ARRL Files Regulation-by-Bandwidth Petition with FCC

[W9AD]

       Here we go.   

http://www.arrl.org/news/stories/2005/11/15/1/?nc=1

[W2VW]

Those clowns are doing this without my dues. The Roman Empire only lasted so long. Time to start anew.

[Paul, K2ORC]

   The ARRL demonstrates once again that it has its atrophied finger on the pulse of amateur radio. 

[w3jn]

Feh.  Way I read it is if/when this is adopted we now have phone privileges from 3620-4000 and 7100-7300 among others.  Doesn't really look like much of a change for us except to keep the audio within about 4.5KHz.

The whole proposal is, however, based upon the fallacial assumption that digital use is greatly increasing.  Maybe I'm ignorant but I just don't see it.

Although it's gonna provoke all kinds of on the air fights about "them AM boys is runnin to wahd a signals!"

[W2VW]

Although it's gonna provoke all kinds of on the air fights about "them AM boys is runnin to wahd a signals!"

Every lid with a prothree will be writing letters.

[Paul, K2ORC]

Although it's gonna provoke all kinds of on the air fights about "them AM boys is runnin to wahd a signals!"

Every lid with a prothree will be writing letters.

Which may be what stops this thing.  The FCC may ask why they want  more aggravation when they've already got guys complaining to R. Hollingsworth about everything else.

[k4kyv]

I printed all 25 pages of the petition so I can sit down comfortably and digest it all.

I don't think the FCC accepts comments to a petition until it has been assigned a RM- number.  Also, not sure if they have a reply-comment period for a petition that has not officially become a NPRM.  Maybe someone could clarify this.

No doubt some of the anti-AM crowd will call for getting rid of the 9 kHz exception for AM, and that's what bothers me most about this thing - AM would be permitted only by an exception containted in a footnote, which could be very easily deleted.

Also, there is no guarantee that the FCC's NPRM would even resemble the original petition.  They could come out with something pretty much identical to Docket 20777, which would have eliminated AM altogether, back in the 70's.

Also, I'm not sure about the "occupied bandwidth" vs "necessary bandwidth" issue, as far as how bandwidth would be defined.

The last time I checked, Canada still had a maximum bandwidth limit of 6 kHz for AM, but I never have heard of a Canadian ham being cited for running too much bandwidth while running a normal AM signal. I don't know how picky the FCC would be about this.  Of course, a strict 3.5 kHz limit would shut down a lot of slopbuckets as well.

[WA3VJB]

You would have thought that with all the time spent deliberating this long-threatened proposal that the group in Newington would have tried to come up with a reason WHY it feels the need to "encourage" what it calls digital techniques and advanced technologies.

It failed to do so.

Their unstated premise, that these modes are now suffering a lack of popularity and acceptance, undercuts whether it makes sense to force such modes by way of the regulatory structure.

John's observation may become a popular argument against their idea --


The whole proposal is, however, based upon the fallacial assumption that digital use is greatly increasing.  Maybe I'm ignorant but I just don't see it.

In my view, this is the strongest argument to make, and better than if we were to weigh in with a pile of gored-ox comments.

[w3jn]

I guess I don't really have too much of a problem with this proposal.

It (apparently) allows use of the underutilized CW sub bands (in particular, the old novice sub bands whose denizens are now only tumbleweeds) for phone.  That's a Good Thing.

The "effective" bandwidth provision *appears* to imply that if you take care in engineering your station to keep within the BW limits, that appears to comply with the spirit of the law.  Another Good Thing (or at least, better than it could have been).

The main downside I see is that this is gonna create all kinds of new angry complaints to the FCC for perceived violations of excessive bandwidth.  As if 99.9% of the hams out there have the slightest clue of how to measure and/or how to keep their signal clean.

The second issue is digital stations cropping up in what is now the phone band.  Just because two signals are of equivalent bandwidth doesn't mean they can coexist peacefully, due mainly to receiver limitations.

[WA3VJB]

There are a bunch of problems with this proposal John.

Not in any particular order, but the top issues are:

There is no documentation to support Newington's claim digital is popular.

There is no precedent of using the regulatory structure to promote a specific mode or activity.

There is a penalty to contemporary, popular modes -- constraints on bandwidth.

No accompanying proposal for a "voluntary band plan" that Newington predicates this petition upon.

[W8MW]

Oh, how the spin has spun since the petition was announced in 2004.  The new language suggests they are making oh-so-generous concessions for the handful of amateurs who won't jump on the digital bandwagon.  Mighty big of 'em, but 180 degrees away from their original goal of "making adequate provision for digital modes in the HF amateur bands".

Last year it was absolutely necessary to gain regulated spectrum and opportunity for digital to thrive.  This year it's a machine-copy radio service allowing exceptions for human-copy emissions.  Are we having fun now?

3's Mike   

[Paul, K2ORC]

Although the ARRL proposal appears at first glance to seek an expansion of phone operation on some bands, things aren't always what they seem.  

Footnote 12 at page 11 of the Petition for Rulemaking reads in part:

"Nor is the proposal a means of expanding telephony subbands. The specification of bandwidth only will have the regulatory effect of permitting telephony operation.....  However, it is not the ARRL's intent to encourage telephony operation in those segments.  Rather, such matters should be regulated by voluntary band planning."

This seems a tad ironic in light of the following, found two pages earlier in the Petition at Section II, paragraph 11:

Because there is strong tradition in the United States of restricting subbands by rule rather than purely through voluntary band plands, complete elimination of regulatory band segments and complete reliance on informal band planning does not appear to be a suitable option in the United States.

Despite a purported reliance by the ARRL Petition on signal bandwidth as a way to divvy up the bands, it would appear that a paraphrase of Animal Farm might be apt:  some modes are more equal than others.  

[w3jn]

Paul/VJB - agree, agree, agree with your points.  However, until Paul ORC pointed out the Fine Business Print, I thought that perhaps we were actually a step ahead.

Paul/ORC, thanks for pointing that little discrepancy out.  I can now wholeheartedly piss on this proposal. 

[W2VW]

Paul/ORC, thanks for pointing that little discrepancy out.  I can now wholeheartedly piss on this proposal. 

Picture the Who's Next album photo.

[WA3VJB]

What I want to know is where Pete/CWA has been.
He could explain away our fears and concerns with a wave of his

[w3jn]

<and then a miracle occurs>

[k4kyv]

This seems a tad ironic in light of the following, found two pages earlier in the Petition at Section II, paragraph 11:

Because there is strong tradition in the United States of restricting subbands by rule rather than purely through voluntary band plands, complete elimination of regulatory band segments and complete reliance on informal band planning does not appear to be a suitable option in the United States.

Note that they don't give any technical reason to maintain subbands, but justify this only on the basis of "a strong tradition in the United States".  Do the laws of physics somehow change when you cross the border into the US?  Basically, they are saying, that because I have a lousy American licence, I have fewer voice privileges than amateurs in any other other country in the world.  While hams in other countries can enjoy working foreign stations in a normal QSO directly on the other station's frequency , we in the US are stuck to working split frequencies because of the goddam subbands.

Wonder if the fee cee will go along with increased expenditure of its limited resources and federal tax money in order to begin  enforcing our "strong tradition" by measured bandwidth.

[Paul, K2ORC]

This seems a tad ironic in light of the following, found two pages earlier in the Petition at Section II, paragraph 11:

Because there is strong tradition in the United States of restricting subbands by rule rather than purely through voluntary band plands, complete elimination of regulatory band segments and complete reliance on informal band planning does not appear to be a suitable option in the United States.

Note that they don't give any technical reason to maintain subbands, but justify this only on the basis of "a strong tradition in the United States".  Do the laws of physics somehow change when you cross the border into the US? Basically, they are saying, that because I have a lousy American licence, I have fewer voice privileges than amateurs in any other other country in the world. While hams in other countries can enjoy working foreign stations in a normal QSO directly on the other station's frequency , we in the US are stuck to working split frequencies because of the goddam subbands.

Wonder if the fee cee will go along with increased expenditure of its limited resources and federal tax money in order to begin enforcing our "strong tradition" by measured bandwidth.

Ironies abound in this Petition, conceived and set forth in the Land of Liberty.  Hallelujah and amen. 

At the top of page 17 of the Petition, observe the hoops the ARRL jumps through while discussing what to do about 160 meters.  Now there's a real head scratcher.  Operating on a band without any regulation telling us "Thou shalt place thy voice here, but not there."  Perhaps something magical happens to operators' temperaments when they fire up on 160 meters?

Topband has a "strong tradition" of no division by modes.  So as the ARRL Petition goes through the bands on page 17, they expend far and away the most ink on discussing 160 meters.  And not surprisingly, since what goes on on that band disproves the League's assertion that the "paradigmatic change" urged in their Petition is necessary. 

[WA3VJB]

Newington's lawyer really should not try to use such big words.
Not only does it clutter up the points he tries to make, but he looks foolish for trying.
Paradigm, as the Petition uses the word, seems to be an incorrect choice.
Probably, and that's a stretch on my part, he intended to portray the need for a fundamental, systemic change. Instead, well, here, you try to sort it out.


http://www.m-w.com/cgi-bin/dictionary?paradigm
Main Entry: par·a·digm
Pronunciation: 'per-&-"dIm, 'pa-r&- also -"dim
Function: noun
Etymology: Late Latin paradigma, from Greek paradeigma, from paradeiknynai to show side by side, from para- + deiknynai to show -- more at DICTION
1 : EXAMPLE, PATTERN; especially : an outstandingly clear or typical example or archetype
2 : an example of a conjugation or declension showing a word in all its inflectional forms
3 : a philosophical and theoretical framework of a scientific school or discipline within which theories, laws, and generalizations and the experiments performed in support of them are formulated; broadly : a philosophical or theoretical framework of any kind
- par·a·dig·mat·ic /"par-&-dig-'ma-tik/ adjective
- par·a·dig·mat·i·cal·ly /-ti-k(&-)lE/ adverb

Definition 3 comes close to being an understandable application of the word, yet, what the group in Newington has proposed contains NO fomulation of where to perform the "experiments" in its theoretical system.

In other words, without an accompanying "Voluntary Band Plan" their proposal is a shell with no filling.

[Paul, K2ORC]

A QRZ.com thread[/b] is also underway with discussion of the digital modes that drive the ARRL petition.  

[Tom WA3KLR]

The Paradigmatic.  Isn't that a laundromat dryer?

Seriously though,  I renewed my ARRL membership 1 year ago for 3 years and am regretting it more every day.  I just sent in my ballot for Atlantic Division Director.  I wrote in Carl WK3C.  So my ballot wil be discarded I suppose.  He was disqualified by the Board because he MIGHT have a FUTURE conflict of interest.

[W2VW]

Newington's lawyer really should not try to use such big words.
Not only does it clutter up the points he tries to make, but he looks foolish for trying.
Paradigm, as the Petition uses the word, seems to be an incorrect choice.
Probably, and that's a stretch on my part, he intended to portray the need for a fundamental, systemic change. Instead, well, here, you try to sort it out.


http://www.m-w.com/cgi-bin/dictionary?paradigm
Main Entry: par·a·digm
Pronunciation: 'per-&-"dIm, 'pa-r&- also -"dim
Function: noun
Etymology: Late Latin paradigma, from Greek paradeigma, from paradeiknynai to show side by side, from para- + deiknynai to show -- more at DICTION
1 : EXAMPLE, PATTERN; especially : an outstandingly clear or typical example or archetype
2 : an example of a conjugation or declension showing a word in all its inflectional forms
3 : a philosophical and theoretical framework of a scientific school or discipline within which theories, laws, and generalizations and the experiments performed in support of them are formulated; broadly : a philosophical or theoretical framework of any kind
- par·a·dig·mat·ic /"par-&-dig-'ma-tik/ adjective
- par·a·dig·mat·i·cal·ly /-ti-k(&-)lE/ adverb

Definition 3 comes close to being an understandable application of the word, yet, what the group in Newington has proposed contains NO fomulation of where to perform the "experiments" in its theoretical system.

In other words, without an accompanying "Voluntary Band Plan" their proposal is a shell with no filling.

They seem to have trouble with this one too:

Bandwidth
== Analog ==

For analog signals, bandwidth is the width, usually measured in hertz, of a frequency band f2 − f1. It can also be used to describe a signal, in which case the meaning is the width of the smallest frequency band within which the signal can fit.

It is usually notated B, W, or BW. The fact that real baseband systems have both negative and positive frequencies can lead to confusion about bandwidth, since they are sometimes referred to only by the positive half, and one will occasionally see expressions such as B = 2W, where B is the total bandwidth, and W is the positive bandwidth. For instance, this signal would require a lowpass filter with cutoff frequency of at least W to stay intact.

The bandwidth of an electronic filter is the part of the filter's frequency response that lies within 3 dB compared to the center frequency of its peak.

Image:bandwidth.png

In signal processing and control theory, the bandwidth is the frequency at which the closed-loop system gain drops to −3 dB.

In basic electric circuit theory when studying Band-pass and Band-reject filters the bandwidth represents the distance between the two points in the frequency domain where the the signal is 1/Sqrt(2) of the maximum signal strength

[WA3VJB]

Sometimes a real nugget pops up among the many comments and discussion points people have now brought out about the scheme from the group in Newington.

I discovered this one on QRZ.com, from Mike, W8MW :


IMHO, attempts to tweak the league's petition cannot mitigate the flawed process that produced a biased plan.  Among the many mis-steps of the digital committee, they took it upon themselves to mingle in the operating interests of legacy mode operators.  A handful of individuals not sharing these interests is intent on placing new restrictions on them.  I see this as arrogance to the extreme from those individuals and a serious lapse in stewardship by the league.  So now there's a petition seeking to regulate us all, based on the views of a few and lacking benefit of a fair and reasonable process involving all stakeholders.

Very well put! Thank you.
Put me on record associating myself with your comments.

Paul/VJB