Good points, Bill! Comments are accepted anytime, so the filing deadline is
not relevant for filers itching to submit their comments now. The only
disadvantage is that this gives opponents insight into your position in
advance of their first filing, in effect giving them two bites at the apple.
That seems less relevant in this case, of course, but it still resonates as
the rationale for filing on the last day! I intend to file short comments
electronically, but I also will send messages to ARRL preparers so they know
there is a constituency that is awake and interested - and, at least in my
case, prefers segmentation.
Jim, N3JT
> -----Original Message-----
> From: pvrc-admin@mailman.qth.net [mailto:pvrc-admin@mailman.qth.net]On
> Behalf Of Bill Tippett
> Sent: Thursday, May 23, 2002 9:00 AM
> To: pvrc@mailman.qth.net; cq-contest@contesting.com;
> topband@contesting.com
> Subject: Re: [PVRC] FCC issues NPRM on 5 MHz ham band
>
>
> K3ZO wrote:
> >If I understand these matters correctly, this means that the FCC
> has opened
> a comment period under which concerned parties may file comments and
> depending on the results of the comments the FCC will take final action.
>
> From the FCC's NPRM itself:
>
> Adopted: May 2, 2002: Released: May 15, 2002
> Comments Due: 45 days from publication in the Federal Register.
> Reply Comments Due: 60 days from publication in the Federal Register.
>
> While I am not sure exactly when this was published in the
> Federal Register, ET 02-98 is available for comment now and the
> comment window can be opened by going here:
>
> http://gullfoss2.fcc.gov/prod/ecfs/comsrch_v2.cgi
>
> and entering only 02-98 in Box 1 and clicking Retreive Document List.
> There is only one comment there because I'm not sure many even know that
> the comment window is open! You can read the full FCC NPRM here:
>
> http://www.arrl.org/announce/regulatory/et02-98/
>
> I have a particular concern with the following paragraph:
>
> "40. The 5000 kHz Petition does not discuss sub-banding and
> ARRL's suggested
> rules would allow all emission types to use the entire band.[94] We note
> that several commenters suggest that sub-banding would be useful.
> We further
> note that Section 97.305 of our Rules segregates digital modes from other
> amateur station emission modes in the 3500 kHz and 7000 kHz bands
> to protect
> narrow band emissions like data from wider emissions like single-side band
> voice.[95] We request comment on whether sub-banding is necessary and/or
> appropriate for the 5000 kHz band as well."
>
> ARRL is very schizophrenic on this issue. Today we have mode
> segmentation on every HF band except 160, then ARRL proposes NO mode
> segmentation for the new 5 MHz band, and now as part of RM-10413 (Novice
> and Tech Plus Refarming) they endorse continued segmentation on 80, 40
> and 15. From their comments above, I believe even the FCC must be
> wondering what ARRL's true position is on mode segmentation...they are
> totally inconsistent in their actions IMHO.
>
> I obviously have my biases about mode segmentation since that
> was the main issue in RM-10352 for Topband. However, I believe no
> segmentation is a dangerous precedent to begin anywhere. Today we seldom
> see modes out of place on any bands except 160, and I hope we are not
> about to repeat the bad experience we've had there over the past 15
> years!
>
> Here is a summary of current and proposed mode segmentation
> by band for all HF amateur bands:
>
> ******************************************************************
> *********
> Listed below are the percentage of HF spectrum by band currently
> allocated exclusively for Narrowband modes compared with proposed
> allocation changes if proposed RM Petitions RM-10352 (160 meters),
> RM-10413 (Novice/Tech Plus Refarming on 80, 40 and 15 meters), and
> NPRM ET 02-98 (60 meters) are adopted (other HF bands included for
> reference):
>
> NARROWBAND ALLOCATIONS BY BAND
>
> Band Current % Proposed % Proposal Narrowband/Total (kHz)
> 160 0 20 RM-10352 40 / 200
> 80 50 45 RM-10413 225 / 500
> 60 N/A 0 ET 02-98 0 / 150
> 40 50 41.7 RM-10413 125 / 300
> 30 100 100 No change 50 / 50
> 20 42.9 42.9 No change 150 / 350
> 17 42.0 42.0 No change 42 / 100
> 15 44.4 44.4 RM-10413 200 / 450
> 12 40 40 No change 40 / 100
> 10 17.6 17.6 No change 300 / 1700
> ************************************************************************
>
> Whether you agree or disagree with me about the need for
> mode segmentation on our HF bands, I think we all need to make
> our feelings known to the FCC. If we do nothing, we have nobody
> to blame but ourselves. If you want to comment on the FCC's NPRM,
> go to this site, enter only 02-98 in Box 1, fill out the other non-
> optional boxes and submit a brief comment in the bottom box or attach
> your file (Adobe, Lotus, Word, WordPerfect, etc) in the box above that:
>
> http://gullfoss2.fcc.gov/prod/ecfs/upload_v2.cgi
>
> Be sure to confirm your submission on the page that appears after you
> submit. When you do everything correctly, you should see a page with
> your name and a confirmation number.
>
> I am not sure of the exact date when the window for ET 02-98
> opened, but it apparently has and will be available for comment until
> late June or early July. Speak now or forever hold your peace!
>
> 73, Bill W4ZV
>
>
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