SB QST @ ARL $ARLB028   
   ARLB028 ARRL Supports Maximum Flexibility for Amateur Use of New 2200 and 630   
   Meter Bands   
      
   ZCZC AG28   
   QST de W1AW   
   ARRL Bulletin 28  ARLB028   
   > From ARRL Headquarters   
   Newington CT  September 1, 2015   
   To all radio amateurs   
      
   SB QST ARL ARLB028   
   ARLB028 ARRL Supports Maximum Flexibility for Amateur Use of New 2200 and 630   
   Meter Bands   
      
   The ARRL has told the FCC that Amateur Radio operation in the new 135.7-137.8   
   kHz (2200 meters) and 472-479 kHz (630 meters) bands should be as unfettered   
   as possible from a regulatory standpoint. The League spelled out its case   
   August 31 in detailed comments that argue in favor of flexible FCC Part 97   
   regulations in light of the exceptionally low interference potential to   
   unlicensed power line carrier (PLC) systems that utilities use to manage the   
   power grid. In its April Report and Order, Order, and Notice of Proposed   
   Rulemaking (R&O/NPRM) in ET Docket 15-99, the FCC had raised several questions   
   regarding how Amateur Radio and PLC systems might coexist. The ARRL said, in   
   its view, there is little to no evidence that Amateur Radio operation would be   
   incompatible on the LF spectrum, where the great majority of PLC systems are   
   deployed, and that few, if any, PLCs operate in the MF band.   
      
   "The allocation of the 2200 meter band, together with the proposal to adopt   
   flexible rules for the use of that first LF allocation, and the proposal to   
   allocate the 630 meter band for amateur use, when implemented, will complete   
   at least a basic complement of Amateur Radio allocations in all portions of   
   the radio spectrum domestically," the ARRL told the FCC. "It is readily   
   apparent from the record...that there can most assuredly be compatible   
   operation by amateur stations in both the 2200 and 630 meter bands without   
   adverse interaction with PLCs."   
      
   The League asserted that "well-established notification procedures conducted   
   entirely in the private sector" as well as the sharing of available database   
   information should facilitate compatible operation. "Notification procedures   
   will be necessary only in those predictably few instances in which geographic   
   proximity and co-channel or overlapping channel operation occurs," the ARRL   
   added.   
      
   The League requested that the FCC finalize service rules for 2200 meters that   
   the ARRL outlined, and that it create the proposed 630 meter allocation.   
   Operation on 2200 meters would be limited to 1 W EIRP, and operation on 630   
   meters held to 5 W EIRP, in both cases with an absolute EIRP transmitter   
   output limit of 1500 W PEP and a 200 foot maximum antenna height. Assuming   
   continued PLC compliance with Part 15 rules, the ARRL argued, "there is no   
   significant interference potential to PLC systems operated on an unlicensed   
   basis in that very small segment of the 9-490 kHz band that is available for   
   PLC operation, even at separation distances of less than 1 kilometer from the   
   transmission line. At distances of 1 kilometer or more, there is no chance of   
   interference to a PLC line whatsoever, and no restrictions on Amateur   
   operation outside of that distance need be imposed."   
      
   The ARRL said PLCs that might be operating in the two bands should be   
   frequency agile enough to relocate to frequencies falling outside the proposed   
   allocations, making additional regulations unnecessary. The League has   
   conducted a lengthy and ongoing experimental operation (WD2XSH) on 630 meters.   
   It pointed out that it was "unaware of any reports of interference to PLC   
   systems arising from that operation conducted pursuant to numerous Part 5   
   experimental licenses...in the large band utilized by PLCs."   
      
   The League agreed with the FCC's proposal to make both 2200 and 630 meters   
   available to Amateur Extra, Advanced, and General licensees. The ARRL also   
   said the FCC should provide "maximum flexibility with emission types"   
   emissions throughout the 630 and 2200 meters, including CW, RTTY, data, and   
   even phone and image, the last "especially at 630 meters."   
      
   The ARRL also commented on the FCC's proposal to amend its Part 80 rules to   
   permanently authorize radio buoy operations on the "open sea" under a ship   
   station license in the 1900-2000 kHz band, which the Commission recently   
   elevated to primary for Amateur Radio. The League said there is "no evidence   
   of compatibility" between Amateur Radio operation in the band and the   
   "heretofore illegal" ocean buoy operations there.   
      
   "[S]hould the Commission proceed with its proposal...to make the 1900-2000 kHz   
   band available to commercial fishing vessels for use by radio buoys on the   
   open sea and to include them in the equipment authorized as part of a ship   
   station license, it should not do so by means of a primary allocation for   
   these devices in ITU Regions 2 and 3 as proposed," the League said. "The   
   entitlement to utilize radio buoys should be on a secondary basis to the   
   Amateur Service (and other radio services operating in the 1900-2000 kHz   
   band), and the buoys should be prohibited from causing harmful interference to   
   Amateur stations without qualification."   
      
   In a footnote, the ARRL said, "The record is silent heretofore as to the need   
   to use radio buoys in this frequency range. There is no information as to the   
   necessary path distances for these devices and why a band with very long   
   distance propagation is necessary for these buoys rather than VHF or some   
   other suitable alternative."   
      
   NNNN   
   /EX   
      
   )\/(ark   
      
   ... Do Androids Dream of Electric Sheep?   
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