De-Reg Proposed Rule Making

[Art]

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

[Jack-KA3ZLR-]

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.

[Art]

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

[W2INR]

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

[Art]

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.

[k4kyv]

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.

[WD8BIL]

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.

[wa2zdy]

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.

[W3SLK]

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!

[Steve - WB3HUZ]

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.

[Jack-KA3ZLR-]

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

[Art]

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

[WD8BIL]

The biggest weakness I see in the proposal is the nature of any proposal made by a small group of people:

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.

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 [/b]- ARRL or otherwise.

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

[Glenn K2KL]

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...

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.

[Art]

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?

[Todd, KA1KAQ]

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.

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.

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.

[k4kyv]

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.

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.

[Glenn K2KL]

Never said anything about "bandwidth"...

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

You mean like AM?

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?

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.

[WD8BIL]

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.

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 !

[Glenn K2KL]

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.

It's time to stop favoring any mode and let them all receive equal treatment.

[Glenn K2KL]

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?

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.

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 !

[Art]

"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

[Glenn K2KL]

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: )

"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

[Art]

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

[Todd, KA1KAQ]

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