FCC Invites Comments on ARRL Petition That Seeks 80/75 Meter Adjustments

[Steve - K4HX]

From the latest ARRL Letter:


FCC Invites Comments on ARRL Petition That Seeks 80/75 Meter Adjustments

The FCC has put the ARRL's January Petition for Rule Making (RM 11759) on public notice and invited interested parties to comment on what the League has called "minimal but necessary changes" to 80 and 75 meters. The ARRL petitioned the FCC to fix a "shortfall in available RTTY/data spectrum" that the Commission created when it reapportioned 80 and 75 meters 10 years ago. The League's petition asked the FCC to shift the boundary between the 80 meter RTTY/data subband and the 75 meter phone/image subband from 3600 kHz to 3650 kHz. The proposed change received strong support from ARRL members, and the ARRL Board of Directors adopted it as policy at its July 2015 meeting. At that time the Board also agreed to seek RTTY and data privileges for Novice and Technician licensees within their current 15 meter CW subband, and to do the same on 80 meters, depending on the outcome of the 80/75 meter subband revision.

The petition asks the FCC to make the following changes to the Part 97 Amateur Radio Service rules, with respect to 80/75 meters:

Modify the RTTY/data subband, so that it extends from 3500 kHz to 3650 kHz.

Modify the phone/image subband, so that it extends from 3650 kHz to 4000 kHz.

Make 3600-3650 kHz available for General and Advanced Class licensees, as was the case prior to 2006.

Make 3600-3650 kHz available to Novice and Technician licensees for telegraphy -- consistent with existing rules permitting Novices and Technicians to operate CW in the 80, 40, and 15 meter General and Advanced RTTY/data subbands.

Modify the rules governing automatically controlled digital stations (ACDS), to shift the ACDS segment from 3585-3600 kHz to 3600-3615 kHz, consistent with the IARU Region 1 and 2 band plans.

According to the ARRL, the FCC Report and Order in Docket 04-140 released in 2006 departed substantially and without justification from the rules proposed in the FCC's so-called "Omnibus" Notice of Proposed Rule Making (NPRM), with respect to 75 and 80 meters. Among other actions, the resulting changes expanded voice privileges on additional frequencies in various bands, including 75 meters. The FCC shifted the phone/image subband from 3750-4000 kHz to 3600-4000 kHz, trimming the 80 meter RTTY/data subband from 3500-3750 kHz to 3500-3600 kHz and substantially changing "the entire dynamic of this band," the League said.

Although the Omnibus R&O had indicated that incumbent licensees would not lose any operating privileges, some clearly did, the ARRL has pointed out. The most substantial adverse effect of the "unexpected and vast expansion" of the 75 meter phone/image subband, the League said, was the elimination of access to 3620-3635 kHz by ACDS.

[Steve - K4HX]

Enter your comment for the FCC at the link below.

http://apps.fcc.gov/ecfs/comment/view?id=60001374190

[Steve - K4HX]

Enter your comment for the FCC at the link below.

http://apps.fcc.gov/ecfs/comment/view?id=60001374190

Click on submit a filing. File out the form at attach your comments. Enter RM-11759 in the Proceeding Number block.

[WBear2GCR]

I'm confused.

When did General class licensees have privileges between 3600 - 3650??

What privileges do Extra class licenses give on 75m with these changes that are unique?
Maybe I need to look at the bandplan again. Dunno.

[W3RSW]

Once again you'll be allowed to transmit CW and RTTY as a general. 
And of course digital DATA in myriads of forms these days.

Interesting that for about a week now I've heard numerous SSB conversations popping up in the early morning from groups that a week before used to be in the  3700's but now are almost wall to wall 3600 to 3650.  I guess they're building up crying rights for the inevitable since it's probably a little too late to prove occupancy.

[Steve - K4HX]

Quite a few regular SSB groups in the range most nights too. There was even some AM activity at around 3625 for a while.

This proposal could have a negative impact on AM ops, since it shrinks the phone band, especially the Extra class portion.

[W3RSW]

AM ops?  How about ESSB ops?
7kHz wide just a few minutes ago, mid morning, on 3630
wb9vmz I think.

[Steve - K4HX]

Yes, that area is frequented by ESSB groups.

[Opcom]

So the thing to do is argue against the downsizing of the voice band. I don't like unknown, shadowy people playing whack-a-mole with my hobbies. In the past there have been things like this that were started and led by one or two people with their own agendas not so much aligned with the idea of what's good for the service, but rather what's good for themselves or to 'combat' a perceived inconvenience. What are the best constructive arguments against it? Saying 'I don't want to lose band space for the emissions I prefer' seems shallow.

[W1ITT]

Patrick..
The argument about whether or not there is sufficient spectrum space below 3.6 mhz for both digital and CW modes is hard to settle.  I suppose it depends upon which night you tune the band. It will be resolved about as quickly as the Ford versus Chevy fight.
As for the inclusion of Novices, Techs, and Generals into this part of the band, should it be annexed for digital modes, it is resolved rather simply by telling them to upgrade.  None of the exams, Extra included, require anything like a diploma from Hahvud University.  They dropped the code test, so that's no impediment.  Certainly anyone who fancies himself to be a digital whizbang should not be intimidated by an FCC exam where the questions and answers are in the public domain.
It appears to me that the ARRL is offering solution for a non-problem so that they can be perceived as giving away more "free stuff". 
Norm W1ITT

[Pete, WA2CWA]

I'm all for it. The FCC trimmed the RTTY/data subband too much back in 2006. However, it find it difficult to believe the FCC will fly with the request since it would indicate they made a mistake back in 2006. And, how often do government agencies acknowledge they made a mistake and are willing to correct it. But, this is the 21st century; lots of strange/weird things are happening.

[W3RSW]

I think it will pass.
Digital encompasses so much more than the original CW and Rtty of yore.

But paradoxically it seems that the anciently digital Rtty boys of all people are pushing this reoccupation, not the avant guard  jt65, et. al., crowd. Go figure.
--The same Rtty boys (perhaps not the exact same ops.) that got an extra 3db by pushing 1.5kw pep output back in the day for full 2kw pep input instead of the old 1 kw input and 750 pep rtty out, meanwhile halving the AM fellows' output as you all have mentioned before.

Younger FCC personnel of course are somewhat in the dark when it comes to what games were played in the past so will probably think of it as "modern" digital necessity and also look at the "over expansion" that Pete's mentioned as just that.  Conversely, and a good reason to retain the current voice bands,  you get the digital voice mode being consigned to the analog voice part of the band as further confusion in FCC minds.

 So I'll be fine either way, since it really is just a 50kHz take-back from a pretty huge allotment which really surprised me when it came about.
...um, like I was very active anyway.