[NLRS] ARRL Asks Members to Write in Opposition to HR 607

[John (JK) Kalenowsky, K9JK]

Hello NLRSers,

According to the FCC's Spectrum Allocation Table in Part 2 of 
CFR47 (Table 2.106), the entire spectrum 420-450 MHz is 
specified as "RADIOLOCATION" in the "Federal Table" column of 
the 'big' table. "Amateur" is specified in the "Non-Federal 
Table" column so "we Amateurs" are indeed 'secondary' in the 
70cm band. ('All Caps' versus 'mixed case' is significant in 
this table.)

"We" should also keep in mind that 421-430 MHz is ALREADY 
restricted to "us" by allocation along the Great Lakes that 
border Canada, primarily Lakes Ontario, Erie and Huron, to "Land 
Mobile". This does not impact NLRS-land or even those of us in 
Southeast Outer NLRS-land.

It should also be remembered that many parts of the country have 
power output restrictions for Amateurs in the 70 cm band (at 
least parts of California, Colorado, Florida, New Mexico that I 
recall, possibly OTHER areas).

In the rest of the world, the allocation to Amateur is 
restricted to 430-440 MHz, apparently on equal "primary" 
standing to Radiolocation in IARU Region 1 but still "secondary" 
to Radiolocation in IARU Regions 2 and 3.

PERHAPS suggest that instead of 420-440 MHz paired with 450-470 
MHz, *410-430 MHz* paired with 450-470 MHz would be a better 
pairing of frequency ranges and in less contention with 
worldwide spectrum allocations (see next paragraph). 410-420MHz 
IS already allocated to "Fixed" and "Mobile" (as is 420-430 MHz) 
in all 3 IARU Regions. That would still reduce "our" spectrum by 
10 MHz BUT it would "maintain" 430-450 MHz pretty much 'as is'. 
Impacts WOULD be present for ATV at 70cm (loss of ATV Channels 
1, 420-426 and Channel 2, 426-432, though I note those are 
already "restricted" in that Great Lakes region and I admit to 
NOT being aware of how much ATV activity there is), but "weak 
signal" and Satellite segments in 430-440 MHz could survive, as 
could the U.S. (and Canada) repeater sub-band, 440-450 MHz.

Paired with this thinking would be a statement of reasons for 
NOT reallocating the 430-440 MHz segment, noting that, according 
to international agreements, "Fixed" or "Mobile" are NOT 
allocated in that frequency range (while "Fixed" and "Mobile" 
ARE allocated in 410-420 MHz AND in 420-430 MHz).  A possible 
"technical" argument for the larger separation between the two 
band segments is that equipment might be more easily implemented 
with a 40 MHz duplex spacing and 20 MHz minimum band segment 
spacing versus 30 MHz duplex spacing and 10 MHz minimum band 
segment spacing IF the spectrum segments are paired.

I've NOT looked through all of the footnotes (and there are a 
BUNCH of them) for these ranges in the table (though I believe 
that the 421-430 MHz that I mentioned for the Great Lakes border 
area and the power output restrictions for amateurs in 420-450 
MHz are among those footnotes or possibly in other Rule Parts, 
such as Part 90 for "Private Land Mobile" and Part 97 for 
"Amateur").

This is also BEYOND what the ARRL is "asking" for "us" to 
do...suggesting that "we" focus on ANY loss of 420-440 MHz and 
the impact it would have on "us", rather than suggesting any 
compromise alternative.

My "zero cents" worth and any typos that I've left in here are 
also "free".

73, JK


----- Original Message ----- 
From: "Andy Lokken" <alokken at gmail.com>
To: "Aaron Sloan" <ka0zoz at sixone.org>; "NLRS List" 
<NLRS at mailman.qth.net>
Sent: Wednesday, February 23, 2011 08:16
Subject: Re: [NLRS] ARRL Asks Members to Write in Opposition to 
HR 607


>
>
> I'm glad to see this come up on this reflector... I have been 
> watching it
> discussed on other reflectors lately, but didn't want to bait 
> any trolls.
>
> Anyway... Isn't the 70cm amateur allocation secondary to USAF 
> PAVE PAWS
> radar? In about a minute of Googling, I learned that they had 
> recently
> installed some seemingly large upgrades to this system, that 
> it's used for
> missile defense and that they are actively developing it.
>
> I haven't read the bill, but I've seen enough legislation to 
> think that this
> looks like a red herring.
>
> What do you guys know about this?
>
> -Andy
>
>