Robert Horvitz <rh@well.uucp> (02/21/90)
Here are the key parts of the comments I filed with the FCC on
Friday, concerning WARC-92 and the question of allocating more
spectrum for shortwave broadcasting (Gen. Docket 89-554):
"...ANARC believes that a substantial increase in the high
frequency (HF) spectrum allocated for International Broadcasting
is urgently needed to reduce co- and adjacent-channel interference
among the many stations currently on the air, and to accommodate
the growing needs of the international broadcasting service in the
future. This is consistent with the United States' position at all
WARCs in recent decades which have considered broadcasting
allocations in the HF band. Thus, we urge the Commission to
support continuation of this well-established and clearly justified
policy by developing specific proposals for accommodating the needs
of international broadcasters and their listeners in the United
States, with the assistance of the joint government/private-sector
advisory committee for WARC-92 which the Commission is
establishing. ANARC regards it is as essential that American
listeners be represented on this advisory committee, since we are
the targets, consumers and end-users of the international
broadcasting service..."
"Expanding the band allocation for international broadcasting
by at least 50% would reduce congestion and significantly improve
the audibility of stations operating in these bands...
"There are large blocks of under-utilized channels presently
allocated to the Fixed Service, many of which are adjacent to the
bands for International Broadcasting. Many point-to-point stations
that once depended on Fixed Service channels have switched to
satellite circuits. This trend is sure to continue. The under-
used portions of the Fixed Service HF bands are an obvious source
of additional spectrum which could and should be reallocated for
International Broadcasting..."
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Here are excerpts from the comments filed by George Jacobs, whose
clients include most of the FCC-licensed SWBC stations:
"...The amount of h.f. spectrum allocated to the broadcasting
service between 5,960 and 26,100 kHz, including the WARC-79
extensions, totals 3,130 kHz. The results of HFBC-87, as discussed
previously, show that an increase on the order of 50% in these
allocations is necessary in appropriate bands to accommodate the
world's broadcasting requirements. To accomplish this, I propose
the following additional exclusive allocations to the h.f.
broadcasting service for consideration at WARC-92. This amounts
to an additional 1,500 kHz, or an increase of 48%.
Present Present Proposed Additional
Allocations Bandwidth New Bandwidth
including kHz Allocations kHz
WARC-79
extensions
kHz
--------------------------------------------------------------
5950-6200 250 5850-5950 100
7100-7300* 200 7300-7750 450
9500-9900 400 9350-9500 150
11650-12050 400 11550-11650 100
13600-13800 200 13800-13900 100
15100-15600 500 15600-15700 100
17550-17900 350 17450-17550 100
21450-21850 400 18900-19300 400
TOTALS: 3,130 1,500
* Regions 1 and 3 only. Amateur Service in Region 2. All other
allocations are exclusive worldwide.
----------------------------------------------------------------
"The proposed increased spectrum would come from present
allocations to the Fixed Service, except in the case of 5850-5950
kHz which is shared between the Fixed, Land Mobile and Mobile
Services..."
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rh: In an earlier posting, I quoted George Jacobs to the effect
that VOA and RFE/RL were likely to oppose more spectrum for
shortwave broadcasting. However, Stanley Leinwoll, RFE/RL's
propagation engineer, says he has submitted proposals to the
federal interagency subgroup responsible for WARC-92, seeking "a
total of more than 1 Megahertz of additional HF broadcasting
spectrum. Discussions dealing with these papers will begin
early next month. They were introduced at a meeting in
Washington, DC on February 8... I will also add that engineers
with whom I deal at VOA are also highly supportive of HFBC band
expansion."
If you haven't written the FCC yet, you still have time to do so.
But you have to do it as a REPLY to comments already filed. If you
agree with either ANARC's or George Jacobs' comments, your telling
that to the FCC will add weight to what we've said.
Reply comments must reach the FCC by 16 March 1990. Make sure you
write:
Re: Gen. Docket No. 89-554 REPLY TO COMMENTS
at the top of your first page. Be sure to quote from or cite
comments filed in the first round, use standard-size typing paper
(8.5 x 11 inches), and leave wide margins. Send a signed original
and 5 signed copies to:
Ms. Donna R. Searcy, Secretary
Federal Communications Commission
1919 M St. NW
Washington, DC 20554
Don't forget: the filing deadline for reply comments is 16 March
1990. Thanks for your support.
--
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
Robert Horvitz, Executive Secretary ANARC BBS: 1-913-345-1978
Association of North American Radio Clubs Compuserve: 76210,517
P.O. Box 143, Falls Church, VA 22040-0143 USA uucp: rh@well.sf.ca.us