In a letter to staff within the Federal Communications Commission (FCC) and the National Telecommunications and Information Administration (NTIA), REC Networks, through it's founder, Michelle (Michi) Bradley, KU3N, expressed continuing support for RM-11843, a Petition for Rulemaking filed by REC in support of creating a new allocation for the Amateur Radio Service (ARS) on a secondary basis in a portion of spectrum between 40 and 41 MHz, commonly referred to as the "8 meter band".
In the letter, REC also calls attention to the Part 5 experimental operations that are taking place in the 40~41 MHz spectrum and the data that is being gathered from it. The experiments, which were not initiated by REC, but were completely independent of the RM-11843 efforts have been conducted by a small number of persons in order to study E and F layer propagation in this spectrum, located directly between the 10 and 6 meter ARS bands. REC has raised concerns that, while experimental authorizations were granted in the past, they are now being denied and discounted as being for "Amateur" purposes and can be performed in spectrum already allocated to the ARS. REC cites the fact that we are currently in the rise for Solar Cycle 25, which is expected to peak in early 2025 and that suspending the experiment well prior to the cycle peak was premature. REC called on the FCC's Office of Engineering and Technology to permit these experiments to continue as they serve the public interest in the promotion of science, technology, engineering and mathematics (STEM) and is providing valuable data, not only to justify a secondary amateur allocation, but for other purposes related to the study of propagation.
In ITU Region 1, which includes Europe and Africa, the Ireland department of Communications Regulation (ComReg) has already created a wide low band VHF allocation permitting use of the 40~41 MHz band on a secondary basis. Other Region 1 nations have also provided some form of authorization for 8 meter band experimentation.
REC also addressed concerns received regarding the US Government use of the spectrum from 40.66~40.68 MHz (centered at 40.67 MHz) for telemetry regarding snowfall. These operations are in various western states and Alaska. Under REC's proposal, in order to protect these "SNOTEL" operations, it was proposed that the ARS would not have access to the band between 40.66~40.68 MHz in any area of the Continental United States west of 90 degrees longitude nor within the state of Alaska. Operations in all other areas are proposed to be limited to 25 watts peak envelope power, which is more than enough to support certain digital modes that are currently being used in the experiments.
REC also addressed the potential of simplex FM communications in this proposed band. This issue was raised by ARS community members in light of the fact that there are many surplus transcievers available for land mobile radio that can be used in this spectrum. REC stated that with the current 40.51~40.70 proposed allotment, there could be up to 9 FM channels, however using this band for FM on such a basis could deny its use for weak signal and other modes. REC revised its proposed non-binding band plan to include a 20 kHz carve-out for a single FM channel. REC has proposed that one or more FM channels are desired and can be cleared by the NTIA for ARS use, spot channels in the spectrum 40.7~41.0 can be used. If the entire sub-band is made available for ARS use, this could be 15 FM channels for simplex purposes. Otherwise, the NTIA could specify specific channels that may no longer be used by Federal agencies under their channelized land mobile plan for amateur use. REC also expressed that FM operations in 40 MHz could be used in emergency communications as part of an effort to provide interconnection between radio amateurs and Federal government agencies, such as the Federal Emergency Management Agency.
REC again cites the long standing relationship between the Federal Government and the ARS where it comes to frequency sharing, especially in the 60 meter (5 MHz) band, which is currently being looked at for more reallocation in a different FCC proceeding that is already in a Notice of Proposed Rulemaking.
May 7, 2023 REC Letter to FCC/NTIA
