SB QST @ ARL $ARLB013   
   ARLB013 ARRL Tells FCC to Restore Balance of Modes on 80 and 75 Meters   
      
   ZCZC AG13   
   QST de W1AW   
   ARRL Bulletin 13  ARLB013   
   > From ARRL Headquarters   
   Newington CT  March 28, 2016   
   To all radio amateurs   
      
   SB QST ARL ARLB013   
   ARLB013 ARRL Tells FCC to Restore Balance of Modes on 80 and 75 Meters   
      
   In comments filed on March 23 on its Petition for Rule Making (RM 11759)   
   seeking changes to 80 and 75 meters, the ARRL has told the FCC that its   
   primary objective is to "rebalance" the bands by correcting a 10-year old FCC   
   error.   
      
   "ARRL's proposal is not fairly viewed as a proposal to take anything away from   
   anyone," the League's comments assured. "It is more properly viewed as the   
   effectuation of a fair, equitable, and efficient 'band plan' looking forward   
   for the foreseeable future that balances everyone's needs, and which remedies   
   a plainly unfair plan, imprudently created in the 2006 Report and Order in WT   
   Docket 04-140."  The Report and Order can be found on the web at,   
   http://apps.fcc.gov/ecfs/comment/view?id=5513680269 .   
      
   Prompting the League's assurances were comments filed on the ARRL's Petition   
   by a number of Amateur Extra class licensees, who felt that refarming 3600 to   
   3650 kHz for data modes could prove to be a disincentive to General licensees   
   to upgrade. Others commenters saw it as an unfair spectrum grab. The ARRL   
   noted that prior to 2006, the band was evenly divided between RTTY/data and   
   phone/image subbands, with the RTTY/data subband extending from 3500 to 3750   
   kHz, and the phone/image subband extending from 3750 to 4000 kHz.   
      
   The 2006 FCC Report and Order "substantially altered" what the League called   
   "this even division of emission types." In outlining the history of the   
   proceeding, the ARRL pointed out that the FCC's   
   Notice of Proposed Rulemaking in Docket 01-140 would have shifted the line   
   between the 80 meter RTTY/data subband and the 75 meter phone/image subband   
   from 3750 kHz to 3725 kHz, pursuant to a 2002   
   ARRL Petition for Rule Making, RM-10413. This would change the ratio of   
   spectrum between phone/image and RTTY/data segments on 75/80 meters from 50/50   
   to 55/45, and it is what the FCC proposed in its NPRM.   
      
   In its Report and Order in Docket 04-140, however, the FCC made "a very   
   substantial and unjustifiable departure" from what it had proposed in its   
   NPRM, the ARRL recounted. The Commission expanded   
   the phone/image subband at 75 meters to 3600-4000 kHz, and it reduced the 80   
   meter RTTY/data subband to 3500-3600 kHz, eliminating RTTY operation above   
   3600 kHz and changing "the entire dynamic of   
   this band," the League said.   
      
   The FCC had said in its proposal that no licensees would lose operating   
   privileges. Nonetheless, the FCC's phone band expansion reduced by 100 kHz the   
   spectrum between 3500 and 4000 kHz that was previously available to General   
   class licensees, while Advanced licensees lost 75 kHz. In an apparent FCC   
   oversight, the Report and Order completely eliminated access by automatically   
   controlled digital stations (ACDS) to 3620 to 3635 kHz. A subsequent FCC   
   Report and order and Order on Reconsideration only made the situation worse by   
   replacing the deleted ACDS segment with 3585-3600 kHz.   
      
   "It resulted in a sudden and severe dislocation of traffic-handling nets using   
   telegraphy, without advance planning or notice," the ARRL said. "It   
   disaccommodated net participants with General and Advanced class licenses; and   
   it worsened the effect of the overexpansion of the 75 meter phone/image   
   subband."   
      
   The result, the ARRL noted, has been "a shortfall in available RTTY/data   
   spectrum on 80 meters" that has created a significant obstacle to narrowband   
   digital data communications and experimentation. The League said its current   
   Petition "simply restores that which was disrupted in 2006 in error."   
      
   In its comments, the League conceded that compromises are inevitable in   
   managing a heavily used band like 75/80 meters, no matter the band planning   
   approach. "Looking forward, it is necessary, in order to encourage   
   experimentation with and expand the use of digital communication techniques,   
   to rebalance the 75 and 80 meter subbands," the ARRL concluded.   
      
   NNNN   
   /EX   
      
   )\/(ark   
      
   Always Mount a Scratch Monkey   
      
   ... Sandwich: An faulty attempt to make both ends meat.   
   ---   
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