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ARRL General Bulletin ARLB028 (2015)

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ARLB028 ARRL Supports Maximum Flexibility for Amateur Use of New
2200 and 630 Meter Bands

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ARRL Bulletin 28  ARLB028
From ARRL Headquarters  
Newington CT  September 1, 2015
To all radio amateurs 

SB QST ARL ARLB028
ARLB028 ARRL Supports Maximum Flexibility for Amateur Use of New
2200 and 630 Meter Bands

The ARRL has told the FCC that Amateur Radio operation in the new
135.7-137.8 kHz (2200 meters) and 472-479 kHz (630 meters) bands
should be as unfettered as possible from a regulatory standpoint.
The League spelled out its case August 31 in detailed comments that
argue in favor of flexible FCC Part 97 regulations in light of the
exceptionally low interference potential to unlicensed power line
carrier (PLC) systems that utilities use to manage the power grid.
In its April Report and Order, Order, and Notice of Proposed
Rulemaking (R&O/NPRM) in ET Docket 15-99, the FCC had raised several
questions regarding how Amateur Radio and PLC systems might coexist.
The ARRL said, in its view, there is little to no evidence that
Amateur Radio operation would be incompatible on the LF spectrum,
where the great majority of PLC systems are deployed, and that few,
if any, PLCs operate in the MF band.

"The allocation of the 2200 meter band, together with the proposal
to adopt flexible rules for the use of that first LF allocation, and
the proposal to allocate the 630 meter band for amateur use, when
implemented, will complete at least a basic complement of Amateur
Radio allocations in all portions of the radio spectrum
domestically," the ARRL told the FCC. "It is readily apparent from
the record...that there can most assuredly be compatible operation
by amateur stations in both the 2200 and 630 meter bands without
adverse interaction with PLCs."

The League asserted that "well-established notification procedures
conducted entirely in the private sector" as well as the sharing of
available database information should facilitate compatible
operation. "Notification procedures will be necessary only in those
predictably few instances in which geographic proximity and
co-channel or overlapping channel operation occurs," the ARRL added.

The League requested that the FCC finalize service rules for 2200
meters that the ARRL outlined, and that it create the proposed 630
meter allocation. Operation on 2200 meters would be limited to 1 W
EIRP, and operation on 630 meters held to 5 W EIRP, in both cases
with an absolute EIRP transmitter output limit of 1500 W PEP and a
200 foot maximum antenna height. Assuming continued PLC compliance
with Part 15 rules, the ARRL argued, "there is no significant
interference potential to PLC systems operated on an unlicensed
basis in that very small segment of the 9-490 kHz band that is
available for PLC operation, even at separation distances of less
than 1 kilometer from the transmission line. At distances of 1
kilometer or more, there is no chance of interference to a PLC line
whatsoever, and no restrictions on Amateur operation outside of that
distance need be imposed."

The ARRL said PLCs that might be operating in the two bands should
be frequency agile enough to relocate to frequencies falling outside
the proposed allocations, making additional regulations unnecessary.
The League has conducted a lengthy and ongoing experimental
operation (WD2XSH) on 630 meters. It pointed out that it was
"unaware of any reports of interference to PLC systems arising from
that operation conducted pursuant to numerous Part 5 experimental
licenses...in the large band utilized by PLCs."

The League agreed with the FCC's proposal to make both 2200 and 630
meters available to Amateur Extra, Advanced, and General licensees.
The ARRL also said the FCC should provide "maximum flexibility with
emission types" emissions throughout the 630 and 2200 meters,
including CW, RTTY, data, and even phone and image, the last
"especially at 630 meters."

The ARRL also commented on the FCC's proposal to amend its Part 80
rules to permanently authorize radio buoy operations on the "open
sea" under a ship station license in the 1900-2000 kHz band, which
the Commission recently elevated to primary for Amateur Radio. The
League said there is "no evidence of compatibility" between Amateur
Radio operation in the band and the "heretofore illegal" ocean buoy
operations there.

"[S]hould the Commission proceed with its proposal...to make the
1900-2000 kHz band available to commercial fishing vessels for use
by radio buoys on the open sea and to include them in the equipment
authorized as part of a ship station license, it should not do so by
means of a primary allocation for these devices in ITU Regions 2 and
3 as proposed," the League said. "The entitlement to utilize radio
buoys should be on a secondary basis to the Amateur Service (and
other radio services operating in the 1900-2000 kHz band), and the
buoys should be prohibited from causing harmful interference to
Amateur stations without qualification."

In a footnote, the ARRL said, "The record is silent heretofore as to
the need to use radio buoys in this frequency range. There is no
information as to the necessary path distances for these devices and
why a band with very long distance propagation is necessary for
these buoys rather than VHF or some other suitable alternative."
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