ARRL Slams Shortwave Modernization Coalition Petition Seeking FCC Rulemaking
ARRL, which represents amateur operators, slammed an April petition by the Shortwave Modernization Coalition (SMC) asking the FCC to launch a rulemaking to amend its eligibility and technical rules for industrial/business pool licensees to authorize licensed use of frequencies above 2 MHz and below 25 MHz for fixed, long-distance, non-voice communications (see 2305010053). SMC defended the petition in two filings. Hundreds of amateur operators warned the proposal would be harmful to their operations (see 2307270035). Comments were posted Friday in RM-11953.
“The petition should be denied or dismissed without further consideration for reasons well-explained in multiple responsive filings,” ARRL said. “The proposed rules changes, if adopted, would result in significant harmful interference to an array of other services and users,” the group said: As demonstrated by multiple commenters, the SMC “has offered no meaningful test results, no accurate assessment of interference, and no meaningful suggestion(s) for mitigation of the interference to other users.”
“There is no merit to claims that any additional use of the 2-25 MHz Band frequencies would be contrary to the public interest,” SMC responded. Instead, “modernization” of the Part 90 Rules is “consistent with the Commission’s duty to make efficient and effective use of spectrum and manifestly is in the public interest” and the frequencies “are ideal for transmission of relatively low-bandwidth data over long distances with minimal delay as compared to other transmission technologies,” the coalition said.
SMC said its goal is to encourage a rulemaking that will “allow these new data services to coexist with existing Part 90 users (including public safety users), and with users licensed in the 2-25 MHz Band under other rule parts that are not the subject of the Petition, such as Maritime (Part 80), Aviation (Part 87), and Amateur (Part 97)” and with federal users of the band.
NCTA said changing the rules for the band could be harmful to cable systems that have used the band for broadband and TV services for many years. NCTA questioned whether SMC was fully transparent about potential interference problems when it sought the rulemaking. “The band represents almost half of the frequencies used for upstream internet access delivered by cable providers over wired systems,” NCTA said: “These frequencies are essential to the delivery of broadband, VoIP telephone (including 911 calls), video distribution, and interactive services (such as video on-demand and pay-per-view services) to households across the country.”
SMC relies on a coexistence report attached to the petition, but “its focus is very narrow, and its limited results are plainly inadequate to warrant further Commission consideration of Petitioners’ proposal,” NCTA said.
SMC refuted the cable arguments in a second filing posted Friday. “NCTA omits a highly relevant fact: cable providers are not licensed wireless providers in this band entitled to protection from others.” SMC said: “Instead, cable systems are unintentional radiators subject to regulation so that they do not cause problems to licensed providers.” The FCC shouldn’t “base spectrum management decisions -- particularly a decision as to whether to take the initial step of launching a notice of proposed rulemaking -- on the qualms of an operator of an unintentional radiator,” the coalition said.
Most of the reply comments were short, and filed by ham radio enthusiasts. “Numerous comments point out, in various ways, that the benefits of this petition are focused very narrowly, while the harms will be widespread,” said amateur operator Fred Goldstein.