ARRL Comments re Docket 12-338: 1900-2000 kHz Status, 135.7-137.8 kHz "band"

[k4kyv]

View League's comments here:
http://apps.fcc.gov/ecfs/comment/view?id=6017164923

Another commenter brings up heretofore unpublicised National Security concern:
http://apps.fcc.gov/ecfs/comment/view?id=6017164985

[WA3VJB]

Thanks for the links, Don.

I was tempted to file a Reply comment in the public record of this proceeding as a way to nail the ARRL for its failure to repair its voluntary band plan, which makes no reference to AM activity among the phone modes otherwise listed.

But except for the Gray Hair Net, the FCC's proposal does not cover frequencies popular among AMers.

Yet there are some problems with how the League's lawyer came across in his submission.

In graf 21, he portrays the FCC's offer as an "upgrade," when in reality the agency proposes to restore the status of licensed radio hobbyists as primary users of this allocation (1900-2000Kc). The proposal does not involve some new privilege, in other words.

The lawyer should also have expressed the successful, but temporary, sharing of this allocation with radionavigation users as a way to show how active, concerned licensees can work with other wireless users to coordinate other modes and activities. He had the opportunity to include an example of such cooperation by citing the AM community's efforts to lead the array of the hobby's activities on 160 to minimize friction with others.

As it turns out, the FCC's earlier decision to downgrade Amateur status to secondary was done on the prospect of handling radionavigation services that were displaced by the expanded Standard Broadcast band.  That need dissipated as GPS came in.

This was also a chance to promote the technical and experimental activities of the hobby by pointing to the repair, restoration, and retuning of retired broadcast transmitters to 160 meters.  Eliciting a supporting statement from a broadcast engineering group, say the Society of Broadcast Engineers, would have added weight to the assertion, and raised the flag for the popularity of AM among radio hobbyists on 160m.

The same lawyer has been legal counsel to the SBE, so you think he might know someone to have asked for such a statement?

[k4kyv]

Looks like the first, and so far only, comment has come in (they missed the formal comment deadline), opposing the proposed 1900-2000 kHz changes.

http://apps.fcc.gov/ecfs/comment/view?id=6017166561


The following was submitted as a reply comment to the above, to refute the claims.

http://apps.fcc.gov/ecfs/comment/view?id=6017166592

[wa1mtz]

Hi Don! Just wanted to say, I don't know who comes up with these frequencies..137 kc is used for rfid tagging!
I think there ought to be a band in the LF range, as I have operated on 185kc in daylight on am & mcw.nightime the b'cast stations come in here very well methinks 400-430 would be good I don't hear any marine cw there anymore, at least not here. The old beacons are going away but being replaced by 75 baud transmissions which give all the info on the airport along with station callsign.  73, mike, wa1mtz