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FCC Invites Comments on ARRL Petition to Allocate New 5 MHz Band:

from The ARRL Letter on February 16, 2017
View comments about this article!

FCC Invites Comments on ARRL Petition to Allocate New 5 MHz Band:

The FCC has invited comments on the ARRL's January 12 Petition for Rule Making https://ecfsapi.fcc.gov/file/101122964205072/Petition%20for%20Rule%20Making%205%20MHz%20FINAL%20January%2012%2C%202017.pdf to allocate a new, secondary contiguous band at 5 MHz to the Amateur Service. The League also asked the Commission to keep four of the current five 60-meter channels -- one would be within the new band -- as well as the current operating rules, including the 100 W PEP effective radiated power (ERP) limit. The federal government is the primary user of the 5 MHz spectrum. The FCC has designated the League's Petition as RM-11785 and put it on public notice. Comments are due Monday, March 20. ARRL plans to file comments in support of its petition.

The proposed ARRL action would implement a portion of the Final Acts of World Radiocommunication Conference 2015 (WRC-15) that provided for a secondary international allocation of 5,351.5 to 5,366.5 kHz to the Amateur Service; that band includes 5,358.5 KHz, one of the existing 5 MHz channels in the US. The FCC has not yet acted to implement other portions of the WRC-15 Final Acts.

"Such implementation will allow radio amateurs engaged in emergency and disaster relief communications, and especially those between the United States and the Caribbean basin, to more reliably, more flexibly and more capably conduct those communications [and preparedness exercises], before the next hurricane season in the summer of 2017," ARRL said in its petition.

The League said that 14 years of Amateur Radio experience using the five discrete 5-MHz channels have shown that hams can get along well with primary users at 5 MHz, while complying with the regulations established for their use. "Neither ARRL, nor, apparently, NTIA is aware of a single reported instance of interference to a federal user by a radio amateur operating at 5 MHz to date," ARRL said in its petition. NTIA -- the National Telecommunications and Information Administration, which regulates federal spectrum -- initially proposed the five channels for Amateur Radio use. In recent years, Amateur Radio has cooperated with federal users such as FEMA in conducting communication interoperability exercises.

The League said in its petition that while the Amateur Radio community is grateful to the FCC and NTIA for providing some access to the 5-MHz band, "the five channels are, simply stated, completely inadequate to accommodate the emergency preparedness needs of the Amateur Service in this HF frequency range," ARRL said. Access even to the tiny 15-kHz wide band adopted at WRC-15 would "radically improve the current, very limited capacity of the Amateur Service in the United States to address emergencies and disaster relief," ARRL said.

The WRC-15 Final Acts stipulated a power limit of 15 W effective isotropic radiated power (EIRP), which the League said "completely defeats the entire premise for the allocation in the first place." ARRL said the FCC should permit a power level of 100 W PEP ERP, assuming use of a 0 dBd gain antenna, in the contiguous 60-meter band. "To impose the power limit adopted at WRC-15 for the contiguous band would render the band unsuitable for emergency and public service communications," the League said.

The ITU Radio Regulations permit assignments at variance with the International Table of Allocations, provided a non-interference condition is attached.

Source:

The ARRL Letter

Member Comments:
This article has expired. No more comments may be added.
 
FCC Invites Comments on ARRL Petition to Allocate New 5 MHz  
by N7IBC on February 17, 2017 Mail this to a friend!
Everyone should go to the original document and read the details.The attached document on eham.net does not go into the very detailed description of the whole petition.
 
FCC Invites Comments on ARRL Petition to Allocate New 5 MHz  
by AB9TA on February 17, 2017 Mail this to a friend!
The FCC comments site is notoriously hard to navigate, but I recommend commenting anyway. You can comment here: https://www.fcc.gov/ecfs/filings

My comments to the FCC:

February 17, 2017
In the matter of RM-11785,

Amendment of Parts 2 and 97 of the Commission’s Rules Regarding Implementation of the Final Acts of the World Radiocommunication Conference (Geneva, 2015) To Allocate the Band 5351.5 - 5366.5 kHz to the Amateur Radio Service

While I strongly support the addition of more spectrum to the 60 Meter Amateur allocation, I strongly disagree with the ARRL's positions on the implementation of the new allocation, specifically:

1) The new allocation of 5351.5 - 5366.5 kHz should NOT allow the use of variable frequency operation, it should instead be channelized the same as the rest of the 60 Meter band. This 15 kHz band will neatly fit five 3 kHz channels, and help maintain order in this spectrum that is found lacking in all the other HF amateur bands. Five voice conversations are about the limit to the number that can be accommodated in 15 kHz of spectrum. Trying to cram more than that into 15 kHz is only going to cause interference to other users.
Variable frequency operation allows overlapping transmissions, and could cause interference to Federal Primary users, who could be transmitting off-frequency from where an amateur stations is receiving. In this case, the amateur station might not recognize that a Primary station is trying to transmit, as they wouldn't hear it clearly. Requiring channelized operation lets all users know where transmissions must occur, and will avoid the chaos we so often see in the amateur HF spectrum.

2) The use of CW should NOT be allowed anywhere in the 60 Meter band. CW is obsolete, and has NOT been used for primary communications in other radio services for years. Contrary to claims by its acolytes, CW is not the best mode for emergencies in degraded band conditions.
Many digital modes are faster, more accurate, and can be used where the received signal is so far below the noise and interference it cannot be heard by a human operator. In the modern era of today, much emergency management information is collected and exchanged in electronic formats, for example spreadsheet files.
As far as I know, there have been no cases where a CW operator was able to attach a fully formatted spreadsheet file to their CW transmission. Additionally, allowing the use of multiple, closely spaced CW signals will make it very difficult for a Federal Primary user to quickly clear the channel, compared to basically single conversations in the channelized spectrum. This effect will be especially pronounced if CW operators are using very narrow CW bandwidth filters to receive.
If the Commission feels it must continue to allow CW operation in this band, especially multiple CW signals in a 3 kHz slot, then it should be restricted to a single 3 kHz channel or slot.

3) The use of digital modes on 60 Meters is good, and will enhance emergency communications. However, instead of specifying modes, the Commission should consider specifying a maximum occupied bandwidth, and any commonly-available, unencrypted mode which fits within that bandwidth may be used. As an example, the Commission might specify a 2 kHz maximum occupied bandwidth, centered in the middle of a 3 kHz channel, thus allowing 0.5 kHz of guard band on either side, and include a requirement limiting the maximum amount of time a digital station may continuously transmit before listening for other stations.
As digital modes improve over time, their greater spectral efficiency and throughput will enhance emergency communications, especially in degraded band conditions.

4) The Commission should follow the WRC-15 recommendation, and stay with a 15W ERP power limit. Since Amateur use of the new allocation is ostensibly for emergency communications, the new spectrum could be intended for mostly mobile and portable use, where inefficient and lossy antennas are the norm. In most cases, a 50W transmit power would easily become a 15W, or lower, ERP. Additionally, with the use of newer, and more efficient digital modes, weak signals are not an impediment to sending information (see point 3, above).
In fact, the power increase from 50W to 100W ERP was unnecessary, and if the Commission saw fit to set the ERP limit back to 50W in the “old” part of the 60 Meter band, this would cause little to no harm.

In closing, I thank the Commission for the opportunity to comment on this rulemaking, and hope the Commission chooses the best alternatives. I especially hope the Commission retains the unique operating advantages of channelization of the entire 60 Meter band. The addition of new spectrum in the 60 Meter band is a great opportunity, and I thank the Commission for acting on this matter.

Sincerely,
Bill Springer AB9TA
 
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