Subj : ARRL Files Comments Against "Seriously Flawed" HF Rules Petition
To   : QST
From : ARRL de WD1CKS
Date : Wed Aug 02 2023 08:14 pm

08/02/2023

ARRL� The National Association for Amateur Radio[1]�, as part of its mission to
protect Amateur Radio, has filed comments[2] against a proposal that would
introduce high-power digital communications to the shortwave spectrum that in
many instances is immediately adjacent to the Amateur HF bands.

The "Shortwave Modernization Coalition" (SMC), which represents certain
high-frequency stock trading interests, filed the petition[3] with the Federal
Communications Commission (FCC). (Previous coverage can be found on ARRL
News[4].) ARRL responded on behalf of its members and the 760,000 licensees of
the Amateur Radio Service in the US.

The ARRL Laboratory performed a detailed technical analysis over several months
to determine if the proposed rules would affect operations on the bands
allocated to Radio Amateurs that are inter-mixed with the Part 90 bands in the
spectrum in question.

ARRL's analysis determined that, if the proposed rules are adopted, the new
operations inevitably will cause significant harmful interference to many users
of adjacent and nearby spectrum, including Amateur Radio licensees. Ed Hare,
W1RFI, a 37-year veteran of the ARRL Lab and internationally recognized expert
on radio frequency interference, was the principal investigator on the study.
Hare concluded the petition should not be granted. "This petition seeks to put
50 kHz wide, 20,000-watt signals immediately next to seven different amateur
bands with weaker protections against interference than required in other
services," said Hare.

In its formal opposition, ARRL stated, "That destructive interference would
result if operations commenced using anything close to the proposed maximum
levels."

ARRL's filed comments highlight flawed analysis and incomplete data submitted
by the petitioners. It noted the petitioners "...significantly understate the
harmful interference that is not just likely, but certain, if the rules
proposed by SMC are adopted as proposed. It is noteworthy that SMC's proposed
rules would provide less protection than the much-lower power amateur radio
transmitters are required to provide Part 90 receivers." ARRL's opposition also
noted that there was no reported tests conducted with Amateur or other affected
stations, but referenced a spectrum capture in the Comments filed with the
Dayton Group that showed actual interference into the Amateur 20-meter band
from one of the High Frequency Trading experimental stations.

Part 90 HF rules currently authorize a maximum signal bandwidth equal to a
voice communications channel, at up to 1000 W peak envelope power (PEP). The
petition seeks multiplication of signal width, greater transmitted power, and
weaker rules that protect users of adjacent spectrum. ARRL's comments expose
the likely fallout:

"Incredibly, notwithstanding the significant increase in potential interference
that would result from using digital schemes with 50 kHz bandwidths and 20,000
watts of power, SMC also proposes to substantially lessen the protections
required to protect adjacent and neighboring licensees. SMC proposes
[out-of-band emissions] limits that offer less protection than the existing
Part 90 limits and would actually permit no attenuation (0 dB) at the edge of
adjacent allocations, many of which are bands allocated to and heavily used in
the Amateur Radio Service. Consistent with lessening protections while
increasing the potential for harmful interference, SMC also proposes a lower
limit for spurious emissions. SMC would reduce the existing protection of -73
dB for the applicable 1000-watt power limit to just -50 dB protection for their
proposed 20,000-watt limit. Due to the much wider 50 kHz proposed bandwidth,
the resulting interference would penetrate deep into the adjacent Amateur
bands."

The proposal has been assigned FCC Docket No. RM-11953. While the period for
commenting on the petition has now closed, replies to comments in the record
may now be submitted.

Hundreds of licensed Radio Amateurs filed comments in the Docket, expressing
overwhelming opposition to the proposal. Those interested may read ARRL's full
comments and the results of the technical analysis, which are included in the
filing. "If granted as written, this would be devastating to Amateur operation
for many tens of kHz into our bands," said Hare.

ARRL will continue to advocate for its members and the Amateur Radio Service in
this proceeding.

About Amateur Radio and ARRL

Amateur Radio Service licensees use their training, skills, and equipment to
practice radio communications and develop radio technology. Amateur Radio
Operators volunteer their qualifications and equipment for communications duty
in public service and during emergencies. Amateur Radio also provides a basis
for hands-on STEM education and pathways to careers.

ARRL� The National Association for Amateur Radio[5]� was founded in 1914 as The
American Radio Relay League, and is a noncommercial organization of Radio
Amateurs. ARRL numbers within its ranks the vast majority of active Radio
Amateurs (or "hams") in the US and has a proud history of achievement as the
standard-bearer in promoting and protecting Amateur Radio. For more information
about ARRL and Amateur Radio, visit www.arrl.org[6].


[1] http://www.arrl.org
[2] http://www.arrl.org/files/file/FCC%20Documents/ARRL%20Opposition%20FCC%20RM-11953%2008_2023.pdf
[3] https://www.fcc.gov/ecfs/document/1042840187330/1
[4] https://www.arrl.org/news/commercial-interests-petition-fcc-for-high-power-allocation-on-shortwave-spectrum
[5] https:
[6] https://www.arrl.org

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