[AMRadio] ARRL asks for modification of 80 meter plan

Mike Duke, K5XU k5xu at jam.rr.com
Mon Dec 11 20:24:47 EST 2006


This was posted on the ARRL site today, see


League Asks FCC to Postpone, Modify Part of 75-Meter
Band Change

NEWINGTON, CT, Dec 11, 2006 -- In separate petitions
today, the ARRL asked the FCC to postpone the change
in allocation for 3600 to 3635 kHz while it considers
a request to maintain the status quo in the segment.
The so-called "omnibus" Report and Order (R&O) in WT
Docket 04-140, which included moving the lower edge of
the Amateur Extra 75-meter phone band to 3600 kHz, is
set to go into effect Friday, December 15. The League
wants the Commission to rectify the "unintended
consequence" of the expansion by moving the dividing
line between the narrowband and wideband segments of
80/75 meters to 3635 kHz. This would keep 3600 to 3635
kHz available to General and higher licensees for
RTTY, data and CW and open to Novice and Tech Plus
licensees for CW. The requested change also would
maintain access to the automatically controlled
digital subband, 3620 to 3635 kHz. In a Petition for
Reconsideration, the League emphasized that it was not
seeking reconsideration of the entire 75-meter phone
band expansion.

"Rather, we ask only that the Commission restore the
privileges unintentionally withdrawn from those who
operate and who utilize automatically controlled
narrowband digital stations between 3620 and 3635
kHz," the League said. The ARRL pointed out that while
the R&O left unchanged rules permitting automatically
controlled narrowband digital in that segment, it
eliminated RTTY and data as permitted emissions above
3600 kHz. The ARRL also filed a Petition for Partial
Stay of Effective Date of Rule pending final action on
its reconsideration petition.

To justify its far greater-than-requested expansion,
the League asserted, the FCC relied on the flawed
logic of a handful of commenters who specifically
asked for a 3600 to 4000 kHz phone band. Some
commenters had made the case during the proceeding
that the "CW subband" is vastly underutilized while
space for SSB is at a premium.

"It affects considerably more than just those two
operating modes," the ARRL said of the expansion.
"Narrowband RTTY and data modes are increasingly used
at 80 meters as well, and substantial numbers of RTTY
and data users stand to be displaced, as well as
precluded entirely, by the extent of the telephony
subband expansion there."

The League contends the FCC contradicted itself by
saying the rule revisions wouldn't result in any
licensee losing spectrum privileges. "But operating
privileges have been lost by the extent of the
expansion at 80 meters," the reconsideration petition
states. The expansion also significantly burdens and
adversely impacts CW nets above 3600 kHz -- including
emergency and public service nets -- most, if not all,
of which will have to cease operating or change
frequency, the League added.

Most important, however, is the loss of spectrum for
automatically controlled digital modes. The ARRL
petition cites the comments of several League members
decrying the loss of spectrum for PACTOR, CW and RTTY.
"The Winlink 2000 system was cited as a best practice
by several post-Hurricane Katrina reviews, including
the Congressional 'Failure of Initiative' report,"
remarked ARRL South Texas Section Emergency
Coordinator Jerry Reimer, KK5CA.

The ARRL says shifting the band edge slightly upward
would provide a "simple and equitable fix" to the
obvious error in the R&O.

"This is neither a minor matter nor an academic
exercise in future band planning," the ARRL concluded.
"It is an urgent problem which, unless corrected,
affects a substantial number of existing Amateur Radio
fixed facilities and an even more substantial number
of mobile facilities."

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