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NEWINGTON, CT, Apr 17, 2002--Comments are due by May 16 on two Amateur Radio-related petitions put on public notice this week by the FCC. An ARRL Petition for Rule Making would eliminate the 80, 40 and 15-meter Novice/Technician Plus CW subbands and reuse the spectrum in part to expand the 80 and 40-meter phone allocations. The FCC designated the League's petition as RM-10413. Another Petition for Rule Making filed by Nick Leggett, N3NL, would require most commercially manufactured Amateur Radio transmitters and transceivers to be field-repairable "in some manner." The Commission designated Leggett's petition as RM-10412.
Amateurs may view and comment on these proposals via the FCC's Electronic Comment Filing System (ECFS) on the FCC Web site. (Click on "Search for Filed Comments." In the "Proceeding" field enter the rulemaking number, with "RM" in upper-case and the hyphen included.)
The ARRL's petition, filed in March, asks the FCC to revise its Amateur Service rules in accordance with a modified Novice band "refarming" scheme the ARRL Board of Directors adopted in January. The ARRL says that eliminating the Novice and Technician-Plus CW bands and reapportioning these "inefficiently deployed segments" would help to alleviate overcrowding elsewhere.
If the FCC goes along with the League's proposal, current Novice and Technician Plus (ie, Technician with Element 1 credit) licensees would be permitted to operate on the 80, 40, 15 and 10-meter General-class CW allocations at up to 200-W output. For General and higher class operators, the ARRL wants the FCC to implement changes in the 80, 40 and 15-meter "phone" bands.
On 80 meters (3500-4000 kHz), phone privileges would begin at 3725 kHz for Extra, at 3750 kHz for Advanced and 3800 for General.
On 40 meters (7000-7300 kHz), phone privileges would begin at 7125 kHz for Advanced and Extra and at 7175 kHz for General.
On 15 meters (21,000-21,450 kHz), phone privileges would begin at 21,200 kHz for Extra, at 21,225 kHz for Advanced and at 21,275 kHz for General.
On 10 meters, the ARRL has recommended no changes other than to accommodate CW, RTTY and data by Novice and Tech Plus licensees over the 28,000-28,300 kHz segment.
The ARRL said its petition attempts to carefully balance a desire for more phone spectrum in the affected bands against "the important goal" of encouraging further development of narrowband data modes in the CW segments.
The League's petition also asks the FCC to permit amateurs to use spread spectrum on the 222-225 MHz band; expand the pool of special event call signs beyond the 1x1 format to include identifiers for US territories and possessions that do not provide for mailing addresses; clarify its rules to indicate that modulated CW (MCW) is permitted for repeater station identification; and to incorporate into its rules a 1990 FCC waiver authorizing amateurs in certain areas of Colorado and Wyoming to operate on certain segments of the 33-cm band.
A copy of the ARRL Petition for Rulemaking is available on the ARRL Web site.
Leggett Petition Would Require Field-Repairable Commercial Ham Gear
The Leggett petition was filed in February. "Field repair is important to the Amateur Radio Service because it enhances emergency communications preparedness and the growth of technical knowledge in the Amateur Radio Service," Leggett said in his petition.
Leggett suggests that the FCC consider mandating easily replaceable modules or circuit boards, minimum component spacings on circuit boards, removable integrated circuits mounted in sockets and other requirements for commercially made amateur transmitters and transceivers. He would exempt ham radio receivers.
"These design enhancements cannot be left to the amateur radio market because the market will not make them," he asserted. "Much amateur radio equipment is basically a spin-off of commercial communications equipment design. Commercial practice is the production of equipment that is not field-repairable."
Leggett argues that the lack of field-repairable gear is inconsistent with four of the five of the regulatory bases and purposes of the Amateur Radio Service--the provision of emergency communications, the advancement of the radio art, the advancement of technical skills and the expansion of the reservoir of trained operators, technicians, and electronics experts within the amateur ranks.
Leggett asked the FCC to address these concerns either in a Notice of Proposed Rulemaking or a Notice of Inquiry, but he didn't propose any specific rule changes or additions. The FCC, on its own action, chose to treat Leggett's filing as a Petition for Rulemaking and accept comments.
Leggett concedes that some manufacturers may drop out of the amateur market if the FCC were to adopt his recommendations, but he suggests that they would be replaced by other manufacturers, such as those making QRP equipment, who could "diversify their product lines to meet the opportunities presented by departing firms." Less emphasis on commercially built ham gear might even be a good thing, Leggett suggested. "The Amateur Services in other nations where equipment is less available have special strengths due to the fact that amateur operators must improvise and build much of their own equipment," he said, citing India and Russia as examples.
Last December, Leggett and attorney Don Schellhardt petitioned the FCC to require that all electronic equipment subject to FCC jurisdiction be shielded against electromagnetic pulse (EMP) damage. Designated as RM-10330, that proposal, as drafted, would apply to both new and existing equipment and would include Amateur Radio equipment. The ARRL did not comment on the Schellhardt-Leggett proposal.