AG19
QST de W1AW  
ARRL Bulletin 19  ARLB019
>From ARRL Headquarters  
Newington CT  October 1, 2014
To all radio amateurs 

SB QST ARL ARLB019
ARLB019 ARRL Takes Issue with NTIA's WRC-15 Proposal for 5 MHz

The ARRL is taking issue with the World Radiocommunication
Conference 2015 (WRC-15) stance of the National Telecommunications
and Information Administration (NTIA) with respect to an upgraded 60
meter Amateur Radio allocation. In response to WRC-15 agenda item
1.4, the NTIA has called for no change at 5250-5450 kHz. The League
said in comments filed September 24 in IB Docket 04-286 that while
it concurs with the NTIA's view regarding 5250 to 5275 kHz -
allocated to the radiolocation service for oceanographic
applications at WRC-12 - the rest of the agency's proposal is
'unsupportable in light of actual domestic and international
practice and contains assertions of incompatibility that are
demonstrably not correct.' The US has authorized Amateur Radio
secondary operation on five discrete channels in the 5275-5450 kHz
range for more than a decade, the ARRL pointed out, with no
instances of unresolved interference to primary users.

'Against this backdrop, the stated reason for the no-change proposal
- that '[e]xperience has shown that sharing is not possible between
the Amateur Service and the fixed and mobile service' - fails the
straight-face test,' the ARRL said in its comments.

The NTIA's position is at odds with the proposal for agenda item 1.4
previously adopted by the FCC's WRC-15 Advisory Committee (WAC). In
January, the WAC recommended a secondary allocation to the Amateur
Radio Service from 5275-5450 kHz, and the FCC indicated in a
subsequent Public Notice that it could generally support this
recommendation.

The League called the NTIA's position 'particularly puzzling' given
the position of federal agencies, for which the NTIA manages
spectrum, to allow what the ARRL called, 'a more disruptive service
(radiolocation) in the identical frequency range under consideration
here less than three years ago.'

'Neither NTIA nor its constituent federal agencies have credibly or
persuasively articulated why fixed and mobile systems in the
5250-5450 kHz range can withstand the demonstrated potential for
interference from automated, wideband, HF oceanographic radars, but
cannot withstand operation by trained, licensed operators using
smaller bandwidths, actually monitoring the spectrum to be used
before and during a transmission, and with the capability to shift
frequency immediately to avoid incidents of interference with a
primary service,' the ARRL commented.

The League asserted that the Amateur Service deserves 'the same
treatment' that NTIA proposed for HF radiolocation less than 3 years
ago. 'Proponents of a different treatment, particularly a
channelized treatment or a no-change approach, have still not
presented a compelling distinction between amateur operation and
radiolocation that would justify a departure from the general policy
followed by the United States at WRC-12,' the ARRL concluded.