The AM Forum

The loosely kept secret proposal to deregulate the amateur service bands was submitted to the FCC today.

Many have asked why the group worked in the rather reclusive way we did. Each member of the Communications Think Tank was tasked with acquiring a sense of a group of amateurs and bringing their input and impressions. The members of the AM board were represented by CTT members who, often somewhat blatantly, solicited input for the proposal. Maintaining focus through the chaos of data acquisition, numerous iterations, battles royale, compromise, editing, and final submittal was a real challenge and would have been multiplied many times over if we attempted this with a larger group.

I wish to personally apologize to any who felt slighted by this process and on behalf of the CTT thank all those who freely gave their opinion and helped shape the proposal.

The link to the proposal is: http://www.geocities.com/k3xf/Rver124F.pdf

All the best,
Art

Thank You Art,

 Bravo men, well done, and I'm very glad to see Paul VJB was in the mix, I miss him dearly on the Forum here.

I've always felt that Techs shud have, had, full priv on 10 meters but well it never surfaced and I guess Techs and Gens are going to be combined in the future, as I understand it, so somewhat this is a gud thing, Time marches on.

I do hope the powers that be think in the Dynamic and Not in the Unpragmatic past in considering this proposal.

wishing this gud luck fellas.

Thanks Jack. I appreciate the positive comments.

The bottom line is all classes of license can use any mode on any frequency  permitted by their license class. That includes novices.

This is truly a bid for freedom of movement and selection vs predefined territories for different modes. The constraint of people or action has never worked in US history on an ongoing basis.

If there are any questions about specific sections or about the proposal itself I will be pleased to provide whatever help I can.

This will be a difficult journey to rule making and your support is critical.

-ap

Hi Art

I have just spent the last few hours going over the document.

I recommend that all that visit this site invest a few hours of time  into your hobby. Read the proposal. This document outlines a  valid direction this hobby could  take.

Art could you give us an idea of what is next in the process? How does this end up in rule making etc etc?

Gary

Thanks Gary. A lot of thought went into the proposal and we hope it encompasses the majority of opinions and concerns about band planning. The FCC process can be complex but some times it can also be fast tracked:

Plagiarized from the FCC;

Knowing one’s NOIs, NPRMs, and R&Os is key to understanding the Commission’s decision-making process. Below is a guide to understanding the "alphabets" of the FCC.

Notice of Inquiry (NOI): The Commission releases an NOI for the purpose of gathering information about a broad subject or as a means of generating ideas on a specific issue. NOIs are initiated either by the Commission or an outside request. In our case we are an outside request.

Notice of Proposed Rulemaking (NPRM): After reviewing comments from the public, the FCC may issue a Notice of Proposed Rulemaking. An NPRM contains proposed changes to the Commission’s rules and seeks public comment on these proposals. This is the best opportunity to express your views and support for the proposal.

Further Notice of Proposed Rulemaking (FNPRM): After reviewing your comments and the comments of others to the NPRM, the FCC may also choose to issue an FNPRM regarding specific issues raised in comments. The FNPRM provides an opportunity for you to comment further on a related or specific proposal. This is where we address the concerns brought to NPRM.

Report and Order (R&O): After considering comments to a Notice of Proposed Rulemaking (or Further Notice of Proposed Rulemaking), the FCC issues a Report and Order. The R&O may develop new rules, amend existing rules or make a decision not to do so. Summaries of the R&O are published in the Federal Register. The Federal Register summary will tell you when a rule change will become effective.

Changes After the R&O

Petition for Reconsideration: If you are not satisfied with the way an issue is resolved in the R&O, you can file a Petition for Reconsideration within 30 days from the date the R&O appears in the Federal Register.

Memorandum Opinion and Order (MO&O): In response to the Petition for Reconsideration, the FCC may issue a Memorandum Opinion and Order (MO&O) or an Order on Reconsideration amending the new rules or stating that the rules will not be changed.

It's a long strange road but this proposal will update our frequency allocations and provide flexibility. Yesterday and todays modes will be used as long as there is amateur radio. New and cutting edge modes will come and some go. It will put the power to decide in the hands of the operator. . . .the power and the responsibility.

I have read through the proposal.  Looks like a lot of thought and hard work was put into it.

The one thing I don't like about it is that it proposes to retain subbands by licence class.  With recent dumbdowns and more to come, incentive licensing has become a joke, and segmentation by licence class no longer serves any useful purpose (I'm not sure it ever did).  Besides, from the outset, it was a dismal failure in terms of its stated goal, to increase the technical competence of the amateur radio community.

I say get rid subbands altogether, once and for all, including General/Advanced/Extra class segmentation.

Hi Don,

Your point was discussed at length early in the process as we were hashing out exactly what the goals were to be. Although doing away with license classes was an agreeable point, we felt sticking with the All Mode All Frequency target should be the thrust of this petition.

IMHO, burying incentive licensing is a battle for another day.

Let me take this time to say thank you for your comments.

I just read the proposal and it is obvious a lot of good hard work and thought went into it.  

I agree with it almost entirely.  I say almost as being a CW op, I fear there may be no holding back the slopbucketeers when they see the wide open spaces of the CW band as a place to colonise.

The other thing I see is that the proposed priviledges for Generals restrict them to 7025-7150 (page vii.)   I'm hoping that's a misprint that didn't go to FCC.  Taking 75 kc off the top wouldn't make anyone any friends.

I have to say looking at the credentials of everyone involved is impressive.  There can be no mistaking this group for a bunch of tobacky spitting ragchewing skipshootin ratchetjawed salami radio ops.  Well done gentlemen.

I read it last night when it hit the AM reflector.  I'll post my reply to Paul to you other jabrones:
Paul,
    Not too bad for a bunch guys "drinking Old Grand Dad by the bucket load and listening to rap music. In a nut shell, I see that you are demonstrating to the FCC to set the bands up pretty much like 160M with boundaries based on license level. To me it seems like a well organized docket spelled out in "lawyer-eeze". Which I think the FCC will understand. Pete is just upset that this didn't come from the stodgy stuff shirts up in Newington but rather from a group of amateurs who are tired of asking for a giraffe and winding up with a zebra!
Good job!

The biggest weakness I see in the proposal is the nature of any proposal made by a small group of people: It can be slammed for representing only small group of people (much like the proposal made by a few so called weak signal snobs for 160 meter exclusive frequencies a few years ago). This is why individual comments to the FCC are so important. If this proposal makes it to the NPRM stage, individual responses/comments will make or break it. Don't sit back and let others do it - ARRL or otherwise.

It Never Hurts to try, if anything it will add to the light that there are some growing pains that need to be addressed.

Any modification to part 97 we provided was an 'example'. The members of the team have technical credentials for the most part and did not intend  to precisely define the changes to part 97.
However, the concept, nicely articulated by Mikey, is to create a band plan independent of mode and based upon the frequency allocated to ones license class. A lot like 160. BTW Do is an "abbreviation" for ditto. Don't ask me how that works. . . it's FCCese. Yes, novices would have voice privileges in their section of the HF bands.

My opinion, being a part time CW op, and a long time life member of the ARRL, and fairly suspicious of actions that don't benefit the membership . . . I think there is a movement to allocate the 'underutilized' CW bands to bots and digital and force CW to live with it. This proposal will go a long way toward defense of the bands for all mode use and establishing a non interference emphasis in operation.

Now whar did I leave my chaw . . .


-ap




=ap

I think you point out a valid obstacle here Steve. Any "group" of hams will have an uphill battle with petitions given the history the League has in Washington. Say what we will about the League, but the fact remains they have been "Amateur Radio" in Washington for sometime now.



Bravo ..... and this is where we have the chance to demonstrate that the ARRL no longer speaks for the majority of hams.

You hit the nail on the Head Chris. That's reality.

Art commented.... "I think there is a movement to allocate the 'underutilized' CW bands to bots and digital and force CW to live with it."

For the good of amateur radio? More like, to put the nail in the coffin of amateur radio...




(http://www.fists.org/fistkey.jpg)

Glenn. . . .this comment is well beyond the scope of the proposal:

Whether a mode is the most popular, 2nd, 3rd, declining in interest or increasing.

Why should one mode have an exclusive section of an amateur band?

It may be your favorite but it isn't the favorite of the amateur population in general. The ARRL has seen to that.

Bandwidth is an absurd premise. I can operate CW in the middle of the evening in the 'phone' bands. It takes skill and narrow filters. However, I can't operate phone below an arbitrary and obsolete line in the band. Does that make sense?

Absolutely not. I like CW almost as much as AM, but I've never understood this. Sure, there are CW ops in those chunks of band almost anytime you listen...but how many? Compare them to the phone bands and you can see why some are worried at the way the spectrum is under-utilized. It also bothers me that AMers have always been expected to adhere to the AM windows while SSB ops haven't been equally expected to stay out. Something like 'voluntary segregation by the AM community' is what I think I read somewhere. IMHO, this type of thinking is what has helped lead to ideas like the 'special AM exemption' which can more easily be revoked at a later date.

It's time to stop favoring any mode and let them all receive equal treatment. It should only be about amateur radio, not this mode or that. AM and CW deserve just as much consideration as SSB or any digital modes. Supporting special rights opens it up to selective inclusion for future rulemaking.



If it does get that far, we really need to rally to the cause and get as many folks as possible to participate. I mentioned this to Paul in my response to him yesterday. You can bet that the bandwidth crowd will be fighting tooth and nail to defeat it.

I doubt it will make it to the NPRM stage on its own.  But it likely will be assigned an RM- number, which will open the petition to public comment.  Most likely, its ultimate disposition will be to combine this proposal with a long list of other petitions on related issues, including the ARRL bandwidth proposal, numerous pro- and anti-Morse Code petitions, Novice "refarming," etc, in the release of the major restructuring NPRM the FCC has been promising for a couple of years now.  But this petition might very well have a substantial influence on whatever NPRM the FCC finally presents to the public, pushing them a little more in the direction of at least partially dismantling the complex matrix of subband segmentation that exists today.  Hopefully, the FCC rulemakers will see this as a reasonable alternative to the ARRL bandwidth proposal.

Never said anything about "bandwidth"...



You mean like AM?



I've said before, I'll say it again, skill and narrow filters aren't going to help you when a 1KW SSB station plops down right on top of your 5 watt CW qso. Having a SMALL segment of the band (is 25khz too much to ask for crying out loud?) dedicated for CW use makes the most sense.

Change SSB to CW and you still have the same dilema. A 1KW ANYTHING station will do the same. Besides, this senerio is already covered by existing regulations concerning "good amateur practices" AND those concepts are well mentioned in the proposal !

Because CW is a non-voice mode it will not receive equal treatment when placed in the same "space" as SSB.

I don't think it is unreasonable to allow a measley 25khz at the end of the band for CW operation.

The dumbing-down and de-regulation of the licensing structure has already seen to the end of "good amateur practice" ya know? issues like which way to put in the resistor, or where do I buy a dipole?

"The dumbing-down and de-regulation of the licensing structure has already seen to the end of "good amateur practice" ya know? issues like which way to put in the resistor, or where do I buy a dipole?"

Yeah, I gotta agree with you there.

The problem is, if we set aside 25KHz for CW we have to answer why we don't put 25KHz aside for PSK, or AM, or FM, or SSB, or ESSB. Then we wind up with a whole lot of administrative, enforcement. and operational BS. All this to try to legislate good amateur practice which cannot be done.
 
I can safely say I can always find a spot to carry on a CW contact. There are plenty of times when I cannot find a spot for a phone contact. Yet, 50KHz down the band nothing, but Canadians operating phone.
That doesn't make sense to me.

-ap

Good point Art, that is a dilema, I hate to use the "B" word, but since CW and digital modes are very narrow by nature,....

wouldn't it be simple... 3.50mhz - 3.525 = CW only, 3.525 - 3.550 = digital modes... everything else "The phone band" ?

This not only eases the crowding on the present phone bands but also makes it very easy to regulate and enforce...

Don't forget, I'm the CW guy who's saying reduce the size of the CW bands... (don't shoot the messenger :oops: )

Don't worry . . 'left my .44 in the filing cabinet . . .

you make a good point and the end product may well provide for just such a slot for CW in the regs.
I would like to think we could agree as amateur ops to keep that bottom 25Kc for CW . . .  'a gentlemans agreement . . .

-ap

Art & Glenn -

My thoughts on having an open band with no favoratism shown to any mode wouldn't mean that I'd see fit to go plop down between CW stations for an AM contact. But if things were noisey in the current phone band and there was little/no operation down there, why not make use of the space? I'm not the type to lay claim to a frequency, take up residence, call a Net or whatever else. But as you pointed out, Art - the canadians are already using it and the CW stations seem to get along fine?

Glenn, my remarks about treating one mode differently than another are more about making some special exception or exemption as the new warm-fuzzy of choice. I have the distinct feeling that once they single you out for anything, it's just a matter of time until they cut your mode out of the picture entirely. One could think that making something an exemption could also make it easier to dispense with since it isn't really covered in the same way everything else is. I'd just like to see the same rules apply to all modes, which makes it a whole lot more difficult to single out one for exclusion. They (FCC or ARRL) should treat all modes the same: as modes of communication, nothing more or less.

Like AM, some out there would like to see CW eliminated entirely because its "old" or "unnecessary" or whatever other lame excuse they can come up with to cover the fact that they just don't like it. Making CW stand out in a way that it appears to be taking up space it isn't utilizing well just gives them more fuel. I think that opening the band up and keeping an understanding that the lower portion of the band would be a CW window of sorts would work fine, with the understanding that ops could utilize it just as SSB stations use the AM window when there are no AM stations on. Nevermind that they do it when there are AM stations present, nothing will prevent the lids from being lids.

~ Todd 'KAQ

I too would like to believe we could agree to at least keep the first 25kc for CW ops, however I'm not as optimistic as I use to be  :?  and I don't think turning the ham bands into a free-for-all is the answer either.

It's a mystery as to why the gentleman's agreement works on 160 meters. I have a bad feeling that if the lower 25kc or 50kc of 80 or 40 meters were legal for phone operation, that some slopbucket candystore net would set up shop there..... or worse, some clown who's name escapes me, would start broadcasting there.  :evil:

Judging from past proposals and FCC actions, when all is said and done, I have a strong feeling things will remain exactly as they are right now

Glen said:
I had thought  about this too. The only reason I could come up with is that making an antenna needs alot of land (to have any efficiency). Most people don't go thru all the trouble to put up a large cumbersome array just to jam others. Please note that I said MOST.

You are correct Don, and that is what I meant. When we have a chance to comment, we need to be heard - for, against, don't  care - but speak up. As Buddly noted, this is one good way to show the FCC there are other 'voices' besides the ARRL.

From a previous post I made on the subject.

Welp, just like the insurance debacle, Why do I Need an all consuming out of control bureauacy to be the only representative of my interests. Why can't I go straight to the caregiver with my money and my interests and make a deal Directly, think of what it would do for industry to deal directly with the caregiver.

The premise is the same be good for the hospital, be good for me and mine and be less hasstle all the way around.

If the Though today is what "I" have to do, then "I" should have and assume all control, and voice my matters directly.

OK.... as long as we're reserving spectrum for our little pet modes;

I want 50 Khz on every band to operate AM with 6 KW so I can run 1500 watts PEP on USB like the slopbuckets do !! (is 50khz too much to ask for crying out loud?)

Now everybody put your request in and let Riley sort it all out !!

No.... the "here's your frequencies and this is your power limit" approach is the only equitable structure. It gives all modes equal access. If someone chooses to use qrp cw that's HIS choice. But why shud I put up with overcrowded conditions nite after nite while the vast majority of the cw spectrum goes un-used ?

That's why I suggested REDUCING the cw band and INCREASING the phone band.... There's your answer to overcrowding.. not your knee-jerk reation of take it away completely!

Oh... I understand now Glen.

Expand the phone portions to qrm the novices, rtty ops, PSK ops, SS ops, DX split ops, packet ops ect ect .....
but leave my cw alone !!!

There's an Equitable solution !

Re-read my comment from previous post...

"3.50mhz - 3.525 = CW only, 3.525 - 3.550 = digital modes... everything else "The phone band"

YES! that is a very equatible solution! Since Phone ops consume the most band space and since phone operation is the most popular mode, without question the phone band should be expanded and the CW band reduced... NOT forced out...

Fortunately, there are very many active CW operators thet feel the same way.

Very well put Mark!

As always, good observations. There will be huge resistance from those who believe their ox is being gored or insufficiently fed. . . there always is. Such views seldom include the betterment of the service.

As for the absence of regulation making gentleops of those who are not . . . well, if the regulation which exists doesn't create those changes why would you expect this proposal to perform such a miracle? Do you think the ARRL proposal/band plan/rumored change/someday thing will? Well, if more regulation won't change the behavior, and less regulation won't change the behavior, at least let's provide more room to tune off . . .

'a magic potion or regulation that will solve personal interference  problems and/or provide exclusive use of the amateur band for any particular use?. . . . . news flash, this proposal ain't it . . . it allows for more efficient utilization of the resources we have. . . and probably  reduce some operational problems due to overcrowding.
 

-ap

On a psycho level... people living in overcrowded cities tend to be more irritable and violent.

Are there violent people inthe country? Sure !
But, in general, people in the wide open spaces tend to be more .......
neighborly !!!



 Nature of Human Behavior  (http://jrscience.wcp.muohio.edu/reflections/FinalArticles/TheNatureOfHumanAggressio.html)

Good Evening Everyone,


I always like to know how, point being that 99% of the board agrees to this what's being discussed here, that it is said that we're Wrong. That just amazes me. I've seen first hand here some of the Stations that are in the posession of most of you men and then i look on QRZd or Eham or just any old place and weight the difference, and I look at the Some of the license holders of today and the actions of some Extras, and I look at the actions of the powers that be, Some where along the line i keep coming up with head scratching and when i start to do that well they're in trouble, they just haven't convinced me.

ya know something gang. . . if you look deep into yourself . . remove the self interest and think of the good of the service . . . you will know this is the right thing to do . . . lot's of people are fearful they will be strapped on their frequency by someone using an alien mode . . .  well one ops poison is anothers Fosters . . .  use a little nail polish remover on the super glue you have on the VFO and go where you can do what you want to do.
The proposal doesn't change ops or human nature. It provides more ways to go and more efficiently uses the precious resources we have . . .
That is a good thing . . . you know it . . . I know it . . . we all know it. . . .

-ap

Thanks Phil. I have been barraged with the opinion that US amateur radio operators are inferior and cannot behave themselves unless they have the sword hanging over their heads. . . .
I am reassured to know the opposite opinion also exists.

-ap

Well FWIW I feel this is the most progressive and sensible recommendation to come from ANY organization or person. Cripes! The CW ops have a whole band to theirselves on 30M. Along with the opportunity to operate on all amatuer bands. Forget the cultural notion about animals being holed up together in tight quarters. This just makes sense! Period!! And as previously stated, its not perfect, but its a start!

I'm actually quite happy a proposal like this didn't come from them. The essence of the proposal, "here's your band edges; play like nice people". The terms CB, "wild west", and badlands all come to mind. A proposal with 600,000 (or whatever the number is today) amateurs trying to do self-management of their operating and operating habits on the HF bands is quite a stretch. To believe the FCC, with their current manpower, and OO's(this was good) could manage the probable chaos is even a further stretch.

If the FCC does move to request comments on this proposal, and if the ARRL does file their proposal, and if a third proposal also makes it to the FCC, amateurs will definitely be able to make clear distinctions between them.

Art, I'll assume you're reading this;
error in your(CTT) proposal under 97.301 chart for amateur Extra, ITU Region 1:
40 m 7.0-7.
7.what??

Thanks Pete. Good eyes. . . my info from the FCC is they want the concept clear and the precise changes to part 97 will be generated during the actual rule making process. 'might mean a work day in DC for me . . don't have that i dotted yet.

As far as being different from the ARRL proposal/band plan/whatever it is today . .  to be sure it is . .  we won't be able to really compare them until the ARRL puts out something coherent. Considering the June issue of QST that may be some time.

Your opinion is definitely shared by many. However, treating US amateurs like they are inconsiderate twits, unable to coexist with their fellow amateur ops, and in need of direction to keep them from degenerating into chaos misses the mark by a long shot. . . . and does not merit US ops having regs different from the rest of the world.

Would you simply plop down in the middle of the beacon section of the band? I don't think so. I wouldn't. Most people wouldn't. There will always be those who do though but I don't think the majority should be burdened with regulation based on the lowest common denominator when the folks who populate the lowlands will ignore the regs anyway.
The result of this kind of regulation is the law abiding citizens like you have to follow the rules based on the misbehavior of a few. . . . I have said it before, that just isn't right.

-ap

Art and the rest of the CTT,
I just took some time out to review the responses of your proposal on QRZ.com. I thank you for taking the time out to explain to some of these people the reasons for its genesis. Its otherwise obvious that there will always be some scofflaws who you will never please because their sole intent is to create hate and discontent. Maintaining your composure in answering replies is a tough row to hoe. I guess there is some personal browbeating going on behind the scenes. Your choice not to respond to them in a direct manner demonstrates a hell of a lot or restraint (more than I would grant them). Moreover, it shows their cowardice not to maintain the discussion in a public forum.
I just want to thank you for taking on an issue that may seem petty to the rest of the world and getting little or no reward for your efforts. I'll chime in when I can but I'm pretty lame when it comes to legal dissertations.

Thanks Mike. I appreciate the help.
I figure we might just get some good input even from the perennial negatrons. You would be surprised how hard they will work and how much research they will do to criticise. I have noted they are multi media; posting, emails, PMs . . . if that kind of energy could just be turned to the light side of the force . . . If I can convert even one detractor it is a 100% return on the effort.

-ap

I was born in Lackawanna County.



Different country, different rules.



Yes, I'm familiar with your area.

I have no idea where you get this notion ""Americans are inferior to the rest of the world" attitude". Maybe you need some counciling. And, yes, amateur radio's future will likely change over the next 10 to 20 years as new modes come on the scene and older amateurs die off.



I'm happy for you that you like 160, but 160 does not respresent the operating habits across all HF bands.



Maybe I'll consider that when you migrate to a more liberal country.

Ghettos generally develop by the people who live there.



You make a great stand-up comedian. You should work the bars in Pittston.

Your responses, and the responses on other boards, reinforces my opinion that self-management of our HF bands would be difficult, if not impossible, to implement.

Before the
Federal Communications Commission
Washington, D.C. 20554

In the Matter of : )
) Petition for
Amendment of Part 97 of the Commission’s Rules ) Rulemaking
Governing the Amateur Radio Service )
Petition For Spectrum Deregulation in the Amateur Service

INTRODUCTION

The petitioners propose to discontinue mandatory segregation of emission modes and the activities using these modes in the Amateur Service, and substitute a voluntary system of coordination to achieve greater, and more efficient, utilization of frequency allocations within the amateur radio service bands. Spectrum utilization would be improved because amateur radio operators would dynamically select from among the entire range of frequencies available in a given band.

An important component of this change is consideration of the existing system of license classes and the desire to maintain motivation for basic licensees to improve their knowledge and skill. We propose retaining sub-bands that today recognize higher license class levels of achievement. In accord with the basic premise of this proposal, such sub bands by license class would also be permitted all modes of operation.

DISCUSSION

The proposed change addresses an imbalance in our ability to use amateur allocations in the high-frequency "shortwave" bands. Amateur activity in these bands favors voice communications (appendix A), and there is a chronic need to allow greater leeway in selecting a place to operate within our frequency range. Such flexibility is currently constrained by FCC regulations defining sub band frequency allocation by mode of operation.

The federally regulated zones do not match today's typical level of use by enthusiasts of Morse code as compared to phone operation. Digital operation is currently anomalous, neither CW nor phone. Phone use, on many bands, often exhibits signs of overcrowding. Our proposal, to discontinue the system of sub band definition by mode in the amateur service, supplies a way to address contemporary patterns of use while retaining and encouraging expansion of traditional voluntary agreements on mode utilization in sub sets of the frequency spectrum.

We believe the ideal band plan is one where good judgment on the operator's part supports use of any mode and any frequency available within their license class. Good judgment is centered on cooperative, flexible use of frequencies, with a specific goal of avoiding and/or resolving interference to others at a direct and low level, avoiding escalation and any need for outside enforcement.

Guided by the use of good judgment, removal of artificial boundaries would encourage dynamic selection of frequency, affording an operator the best chance to minimize compatibility issues with other modes and activities. This would lead to greater band "loading" and improved utilization by allowing an operator to choose a clear spot on the dial across a greater frequency range.

Intentional interference with communications is a violation of the regulations, independent of the mode in use, and whether automatic, semi automatic, or manually keyed. Sanctions would continue to be available against deliberate interference or problems involving technical signal purity, using volunteer "official observer" type programs. If a documented problem remains chronic or unresolved, the intervention of federal authority would reinforce volunteer OO in self-regulation efforts, as it does today. Automatic or semi automatic data operation not copied by the human ear becomes of particular concern under our proposal, since the activity would be unencumbered by subband. This group of users would have a specific challenge to maintain the good judgment pre-requisite by making certain their telemetry-polling systems recognize the presence of other modes and activities and avoiding interference to other communications. Chronically failing to do so would remain an actionable violation under existing rules against deliberate interference, since it could be shown such judgment had not been exercised. We contend that the goal of voluntary selection of operating frequencies for improved spectrum use is best achieved through real-time assessment of variables in propagation and radio traffic load. Efforts to improve spectrum use are currently constrained because these variables cannot be accommodated with fulltime, rigidly defined sub-bands. Additionally, contemporary technology offers interference protection at the receiver to an extent not possible 60 years ago, when protection was implemented by regulatory mandate to divide "phone" and "code" activity. Technology and patterns of use now encourage the more effective coordination that we propose.

Therefore, to address the need to improve use of our entire range of frequencies, we propose a system of coordination that enables operators to adapt to the variables of propagation, and overall levels of use, and to accommodate and cooperatively respect the footprints imposed by our various modes and activities. That is, we propose ending mode-based sub bands in the amateur radio service, and we seek affirmation of established operator responsibility against interference as part of this request for greater latitude in frequency selection.

BENEFITS

 Enhancing the Basic Purpose of the Amateur Service: This petition is centered on the premise that all operating interests and emission types enjoy equal status in the amateur service, with emergency communications taking priority. Operation of an amateur station includes a "listen before transmit" function that involves searching for a vacant spot on the dial. Recognizing that all non-emergency communications are of a hobbyist and experimental nature, we propose access to any vacant frequency for any amateur activity within the scope of privileges granted by license class. Digital experimentation and development will be encouraged in a progressive environment which allows exchanges of data, image and voice on any vacant frequency, defined as one selected to minimize the chance for unintentional interference to other operators. The DX community and others will benefit from the great reduction in use of split-frequency operation. Split refers to the use of two frequencies on the same band as a means of finding a common way to communicate when international mode and frequency privileges differ. This proposal also provides for better international coordination of amateur frequencies. IARU (International Amateur Radio Union) acknowledges the need for greater cooperation and coordination of the increasing and changing usage patterns of the amateur HF bands. Deregulation of usage, and flexibility to accommodate changing demand, is a principle goal set forth in band planning discussions. (See IARU HFC-C4, 13 November 2002). Our proposal also aligns U.S. amateur radio operator privileges with the rest of the world. Communications authorities in many countries rely on amateur service licensees to achieve better spectral efficiency through voluntary band plans. Among those countries, our Canadian neighbors provide an excellent example of voluntary band plan success. Canadian phone operation coexists quite well with U.S. operators in the current U.S. CW/Data sub bands.

Another successful example of voluntary coordination involving U.S. amateurs is the way modes and activities have sorted themselves out on 160 meters, on a basis that has been overwhelmingly cooperative with a long-term record of minimal complaints. Our proposal, if approved, would reduce potential friction among operators when bands are in heavy use and congested, especially during contests. Greater flexibility in selection of operating frequencies will enhance cooperation between those who choose to participate in organized operating events and those who do not. Our proposal may benefit other services near certain amateur band edges by maintaining the license class band allocation of licensees, who have not yet demonstrated higher levels of achievement by advancing their license class, safely within our allocations.

By demonstrating improved utilization of our range of frequencies, we can forestall any proposals for use of the amateur radio spectrum by other services. These potential rivals now can see a portion of our bands appear deserted much of the time under today's allocation-bymode. In reality other modes are quite active and crowded into the top section of the bands. In sum, greater operating flexibility will significantly relieve conditions of over-crowding attributed to regulatory divisions of available spectrum against popular operating interests.

ISSUES

(See also Appendix B)
Interference:

A certain amount of unintentional interference must be accepted in a hobbyist, experimental communications system. Good judgment remains the tenet guiding when that level must be cooperatively addressed by operators involved. Intentional and/or deliberate interference with communications in process is in violation of the regulations, independent of the mode in use, and whether automatic, semi automatic, or manually keyed. Operators presuming use of a specific frequency for their use: The proposal to discontinue forced segregation by mode would drain pressure away from the problem of operators who make squatter's claims on frequency space during times of congestion, since there would be more room and a greater range to move elsewhere.


PROPOSED CHANGES
Section 97.301
(b) For a station having a control operator who has been granted an operator license of Amateur Extra
Class:
Wavelength Band ITU-Region 1 ITU-Region 2 ITU-Region 3
Sharing
Requirements
See 97.303
MF kHz kHz kHz
160 m 1810-1850 1800-2000 1800-2000 a,b,c
HF MHz MHz MHz
80 m 3.50-3.75 3.50-3.75 3.50-3.75 a
75 m 3.75-3.80 3.75-4.00 3.75-4.00 a
40 m 7.0-7. 7.0-7.3 7.0-7.1 a
30 m 10.10-10.15 10.10-10.15 10.10-10.15 d
20 m 14.00-14.35 14.00-14.35 14.00-14.35
17 m 18.068-18.168 18.068-18.168 18.068-18.168
15 m 21.00-21.45 21.00-21.45 21.00-21.45
12 m 24.89-24.99 24.89-24.99 24.89-24.99
10 m 28.00-29.7 28.00-29.7 28.00-29.7


Section 97.301
(c) For a station having a control operator who has been granted an operator license of Amateur Advanced
Class:
Wavelength Band ITU-Region 1 ITU-Region 2 ITU-Region 3
Sharing
Requirements
See 97.303
MF kHz kHz kHz
160 m 1810-1850 1800-2000 1800-2000 a,b,c
HF MHz MHz MHz
80 m 3.525-3.75 3.525-3.75 3.525-3.75 a
75 m 3.775-3.800 3.775-4.00 3.775-3.900 a
40 m 7.025-7.100 7.025-7.300 7.025-7.100 a
30 m 10.10-10.15 10.10-10.15 10.10-10.15 d
20 m 14.025-14.150 14.025-14.35 14.025-14.150
Do 14.175-14.350 14.175-14.350 14.175-14.350
17 m 18.068-18.168 18.068-18.168 18.068-18.168
15 m 21.025-21.200 21.025-21.200 21.025-21.200
Do 21.225-21.450 21.225-21.450 21.225-21.450
12 m 24.89-24.99 24.89-24.99 24.89-24.99
10 m 28.00-29.7 28.00-29.7 28.00-29.7


Section 97.301
(d) For a station having a control operator who has been granted an operator license of Amateur General
Class:
Wavelength Band ITU-Region 1 ITU-Region 2 ITU-Region 3
Sharing
Requirements
See 97.303
MF kHz kHz kHz
160 m 1810-1850 1800-2000 1800-2000 a,b,c
HF MHz MHz MHz
80 m 3.525-3.75 3.525-3.75 3.525-3.75 a
75 m 3.850-4.00 3.850-3.900 a
40 m 7.025-7.100 7.025-7.150 7.025-7.100 a
30 m 10.10-10.15 10.10-10.15 10.10-10.15 d
20 m
14.025-14.150
. 14.025-14.150 14.025-14.150
Do 14.225-14.350 14.225-14.350 14.225-14.350
17 m 18.068-18.168 18.068-18.168 18.068-18.168
15 m 21.025-21.200 21.025-21.200 21.025-21.200
Do 21.3-21.450 21.3-21.450 21.3-21.450
12 m 24.89-24.99 24.89-24.99 24.89-24.99
10 m 28.00-29.7 28.00-29.7 28.00-29.7


Section 97.301
(e) For a station having a control operator who has been granted an operator license of Amateur Novice or
Technician Plus Class:
Wavelength Band ITU-Region 1 ITU-Region 2 ITU-Region 3
Sharing
Requirements
See 97.303
HF MHz MHz MHz
80 m 3.675-3.725 3.675-3.725 3.675-3.725 a
40 m 7.050-7.075 7.10-7.15 7.050-7.075 a
15 m 21.10-21.2 21.10-21.2 21.10-21.2
10 m 28.1-28.5 28.1-28.5 28.1-28.5
(f) For a station having a control operator who has been granted an operator license of Amateur Novice
Class:
Wavelength Band ITU-Region 1 ITU-Region 2 ITU-Region 3
Sharing
Requirements
See 97.303
VHF kHz kHz kHz
1.25 m 222-225 a
UHF MHz MHz MHz
23 cm 1270-1295 1270-1295 1270-1295

Appendix A
An Analysis of Band Occupancy by Mode
Art Pightling, K3XF, PG-11-25720


Executive Summary

This report demonstrates and quantifies amateur radio band occupancy by mode of operation during a typical operating day. It is, by definition, a snapshot in time and subject to several variables that have been addressed, in majority, in the sample collection process.

Introduction

Amateur radio operators congregate in sub bands in accord with tradition as related to their respective modes of operation. The lower sections of allocated frequency spectrum are typically occupied by CW and higher frequency sections by phone. Other communication techniques such as keyboard digital, image, and experimental modes are often conducted in roughly the center of a given band. In the past few years there has been a growing observation that the lower portions of the bands are becoming less and less populated. Conversely, the upper sections are becoming more active with new licensees trending toward phone modes. This report is based upon test data that has been verified and shown to be statistically viable.

Survey Process

The object of the survey is to demonstrate amateur radio band occupancy by mode. Test scheduling, execution, and data collection were accomplished in a consistent manner to yield accurate observations of actual conversations in progress (QSOs).

Determination of test schedule

Observations of the HF bands were conducted for two weeks to ascertain the most likely period(s) necessary for valid data collection. It was found that weekday operation was very heavily biased toward phone operation and unlikely to accurately represent potential CW operations. After these observations it is reasonable to conclude an extended test, which would exceed the scope of this study, would clearly indicate phone QSOs in process exceed CW QSOs in the same time period by a wide margin. Therefore, it was determined testing on a Saturday would yield a representation of band occupancy that would more accurately demonstrate potential and actual band occupancy during peak usage periods. June 4, 2005 was selected as the survey date and a twelve-hour time period from 1200Z to 2359Z.

Test equipment

A typical amateur radio station consisting of a Kenwood TS-2000 and antenna system with dipoles on 160M, 80M, and a delta loop for 40M was the primary data-gathering tool. Additional test equipment that may not appear in the usual operating station was utilized to observe the entire band: 1. A Motorola 2002C spectrum analyzer 2. A FlexRadio SDR-1000 and 3. An AOR AR7030 receiver.

Data gathering process

Amateur radio contacts in process were observed by tuning from the lower end of a given band to the top sequentially and iteratively. When a signal was encountered it was determined if the signal was a contact in process and if an operator party to the contact using a US call was involved. This required significantly more effort than a simple band scan, or count of signals on the band and more accurately represented the occupancy of US operators. As a signal was encountered and validated it was entered in a spreadsheet. After an operator completed a pass another operator performed a second pass and the two passes analyzed for relative percent difference to achieve validation of the data. Note that this identified who was transmitting and if they were a US amateur or in QSO with a US amateur. It does not count all parties to all QSOs. There were roundtables in process, particularly on the upper end of 40M, which may understate phone operation somewhat. There were also nets (CARS) that provided a count for phone on every pass while they were in session. This may have elevated the phone count and the two situations were considered to offset each other. The numbers may be different if your antenna system or equipment is different but the ratio of CW to Phone QSOs using the same method should be very close to the results obtained using the process described here. There was also a CW contest in process and many of the signals on the bands (notably not counted as QSOs) were CQ test. If a contest QSO in process was encountered, and there was a US operator involved it was counted. This may have elevated the CW QSO count somewhat but one must also consider there are amateurs who avoid operation during contests. There was considerable activity but not as many QSOs as might be expected with general band activity at this level. Phone contests could be expected to generate similar results, skewing the count toward more observed phone QSOs.

Band selection criteria

The On Line HF Propagation site (http://salsawaves.com/propagation/frequency.html) was employed to indicate the Maximum Usable Frequency (MUF) for communication from the test location to Europe. Considerable amateur radio operation is focused on communication with distant stations. Europe was chosen as an intermediate 'DX' contact area that would be sought after by both phone and CW operators. The test data collection was done one and two bands below the MUF. Later in the test period lower HF bands were utilized to "follow the action". This process was validated by the higher relative occupancy of band measurement points chosen in accord with this process.

Survey Results

Before the data was analyzed, and observing the bands on a spectrum analyzer, it is easy to get the impression that phone is by far more prevalent than CW operation. However, analysis of the data indicates that the phone to CW QSO ratio aggregated over the test period is 1.75:1 in favor of phone operations.

SURVEY DATA
DTG MUF -Europe Band CW
Control Phone Control Keyboard
604051200Z 15M 20M 6 5 9 11 2
15M 40M 8 9 21 19 1
0604051300Z 15M 20M 3 3 14 13 1
15M 40M 14 13 21 23 1
0604051400Z 15M 20M 10 10 33 27 2
15M 40M 6 4 12 12 0
0604051500Z 15M 20M 9 8 13 18 4
15M 40M 5 7 11 9 0
0604051600Z 15M 20M 22 24 25 27 1
15M 40M 6 6 11 10 0
0604051700Z 15M 20M 14 16 16 19 2
15M 40M 5 4 9 7 0
0604051800Z 20M 20M 11 13 11 12 3
20M 40M 2 2 11 11 0
0604051900Z 20M 20M 13 11 17 13 2
20M 40M 6 6 11 8 0
0604052000Z 20M 20M 11 12 16 19 5
20M 40M 6 6 18 17 1
0604052100Z 20M 20M 18 17 22 26 4
20M 40M 13 14 16 16 1
0604052200Z 20M 20M 13 15 19 18 5
20M 40M 9 11 19 21 3
0604052300Z 30M 40M 9 8 13 13 0
40M 80M 0 0 8 9 1
0604052359Z 40M 40M 18 16 25 21 1
40M 80M 3 3 23 23 2
Totals 240 243 424 422 42
Averages 241.5 423
RPD mode-control <1.25% 1.242% 0.473%

The observed ratio of phone to CW QSOs in progress in the measurement time frame is
423/241.5=1.75:1.




(http://www.amwindow.org/misc/gif/qsocount.gif)
QSO relative count graph.

This chart illustrates the QSO counts tracking consistently throughout the survey. It adds an additional layer of validation to the individual measurements.

Conclusion

This report demonstrates and quantifies amateur radio band occupancy by mode of operation during a typical operating day. Data was collected in a consistent manner with validating statistical and graphical analysis.

We may conclude from this study that CW occupancy of the bands evaluated is significantly less than phone use of the same bands at the same time and utilizing consistent sampling techniques.

Note: 80M and 10M yielded surprisingly low CW QSO counts during the survey, when, in accord with propagation conditions, expected band usage, and phone QSOs in progress, they should have been more heavily populated. Therefore, 10M was not utilized in the survey, 15M was monitored as a candidate but was not utilized, and 80M was used after 40M activity dropped off.

Actually, I feel none of this, no reason to, but I do feel some pity. I should also remind you to read the "Rules and Regs" on the home page, click on Rule Updates, or, if you get lost, just go here, http://amfone.net/phpBB2/viewtopic.php?t=4086




Phil, we all know you're an angel on the air and recite the bandplans every  day. Never said you might be the on-the-air problem.



Sold 5 rigs at Dayton this year. And the only issue that disturbs me is your total lack of insight to the future of the amateur radio service.



Pittston has great bars. Actually Sayreville, Parlin,  and South Amboy all border that strip of Route 35. What's left of those "sleazy nightclubs" (ah, all those great times when I was single) are now mostly in South Amboy.

I do love the way you read things into my statements though. It's another great way to say "Gotcha".

Cheese, anyone???



Ahh, the old CB chestnut brought out yet again to refute any proposal  one doesn't like.  Actually, CB is a case history in WHY this proposal is a Good Thing.  Although CB and ham radio are not comparable in that one was never intended to be a hobby service and the other is populated by persons with more or less technical interests and qualifications, the absolute crowding of CB certainly has no positive effect on the conduct of that band's occupants.

Crowding of the phone bands and the inevitible conflicts that therefore arise (while other portions of the band are virtually empty) is the cause of no end of headache for the FCC.  More space = less conflict = more time for the FCC to concentrate on other, more important matters.

73 John

If you all get an opportunity, you might to check out Rich Moseson's Zero Bias Column, in the July 2005 issue of CQ Magazine. Rich and I discussed his feelings about the ARRL proposal back in May at Dayton. If you don't get CQ Mag., go here to view the column:

http://www.cq-amateur-radio.com/Zero%20Bias%20July05.pdf

Fred Maia, W5YI, also has a report about the bandwidth proposal under "Washington Readout" in the same issue, but has a glaring error for 75/80 meters in his undated proposal chart.

Also, on eHam.net, there is an article topic called "Alternative to ARRL Bandwidth Proposal", dated May24, 2005. http://www.eham.net/articles/11055
It's curious to read the responses to this pending proposal, since a number of contributors also provided "input" to Art's posting of CTT's proposal announcement on QRZ.com several days ago. In some cases, it's hard to believe the same people (extensive attitude adjustments, I guess)  wrote responses in these two locations. It's also curious that no one from the CTT group made any comments to this pending proposal.

Yep, I saw both Pete. Observations of these suggestions and potential proposals were some of the reasons I was ready to participate in a different perspective. Both stated something needed to be done in terms of bandplan. Tims and Jims plan creates emission by bandwidth sub bands of a type that have been designated as unenforceable by the ARRL, only more restrictive and much more structured. I guess this would appeal to everyone who operated a mode that didn't conflict with the bandwidth specified but did nothing for digital voice, analog voice modes, or other 'wideband' modes except render current and most vintage equipment obsolete.
It would also appeal to the people who need the government to tell them how to behave or are willing to trade their freedom for the illusion of protection. Why would you be surprised that I wouldn't try to polish a . . . potential proposal (though it's genesis predates the CTT proposal, as did the ARRLs offerings, it is still not submitted. . . ), that I believe is fundamentally flawed, unenforceable, and based on a premise with which I disagree.
That being said Pete. I am surprised you haven't provided suggestions to move toward your opinion. Yes, yes, I saw you objected but what I didn't see was. 'This part doesn't make it for me. If you added X, Y, Z we would be going someplace . . .', like that.
I do respect your opinion Pete if you could get the wouff-hong out of your mouth. . . . that didn't come out exactly as I meant, but was pretty funny on my end. . .sorry. What I meant is it appears you think the ARRL is the way to regulate the amateur population. I disagree. The ARRL is more distant from representing amateur radio all the time. Their own statements of concern about declining membership should be a good clue. Another should be the response to the increasing regulation plan they seem to be going toward. You can observe that the CTT proposal has a fairly significant following now. These are people by definition opposed to the ARRL efforts as we know them. Add the people who are displaced and poorly represented in the ARRL proposal, and the people who would have voted for the concept but won't because it is an ARRL suggestion and it paints a sorry picture of an organization degenerating before our eyes.

Well there's better than 1700 dead from Iraq and I don't feel one bit safer in this country, The Deficit is,, well it's somewhere beyond my thinking and i don't  feel one bit happy that my children are Broke before they get a chance to make mistakes, and Rumsfield says it's going to be another 10-11 years before we see any real "evidence" that things are progressing.. Yessir We really need more Rep Gov inter"fear"ing in our lives....Yessir....

Which is more Important Being an Amateur Radio Operator..Or...Being a Mode specific Yes man Placating Special interests that charge for your involvement and Speak for what They believe to be Your interests.

and that's all from me,..


Arty I still like and Support your view, and the work you Men have done.


Somewhere Somebody Wake up and Smell the coffee, it needs Changing...

With apologies to the late John Lennon:

The American Ham IS THE NIGGER OF THE WORLD LYRICS
   
 

   
American ham is the nigger of the world
Yes he is...think about it
American ham is the nigger of the world
Think about it...do something about it

We make him paint his face and dance
If he won’t be a slave, we say that he don’t love us
If he’s real, we say she’s trying to be a contester
While putting him down, we pretend that he’s above us

American ham is the nigger of the world...yes he is
If you don’t believe me, take a look at the one you’re with
Segragationalized American ham is the slave of the slaves
Ah, yeah...better scream about it

We make him bear and raise our skyhook
And then we leave him flat for being a fat old mother net control
We tell him home is the only place he should be
Then we complain that he’s too unworldly to be our friend

The American ham is the nigger of the world...yes he is
If you don’t believe me, take a look at the one you’re with
W/K/A/N is the slave to the slaves
Yeah...alright...hit it!

We insult him every day on tv
And wonder why he has no guts or confidence
When he’s young we kill his will to be free
While telling him not to be so smart we put him down for being so dumb

The ugly American ham is the nigger of the world
Yes he is...if you don’t believe me, take a look at the one you’re with
Yankee is the slave to the slaves
Yes he is...if you believe me, you better scream about it

We make her paint her face and dance
We make her paint her face and dance
We make her paint her face and dance
We make her paint her face and dance
We make her paint her face and dance
We make her paint her face and dance

AM Buzzards swinging in the dead of night,
Take those broken rigs and fry away,
fry, fry, fry ......

When I get to the bottom I go back to the top of the band
and I stop and I turn and I go for a ride
and I get to the bottom and I don't hear any CW againnnnnn
yeah yeah yeah yeah

but do you don't you want me to propose a rule making
I'm coming down to QRZ fast but I'm miles above all the trolls
tell me tell me tell me the anSWeR
you may be a lover but you ain't no DXer.

Since we are waxing philosophical . . . this was written some time ago:

ORDO AB CHAO

Others have described it as: PROBLEM -- REACTION -- SOLUTION in that firstly you create the problem; then secondly you fan the flames to get a reaction; then thirdly (like Johnny-on-the-spot) you provide a solution. The solution is what you were wanting to achieve in the first place, but wouldn't have been able to achieve under normal circumstances.

The puppetmasters create "disorder" so the people will demand "order". The price of "order" always entails a handing over of control and loss of freedom on the part of the citizenry. Out of "chaos" comes "order" - THEIR order.

Orwell described it as REALITY CONTROL

Well hopefully a couple of clowns will show up during the fanning of the flames and butcher some old Beatles songs....

And in the end
the QRM you make
is equal to the NAL you take.

Come All Ye Hams

Come all ye hams in radio land,
And flip your mode switch to good old AM.
It's the sound of a voice that makes him a man,
Unlike Donald Duck on sideband.
Open your bandpass to a wide 12 kc,
And listen to the sound of high fidelity.

Throw away your ricebox, it's nothing but junk,
Get a boatanchor - something with spunk.
An Apache, Valiant or homebrew will do,
A carrier and two sidebands.
With the flip of the plate switch there's mighty loud arc,
Cause real radios glow in the dark.

It's more than a mode, it's Angel Music,
To be in a QSO and not feel sick.
It's six foot tall racks of iron and steel,
807's piled high.
It's the warmth of a carrier that quiets the noise,
It's AM Radio makin' men from boys.

So all ye hams in radio land,
Flip your mode switch to good old AM.
It's the sound of a voice that makes him a man,
Unlike Donald Duck on sideband.
Open your bandpass to a wide 12 kc,
And listen to the sound of high fidelity.

http://www.amwindow.org/audio/ra/allyeham.ram

I guess all 7 of your members must feel the same way.



I'll answer this maybe later today.



Seems to be a common practice to mock someone with "digging phrases" who firmly believe in the organization they are supporting. You're not the first one to do it.  I guess it's part of the ARRL "hate" campaign.



The ARRL doesn't regulate amateur population. FCC does the regulating. I thought you knew that. The ARRL provides recommendations and proposals based on the perceived view of  current and future trends in amateur radio with inputs from many sources.



It's difficult, if not impossible, to respresent "all" amateur concerns and "all " amateur activities all the time.



The declining membership is probably due to a number of factors but probably has little effect on it's financial stability. If you review the latest Annual Report, you would notice that they are very financially solid.

As far as the CTT proposal "following", not counting "AM buddies", I think I saw two on the QRZ responses.

My comments to your last paragraph in red:[/i]
"These are people by definition opposed to the ARRL efforts as we know them. Or maybe they will support the third or fouth proposal[/i] Add the people who are displaced and poorly represented in the ARRL proposal, The only one I see getting screwed in the ARRL proposal is the ESSB crowd; who got displaced?[/i] and the people who would have voted for the concept but won't because it is an ARRL suggestion That's natural; it's the "hate" syndrome[/i] and it paints a sorry picture of an organization degenerating before our eyes." You have a very vivid imagination. I don't see any degenerating. In large organizations, with so many "special interest" groups, there will always be dissent. It's natural and healthy for the organization.[/i]

"You have a very vivid imagination. I don't see any degenerating. In large organizations, with so many "special interest" groups, there will always be dissent. It's natural and healthy for the organization."

Yes Pete, I imagined the mail I get from the ARRL asking for contributions and stating the membership is declining.

The other topics re the ARRL I am being intentionally obtuse about and so are you. That is, we are looking for the most SPIN to support our points. Therefore, both our minds are probably already made up and this part of the discussion is a waste of time.

Let's drop the ARRL topic based on the preceding and go on to building something.  You stated something much more interesting; that you would get back to me on how to make the CTT proposal better or more in alignment with your ideas of what would work. I look forward to your response and promise I won't bring up the ARRL at all.

WHEW! Thank goodness. There's an ARRL Forum for that.

Why don't we d' do it on AM...

Why don't we d' do it on AM

Why don't we d' do it on AM?

Why don't we d' do it on AM.

Nobody will be watching us -

Why don't we d' do it on AM.

Thank you, Ringo, your lyrics are enlightening..

"T" is one of our More Creative and Spontaneous members and is a Great Help, a much needed Asset.

".Should I list every frequency every other mode may use?  And if I did, what does that have to do with a flexible band plan..one that will follow the popularity of current technology, and allow advancement of new methodologies?"

'right on the button. Pre defining frequencies that will be used for a specific mode is an exercise in futility. Winlink operation has taken over the thread as a good example of this concept. However, it applies to all modes on all frequencies. I think we can listen before transmitting, respect others and use the amateur bands more effectively. As has been enthusiastically pointed out, there will be exceptions (propagation changes, somebody in QSO in the band pass you didn't hear, etc. etc.). There will be more bandwidth to QSY to under the petition. This maximizes the probability the intentional interference will be dealt with in a less contentious manner and lowers the "temperature" of accidental interference.

There are many who will say this is utopian. I also agree with this view. To expect all ops to solve their interference problems in a gentlemanly manner is naive at best. Those hard-core types who will not cooperate to solve problems will behave the same whether restrictive rules are in place or not. Therefore the restrictions would constrain only  law/regulation abiding ops. Regulation of ops who would behave in accord with good amateur practice is like directing an ice cube to melt in July.

Before we get into a heated discussion of what a gentlemanly manner is, and how it is difficult to attain . . . . There is only one answer . .  If you have to ask, I am not the one to tell you . . . . and I agree, it is difficult to cooperate to resolve issues. There is no single act or process that applies in all cases. Good amateur practice is general guidelines, not a checklist of specific actions that will solve all problems. . . . and if something is not covered its "their fault". You are responsible for your interaction with others. The CTT petition puts this concept front and center.

There will always be those who feel it is their duty and right to tell you how to behave on behalf of be greater good. I find them more annoying than any interference I have experienced on the amateur bands. . . . plastic badges . .  well, we don't need no stinking badges. They use fear of chaos and inability to survive in a "wild west" or wide-open environment to forward their attempts to control  us. There  are also those pathetic individuals (are they individuals?) who speak this way and do not have a plan to control others.

All modes and all people are treated equally under this petition. The real question is: Can we handle the privileges and the responsibilities of freedom?

Very Well Art,

 I think you hit one on the head, "Responsibilities of Freedom" No I don't think it's possible, this is not a mark against your cause, it's a truth, and by it's very nature it Scares the average Joe into Reality.

 Today is all consumed in "It being taken care of", "We have Laws for that", "That's someone elses Job", get my drift, it's all to easy Now, everything, Just exsist and "We'll Handle everything".... the better part of Liberty is the Responsibilities, Personal Responsibilities.

This is Scary Now I'm sounding like IRB.. :D

I was thinking the same thing after my post . . . next thing you know I'll be rattling chimes and eating oatmeal on 3885.

Unfortunately, Irb is a classic example of the opposite of freedom. Ask him. He will tell you exactly how to live your life and why.

The CTT petition puts that responsibility squarely where it belongs . . . check out that mirror . . .

-ap

I'm all for it Arty, I hope there is some interest from the Commision and Lord only knows what they'll decree, But we Can Hope, and Support your endeavours.

Art/CTT:

In reviewing your proposed changes to Section 97.301, I see that General Class operators lose the ability to operate between 7.225 to 7.300 MHz in ITU Region 2. Why?

For Advanced Class, the first line of 20 meter information indicates that Advanced Class operators can operate from 14.025 to 14.350 MHz. Shouldn’t the 14.350 MHz actually be 14.150 MHz?

For Amateur Extra Class, on 75 meters, ITU Region 3, you indicate 3.75 to 4.00 MHz. Shouldn’t this be 3.75 to 3.90 MHz?

Your Appendix A, “An Analysis of Band Occupancy by Mode”, was added, I assume, to help validate your conclusions as to why there should be a discontinuation of sub band definition by mode in the HF bands. Curiously, there is no mention of where the actual test was done. Since Art penned the report, should we also assume he manned the equipment and collected the data at his location and at no other location? The data was also curious in that it did not show, nor made any mention of, any “digital” modes. In a 12-hour period, your data suggests you either heard no digital modes or possibly you couldn’t identify signals as digital modes or digital type transmissions.

Quoting your survey process:
”The object of the survey is to demonstrate amateur radio band occupancy by mode. Test scheduling, execution, and data collection were accomplished in a consistent manner to yield accurate observations of actual conversations in progress (QSOs).”

If you ignored digital modes as part of your survey, it seems your survey is incomplete. If you couldn’t identify them as digital (QSO) transmissions, how do you plan to identify signals on the band at your station before transmitting as part of  “good operating practices” if your proposal is cast into stone by the FCC?

Quoting your conclusion:
”This report demonstrates and quantifies amateur radio band occupancy by mode of operation during a typical operating day. Data was collected in a consistent manner with validating statistical and graphical analysis.

We may conclude from this study that CW occupancy of the bands evaluated is significantly less than phone use of the same bands at the same time and utilizing consistent sampling techniques.”

I’m still fuzzy on what a “typical operating day” is in your/CTT analysis, given that propagation  conditions, weather phenomena, local type interference, etc. varies from hour to hour, day to day, and location to location all the time.

Further, what’s missing from this statement, “We may conclude from this study that CW occupancy of the bands evaluated is significantly less than phone use of the same bands at the same time and utilizing consistent sampling techniques”, are the words that this conclusion is based on data analysis taken at one location (if that is the case) and, in all probability, data collected using the same equipment and sampling techniques at other locations across the FCC’s jurisdiction (typically from Florida to Alaska and Maine to Hawaii), may not result in the same conclusions. Given that you haven’t proved that the same ratios of phone to CW occupancy exist across the FCC’s entire jurisdiction, it seems premature for your team to have requested a total deregulation of the bands that affects “all” of the FCC’s jurisdiction. All you have proven here is that at the testing location (SE PA?) on a “typical operating day”, during a defined time frame, phone QSO’s outnumbered CW QSO’s. More convincing validity to your analysis and eventual conclusions would have resulted if your data collection included reception analysis from such locations as Maine, Florida, Texas, Iowa, California, Colorado, Minnesota, Hawaii, and Alaska. To me, if you had provided analysis of data collected at locations such as these, it would have provided the necessary depth and breath to substantiate your conclusions and requests in your proposal.

Pete, WA2CWA
Back from several days of fun, sun, & nightlife

Welcome back Pete. We missed you. (To the conspiracy theorists, Pete and I enjoy discussing issues of the day. . .  often from very different perspectives.)

"Art/Paul: Not sure if you're checking both(QRZ and AM) forums, so I put this post in both places."

Thanks Pete. We have over 700 inputs on this topic at this time. I just have QRZ, eham, and AM forum and it is seriously cutting into my on the air time but the input is well worth it.

"In reviewing your proposed changes to Section 97.301, I see that General Class operators lose the ability to operate between 7.225 to 7.300 MHz in ITU Region 2. Why? For Advanced Class, the first line of 20 meter information indicates that Advanced Class operators can operate from 14.025 to 14.350 MHz. Shouldn’t the 14.350 MHz actually be 14.150 MHz? For Amateur Extra Class, on 75 meters, ITU Region 3, you indicate 3.75 to 4.00 MHz. Shouldn’t this be 3.75 to 3.90 MHz?"

Good eyes and thanks for reading the petition. This was an error. The intent is to allow all modes of operation on any frequency permitted by a given license class. . . . Including novice . . . That should rattle some cages.

"Your Appendix A, “An Analysis of Band Occupancy by Mode”, was added, I assume, to help validate your conclusions as to why there should be a discontinuation of sub band definition by mode in the HF bands."

Actually no. It was done before the final conclusions were drawn. I must admit we were well along the way but I worked to keep conditions as neutral as possible. I have worked in commercial radio for some time and utilized many of the techniques devised to illustrate band occupancy for commercial applications. Such surveys have been used by many utility, public safety, and commercial, entities across the US.

"Curiously, there is no mention of where the actual test was done. Since Art penned the report, should we also assume he manned the equipment and collected the data at his location and at no other location?"

The data was collected at my shack and I was one of three operators who collected the data. I stated the equipment in use and the rationale for the test period in the test description. In summary, I chose a Saturday during a CW contest because I wanted to illustrate a peak use period. Previous surveys during the week yielded a significantly greater advantage to phone QSOs in process during observations. A longer test would have included these periods and, I believe, would have favored phone more than the test period and day chosen.

"The data was also curious in that it did not show, nor made any mention of, any “digital” modes. In a 12-hour period, your data suggests you either heard no digital modes or possibly you couldn’t identify signals as digital modes or digital type transmissions."

Though we did collect digital mode information we were focused on CW vs phone. Keyboard digital was a distant third and other digital signals, some of which I couldn't demod, were very few.

"Quoting your survey process:
”The object of the survey is to demonstrate amateur radio band occupancy by mode. Test scheduling, execution, and data collection were accomplished in a consistent manner to yield accurate observations of actual conversations in progress (QSOs).”
If you ignored digital modes as part of your survey, it seems your survey is incomplete. If you couldn’t identify them as digital (QSO) transmissions, how do you plan to identify signals on the band at your station before transmitting as part of  “good operating practices” if your proposal is cast into stone by the FCC?"

Please see the preceding response. However, just like on 60M, I don't need to know what type of QSO is in process, I need to avoid it. If there is someone else operating I go someplace else to do my transmitting. That's my definition of good amateur practice.

"Quoting your conclusion:
”'This report demonstrates and quantifies amateur radio band occupancy by mode of operation during a typical operating day. Data was collected in a consistent manner with validating statistical and graphical analysis.
We may conclude from this study that CW occupancy of the bands evaluated is significantly less than phone use of the same bands at the same time and utilizing consistent sampling techniques.”
'I’m still fuzzy on what a “typical operating day” is in your/CTT analysis, given that propagation  conditions, weather phenomena, local type interference, etc. varies from hour to hour, day to day, and location to location all the time."

Yep, I agree it is a snap shot in time. Statistical validation was by relative percentage error on two or more passes conducted by different operators who were isolated during their collection of the data. Graphical analysis was a visual analog of the statistical validation.

"Further, what’s missing from this statement, “We may conclude from this study that CW occupancy of the bands evaluated is significantly less than phone use of the same bands at the same time and utilizing consistent sampling techniques”, are the words that this conclusion is based on data analysis taken at one location (if that is the case)"

Yes.

" and, in all probability, data collected using the same equipment and sampling techniques at other locations across the FCC’s jurisdiction (typically from Florida to Alaska and Maine to Hawaii), may not result in the same conclusions."

That is possible. Once again, it is a snapshot in time.

"Given that you haven’t proved that the same ratios of phone to CW occupancy exist across the FCC’s entire jurisdiction,"

This is neither within the scope nor intent of the test. It was a demonstration of activity on a given day chosen to illustrate CW vs phone operation. If you did the same test under the same conditions at your location I am quite sure your ratios would be similar unless you have a particularly dense phone (as you do, Pete) or CW population in your area.

"it seems premature for your team to have requested a total deregulation of the bands that affects “all” of the FCC’s jurisdiction. All you have proven here is that at the testing location (SE PA?) on a “typical operating day”, during a defined time frame, phone QSO’s outnumbered CW QSO’s."

I am in south central PA and the antennas are arrayed such that most of the US is served. This was well illustrated by the number of call areas represented in the data.

"More convincing validity to your analysis and eventual conclusions would have resulted if your data collection included reception analysis from such locations as Maine, Florida, Texas, Iowa, California, Colorado, Minnesota, Hawaii, and Alaska. To me, if you had provided analysis of data collected at locations such as these, it would have provided the necessary depth and breath to substantiate your conclusions and requests in your proposal."

Actually, the data did include locations such as you describe except I didn't get Hawaii and Alaska. Remember, we didn't just count blips on a scope. We listened to each QSO long enough to determine if there was a US op involved. That involved acquiring their call. I know this isn't what you meant. You would like a test from all those places. My bet at this time, such a survey would yield a 1.75:1 ratio (or more) phone to CW US op QSOs in process.  Between us, Pete. Don't take that bet. : )

I would be the first to say the survey is a snap shot in time. In fact, I was. The typical response of those who reviewed the data was skepticism that the CW count was way higher than they expected and from their experience.

Further, spectrum analysis and band displays from commercial equipment was used to get a sense of 'where the action was' to validate the process of using 1 or 2 bands below the MUF to Europe as the band selection criteria. The pictures are worth a thousand words. They show phone transmissions rather densely packed and CW transmissions as notably less prevalent. This type of analysis was also done in Ohio as well and yielded similar results. I admit, Ohio is not all that far away from south central PA but it did provide geographic diversity of sorts while we made date, day, and time selection for the survey.

The survey was not the sole motivation for the petition. There were many others. Even the ARRL understands something must be done to reorganize the amateur bands.

This is one perspective. There seems to be no middle ground but good data has been collected and people are ready with their action points.

I think with input such as the CTT petition and the 500 or so inputs the ARRL has already received, maybe, just maybe, they will do something remarkable in the near future.

http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-05-143A1.doc

I just finished reading the NPRM. The thrust is the elimination of all morse requirements for all classes of amateur licenses.

The NPRM took many issues, including license class modifications and requested examination changes, and evaluated them critically issue by issue. It is EXTREMELY significant that the FCC disagreed with the ARRL and FISTS several times. We will not be having any new Novice class license or expansion of their priveleges and there will be no additional "grandfathering" if this NPRM becomes law.

What this NPRM does tell me is the FCC may be looking at the CTT proposal favorably. In the act of eliminating the morse requirement for licensing, they essentially recognize CW as an operating mode used by amateurs just like any other. They also downplay it's importance in emergency communications by noting that in common practice, morse is rarely used.

 
ob·sess [ əb séss, ob séss ] (past and past participle ob·sessed, present participle ob·sess·ing, 3rd person present singular ob·sess·es)


verb  
 
1. transitive verb never stop thinking about something: to occupy somebody's thoughts constantly and exclusively
The desire for vengeance obsesses him.

 
2. intransitive verb be preoccupied: to think or worry about something constantly and compulsively

ANNOY n.  Archaic. An annoyance.

--v.t. 1. To disturb or irritate, esp. by repeated acts; to vex.

2. To molest; harass; as to annoy an army by impeding its march.

--v.i. to be troublesome or irritating. -- annoyer. n.

editorial addition:  irritating, as in Irritating Radio Buckshot

insensitivity - Insensitivity - INSENSITIVITY - :D


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