REC/KU3N 8 meter band FAQ

Greetings from Riverton.  

I have been reviewing the various articles, Facebook posts and yes, even for discussion on the 8-meter proposal.  Now with that said, here's some answers to some questions, comments and concerns made in the various channels...

Who is KU3N?

KU3N is myself. I am the founder of REC Networks, an entity that has been in existence since 1984 and have worked for many years on policy issues on various FCC issues including broadcasting, personal radio services, Part 15 unlicensed services and amateur radio.  I have been a licensed ham since 1986. I am also a SBE Certified Broadcast Technologist.  While not as active as I once was, I used to be involved mainly in VHF/UHF in Southern California during the time I lived there.  Back in the late 80s and early 90s, I participated in ARRL VHF contests.  I currently live on the east coast on the Delmarva Peninsula.  My policy speciality is around spectrum related issues and I am also the leading policy advocate who is physically active in Washington DC to represent the Low Power FM (LPFM) radio service. 

Why did you get involved in this petition?

I am also a dual citizen of the United States and Ireland.  I also follow spectrum policy issues at ComReg (Ireland) and Ofcom (UK).  Recently, ComReg amended their regulations to give amateurs access to a huge amount of spectrum in the VHF low band (30~49, 54~69 MHz).  When the Irish Radio Transmitters Society (IRTS) was accepting consultations on their proposed bandplan for the new spectrum, I did participate in that bandplan.  The IARU in Region 1 is working to get 40 MHz cleared in more countries within the region.  I filed this petition to get this band on the FCC's radar, especially if a 40 MHz secondary allocation ever comes up at a future WRC.   The FCC never moves on its own.  It depends on stakeholders and industry to move proposals forward.  

Why didn't you ask for more spectrum?  Why didn't you ask for xx MHz?

The primary piece of spectrum that is being looked at here is 40.66~40.70.  This is a 40 kHz wide industrial scientific and medical (ISM) band.  A few nations such as South Africa have already granted amateurs access to this specific subband.  The IRTS bandplan calls for various activites in the section between 40.51~40.70 that are mainly geared towards "narrower" communications such as CW and digital modes.  The band was not brought down below 40.51 due to considerations made in the IRTS bandplan to avoid the carrier frequency 40.50 as that is the third harmonic for the distress and calling frequency, 121.5 MHz.  The 40 MHz band was chosen to maintain harmonization with the efforts going on in Europe with anticiaption that someday we can have transatlantic paths on the band.  Its also important to realize that other spectrum is currently being used by documented non (federal) government licensees, especially state highway patrols and police departments and I can get a grasp on the loading of that spectrum.  Most critical federal government use (such as protection of the President) takes place on VHF high band and other spectrum, not on low band.  

Isn't this military spectrum?

It is federal government spectrum.  Yes, there is military usage in the 40~42 MHz band for what NTIA calls "networks for providing command and control for combat, combat support, and combat service support as part of tactical and training operations" as well as tactical air-to-ground and air-to-air communication systems for close air support missions.  This spectrum is also allocated federally for land mobile communications for the national parks as well as for telemetry purposes for measuring snow fall data.

It's important to remember though that the NTIA permits the military to also use 6 meters and 220 on a secondary basis.  On those bands, the military can't interfere with hams.  Hams also use the 420~450 MHz,  902~928 MHz, 1240~1300 MHz on a non-interference basis to the military and other federal users.  Let's also not forget the channelized access with have at 60 meters. 

The amateur radio service does a very good job at sharing spectrum with the NTIA users in these bands.  I see 8 meters as no different.

Why no FM in this band?  There's already a ton of old land mobile gear that could be recrystaled for this spectrum.

The petition was written for 190 kHz of spectrum.  If we were to allow FM and especially using the old LMR gear, then we will have to create up to 9 20 kHz wide channels which would take away other weak signal activities in the band.  Also, the NTIA Redbook specifies a channelized land mobile system creating 20 kHz channels within the entire 40 MHz band.  If the federal government is using this spectrum, especially in the west for national parks and forests, it would not be a compatible use if 20 kHz signals from hams are coming in on federal systems during openings.  The narrower signals would be less likely to cause any interference to federal users.  If the NTIA is willing to budge, then we could look at some channelized FM above 40.7 as that would be compatible with the IARU Region 1 bandplan. 

Who is backing this proposal?  The industry?  The ARRL?  Who?

REC is not receiving any backing from anyone nor is REC soiliciting any financial support from any entity.  REC is about a citizen's access to spectrum and when there is a development, to jump on it.  If REC didn't file this, who would have?

What's all this stuff I hear about "women and girls"?

I personally support efforts to bring more women and girls into the subjects of science, technology, engineering and mathematics.  Some were confused by that statement made in the petition for rulemaking but it is an overall objective of REC Networks to support diversity in the STEM fields.  The youth of today, regardless of gender, are our future and we need to assure that they are prepared for the technologies of tomorrow.  As a nation, we need to get back into the technology race and get to the head of the pack.  This will bring the new industries here, which will bring jobs and bolster our economy and make us less dependent on foreign outsourced labor.  Even for those who want to "make America great again", this is how you do it.  Develop your youth, boys and girls to learn advanced skills.  Ham radio provides an excellent sandbox for experimentation.  There's more you can do beyond chewing the rag.  This is the part of the hobby we need to advance.  Learning about propagation, radio theory, antennas, components and safety, especially on a hands-on basis is very important. 

I had even read in one place that the proposed band is a "band for girls" and that someone would not support it for that reason.  This addresses a bigger issue of misogyny in a small, but vocal aspect of the amateur radio community.  Japan does a better job at attracting women and girls into the hobby than we do here.  Perhaps, it is time for us to take a few lessons from the JA.  Again, attracting women and girls to the hobby is not specific to 8 meters.  It is specific to all bands, all modes and all technologies, including those that have not been invented yet.  

Was this petition in reaction to the French threat on 2 meters?

REC Networks filed this Petition for Rulemaking on May 24, 2019.  An Erratum was filed on May 28, 2019 to make corrections to the information about NTIA usage of the band.  The CEPT Project Team A (PTA) held their meetings in Prague between June 17~21, 2019.  The FCC released the Public Notice announcing RM-11843 on June 26, 2019.  Even though the FCC's timing to release the Public Notice and assign the RM number was subsequent to the PTA meeting, the actual petition was written over three weeks prior to the proposal made by France at this low-level CEPT planning meeting.  

Do you think the FCC released this rulemaking when it did in response to the French threat on 2 meters?

No.  This is about the average time that it takes for the Wireless Telecommunications Bureau (WTB) to move forward a Petition for Rulemaking.  When you look at the various proceedings in the FCC, you will find that the WTB moves forward many amateur radio petitions.  How do you think the "Tyro" petition got front and center?  

Why do you call it "8 meters" when it is really 7 meters?

Ask the Europeans.  That is their terminology.  I assume it's because the 40 MHz band is directly between the 10 and 6 meter band (hence midway would be 8).  Plus, 40.000 MHz is 7.5 meters, 7.5 rounds up to 8.  Again, the Europeans set this standard, not me.

Do you really see the FCC eventually adding 8 meters?

It's hard to say.  We won't know if we don't ask.  If we have an active 40 MHz proposal in the dockets and the issue comes up at a future World Radio Conference by a different administration (such as the CEPT representing the entire EU), then the FCC has something to work with and a set of comments already collected.  Like with 60 meters, it will depend on the NTIA (the Federal Government's frequency coordinator) to determine if spectrum can be made available to share and if so, what kind of restrictions such as power levels, antenna types, etc.  I don't see much harm with east coast and midwest hams beaming Europe on 8 meter CW or even FT8, especailly with how sporadic this band would probably be used.  I think, if planned right, ham radio can cohabitate very well with the feds.  We have already shown it elsewhere.  

Thank you for reading and your support in comments!

Michelle Bradley, CBT, KU3N
REC Networks