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[CQ-Contest] FCC Wants Your Input

Subject: [CQ-Contest] FCC Wants Your Input
From: btippett@alum.mit.edu (Bill Tippett)
Date: Fri Jul 12 11:23:55 2002
        Here's a copy of a message I put on the DX List:

"While on the subject of the new 5 MHz and 137 kHz bands, ARRL
summarized the FCC's NPRM here:

                http://www.arrl.org/news/stories/2002/05/15/100/

In particular, note the following:

                "The FCC has proposed letting amateurs
                operate at full legal limit on 
                a new 5 MHz allocation, but it left
                open for further discussion 
                whether to restrict the band to Amateur
                Extra Class licensees or make 
                it available to General and higher
                class licensees. The FCC also 
                invited further comment on whether the
                band should be broken
                down into mode-specific subbands. The 
                ARRL had proposed opening the entire band 
                to RTTY, data (including CW), phone and 
                image emission types."

The FCC's NPRM is here:

                http://www.arrl.org/announce/regulatory/et02-98/

with the specific paragraphs regarding these issues here:

39. It appears that amateur radio operators should be able to avoid
interference to primary operations in this band due to the
limited numbers of primary assignments[92] which are authorized for
operation in the 5250-5400 kHz band, and their
experience in sharing HF frequencies in other bands. The operational
protocol of "listen before transmit" employed by amateur
radio operators should further minimize interference. We note that currently
this technique is not explicitly required by our Rules
and we request comment on whether it should be explicitly stated in the
Rules in order to protect the primary operators in the
5250-5400 kHz band. We propose to limit the output power of the amateur
stations to 1500 W PEP as requested by ARRL.
Further, we invite comments as to whether the 5250-5400 kHz band should be
restricted to Amateur radio operators with an
Amateur Extra Class license to better ensure compatible sharing with the
Federal Government operations, or could the band
also be made available to operators with a General or Advanced Class license
just as in the 10,100-10,150 kHz band (30
meter band). [93] We invite comment on whether the power limit and operator
license requirement are sufficient to prevent
interference to primary users, and whether an EIRP limit would also be
appropriate for this frequency band. We also invite
comment on other means that will reduce potential interference. 

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. 

        I personally believe sub-banding should be done with a simple
demarcation between narrowband (CW, digital) and wideband (phone, 
image) just as we have on every other HF band except 160 meters. On 
160, I've personally experienced numerous problems with inter-modal 
interference over the past 18 years, and that is whay I was a 
co-sponsor of RM-10352 which proposed a simple demarcation of 1840 and 
below for narrowband modes only. 

        If you want to submit comments to the FCC, it is VERY simple 
to do. Just go to this site:

                http://gullfoss2.fcc.gov/prod/ecfs/upload_v2.cgi

enter only 02-98 in Box 1, fill out the other "required" boxes 
(2,3,7,8,9,10 and 12), and submit your comments either as an attached 
file (using the first form in Adobe PDF, MS Word, MS Excel, 
WordPerfect, ASCII or Lotus 123) or, more simply, just type your 
comments in the bottom Brief Comment form. After you submit, 
a confirmation screen will appear and you click "Finish Transaction 
and Receive Confirmation". A final confirmation screen should appear 
with your name and a confirmation number if all is accepted correctly.

        In summary, the FCC's questions about 5 MHz are:

1. Power limit of 1500 watts OK?
2. Amateur Extra or General and above?
3. Is sub-banding necessary and appropriate? If you feel 
it is, you might want to suggest a dividing line such as 5250-5300 
for narrowband only (CW, digital).

        I feel ARRL generally represents our interests well, but the 
FCC has made it very simple for all of us to make comments directly. 
If you feel you want to make your voice heard, take a few minutes to 
do so now before the comment window closes July 29. If we don't, 
we have nobody (including ARRL) to blame but ourselves.

                                        73, Bill W4ZV

P.S. If any of you have problems with the FCC site, E-mail me 
directly and I'll be happy to help." 


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