[ETS/PARC List] FW: ARLB013 ARRL Tells FCC to Restore Balance of Modes on 80 and 75 Me ters

[Don WILSON]

> From: "ARRL Web site" <memberlist at www.arrl.org>
> To: k2dsv at juno.com
> Subject: ARLB013 ARRL Tells FCC to Restore Balance of Modes on 80 and 75 Meters
> Date: Mon, 28 Mar 2016 17:08:35 -0400 (EDT)
> 
> SB QST @ ARL $ARLB013
> ARLB013 ARRL Tells FCC to Restore Balance of Modes on 80 and 75
> Meters
> 
> ZCZC AG13
> QST de W1AW  
> ARRL Bulletin 13  ARLB013
> From ARRL Headquarters  
> Newington CT  March 28, 2016
> To all radio amateurs 
> 
> SB QST ARL ARLB013
> ARLB013 ARRL Tells FCC to Restore Balance of Modes on 80 and 75
> Meters
> 
> In comments filed on March 23 on its Petition for Rule Making (RM
> 11759) seeking changes to 80 and 75 meters, the ARRL has told the
> FCC that its primary objective is to "rebalance" the bands by
> correcting a 10-year old FCC error.
> 
> "ARRL's proposal is not fairly viewed as a proposal to take anything
> away from anyone," the League's comments assured. "It is more
> properly viewed as the effectuation of a fair, equitable, and
> efficient 'band plan' looking forward for the foreseeable future
> that balances everyone's needs, and which remedies a plainly unfair
> plan, imprudently created in the 2006 Report and Order in WT Docket
> 04-140."  The Report and Order can be found on the web at,
> http://apps.fcc.gov/ecfs/comment/view?id=5513680269 .
> 
> Prompting the League's assurances were comments filed on the ARRL's
> Petition by a number of Amateur Extra class licensees, who felt that
> refarming 3600 to 3650 kHz for data modes could prove to be a
> disincentive to General licensees to upgrade. Others commenters saw
> it as an unfair spectrum grab. The ARRL noted that prior to 2006,
> the band was evenly divided between RTTY/data and phone/image
> subbands, with the RTTY/data subband extending from 3500 to 3750
> kHz, and the phone/image subband extending from 3750 to 4000 kHz.
> 
> The 2006 FCC Report and Order "substantially altered" what the
> League called "this even division of emission types." In outlining
> the history of the proceeding, the ARRL pointed out that the FCC's
> Notice of Proposed Rulemaking in Docket 01-140 would have shifted
> the line between the 80 meter RTTY/data subband and the 75 meter
> phone/image subband from 3750 kHz to 3725 kHz, pursuant to a 2002
> ARRL Petition for Rule Making, RM-10413. This would change the ratio
> of spectrum between phone/image and RTTY/data segments on 75/80
> meters from 50/50 to 55/45, and it is what the FCC proposed in its
> NPRM.
> 
> In its Report and Order in Docket 04-140, however, the FCC made "a
> very substantial and unjustifiable departure" from what it had
> proposed in its NPRM, the ARRL recounted. The Commission expanded
> the phone/image subband at 75 meters to 3600-4000 kHz, and it
> reduced the 80 meter RTTY/data subband to 3500-3600 kHz, eliminating
> RTTY operation above 3600 kHz and changing "the entire dynamic of
> this band," the League said.
> 
> The FCC had said in its proposal that no licensees would lose
> operating privileges. Nonetheless, the FCC's phone band expansion
> reduced by 100 kHz the spectrum between 3500 and 4000 kHz that was
> previously available to General class licensees, while Advanced
> licensees lost 75 kHz. In an apparent FCC oversight, the Report and
> Order completely eliminated access by automatically controlled
> digital stations (ACDS) to 3620 to 3635 kHz. A subsequent FCC Report
> and order and Order on Reconsideration only made the situation worse
> by replacing the deleted ACDS segment with 3585-3600 kHz.
> 
> "It resulted in a sudden and severe dislocation of traffic-handling
> nets using telegraphy, without advance planning or notice," the ARRL
> said. "It disaccommodated net participants with General and Advanced
> class licenses; and it worsened the effect of the overexpansion of
> the 75 meter phone/image subband."
> 
> The result, the ARRL noted, has been "a shortfall in available
> RTTY/data spectrum on 80 meters" that has created a significant
> obstacle to narrowband digital data communications and
> experimentation. The League said its current Petition "simply
> restores that which was disrupted in 2006 in error."
> 
> In its comments, the League conceded that compromises are inevitable
> in managing a heavily used band like 75/80 meters, no matter the
> band planning approach. "Looking forward, it is necessary, in order
> to encourage experimentation with and expand the use of digital
> communication techniques, to rebalance the 75 and 80 meter
> subbands," the ARRL concluded.
> NNNN
> /EX
> 
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