petition

ARRL Files Comments Against “Seriously Flawed” HF Rules Petition

Posted on by VA3DBJ

08/02/2023

ARRL  The National Association for Amateur Radio®, as part of its mission to protect Amateur Radio, has filed comments 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 with the Federal Communications Commission (FCC). 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® 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.

NIST FY 2019 Budget Would Eliminate WWV and WWVH

Posted on by VA3DBJ

UPDATED: White House petition setup. See below.

ARRL – The National Institute of Standards and Technology (NIST) FY 2019 budget request includes shutting down “NIST radio stations in Colorado and Hawaii” — in other words, WWV and WWVH. Radio amateurs, HF listeners, and others around the world routinely make use of the time and frequency standard signals, which also include propagation information. NIST said eliminating funding currently “supporting fundamental measurement dissemination” would include putting WWV and WWVH off the air for a saving of $6.3 million. The overall NIST FY 2019 budget request is $127 million, which, the agency said, is a net decrease of $49 million from FY 2018 levels.

“The proposed reductions will allow NIST to consolidate and focus on narrower core [fundamental] measurement programs while meeting budget levels,” the agency said in its FY 2019 budget summary. “NIST will focus on basic research while reducing funding for efforts applying some of its breakthroughs into new measurement applications.

The FY 2019 proposed budget cuts developed earlier this year came to light via Tom Witherspoon, K4SWL, who maintains The SWLing Post website, after a number of viewers called it to his attention. He posted an article on his blog.

“I’ve always considered WWV and WWVH to be the heartbeat of the shortwaves here in North America — a constant, timely companion and brilliant gauge of HF propagation,” Witherspoon wrote. I assumed both stations would be some of the last to go silent on the shortwaves.”

NIST said other “illustrative” cuts in the FY 2019 budget include:

  • $3.5 million for Lab to Market, which seeks to accelerate technology transfer from federal laboratories
  • $6.6 million in environmental measurements projects across NIST laboratories, including work measuring the impact of aerosols on pollution and climate change, and gas reference materials used by industry to reduce costs of complying with regulations
  • $5.8 million eliminating the NIST Greenhouse Gas (GHG) Measurements program, including Urban Dome research grants to advance the direct measurement of GHG emissions on the scale of cities or regions.
  • $6.7 million in forensic science, reducing the program size to $7.3 million by prioritizing measurement science in the NIST labs and eliminating program management functions and external grants for the Organization of Scientific Area Committees for Forensic Science and the Forensic Science Center of Excellence 
  • $4.1 million in R&D targeting application of NIST quantum breakthroughs to applied measurement needs, including temperature and atmospheric gas metrology

“I find this budget request very disappointing,” Witherspoon said with respect to the proposed elimination of WWV and WWVH. “Let’s hope, somehow, this does not come to fruition.” He said The SWLing Post would be tracking and posting any new developments.

UPDATE: White House petition to maintain NIST funding of WWV time stations.

I recently read your article concerning the proposed shutdown of the NIST stations WWV/WWVH.
To that end, I have gone ahead and created a Whitehouse petition to see if this decision can be reversed:
https://petitions.whitehouse.gov/petition/maintain-funding-nist-stations-wwv-wwvh
Would there be any way you could perhaps post the link to this so that fellow members of the SWLing Post could sign it? I believe the more folks we have sign the better chance we have of maintaining the radio stations we have all come to rely upon.

Tom Kelly
Click here to sign!