spectrum currently allocated for amateur radio operations, ARRL nevertheless objects to authorization of the Flash Comm system. ARRL contends that such operation could represent a potential source of interference to future amateur radio operations in portions of the HF bands that have been identified by the National Telecommunications and Information Agency ("NTIA") as potential candidates for allocation to the Amateur Radio Service in upcoming international conferences. ARRL observes that the NTIA report states that future expansion and upgrading of international amateur radio HF allocations will depend on the future decrease of requirements for the aeronautical mobile and fixed services internationally. ARRL requests that Flash Comm exclude the HF segments under consideration for near-term allocation to the amateur service, and indicates that, if Flash Comm does so, ARRL will withdraw its objection. 14. DISA filed a comprehensive analysis of the potential effect of operation of the Flash Comm system upon critical National Security / Emergency Preparedness ("NS/EP") operations. According to DISA, a major problem with respect to the effect of Flash Comm's system on government use of the HF spectrum is that Flash Comm's method of determining whether a channel is not in use is not sophisticated enough to determine if the channel is indeed clear. According to DISA, military HF radio facilities use receiving systems many times more sensitive than those proposed by Flash Comm. Thus, a military facility could be receiving weak signal transmissions that are unheard by the Flash Comm system. DISA also objected to Flash Comm's request for a waiver of type acceptance. It submits that such waivers have been granted in the past, but generally for one-of-a-kind units. In the case of Flash Comm, DISA notes, the type acceptance waiver could eventually cover hundreds or thousands of transmitters, eventually made by different manufacturers, not all of which would be of "equal competence". 15. Procedural objections. Because ionospheric propagation of HF radio transmissions is worldwide, Globe believes that ITU notification is required for a system such as Flash Comm. MMCI apparently considers Flash Comm to be a potential competitor for nationwide messaging service and objects to the process by which Flash Comm seeks authority, stating that Flash Comm has requested "a slew of blanket rule waivers" and seeks to be exempt from the kinds of regulations by which its competitors must abide. MMCI further argues that the technical parameters for a service such as Flash Comm must be considered in a rule making proceeding. 16. DISA states that, in addition to the three formally-requested rule waivers, there are two more "hidden" waiver requests implied in the Flash Comm petition to the FCC. By this DISA first refers to rules (e.g. Section 90.266) governing HF spectrum policy which provide that HF assignments may be made only for emergency, standby backup facilities and for uses "...highly important to the national interest and where other means of communications are unavailable." While it may be publicly beneficial, according to DISA, the Flash Comm system is not "highly important to the national interest" within the generally understood meaning of that term as applied to HF spectrum policy. DISA also notes that there are satellite-based alternatives to Flash Comm's system. In the second instance, DISA notes that the HF channels are normally assigned specifically rather than in ranges. 17. Flash Comm reply. Addressing the concerns of the commenters, Flash Comm in reply notes that its operating carrier frequency list excludes channels within the maritime and aviation safety service bands and the current amateur radio bands. Furthermore, Flash Comm states that it can temporarily or permanently "lock out" (exclude from further usage) any specific HF channels that may be in use under an emergency STA or that may be found to cause adjacent channel interference, concerns that were raised by ARINC, or any channels that may be allocated to the amateur radio service in the future, a concern noted by ARRL. Flash Comm also withdrew its request for waiver of the type acceptance rule, as type acceptance is considered by DISA to be essential to avoid interference caused by out-of-specification equipment operation. Also, in its reply, Flash Comm clarified certain minor points. 18. Proposed licensing conditions. After additional correspondence between Flash Comm and DISA, and meetings with NTIA, Flash Comm developed a set of proposed licensing conditions that it believes adequately address the collective concerns of the Federal agencies that use the HF spectrum. In a March 7, 1997 letter from NTIA Associate Administrator Richard D. Parlow to the Bureau ("NTIA letter"), it is stated that the proposed licensing conditions (set forth in an attachment to that letter) provide a "possible basis for accommodating Flash Comm in the HF bands." 19. The proposed licensing conditions include a number of provisions intended to reduce the likelihood of harmful interference to existing active and passive HF operations, and to provide procedures for immediate relief in the event interference does occur. For example, the Flash Comm system will be controlled by a master control center having the capability to selectively cease transmission from any transponder or from all transponders. The Flash Comm transponders may transmit only on HF channels specified in a list of carrier frequencies. Additionally, the conditions establish limits on the duration of transmissions, geographic channel occupancy, directivity of HF transmit antennas and daily average power density and daily transmitted energy. The Flash Comm HF service may operate only on a secondary basis to other authorized HF services. Only FCC type-accepted HF transmitting equipment may be used. Finally, a publicly accessible log of all HF transmissions must be maintained. IV. DISCUSSION 20. Section 90.151 of the Commission's rules sets forth requirements for a request to waive a provision of Part 90 of the Commission's Rules. This rule requires that requests for waiver of rules show that unique circumstances are involved and that there is no reasonable alternative solution within existing rules. When deciding whether grant of a particular waiver request is justified, the Commission looks to two criteria; namely that either (1) the underlying purpose of the rule would not be served or would be frustrated by its application to the instant case, and that a grant of the requested waiver would be in the public interest, or (2) in view of unique or unusual factual circumstances of the instant case, application of the rule would be inequitable, unduly burdensome or contrary to the public interest, and that the applicant has no reasonable alternative. 21. After consideration of the factual circumstances in the record, we find that Flash Comm has made a compelling case that its proposed service will indeed be a unique and cost-effective way to monitor public and private property and infrastructure. We find that applying rules designed for conventional VHF and UHF private radio facilities to the Flash Comm system would be inequitable, unduly burdensome, and contrary to the public interest. 22. We also conclude that Flash Comm's modified proposal satisfactorily addresses the concerns of Globe, MMR, ARINC and ARRL that operation of the Flash Comm system may cause interference to their operations. First, we note that the list of Flash Comm HF channels does not include frequencies falling within the maritime or aviation safety service spectrum or the current amateur radio bands. In regard to prospective future allocations to the amateur radio service, we note that, in the event such band expansions for the amateur radio are made in the future, Flash Comm's operation will be on a secondary basis to amateur radio operations in those segments, and that any interference problems that may occur can be addressed at that time. 23. With respect to the DoD concerns of interference or other impact on federal defense HF usage, we consider the licensing conditions proposed in the NTIA letter, as modified and approved by NTIA and included as Appendix A to this Order, to be dispositive of these concerns. These conditions reduce the likelihood of interference with DoD's active and passive HF operations, and provide a mechanism for addressing interference if it does occur. Moreover, we have received notification from NTIA on behalf of DoD and the other Federal users of the HF spectrum that they concur with our authorization of the Flash Comm system, provided that it operates in compliance with the aforementioned licensing conditions. 24. Finally, we also note that operation of the Flash Comm system may yield operational and technical data that could be useful to the Commission in its consideration of proposed rules for regular operations in the HF spectrum. The Flash Comm system is designed to automatically maintain log data showing the technical parameters resulting in successful data communications over the HF link. 25. Accordingly, we are granting a 5 year authorization to Flash Comm to construct and operate their system, conditioned on the outcome of any proceeding arising from Flash Comm's pending petition for rule making that establishes rules providing for regular authorization of this type of service. After further review of the Flash Comm proposal and existing FCC rules, the Bureau staff identified three rules in addition to those cited by Flash Comm that must be waived to allow Flash Comm to construct and operate its system. First, we waive Sections 2.102(h)(1) and 2.102(h)(2), for commercial fixed and mobile communications, respectively, and also Section 90.266(b), to allow commercial operation of Flash Comm's system in the HF spectrum. Second, we waive Section 90.75(d) to allow the assignment of HF channels to Flash Comm in the Business Radio Service. Third, we waive Section 90.266(f) to allow Flash Comm's system to use emission type 2K80G1D in the HF spectrum. Fourth, we waive Section 90.266(g) to allow assignment of HF channels to Flash Comm, which is not eligible for licensing in the Power, Petroleum, Special Industrial or Telephone Maintenance Radio services. Fifth, we waive Section 90.425(a) to permit Flash Comm to identify transmissions solely by means of the preamble in its packet transmissions, and not be required to transmit an FCC assigned call sign by voice or Morse telegraphy. 26. Flash Comm's authority to operate facilities in the HF spectrum is subject to all of the specific technical and operating conditions listed in Appendix A hereto. These conditions are essentially the same as those contained in the NTIA letter, with certain minor modifications required by the Bureau. NTIA staff has indicated concurrence with the conditions, as so modified. Operation is limited to the HF channels specified by carrier frequency in Appendix C hereto. 27. The Commission will accept application(s) for type-acceptance under Part 2 of the Commission's rules from Flash Comm or other manufacturers designated by Flash Comm. Action on any such applications for type-acceptance for equipment to be used under this Part 90 waiver order will be based upon compliance with the technical equipment characteristics listed in Appendix B, attached hereto. V. ORDERING CLAUSES 28. In view of the foregoing, IT IS ORDERED That the Application and Request for Waiver of the Commission's Rules file by Flash Comm, Inc. ARE GRANTED, effective upon release of this Order. This action is taken under authority delegated in Sections 0.331 and 0.241 of the Commission's rules, 47 C.F.R.  0.331. FEDERAL COMMUNICATIONS COMMISSION Rosalind K. Allen Deputy Chief, Wireless Telecommunications Bureau Richard M. Smith Chief, Office of Engineering and Technology APPENDIX A Special Conditions The authority of Flash Comm, Inc. to operate its system in the high frequency ("HF") portion of the electromagnetic spectrum is subject to the following conditions: 1. Secondary service. The Flash Comm service is a secondary service and as such is subject to the provisions of Section 2.104(d)(4) of the Commission's rules (47 C.F.R.  2.104(d)(4)). 2. Type accepted equipment. Each HF transmitter used by the Flash Comm system must be of a type that is included in the Commission's current Radio Equipment List as a type accepted for use under the authority of this Order. Grant of type acceptance will be based on compliance with the equipment technical specifications listed in Appendix B of this Order. 3. Station identification. Each HF transmitted packet must be identified by a digital identifier embedded in the preamble of the packet. 4. Carrier frequencies. The Flash Comm system may make HF transmissions using only specified carrier frequencies. An initial list of the carrier frequencies Flash Comm may use appears as Appendix C to this Order. This list of carrier frequencies may be modified in consultation with the Federal Communications Commission and the National Telecommunications and Information Administration, provided that (a) a 15 kHz guard band is preserved between Flash Comm operations and aeronautical, radio astronomy, maritime, amateur, time standard and industrial, scientific and medical bands, and (b) the total spectrum specified for use by the Flash Comm system does not exceed 11.7% of the spectrum between 3 and 27 MHz (2.8 MHz). 5. Duration of transmissions. The duration of each HF transmission by each Flash Comm transmitter must not exceed 4 seconds. Flash Comm must maintain a daily record of the 7-day moving average of the durations of all completed Flash Comm HF transmissions and notify the Commission by letter if it appears that such average is regularly exceeding 2 seconds. 6. Occupancy. Accumulated transmissions by the Flash Comm system on each HF channel must not exceed one percent (36 seconds) in each hour in each geographical area in the contiguous United States bounded by each 5 degrees of latitude (beginning at 49ø North Latitude and proceeding Southward) and each 5 degrees of longitude (beginning at 70ø West Longitude and proceeding Westward). 7. Daily average power density limit; daily transmitted energy limit. The number of messages transmitted by the Flash Comm system must be limited such that (a) the daily accumulated average power density over the contiguous United States does not exceed -174 dBW/Hz-m2 and (b) the total HF radio frequency energy transmitted daily by the Flash Comm system does not exceed 2 million Watt-seconds. 8. Radiated power. The radiated power of the transmitter and its antenna system(s) as typically installed must not exceed one Watt. Radiated power is considered to be the antenna current squared multiplied by the theoretical radiation resistance of the antenna at the operating frequency, that is, it excludes ohmic and ground losses. 9. Control center functions. Flash Comm HF transmissions must be controlled by a master control center that is capable of (a) preventing Flash Comm transmissions on individual channels or frequency bands and (b) shutting down the entire Flash Comm system. The Flash Comm control center must assess HF channel occupancy using a minimum of four diverse receive sites during the first year of operation, and a minimum of six diverse receive sites thereafter. HF channel occupancy assessments indicating a clear (available) channel must be valid for no longer than 10 seconds. Flash Comm HF transmitters must not transmit on any channel unless and until that channel has been declared clear by the master control center. If the Flash Comm control center is directed by an authorized official of the Federal Communications Commission ("FCC") to cease transmissions on specific HF channel(s), Flash Comm will cease all transmissions on the specified HF channel(s) within one hour after being so directed. If an authorized official of the National Telecommunications and Information Administration (NTIA) advises the FCC that Flash Comm should cease all transmissions on specific HF channel(s), the FCC may immediately direct Flash Comm to do so. 10. HF transmitting antennas. HF transmit antennas used in the Flash Comm system must be of a type that has no more directivity than a half-wavelength dipole antenna or a quarter- wavelength monopole on a ground plane, based on free-space radiation patterns. 11. Publicly available log of transmissions. Flash Comm must log and make publicly available via the Internet the time, frequency, location and duration of all completed Flash Comm HF transmissions for the prior 24 hours. The URL of the Internet log must be provided to the Commission and to NTIA. APPENDIX B Equipment Type-acceptance Requirements Flash Comm HF transmitting equipment must be capable of compliance with the following technical specifications in order to receive a grant of type-acceptance: 1. Transmitter power output. The transmitter power output must not exceed 15 Watts. 2. Carrier frequency stability. The carrier frequency must be stable to ñ 10 ppm over an environmental temperature range of -20 to +70 degrees C. 3. Emission type. The operational modulated emission type must be 2K80G1D. Type N0N emission capability is permitted in a test mode; otherwise the energy must spread over a 2.8 kHz bandwidth. The authorized bandwidth is 3.0 kiloHertz. 4. Emission mask. The power of emissions outside of the authorized bandwidth must be attenuated below the power of the unmodulated carrier wave in accordance with the following schedule: On any frequency removed from the carrier frequency by 50% up to 150% of the authorized bandwidth, at least 25 dB; On any frequency removed from the carrier frequency by 150% up to 250% of the authorized bandwidth, at least 35 dB; On any frequency removed from the carrier frequency by 250% or more of the authorized bandwidth, at least 43 dB. APPENDIX C Flash Comm HF Channel Carrier Frequencies (MHz) 3.170 5.150 5.838 7.615 9.156 9.342 10.336 11.508 3.173 5.153 5.841 7.618 9.159 9.345 10.339 11.511 3.176 5.156 5.844 7.621 9.162 10.342 11.514 3.179 5.159 5.847 7.624 9.165 10.345 11.517 3.182 5.162 5.850 7.627 9.168 10.348 11.520 3.185 5.165 5.853 7.630 9.171 10.165 10.351 11.523 3.188 5.168 5.856 7.633 9.174 10.168 10.354 11.526 3.191 5.171 5.859 7.636 9.177 10.171 10.357 11.529 3.194 5.174 5.862 7.639 9.180 10.174 10.360 11.532 3.197 5.177 5.865 7.642 9.183 10.177 10.363 11.535 3.200 5.180 7.645 9.186 10.180 10.366 11.538 3.203 5.183 7.648 9.189 10.183 10.369 11.541 3.206 5.186 7.651 9.192 10.186 10.372 11.544 3.209 5.189 6.780 7.654 9.195 10.189 10.375 11.547 5.192 6.783 7.657 9.198 10.192 10.378 11.550 5.195 6.786 7.660 9.201 10.195 10.381 11.553 4.453 5.198 6.789 7.663 9.204 10.198 10.384 11.556 4.456 5.201 6.792 7.666 9.207 10.201 10.387 11.559 4.459 5.204 6.795 7.669 9.210 10.204 10.390 11.562 4.462 5.207 6.798 7.672 9.213 10.207 10.393 11.565 4.465 5.210 6.801 7.675 9.216 10.210 10.396 11.568 4.468 5.213 6.804 7.678 9.219 10.213 10.399 11.571 4.471 5.216 6.807 7.681 9.222 10.216 10.402 11.574 4.474 5.219 6.810 7.684 9.225 10.219 10.405 11.577 4.477 5.222 6.813 7.687 9.228 10.222 10.408 4.480 5.225 6.816 7.690 9.231 10.225 10.411 4.483 5.228 6.819 7.693 9.234 10.228 10.414 4.486 5.231 6.822 7.696 9.237 10.231 10.417 12.170 4.489 6.825 7.699 9.240 10.234 10.420 12.173 4.492 6.828 7.702 9.243 10.237 12.176 6.831 7.705 9.246 10.240 12.179 5.745 6.834 7.708 9.249 10.243 11.415 12.182 4.925 5.748 6.837 7.711 9.252 10.246 11.418 12.185 4.928 5.751 6.840 7.714 9.255 10.249 11.421 12.188 4.931 5.754 7.717 9.258 10.252 11.424 12.191 4.934 5.757 7.720 9.261 10.255 11.427 12.194 4.937 5.760 7.723 9.264 10.258 11.430 12.197 4.940 5.763 7.540 7.726 9.267 10.261 11.433 12.200 4.943 5.766 7.543 7.729 9.270 10.264 11.436 12.203 4.946 5.769 7.546 7.732 9.273 10.267 11.439 12.206 4.949 5.772 7.549 7.735 9.276 10.270 11.442 12.209 4.952 5.775 7.552 7.738 9.279 10.273 11.445 12.212 4.955 5.778 7.555 9.282 10.276 11.448 12.215 4.958 5.781 7.558 9.285 10.279 11.451 4.961 5.784 7.561 9.288 10.282 11.454 4.964 5.787 7.564 9.105 9.291 10.285 11.457 4.967 5.790 7.567 9.108 9.294 10.288 11.460 13.425 4.970 5.793 7.570 9.111 9.297 10.291 11.463 13.428 4.973 5.796 7.573 9.114 9.300 10.294 11.466 13.431 4.976 5.799 7.576 9.117 9.303 10.297 11.469 13.434 5.802 7.579 9.120 9.306 10.300 11.472 13.437 5.805 7.582 9.123 9.309 10.303 11.475 13.440 5.120 5.808 7.585 9.126 9.312 10.306 11.478 13.443 5.123 5.811 7.588 9.129 9.315 10.309 11.481 13.446 5.126 5.814 7.591 9.132 9.318 10.312 11.484 13.449 5.129 5.817 7.594 9.135 9.321 10.315 11.487 13.452 5.132 5.820 7.597 9.138 9.324 10.318 11.490 13.455 5.135 5.823 7.600 9.141 9.327 10.321 11.493 13.458 5.138 5.826 7.603 9.144 9.330 10.324 11.496 13.461 5.141 5.829 7.606 9.147 9.333 10.327 11.499 13.464 5.144 5.832 7.609 9.150 9.336 10.330 11.502 13.467 5.147 5.835 7.612 9.153 9.339 10.333 11.505 13.470 Flash Comm HF Channel Carrier Frequencies (MHz) continued 13.473 14.440 15.908 16.094 18.183 19.136 19.815 21.880 23.464 13.476 14.443 15.911 16.097 18.186 19.139 19.818 21.883 23.467 13.479 14.446 15.914 16.100 18.189 19.142 19.821 21.886 23.470 13.482 14.449 15.917 16.103 18.192 19.145 19.824 21.889 23.473 13.485 14.452 15.920 16.106 18.195 19.148 19.827 21.892 23.476 13.488 14.455 15.923 16.109 18.198 19.151 19.830 21.895 23.479 13.491 14.458 15.926 16.112 18.201 19.154 19.833 21.898 23.482 13.494 14.461 15.929 16.115 18.204 19.157 19.836 21.901 23.485 13.497 14.464 15.932 16.118 18.207 19.160 19.839 21.904 23.488 13.500 14.467 15.935 16.121 18.210 19.163 19.842 21.907 23.491 13.503 14.470 15.938 16.124 18.213 19.166 19.845 23.494 13.506 14.473 15.941 16.127 18.216 19.169 19.848 23.497 13.509 14.476 15.944 16.130 18.219 19.172 19.851 23.500 13.512 14.479 15.947 18.222 19.175 19.854 22.870 23.503 13.515 14.482 15.950 18.225 19.178 19.857 22.873 23.506 13.518 14.485 15.953 18.228 19.181 19.860 22.876 23.509 13.521 14.488 15.956 17.425 18.231 19.184 19.863 22.879 23.512 13.524 14.491 15.959 17.428 18.234 19.187 22.882 23.515 13.527 14.494 15.962 17.431 18.237 19.190 22.885 13.530 14.497 15.965 17.434 18.240 19.193 22.888 13.533 14.500 15.968 17.437 18.243 19.196 20.025 22.891 13.536 14.503 15.971 17.440 18.246 19.199 20.028 22.894 25.025 13.539 14.506 15.974 17.443 18.249 19.202 20.031 22.897 25.028 13.542 14.509 15.977 17.446 18.252 19.205 20.034 22.900 25.031 13.545 14.512 15.980 17.449 18.255 19.208 20.037 22.903 25.034 13.548 14.515 15.983 17.452 18.258 19.211 20.040 22.906 25.037 13.551 14.518 15.986 17.455 18.261 19.214 20.043 13.554 14.521 15.989 17.458 18.264 19.217 20.046 13.557 14.524 15.992 17.461 18.267 19.220 20.049 13.560 15.995 17.464 18.270 19.223 20.052 23.365 13.563 15.998 17.467 18.273 19.226 20.055 23.368 13.566 15.815 16.001 17.470 18.276 19.229 20.058 23.371 13.569 15.818 16.004 17.473 18.279 19.232 20.061 23.374 13.572 15.821 16.007 17.476 18.282 19.235 20.064 23.377 15.824 16.010 17.479 18.285 19.238 20.067 23.380 15.827 16.013 17.482 18.288 19.241 20.070 23.383 15.830 16.016 17.485 18.291 19.244 20.073 23.386 14.365 15.833 16.019 17.488 18.294 19.247 20.076 23.389 14.368 15.836 16.022 17.491 18.297 19.250 20.079 23.392 14.371 15.839 16.025 17.494 18.300 19.253 20.082 23.395 14.374 15.842 16.028 17.497 18.303 19.256 20.085 23.398 14.377 15.845 16.031 17.500 18.306 19.259 20.088 23.401 14.380 15.848 16.034 17.503 18.309 19.262 20.091 23.404 14.383 15.851 16.037 17.506 18.312 19.265 20.094 23.407 14.386 15.854 16.040 17.509 18.315 19.268 20.097 23.410 14.389 15.857 16.043 17.512 18.318 19.271 20.100 23.413 14.392 15.860 16.046 17.515 18.321 19.274 20.103 23.416 14.395 15.863 16.049 17.518 18.324 19.277 20.106 23.419 14.398 15.866 16.052 17.521 18.327 19.280 20.109 23.422 14.401 15.869 16.055 17.524 18.330 19.283 20.112 23.425 14.404 15.872 16.058 17.527 18.333 19.286 20.115 23.428 14.407 15.875 16.061 17.530 18.336 19.289 20.118 23.431 14.410 15.878 16.064 17.533 19.292 20.121 23.434 14.413 15.881 16.067 19.295 20.124 23.437 14.416 15.884 16.070 19.298 23.440 14.419 15.887 16.073 19.115 19.301 23.443 14.422 15.890 16.076 18.045 19.118 19.304 23.446 14.425 15.893 16.079 18.048 19.121 19.307 21.865 23.449 14.428 15.896 16.082 18.051 19.124 19.310 21.868 23.452 14.431 15.899 16.085 19.127 21.871 23.455 14.434 15.902 16.088 19.130 21.874 23.458 14.437 15.905 16.091 19.133 21.877 23.461