[Qcwa] 60 METER COMMENTS TO THE FCC

[Howard Cunningham]

Hi

I sure wish someone would explain to me what is objectionable about John's =
comments on behalf of the QCWA.=20

hc=20
WD5DBC

Howard Cunningham
MACRO Systems, LLC
3867 Plaza Drive
Fairfax, VA 22030

(703) 359-9211
(703) 591-0446 (F)
www.macrollc.com

howardc@macrollc.com
for service:  service@macrollc.com


>>> k5dle@juno.com 07/29/02 09:55PM >>>
FROM: K5DLE
29 July 2002

60 METER COMMENTS TO THE FCC:

THIS IS WHAT OUR CRAVEN LEADERS WOULD NOT POST=20
The conversion from PDF format to plain text is not perfect. =20
The text is all there.

Best regards,

Gene Nailon
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Before the FEDERAL COMMUNICATIONS COMMISSION

Washington, D.C. 20554

In the Matter of )

)

Amendment of Parts 2 and 97 of the )

Commission.s Rules to Create a Low Frequency ) ET Docket No. 02-98

Allocation for the Amateur Radio Service ) RM-9404

)

Amendment of Parts 2 and 97 of the )

Commission.s Rules Regarding an Allocation of a ) RM-10209

Band Near 5 MHz for the Amateur Radio Service )

)

Amendment of Parts 2 and 97 of the )

Commission.s Rules Concerning the Use ) RM-9949

Of the 2400-2402 MHz Band by the )

Amateur and Amateur-Satellite Services )

To: The Commission

COMMENTS OF THE QUARTER CENTURY WIRELESS ASSOCIATION

Introduction

The Quarter Century Wireless Association, Inc. (.QCWA.), strongly
supports the

adoption of the well-reasoned proposals put forth in the Notice of
Proposed Rule Making

(.Notice.) adopted by the Commission on May 2, 2002. In particular, the
allocation of HF

spectrum in the 5250-5400 kHz band (.60 meter band.) to the amateur
service will significantly

enhance the capability of the amateur service community in the United
States to provide essential

communication needs and facilitate relief actions when normal
communication systems are

overloaded, damaged or disrupted because a disaster has occurred.

Interests of petitioner

The QCWA is committed to promoting interest in the amateur service, the
advancement

of the electronic art, making use of the reservoir of knowledge and
experience among the nearly

2

10,000 members of the QCWA for the benefit of all amateur operators and
the furtherance of the

public welfare through amateur service communications. As the
organization whose purpose is

to promote cooperation and friendship among amateur operators of at
least 25 years service, the

QCWA membership is comprised of persons who have been amateur operators
for many

decades. Our combined service in operating amateur stations properly
probably exceeds some

300 millennia.

Response to call for specific comments

In the Notice, the Commission requests comments on its proposal for a
secondary

allocation in the 60 meter band to the amateur service. The QCWA
respectfully provides its

responses to the Commission.s questions in the following paragraphs.

At =3DB638, the Commission requests comment on its proposal to establish a
secondary

allocation for the amateur service in the 60 meter band. The QCWA
strongly agrees with the

Commission, for the good and valid reasons given in the Notice, the
amateur service would

benefit from such an allocation. We agree completely with the American
Radio Relay League.s

contention that the 5000 kHz frequency band can be effective in
supporting communication

when the 3500 kHz and 7000 kHz bands are not. In particular, the QCWA
looks toward having

available the 60 meter band for intercommunications with amateur
stations located within the

hurricane-prone Caribbean Insular area during times of distress.

Additionally, the QCWA believes that there is a somewhat similar
situation where the

Commission regulates the amateur service in ITU Region 3. American
Samoa, the

Commonwealth of Northern Mariana Islands, Guam Island and other United
States territories in

ITU Region 3 would similarly benefit by having the 60 meter band
availability for

3

intercommunications between those typhoon-prone areas as well as with
the State of Hawaii

during times when other communications are disrupted.

The QCWA recommends, therefore, the Commission authorize amateur
stations to

transmit from appropriate locations throughout all three ITU Regions.
This would enable our

amateur stations to provide emergency communications from aircraft and
ships on or over any

area of the world, except for those where another government or agency
regulates the amateur

service.

At =3DB639, the Commission invites comments as to whether the 5250-5400
kHz band should

be restricted to Amateur Extra Class operators to better ensure
compatible sharing with the

Federal Government operations, or could the band also be made also
available to General or

Advanced Class operators. The QCWA strongly recommends that the 60 meter
band be

authorized to General, Advanced and Amateur Extra Class operators. This
is essential to taking

the best possible advantage of the randomly distributed locations of
amateur stations in providing

emergency communications. Being situated at practically every point
throughout the world, it

often falls to the amateur operators on the scene to make known the
situation and call for

emergency assistance when disaster strikes unexpectedly such that normal
communications are

disrupted. The traditional dependency upon amateur operator
self-reliance and the unstructured

nature of the amateur service sometimes make it the only communication
system able to function

immediately in the wake of a major disaster. The 60 meter band should be
made available,

therefore, to all General, Advanced and Amateur Extra Class operators.
These operators are

fully qualified to operate properly amateur stations in the 60 meter
band and have the skill and

knowledge necessary to taking full advantage of the long- and
short-range propagation

characteristics of the 60 meter band.

4

Also, at =3DB639, the Commission invites comment on whether the 1.5kW PEP
power limit

and operator license limitations are sufficient to prevent interference
to primary users, and

whether an EIRP limit would also be appropriate for this frequency band.
Members of the

QCWA throughout the United States have, since the adoption of the
subject NPRM, monitored

the 5250-5400 frequency band to determine the nature of the on-going
communications engaged

in by the primary users so as to be responsive to the Commission.s
concerns. They have found

the band to be lightly occupied with signals similar to those typically
used by amateur stations:

RTTY, Data and Phone. Assuming that these are indeed the legitimately
authorized

transmissions by Government Fixed facilities that would have to be
protected, it is obvious that

sharing of the band will be highly effective. Based upon the long-time
successes the numerous

sharing arrangements for other frequency bands codified in =3DA797.303, 47
CFR =3DA797.303, adequate

protection from transmissions by amateur stations will not be at all
difficult. These arrangements

have well served the existing primary users and have instilled the
amateur service community

with the know-how that has earned it the reputation as being a
cooperative and non-obtrusive

sharing user. The QCWA sees no reason to curtail either the numbers of
operators or the

maximum power of their stations.

Unlike practically any other type of radio station, an amateur HF
station is specifically

and carefully designed to enable the control operator to avoid causing
interference to other

stations. Technology is employed that facilitates highly efficient
instant spectrum management.

For example, frequency and power changes are made with but the tap of a
button or the flick of a

knob. Achieving favorable directed radiation is a widely active pursuit.
Another useful receiver

innovation is automatic band scanning and swept-spectrum usage visual
presentations that show

the operator on-going activity throughout an entire band. Still another
precaution that has been

5

effective is the publication in advance of the specific channels and
times where those stations

that must receive protection intend to operate. There is a host of
amateur service publications

and websites that would offer to disseminate such information.

QCWA recommends against adopting an EIRP limit for amateur stations.
EIRP is, at

best, but a calculated estimate of the energy radiated by a station
based upon a host of

assumptions. It is all but useless in predicting the interference
potential to some unknown distant

receptor. It would be completely out of place among the very practical,
and enforceable,

technical standards that are now in specified in =3DA7=3DA797.301 though
97.317, 47 CFR =3DA7=3DA797.301-

97.317. Note that the actual power limit, as stated in =3DA797.313(a), 47
CFR =3DA797.313(a), is that an

amateur station must use the minimum transmitter power necessary to
carry out the desired

communications. This is a very realistic and effective way to specify
maximum transmitter

power for all amateur service bands.

Further, at =3DB639, the Commission invites comments on other means that
will reduce

potential interference, such as the operational protocol of .listen
before transmit. employed by

amateur radio operators. In particular, the Commission requests comment
on whether this

protocol should be explicitly stated in the Rules in order to protect
the primary operators. In

response, the QCWA can most assuredly report that the amateur service
community.s nearly

century-long protocol of .listen-before-transmit. instant spectrum
management protocol is alive

and well and needs no codification into the Commission.s rules. It is
well covered by the general

standards for station operation in =3DA797.101, 47 CFR =3DA797.101.
Furthermore, this basic operational

principle is well known to every amateur operator and is a highlight of
the qualifying

examination every person must pass in order to obtain an amateur
operator license grant from the

FCC. For the Commission to introduce such a traditional protocol into
the amateur service rules

6

could set the table for still other how-to provisions being added until
the very flexible self-

regulating nature of the amateur service is compromised. The QCWA,
therefore, recommends

against adopting any requirements of this type.

At =3DB640, the Commission requests comments on whether it is necessary
and or appropriate

to segregate digital emission modes in the 60 meter band from other
emission modes similar to

that provided in the 40, 75 and 80 meter bands by =3DA797.305(c), 47 CFR
=3DA797.305(c). The QCWA

favors allowing the amateur service community to determine, as changing
interests and

conditions warrant, how best to segregate emission modes. In any event,
please be informed that

the QCWA has a policy with regard to emission type CW, the most basic
form of radio

communications. The QCWA supports authorization of International Morse
telegraphy coded

on-off CW transmissions on all frequencies on all amateur radio service
frequency bands.

Summary

The QCWA strongly supports the adoption of the proposals put forth in
the subject

Notice. In particular, the allocation of HF spectrum in the 60 meter
band to the amateur service

will significantly enhance the capability of the amateur service
community in the United States

to provide essential communication needs and facilitate relief actions
when normal

communication systems are overloaded, damaged or disrupted because a
disaster has occurred.

The QCWA, therefore, recommends prompt adoption of the rules as proposed
with the revisions

suggested above.

Respectfully submitted for the Board of Directors,

John B. Johnston, Member of the Board

Quarter Century Wireless Association, Inc.

17701 Bowie Mill Road

Derwood, MD 20855-1608

July 22, 2002
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