[SFDXA] ARLB007 FCC Invites Comments on ARRL Petition That Seeks 80/75 Meter Adjustments

[Bill]

SB QST @ ARL $ARLB007
ARLB007 FCC Invites Comments on ARRL Petition That Seeks 80/75 Meter 
Adjustments

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ARRL Bulletin 7  ARLB007
>From ARRL Headquarters
Newington CT  February 23, 2016
To all radio amateurs

SB QST ARL ARLB007
ARLB007 FCC Invites Comments on ARRL Petition That Seeks 80/75 Meter 
Adjustments

The FCC has put the ARRL's January Petition for Rule Making (RM 11759 - 
found on the web at, 
http://apps.fcc.gov/ecfs/comment/view?id=60001374190) on public notice 
and invited interested parties to comment on what the League has called 
"minimal but necessary changes" to 80 and 75 meters. The ARRL petitioned 
the FCC to fix a "shortfall in available RTTY/data spectrum" that the 
Commission created when it reapportioned 80 and 75 meters 10 years ago.

The League's petition asked the FCC to shift the boundary between the 80 
meter RTTY/data subband and the 75 meter phone/image subband from 3600 
kHz to 3650 kHz. The proposed change received strong support from ARRL 
members, and the ARRL Board of Directors adopted it as policy at its 
July 2015 meeting. At that time the Board also
agreed to seek RTTY and data privileges for Novice and Technician 
licensees within their current 15 meter CW subband, and to do the same 
on 80 meters, depending on the outcome of the 80/75 meter subband revision.

The petition asks the FCC to make the following changes to the Part 97 
Amateur Radio Service rules, with respect to 80/75 meters:

* Modify the RTTY/data subband, so that it extends from 3500 kHz to 3650 
kHz.

* Modify the phone/image subband, so that it extends from 3650 kHz to 
4000 kHz.

* Make 3600-3650 kHz available for General and Advanced Class licensees, 
as was the case prior to 2006.

* Make 3600-3650 kHz available to Novice and Technician licensees for 
telegraphy - consistent with existing rules permitting Novices and 
Technicians to operate CW in the 80, 40, and 15 meter General and 
Advanced RTTY/data subbands.

* Modify the rules governing automatically controlled digital stations 
(ACDS), to shift the ACDS segment from 3585-3600 kHz to 3600-3615 kHz, 
consistent with the IARU Region 1 and 2 band plans.

According to the ARRL, the FCC R&O in Docket 04-140 released in 2006 
departed substantially and without justification from the rules proposed 
in the FCC's so-called "Omnibus" Notice of Proposed Rule Making (NPRM), 
with respect to 75 and 80 meters. Among other actions, the resulting 
changes expanded voice privileges on additional frequencies in various 
bands, including 75 meters. The FCC shifted the phone/image subband from 
3750-4000 kHz to 3600-4000 kHz, trimming the 80 meter RTTY/data subband 
from 3500-3750 kHz to
3500-3600 kHz and substantially changing "the entire dynamic of this 
band," the League said.

Although the Omnibus R&O had indicated that incumbent licensees would 
not lose any operating privileges, some clearly did, the ARRL has 
pointed out. The most substantial adverse effect of the "unexpected and 
vast expansion" of the 75 meter phone/image subband, the League said, 
was the elimination of access to 3620-3635 kHz by ACDS.

The Omnibus R&O rule changes limited 80 meters to 3500-3600 kHz, and no 
longer authorized RTTY and data emissions above 3600 kHz. That the 
Omnibus R&O did not modify Part 97.221 of the rules to provide for ACDS 
"was clearly an oversight by the Commission."

After the FCC denied a subsequent ARRL Petition for Reconsideration, the 
Commission replaced the inadvertently deleted 3620-3635 kHz ACDS segment 
with 3585-3600 kHz.

"Far from fixing the problem created by the error in the Omnibus R&O, 
the moving of the inadvertently deleted digital subband downward in 
frequency below 3600 kHz made the situation in the 80 meter RTTY/data 
subband even worse than it was," the ARRL said. The result has been a 
shortfall in available RTTY/data spectrum at 80 meters.

"ARRL has analyzed the regulatory limitations as part of a comprehensive 
effort to make more efficient the use of those HF allocations, 
especially with respect to encouraging further
experimentation and proficiency in narrowband digital communications 
technologies," the League said in concluding its Petition. "The 
recommendations for modified band plans developed by ARRL necessitate 
the few, but important regulatory changes proposed."
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