Petitions Run Neck in Neck

[John Holotko]

Both petitions RM-11305 and RM-11306 are both running neck and neck percentage wise with respect to the number of people who files comments on each. Based on the daily stats provided on this page we have:

          RM-11305:  14% For  86% Against
          RM-11306:  17% For 83% Against

With these results shouldn't both petitions be sent home packing ? How could anyone do rulemaking on these results ??

[Bill, KD0HG]

John, it's not a *vote*.

[John Holotko]

John, it's not a *vote*.

Yeah I know, but the fact  that  the vast majority are against the proposal will likely also be reflected in the comments. Therefore isn;t  the vast majority of commentary the FCC has to look at going to be negative with regard to what has been proposed ? And if so how to they establish a basis by which to rule on these proposals if the vast majority of comments are negative  and in opposition ? Otherwise why have a comment filing period at all ? From what I have been reading on this board it seems that  quite a few people  wanted comments files against  RM-11306. Well it seesm that is exactly what we got so far, and by a  very large margin percentage wise.

I admit I am still quite ignorant of how the FCC's rulemaking process works. I guess I'll learn at things move on.
 

[K1MVP]

Both petitions RM-11305 and RM-11306 are both running neck and neck percentage wise with respect to the number of people who files comments on each. Based on the daily stats provided on this page we have:

          RM-11305:  14% for  86% Against
          RM-11396L 17% For 83% Against

With these results shouldn't both petitions be sent home packing ? How could anyone do rulemaking on these results ??

John,
Question is, will the FCC "see" this as a "microcosm" of REAL ham feelings on
these Bandwidth issues and "tell" the ARRL to "go back to the "drawing board"
or will they(the FCC) "coddle" to these guys in Newington?

Believe, me--when I wrote my comments to the FCC (at the "eleventh hour")
I felt like telling the FCC to tell the ARRL to go back to the drawing board.
Although,--thats basically what I did in "politically correct" terms.

I would like to thank Gary,(INR) for REALLY bringing this issue "to light" on the
amforum,--if the ARRL had really tried to bring these issue before the average
ham, rather than behind "closed doors", or had they not put their "own spin"
for obvious reasons,--then we would not be in this "mess". IMO
 
                                          73, K1MVP
 

[Pete, WA2CWA]

If the FCC rules favorably towards RM-11305, I don’t think the ARRL would have a problem with that. The fact is all that they really want is mode restrictions lifted so that any new modes that come down road for experimentation, amateurs will be free to use them on the HF amateur bands. The bandwidth idea was put in to provide some order and not turn the bands into entire unruly areas. I’m sure the band plans that they plan on developing, would be easy modifiable under either proposal acceptance. Plus, under the “any mode – any where” plan, a centralized source for coordination would likely fall into their laps anyway. Either plan makes them the central player which is probably also why you haven’t heard any negative comments from the ARRL staff in regards to RM-11305.

As in the most recent proposals just past, put forth by 18 different submissions, the FCC choose to accept only one idea/change from all of them. The FCC can accept and push forward a proposal in its entirely, pick specific proposals or ideas from within a proposal, or reject them in their entirety, and then choose to take their own rule making actions based on their own internal inputs.

[John Holotko]

I guess ultimately whatever will be will be. All in all I doubt the comments I made, not the comments anyone else made matter very much. Collectivly they might have some small impact but ultimately the FCC will do as they see fit. It's not anything I would loose any sleep over. Even if the FCC were to end ham radio tomorrow I'd probably miss it but then there are lots of other interesting things to do. Ham radio is just  one of  many.

[K1MVP]

I guess ultimately whatever will be will be. All in all I doubt the comments I made, not the comments anyone else made matter very much. Collectivly they might have some small impact but ultimately the FCC will do as they see fit. It's not anything I would loose any sleep over. Even if the FCC were to end ham radio tomorrow I'd probably miss it but then there are lots of other interesting things to do. Ham radio is just  one of  many.

I DO agree with you John,(as I have said before in one of my previous posts)
that the FCC will do what is "expediient" for themselves, as they will want to
"streamline" the service for obvious reasons,--less "manpower", less "resources"
 to work with, and little if no time to "chase" those who "break the law".(what law?)

I still feel that they will go the "pragmatic route" and further go down the
road to "streamline" ham radio,--which will include more of the "dumbing down"
of the service, which will ultimately lead to a "single class" license and ultimately
to "type acceptance" equipment.IMO

AS far as not hearing anything "negative" from the league,--of course you would
not,--they are in the business of "selling" stuff, and we all know you cannot
sell anything in today`s world,(as any salesman knows) by telling someone what
is "wrong" with the product one is selling.

At the very least,--one must "withold" from the customer any defects that are in the product.
And so, in the end,--it`s what they DO NOT tell you that can "kill you", or "them".
The " powers that be" will call this "progress" in the 21st century.
                                       
                                         73, K1MVP

P.S,--you are right there are other things besides HR in this world,(thank God)
 

[AG4YO]

Whatever the FCC's action, the tally on comments showed that Amateurs don't want this.  Many people fond of saying "but the comments are not representative", yet wherever I talk to Amateurs on the air I find out:
 
1. They know nothing about this.
2. They are against the petition when they read it.
3. They are not happy with the ARRL.

There is no arm twisting necessary to get people to comment.  But the "silent majority" the ARRL likes to fantisize they represent are in the dark and pretty mad when they find out.  I'd even go as far as saying that the online comment system favors the digital enthusiasts.  Alot to think about for shure.

Good job to AM Fone for rallying the troops. 

[Art]

"The FCC can accept and push forward a proposal in its entirely, pick specific proposals or ideas from within a proposal, or reject them in their entirety, and then choose to take their own rule making actions based on their own internal inputs."

. . . 'just like the . . . . oh, never mind ..  .

-ap

[k4kyv]

I haven't scanned through the comments re 11306 yet.  But looking at the ones for 11305, I'd say there were maybe a dozen or two good solid well-thought-out comments submitted, pro- and con- combined.  The rest consisted of brief "votes" not saying much more than that they were for or against.  The vast majority of the comments "against" said approximately the same thing, expressed in a variety of ways: eliminating subband segmentation and mixing the modes would result in anarchy and chaos, with little clarification or specific reasoning to back up their opinion beyond that.  Probably the second largest group against were opposed primarily to removing restrictions on automatic/semi-automatic robots like Winlink.

Quite a few of the comments I read re 11305 were actually addressing the segmentation-by-bandwidth (11306) issue, rather than the merits of segmentation itself.  I am sure the similarity of RM- numbers, proximity of issues involved and simultaneous release times led to considerable confusion. 

[Art]

Hey sports fans . . . again . .  if '06 and '05 are a problem for you, and you believe some change is in order to accommodate new licensees, would you support the IARU Region 2 band plan?? It does provide segments and for a reservation for digi ops as well as more room to operate.

For those who don't know what it is, here you go . . .

IARU Region 2 HF Band Plan

(This BAND PLAN was approved by the XIII General Assembly of Delegates of IARU Region II held at Porlamar, Margarita Island, Venezuela from
September 28 to October 2, 1998)

1800 - 1830 CW, Digimode
1830 - 1840 CW, Digimode
                   (DX CW window)
1840 - 1850 Phone (DX Phone window) - CW         
1850 - 2000 Phone - CW

3500 - 3510 CW (DX CW window)
3510- 3525 CW
3525 - 3580 CW, (Phone permitted, non interference basis)
3580 - 3620 Digimode, (Phone permitted, non interference basis), CW
3620 - 3635 Packet Priority, (Phone permitted, non interference basis), CW
3635 - 3775 Phone, CW
3775 - 3800 Phone (DX Phone window), CW
3800 - 3840 Phone, CW
3840 - 3850 SSTV, FAX, Phone, CW
3850 - 4000 Phone, CW

7000 - 7035 CW
7035 - 7040 Digimode with other Regions, CW
7040 - 7050 Packet with other Regions, CW
7050 - 7100 Phone, CW
7100 - 7120 Digimode, Phone, CW
7120 - 7165 Phone, CW
7165 - 7175 SSTV, FAX, Phone, CW
7175 - 7300 Phone, CW

10100 – 10130 CW
10130 – 10140 Digimode, CW
10140 – 10150 Packet Priority, CW

14000 - 14070 CW
14070 - 14095 Digimode, CW
14095 - 14099,5 Packet, Digimode, CW
14099,5 - 14100,5 IBP/NCDXF
14100,5 - 14112 Packet, Phone, CW
14112 - 14225 Phone, CW
14225 - 14235 SSTV, FAX, Phone, CW
14235 - 14350 Phone, CW

18068 - 18100 CW
18100 - 18105 Digimode, CW
18105 - 18109,5 Packet Priority, CW
18109,5 - 18110,5 IBP/NCDXF
18110,5 - 18168 Phone, CW

21000 – 21070 CW
21070 – 21090 Digimode, CW
21090 – 21125 Packet Priority, CW
21125 – 21149,5 CW
21149,5 – 21150,5 IBP/NCDXF
21150,5 – 21335 Phone, CW
21335 – 21345 SSTV, FAX, Phone
21345 – 21450 Phone, CW

24890 – 24920 CW
24920 – 24925 Digimode, CW
24925 – 24929,5 Packet Priority, CW
24929,5 – 24930,5 IBP/NCDXF
24930,5 – 24990 Phone, CW

28000 - 28070 CW
28070 - 28120 Digimode, CW
28120 - 28189,5 Packet priority, CW
28189,5 - 28190,5 World Wide Beacon Network #2
28190,5 - 28199,5 Intra-regional Beacon Network
28199,5 - 28200,5 IBP/NCDXF
28200,5 - 28225 Beacons, CW
28225 - 28670 Phone, CW
28670 - 28690 SSTV, FAX, Phone, CW
28690 - 29300 Phone, CW
29300 - 29510 Satellites
29510 - 29700 FM Phone and Repeaters

FOOTNOTES :

1.    CW is permitted on all frequencies but is exclusive where shown.
2.    Digimode refers to the digital modes RTTY, AMTOR and Packet (including new systems like PACTOR andCLOVER).
3.    NB (narrow band) includes all digital modes.
4.    RTTY includes all digital modes.
5.    Some operating frequencies may not be allowed in certain countries or may be shared on a secondary basis.

PURPOSE OF THE IARU BANDPLANS

The IARU bandplans have been compiled and modified over the years to reflect changes in operating requirements and are to be used as a guideline by the individual societies of each country. Unique situations in certain countries may require slight modification to that individual country's own bandplan but the impact of any changes must take into consideration their effect on other countries.

[w3jn]

So the IARU argument that some presented in opposition to 305 is somewhat specious in that the present FCC regulations are in direct violation of the IARU bandplan.  Why not run phone down to 3635 and 7050?

[Tom WA3KLR]

"Why not run phone down to 3635 and 7050?"

That's what I recommended in my RM-11305 comments. 
And cut the Novice bandwidth down to 25 kHz. from 50 kHz.

[Pete, WA2CWA]

The ARRL's proposal in many ways follows the ITU Region 2  band plan for most of the HF bands. As an example, in the proposed ARRL plan, phone is allowed from 3620 to 4000 KHz.

[Art]

There we go . . . now all we need to do is clearly define data, or any transmission must check the frequency before transmitting and be identifiable by a common receiver with BFO.
This would: align the US with other region 2 countries, restrict data to defined areas, permit all modes of operation as currently defined to operate within their defined areas,  eliminate the rather contentious bandwidth and chaos concerns, and provide growing room for the future.

. . .  and you imply this is what the ARRL intended, or is in the process of actually suggesting,  Pete?

-ap.

[Art]

But then . . . that isn't what you said, is it . . . sorry, your statement confused me for a minute.

"The ARRL's proposal in many ways follows the ITU Region 2  band plan for most of the HF bands. As an example, in the proposed ARRL plan, phone is allowed from 3620 to 4000 KH"

3620-4000 does not equal 3525-4000 . . . and I bet thats just the start of the differences between the ARRL output and R2 bandplans . . . oh well . .

The real cliff hanger is bandwidth as a function of definition of mode. No matter what the ARRL proposes, if they insist on bandwidth as a determining factor I think it is unlikely to succeed.

-ap

[Tom WA3KLR]

The IARU bandplan for Region 2  does allow phone all the way down to 3525 on a non-interference basis with CW.

[Pete, WA2CWA]

"proposal in many ways"
ITU Region 2:
3525 - 3580 CW, (Phone permitted, non interference basis)
3580 - 3620 Digimode, (Phone permitted, non interference basis), CW

Yep! Good operating practices and those "gentlemen's agreements" again. Would work well for U. S. (check Phil for a bridge sale). Or maybe the ARRL is more sensitive to the incompatibilities of narrow band digital and analog modes operating in this area.

[Art]

Good point, the non interference is implicit on all frequencies though, so such terms are a good reinforcement of operator responsibility. If there is a cw QSO in process, obviously, one wouldn't start a QSO on top of it. it's the gentlemanly thing to do.

-ap

[John Holotko]

Gentlemanly agreements and gentlemanly operating practices don't work in the US. They only work in foreign nations.

[Pete, WA2CWA]

Gentlemanly agreements and gentlemanly operating practices don't work in the US. They only work in foreign nations.

"They only work in foreign nations" and on VHF/UHF frequencies except during band openings and contests.

And where's all this great 160 "gentleman" behavior. I heard joe, IBX, tell someone earlier in the week that the frequency was in use when someone fired up on his QSO frequency and, the other night when Phil was doing a transmission, someone fired up 2 KHz away and called CQ twice on SSB. During the evening hours, there always seems to be stations hassling each other between 1980 and 1995.

[John Holotko]

Gentlemanly agreements and gentlemanly operating practices don't work in the US. They only work in foreign nations.

"They only work in foreign nations" and on VHF/UHF frequencies except during band openings and contests.

And where's all this great 160 "gentleman" behavior. I heard joe, IBX, tell someone earlier in the week that the frequency was in use when someone fired up on his QSO frequency and, the other night when Phil was doing a transmission, someone fired up 2 KHz away and called CQ twice on SSB. During the evening hours, there always seems to be stations hassling each other between 1980 and 1995.

There is no band plan that  is going to prevent things like that from happening. Just the other morning I fired up on 3873 mc with a few guys and a minute  later Dave/W2APE had to come  on frequency and request  I  move because we were  clobbering a few QRP stations he was in QSO with a few kc's down the band. I couldn't hear them because I had a very high local  line noise at  the time, otherwise I would have not  fired up where I did.   Had I known they were in there I would not have fired up where I did. As soon as Dave made me aware of the problem we  moved.

In the case of the SSB station did the station move once  Joe made  it clear he was causing interference  to a QSO in progress ??
My point being for laziness or or failure to  listen to who is on freq or nearby BEFORE transmitting, or, perhaps for legitimate reasons such incidents will  happen regardless  of band plan.
 

[Art]

"There is no band plan that  is going to prevent things like that from happening. "

Bingo!! If we enact regulations based on the premise they will prevent unintentional OR intentional interference we are deluding ourselves. Then the only people who are 'regulated' are those who don't need it in the first place (the vast majority).

[Art]

""They only work in foreign nations" and on VHF/UHF frequencies except during band openings and contests."

I have never had a problem conducting a conversation with a friend even during a VHF/UHF contest. (There are a few ops I only find on during such events.) FM calling frequencies are respected.  Band occupancy is high but civility is the order of the day. Sure there are a bunch of mountain toppers calling CQ contest but there is plenty of room because only a small part of the bands is CW/data specific. Occasionally there is a propagation shift and more distant stations find themselves on the same frequency as other ops . . . then someone moves . . . 
All this without the pie being cut up into regulatory fiefdoms and all this in North America XE, VE, W . . . all living, communicating, and working together. Great example!!
Pete, I don't find you in my VHF/UHF logs for the past couple of decades. Have you operated any VHF/UHF contests?

-ap

[wa2zdy]

Gentlemanly agreements and gentlemanly operating practices don't work in the US. They only work in foreign nations.

And I wouldn't bet that they work so well there either.  There are just so many fewer hams in other places that we don't have issues with them.  There was a post on qrz.com this mornng from a G station who said the bandplans there are totally ignored on VHF/UHF.   So who knows what the rest of the world is dealing with.

As I've said many times now, the phone bands need to be expanded.  To deny that is ludicrous.   But anarchy is not the answer either.  And I know (now) that many in the AM community are in favour of 11305.   Yes, ta would give you more room, but would you really fire up an AM roundtable on . . .  say, 3550?    I don't see any of you felows doing that.   11305 will be a disaster of major proportions, which might be exactly what FCC wants.