Topband: FCC and ARRL 160 Bandplan

[Bill Tippett]

AA4LR wrote:

>I think it is a grave mistake to look at the ARRL bandplan as having the 
>force of regulation. As I read the FCC regulations, SSB operation is 
>permitted from 1800-1843 kHz. So, emitting SSB signals in this spectrum 
>is not, by itself, a violation of the FCC rules.

        I think it would be a grave mistake to ignore the bandplan unless
you enjoy corresponding with the FCC.  For those who may not like the idea
of mode segmentation on 160, you should get used to the idea of following
bandplans because I predict there will be no mode segmentation on any band
if current trends continue (no-code licensing and consequent growth in
demand for more SSB spectrum).  Following voluntary bandplans may become 
more important on all bands as sunspots decline, no-code grows and we are 
all forced into the existing spectrum.  Extrapolate ARRL's current direction
and it does not take a rocket scientist to figure out what may be next (no
mode segmentation anywhere with voluntary bandplans becoming the rule is
my personal reading of their desired direction).

>The issue at hand that the FCC is enforcing is willful interference. Now, 
>far be it for someone pushing the agenda that 1800-1843 is supposed to be 
>CW-only to make claims of willful interference to those who happen to 
>operate some SSB in this spectrum....

        This has been the issue since I have been on 160.  Some groups
have been incalcitrant and even vengeful (complete with recorded gun 
threats).  If it were not for Hollingsworth's letters, they would be there
today.  Just because they "were there first" (which I doubt is true if
you go back in time far enough) does not give them the right to ignore
the bandplan.  If it were not for the recalcitrant few and for SSB contests
filling the entire band, the situation on 160 today would be perfectly
fine.  I'll repeat Hollingsworth's comments again for those who may have 
missed them the first time:

*************************************************************************
Excerpt from Hollingsworth's letter to K3NM:

"Please be advised that Amateurs are responsible for taking steps to make 
sure they do not interfere with ongoing communications, and contest 
participants have no greater rights to any specific frequency than other 
Amateurs."


Excerpt from Hollingsworth's letters to W5TZ, KT5S and WA4TWM:
 
"Band plans are voluntary in nature, but the Commission depends upon them
because they minimize the necessity for Commission resources to be used in 
solving Amateur problems and they provide an opportunity for Amateurs to use 
various modes of Communications.  Where interference results from band plans 
not being followed, the Commission expects substantial justification to be 
shown by the operators ignoring the band plans."
**************************************************************************

>That said, if you really want the bandplan to work -- and I think it 
>could -- then there's a big education process that has to take place. DX 
>stations have to listen above 1843 kHz -- both for US stations calling 
>CQ, and US stations trying to answer their CQs. 

        Of course it can work just as it does on 40 and 80.  And I doubt
that much more education is needed than the exposure this issue has already
received on this reflector.  If you are a serious contester, you quickly
learn what works and what doesn't.  This is exactly the reason that most
DX contest QSO's on 75 meters are made split rather than simplex in the 
3750-3800 area common to both ITU Regions 1 and 2.  The common "window" is
filled with QRM from strong local stations calling CQ while most weaker
stations are worked split with Region 1 below 3750 and Region 2 above 3800. 
Just listen during the CQ WW SSB and you will find the KC1XX, W3LPL and K3LR 
gang mostly above 3800 and listening below 3750.  That is not an accident 
even though they certainly have the option and signal presence to operate in
the 3750-3800 area if they so chose.  So why are they split?  Simply because 
it is MORE EFFECTIVE...QED and end of debate IMHO.

>For a contest like CQWW, the control is really in the hands of the DX 
>stations. If a DX station is loud and calling CQ on 1830 kHz simplex -- 
>are you saying I should ignore him because he isn't following the 
>bandplan? 
>
>Heck, 1830 kHz may be a good frequency for him. He may not even have 
>allocations above 1843 kHz. 

        If I were a Region 1 DX station in a 160 SSB contest, I would
transmit on the clearest frequency I could find, listening simplex (for
other Region 1 stations) and split for Region 2 on the clearest frequency
I could find between 1843 and 2000.  Why?  Because local signals are 
likely -25 to -35 dBm, with adjacent sidebands/spurs down only -40 dB 
(to -65 to -75 dBm) in the presence of which I am trying to hear weak (-100 
to -130 dBm) DX signals.  If I compound this with strong Region 2 stations 
also calling CQ on the same frequencies (which would be covering Region 1
stations), it gets even worse which is exactly the chaotic situation that 
exists today.

>I do think that perhaps it would be poor form for US stations to call CQ 
>below 1843 kHz, but I think it is likely to happen. Again, the DX 
>stations are the key. If they aren't listening above 1843 kHz, then what 
>is a US station supposed to do?
>
>Again, all this realising that 1800-1843 is perfectly legal for SSB 
>emissions, at least as the regulations are today, and many DX stations do 
>not have allocations above 1840 or 1850 kHz.

        I would be very careful with your "perfectly legal" comment unless
you are willing to take the FCC to court.  Hollingsworth's comments clearly
indicate otherwise to me and it is not worth my time or money to argue in
court...besides I happen to agree with him.  I'm a firm believer in choices 
and consequences...if you are willing to risk the consequences of operating
SSB below 1843, please feel free to do so since you have been forewarned 
of the consequences.

        On a side note, the argument that 160 antennas cannot be retuned 
for SSB is very weak.  Somehow we have learned to tune them from 3.5 MHz
to 3.8 MHz which is a much smaller percentage shift than tuning from 1.830 
to 1.875.  It takes all of 10 seconds to reresonate my shunt-fed tower by
moving the series capacitor and should not take very long to short out about
3-4 feet of an inverted-L or 3-4 feet from both sides of an inverted-V.

                                                73,  Bill  W4ZV

P.S.  The Churchill Polar Bear trip was great with lots of wildlife seen 
but no Aurora due to overcast skies at night...may have to plan another 
trip to Fairbanks in March to see them Cycle 23 declines more.