[SFDXA] Comments to FCC needed ASAP, regarding Fish Net Beacons in 1900-2000 kHz

[Bill]

 From QRZ:

K4KYV Said:

Here's an item from the FCC that needs our attention, since 160m is one 
of the bands most widely used by the amateur community.

While most attention so far has focused on the proposed new MF and LF 
allocations, there is also the issue of fish net beacons on 160m. The 
initial comment deadline is past due, but reply comments are still open 
through the 30th of September. We can reply to the ARRL comments; they 
pretty much have the issue identified and defined spot on, except for a 
suggestion that fish net beacons on 1900-2000 kHz be moved to the 
"lightly used" portion of the Radiolocation frequencies between the 
broadcast band and 160m ham band, specifically 1750-1800 kHz. From what 
I hear on my receiver at this location, the entire segment of 
frequencies between 1705 kHz and 1800 kHz is lightly used. I rarely ever 
hear a signal of any kind in that segment, which was once packed full of 
now-discontinued radiolocation beacons. I would strongly urge everyone 
to submit a reply comment explaining why you support the ARRL position, 
with a further suggestion that the entire band of Radiolocation 
frequencies between 1705 and 1800 kHz be considered for re-accommodating 
beacons presently on 1900-2000.

I am not familiar with the beacon transmitters except for a few online 
ads for the products, but I suspect it would be very easy to move the 
transmit frequency, requiring only re-setting a synthesized master 
oscillator and tweaking the antenna tuning network. A technician could 
probably complete the task in less than 10 minutes.

The beacons would suffer far less interference operating in the 
now-vacant Radiolocation spectrum, than in the heavily used amateur 
band. Even though they operate at low transmitting power, amateurs, 
particularly those living in coastal areas, frequently complain of 
interference. Likewise, signals from high power amateur transmitters are 
undoubtedly capable of causing harmful interference to the beacons.

When the FCC released the Report & Order upgrading amateur status to 
primary, it wasn't immediately clear that this included a new docket 
proposal (15-99) with a subsequent comment deadline. It is unusual for 
the FCC to combine a R&O for one proceeding with a new Notice of 
Proposed Rulemaking all in the same release, so this did not come to the 
attention of most amateurs until a recent news item appeared on the ARRL 
website.

Some useful links:

Here, you see a list of links to recent comments, plus a link to the 
text of the original FCC Release in the right-hand pane. If you wish to 
submit a (reply) comment, click on "Submit a Filing in 15-99", which is 
located at the top of the page just above the main heading.

http://apps.fcc.gov/ecfs/proceeding/view?name=15-99

Here is the entire FCC Docket, which is very lengthy. The pertinent 
section addressing the 1900-2000 kHz issue begins with paragraph 30.

http://apps.fcc.gov/ecfs/comment/view?id=60001030137

Here are the ARRL's submitted comments. The 160m issue is addressed in 
Section II, beginning on page 4 and running through page 11.

http://apps.fcc.gov/ecfs/comment/view?id=60001198635