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NEWINGTON, CT, Oct 20, 2006 -- While the FCC's recent Report and Order (R&O) in WT Docket 04-140 seems to offer something for just about every sector of the Amateur Radio community, it's not without its shortcomings. Most of these appear to be unintended consequences stemming from the FCC's arguably too-generous allocation of 75 meter phone spectrum to Amateur Extra class licensees. Based on the record, the FCC said it was persuaded to authorize more 75 meter spectrum than indicated in its 2004 Notice of Proposed Rule Making (NPRM).
"Indeed, a number of commenters argue that the NPRM proposal to increase the amount of spectrum permitted for voice communications would still not meet the demand for voice communication in the HF bands, particularly in the 80 meter band," the FCC said in the R&O, released October 10. Several radio amateurs filing comments made a case to extend the 80 meter allocation further downward, the FCC continued, "believing that expanding the band more than the Commission proposed is justified because the CW band 'is grossly underused and represents a huge waste in spectrum.'"
The FCC concluded that the commenters' arguments -- several suggested a phone band extending down to 3600 kHz -- were "reasonable." Far more modest phone expansions were the rule for 40 and 15 meters, the other affected bands (see revised band charts for details).
Once the new rules go into effect, the 75 meter phone band will span 3800 to 4000 kHz for Generals, 3700 to 4000 kHz for Advanced class licensees (ARRL had requested 3750 to 4000 kHz), and 3600 to 4000 kHz for Amateur Extras (ARRL had requested 3725 to 4000 kHz).
Reallocation Credits and Debits
The ample 75 meter Amateur Extra class phone allocation not only effectively reduces the amount of 80-meter spectrum available for CW, RTTY and data, it actually eliminates Advanced and General class access on any mode to certain segments where they now have privileges. Sensitive to fallout from the "incentive licensing" debacle of the late 1960s, the FCC has indicated it wouldn't let that kind of thing happen again.
In the runup to the April 2000 license restructuring, the FCC assured the Amateur Radio community that any pending changes would not take away any incumbent licensee's privileges, and it carefully avoided doing so in its restructuring R&O. Even while applauding the ARRL's "refarming" proposal in this docket's NPRM, the FCC pointed out that "as proposed, no licensees would lose any spectrum privileges." Nonetheless that's just what happened:
Generals lose access to 150 kHz of CW/data spectrum on 80 meters while gaining 50 kHz of phone spectrum on 75. They also lose access to 25 kHz of CW/data spectrum on 40 meters but gain 50 kHz of phone privileges on that band. Factoring in another 25 kHz of phone spectrum on 15 meters that's an overall gain in privileges of 125 kHz of phone spectrum offset by an overall loss of 175 kHz of CW/data spectrum -- or a net loss of 50 kHz in spectrum privileges.
Advanced licensees also lose access to 150 kHz of CW/data spectrum on 80 meters but gain 75 kHz of phone spectrum on 75. They also lose access to 25 kHz of CW/data spectrum on 40 meters but gain 25 kHz of phone spectrum there. That's an overall loss of 175 kHz of CW/data spectrum offset by an overall gain of 100 kHz of phone spectrum (25 kHz less than Generals). The net loss in Advanced privileges works out to 75 kHz (25 kHz greater than Generals).
On the other hand, the new rules are "nothing but net" for Novice and Tech Plus (Technician with Element 1 credit) licensees. Given permission to operate CW in the current General exclusive-CW allocations on 80, 40 and 15 meters and CW/data on 10 meters, where the FCC provided an another 100 kHz, these licensees take home a whopping 250 kHz of additional HF spectrum.
Did the FCC Mean to Do That?
The R&O contains several apparent mistakes, too. For example, in §97.301(d) the 80 meter row should read 3.525-3.600 MHz for all three ITU regions. In §97.305(c), the frequencies in the first line for 40 meters should read 7.000-7.100 MHz. The FCC plans to fix these errors in the "official" R&O text that will appear in the Federal Register later this fall.
Other corrections may prove more troublesome. Creating a humongous 75 meter phone band for Extras effectively, but apparently inadvertently, deleted the only 80 meter segment where automatically controlled digital stations may operate -- 3620 to 3635 kHz. The new rules no longer permit RTTY and data there, however.
In addition, the FCC accommodated the inclusion of images in data transmissions by defining a range of image emission types as "data" and limiting them to 500 Hz bandwidth in the RTTY/data subbands. Unfortunately, it did so in a way that also limits J2D emissions -- data sent by modulating an SSB transmitter -- to 500 Hz bandwidth.
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