[Swprograms] DRM on SW for Alaska Domestic Service.

[Joe Buch <josephbuch@xxxxxxxxx>]

The ARRL is taking on a company, Digital Aurora Technologies, that is proposing an HF DRM service to cover Alaska.  They made the mistake of wanting to use the 7.1-7.3 MHz ham band for test transmissions.

Joe Buch 

==> ARRL FILES PETITION WITH FCC AGAINST EXPERIMENTAL LICENSE USING 40
METER BAND 

On Monday, October 20, the ARRL filed a "Petition for Modification or
Cancellation of Experimental Authorization" ("Petition")
<http://www.arrl.org/news/files/Digital_Aurora_Radio_Technologies_Petiti
on_10_20_08.pdf> with the FCC with respect to WE2XRH. According to the
FCC, this experimental license -- issued to Digital Aurora Radio
Technologies (DART) -- proposes to "test digital transmissions in
4.50-5.10 MHz, 7.10-7.60 MHz and 9.25-9.95 MHz for a terrestrial digital
radio service to the citizens of Alaska."

The League's petition states that DART's hopes that this experimentation
"will lead to a terrestrial, high-frequency (HF) digital aural (domestic
broadcast) service in Alaska. Ostensibly to study the operation of this
'shortwave' system at high latitudes, and apparently in order to roll
out this domestic broadcast service, DART specifies exceptionally high
power operation in various segments of the HF spectrum. ARRL's interest
in this matter is limited to the fact that the experimental license
includes the band 7.1 -7.3 MHz...allocated domestically exclusively to
the Amateur Radio Service."

"It is astonishing that the FCC would grant this experimental license
for operation at such a high power level in a band that is allocated
exclusively to a service with which such operation is clearly
incompatible," said ARRL Chief Executive Officer David Sumner, K1ZZ.
"The only possible explanation is that it was an error; the only
reasonable step for the FCC to take is to correct its error immediately,
either by cancelling the license or by amending the frequency ranges to
delete 7.1 -7.3 MHz."

It is the ARRL's view that "Simply stated, there is a 100 percent
certainty of severe, continuous, harmful interference from operation of
the DART facilities as authorized by the Commission to ongoing Amateur
Radio operation at 7.1 to 7.3 MHz. This authorization must be modified
immediately (if not cancelled completely), so as to delete the band
7.1-7.3 MHz" from DART's experimental license application.

DART has been permitted operation in the 7.1-7.6 MHz band using a 20 kHz
bandwidth digital emission at a transmitter output power of 100 kW and
an ERP of 660 kW within a radius of 1500 kilometers of Delta Junction,
Alaska. In the petition, ARRL General Counsel Chris Imlay, W3KD, points
out that while DART says it will coordinate with the High Frequency
Coordination Conference (HFCC) <http://www.hfcc.org/>, "[i]t does not
propose any coordination with any individual or entity in the Amateur
Service. There is no showing whatsoever how DART proposes to avoid
interference to Amateur Radio operation at 7.1-7.3 MHz. In fact, there
is no indication that DART is even aware of the allocation."

Calling the 40 meter band "perhaps the most heavily-utilized Amateur HF
band in the United States," the ARRL states that it can see "no
compatible use that DART can make of this band in any state or territory
of the United States, at any time of the day or night" and that such use
will cause "preclusive interference" to amateurs using that portion of
the band. "The entire 7.0 - 7.3 MHz band is used heavily within Alaska,
especially by radio amateurs located in its remotest areas, at all
times. It is particularly critical in times of emergency due to its
daytime and nighttime propagation characteristics. The band is also used
at all times of the day and night for worldwide communications by radio
amateurs."

The League's "Petition" points out that the FCC's Rules at Section
5.83(b) state that experimental license grants are subject to change or
cancellation by the Commission at any time without hearing if in the
Commission's discretion the need for such action arises: "ARRL submits
that this application should never have been granted as applied for in
the first place, and there is an urgent need to prohibit operation of
the DART high power transmitters in the entirety of the 7.1-7.3 MHz
band. It is likely that DART has been under a misapprehension that the
band is among the international broadcast allocations, because, in ITU
Regions 1 and 3, the band is allocated to that Service. However, in
Region 2, in Alaska, it is not." After March 29, 2009, 7.1-7.2 MHz will
not be available for broadcasting anywhere.

The League goes on to say that Section 5.85 of the Commission's Rules
governs the selection and use of frequencies by holders of experimental
authorizations and adamantly states that "there is no justification
submitted by DART for the use of the frequency bands requested,
particularly with respect to 7.1-7.3 MHz. It is unclear why such large
segments of spectrum were specified by DART, given its stated course of
experimentation, and given its narrow occupied bandwidth" and notes that
DART "should have been required to conduct its frequency coordination
efforts in advance of the filing of its application."

The ARRL contends that DART's proposed facility cannot meet the FCC's
requirements, as outlined in the Commission's Rules, Section
5.111(a)(2), "and there is no showing that the transmitter power is the
lowest practical value consistent with the program of experimentation.
Nor has it even taken Amateur Radio operation into account." This
portion of the Rules state that when transmitting, the experimental
licensee "must use every precaution to ensure that the radio frequency
energy emitted will not cause harmful interference to the services
carried on by stations operating in accordance with the Table of
Frequency Allocations of part 2 of this chapter and, further, that the
power radiated is reduced to the lowest practical value consistent with
the program of experimentation for which the station authorization is
granted. If harmful interference to an established radio service
develops, the licensee shall cease transmissions and such transmissions
shall not be resumed until it is certain that harmful interference will
not be caused."

Calling for DART's WE2XRH experimental license to "be cancelled
entirely, or at least modified so as to delete the reference to any
Amateur HF allocation," the ARRL reminded the FCC that DART failed to
make any showing as to how it would avoid interference to Amateur Radio
operation at 7.1-7.3 MHz: "ARRL submits that such a showing could not be
made in any case."



      
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