It’s not just broadcasters who are getting their say in the FCC’s “Delete, Delete, Delete” deregulation initiative.
The National Association for Amateur Radio (ARRL) has also filed comments, advocating for a modernization of the Part 97 Amateur Radio Service regulations. Their proposals include both previously submitted items and new requests that the ARRL said is centered on updating the rules to reflect technological advancements while preserving the foundations of traditional amateur radio practices.
“The soldering iron and discrete physical components used in past experiments often are replaced by a personal computer and coding knowledge to experiment with new techniques and functions,” the ARRL wrote.
Modernizing Technician class license privileges
The ARRL said that while digital technologies like FT8, RTTY and PSK31 have become integral to the Amateur Radio Service, entry-level Technician class license privileges have not been updated accordingly. It advocates for granting Technicians access to HF frequencies where digital modes are prevalent, which it says is crucial for introducing newcomers to the fundamentals of low-power communication and fostering self-training and emergency communication skills.
“The youth attracted to amateur radio today will become the wireless engineers and space scientists of tomorrow that are critical to our nation’s future if given a chance,” the ARRL wrote.
The ARRL references a February 2018 petition on this matter that has yet to see action. Their specific requests include phone privileges in the 3.900 to 4.000 MHz, 7.225 to 7.300 MHz and 21.350 to 21.450 MHz bands, as well as RTTY and digital privileges within current Technician allocations on the 80, 40 and 15-meter bands.
Addressing 80- and 75-meter subband imbalance
The ARRL noted the increasing use of digital modes leading to an imbalance within the 80- and 75-meter amateur bands. To improve spectrum efficiency and better accommodate the demand for digital modes, the association refers to their 2016 petition requesting adjustments to the subband boundaries.
Specifically, it proposed shifting the lower edge of the phone band upward to 3.650 MHz, allowing RTTY data in the 3.500-3.650 MHz range, aligning the ACDS subband with international practices at 3.600-3.615 MHz, and granting Novice and Technician licensees CW, RTTY and data privileges in the 3.600-3.650 MHz segment, with General and Advanced licensees also gaining access to this segment.
Deleting baud rate and bandwidth limits
The ARRL reiterated its support for the FCC’s ongoing Further Notice of Proposed Rulemaking that Radio World reported on in 2023 to eliminate baud rate and bandwidth limitations on specific amateur LF and VHF/UHF bands. It noted the widespread support for this change among commenters.
Additional areas of interest in the ARRL filing include:
- Deleting Obsolete Digital Code Limitations: It proposes allowing amateurs to freely experiment with new, publicly documented and decodable digital codes.
- Deleting Amplifier Drive Limitation: The ARRL requests the removal of the 15 dB gain limit for HF amplifiers. It argues this rule, originally intended to prevent CB misuse, is now obsolete due to advancements in solid-state amplifier technology and restricts efficiency for U.S. amateurs.
- Deleting Obsolete Identification Requirement for Special Call Signs: The ARRL seeks to remove the requirement for operators using special event call signs to identify hourly with their assigned call sign.
- Implementing WRC-03 Third Party Rule Changes: The ARRL calls for aligning FCC rules with the 2003 World Radiocommunication Conference updates regarding third-party communication. The association points out that despite the international agreement removing the need for bilateral treaties for most third-party communication, the FCC still requires such agreements, hindering cross-border communication and emergency training.
“Technology has changed dramatically in the amateur radio domain, as it has in most other communications services, and the above requested rules deletions and modifications will foster the regulatory goals for the amateur service and continue to increase the amateurs’ historical experimentation and service in meaningful ways,” the ARRL concluded.
(Read the comments of the ARRL to the FCC, filed on April 11.)