[AMRadio] WT Docket No. 04-140, 80m phone proposal

Sat Apr 24 17:34:03 EDT 2004

  Don, I agree that many hams just can't leave a certain frequency.  If you
gave hams extended band coverage, many of them would still stay above 3800
Khz and fight the QRM.  Creatures of habit, I guess.

  Are you going to Dayton?

  Dave, W3ST
  Secretary to the Collins Radio Association
  Publisher of the Collins Journal
  www.collinsra.com
  ----- Original Message -----
  From: "Donald Chester" <k4kyv at hotmail.com>
  To: <amradio at mailman.qth.net>
  Sent: Saturday, April 24, 2004 12:26 PM
  Subject: [AMRadio] WT Docket No. 04-140, 80m phone proposal

  > Because of the length and complexity of the latest FCC "restructuring"
  > proposal, it may not be immediately obvious when first reading the
  > document that THE FCC IS PROPOSING TO ADD ONLY 25 kHz to our
  > existing 75/80m phone privileges, as petitioned by ARRL.
  >
  > We are all aware of the overcrowding of the 75m phone band while tens
  > of kilohertz of spectrum below 3750 lies idle, even during optimum
  > wintertime condx, due to the outdated, unrealistic size of the 80m "cw
  > subband".
  > Quoting a comment by Jim, N2EY that appeared on the CW Reflector, one of
  > the reasons for this lack of activity is that "80 CW/data is a huge band
  > compared to the others, so it takes a lot of hams to fill it up."
  >
  > It appears that the FCC has rejected the idea of eliminating mode
  > subbands Canadian style, but the "phone" community, including AM, SSB,
NBFM
  > and SSTV enthusiasts should try to persuade the Commission to adopt a
  > more realistic reapportionment between narrowband (cw/data)
  > and wideband (phone, etc.). The topic of "spectrum efficiency" is
brought
  > up, but little is proposed that would remedy the present
  > inefficient allocation of subbands that results in simultaneous
  > overcongestion and
  > underuse of the amateur spectrum in the 75/80m band.
  >
  > The current proposal would extend the "phone" band down to 3725 kHz,
  > with 3725-3750 limited to Extra Class, 3750-3800 limited to Extra and
  > Advanced, and 3800-4000 open to Extra, Advanced and General.
  > Nothing is proposed to simplify the complex matrix of
  > emission mode/operator class subbands that exists today.
  >
  > I believe at the present time it would be futile to push for
  > subband-free amateur bands in the US, and with the possibility of
  > eliminating the Morse Code testing requirement altogether,
  > cw/narrowband data modes may end up needing a reasonable amount of
  > "protected"
  > frequency space, in the (unlikely, in my opinion) case that the eventual
  > no-code licence exam does result in an influx of SSB appliance
  > operators. However, the existing subbands need to be at least
reapportioned
  > to
  > reflect the actual level of usage of the various modes.
  >
  > I would suggest that the "phone" or "wideband" segment be extended
  > down at minimum to 3600 kHz. 100 kHz seems more than adequate to
  > accomodate the present level of cw and narrowband data activity on 80m.
  >
  > This is more than an AM issue. It would be in the interests of the SSB
  > and SSTV communities, as well as amateurs who might want to
  > experiment in the future with wideband digital modes including digital
  > voice transmission. This should not become a "CW vs Phone" issue; I
  > work cw myself and certainly do not want to see cw shoved off the band
  > to accommodate more bubbas with riceboxes. However, the cw
  > community seems particularly adamant in insisting on not budging an
  > inch, to keep every kilocycle of the present exclusive 80m allocation,
  > despite its sparce occupancy.
  >
  > With the amateur community reportedly split close to 50-50 on the issue
  > of code vs no-code, it would seem that there would be much more
  > support in the US for a more equitable apportionment between phone and
  > cw, than what is reflected in this FCC proposal.
  >
  > Maybe too many active US hf hams, especially the SSB community, are
  > content to meet daily on their one frequency to talk to their same half
  > dozen or so cronies, with little interest these matters beyond bitching
and
  > griping about the QRM.
  >
  > Oughtn't we to talk up the idea of advocating more than 25 kHz of
expansion
  > of the US phone bands by actually filing comments with the FCC? The
  > comment deadline is the 15th of June. See excerpts from the FCC
  > proposal (WT Docket No. 04-140) that follow below.
  >
  > Don K4KYV
  >
  >
****************************************************************************
***********************************************
  >
  > 1. High Frequency Privileges...
  >
  > ARRL Petition. Background. On March 22, 2002, the ARRL requested that we
  > eliminate the telegraphy frequency segments currently authorized to
Novice
  > and Technician Plus
  > Class licensees, and to restructure the operating privileges authorized
  > licensees in certain HF
  > amateur service bands. The ARRL based its request on over 4,700
responses to
  > a survey it
  > conducted regarding different emission subband options for four of the
eight
  > HF amateur service
  > bands. The ARRL notes that while the survey results did not reflect a
  > consensus on any one HF
  > band frequency alternative, most respondents favored dissolving the
Novice
  > and Technician
  > Plus Class telegraphy subbands so that additional spectrum could be
  > authorized for phone
  > communications. The ARRL requests the Commission to amend Section 97.301
of
  > its Rules to
  > expand the frequency segments of the 80-, 40-, and 15 m HF amateur
service
  > bands that licensees
  > may use for phone communications. The ARRL states that a "refarming"
plan
  > based on
  > eliminating the Novice and Technician Plus Class subbands is critical
  > because the segments
  > presently authorized for phone and digital communications are severely
  > overcrowded.
  > ...(2)General Class licensees should be authorized to control an
  > amateur station transmitting voice communications on the 3800-4000 kHz,
  > 7175-7300 kHz and
  > 21275-21450 kHz frequency segments; (3) Advanced Class licensees should
be
  > authorized to
  > control an amateur station transmitting voice communications on the
  > 3750-4000 kHz and 7125-
  > 7300 kHz frequency segments; and (4) Amateur Extra Class licensees
should be
  > authorized to
  > control an amateur station transmitting voice communications on the
  > 3725-4000 kHz and 7125-
  > 7300 kHz frequency segments...
  >
  > 9. Discussion. The Commission received over one hundred and twenty
comments
  > regarding the ARRL's Petition... Other commenters also note that the
Novice
  > Class subbands are
  > underutilized thus agreeing with the ARRL's request
  > that we reallocate these subbands to other
  > uses. Other commenters supporting the ARRL's request suggest that we ...
  > establish
  > different frequency limits for the phone subbands...As an alternative to
the
  > ARRL's request,
  > two commenters suggest that we eliminate subbands
  > altogether and allow the amateur service community to address emission
  > separation on its own
  > through voluntary band planning. This suggestion, we note, was opposed
by
  > others...
  > On the other hand, some commenters oppose the request explaining that
the
  > current
  > allocation of spectrum for voice communications is sufficient. Two
  > commenters in particular
  > state that allocating additional spectrum for single sideband (SSB)
phone
  > communications is
  > spectrum-inefficient....In addition, some
  > commenters believe that the proposal will not have any significant
effect on
  > congestion in the
  > amateur service phone bands...
  >
  > We believe
  > that the tremendous volume of survey responses indicates intense
interest on
  > the part of the
  > amateur service community to promote spectrum efficiency. Because the
ARRL
  > Petition
  > addresses the operating privileges of all classes of licensees on these
  > amateur service bands, we
  > believe that the ARRL Petition provides a basis for a comprehensive
  > restructuring of operating
  > privileges. We note that, as proposed, no licensees would lose any
spectrum
  > privileges and that
  > General, Advanced, and Amateur Extra Class licensees would gain spectrum
for
  > phone
  > emissions, one of the most popular operating modes on the HF bands. For
  > these reasons, we will
  > propose amending Part 97 of our Rules as the ARRL requests. We seek
comment
  > on this
  > proposal.
  >
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