> > SB QST @ ARL $ARLB017 > ARLB017 ARRL Files Comments Against "Seriously Flawed" HF Rules > Petition > > ZCZC AG17 > QST de W1AW > ARRL Bulletin 17 ARLB017 > From ARRL Headquarters > Newington CT August 3, 2023 > To all radio amateurs > > SB QST ARL ARLB017 > ARLB017 ARRL Files Comments Against "Seriously Flawed" HF Rules > Petition > > ARRL, as part of its mission to protect Amateur Radio, has filed > comments against a proposal that would introduce high-power digital > communications to the shortwave spectrum that in many instances is > immediately adjacent to the Amateur HF bands. > > The "Shortwave Modernization Coalition" (SMC), which represents > certain high-frequency stock trading interests, filed the petition > with the Federal Communications Commission (FCC). ARRL responded on > behalf of its members and the 760,000 licensees of the Amateur Radio > Service in the US. > > The petition can be found online at, > https://www.fcc.gov/ecfs/document/1042840187330/1 . > > The ARRL Laboratory performed a detailed technical analysis over > several months to determine if the proposed rules would affect > operations on the bands allocated to Radio Amateurs that are > inter-mixed with the Part 90 bands in the spectrum in question. > > ARRL's analysis determined that, if the proposed rules are adopted, > the new operations inevitably will cause significant harmful > interference to many users of adjacent and nearby spectrum, > including Amateur Radio licensees. Ed Hare, W1RFI, a 37-year veteran > of the ARRL Lab and internationally recognized expert on radio > frequency interference, was the principal investigator on the study. > Hare concluded the petition should not be granted. "This petition > seeks to put 50 kHz wide, 20,000-watt signals immediately next to > seven different amateur bands with weaker protections against > interference than required in other services," said Hare. > > In its formal opposition, ARRL stated, "That destructive > interference would result if operations commenced using anything > close to the proposed maximum levels." > > ARRL's filed comments highlight flawed analysis and incomplete data > submitted by the petitioners. It noted the petitioners > "...significantly understate the harmful interference that is not > just likely, but certain, if the rules proposed by SMC are adopted > as proposed. It is noteworthy that SMC's proposed rules would > provide less protection than the much-lower power amateur radio > transmitters are required to provide Part 90 receivers." ARRL's > opposition also noted that there was no reported tests conducted > with Amateur or other affected stations, but referenced a spectrum > capture in the Comments filed with the Dayton Group that showed > actual interference into the Amateur 20-meter band from one of the > High Frequency Trading experimental stations. > > Part 90 HF rules currently authorize a maximum signal bandwidth > equal to a voice communications channel, at up to 1000 W peak > envelope power (PEP). The petition seeks multiplication of signal > width, greater transmitted power, and weaker rules that protect > users of adjacent spectrum. ARRL's comments expose the likely > fallout: > > "Incredibly, notwithstanding the significant increase in potential > interference that would result from using digital schemes with 50 > kHz bandwidths and 20,000 watts of power, SMC also proposes to > substantially lessen the protections required to protect adjacent > and neighboring licensees. SMC proposes [out-of-band emissions] > limits that offer less protection than the existing Part 90 limits > and would actually permit no attenuation (0 dB) at the edge of > adjacent allocations, many of which are bands allocated to and > heavily used in the Amateur Radio Service. Consistent with lessening > protections while increasing the potential for harmful interference, > SMC also proposes a lower limit for spurious emissions. SMC would > reduce the existing protection of -73 dB for the applicable > 1000-watt power limit to just -50 dB protection for their proposed > 20,000-watt limit. Due to the much wider 50 kHz proposed bandwidth, > the resulting interference would penetrate deep into the adjacent > Amateur bands." > > The proposal has been assigned FCC Docket No. RM-11953. While the > period for commenting on the petition has now closed, replies to > comments in the record may now be submitted. > > Hundreds of licensed Radio Amateurs filed comments in the Docket, > expressing overwhelming opposition to the proposal. Those interested > may read ARRL's full comments and the results of the technical > analysis, which are included in the filing. "If granted as written, > this would be devastating to Amateur operation for many tens of kHz > into our bands," said Hare. > > ARRL will continue to advocate for its members and the Amateur Radio > Service in this proceeding. > NNNN > /EX
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