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ARRL Comments on FCC 5 MHz Proposals

08/09/2010

On July 13, the ARRL filed its comments in response to the FCC’s Notice of Proposed Rulemaking (NPRM) in ET Docket No. 10-98. The NPRM was issued in response to an ARRL Petition for Rule Making -- RM-11353 -- filed in October 2006. In its 2006 Petition, the ARRL had sought modest improvements in operating privileges in the so-called “60 meter” band, which presently consists of five channels on which General, Advanced and Amateur Extra class licensees may use upper sideband (USB) emission and no more than 50 W effective radiated power (ERP) relative to a dipole antenna. Amateur use of these five channels is on a secondary basis and must not cause harmful interference to authorized stations in the mobile and fixed services. US amateurs were first authorized to operate on 60 meters in 2003, thanks to agreement by the Interdepartment Radio Advisory Committee (IRAC) of the National Telecommunications and Information Administration (NTIA), that with such limits, amateur use would be compatible with federal government requirements.

The ARRL’s 2006 Petition had requested the substitution of a different channel for one that is generally occupied and not available for amateur use, an increase in authorized ERP from 50 to 100 W, as well as authorization for amateurs to use Morse code and certain data modes in addition to USB. It also suggested that Voice-Operated Transmit (VOX) operation be required in order to ensure that a federal agency can interrupt an amateur contact quickly should the need arise. The ARRL sought and received IRAC’s endorsement of the proposed changes.

In its NPRM, the FCC proposed substituting 5358.5 kHz for 5368.0 kHz, as well as the requested power increase. The FCC also proposed allowing Morse telegraphy (emission designator 150HA1A), PSK31 (emission designator 60H0J2B) and PACTOR-III (emission designator 2K80J2D), but with the use of Morse and PSK31 limited to the center frequency of each channel. In its comments in response, the ARRL supported the substitute frequency and power increase; however, the ARRL requested that Morse and PSK31 be permitted within the channel limits, rather than confined to the center frequency of each channel, in order to permit multiple communications to occur simultaneously within the same channel. The ARRL also requested that the rules specify the emission designators 60H0J2B and 2K80J2D, but not the specific data modes of PSK31 and PACTOR-III, in order to provide for future flexibility.

In response to the FCC’s observation that stipulating VOX operation might actually increase the potential for interference in a high noise environment such as an emergency operations center, the ARRL concurred. With regard to the FCC’s proposal that “Amateur operators using data emissions must exercise care to limit the length of transmissions so as to avoid causing harmful interference to Federal stations,” the ARRL observed that “The Commission has reached the proper balance of regulatory flexibility and channel preclusion avoidance.” Finally, other than to say that it should not be a requirement, the ARRL took no position in response to the FCC’s solicitation -- on behalf of the NTIA -- of comments as to whether amateurs should be encouraged to add a sound card generated Automatic Link Establishment (ALE) capability to their stations.

“Amateurs have proven, through interference-free operation on these channels, that compatible sharing of the channels is possible,” the ARRL noted in its comments. “The proposed minor changes retain sufficient safeguards to protect the primary and important Federal Government operations that make use of these channels from time to time. ARRL firmly commits to the preparation and widespread dissemination of a ‘best practice’ document for amateur use of these channels going forward with the replacement channel, modified power limit and more flexible emission types permitted.”

The ARRL also pledged to develop a workable band plan for occupancy of these channels “to ensure against usurpation by any one emission type and to continue the excellent track record of interference avoidance to Federal operations.”

Saying that it hopes that consideration can be given to a domestic secondary allocation of a contiguous band of at least 50 kHz in the vicinity of the existing channels, the ARRL pointed out that a “continuous band rather than discrete channels is more normal for the Amateur Service, as it affords the opportunity for dynamic frequency selection according to band occupancy.” But in the meantime, the ARRL said that increased flexibility in the use of the five channels allocated to the Amateur Service on a secondary basis “will greatly facilitate emergency communications preparedness and will permit a substantial degree of additional flexibility in the use of the channels without any increase in interference potential.”



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