[AMRadio] ARRL Petitions FCC to Reduce 75/80m Phone Allocation from 3600-4000 to 3650-4000

Donald Chester k4kyv at charter.net
Wed Jan 13 14:27:51 EST 2016

Regardless of your opinion of this proposal, I would urge everyone to submit
comments to the FCC as soon as (or if) the FCC assigns it a RM- number. Most
importantly, please read the entire text of the League's petition before
formulating comments.

While the ARRL's Petition points out that the proposed change has received
"strong support from the ARRL membership", it must be remembered that the
ARRL membership comprises a minority of licensed amateurs, so this petition
does not necessarily represent the wishes of the greater amateur community.

Apparently the main impetus behind this petition is to benefit users of
Automatically Controlled Digital Station modes; "the most substantial
adverse effect of the unexpected and vast expansion of the 75 meter
phone/image (to 3600 kHz) was the elimination of access to 3620-3635 kHz by
ACDS" says the League.

For those unfamiliar with ACDS, see Part 97 : Sec. 97.221 of the rules:

Automatically controlled digital station
(a) This rule section does not apply to an auxiliary station, a beacon
station, a repeater station, an earth station, a space station, or a space
telecommand station.

(b) A station may be automatically controlled while transmitting a RTTY or
data emission on the 6 m or shorter wavelength bands, and on the
28.120-28.189 MHz, 24.925-24.930 MHz, 21.090-21.100 MHz, 18.105-18.110 MHz,
14.0950-14.0995 MHz, 14.1005-14.112 MHz, 10.140-10.150 MHz, 7.100-7.105 MHz,
or 3.585-3.600 MHz segments.

(c) A station may be automatically controlled while transmitting a RTTY or
data emission on any other frequency authorized for such emission types
provided that:

(1) The station is responding to interrogation by a station under local or
remote control; and

(2) No transmission from the automatically controlled station occupies a
bandwidth of more than 500 Hz.

[60 FR 26001, May 16, 1995, as amended at 72 FR 3082, Jan. 24, 2007]

The League likely started out on the wrong foot with this petition from the
outset, referring to the FCC's original expansion of the phone band down to
3600 as a "Reapportioning Error" and "a very substantial and unjustifiable
departure" from what had been originally proposed. Regulatory agencies like
the FCC rarely admit they were in error in a recent rulemaking decision,
which would amount to officially acknowledging that their wisdom might be
less than infinite. 

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