[K4YZ]

FROM THE ARRL WEBSITE

League Asks FCC to Postpone, Modify Part of 75-Meter Band Change


NEWINGTON, CT, Dec 11, 2006 -- In separate petitions today, the ARRL
asked the FCC to postpone the change in allocation for 3600 to 3635 kHz

while it considers a request to maintain the status quo in the segment.

The so-called "omnibus" Report and Order (R&O) in WT Docket 04-140,
which included moving the lower edge of the Amateur Extra 75-meter
phone band to 3600 kHz, is set to go into effect Friday, December 15.
The League wants the Commission to rectify the "unintended consequence"

of the expansion by moving the dividing line between the narrowband and

wideband segments of 80/75 meters to 3635 kHz. This would keep 3600 to
3635 kHz available to General and higher licensees for RTTY, data and
CW and open to Novice and Tech Plus licensees for CW. The requested
change also would maintain access to the automatically controlled
digital subband, 3620 to 3635 kHz. In a Petition for Reconsideration,
the League emphasized that it was not seeking reconsideration of the
entire 75-meter phone band expansion.


"Rather, we ask only that the Commission restore the privileges
unintentionally withdrawn from those who operate and who utilize
automatically controlled narrowband digital stations between 3620 and
3635 kHz," the League said. The ARRL pointed out that while the R&O
left unchanged rules permitting automatically controlled narrowband
digital in that segment, it eliminated RTTY and data as permitted
emissions above 3600 kHz. The ARRL also filed a Petition for Partial
Stay of Effective Date of Rule pending final action on its
reconsideration petition.


To justify its far greater-than-requested expansion, the League
asserted, the FCC relied on the flawed logic of a handful of commenters

who specifically asked for a 3600 to 4000 kHz phone band. Some
commenters had made the case during the proceeding that the "CW
subband" is vastly underutilized while space for SSB is at a premium.


"It affects considerably more than just those two operating modes," the

ARRL said of the expansion. "Narrowband RTTY and data modes are
increasingly used at 80 meters as well, and substantial numbers of RTTY

and data users stand to be displaced, as well as precluded entirely, by

the extent of the telephony subband expansion there."


The League contends the FCC contradicted itself by saying the rule
revisions wouldn't result in any licensee losing spectrum privileges.
"But operating privileges have been lost by the extent of the expansion

at 80 meters," the reconsideration petition states. The expansion also
significantly burdens and adversely impacts CW nets above 3600 kHz --
including emergency and public service nets -- most, if not all, of
which will have to cease operating or change frequency, the League
added.


Most important, however, is the loss of spectrum for automatically
controlled digital modes. The ARRL petition cites the comments of
several League members decrying the loss of spectrum for PACTOR, CW and

RTTY. "The Winlink 2000 system was cited as a best practice by several
post-Hurricane Katrina reviews, including the Congressional 'Failure of

Initiative' report," remarked ARRL South Texas Section Emergency
Coordinator Jerry Reimer, KK5CA.


The ARRL says shifting the band edge slightly upward would provide a
"simple and equitable fix" to the obvious error in the R&O.


"This is neither a minor matter nor an academic exercise in future band

planning," the ARRL concluded. "It is an urgent problem which, unless
corrected, affects a substantial number of existing Amateur Radio fixed

facilities and an even more substantial number of mobile facilities."


UNQUOTE


This IS a minor matter and it IS an "...academic exercise in future

band planning..."

The ARRL USUALLY goes out of it's way to get the FCC to allow
"Gentleman's Agreements" and other "good Amateur practice" to establish

how Amateurs divy up the spectrum.

Now it wants the FCC to micomanage spectrum allocations.

The whole re-farming episode has been in the mill for three years
now, and there's no reason to gunk-up the works at H-Hour.

73

Steve, K4YZ

[[email protected]]

K4YZ wrote:

This IS a minor matter and it IS an "...academic exercise in future
band planning..."

Yup. And FCC should do what ARRL suggests, IMHO.

The ARRL USUALLY goes out of it's way to get the FCC to allow
"Gentleman's Agreements" and other "good Amateur practice" to establish
how Amateurs divy up the spectrum.

Now it wants the FCC to micomanage spectrum allocations.

The whole re-farming episode has been in the mill for three years
now, and there's no reason to gunk-up the works at H-Hour.

I don't think you understand the issue, Steve. It's about an obvious
error in the Report and Order that will outlaw automatic RTTY and data
modes from the 3500-4000 kHz band.

Under current FCC Part 97 rules:

1) RTTY and data modes are not allowed in the "phone/image" HF subbands

2) "Automatic" RTTY and data operation in the 3500-4000 kHz band is
only allowed from 3620-3635 kHz.

3) The lower edge of the "phone/image" HF subband of the 3500-4000 kHz
band is at 3750 kHz.

If the current FCC Report and Order goes into effect on December 15:

1) RTTY and data modes will still notbe allowed in the "phone/image" HF
subbands

2) "Automatic" operation in the 3500-4000 kHz band will only be allowed
from 3620-3635 kHz.

3) The lower edge of the "phone/image" HF subband of the 3500-4000 kHz
band will be at 3600 kHz.

IOW, the "automatic" RTTY/data subband will be in the 'phone/image
subband, where RTTY and data modes are not allowed!

All ARRL is asking is that the dividing line be at 3635 instead of
3600. Problem solved.

That's not micromanaging. It's fixing a simple but important error in
the Report and Order.

Would you rather that automatic RTTY/data be completely banned from
3500-4000? That's what will happen if the Report and Order goes into
effect as written.

--

The ARRL did not ask for the lower edge of the 'phone/image subband to
be at 3600. Nor did they ask for 100 kHz of Extra-only 'phone/image
bandspace.

73 de Jim, N2EY

[[email protected]]

K4YZ wrote:

This IS a minor matter and it IS an "...academic exercise in future
band planning..."

The FCC should do what ARRL suggests, IMHO.

The ARRL USUALLY goes out of it's way to get the FCC to allow
"Gentleman's Agreements" and other "good Amateur practice" to establish
how Amateurs divy up the spectrum.

The dividing line between the various subbands-by-mode on the HF bands
isn't a gentleman's agreement. It's FCC regulations.

Now it wants the FCC to micomanage spectrum allocations.

No, that's not true.

All ARRL wants is to keep automatic RTTY and data modes legal on part
of the 3500-4000 kHz band, just as it is today.

The whole re-farming episode has been in the mill for three years
now, and there's no reason to gunk-up the works at H-Hour.

I don't think you understand the issue, Steve. It's about an obvious
error in the Report and Order that will outlaw automatic RTTY and data
modes from the small part of the 3500-4000 kHz band where they are
legal today

Under current FCC Part 97 rules:

1) RTTY and data modes are not allowed in the "phone/image" HF subbands


2) "Automatic" RTTY and data operation in the 3500-4000 kHz band is
only allowed from 3620-3635 kHz.

3) The lower edge of the "phone/image" HF subband of the 3500-4000 kHz
band is at 3750 kHz.

If the current FCC Report and Order goes into effect on December 15:

1) RTTY and data modes will still not be allowed in the "phone/image"
HF
subbands

2) "Automatic" operation in the 3500-4000 kHz band will only be allowed

from 3620-3635 kHz.

3) The lower edge of the "phone/image" HF subband of the 3500-4000 kHz
band will be at 3600 kHz.

IOW, the "automatic" RTTY/data subband will be in the 'phone/image
subband, where RTTY and data modes are not allowed!

All ARRL is asking is that the dividing line be at 3635 instead of
3600. Problem solved.

That's not micromanaging. It's fixing a simple but important error in
the Report and Order.


Would you rather that automatic RTTY/data be completely banned from
3500-4000? That's what will happen if the Report and Order goes into
effect as written.


--


The ARRL did not ask for the lower edge of the 'phone/image subband to
be at 3600. Nor did they ask for 100 kHz of Extra-only 'phone/image
bandspace.

It's clear that when FCC decided to make the dividing line much further
down the
band than ARRL requested, FCC didn't consider the impact it would have
on
automatic RTTY/data operations that are currently allowed on 3620-3635
kHz.

Now it's time to fix that oversight.


73 de Jim, N2EY

[Iitoi]

Originally Posted by K4YZ

The ARRL USUALLY goes out of it's way to get the FCC to allow
"Gentleman's Agreements" and other "good Amateur practice" to establish
how Amateurs divy up the spectrum.

I don't think the gentleman from Tennessee understands the situation in play here. A "Gentleman's Agreement" won't solve this problem.

The FCC Docket (intentionally or unintentionally?) effectively outlawed modes that previously were legal on 75M, specifically the use of automated data stations. The ARRL petition rightly asks FCC to reconsider and restore this mode to our use on this band.

The Man in the Maze
QRV from Baboquivari Peak, AZ