March 21, 2017–The American Radio Relay League is defending its petition for rulemaking asking the FCC to adopt regulations to implement acts of the 2015 World Radiocommunication Conference (WRC-15) dealing with the international allocation of the 5351.5-5366.5 kilohertz band to the amateur service on a secondary basis (TRDaily, Jan. 12). In particular, the group said “there is not really much room for debate” concerning operating parameters for the allocation given the need to protect primary users of the band.
In comments filed yesterday in Rulemaking 11785, ARRL said, “There are as of this writing just over 60 comments filed in response to ARRL’s Petition. All of them were filed by individual Amateur Radio licensees. They all support an allocation to the Amateur Service of a contiguous band in the vicinity of 5 megahertz. They are all in agreement with ARRL that a contiguous band in the vicinity of 5 MHz will assist in conducting emergency and disaster relief communications in the United States; with the Caribbean basin; with Alaska and with other parts of North, Central and South America. Some of the comments filed to date propose the elimination completely of channelized operation in that frequency range, and instead suggest a conversion to what they describe as the ‘European model’ for this allocation in the United States, which they describe as being considerably larger than the 15 kHz worldwide, secondary frequency allocation at 5351.5 – 5366.5 kHz for the Amateur Service agreed upon at WRC-15. Many of the commenters also recommend that the Commission permit maximum power levels on the order of 500 watts, one kilowatt or 1.5 kilowatts PEP output power, which is considerably higher than that proposed in ARRL’s Petition.
“Other commenters suggest the opposite: that, regardless of the allocation to the Amateur Service of a contiguous band domestically, only channelized operation within that band should be permitted,” ARRL added. “A few comments propose that no telegraphy or telephony operation should be allowed within the allocation. Instead, they argue, only data emissions should be permitted in this band so as to encourage more regulated, spectrum-efficient and reliable operation in furtherance of emergency and disaster relief communications. Most comments in any case acknowledge the absence of reported interference to Federal government users or anyone else resulting from Amateur operation on the five current, discrete channels permitted on a secondary basis pursuant to Section 97.303(s) of the Commission’s rules.”
ARRL continued, “A fair summary of the comments filed to date, therefore, is that they universally support the allocation of a contiguous band to the Amateur Service; that they in general support a power level in excess of the maximum radiated power of 15 Watts (e.i.r.p.) permitted by the Final Acts of WRC-15; and they note that the band is most useful for emergency and disaster relief communications between, for example, the continental United States and the Caribbean basin. There is, however, an absence of consensus with respect to the appropriate size of the contiguous allocation; the proper status going forward of the discrete channels that are in regular daily use now that are outside the international allocation at 5351.5 – 5366.5 kHz; and the proper power limit to be permitted domestically for this allocation in particular. While ARRL understands and agrees that there is a long-term, justifiable need for an allocation at 5 MHz that is larger than the 15 kHz made available at WRC-15, and there is a very practical need for power in excess of the 100 watts PEP requested in ARRL’s Petition, there are practical considerations inherent in the ARRL Petition that stem from an urgent and ongoing need to share the Amateur allocation compatibly with other, primary users.
“The Amateur Service must, of necessity, avoid interference to the primary users of this band (which it has, to date) in order to be permitted to operate there,” the group said. “ARRL’s Petition recited the history of its decades-long effort to obtain a contiguous band near 5 MHz. This history demonstrates that there is not really much room for debate about the size of the band and the power limit domestically at the present time, given the allocation status of the band (domestically and internationally) and the necessary interference protection requirements for primary users. It is hoped that as regular Amateur operation in this contiguous band develops, with the operating parameters recommended in ARRL’s Petition, such operation will continue to demonstrate compatible sharing with Federal and other users and the operating parameters and the band can be re-examined and adjusted equitably at a later time.” – Paul Kirby, firstname.lastname@example.org