Regulatory & Advocacy

From ARRL News:

08/02/2023 – ARRL  The National Association for Amateur Radio®, as part of its mission to protect Amateur Radio, has filed comments against a proposal that would introduce high-power digital communications to the shortwave spectrum that in many instances is immediately adjacent to the Amateur HF bands.

The “Shortwave Modernization Coalition” (SMC), which represents certain high-frequency stock trading interests, filed the petition with the Federal Communications Commission (FCC). (Previous coverage can be found on ARRL News.) ARRL responded on behalf of its members and the 760,000 licensees of the Amateur Radio Service in the US.

The ARRL Laboratory performed a detailed technical analysis over several months to determine if the proposed rules would affect operations on the bands allocated to Radio Amateurs that are inter-mixed with the Part 90 bands in the spectrum in question.

ARRL’s analysis determined that, if the proposed rules are adopted, the new operations inevitably will cause significant harmful interference to many users of adjacent and nearby spectrum, including Amateur Radio licensees. Ed Hare, W1RFI, a 37-year veteran of the ARRL Lab and internationally recognized expert on radio frequency interference, was the principal investigator on the study. Hare concluded the petition should not be granted. “This petition seeks to put 50 kHz wide, 20,000-watt signals immediately next to seven different amateur bands with weaker protections against interference than required in other services,” said Hare.

In its formal opposition, ARRL stated, “That destructive interference would result if operations commenced using anything close to the proposed maximum levels.”

ARRL’s filed comments highlight flawed analysis and incomplete data submitted by the petitioners. It noted the petitioners “…significantly understate the harmful interference that is not just likely, but certain, if the rules proposed by SMC are adopted as proposed. It is noteworthy that SMC’s proposed rules would provide less protection than the much-lower power amateur radio transmitters are required to provide Part 90 receivers.” ARRL’s opposition also noted that there was no reported tests conducted with Amateur or other affected stations, but referenced a spectrum capture in the Comments filed with the Dayton Group that showed actual interference into the Amateur 20-meter band from one of the High Frequency Trading experimental stations.

Part 90 HF rules currently authorize a maximum signal bandwidth equal to a voice communications channel, at up to 1000 W peak envelope power (PEP). The petition seeks multiplication of signal width, greater transmitted power, and weaker rules that protect users of adjacent spectrum. ARRL’s comments expose the likely fallout:

“Incredibly, notwithstanding the significant increase in potential interference that would result from using digital schemes with 50 kHz bandwidths and 20,000 watts of power, SMC also proposes to substantially lessen the protections required to protect adjacent and neighboring licensees. SMC proposes [out-of-band emissions] limits that offer less protection than the existing Part 90 limits and would actually permit no attenuation (0 dB) at the edge of adjacent allocations, many of which are bands allocated to and heavily used in the Amateur Radio Service. Consistent with lessening protections while increasing the potential for harmful interference, SMC also proposes a lower limit for spurious emissions. SMC would reduce the existing protection of -73 dB for the applicable 1000-watt power limit to just -50 dB protection for their proposed 20,000-watt limit. Due to the much wider 50 kHz proposed bandwidth, the resulting interference would penetrate deep into the adjacent Amateur bands.”

The proposal has been assigned FCC Docket No. RM-11953. While the period for commenting on the petition has now closed, replies to comments in the record may now be submitted.

Hundreds of licensed Radio Amateurs filed comments in the Docket, expressing overwhelming opposition to the proposal. Those interested may read ARRL’s full comments and the results of the technical analysis, which are included in the filing. “If granted as written, this would be devastating to Amateur operation for many tens of kHz into our bands,” said Hare.

ARRL will continue to advocate for its members and the Amateur Radio Service in this proceeding.

From ARRL News, 07/11/2023:

The ad hoc group “Shortwave Modernization Coalition” petitioned the Federal Communications Commission (FCC) to allow data communications on multiple bands within the HF 2 – 25 MHz range with up to 20 KW, including in bands immediately adjacent to spectrum allocated to the Amateur Radio Service. This group appears to represent high-speed stock trading interests. The FCC has assigned it RM-11953. Comments are due by July 31, 2023, and reply comments by August 15. While the petitioners exclude the amateur bands, high power operations on immediately adjacent bands are proposed. ARRL  The National Association for Amateur Radio® is reviewing the petition. A copy of the petition is at: https://www.fcc.gov/ecfs/document/1042840187330/1 (PDF).

Paul N Gayet, AA1SU, writes on the Vermont ARRL Members list:

Executive Department
A Proclamation

WHEREAS, amateur radio operators are celebrating over a century of  broadcasting the human voice over the airwaves; and

WHEREAS, amateur radio has continued to build bridges between people, societies, and countries through the sharing of ideas and creation of friendship; and

WHEREAS, amateur radio operators have provided countless hours of community service to other local organizations; and

WHEREAS, the state also recognizes the services amateur radio operators provide to our many emergency response organizations, including local and state government; and

WHEREAS, these amateur radio services are provided as a voluntary
service to the public; and

WHEREAS, these same individuals have further demonstrated their value in public assistance by providing free radio communications for local parades, bike-a-thons, walk-a-thons, fairs, and other charitable public events.

NOW, THEREFORE, I, Philip B. Scott, Governor, hereby proclaim June 18-24, 2023 as AMATEUR RADIO WEEK in Vermont.

Given under my hand and the Great Seal of the State of Vermont on this 19th day of June, A.D. 2023.

______________________
Philip B. Scott
Governor

__________________________
Brittney L. Wilson
Secretary of Civil and Military Affairs

——————————————————————–
ARRL Vermont Section
Section Manager: Paul N Gayet, AA1SU
aa1su@arrl.org
——————————————————————–

QST de W1AW
ARRL Bulletin 11 ARLB011
From ARRL Headquarters
Newington CT June 14, 2023
To all radio amateurs

SB QST ARL ARLB011
ARLB011 Legislation to Remove Private Land Use Restrictions on Amateur Radio Introduced in Congress

Congressmen Bill Johnson (OH-06) and Joe Courtney (CT-02) reintroduced a bill in the US House of Representatives on June 12 – H.R.4006 – to remove private land use restrictions that prohibit, restrict, or impair the ability of Amateur Radio operators from operating and installing reasonable antennas on property that they own or control. Similar legislation, H.R. 9670, was introduced by Congressman Johnson in 2022.

The full text of the bill can be found in PDF format at, https://billjohnson.house.gov/uploadedfiles/amateur_radio_emergency_preparedness_act_signed_bill_text.pdf

“I reintroduced the Amateur Radio Emergency Preparedness Act to remove barriers to disaster and emergency communications and training, and to promote education in STEM subjects related to critically needed wireless technology,” Congressman Johnson said in a release. “Passage of this bill will promote developing and sustaining our nation’s wireless future and facilitate and encourage amateur radio operations as a public benefit.”

“As their actions during recent natural disasters such as Hurricane Sandy proved, amateur radio operators in Connecticut can be a critical component of disaster response and emergency management. It is in our communities’ best interest that we give them the capabilities to operate at the highest level, and with the re-introduction of this bill, we’ve taken a strong step in that direction,” said Congressman Courtney.

The exponential growth of communities bound by private land use restrictions that prohibit both the operation of Amateur Radio and the installation of amateur station antennas has significantly restricted the growth of the Amateur Radio Service.

The ARRL continues its multi-year efforts to eliminate private land use restrictions that prevent Amateur Radio operations and has pledged to strongly support Congressman Johnson and Congressman Courtney in their efforts on behalf of Amateur Radio.

Rick Roderick, K5UR, President of ARRL, on behalf its Members and America’s Amateur Radio community extended his thanks and appreciation for the leadership of Congressman Johnson and Congressman Courtney in their tireless efforts to support and protect the rights of all Amateur Radio Operators and to further STEM education and the advancement of American expertise in wireless technology.

QST de W1AW 
ARRL Bulletin 26  ARLB026
From ARRL Headquarters 
Newington CT  December 24, 2022
To all radio amateurs

SB QST ARL ARLB026
ARLB026 Rep. Bill Johnson Introduces Bill to Eliminate Private Land Use Restrictions on Amateur Radio

Congressman Bill Johnson (OH-6) introduced a bill in the U.S. House of Representatives (H.R.9670) on Thursday, December 22, 2022, to eliminate private land use restrictions that prohibit, restrict, or impair the ability of an Amateur Radio Operator from operating and installing amateur station antennas on property subject to the control of the Amateur Radio Operator.

The exponential growth of communities subject to private land use restrictions that prohibit both the operation of Amateur Radio and the installation of amateur station antennas has significantly restricted the growth of the Amateur Radio Service. These restrictions are pervasive in private common interest residential communities such as single-family subdivisions, condominiums, cooperatives, gated communities, master-planned communities, planned unit developments, and communities governed by community associations. The restrictions have particularly impacted the ability of Amateur Radio to fulfill its statutorily mandated duty of serving as a voluntary noncommercial emergency communications service.

Congress in 1996 directed the Federal Communications Commission (FCC) to promulgate regulations (Public Law 104-104, title II, section 207, 110 Stat. 114; 47 U.S.C. 303 note) that have preempted all private land use restrictions applicable to exterior communications facilities that impair the ability of citizens to receive television broadcast signals, direct broadcast satellite services, or multichannel multipoint distribution services, or to transmit and receive wireless internet services. ARRL attempts to obtain similar relief for Amateur Radio were rejected by the FCC with a statement such relief would have to come from Congress.

ARRL Legislative Advocacy Committee Chairman John Robert Stratton, N5AUS, noted that Congress, in 1994 by Joint Resolution, S.J.Res.90/H.J.Res.199, declared that regulations at all levels of government should facilitate and encourage the effective operation of Amateur Radio from residences as a public benefit. He continued by stating that “H.R.9670, the Amateur Radio Emergency Preparedness Act, is intended to fulfill that mandate and preserve the ability of Amateur Radio Operators to continue to serve as a key component of American critical communications infrastructure.”

ARRL President Rick Roderick, K5UR, and Mr. Stratton both extended on behalf of the ARRL, its Members, and the Amateur Radio community their thanks and appreciation for the leadership of Rep. Johnson in his tireless efforts to support and protect the rights of all Amateur Radio Operators.

The full text of the bill in PDF format is available online at, https://www.arrl.org/files/file/HR9670/HR9670-Amateur-Radio-Emergency-Preparedness-Act.pdf

From ARRL News:

(Updated 5/9/2022) – The ARRL Volunteer Examiner Coordinator (VEC) reports that the FCC Universal Licensing System (ULS) electronic batch filing (EBF) system is back online and functioning normally. A message sent by the FCC ULS EBF Team to VECs explains that the technical issues with ULS EBF filing are resolved, and that VECs may resume submitting files containing amateur radio license applications. ARRL VEC has submitted most of the backlog of its files for applications processed on, or after, April 27, and expects to have all of the backlog submitted by the end of the day (May 9).