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

Sat, 24 Apr 2004 17:02:53 -0500

Forwarded from the AM Reflector

-----Original Message-----
From: [email protected]
[mailto:[email protected]] On Behalf Of Donald Chester
[[email protected]]
Sent: Saturday, April 24, 2004 11:26 AM
To: [email protected]
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wintertime condx, due to the outdated, unrealistic size of the 80m "cw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

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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 estructuring 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.