ARLA/CLUSTER: ARRL defende perante a FCC máxima flexibilidade no uso das novas bandas de 2200 e 630m

[João Costa > CT1FBF]

ARRL supports maximum flexibility for Amateur use of new 2200 and 630 meter
bands

The ARRL has told the FCC that Amateur Radio operation in the new
135.7-137.8 kHz (2200 meters) and 472-479 kHz (630 meters) bands should be
as unfettered as possible from a regulatory standpoint.

The League spelled out its case August 31 in detailed comments that argue
in favor of flexible FCC Part 97 regulations in light of the exceptionally
low interference potential to unlicensed power line carrier (PLC) systems
that utilities use to manage the power grid.

In its April Report and Order, Order, and Notice of Proposed Rulemaking
(R&O/NPRM) in ET Docket 15-99, the FCC had raised several questions
regarding how Amateur Radio and PLC systems might coexist.

The ARRL said, in its view, there is little to no evidence that Amateur
Radio operation would be incompatible on the LF spectrum, where the great
majority of PLC systems are deployed, and that few, if any, PLCs operate in
the MF band.

"The allocation of the 2200 meter band, together with the proposal to adopt
flexible rules for the use of that first LF allocation, and the proposal to
allocate the 630 meter band for amateur use, when implemented, will
complete at least a basic complement of Amateur Radio allocations in all
portions of the radio spectrum domestically," the ARRL told the FCC. "It is
readily apparent from the record...that there can most assuredly be
compatible operation by amateur stations in both the 2200 and 630 meter
bands without adverse interaction with PLCs."

The League asserted that "well-established notification procedures
conducted entirely in the private sector" as well as the sharing of
available database information should facilitate compatible operation.
"Notification procedures will be necessary only in those predictably few
instances in which geographic proximity and co-channel or overlapping
channel operation occurs," the ARRL added.

The League requested that the FCC finalize service rules for 2200 meters
that the ARRL outlined, and that it create the proposed 630 meter
allocation. Operation on 2200 meters would be limited to 1 W EIRP, and
operation on 630 meters held to 5 W EIRP, in both cases with an absolute
EIRP transmitter output limit of 1500 W PEP and a 200 foot maximum antenna
height. Assuming continued PLC compliance with Part 15 rules, the ARRL
argued, "there is no significant interference potential to PLC systems
operated on an unlicensed basis in that very small segment of the 9-490 kHz
band that is available for PLC operation, even at separation distances of
less than 1 kilometer from the transmission line. At distances of 1
kilometer or more, there is no chance of interference to a PLC line
whatsoever, and no restrictions on Amateur operation outside of that
distance need be imposed."

The ARRL said PLCs that might be operating in the two bands should be
frequency agile enough to relocate to frequencies falling outside the
proposed allocations, making additional regulations unnecessary.

The League has conducted a lengthy and ongoing experimental operation
(WD2XSH) on 630 meters. It pointed out that it was "unaware of any reports
of interference to PLC systems arising from that operation conducted
pursuant to numerous Part 5 experimental licenses...in the large band
utilized by PLCs."

The League agreed with the FCC's proposal to make both 2200 and 630 meters
available to Amateur Extra, Advanced, and General licensees.

The ARRL also said the FCC should provide "maximum flexibility with
emission types" emissions throughout the 630 and 2200 meters, including CW,
RTTY, data, and even phone and image, the last "especially at 630 meters."

The ARRL also commented on the FCC's proposal to amend its Part 80 rules to
permanently authorize radio buoy operations on the "open sea" under a ship
station license in the 1900-2000 kHz band, which the Commission recently
elevated to primary for Amateur Radio. The League said there is "no
evidence of compatibility" between Amateur Radio operation in the band and
the "heretofore illegal" ocean buoy operations there.

"[S]hould the Commission proceed with its proposal...to make the 1900-2000
kHz band available to commercial fishing vessels for use by radio buoys on
the open sea and to include them in the equipment authorized as part of a
ship station license, it should not do so by means of a primary allocation
for these devices in ITU Regions 2 and 3 as proposed," the League said.
"The entitlement to utilize radio buoys should be on a secondary basis to
the Amateur Service (and other radio services operating in the 1900-2000
kHz band), and the buoys should be prohibited from causing harmful
interference to Amateur stations without qualification."

In a footnote, the ARRL said, "The record is silent heretofore as to the
need to use radio buoys in this frequency range. There is no information as
to the necessary path distances for these devices and why a band with very
long distance propagation is necessary for these buoys rather than VHF or
some other suitable alternative."

Fonte: The American Radio Relay League <http://www.arrl.org/>
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