Thanks, Kermit. There is a lot of work to be done in crafting a response to the NPRM, but this is a big step in the right direction. Dave From: Carlson, Kermit, W9XA Sent: Tuesday, April 28, 2015 1:31 PM To: Sumner, Dave, K1ZZ; arrl-odv Subject: Re: [arrl-odv:24231] FCC acts on LF, MF allocations Hello Dave - Thank you for the good news - In many respects this is far more positive than I had ever hoped. The Commission's 135.7-137.8 proposal, as limited as it is presents an outcome that I had not expected, and it IS extremely welcome. Now - onto the next hurdle (.....and a more careful re-read of FCC 15-50). Cheers ! 73 - Kermit W9XA ________________________________ From: "Sumner, Dave, K1ZZ" <dsumner@arrl.org<mailto:dsumner@arrl.org>> To: arrl-odv <arrl-odv@arrl.org<mailto:arrl-odv@arrl.org>> Sent: Tuesday, April 28, 2015 10:42 AM Subject: [arrl-odv:24231] FCC acts on LF, MF allocations The FCC has released a 257-page Report and Order, Order, and Notice of Proposed Rulemaking (attached) dealing with, among other things, the domestic implementation of the international secondary allocations to the Amateur Service of 135.7-137.8 kHz and 472-479 kHz and the upgrading of the Amateur Service to Primary at 1900-2000 kHz. Overall, the Commission’s actions are somewhat more favorable than we had feared. The proceeding is a bit complicated so I will try to sort it out. The 135.7-137.8 kHz international allocation was made at WRC-07. Some electric utilities, directly and through the industry association UTC, have long (and until now, successfully) objected to any amateur allocation below the AM broadcast band. In this proceeding the FCC has decided to make the allocation to the Amateur Service, which is a big step forward. However, no service (Part 97) rules were adopted and amateur operation will not be permitted until they are. The Commission also has adopted its own proposal to upgrade the Amateur Service allocation at 1900-2000 kHz from secondary to primary, a very positive step. At the same time, though, the Commission decided to regularize the operation of radio buoys by commercial fishing boats, which have been using them illegally for years. It may be confusing to some that the Commission has updated the international Table of Frequency Allocations contained in Part 2 of its Rules to reflect WRC-12 as well as WRC-07 decisions. This is a sensible step for them to take inasmuch as WRC-15 is little more than 6 months away, but it is the United States (right hand) portion of the Table that governs domestic allocations and operation by a Commission-regulated service is not authorized until service rules (referenced in the last right-hand column of the Table) are adopted and in force. In the NPRM portion of the proceeding the Commission proposes to allocate 472-479 kHz to the Amateur Service on a secondary basis, consistent with the international allocation made at WRC-12. Proposed Part 97 rules are also included that if adopted as proposed would authorize Extra, Advanced, and General licensees to use the 135.7-137.8 kHz and 472-479 kHz bands subject to certain limitations, but I do not see where any emission types other than CW and brief test emissions are proposed to be authorized; our comments will need to address that omission. The NPRM poses many questions to which we also will have to respond. The comment period is 60 days beginning with the publication of the summary in the Federal Register, with reply comments due 30 days after the comment deadline. This summary is the result of a quick reading of a very long document and so is subject to revision. If you spot anything that I have neglected to mention or that I got wrong, please holler. 73, Dave Sumner, K1ZZ _______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org<mailto:arrl-odv@reflector.arrl.org> https://reflector.arrl.org/mailman/listinfo/arrl-odv