[Alexandria Radio Club Reflector] new proposed rules could affect ham radio

[Rich Adamy]

The Shortwave Modernization Coalition has been testing this concept at
far lower power than what they are asking for in their petition.  With
gain antennas, there is no way they will be able to reduce
interference to adjacent services to an acceptable level.  In fact,
the level of interference they are proposing exceeds the maximum
acceptable level as mandated by the International Telecommunications
Union and good engineering practice.

This proposal also not only affects communications in the US, but
because of the spectrum they are using, it will be detrimental to
communications worldwide.  While the amatuer service is taking the
brunt of the interference, other services such as maritime and
aviation will be subjected to some interference.  If the FCC allows
this proposal to go through, other groups are sure to follow.

The comment period closed July 31, but I believe the reply period may
still be open.  If you have not already filed comments/replies, please
do so ASAP.  I filed mine last month.

Rich, KA4GFY

On Tue, Aug 8, 2023 at 5:53 AM Sandra Cruz-Pol via AlexandriaRadioClub
<alexandriaradioclub at mailman.qth.net> wrote:
>
> hi all
> I learned about this
> 1. petition from private companies
> <https://www.radioworld.com/wp-content/uploads/2023/07/5b410673-0cbd-467b-8ea9-06d7808c7924.pdf>,
> so called"shortwave modernization commission' -they would make a lot of $$$$
> 2. and after such request, the FCC publishes a Rule Making (RM-11953)
> <https://www.fcc.gov/ecfs/search/docket-detail/RM-11953> which is a public
> notice, on Jun 29, 2023 (usually they give the public 60 days to respond)
> 3. and here's  ARRL response:
> <https://www.arrl.org/files/file/FCC%20Documents/ARRL%20Opposition%20FCC%20RM-11953%2008_2023.pdf>Aug
> 2.
>
> *"ARRL commissioned a technical analysis to determine if the rules proposed
> by SMC would affect operations on the bands allocated to the Amateur Radio
> Service that are inter-mixed with the Part 90 bands in the subject
> spectrum....ARRL’s analysis concludes that Part 90 operations as they would
> be permitted under the proposed rules would not just threaten to cause
> harmful interference to Amateur communications, but would cause widespread
> disruption to Amateur and other communications services on multiple
> spectrum bands. The proposed rules are seriously flawed, and would
> adversely impact other services as well as the Amateur Radio Service. If
> the Part 90 HF spectrum is to be used for a service of the type proposed,
> the rules must reflect the realities and peculiarities of HF propagation
> and be limited to power levels and bandwidths that, with appropriate
> requirements for suppression of out-of-band emission (OOBE) and spurious
> emissions, will reasonably protect neighboring and adjacent services from
> harmful interference.*
>
> Let's hope the FCC listens.
> 73
>
> Sandra
> KQ4BDG
> __________________
> Dr. Sandra Cruz-Pol
> NSF ERC Program Director
> https://sites.google.com/view/sandraxpol
> SandraCruzPol at ieee.org
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