Sharing HF Spectrum has worked for 20 years!
-Doug Garlinger
President, NASB
July 2005
The viability of the U.S. private shortwave broadcaster depends upon
the availability of suitable frequencies for international broadcasting.
In 1980, there were only four private shortwave broadcasters licensed in
the United States and its territories. In the mid-80’s, there were calls
for a moratorium on further licensing of private shortwave broadcasters
due to a world-wide frequency shortage. Fortunately, no moratorium occurred,
and the private shortwave industry has grown steadily through the strategic
use of in-band and out-of-band frequencies.
An examination of the current A05 HFCC schedule will reveal that approximately
40% of the frequency-hours used by U.S. private broadcasters are out-of-band
frequencies authorized on a non-interference basis. It is a concept
based on the sharing of HF spectrum that has worked well for twenty years.
In the last year, however, there have been numerous instances of stations
being displaced from out-of-band frequencies that were shared by the private
broadcaster for many years. This is a tremendous hardship on any station.
It is particularly difficult for a small 100 kW (or less) station that
relies upon out-of-band frequencies to allow their signals to arrive at
their target areas without the competition of strong co-channel or adjacent
channel interference from powerful government-funded international broadcast
stations.
A few private broadcasters have 250 kW and 500 kW transmitters with
sophisticated antenna arrays that allow greater flexibility in the choice
of frequencies and can compete with government broadcasters in the selection
of suitable in-band frequencies. However, even these more powerful private
broadcasters sometimes use out-of-band frequencies due to the intense competition
in the international frequency coordination process. Nearly all of the
twenty-five private broadcasters use out-of-band frequencies for a portion
of their broadcast day and some smaller stations use out-of-band frequencies
exclusively.
Two primary factors threaten the continued use of out-of-band frequencies.
One is the natural technological advancement in HF Communications techniques
that will result in more intensive use of the available spectrum. HF e-mail
and other digital data technologies will present new pressures for spectrum
use by Fixed Services and Land, Aeronautical and Maritime Mobile Services.
It may be several years before the analysis of these needs can be properly
placed in a document for consideration at a WRC conference.
The greater threat to the continued use of out-of-band frequencies
is the result of the terrorist attacks of September 11, 2001. Several U.S.
government agencies are drafting plans to protect America from future attacks
by reclaiming HF spectrum previously shared with U.S. private shortwave
broadcasters. The Department of Defense, Homeland Security, Federal Emergency
Management Agency (FEMA), the Justice Department and other local jurisdictions
are rediscovering HF. Many of these government agencies are re-asserting
their inherent right to these out-of-band frequencies whether they actually
need them or not. There is no effective argument to be made by a private
broadcaster that can trump the national security interest.
Many out-of-band frequencies are being lost. It is increasingly difficult
or impossible for the private broadcaster to find a new one. The
status quo has that has served us so well for the last twenty years was
forever changed by the events of September 11th. In WRC-03,
the NASB supported efforts to expand the in-band HF broadcast spectrum
between 4 and 10 MHz by at least 250 kHz. The catch-22 in supporting such
expansion is that if successful, the result may be the curtailment of the
authorization of any out-of-band frequencies. The cure could be as bad
as the illness.
Opponents of expanded frequencies for HF broadcasters are carefully
searching the shortwave bands and comparing the actual frequencies used
with the HFCC coordinated database. Whenever an unused frequency is found
that has been coordinated for use; it gives ammunition to these opponents
that the industry does not need additional frequencies. It is vitally
important that all broadcasters actually use all the frequencies they have
coordinated. These unused frequencies known as “wood” should
be released in the database to other users.
It should be noted, that in the event of a national emergency that
results in the activation of the Emergency Alert System (EAS); all U.S.
licensed private shortwave broadcasters are required to cease transmission
during the period of an Emergency Action Notification (EAN) issued by the
White House. In addition, the FCC can order any station to leave the air
on an individual basis at any time. Shared out-of-band frequencies used
by private broadcasters can be made immediately available to government
agencies if the need arises.
The National Association of Shortwave Broadcasters must have a voice
in forums that will affect our future. This point was stressed during discussions
at our annual meeting in Washington. We plan to participate in the IWG-4
meetings to develop the U.S. position for WRC-07. On June 16th, our legal
counsel Ed Bailey represented NASB at the IWG-4 meeting in Washington DC.
In the future, the NASB intends to send a representative to as many meetings
as possible.
As the IWG-4 meetings progress, the NASB must determine the likelihood
of U.S. government support for band expansion. We must preserve the availability
of spectrum for our use in the solar minima of the next sunspot cycle.
We must determine the continued viability of out-of-band authorizations
and work to protect our shared use of those frequencies on a non-interfering
basis as we have for the last twenty years.