I checked the final comments on Docket 02-98 last night, before starting on
my reply comments. It looks like the greatest threat to
amateur radio right now is NOT shortwave broadcasters or
commercial/government interests who may want to reallocate our frequencies
to other radio services. Actually, HF seems pretty deserted these days, so
you would think there would be loads of spectrum available to us. The
existing WARC bands could be expanded, and more new bands could be created
all over the HF spectrum.
The threat I now see is the proliferation of unlicensed Part 15 devices.
Amongst the comments, Part 15 interests are expressing concern about ALL
THREE of the proposed new bands; this includes the proposed 2400-2402 mHz,
60m and 135.7-137.8 kHz allocations. We all know about the power industry
and power line carrier systems, but yet another industry is opposing us on
60m. They are trying to establish home delivery of high speed data over
power lines. Evidently they reached some agreement with the FCC that they
could operate if they filter out ham frequencies, but they are moaning and
groaning about the existing systems that already use the 5 mHz spectrum,
both because of potential interference from hams and the fact that they
would have to shut down systems that cause harmful interference to amateur
communication on the new band. A similar concern comes from some outfit that
is using the UHF/microwave spectrum for some other Part 15 gadget.
Part 15 devices are, by definition, operate with the prior understanding
that they are completely unprotected. The industry knew from the beginning
that if there is a problem from licensed services, satisfactory resolution
is completely in their lap. But now they are trying to gain protection
through the FCC, saying that since there so many users of these devices,
including individuals as well as electric power distributors, that it would
be in the public interest to extend FCC protection to unlicensed devices
because Part 15 users are so much more numerous than hams. If this stuff
continues to proliferate, the entire non-broadcast radio spectrum will
eventually become tied up. There will be no need for EPCA, because you won't
be able to receive anything through the buzzies from all this rubbish
anyway.
Use of the radio spectrum under Part 15 began with the clear understanding
that these devices had no government protection whatever. Now unlicensed
interests are seeking minimal protection through the FCC. It doesn't take a
rocket scientist to figure out that as this technology expands, they will
continue asking for more frequencies and more protection. I am already
hearing non-powerline interference in the lower frequency shortwave
broadcast bands and in between. How much longer before unlicensed interests
begin lobbying to trash the ham bands as well? If nothing is done to
discourage this pollution of the radio spectrum, it will eventually end up
worse than LORAN ever was on 160.
Don K4KYV
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