Here is the latest from the ARRL

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). (Previous coverage can be
found on ARRL News.) 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.