Carl,

Excellent, thanks.  This helps clarify what otherwise is gibberish.  One correction: This is not an “NTIA proposal”.  It is the “ITU WRC-2015 allocation”. NTIA, as the government spectrum regulator, supports the ITU WRC decision. ARRL is asking the FCC to implement the WRC-2015 decision with changes.

And for you or anyone else: would one of you more technical types explain what footnote 96 is getting at? Is it that PEP and ERP do not relate together, so ERP should be used without the “PEP” designation?  In the 60 meter NPRM (https://docs.fcc.gov/public/attachments/FCC-23-26A1.pdf) footnote 96 reads:

“Footnote US23 of the Allocations Table and section 97.313(i) of the Commission’s rules state that amateur service use of these frequencies is restricted to a maximum ERP of 100 watts “PEP” and that no station may transmit with an ERP exceeding 100 watts “PEP,” respectively. These requirements are inconsistent with the definitions in part 97 of the Commission’s rules, i.e., PEP is the average power supplied to the antenna transmission line by a transmitter during one RF cycle at the crest of the modulation envelope taken under normal operating conditions and ERP is the product of the power supplied to the antenna and its gain relative to a half-wave dipole in a given direction. 47 CFR § 97.3(b)(2)-(3), (9). Our review finds that these rules were intended to limit the radiated power to 100 watts ERP based on the 2006 agreement between NTIA and ARRL and, to minimize confusion we refer to this limit in our discussion….”

Thanks es 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

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From: "Luetzelschwab, Carl, K9LA (Dir, CD)" <K9LA@arrl.org>
Date: Tuesday, October 3, 2023 at 4:57 PM
To: "david@davidsiddall-law.com" <david@davidsiddall-law.com>, "arrl-odv@reflector.arrl.org" <arrl-odv@arrl.org>
Subject: Re: [arrl-odv:35236] Re: Comment Deadlines Established for 60 Meter Allocation Changes

David and ODV,

I put this together several months ago to help understand what's on the table.

Carl K9LA