[AMRadio] Comments to FCC needed ASAP, regarding Fish Net Beacons in 1900-2000 kHz

Donald Chester k4kyv at charter.net
Fri Sep 11 14:34:59 EDT 2015

Here's an item from the FCC that needs our attention, since 160m is one of
the bands most widely used by the AM community.

While most attention so far has focussed on the proposed new MF and LF
allocations, there is also the issue of fish net beacons on 160m. The
initial comment deadline is past due, but REPLY COMMENTS ARE STILL OPEN
THROUGH THE 30th of SEPTEMBER.  We can reply to the ARRL comments; they
pretty much have the issue identified and defined spot on, except for a
suggestion that fish net beacons on 1900-2000 kHz be moved to the "lightly
used" portion of the Radiolocation frequencies between the broadcast band
and 160m ham band, specifically 1750-1800 kHz. From what I hear on my
receiver at this location, THE ENTIRE SEGMENT OF FREQUENCIES between 1705
kHz and 1800 kHz is lightly used.  I rarely ever hear a signal of any kind
in that segment, which was once packed full of now-discontinued
radiolocation beacons.  I would strongly urge everyone to submit a reply
comment explaining why you support the ARRL position,  with a further
suggestion that the entire band of Radiolocation frequencies between 1705
and 1800 kHz be considered to re-accommodate beacons presently on 1900-2000.

I am not familiar with the beacon transmitters except for a few online ads
for the products, but I suspect it would be very easy to move the transmit
frequency, requiring only re-setting a synthesised master oscillator and
tweaking the antenna tuning network. A technician could probably complete
the task in less than 10 minutes. 

The beacons would suffer far less interference operating in the now-vacant
Radiolocation spectrum, than in the heavily used amateur band. Even though
they operate at low transmitting power, amateurs, particularly those living
in coastal areas, frequently complain of interference. Likewise, signals
from high power amateur transmitters are undoubtedly capable of causing
harmful interference to the beacons.

When the FCC released the Report & Order upgrading amateur status to
primary, it wasn't immediately clear that this included a new docket
proposal (15-99) with a subsequent comment deadline.  It is unusual for the
FCC to combine a R&O for one proceeding with a new Notice of Proposed
Rulemaking all in the same release, so this did not come to the attention of
most amateurs until a recent news item appeared on the ARRL website.

Some useful links:

Here, you see a list of links to recent comments, plus a link to the text of
the original FCC Release in the right-hand pane. If you wish to submit a
(reply) comment, click on "Submit a Filing in 15-99", which is located at
the top of the page just above the main heading.


Here is the entire FCC Docket, which is very lengthy.  The pertinent section
addressing the 1900-2000 kHz issue begins with paragraph 30.


Here are the ARRL's submitted comments. The 160m issue is addressed in
Section II, beginning on page 4 and running through page 11. 


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