XPost: rec.radio.amateur.policy, oma.general, nebr.misc
XPost: rec.radio.info

Many of you contacted me with concern about the FCC petition proposing
to allow high power digital transmitters adjacent to ham radio HF bands.
As I indicated, the ARRL was working on a technically and legally
strong response. That response has been filed with the FCC. The press
release follows.

Thanks for supporting the ARRL so that we can work to defend the
spectrum we use.

73, Art K0AIZ
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08/02/2023

ARRL The National Association for Amateur Radio®, 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). (Previous coverage can be
found on ARRL News.) ARRL responded on behalf of its members and the
760,000 licensees of the Amateur Radio Service in the US.

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.

About Amateur Radio and ARRL

Amateur Radio Service licensees use their training, skills, and
equipment to practice radio communications and develop radio technology. Amateur Radio Operators volunteer their qualifications and equipment for communications duty in public service and during emergencies. Amateur
Radio also provides a basis for hands-on STEM education and pathways to careers.

ARRL The National Association for Amateur Radio® was founded in 1914
as The American Radio Relay League, and is a noncommercial organization
of Radio Amateurs. ARRL numbers within its ranks the vast majority of
active Radio Amateurs (or "hams") in the US and has a proud history
of achievement as the standard-bearer in promoting and protecting
Amateur Radio. For more information about ARRL and Amateur Radio, visit www.arrl.org.

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ARRL Midwest Division
Director: Arthur I Zygielbaum, K0AIZ
k0aiz@arrl.org --------------------------------------------------------------------

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