Topband: Re: [PVRC] FCC issues NPRM on 5 MHz ham band

[Bill Tippett]

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