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ARRL General Bulletin ARLB013 (2016)

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ARLB013 ARRL Tells FCC to Restore Balance of Modes on 80 and 75
Meters

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ARRL Bulletin 13  ARLB013
From ARRL Headquarters  
Newington CT  March 28, 2016
To all radio amateurs 

SB QST ARL ARLB013
ARLB013 ARRL Tells FCC to Restore Balance of Modes on 80 and 75
Meters

In comments filed on March 23 on its Petition for Rule Making (RM
11759) seeking changes to 80 and 75 meters, the ARRL has told the
FCC that its primary objective is to "rebalance" the bands by
correcting a 10-year old FCC error.

"ARRL's proposal is not fairly viewed as a proposal to take anything
away from anyone," the League's comments assured. "It is more
properly viewed as the effectuation of a fair, equitable, and
efficient 'band plan' looking forward for the foreseeable future
that balances everyone's needs, and which remedies a plainly unfair
plan, imprudently created in the 2006 Report and Order in WT Docket
04-140."  The Report and Order can be found on the web at,
http://apps.fcc.gov/ecfs/comment/view?id=5513680269 .

Prompting the League's assurances were comments filed on the ARRL's
Petition by a number of Amateur Extra class licensees, who felt that
refarming 3600 to 3650 kHz for data modes could prove to be a
disincentive to General licensees to upgrade. Others commenters saw
it as an unfair spectrum grab. The ARRL noted that prior to 2006,
the band was evenly divided between RTTY/data and phone/image
subbands, with the RTTY/data subband extending from 3500 to 3750
kHz, and the phone/image subband extending from 3750 to 4000 kHz.

The 2006 FCC Report and Order "substantially altered" what the
League called "this even division of emission types." In outlining
the history of the proceeding, the ARRL pointed out that the FCC's
Notice of Proposed Rulemaking in Docket 01-140 would have shifted
the line between the 80 meter RTTY/data subband and the 75 meter
phone/image subband from 3750 kHz to 3725 kHz, pursuant to a 2002
ARRL Petition for Rule Making, RM-10413. This would change the ratio
of spectrum between phone/image and RTTY/data segments on 75/80
meters from 50/50 to 55/45, and it is what the FCC proposed in its
NPRM.

In its Report and Order in Docket 04-140, however, the FCC made "a
very substantial and unjustifiable departure" from what it had
proposed in its NPRM, the ARRL recounted. The Commission expanded
the phone/image subband at 75 meters to 3600-4000 kHz, and it
reduced the 80 meter RTTY/data subband to 3500-3600 kHz, eliminating
RTTY operation above 3600 kHz and changing "the entire dynamic of
this band," the League said.

The FCC had said in its proposal that no licensees would lose
operating privileges. Nonetheless, the FCC's phone band expansion
reduced by 100 kHz the spectrum between 3500 and 4000 kHz that was
previously available to General class licensees, while Advanced
licensees lost 75 kHz. In an apparent FCC oversight, the Report and
Order completely eliminated access by automatically controlled
digital stations (ACDS) to 3620 to 3635 kHz. A subsequent FCC Report
and order and Order on Reconsideration only made the situation worse
by replacing the deleted ACDS segment with 3585-3600 kHz.

"It resulted in a sudden and severe dislocation of traffic-handling
nets using telegraphy, without advance planning or notice," the ARRL
said. "It disaccommodated net participants with General and Advanced
class licenses; and it worsened the effect of the overexpansion of
the 75 meter phone/image subband."

The result, the ARRL noted, has been "a shortfall in available
RTTY/data spectrum on 80 meters" that has created a significant
obstacle to narrowband digital data communications and
experimentation. The League said its current Petition "simply
restores that which was disrupted in 2006 in error."

In its comments, the League conceded that compromises are inevitable
in managing a heavily used band like 75/80 meters, no matter the
band planning approach. "Looking forward, it is necessary, in order
to encourage experimentation with and expand the use of digital
communication techniques, to rebalance the 75 and 80 meter
subbands," the ARRL concluded.
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