If ARRL does not take care of this, I will never give them another dime. On Thu, Aug 3, 2023 at 3:27 PM JP Pritchard via BVARC <bvarc@bvarc.org> wrote:
> > > > 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 > > ________________________________________________ > Brazos Valley Amateur Radio Club > > BVARC mailing list > BVARC@bvarc.org > http://mail.bvarc.org/mailman/listinfo/bvarc_bvarc.org > Publicly available archives are available here: > https://www.mail-archive.com/bvarc@bvarc.org/ >
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