[BVARC] Fwd: ARLB017 ARRL Files Comments Against "Seriously Flawed" HF Rules Petition

Paul Easter kc9jty at gmail.com
Thu Aug 3 21:04:17 CDT 2023


If ARRL does not take care of this, I will never give them another dime.

On Thu, Aug 3, 2023 at 3:27 PM JP Pritchard via BVARC <bvarc at bvarc.org>
wrote:

> >
> > SB QST @ ARL $ARLB017
> > ARLB017 ARRL Files Comments Against "Seriously Flawed" HF Rules
> > Petition
> >
> > ZCZC AG17
> > QST de W1AW
> > ARRL Bulletin 17  ARLB017
> > From ARRL Headquarters
> > Newington CT  August 3, 2023
> > To all radio amateurs
> >
> > SB QST ARL ARLB017
> > ARLB017 ARRL Files Comments Against "Seriously Flawed" HF Rules
> > Petition
> >
> > ARRL, 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). ARRL responded on
> > behalf of its members and the 760,000 licensees of the Amateur Radio
> > Service in the US.
> >
> > The petition can be found online at,
> > https://www.fcc.gov/ecfs/document/1042840187330/1  .
> >
> > 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.
> > NNNN
> > /EX
>
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