I feel like I should have a T-shirt made that says “I survived the initial comment period of ET 15-99”. It can be stressful waiting and wondering what might be posted as well as talking other guys “in off of the ledge.” In fact, we are still waiting to see what the opposition posted as I am sure it is being formatted and prepared for publication by the FCC. I only hope that posting process is complete before the FCC maintenance shut down that starts tomorrow and lasts for the better part of a week.
The ARRL’s comment has not been officially posted on the ET 15-99 comment page but is visible on the ARRL website and can be viewed in full here. I think the ARRL did a very nice job with their filing. We all generally seem to be on the same page and while we have not yet seen the opposition’s comments, I think that unity is very important in the continued success of this project.
I think the expectation by many of us was that only narrow bands would be proposed but it appears that standard bandwidth SSB might also be available. Those operators deserve a spot, of course. Historically I have not been one to think band plans were explicitly needed, instead relying on gentlemen’s agreements for placement of modes and policing from within the community. This idea has generally been well accepted on 160-meters where pretty much anything goes but by and large SSB stays above 1843 kHz LSB. I do hope that good common sense is used by potential operators in frequency selection. Assuming that the wider-bandwidth portion of the proposal is upheld, it would be my personal preference that phone operation be conducted at the high end of the band, where there is little existing activity currently. This is analogous with how the HF bands are currently configured – SSB at the top and CW at the bottom. The higher frequency will offer higher antenna efficiency compared to the bottom end of the band and every dB will count for wider band modes.
The bottom and middle portions of the band are currently populated with CW and digital modes, anchored by WSPR, which has a 200 Hz passband from 475.6 kHz to 475.8 kHz worldwide. I know that other areas of the world have experienced difficulties and growing pains due to the limited spectrum. Regardless of mode, its possible and likely to see stations on top of one another because of hearing difficulties. My hope is that stations will approach the situation from a gentleman’s perspective. That approach has worked well on other low bands. We will figure this out and it will be OK…
Figuring things out as we go along is an important goal. Just because something may not look or smell right initially does not mean that it can’t change later. If there is something you don’t like that is ultimately implemented about the current proposal, there is room for adjustment later. I believe that 60-meters is currently undergoing an adjustment, for example.
I really appreciate the comprehensive nature of the ARRL’s filing as well as the work of Dr. Fritz Raab who has not only led the ARRL’s 600-meter research group but also made some very fine comments, calculations and recommendations of his own in the matter of ET 15-99. Without such support, I doubt that we would be where we are at this moment. Thank you!
I’ve said it before and I will say it again – these are exciting times…