[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.
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<http://www.arrl-roanoke.org/> [Text, logo Description automatically generated] 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.
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<http://www.arrl-roanoke.org/> [Text, logo Description automatically generated] 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.
David and ODV, I put this together several months ago to help understand what's on the table. Carl K9LA [cid:4d6cc000-59b3-4d37-b0ac-d22e223d8b9c]
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 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: "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 [cid:4d6cc000-59b3-4d37-b0ac-d22e223d8b9c]
David, The corrected sketch is attached. Thanks for pointing that out. ERP, as the FCC states, is the PEP power delivered to the antenna times the gain of the antenna. ERP is relative to a half wave dipole. As an example, 100 W ERP is 25 W PEP at the antenna with an antenna with 6 dB gain (referenced to a half wave dipole, so it's 6 dBd - which is a power ratio of 4). Or it's 100 W PEP at the antenna with a halfwave dipole (gain is 0 dBd). I think footnote 96 tries to make sure that power at the antenna and antenna gain are the parameters used to determine if you meet the ERP limit. The ITU WRC-2015 allocation of 9.15 W PEP ERP would decrease your transmitted signal by about 10 dB - almost 2 S-units. Carl
participants (3)
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Boehner, James, N2ZZ (Dir, RK) -
david davidsiddall-law.com -
Luetzelschwab, Carl, K9LA (Dir, CD)