IARU REGION 2 MF/HF BAND PLAN, effective 01 JA 2008, would limit AM operation.

[WA3VJB]

Steve did you send that off ?
What's curious is that George ("Dick" as he is known to his comrades) is among the volunteer Division Directors who were unwilling to ask their constituents' opinion in the survey that ARRL's leadership commissioned a few months ago.

This tells me he's more inclined to protect the status quo, and parrot the dogma handed to him by paid staff Paul Rinaldo, Dave Sumner, et. al.

Sumner, for his part, has emailed me that he does not agree with "some" of the language Isley has used in his Nov. 7 message to subscribers in his zone.
But, Sumner did not address my request that he tell his subordinate Rinaldo to endorse the revisions needed in the Region 2 plan.
I don't see a direct connection between Rinaldo's favoring WinLink and his opposition to AM.  What seems more likely is that in order to make automated telemetry systems such as WinLink acceptable to U.S. licensees, he has to market them as being at least as narrow as SSB, so that they can be situated among phone QSOs on that mode as intended.

AM, and the bandwidth ordinarily associated with the mode, is an inconvenient reality Rinaldo has tried to ignore in both his threatened bandwidth scheme to the FCC, and now with his suggestion of a 2.7Kc specification to the other Region 2 delegates of the IARU.

[Steve - WB3HUZ]

All the more reason to fight it now.

Pete

 Just what are you defending here anyways? Are you in agreement with the  proposed restrictions AM or otherwise?

Regulation by bandwidth already exists in some countries including Region 2.

FCC Regulations are the law of the land in the U.S. not a voluntary Region 2 band plan. My point: The Region 2 band plan is voluntary; it has no power of authority for U. S. amateurs; likewise, it has no power in any other country either. The current ITU conference has no plans on their agenda to pursue mandatory regulation by bandwidth in countries where they don't exist now.

Proposed regulation by bandwidth is not going away here in the U. S. We won't see it today or even tomorrow, but several years down the road, most, if not all countries in all Regions, will define and have some sort of "regulations by bandwidth".

[w3jn]

^^^  And fight every quasi-official document that proposes same to the ITU or any other official body.

Proposed regulation by bandwidth is not going away here in the U. S. We won't see it today or even tomorrow, but several years down the road, most, if not all countries in all Regions, will define and have some sort of "regulations by bandwidth".

^^  And there you have it.  That, coupled with Isley's professed support of regulation by bandwidth, certainly could lead one to believe that this IARU-2 proposal is an attempt to get a foot in the door with the FCC.  The louder the ARRL officials bleat that it's unenforceable, the more I believe that this whole thing has ulterior motives.

[K6JEK]

QST p. 74 this month has but that same brief statement about the band plan, "A new Region 2 band plan was adopted ..."   I expected at least a description of the band plan and a statement about its relevance.    They really do seem to be  taking a fly-under-the-radar approach.

I managed to get a few people out here fired up. They corresponded with Sumner, Rinaldo, Stafford, and Harrison. The answers are always "don't worry about it."  The guys I got going were mollified by these exchanges.  I was not.  I kept asking what the ARRL position is and never did get any answer.

They all did say this, though:  ARRL policy is set by the Board of Directors (http://www.arrl.org/divisions/ )  The one guy who did not respond to my inquiries was the Pacific Division Director, Bob Vallio, W6RGG.

I'm keeping at it.   I hope the rest of you are too.

Jon 

[WA3VJB]

I believe that this whole thing has ulterior motives

.

Indeed, what is in it for those pushing it ?

They already have repeatedly said the plan does not have the force of law, does not apply to U.S. licensees, so what if it is at odds with FCC Part 97.

What's left ?

Onetime ARRL president Larry Price said in his letter published on the ITU website* that the intent is to eliminate footnotes among Regions 1, 2 and 3.

Some country footnotes provide for alternative or additional allocations in some of these frequency bands. The amateur radio community seeks increased harmonization of frequency allocations, through the reduction and avoidance of country footnotes that reduce the availability of bands that are allocated internationally to radio amateurs.

AM, come January, joins the footnotes in the Region 2 IARU plan. It is anyone's guess whether Price's use of the word "footnotes" is intended to apply to regulatory discrepancies, IARU exceptions, or both.  Clearly he envisions footnotes as something to discourage.

*http://www.itu.int/itunews/manager/display.asp?lang=en&year=2007&issue=08&ipage=amateur-radio&ext=html

[Steve - WB3HUZ]

There is no plot to shut down amateur radio AM operation in the U.S. or
it's territories.  The existing AM footnotes to our current band plan
still apply and will continue to do so until the FCC changes or erases
them from its Part 97 Regulations.  I repeat, there is no ARRL plan to
get rid of HF amateur radio AM operation in the U.S.  I also point out
that the AM footnotes (that enable AM operation) in the current FCC
Amateur Radio Service band plan would have still applied to our
regulation by bandwidth proposal, if it had become an FCC Regulation.
Only the portions of the HF band plan that would have been changed were
listed in the ARRL petition to the FCC.  This is standard procedure in
an FCC filing.  Many people still do not "get it".

I find it absolutely amazing that many people jump to conclusions
before they do their own homework.  This is true in many activities,
including amateur radio.  There have been, and apparently always will
be, individuals who are gullible, biased, have an axe to grind, or are
some combination of the three when it comes to discussing and
considering amateur radio regulations.  They are few in number, but
there are a lot of others who are taken in by these people simply
because they don't understand the situation and don't want to spend the
effort to get the facts directly from the source.

I don't have a good answer to this situation other than to keep working
to spread the truth.  I apologize for my exasperation that shows
through in this message.

Some more funny stuff from George. Now remember, this is the guy who  says, "There have been, and apparently always will be, individuals who are gullible, biased, have an axe to grind, or are some combination of the three when it comes to discussing and considering amateur radio regulations." And he claims he will "keep working to spread the truth." Yet, he doesn't even have a firm grasp on the current FCC regulations (Part 97).

He speaks of "the AM footnotes (that enable AM operation) in the current FCC Amateur Radio Service band plan." I find no such footnotes anywhere in Part 97. The relevant sections in Part 97 are 97.305(c) and the footnotes therein that reference the emission standards in 97.307(f). AM is not directly referenced anywhere in 97.307 or the so called footnotes of 97.307(c), other than the A3E reference in paragraph 2 which is dealing with the bandwidth of NON-PHONE emissions!

Yet, this guy wants to claim others are ignorant. Incredible! AMers live by 97.307 (a) through(e) with (a) being the only portion relevant to non-spurious or out of band emissions.

No amateur station transmission shall occupy more bandwidth than necessary for the information rate and emission type being transmitted, in accordance with good amateur practice.

It's rather simple and no footnotes, asterisks or special exemptions are involved.

To those Central Division readers that are ARRL members out there, do you want this guy representing you?

[Steve - WB3HUZ]

You did not answer the question Gary asked.

Regulation by bandwidth already exists in some countries including Region 2.

So what? Some countries have power limits different than the US. Some have different testing requirements. Some countries have no amateur radio. All of which is irrelevant to what we have or do in the USA.

Pete

 Just what are you defending here anyways? Are you in agreement with the  proposed restrictions AM or otherwise?

Regulation by bandwidth already exists in some countries including Region 2.

FCC Regulations are the law of the land in the U.S. not a voluntary Region 2 band plan. My point: The Region 2 band plan is voluntary; it has no power of authority for U. S. amateurs; likewise, it has no power in any other country either. The current ITU conference has no plans on their agenda to pursue mandatory regulation by bandwidth in countries where they don't exist now.

Proposed regulation by bandwidth is not going away here in the U. S. We won't see it today or even tomorrow, but several years down the road, most, if not all countries in all Regions, will define and have some sort of "regulations by bandwidth".

[Pete, WA2CWA]

You did not answer the question Gary asked.

Regulation by bandwidth already exists in some countries including Region 2.

So what? Some countries have power limits different than the US. Some have different testing requirements. Some countries have no amateur radio. All of which is irrelevant to what we have or do in the USA.

Actually, you don't have to change any of your AM operating habits or equipment come 1/1/08 since it's a voluntary Region 2 band plan. My point in the previous post was that there are already bandwidth restrictions in some Region 2 countries. I think this also answer's JN's response a second time. And, if you read my 2nd paragraph in the previous post(or in the quote below), you might understand my thinking.

If you review my comments on the NPRM for RM-11306, you will read that I supported parts of the ARRL's proposal on regulation by bandwidth, including 9KHz bandwidth for AM in the phone bands, but not the roving semi-automatic robots that could operate anywhere in an amateur band. I believe there was one other item I was in disagreement with in their proposal, but can't remember what it was.

Pete

 Just what are you defending here anyways? Are you in agreement with the  proposed restrictions AM or otherwise?

Regulation by bandwidth already exists in some countries including Region 2.

FCC Regulations are the law of the land in the U.S. not a voluntary Region 2 band plan. My point: The Region 2 band plan is voluntary; it has no power of authority for U. S. amateurs; likewise, it has no power in any other country either. The current ITU conference has no plans on their agenda to pursue mandatory regulation by bandwidth in countries where they don't exist now.

Proposed regulation by bandwidth is not going away here in the U. S. We won't see it today or even tomorrow, but several years down the road, most, if not all countries in all Regions, will define and have some sort of "regulations by bandwidth".

[wd8das]

>Steve did you send that off ?

Yes, early today I sent my reply message to Isley.  Then later I "condensed" a lot of my previous work into a single letter on this issue and submitted it to QST as a Correspondence or Op-Ed piece. 

Steve WD8DAS

[Steve - WB3HUZ]

And my point is so what? Regs in other countries do not make a legitimate argument (either for or against) for the content of either voluntary band plans or mandatory regulations. They are irrelevant.

 My point in the previous post was that there are already bandwidth restrictions in some Region 2 countries.

[W3SLK]

One of the things that I pointed out to Paul, WA3VJB, was the little disclaimer at the bottom of the 1998 IARU Band Plan:
 ".....These bandplans are voluntary and as such cannot legally be enforced, except
in some countries in which the bandplans are written into the national
regulations. The vast majority of amateurs in all countries do conform to
the IARU bandplans and it is in our own interest that it should continue to
be this way. The plans are prepared in a democratic way with input from any
country's member society. The plans are discussed, modified and voted upon
at IARU Regional General Assemblies with each country (large or small)
having only one vote. If an individual or group is not satisfied with the
bandplans as they are and has a suggestion for improvement then he should
submit it, with as much documentation as possible, to his IARU member
society......"

This little footnote was subtly absent from the one presented to take effect in 2008. Given the recent mistrust of the ARRgghhL, one would be led to believe that there are certainly alterior motives involved. There hasn't been any justification by the (be)League(d) as to why spend so much time, money and effort into a plan if it doesn't have any kind of weight.

[Steve - WB3HUZ]

It's interesting to see the IARU claims to be open about their proceeding with

The plans are prepared in a democratic way with input from any country's member society.

but the ARRL does not do the same. I've never received on correspondence from the ARRL on this issue. Why?


It's also amusing to hear all those who trumpet that the band plan is voluntary but leave out this tidbit.

The vast majority of amateurs in all countries do conform to the IARU bandplans and it is in our own interest that it should continue to be this way.

[k4kyv]

There is no plot to shut down amateur radio AM operation in the U.S. or
it's territories.  The existing AM footnotes to our current band plan
still apply and will continue to do so until the FCC changes or erases
them from its Part 97 Regulations.  I repeat, there is no ARRL plan to
get rid of HF amateur radio AM operation in the U.S.

We must not forget that there are other nations in Region 2 besides the US and Canada.  Just as we are presently enjoying some international AM traffic with a couple of European countries, it would not be in our interests to lose that option with other countries in the Americas.  This is of particular significance given that at international radio conferences, each country, regardless of its population, has one vote that carries equal weight with the votes of each of the other countries.  The only way we will ever have any international support of AM by other governments is for there to be interest in AM by the amateurs in those countries.

A good example of this is the regulations in Bermuda that restrict all transmissions to 3 kHz bandwidth.  I doubt that there are more than a few dozen licensed hams in the entire country.  I suspect that rule got into their regulations by default, simply because none of the present licensees had any interest in AM, and their regulations likely were also influenced by collaboration with stateside DX'ers and contesters who might wish to temporarily operate from there, few of whom would have any kind of positive attitude towards AM.

[AB5S]

Politicos hate it when people undermine them.
Perhaps a few well-crafted letters to the FCC,
pointing out how the ARRL has done this
sneeky end-around, might cause them to
dig in their heels and say: "No way!"

[WA3VJB]

Yes indeed.

Direct contact among concerned licensees and the FCC is what doomed the failed bandwidth petition from the club in Newington.

You by now will have received an email with a suggested letter to friendlies we have encountered at the IARU, where this band plan was developed.

Please consider the points raised and the action suggested.

[Tom WA3KLR]

All of you are under house arrest (HI).

The last time I checked the IARU websites, there still was no posting of the IARU 2 Conference Resolutions.

[Rob K2CU]

HI All!

I think it is clearly a matter of attacking the mode and not the bandwidth. I have measured many an SSB station at way over the 2.5 KHz they claim to limit themselves to. I am more concerned that our hobby's main mouthpiece, the ARRL, has taken a position that is clearly opposite the current trend in mode of operation. Consider this: Twenty years, or so, ago new rigs were generally void of AM mode. Now, almost all, even SDR radios have it. Sure, we got screwed in the power output sham, but that has not stopped the spirit of AMers. Also consider that technology innovation such as Class E,  has been in the AM mode, not SSB. IF anyone else is involved with mentoring new hams,  you know that it is quite easy to build a low power AM rig, and have it understood as to how it works than to tell your student, "Save your money and buy an SSB rig."

or, am I just too cynical about the dumbing down of the hobby we all love?

ras -K2CU

[AB5S]

We should also remember that the ARRL has a history,
going back to the WWII Surplus Radios era,
of siding with new-equipment sellers and against
anyone using "old" equipment.  This is understandable,
since new-equipment sellers pay the bills at ARRL,
but this time I think they've been "too clever by half,"
thinking that screwing the BA AM community would please
their masters at Icom and Kenwood.  I don't think they
are going to get the mileage out of that attitude
this time which they did in the past.
It's too easy, with the new tech available,
to include AM in a "new" rig, so AM users
are not the threat which they were falsely
perceived to be in the past.
73 AB5S

[K7NCR]

Hi!
I did receive Paul's E-mail. I hope everyone takes time to send the letter or a version of it along to the appropriate parties. I also intend to bring it up at our local club meeting this Thur. I may be able to get a few more interested.
Norm

[WA3VJB]

I've never received on correspondence from the ARRL on this issue. Why?

Steve, of all people they could have asked, you are the webmaster of the ARRL's AM page.

I wonder if you would get in trouble if you were to use your position to now use that page as a vehicle for some of these deliberations now underway in the aftermath of the oversight against AM at the IARU activity in Brazil.

http://www.arrl.org/tis/info/am.html

[Todd, KA1KAQ]

It's also amusing to hear all those who trumpet that the band plan is voluntary but leave out this tidbit.

The vast majority of amateurs in all countries do conform to the IARU bandplans and it is in our own interest that it should continue to be this way.

Which is exactly what concerns me. Why, if it has no bearing, would you subject your group/committee/union to objections and possible scorn and ridicule over such restrictive language? Because this, like the AM 'Exception' the ARRL promoted before, is an excellent way to get a foot in the door and prove or provide some need or credibility.

"But all of the other countries are abiding by these guidelines, why shouldn't the USA?"

[AB5S]

On forwarding the email received:
It will be much more effective if you
 re-write the letter in your own words,
and if you send a copy to each person on the list
individually.  "Form Letter" forwards addressed to
multiple people get little respect.
Many email programs filter-out such mail.
Besides- I don't think they'll cotton to
"Big, little and small" as definitions.  Too vague, IMHO.
You know- I wouldn't mind a bandwidth vs. mode
specification; it would allow for experimentation.
But not at the restrictive level of 2.7 KC. 
6 or even 9 makes more sense.
73 Dave S.

[WA3VJB]

OH yes, I hope folks will just take those as talking points, but hey, if they get multiple sendouts that's okay too, since it shows the level of concern. I agree that some spam filters will scrape off an email with too many cc's, but from the traffic I've been seeing in response, the cc list among IARU players is long and varied.
On the enumerated bandwidth, the pitfall of ANY hard number is the need to combine it with a definition. John, W3JN pointed this out quite well in his rebuttal to the pithy sendout from Isely:

one of the reasons the ARRL regulation-by-bandwidth proposal failed was that bandwidth was never strictly defined, nor was any method of measuring same defined.  Would bandwidth be measured at the -3dB points?  -6dB points?  -30 dB points?  How, and with what instrument that is readily available to most amateurs?  Although I have 22 years of experience as an RF engineer, I must tell you that measuring the bandwidth - even when that term is strictly defined - is no easy task on non-repetitive signals such as voice.

The only practical bandwidth-based segregation is what we already have, large for phone, medium for other stuff, and narrow for CW.

Sure, an adjective is softer than a number, but it's just as vague to toss a specified bandwidth out there without a reference to measure compliance.

I got the idea of substituting footprint instead of numbers from among the alternatives we have been discussing on here.
I since have gotten emails from Dave Sumner and Larry Price, functionaries at the IARU who are either present or former ARRL administrators.  Price wrote a somewhat rambling article for the International Telecommunications Union, in which he expressed his opposition to "footnotes."

A footnote is how the ARRL's representatives tried to treat AM in their failed bandwidth petition to the FCC, later withdrawn, and it is the same tactic used in early versions of the IARU's voluntary band plan taking effect in January.

Onetime ARRL president Larry Price, W4RA, now president of the IARU

In his ITU article, Price wrote, in part:

The amateur radio community seeks increased harmonization of frequency allocations, through the reduction and avoidance of country footnotes that reduce the availability of bands that are allocated internationally to radio amateurs.

In effect, Price equates the concept of footnotes with reduced availability of bands to licensees.  This is what would happen if AM were relegated to the status of a footnote in the voluntary IARU Region 2 Band Plan, which is why it is a suitable reference in expressions of concern to these groups.

[Steve - WB3HUZ]

But not at the restrictive level of 2.7 KC. 
6 or even 9 makes more sense.

Why have any number when the current reg works just fine?

97.307 (a)

No amateur station transmission shall occupy more bandwidth than necessary for the information rate and emission type being transmitted, in accordance with good amateur practice.

[K7NCR]

Here is the first reply from my e-mailing of the objection letter:

Norm,

Thank you for letting me know of your concerns with regard to the band plan adopted recently by the member-societies of IARU Region 2. You sent your message to a number of individuals; because the ARRL is the representative organization in the IARU for radio amateurs of the United States , I am replying on their behalf.

IARU regional band plans have been in existence for many years. They are developed, reviewed and approved at regional conferences of the IARU member-societies. The band plans provide voluntary guidelines that are intended to assist amateurs in making the most effective use of our limited frequency allocations. They are not restrictions and carry no regulatory authority. On behalf of the ARRL, I can assure you that there are no plans to propose incorporating any IARU band plan into the FCC rules. One virtue of voluntary band plans is that they are more flexible and can be amended more easily than the FCC rules; writing them into the rules would be counterproductive.

The new IARU Region 2 band plan was developed by delegates to the Region 2 Conference from a number of countries. It does not align in every respect either with the FCC rules or with operating patterns followed by US amateurs. Unlike the United States , most countries do not have regulations setting out subbands for different types of emission. Even in the US the FCC rules do not provide much detail with regard to frequency use. As FCC amateur licensees we are obliged to cooperate with one another in selecting transmitting channels and making the most effective use of amateur service frequencies, and to follow good engineering and good amateur practice.

Your message objects to the Region 2 band plan for “suggesting limits that are more severe than regulations from the governments in the region.” However, the band plan does not contain “limits.” As voluntary guidelines the band plan cannot by definition be “more severe” than regulations. And finally, if the band plan did not suggest an operating pattern that is a subset of the regulations it would serve no purpose.

Your message refers to IARU President Larry Price as wishing “to discourage footnotes among the various regional plans he oversees.” First, the IARU President does not “oversee” regional band plans. Each regional plan is developed by the member-societies of that region, in accordance with the constitution, bylaws and rules of the regional organization. The regional organizations are autonomous entities and do not answer to the IARU President. Second, Mr. Price’s observation with regard to footnotes had nothing whatsoever to do with IARU band plans. Footnotes are not by their nature either good or bad; it depends on what they say. Mr. Price’s observation had to do specifically with footnotes in the ITU Table of Frequency Allocations that prohibit amateur operation, or authorize sharing by additional services, in certain countries in certain parts of the bands that are allocated in the ITU Table to the amateur service. One of the goals of the IARU is to minimize such footnotes. On the other hand, there are other footnotes to the ITU Table that are extremely beneficial to Amateur Radio, such as the ones permitting amateur-satellite operation. In any case this is totally unrelated to IARU band planning activities, which are internal to the amateur service and to each regional IARU organization and have nothing whatever to do with the ITU.

I hope this has reassured you that nothing will happen on January 1 that will in any way affect your use of AM. We are always seeking ways to improve the process of revision of the IARU Region 2 band plan and the ARRL Board of Directors, who determine the policy for ARRL’s input to IARU Region 2, are always open to member input on future revisions that ARRL delegates may take to future Region 2 Conferences. I encourage you to communicate with the Division Director in your ARRL Division.

Sincere 73,

Joel Harrison, W5ZN

ARRL President

Notice I'm "encouraged to communicate with the division director in my ARRL division". I sent him a copy of the letter also, we'll see what his response is.
Norm K7NCR