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Topband: Comments to FCC needed ASAP, regarding Fish Net Beacons in 1900

To: "topband@contesting.com" <topband@contesting.com>
Subject: Topband: Comments to FCC needed ASAP, regarding Fish Net Beacons in 1900-2000 kHz
From: Donald Chester <k4kyv@hotmail.com>
Date: Fri, 11 Sep 2015 19:23:22 +0000
List-post: <topband@contesting.com">mailto:topband@contesting.com>
Re Docket 15-99

While most attention so far has focussed on the proposed new MF and LF 
allocations, there is also the issue of fish net beacons on 160m. The initial 
comment deadline is past due, but REPLY COMMENTS ARE STILL OPEN THROUGH THE 
30th of SEPTEMBER.  We can reply to the ARRL comments; they pretty much have 
the issue identified and defined spot on, except for a suggestion that fish net 
beacons on 1900-2000 kHz be moved to the "lightly used" portion of the 
Radiolocation frequencies between the broadcast band and 160m ham band, 
specifically 1750-1800 kHz. From what I hear on my receiver at this location, 
THE ENTIRE SEGMENT OF FREQUENCIES between 1705 kHz and 1800 kHz is lightly 
used.  I rarely ever hear a signal of any kind in that segment, which was once 
packed full of now-discontinued radiolocation beacons.  I would strongly urge 
everyone to submit a reply comment explaining why you support the ARRL 
position,  with a further suggestion that the entire band of Radiolocation 
frequencies between 1705 and 1800 kHz be considered for re-accommodating 
beacons presently on 1900-2000.

I am not familiar with the beacon transmitters except for a few online ads for 
the products, but I suspect it would be very easy to move the transmit 
frequency, requiring only re-setting a synthesised master oscillator and 
tweaking the antenna tuning network. A technician could probably complete the 
task in less than 10 minutes. 

The beacons would suffer far less interference operating in the now-vacant 
Radiolocation spectrum, than in the heavily used amateur band. Even though they 
operate at low transmitting power, amateurs, particularly those living in 
coastal areas, frequently complain of interference. Likewise, signals from high 
power amateur transmitters are undoubtedly capable of causing harmful 
interference to the beacons.

When the FCC released the Report & Order upgrading amateur status to primary, 
it wasn't immediately clear that this included a new docket proposal (15-99) 
with a subsequent comment deadline.  It is unusual for the FCC to combine a R&O 
for one proceeding with a new Notice of Proposed Rulemaking all in the same 
release, so this did not come to the attention of most amateurs until a recent 
news item appeared on the ARRL website.


73, Don k4kyv


Some useful links:

Here, you see a list of links to recent comments, plus a link to the text of 
the original FCC Release in the right-hand pane. If you wish to submit a 
(reply) comment, click on "Submit a Filing in 15-99", which is located at the 
top of the page just above the main heading.

http://apps.fcc.gov/ecfs/proceeding/view?name=15-99   


Here is the entire FCC Docket, which is very lengthy.  The pertinent section 
addressing the 1900-2000 kHz issue begins with paragraph 30.

http://apps.fcc.gov/ecfs/comment/view?id=60001030137   


Here are the ARRL's submitted comments. The 160m issue is addressed in Section 
II, beginning on page 4 and running through page 11. 

http://apps.fcc.gov/ecfs/comment/view?id=60001198635 ;   

                                          
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