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Thursday, September 17, 2015

Comments to FCC needed ASAP, regarding Fish Net Beacons in 1900-2000 kHz


as it is very important on 160m band for DXers I am re-posting here the article from Don, K4KYV regarding the proposed new MF and LF allocations in FCC Docket 15-99 even although it is a bit late...

Re Docket 15-99

While most attention so far has focussed on the proposed new MF and LF allocations, there is also the issue of fish net beacons on 160m. The initial comment deadline is past due, but REPLY COMMENTS ARE STILL OPEN THROUGH THE 30th of SEPTEMBER.  We can reply to the ARRL comments; they pretty much have the issue identified and defined spot on, except for a suggestion that fish net beacons on 1900-2000 kHz be moved to the "lightly used" portion of the Radiolocation frequencies between the broadcast band and 160m ham band, specifically 1750-1800 kHz. From what I hear on my receiver at this location, THE ENTIRE SEGMENT OF FREQUENCIES between 1705 kHz and 1800 kHz is lightly used.  I rarely ever hear a signal of any kind in that segment, which was once packed full of now-discontinued radiolocation beacons.  I would strongly urge everyone to submit a reply comment explaining why you support the ARRL position,  with a further suggestion that the entire band of Radiolocation frequencies between 1705 and 1800 kHz be considered for re-accommodating beacons presently on 1900-2000.

I am not familiar with the beacon transmitters except for a few online ads for the products, but I suspect it would be very easy to move the transmit frequency, requiring only re-setting a synthesised master oscillator and tweaking the antenna tuning network. A technician could probably complete the task in less than 10 minutes.

The beacons would suffer far less interference operating in the now-vacant Radiolocation spectrum, than in the heavily used amateur band. Even though they operate at low transmitting power, amateurs, particularly those living in coastal areas, frequently complain of interference. Likewise, signals from high power amateur transmitters are undoubtedly capable of causing harmful interference to the beacons.

When the FCC released the Report & Order upgrading amateur status to primary, it wasn't immediately clear that this included a new docket proposal (15-99) with a subsequent comment deadline.  It is unusual for the FCC to combine a R&O for one proceeding with a new Notice of Proposed Rulemaking all in the same release, so this did not come to the attention of most amateurs until a recent news item appeared on the ARRL website.

73, Don k4kyv

Some useful links:

Here, you see a list of links to recent comments, plus a link to the text of the original FCC Release in the right-hand pane. If you wish to submit a (reply) comment, click on "Submit a Filing in 15-99", which is located at the top of the page just above the main heading.

Here is the entire FCC Docket, which is very lengthy.  The pertinent section addressing the 1900-2000 kHz issue begins with paragraph 30.

Here are the ARRL's submitted comments. The 160m issue is addressed in Section II, beginning on page 4 and running through page 11.

73 - Petr, OK1RP

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