02/23/2016
The FCC has put the ARRL's January Petition for Rule Making (RM 11759[1]) 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:
o Modify the RTTY/data subband, so that it extends from 3500 kHz to 3650
kHz.
o Modify the phone/image subband, so that it extends from 3650 kHz to 4000
kHz.
o Make 3600-3650 kHz available for General and Advanced Class licensees, as
was the case prior to 2006.
o 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.
o 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 Report and Order 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 ? 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."
[1] http://apps.fcc.gov/ecfs/comment/view?id=60001374190
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