[CW] FCC Requests Comments on CW Allocation at 5 MHz
Bill Tippett
[email protected]
Tue, 04 Jun 2002 22:31:20 +0100
N7DC wrote:
>Some YL in town consistently working SSB right on top of DX at
14,025, while I was already there, attempting to QSO in cw.
Guess what? This is exactly the situation we have had for
17 years I personally know of on 160 meters. An SSB group "claimed"
1823 for their daily ragchews in the middle of the narrowband
segment (1800-1840) recommended by both ARRL and IARU Region 2
Voluntary Bandplans. After repeated requests to move higher, the
group adamantly refused to move (for 17 years!). ONLY AFTER FCC
INTERVENTION with Enforcement Letters from Hollingsworth last
September did the group move higher in the band:
http://www.arrl.org/news/enforcement_logs/2001/0922.html
160 is the ONLY HF amateur band without mode segmentation
and is the ONLY band where there have been problems of this type.
If the FCC wants less resources focused on intervention, they
need to learn from the mistakes on 160 and not replicate them on
other bands thereby increasing their workload.
I was told by someone at ARRL that the primary reason they
submitted their 5 MHz request without mode segmentation was primarily
expediency, and that they may comment on this during the NPRM. The
ARRL seems totally inconsistent in recommending continued mode
segmentation in Novice Refarming (RM-10413), but then not suggesting
it for 5 MHz (see my comments below).
I might add that one of the other posters on this issue is an
avid AM'er. Could be that he wants no mode segmentation so that
spectrum-inefficient 6 kHz AM signals (more if they run high-fidelity
modes) could have free run on our bands? I suggest we all comment
on the FCC's NPRM (02-98) unless you want the AM/SSB camels poking
their noses under the narrowband tent...today it is only 60 meters
(and 160 meters unless RM-10352 is adopted), but tomorrow it could be
all our bands.
73, Bill W4ZV
P.S. My original comments on the Topband reflector:
From the FCC's NPRM itself:
Adopted: May 2, 2002: Released: May 15, 2002
Comments Due: 45 days from publication in the Federal Register.
Reply Comments Due: 60 days from publication in the Federal Register.
While I am not sure exactly when this was published in the
Federal Register, ET 02-98 is available for comment now and the
comment window can be opened by going here:
http://gullfoss2.fcc.gov/prod/ecfs/comsrch_v2.cgi
and entering only 02-98 in Box 1 and clicking Retreive Document List.
There is only one comment there because I'm not sure many even know that
the comment window is open! You can read the full FCC NPRM here:
http://www.arrl.org/announce/regulatory/et02-98/
I have a particular concern with the following paragraph:
"40. The 5000 kHz Petition does not discuss sub-banding and ARRL's suggested
rules would allow all emission types to use the entire band.[94] We note
that several commenters suggest that sub-banding would be useful. We further
note that Section 97.305 of our Rules segregates digital modes from other
amateur station emission modes in the 3500 kHz and 7000 kHz bands to protect
narrow band emissions like data from wider emissions like single-side band
voice.[95] We request comment on whether sub-banding is necessary and/or
appropriate for the 5000 kHz band as well."
ARRL is very schizophrenic on this issue. Today we have mode
segmentation on every HF band except 160, then ARRL proposes NO mode
segmentation for the new 5 MHz band, and now as part of RM-10413 (Novice
and Tech Plus Refarming) they endorse continued segmentation on 80, 40
and 15. From their comments above, I believe even the FCC must be
wondering what ARRL's true position is on mode segmentation...they are
totally inconsistent in their actions IMHO.
I obviously have my biases about mode segmentation since that
was the main issue in RM-10352 for Topband. However, I believe no
segmentation is a dangerous precedent to begin anywhere. Today we seldom
see modes out of place on any bands except 160, and I hope we are not
about to repeat the bad experience we've had there over the past 15
years!
Here is a summary of current and proposed mode segmentation
by band for all HF amateur bands:
***************************************************************************
Listed below are the percentage of HF spectrum by band currently
allocated exclusively for Narrowband modes compared with proposed
allocation changes if proposed RM Petitions RM-10352 (160 meters),
RM-10413 (Novice/Tech Plus Refarming on 80, 40 and 15 meters), and
NPRM ET 02-98 (60 meters) are adopted (other HF bands included for
reference):
NARROWBAND ALLOCATIONS BY BAND
Band Current % Proposed % Proposal Narrowband/Total (kHz)
160 0 20 RM-10352 40 / 200
80 50 45 RM-10413 225 / 500
60 N/A 0 ET 02-98 0 / 150
40 50 41.7 RM-10413 125 / 300
30 100 100 No change 50 / 50
20 42.9 42.9 No change 150 / 350
17 42.0 42.0 No change 42 / 100
15 44.4 44.4 RM-10413 200 / 450
12 40 40 No change 40 / 100
10 17.6 17.6 No change 300 / 1700
************************************************************************
Whether you agree or disagree with me about the need for
mode segmentation on our HF bands, I think we all need to make
our feelings known to the FCC. If we do nothing, we have nobody
to blame but ourselves. If you want to comment on the FCC's NPRM,
go to this site, enter only 02-98 in Box 1, fill out the other non-
optional boxes and submit a brief comment in the bottom box or attach
your file (Adobe, Lotus, Word, WordPerfect, etc) in the box above that:
http://gullfoss2.fcc.gov/prod/ecfs/upload_v2.cgi
Be sure to confirm your submission on the page that appears after you
submit. When you do everything correctly, you should see a page with
your name and a confirmation number.
I am not sure of the exact date when the window for ET 02-98
opened, but it apparently has and will be available for comment until
late June or early July. Speak now or forever hold your peace!
73, Bill W4ZV