Jim,
Last Friday evening after sending the email to ODV, I followed up with a slightly modified version to W5DX and requested that an article be published about the FCC deadlines and something on the issue itself. I have not heard back her.
W5OV, copied on the email, did respond to several questions that I directed his way in the same email.
Immediately below is what I suggested, which may be of help to you and other directors and for suggested language for hams to use.
73, Dave K3ZJ
Today the FCC published in the Federal Register Notice of the 60-meter Notice of Proposed Rulemaking adopted last April. This sets the comment deadline as October
30, and the reply comment deadline as Nov. 28.
Please use the April article to build a new story announcing these deadlines, provide the ARRL’s position as stated below, and state that those interested should submit comments to the
FCC with regard to maintaining the current 100-watt limit on this band and continued access to the 4 channels that otherwise will be deleted. The FCC’s Notice on the 60-meter matter is ET Docket No. 23-120 at paragraphs 37-53, link: https://tinyurl.com/43dyjekf.
BACKGROUND
The FCC proposed to adopt the 60 meter WRC-2015 allocation of 15 kHz of contiguous spectrum at 5351.5 – 5366.5 kHz on a secondary basis for
General and high-class amateur licensees. It requested comment on replacing the current 100-watt power limit with the accompanying WRC-2015 power limit of 15 watts EIRP (9.1-watt ERP) and on continued operation on
the current four channels outside the new contiguous spectrum.
ARRL has argued for adopting the currently-permitted 100-watt limit and for continued access to the 4 channels outside the narrow 15 kHz international allocation. Canada has adopted this
approach.
The federal government is the holder of primary spectrum rights in this band. NTIA, on behalf of federal user agencies, has opposed anything other than the 15 kHz segment for amateurs
with a 15-watt EIRP power limit.
ARRL will continue to advocate to maintain the 100-watt limit for 60 meters, continued authorization for the four channels outside the WRC allocation that are being used today, and adoption
of the new 15 kHz allocation with the same 100-watt power limit.
As always, email any questions.
David R. Siddall
Managing Partner
DS Law, PLLC
1629 K St. NW, Ste 300
Washington, DC 20006
direct: +1 202 559 4690
Unauthorized Disclosure Prohibited. This e-mail is intended solely for the intended
recipient(s) and may contain information that is proprietary, confidential or privileged. If you are not the intended recipient, it is prohibited to disclose, copy, distribute, or use the contents of this email and its attachments. If you received this e-mail
in error, please notify the sender by reply e-mail and destroy all electronic and physical copies of the e-mail message and its attachments. Unintended transmission shall not constitute waiver of attorney-client or any other privilege. Thank you.
From: "Boehner, James, N2ZZ (Dir, RK)" <n2zz@arrl.org>
Date: Monday, October 2, 2023 at 11:00 PM
To: "david@davidsiddall-law.com" <david@davidsiddall-law.com>, "arrl-odv@reflector.arrl.org" <arrl-odv@arrl.org>
Subject: Comment Deadlines Established for 60 Meter Allocation Changes
David,
Thank you for this information.
Per our member survey, our members value spectrum defense as their top value of ARRL membership.
Potentially, we could lose our five 100 watt channels on 60 meters and have them replaced with 15 kHz of 15 watt contiguous spectrum. Fortunately, the FCC did not propose this,
but we need to drive comments to the FCC from our members.
I have not seen this announced on the ARRL news crawl or on any member bulletins to date. Is there a plan to do so? As noted below, the comment period ends on October 30th.
Is there a possibility of someone at HQ putting together sample comments (to give our members) for submission to the FCC, particularly to demonstrate why granting us our proposed
allocations and power limits is in the public interest? I believe when we petitioned for what eventually became our current allocation, we referenced the propagation characteristics of 60 meters to be ideal in carrying out emergency communications to the Caribbean.
For this, 15 watts would be inadequate.
We could certainly do this Division by Division, but a unified voice would be appreciated.
‘73 de Jim N2ZZ
Director – Roanoke Division
Representing ARRL members in North Carolina, South Carolina, Virginia and West Virginia
ARRL – the national association for Amateur Radio
Facebook Page: ARRL Roanoke Division
Website:
www.arrl-roanoke.org
From: arrl-odv <arrl-odv-bounces@reflector.arrl.org>
On Behalf Of david davidsiddall-law.com
Sent: Friday, September 29, 2023 9:52 PM
To: arrl-odv@reflector.arrl.org <arrl-odv@arrl.org>
Subject: [arrl-odv:35226] Comment Deadlines Established for 60 Meter Allocation Changes
ODV,
Today the FCC published in the Federal Register Notice of the 60-meter Notice of Proposed Rulemaking adopted last April. This sets the comment deadline as October 30, and the reply comment deadline as Nov. 28. Please note these deadlines
wherever you can and ask your constituents to submit comments to the FCC supporting ARRL’s request for a 100-watt limit and continued access to the 4 channels that otherwise will be deleted. The FCC’s Notice on the 60-meter matter is ET Docket No. 23-120
at paragraphs 37-53, link: https://tinyurl.com/43dyjekf.
BACKGROUND
The FCC proposed to adopt the 60 meter WRC-2015 allocation of 15 kHz of contiguous spectrum at 5351.5 – 5366.5 kHz on a secondary basis for General and high-class amateur licensees. Notably, it did not propose to
replace the current 100-watt power limit with the accompanying WRC-2015 power limit of 15 watts EIRP (9.1-watt ERP), nor did it propose cessation of operation on the currently used four channels outside the WRC-2015 allocation and that were rejected
at the Conference. Instead, the Commission described these two issues and requested comment thereon.
In the same Notice the FCC also proposed to update the existing notice requirements for amateurs in geographic areas where amateur operations in the 420-450 MHz band generally are limited to 50 watts.
ARRL has argued for adoption of the current 100-watt limit and for continued access to the 4 channels outside the narrow 15 kHz International allocation in addition to the contiguous 15 kHz. Importantly, Canada
adopted this approach notwithstanding the WRC allocation and its limitations.
The federal government is the holder of primary spectrum rights in this band. NTIA, on behalf of federal user agencies, has opposed any variation from the agreed-upon WRC-2015 result. It supports only the 15 kHz segment for amateurs
with a 15-watt EIRP power limit, noting among other things that although at WRC-2015 some countries obtained slightly higher powers or other concessions with treaty footnotes, the U.S. did not.
ARRL will continue to advocate to maintain the 100-watt limit for 60 meters, continued authorization for the four channels outside the WRC allocation that are being used today, and adoption of the new 15 kHz allocation
with the same 100-watt power limit.
As always, email any questions.
73, Dave K3ZJ
David R. Siddall
Managing Partner
DS Law, PLLC
1629 K St. NW, Ste 300
Washington, DC 20006
direct: +1 202 559 4690
Unauthorized Disclosure Prohibited. This e-mail is intended solely for the intended
recipient(s) and may contain information that is proprietary, confidential or privileged. If you are not the intended recipient, it is prohibited to disclose, copy, distribute, or use the contents of this email and its attachments. If you received this e-mail
in error, please notify the sender by reply e-mail and destroy all electronic and physical copies of the e-mail message and its attachments. Unintended transmission shall not constitute waiver of attorney-client or any other privilege. Thank you.