Fcc proposes to restore 1900-2000 khz in the 160m band to primary status

Discussion in 'Discussions, Opinions & Editorials' started by K4KYV, Dec 3, 2012.

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  1. K4KYV

    K4KYV Subscriber QRZ Page

    In ET Docket 12-338 the FCC proposes to raise the secondary amateur service allocation in the 1900-2000 kHz band segment to primary status, providing amateur radio operators nearly exclusive use of the band. At present, amateur use of the top half of the 160m band is on a secondary basis, shared with Radiolocation beacons that have priority over amateurs on any shared frequency.

    With the avilability of the GPS satellite system for civilian use, radiolocation beacons have virtually disappeared from the 1700-1800 kHz and 1900-2000 kHz bands, but our "secondary" status on 1900-2000 remains, leaving us vulnerable to the whims of Radiolocation interests in the event that they, for whatever reason, might decide to once again operate beacons in our band.

    The FCC is now accepting comments from interested parties. I would encourage everyone who has any interest in 160m to file comments of your own in support of this proposal. Comments already submitted on all proposals contained in the Docket may be viewed at http://apps.fcc.gov/ecfs/proceeding/view?name=12-338

    Rulemaking proposal ET-Docket 12-338 may be viewed in its entirety at http://apps.fcc.gov/ecfs/comment/view?id=6017137896 For specifics on the 160m proposal, scroll down to page 11, beginning at paragraph 20.

    ET-Docket 12-338 may be viewed also at http://apps.fcc.gov/ecfs/document/view?id=7022061247 or downloaded in PDF form at http://transition.fcc.gov/Daily_Releases/Daily_Business/2012/db1119/FCC-12-140A1.pdf

    For information on the FCC's Electronic Comment Filing System go to http://apps.fcc.gov/ecfs/

    For detailed instructions on how to file comments using ECFS, go to http://apps.fcc.gov/ecfs/userManual/ecfsmanual.jsp

    The first submitted comment addressing 160m reallocation may be viewed at http://apps.fcc.gov/ecfs/comment/view?id=6017141101

    The International Telecommunications Union frequency allocation chart may be viewed at http://www.kloth.net/radio/freq-itu.php

    Don k4kyv
  2. N0NB

    N0NB Subscriber QRZ Page

    Wow! I don't think I could type up something like that if I tried! Must comments reek of legalese or will the Commission still read and consider comments written by us common folk?

    The same petitioner makes a good case for allocating 2205m to us as proposed in this docket as well.
    Last edited: Dec 4, 2012
  3. K1VSK

    K1VSK Ham Member QRZ Page

    Nor should you. Having once been one of the folks who reads these petitions, I can assure you that one will create a few laughs. Plain language is always preferable.
  4. K4KYV

    K4KYV Subscriber QRZ Page

    Just use plain English, and write as clearly as you can. The FCC is looking for well thought-out comments that contain convincing arguments. Just saying you support (or oppose) a proposal without giving any reasons to justify your position will be less effective. Proofread for spelling errors and typos before submitting your comments. A sloppily written submission will probably be taken less seriously.
  5. K9STH

    K9STH Ham Member QRZ Page

    In dealing with the FCC in the commercial two-way radio arena, I have found that using plain, simple, concise language works a LOT better than using legaleeze.

    Years ago, when I was a consultant with TXU, the company was in the process of installing an 896 MHz trunking system that covered basically the entire State of Texas. Because of the time needed to completely "build out" the system, a modification of the schedule had to be obtained from the FCC. As such, I wrote a 2-page letter explaining what was needed and why it was needed. One of the executives "panicked" because the law firm in Washington, DC, that TXU used for all dealings with the FCC was not contacted to make the application and sent a copy of the letter to the law firm. A couple of weeks later, the law firm replied stating that the request would never be accepted as written by the FCC and "offered" to do the filing. However, in the same day's mail came a letter from the FCC granting everything that was asked and even more! About a month later a bill for $5,000 came from the law firm "claiming" that they had gotten the variance. Needless to say, that was one bill that definitely was not paid!

    When talking with the various FCC officials concerned with such grants, they definitely said that they preferred simple requests that did not have to be reviewed by several lawyers just to interpret the exact nature of what was being requested.

    Glen, K9STH
  6. KE7VZW

    KE7VZW Ham Member QRZ Page

    removing all radiolocation is unwise IMO. The satellites, via their topology, are a single point of failure.
  7. N0NB

    N0NB Subscriber QRZ Page

    I don't think the FCC has proposed removing the radio location systems currently in use from 1900-2000 kHz but is proposing to make their presence in this band segment secondary and giving amateur radio primary status instead. Radio location's use of this band segment is winding down on its own and will likely be at zero sometime in the future anyway. I don't know much about radio location, but I don't think 160m locators have been the primary means of navigation for many years and that there are still terrestrial radio location beacons, just in other bands not shared with amateur radio. So I don't see satellites being a single point of failure being an argument against granting this proposal.
  8. K4KYV

    K4KYV Subscriber QRZ Page

    The NPRM does not propose to remove all radiolocation. The 1900-2000 segment is actually a very small part of what is allocated to radiolocation throughout the radio spectrum, from VLF to microwave. Look at what the ITU Allocations Table lists for radiolocation in Region II.

    There are presently two radiolocation allocations in the vicinity of the 160m band, 1705-1800 and 1900-2000. Just a few years ago the 1705-1800 kHz segment was packed full of radiolocation beacons and about a dozen were sharing 1900-2000 with hams, but now most if not all the audible beacons in both segments appear to have gone dark. The radiolocation service no longer needs the 1900-2000 segment. Any beacons still operating inside our band could be re-accommodated in the 1705-1800 kHz segment, which is now virtually devoid of signals.
  9. G0GQK

    G0GQK Ham Member QRZ Page

    Corporations and government don't use plain English because of its lack of obfuscation

    Mel G0GQK
  10. KL7AJ

    KL7AJ Ham Member QRZ Page

    Now, if they could just do the same for 7200-7300, that would really be something! :)

    p.s. I know the FCC has no jurisdiction over foreign broadcasters...but......
  11. W7MMQ

    W7MMQ Ham Member QRZ Page

    I would like them see extend the 160M band back to 1715 -2000, making the bottom part on a secondary basis for starters (it's not used anway) that way I can put up an even bigger antenna that I have no chance of fitting in my yard!
  12. N0NB

    N0NB Subscriber QRZ Page

    I too am hopeful that in another decade shortwave broadcast will have diminished to the point where a discussion of a world-wide allocation of 7.000 to 7.300 MHz can take place. Also, it would be nice of Region 3 broadcast were removed from 3.900 to 4.000 as well.

    Is radio location the only service allocated to 1715-1800 kHz? If so, there might be a chance of extending the amateur allocation at some point. But, first things first! Let's get the NPRM for 1900-2000 kHz approved first.
  13. W7MMQ

    W7MMQ Ham Member QRZ Page

    As far as I am aware yes it is, it used to be the old time 160M band for amateurs
  14. K4KYV

    K4KYV Subscriber QRZ Page

    Here's an example of the kind of opposition we may be up against, who may file comments in opposition to the NPRM, since Lindgren Pittman Inc. likely won't want to recall and re-program units they have already sold. This makes it all the more imperative that the amateur community come up with some good well thought out responses to the FCC.

    What I wonder is why they didn't program the units sold in the US to operate in 1705-1800 in the first place, since that segment appears to be completely vacant, rather than risk being overpowered by hams who might not even hear them, in a shared band.


    But this is encouraging:

    Another comment has come in supporting hams in the NPRM. Notice that this one is simple and to the point, no gobbledygook legalese. He should have included his name and address instead of just a call sign, though.

  15. K0RGR

    K0RGR Premium Subscriber QRZ Page

    I don't see this as a huge change, but it's welcome, anyway. The new 137 kHz allocation might be good for a laugh. I think if I work anybody outside my own back yard there, I will deserve a medal, but I know that much longer distance contacts have been made there. I'm also interested in seeing a new 400 kHz. allocation here, and I hope we get one eventually. But, the next big deal will be if we get a real allocation at 60 meters. If the NTIA would give it up, FCC could give us a secondary allocation there right now, and probably would. The question for the moment is which way will the USA go at the next WARC on this matter. A 200 kHz allocation as proposed would take pressure off 75 meters.
  16. W8MLD

    W8MLD Ham Member QRZ Page

    Being a retired Army aviator I see the need for back up systems to GPS and other satellite navigation systems. A simple solar outburst of a major magnitude can render those systems next to worthless. Our back up system was Doppler navigation. Not nearly as accurate as GPS, but it could get you back home. Even a small CME can make GPS useless. We need these legacy systems in place "just in case".

    On shortwave, I actually enjoy shortwave listening time to time. And, in a lot of places around the globe shortwave is their only way to get news and information. Especially in remote locations in S. America and Sub Sahara Africa. They just do not have the infrastructure for standard AM and FM radio like we do. One of the most popular shortwave stations is BBC World News.
  17. K4KYV

    K4KYV Subscriber QRZ Page

    The FCC is not proposing to eliminate Radiolocation. Just to return a tiny rarely used segment, the shared portion of 160m from 1900kHz to 2000 kHz, back to amateurs on an exclusive basis. Radiolocation has another nearby allocation in this part of the spectrum, extending from the top edge of the expanded AM broadcast band to the bottom edge of the 160m ham band, from 1705 to 1800 kHz. The radiolocation beacons that used to be packed in like sardines have gone silent in this segment, too, and it is now practically devoid of signals of any kind, so any back-up radiolocation beacons that might need to be pressed into service would have plenty of room to be accommodated there. They don't need 1900-2000 any more.

    Radiolocation is sprinkled throughout the radio spectrum, from 70 kHz to 10 gHz and beyond. See the ITU frequency allocations chart at http://www.kloth.net/radio/freq-itu.php North America is in Region II. You will see that 1900-2000 is but a minuscule part of the spectrum assigned to radiolocation services.
  18. N2EY

    N2EY Ham Member QRZ Page

    Why not 1715-2050?

    73 de Jim, N2EY
  19. W7MMQ

    W7MMQ Ham Member QRZ Page

    Not sure if it is used or not, have not looked at above 2.0M but why not the more the merrier, I just know that portion below 1.8 has not been used in quite some time
  20. N0NB

    N0NB Subscriber QRZ Page

    The proposal is not that generous. The proposal is to swap the status of radio location and amateur radio in the 1900-2000 kHz segment with amateur radio becoming primary and radio location secondary. This change merely reflects the reality on the ground in large part. The upper half of 160m has become well used by us in recent years. Any radio location beacons would have a tough time of it starting up in that segment these days. I think that the dearth of any operating beacons in the 1715 to 1800 kHz segment would argue against any comments suggesting this proposal not be approved.

    If the next solar cycle minimum is anything like the last one, an expanded 160m allocation may be needed! As I wrote above, let's get this one approved and then move on to other ideas.
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