Regulatory & Advocacy

Recently, the FCC issued a Notice of Proposed Rulemaking (NPRM) which effects Amateur Radio use of the 60m band.  The FCC proposes to allocate 15 kHz of contiguous bandwidth between 5351.5 – 5366.5 kHz on a secondary basis with a maximum power of 15 W EIRP (equivalent to 9.15 W ERP). This allocation was adopted at the 2015 World Radiocommunication Conference (WRC-15).

The NPRM leaves open the question of whether the existing five 60m channels can still be used for Amateur Radio operation as well as if the 100w power level may still be used.

The FCC has requested comments relative to existing channel and power issue.

In 2017, the ARRL petitioned the FCC to keep the four 60-meter channels that fall outside the new band, as well as the current operating rules, including the 100 W ERP limit.

We need as many amateurs as possible to comment on this NPRM and urge the FCC to keep 1) the four existing channels and 2) the 100 w power limit.

Comments are due by October 30th, 2023 – ET Docket No. 23-120.

https://www.fcc.gov/ecfs/filings/express
https://www.fcc.gov/ecfs/filings/standard

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ARRL Bulletin 26  ARLB026
From ARRL Headquarters
Newington CT  October 11, 2023
To all radio amateurs

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ARLB026 ARRL Urges Comments to FCC on 60-Meter Band

The ARRL is asking that all radio amateurs urge the Federal Communications Commission (FCC) to continue the existing use of the 60-meter band. A public comment period is open until October 30, 2023. ARRL encourages expressions of support to the FCC for the current 100 W ERP power limit (instead of reducing the power limit to 15 W EIRP) and continuing secondary access to the current channels.

To submit a filing of your comments for the FCC’s consideration in the rulemaking process, go to the FCC web page for the Notice of Proposed Rulemaking’s (NPRM) Docket Number 23-120 at, https://www.fcc.gov/ecfs/search/docket-detail/23-120.

If you wish to directly enter your comments, select the button labeled SUBMIT AN EXPRESS FILING at, https://www.fcc.gov/ecfs/filings/express?proceeding5d=23-120 .

If you are uploading a document that contains your comments, select SUBMIT A STANDARD FILING at, https://www.fcc.gov/ecfs/filings/standard?proceeding5d=23-120 .

When submitting your comments, be sure the correct proceeding’s docket number, 23-120, is included on the form. Your name and comments will be entered into the official public record of the proceedings and will be viewable by anyone who visits the docket web page.

While radio amateurs are encouraged to include any comments they would like in their submissions, they’re especially encouraged to draw upon their personal experiences using the 60-meter band for public service purposes and for its location between the amateur 80- and 40-meter bands, which is critical to ensuring signal propagation to certain geographic areas during variations in time and the solar cycle.

Some of the main points to comment on for this NPRM are:

* Urging the FCC to keep the four existing channels allocated to amateur radio on a secondary basis.

* Urging the FCC to keep the 100 W power limit for the four existing channels and the new 15 kHz subband.

ARRL Public Relations and Outreach Manager Sierra Harrop, W5DX, underscored the importance of commenting, urging members to speak up. “ARRL members make up the strongest voice in matters of amateur radio spectrum defense,” said Harrop. “Your membership and participation in the rulemaking process both ensure ARRL continues to make the difference when our band privileges are threatened. Please join us in effort to protect our 60-meter band privileges.”
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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
——————————————————————–

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

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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.