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

Discussion in 'Ham Radio Discussions' 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 Premium Subscriber 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......
     
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