Thank you, Dave, that's exactly the guidance what I was looking for. On a side note, I found the ACDS "Joint Proposal" pretty humorous when I read it in your July report to the Board. They would take most of 40 meters for ACDS, but give back some of the 15 meter and 10 meter allocations in exchange. How nice of them! ;-) 73; Mike W7VO
On September 13, 2019 at 4:59 AM k5ur@aol.com wrote:
> > It has been three years to get this far, so I would be reluctant to try to remove or delay
>
I agree.
Thanks for summary and input, Dave.
73 Rick - K5UR
-----Original Message----- From: david davidsiddall-law. com <david@davidsiddall-law.com> To: Michael Ritz <w7vo@comcast.net>; arrl-odv@reflector.arrl.org <arrl-odv@reflector.arrl.org> Sent: Thu, Sep 12, 2019 11:18 pm Subject: [arrl-odv:28758] Re: RM-11759
Hi Mike,
I am copying my reply to everyone inasmuch as proposals pending at the FCC may be of more general interest.
Four pending proposals come to mind that would affect the spectrum bands. Two are contained in Petitions for Rulemaking filed by the League. The third was filed in July after conclusion of the “digital discussions” and directly addresses changes to ACDS bands. (Note that the filed proposal is NOT identical to that on which compromise was reached between the proponents and ARSFI in the discussions, a copy of which is attached to my July Board report.)
Here are links to the relevant spectrum proposals; from the links you can also view the comments thereon filed with the FCC, but there are hundreds so to do more than a sampling is a pretty big task.
80/75 Meter Band changes: ARRL Petition RM-11759 - summary of substantive proposals is on p.2. Link: https://ecfsapi.fcc.gov/file/60001402689.pdf (640 comments as of today). Would make the following six changes: 1. Enlarge RTTY/data band from 3.500 – 3.600 to 3.500 – 3.650 2. Shrink Phone/image band from 3.600 – 4.000 to 3.650 – 4.000 3. Add General and Advanced privileges to 3.600 – 3.650 4. Add Novice & Technician privileges (including CW, RTTY and data) to 3.600 – 3.650. NOTE: RM-11828, below, would add to current CW privileges for Technician (only) RTTY/data privileges to 3.525 – 3.600. 5. Move ACDS 80-meter subband from 3.585-3.600 to 3.600 – 3.615 6. Add RTTY/data privileges to current CW privileges for Novice and Technician privileges from 21.025 – 21.200
Technician Class Operating Privileges: RM-11828 – note: substantive part of the actual proposal is near the end, at pp. 21 – 22. Link: https://ecfsapi.fcc.gov/file/1022823795806/2018 Entry Level License PRM FINAL.pdf https://ecfsapi.fcc.gov/file/1022823795806/2018%20Entry%20Level%20License%20... (1,240 comments as of today). Would add digital privileges to current CW privileges at 3.525-3.600, 7.025-7.125, and 21.025-21.200. (Also proposes to add phone privileges at 3.900-4.000, 7.225-7.300, and 21.350-21.450.)
ACDS Joint Proposal to FCC from W5DNT, AB2RA, K0IDT & W6EM, submitted in multiple dockets but most pertinent to RM-11831 (below), would adjust ACDS bands: https://ecfsapi.fcc.gov/file/10719236004064/FINAL July 18 FCC HF Digital Proposal.pdf https://ecfsapi.fcc.gov/file/10719236004064/FINAL%20July%2018%20FCC%20HF%20D...
K0IDT (Kolarik) Petition would delete 97.221(c), Result is to move all ACDS stations into the ACDS bands, whereas now only ACDS stations with > 500 Hz bandwidth are required to operate within those bands.
Consistency with the IARU band plans always help, of course, but this is not possible for U.S. in 80 meters unless/until FCC extends RTTY/data band up to 3.650, as requested in RM-11759, above. Link to Region 2 band plan: https://www.iaru-r2.org/documents/explorer/files/Plan de bandas | Band-plan/R2 Band Plan 2016.pdf https://www.iaru-r2.org/documents/explorer/files/Plan%20de%20bandas%20%7C%20...
(I also note that IARU band plans separate ACDS subbands into two: one for <500 Hz and the other for <2.7 kHz.)
With regard to your primary question to me – how to account for pending petitions, if I understand it correctly – all of the above petitions and related filings are on the table to be included in an omnibus FCC Notice of Proposed Rulemaking that is expected late this fall. It has been three years to get this far, so I would be reluctant to try to remove or delay – there are other candidates for inclusion as well, such as the amplifier input issue so that QRP transceivers can fully drive today’s SS amps; and any of the issues in the ARRL Board’s July Resolution except for the 300 baud symbol rate issue, which is on a faster track.
Given the situation, I recommend coming up with the Committee’s proposals and submit them either when ready, or if the FCC proceeds as expected and issues an omnibus NPRM, then we need to submit them as comments (assuming that they have taken up the issue) or as a new petition (if they did not take up the issue in an NPRM). If they take up the issue as expected, comments likely would be due early next year, hopefully after the January Board meeting. So this is what I would shoot for. (But timing is impossible to predict, this is a guess.). Does this sound doable?
73, Dave
From: arrl-odv <arrl-odv-bounces@reflector.arrl.org> on behalf of Michael Ritz <w7vo@comcast.net> Reply-To: Michael Ritz <w7vo@comcast.net> Date: Thursday, September 12, 2019 at 1:29 PM To: "arrl-odv@reflector.arrl.org" <arrl-odv@reflector.arrl.org> Subject: [arrl-odv:28755] RM-11759
This note is mostly for members of the EC, but I'm copying all of ODV. Most of you have been here MUCH longer than I have, and may have history on this.
The new HF Digital band planning committee is getting busy, and will have our second teleconference next week. While rummaging around the internet a couple of days ago I ran into RM-11759, a proposal sent to the FCC about three years ago, and like many others seems to have gotten stuck in the quagmire that IS the FCC. Counsel Siddall's report to the board for July simply stated that it was indeed there, with no action. This particular RM sought to jigger around some of the 75/80 meter band, and will have an impact on what the band planning committee is doing with that band. Maybe the final recommendation will stay the same as outlined in the RM, but maybe it will be different as the digital world has changed in the last three years. I don't know, and the committee is VERY far away from any recommendations.
At the advice of our FCC Counsel, the EC needs to decide what to do with this particular RM, including the possibility of putting it on hold, or deciding to maybe later modify it by adding the other proposed changes for the other bands, or create a new RM for all the other bands other than 75/80 meters and let this one either be modified, or left as-is. Maybe it needs to be withdrawn and later replaced with another new proposal that encompasses all the proposed band changes. There's a lot to think about here.
In case you are not familiar, or have forgotten, I have attached RM-11759 for everyone's review.
73; Mike W7VO _______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org mailto:arrl-odv@reflector.arrl.org https://reflector.arrl.org/mailman/listinfo/arrl-odv