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.