In comments filed on March 20 with the FCC on its own January Petition for Rule Making (RM-11785), ARRL reiterated its case for a contiguous secondary 15-kHz wide 60-meter band of 5,351.5 to 5,366.5 kHz in addition to the four existing discrete 60-meter channels that fall outside the requested band, with a permitted power level of 100 W EIRP and retention of current operating rules. More than 5 dozen comments, all supporting the proposed allocation, were filed on the League’s petition, although some suggested more spectrum or higher power, or a combination. ARRL said, however, that it does not at this time favor any changes in its initial request for a new band. The League proposal would implement a portion of the Final Acts of World Radiocommunication Conference 2015 (WRC-15) that provided for a secondary international amateur allocation of 5,351.5 to 5,366.5 kHz at a maximum of 15 W EIRP.
“Each component of this proposal is intended to maximize spectral efficiency by permitting amateurs to operate throughout a band as conditions and availability warrant; to give primary service operations certainty as to where radio Amateurs will be located within the broader fixed and mobile service band between 5.250-5.450 MHz; and it protects those primary users with the same successful interference avoidance techniques and protocols that have been used for the past 15 years domestically, with which radio amateurs have the technical training and experience to comply,” ARRL asserted in its comments.
The League said the WRC-15 power limit of 15 W EIRP “would render the band unsuitable for emergency communication, especially between the US mainland and the Caribbean Basin during summer storms and hurricane season, when atmospheric noise can be severe.
ARRL said there were good reasons for hewing to the proposal it initially crafted and filed with the FCC, most relating to the fact that the spectrum is shared with federal government users and radio amateurs must avoid interfering with them. The ARRL also pointed out that there is no “European Model” for 5 MHz, noting that the vast majority of European countries have held to the 15 kilohertz agreed to at WRC-15, and some even to the 15 W EIPR power limit. The National Telecommunications and Information Administration (NTIA), which regulates government spectrum, would have to sign off on any proposal, and, ARRL noted, it has twice expressed concern about a contiguous allocation at 5 MHz and did not favor the plan agreed to at WRC-15.
“While ARRL understands and agrees that there is a long-term, justifiable need for an allocation at 5 MHz that is larger than the 15 kHz made available at WRC-15, and there is a very practical need for power in excess of the 100 W PEP requested in ARRL’s Petition, there are practical considerations inherent in the ARRL Petition that stem from an urgent and ongoing need to share the Amateur allocation compatibly with other, primary users,” ARRL said. “The Amateur Service must, of necessity, avoid interference to the primary users of this band (which it has, to date) in order to be permitted to operate there.”
Citing its decades-long effort to obtain operating privileges in the vicinity of 5 MHz, ARRL said there’s “not really much room for debate about the size of the band and the power limit domestically at the present time, given the allocation status of the band (domestically and internationally) and the necessary interference protection requirements for primary users.”
“It is hoped that as regular Amateur operation in this contiguous band develops, with the operating parameters recommended in ARRL’s Petition,” the ARRL comments continued, “such operation will continue to demonstrate compatible sharing with federal and other users and the operating parameters and the band can be re-examined and adjusted equitably at a later time.”
ARRL said the most important thing is to have the FCC grant an allocation before offering initiatives to alter the plan it proposed in January. It urged the FCC to adopt the rule changes it’s proposed “at the earliest possible time, if at all possible in advance of the 2017 hurricane season.”