AG07
QST de W1AW  
ARRL Bulletin 7  ARLB007
>From ARRL Headquarters  
Newington CT  February 23, 2016
To all radio amateurs 

SB QST ARL ARLB007
ARLB007 FCC Invites Comments on ARRL Petition That Seeks 80/75 Meter
Adjustments

The FCC has put the ARRL's January Petition for Rule Making (RM
11759 - found on the web at,
apps.fcc.gov/ecfs/comment/view?id=60001374190 ) 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:

* Modify the RTTY/data subband, so that it extends from 3500 kHz to
3650 kHz.

* Modify the phone/image subband, so that it extends from 3650 kHz
to 4000 kHz.

* Make 3600-3650 kHz available for General and Advanced Class
licensees, as was the case prior to 2006.

* 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.

* 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 R&O 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 Part 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.'