[AMRadio] ARRL Prepares Rule Making Petition to FCC, Requesting Reduction of 75m Phone Band

Donald Chester k4kyv at charter.net
Fri Jul 24 22:25:22 EDT 2015

The ARRL freaked out when the FCC expanded the phone band down to 3600 kHz.
Now the Board has given a go-ahead for a rulemaking petition to trim the
phone allocation back to 3650-4000.

>From ARRL Website:

>>>Rule Making Petition to FCC

The Board also authorized the preparation of a rule making petition to the
FCC, seeking changes in the 80 and 75 meter bands that are consistent with
majority opinion among more than 1000 responses to an online membership
survey. The petition would seek to shift the boundary between the 80 meter
RTTY/data subband and the 75 meter phone/image subband from 3600 to 3650
kHz. It also would restore privileges in the 3600-3650 kHz segment to
Advanced, General, Technician, and Novice licensees.

In addition, the League will ask the FCC to shift the automatically
controlled digital station (ACDS) band segment from 3585-3600 kHz to
3600-3615 kHz, consistent with the IARU Region 1 and Region 2 band plans,
and authorize Technician and Novice licensees to use RTTY/data emissions in
their 15 and 80 meter band segments, the latter contingent on expansion of
the 80 meter band.>>>

I would urge all phone operators to keep a close eye on this one.  We need
to discuss the issue over the air, on internet forums, at club meetings,
etc., and most importantly, file our opinions in comments to the FCC once
the petition is submitted and assigned an RM- number.

"It also would restore privileges in the 3600-3650 kHz segment to Advanced,
General, Technician, and Novice licensees."

I believe we could live with that. In my opinion, one of the mistakes the
FCC made in the original  expansion was to restrict such a large swathe of
frequencies to Extra Class. But let's hope the FCC will reject the proposal
to move the sub-band boundary.  One thing going in our favour in this whole
matter is that the FCC seldom reverses recently-made rulemaking decisions,
something that would leave the impression that their initial ruling was in
error and thus their wisdom not infinite.

Eliminating the Extra Class-only restriction in this segment would allay the
oft-heard complaint that the phone band expansion "took frequencies away"
from the CW operators. No CW privileges were lost.  CW is allowed on all
amateur frequencies in the entire radio spectrum (except for some of the
"channels" in the 60m band). The provision that keeps many CW operators from
using the 3600-3650 segment is that it is accessible only to Extra Class
licensees. Moreover, RTTY/data privileges could be extended to this segment
WITHOUT prohibiting phone operation.  Mixed mode phone, CW, RTTY and data
have operated in the 160m band for decades with little difficulty or
conflict; there is no reason this couldn't work just as successfully in the
75/80m band.

One of the chronic complaints heard is that 3600-3700 is sparsely used by
phone operators. To a certain extent, this is true.  When the expanded band
was first opened up, phone operators, both AM and SSB, rushed to fill the
vacuum.  Numerous AMers upgraded to Extra just so they could operate "down
below". For a while, the segment was hopping with phone activity.  But once
the novelty wore off, phone operators slowly began to migrate back to their
old operating frequencies.  Now there are plenty of open spaces in this
segment, and AM signals are seldom heard.

However, the same could be said about CW activity.  One of the reasons the
FCC gave for expanding the phone band in the first place was that 3600-3700
had become sparsely occupied by CW and RTTY operators. In the years just
preceding the expansion, it had  reached the point that the 3600-3700 kHz
segment might be entirely vacant while portions of the phone band were
congested almost beyond the point of usability.  If phone operators have
largely abandoned this segment, the only reason CW operators might not be
able to use it is the Extra Class licensing requirement.

Another point that could be made in comments to the FCC is that moving the
sub-band boundary up to 3650 would result in a LOSS OF PRIVILEGES for some
operators. Even if other proposals in the League's petition were enacted, to
restore Advanced, General, Technician and Novice privileges, and to extend
RTTY/data privileges, no-one would actually lose privileges they presently
enjoy.  If the phone operators wanted to keep their stronghold on this
segment, they would have to be more active in operating there.  Use it or
lose it.

The AM community needs to be thinking this over as we wait to see the ARRL's
planned petition.

Don k4kyv

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