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

Rob Atkinson ranchorobbo at gmail.com
Thu Jan 14 22:10:01 EST 2016

I am interested in finding out what the "error" is that the ARRL
claims the FCC committed.  It seems to me the FCC knew what they were

The flaw here if you will, is the lumping of "phone" with "image,"
hereafter referred to as digital, because that's simply what it is.

The 3600 to 3700 range is a nice place for radiotelephone operation,
i.e. AM, because of its relative lack of congestion.  I have been
operating a bit on 3700 but regular use of frequencies below 3700
would be better.  This space should be preserved as it has been for
the past 9 or 10 years.

A significant flaw has to do with the so-called "phone/image" mode
label, as if the "image" (read digital) is compatible with analog
modes.  It is not.  There is already a problem with nuisance scofflaw
activities of some operators, who use that mode to intentionally cause
QRM to phone operators minding their own business.  These lids, often
recently licensed, use the flawed legal ID rule to hide their
identities, knowing most phone operators are not equipped to decode
their white noise transmissions.  But even if all of the digital
operations employing SSB transceivers, were orderly, this digital mode
would still need to be treated like any other digital mode and be
separated from analog modes because the noise from these emissions in
the passbands of regular analog superhet receivers makes operation on
nearby frequencies challenging when a weak signal is being heard.

It is established by a significant consensus among broadcast engineers
and technicians in the U.S. that combining digital and analog
transmission in the medium wave AM band has been a disaster.  For the
same reason, the two modes are not compatible and the digital causes
harmful interference with analog signals on adjacent channels, spaced
10 kc in the U.S.  For example, I am unable to listen to WSM on 650
because of digital noise coming from a station on 670 kc.

It would be helpful if FCC would reinstate the CW or analog voice ID
requirement for digital modes, which would allow hams with typical
common analog equipment to identify stations causing deliberately
harmful interference.

If _all_ digital were segregated below 3650, I could be persuaded to
go along with the proposal, but the solution ARRL is seeking isn't
addressing the real problem.  ARRL needs to back up and firstly
classify all digital protocols regardless of whatever label they want
to paste on them, as digital, and then put forth a plan that
recognizes the reality that analog and digital are not compatible.

The ARRL is only one "vote" in the FCC ECFS.  They may claim to
represent thousands of hams but I believe legally they only count for
one opinion and voice.

We all will have an opportunity to comment, assuming FCC does not
dismiss the petition.



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