Hi Rod, NTIA did not cite any specific case of interference in response to that argument being made by ARRL in its petition. Nor did they cite any specific interference case when I discussed with them a couple of years after the petition was filed. Dave From: "w6rod@comcast.net" <w6rod@comcast.net> Date: Sunday, April 2, 2023 at 1:07 PM To: "david@davidsiddall-law.com" <david@davidsiddall-law.com>, arrl-odv <arrl-odv-bounces@reflector.arrl.org> Cc: Jon Siverling <siverling@mindspring.com> Subject: Re: 60-Meter Notice Before FCC on April 20 David, Since the amateurs have had access to the “expanded” (expanded from the WRC outcome) use, have there been any issues of interference or problems brought forward by NTIA? Rod From: arrl-odv <arrl-odv-bounces@reflector.arrl.org> on behalf of david davidsiddall-law.com <david@davidsiddall-law.com> Date: Sunday, April 2, 2023 at 6:27 AM To: arrl-odv <arrl-odv-bounces@reflector.arrl.org> Cc: Jon Siverling <siverling@mindspring.com> Subject: [arrl-odv:34711] 60-Meter Notice Before FCC on April 20 ODV, On April 20 the FCC will take up unfinished items from the WRC-2015 and WRC-2019 treaties. WRC-2023 is later this year, so I guess the FCC has discovered these unfinished items from the last two WRCs. The FCC releases drafts of its items three weeks before the public meeting at which they will be considered by the Commissioners. In this case the item the item of concern to us is a Notice of Proposed Rulemaking (NPRM) in which they put forward their proposals and issues open for consideration and will accept public comment before final decisions. The amateur 60-meter allocation will be considered in this proceeding. The 60-meter issue is difficult and I expect that it will be of some note and discussion in the amateur community generally. I regularly get questions about 60-meter operation. At WRC-2015 amateur radio did not succeed in getting the result it desired. A 15-kHz sliver was allocated that excluded 4 of the 5 channels that have been permitted as a temporary measure, and the power limit for amateurs was set at 15 watts EIRP (equivalent to 9.1 watts ERP). It’s an uphill battle because “almost” always the FCC simply implements WRC provisions such as these. In 2017 ARRL petitioned the FCC to implement the 60-meter WRC allocation with changes. We have since lobbied the FCC on 60-meter WRC implementation and, for reference, I included reports on this in my written semi-annual reports to the Board. We have advocated for continuing the current 100 watts limit throughout the band and for continued access to the 4 channels outside the International allocation in addition to the 15 kHz new allocation (which encompasses one of the current channels). Canada adopted this approach, which has been and will continue to be a big help to our efforts. The federal government is the holder of primary spectrum rights in this band. NTIA, on behalf of federal user agencies, adamantly opposed ARRL’s requests for greater 60-meter rights in the run-up to WRC-2015 and continues to oppose any variation from the agreed-upon WRC-2015 result. The outcome at WRC-2015 was to allocate only a 15 kHz segment for amateurs with the 15 watts EIRP power limit. (Some countries obtained slightly higher powers or other concessions “by footnote” but not the U.S., principally due to NTIA opposition.) NOTICE * In response to the ARRL’s petition, NTIA opposed anything other than the WRC-2015 allocation. In this Notice the FCC proposes to make the 15-kHz allocation (an expansion of one of the current channels) for general and high-class amateur licensees, but importantly does not propose a power limit or cessation of operations on the other 4 channels. Instead, the Commission describes the issues and requests comment thereon. This signals that at this time the FCC has not decided to accede to NTIA’s position. This is a positive position for us, since they did not propose to adopt the NTIA’s position on these issues but instead took a more neutral stance notwithstanding the Treaty provisions. There have been multiple conversations between the two agencies that have left this issue unresolved, and undoubtedly these will re-commence after the comment period on this Notice. * There is an additional minor tweak proposed in the NPRM, the purpose of which is 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. A copy of the FCC document may be viewed at FCC NPRM 60-Meter Allocation<https://tinyurl.com/mr24kmdr>. I will be happy to respond to any questions. I plan to file comments consistent with our earlier petitions when the time comes, subject to any changes you may suggest. The deadline for comments is likely to be in June or early July. 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. 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