[Qcwa] 60 METER COMMENTS TO THE FCC

[Harry Hodges]

Hi All,

I have read the QCWA submission to the FCC several times and fail to find
anything I disagree with. Isn't this why we elect a board?

73, Harry
----- Original Message -----
From: "Gene A. Nailon" <k5dle@juno.com>
To: <qcwa@mailman.qth.net>
Sent: Monday, July 29, 2002 6:55 PM
Subject: [Qcwa] 60 METER COMMENTS TO THE FCC


> FROM: K5DLE
> 29 July 2002
>
> 60 METER COMMENTS TO THE FCC:
>
> THIS IS WHAT OUR CRAVEN LEADERS WOULD NOT POST
> The conversion from PDF format to plain text is not perfect.
> The text is all there.
>
> Best regards,
>
> Gene Nailon
> ======================================================
>
> 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 =B638, 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 =B639, 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 =B639, 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 =A797.303, 47
> CFR =A797.303, 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 =A7=A797.301 though
> 97.317, 47 CFR =A7=A797.301-
>
> 97.317. Note that the actual power limit, as stated in =A797.313(a), 47
> CFR =A797.313(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 =B639, 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 =A797.101, 47 CFR =A797.101.
> 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 =B640, 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 =A797.305(c), 47 CFR
> =A797.305(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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