CTT Proposal is assigned an RM number by the FCC

[Art]

The first proposal, submitted by the Communications Think Tank group on the June 20, 2005, has been assigned the Rule request number RM-11305. For those who want to review the proposal: http://www.geocities.com/k3xf/Rver124F.pdf

The second proposal, submitted by the ARRL on November 4, 2005, has been assigned the Rule request number RM-11306[/size].

Hmmm, freedom vs despotism . . . thought that was already decided . . . break down that wall!!


-ap

[WD8BIL]

OK Guys ......

Over the 8 years I've been involved with the Heritage side of the hobby there has been MUCH discussion on the topics addressed in these proposals. Some very heated exchanges have ensued.

Whether pro or con, now is the time to speak up. Please take a few moments and file your comments on the FCC site.

As the preacher says; Speak now or forever hold your piece!

[WA3VJB]

Bud is exactly right -- the best way to help the FCC decide IF any changes need to be made is to do what the ARRL has done with its bandwidth petition, and what the CTT has done with its deregulation petition.

Both become opportunities for the public (that's you) to file Formal Comments in support or dispute of the proposals.

It is not yet clear to me, as a member to the CTT petition, when the Public Comment filing window opens -- it may not necessarily be at the mere issuance of an RM number for the two Petitions cited.

[Art]

Indeed there will be supporters of the ARRL and/or CTT proposals who are truly invested in the greater good of amateur radio. Of course, there are those who will support or oppose on principle and I respect that as well.
Again, we see the spectre of digital or phone anarchy raised and again I reply: The CTT proposal is based on the concept of less mode based regulation and a shift of some of the resources currently policing mode based regulations to enforcement of the non interference regulations currently on the books. This applies to human, animal, vegetable, mechanical, or silicon based life forms, and whatever mode and automation status of any transmission. If they have a US amateur radio license they will be required to avoid interference with communications in process.
I see no reason to leave spectrum unoccupied and subject to incorrect assessments by other services that it is unused. I see no reason to leave exclusive sections of the amateur bands allocated to specific modes that don't occupy the allocation when other mode allocations are crowded. I see no reason to restrict the majority because of a minority who will not follow regulations in any case.
Some "exclusivity" would still exist, if that is important to you, in the license based sub bands as incentive (no, I don't even want to go to the incentive licensing discussion) for those holding more advanced licenses.
Amateur radio operators have been recognized and respected as the gentlepeople of hobbyists from the perspective of those in the hobby and those observing our activities during communications emergencies, etc. etc. I believe this recognition is correct and we can conduct ourselves properly . . . particularly if the FCC is recognized by the licensees as stepping up enforcement of non interference regs.

OK, so you have my opinion and you can take it or leave it. However, now is the time to hammer out a band plan.
My partners in the CTT are probably thinking, Oh . .  gee, there goes Art . . . again.
However, I have done a 5 month band occupancy study (similar to my short term study presented in the CTT proposal) and find that the following occupancy exists CW~30%, Digital (all types) ~ 10%, and Phone ~ 60%. One of my discussion partners has suggested the gentlemans agreement need be no more complex than this three section plan. It would create a plan much like 160M is today, reasonably well aligned with the rest of the world, with segments of the band recognized as primarily occupied by a given mode but not exclusively occupied by it. Yes, this all goes out the window when contests occur . . . we aren't going to change that . . . So what do you think? Ideas, input? Now is a good time to thrash this out and be ready when the time comes so we can define our own plan vs others who may represent a small percentage of amateur radio ops or other interests entirely. . . .

Art

[WA3VJB]

Both the CTT propsoal and the one from the group in Newington carry a 30 day Comment filing window from January 6th.

[Art]

This may be of help in observing comments:

http://gullfoss2.fcc.gov/prod/ecfs/comsrch_v2.cgi

'and this link for filing your comments:

http://gullfoss2.fcc.gov/prod/ecfs/upload_v2.cgi

for reference the CTT proposal number is RM-11305

Everyone, please, comment. Your input is critical.

[W2INR]

Thanks for the quick links Art ,

I just filed my comments on RM-11306 and it was very easy and painless. Just fill in the blanks.

I  have read all of the comments so far and they are as simple as"I am opposed "or "in favor of", to the more self-centered miserable ham type of comments.  Kind of just like on the radio!!

After reading the two submitted RM's, 11305 and 11306. I felt the more important matter right now was to not allow the ARRL's " segregation by bandwidth" RM-11306 plan to succeed. That could be the end of the hobby as we know it or at least the beginning of the end.

Now I know ,as with  myself, that many that hang here on AMfone are not politically motivated, but we have a responsibility to our hobby and ourselves to comment on RM-11306. Those of you that know me understand I despise politics but this isn't politics, it is saving our hobby from the ARRL's attempt to sell us out for monetary interests and I can not stand by and watch this. CAN YOU?

The participating level is important here. It will send a strong message to the FCC.

I am asking all of our users and guests that frequent this site to file you feelings on RM-11306. We have almost 1000 registered users and more than twice that many daily guests that frequent AMfone. I am also asking for all to make sure we spread the word around to all Hams also because this is not an AM issue it is an amateur radio issue.

I am offering my services to file for anyone that feels they can't or don't know how. All you will need to do is send me your comments along with your full legal name and address in an email an I will file your comments for you.

If you feel comfortable doing this yourself then stop reading this BBS and click on the filing link Art posted above and spend  5 minutes for your hobby.


We have 30 days to file and then it is out of our hands. That is 30 days from 1/6/06.

If you wish that I file for you then send your comments with the info listed above to:

 stoprm11306@amfone.net

Thank you and please take this seriously.

Gary/W2INR

 

[W2INR]

Whew!

Well with that all said I wanted to comment on the CTT's initiative or RM 11305 as we know it now.

What a refreshing change from the old ways where the ARRL dictated to us our hobby. We have a choice! We could have had many more!!

I appreciate the hard work taken by the CTT( where the hell did that name come from   ) and what it shows us. It shows that anyone that has a strong feeling about our mode or hobby can be viewed in the eyes of the FCC at the same level as the ARRL ( I really don't know if that is good or bad) with some effort.

Just like many of the other countries in the world that have ham radio, dereg seems to work just fine and it should be a direction we are lookng towards in our future in my opinion. I seem to have many opinions today don't I. . 

We owe it to our hobby to work towards holding this all together in todays world where anyone can talk across the world in seconds with a laptop, cellphone etc. The magic is gone as far as  long distance radio is concerned to the NON radio populaltion in the world, but I think there is still hope.

Just like Satelite radio has kicked Broadcast Radio in the butt and I believe for the better, change (dereg or something) in our hobby could also be a positive thing if handled correctly.

Take the time to read and comment on 11305. It's time to ensure our future will be as fun and interesting as the history of our hobby has been. I do not know if dereg is the answer but the work put forth in this proposal by the CTT deserves a few momnents of our time considering the time and effort put forth by another small group of amateurs for our hobby.

Thanks to the CTT group and thanks for the excitement your efforts I feel are going to bring to our hobby in 2006 and maybe our future.

This concludes my political postings for the year, man I am glad I got it all out of the way at once!!

Back to building

Thanks

G

[W3SLK]

I just finished commenting on both proposals. It was very easy. However I did find it difficult to restrain my self from typing in ARRgghhL when refering to the Nutbags from Newington.

[Ed KB1HVS]

I just got this.....Proceeding RM 11305 is not open for submission to ECFS.  When I tried to submit my comment in favor of the CTT proposal. Did I  F -up? I was able to submit my oppoisition comment though.

[W2INR]

Hi ed you left out the "-" I think.

RM-11305 and don't forget to voice your opinion to 11306 also .

[Ed KB1HVS]

Hi ed you left out the "-" I think.

RM-11305 and don't forget to voice your opinion to 11306 also .

Yes I was able to do that. I will try again.

[k4kyv]

As expected, this ARRL proposal has already brought the anti-AM element out of the woodwork:


Proceeding: RM-11306     Type Code: CO 
Date Received/Adopted: 01/10/06    Date Released/Denied:
Document Type: COMMENT    Total Pages: 1
File Number/Community:    DA/FCC Number:
Filed on Behalf of: Richard L. Tannehill
Filed By:
Attorney/Author Name:    Document Date:
Complete Mailing Address:
5410 W. diana Ave.
Glendale, AZ 85302 -4870
Brief Comment

I agree with the ARRL petition for regulation by bandwidth, and support it, with one major exception.
The League claims that their plan does not favor one mode over another. Not true. It favors AM-DSB
operators. It would allow for 9 KHz AM modulation, in bands which otherwise are limited to 3.5 KHz.
These include the lower HF bands, which are quite crowded at times. The solution is simply to
restrict AM-DSB to above 28.5 MHz. (10 meters & above) Amateurs and the league have been
upset in the past over wide-SSB modulation, meant to improve audio quality. AM is no different from
this. It is an old modulation that adds nothing to advancing the technological art, and should be
confined to bands where there is ample spectrum available.

Richard L. Tannehill P.E. - W7RT

ARRL Life Member
(45-years amateur licensed)

[W2INR]

That's right Don,

As I stated in my post above this could be the end of things as we know it. The ARRLs proposal does not mention the bandplan at all which is suspicious to me. Why wouldn't they? Giving them this victory would give them Carte Blanc on our hobby in the future.

We  don't have to agree with either proposal but in my opinion we must oppose the ARRLs proposal if we do anything.  Participation in this matter is important to us and all amateurs.

I have asked Paul K2ORC to keep a daily updated tally on the results from the comments. I feel we all need to know how this is playing out and having a running tally here is easier then going to the FCC's site.

[Paul, K2ORC]

I will be trying to update the daily count on each petition by 9:00 am ET.  You'll find the results in the Sticky thread Daily tally on RM-11305 and RM-11306   here in the QSO Forum. 

[Glenn NY4NC]

Done!.... How long will it take for comments to show after being posted?

We  don't have to agree with either proposal but in my opinion we must oppose the ARRLs proposal if we do anything. 

[WA1GFZ]

I find it very easy to be against 11306 but on the other hand deregulation has really screwed up the power industry and I have never seen a case where it worked.
I have to consider a kid running 50 watts on cw while some slop bucket moron running 10 KW driving him off the air. I have to give 11305 some thought.
There are a large number of AHs who will spread crappy operating across more bandwidth if the bands are deregulated. I do think digital modes can share space with CW a digital mode.

[Paul, K2ORC]

Done!.... How long will it take for comments to show after being posted?

Hi Glenn.  My experience has been that comments will show up the following business day. 

[Art]

Hi Frank,
One could also cite telephone deregulation. Long distance before deregulation was a lot more expensive than it is now. But this is not about cheaper electricity or phone service due to regulation removal. It is about amateur radio operators. We have been recognized as one of the most gentlemanly and public service minded hobbies and justifiably so. The 10KW miscreants are a lot fewer than the solid ops who run a tight station. Further the 10KW gang won't follow more or less regulation anyway. The good news is they are a minority. The bad news is they stick out like a sore thumb. Sen. Lieberman provided a great analogy; there are 27 million Iraquis and 10 thousand terrorists ruining the country for everyone. So, the bottom line is more regulation restricts good ops because of the behavior of the 10KW twits. That's just not right.

This ends my political rant for the year as well.

-ap

[WA1GFZ]

I see your point Art but I don't think much of mr lieberman.

Just listen to 75 phone and you will see my concern.

[Paul, K2ORC]

The rules are already in place for dealing with bad actors.  They just need to be enforced.

[WA1HZK]

Comments were supplied.
There is less than 50 comments. Half of them would have us slow roasted over a large fire. Don't delay. File your comments now or start selling your stuff on E-Bay!
If AM is Outlawed, Only Outlaws.....
You know the story. This is important. Get off your Ass and do it.
Thank You
Keith

[Todd, KA1KAQ]

Got mine sent. While I'm not quite up to snuff on all of the IARU requirements and how much it obligates us, I do think that RM-11305 is a big step in the right direction and that 11306 is a big step down the road to demise for ham radio.

One thing that I firmly believe: we won't attract more people to amateur radio by making it more like the internet, or a cell phone, or a video game, or whatever else. While I'm not against other modes including digital, it's in our best interest to maintain the hands on, human factor in it. I think that the ARRL proposal, while dressed up in such a way as to appear to be doing this, makes it pretty clear what they see for the future of ham radio.

Hopefully the rest of the folks out there will make their voices heard. I doesn't get much easier. 

[W2INR]

The important issue in my opinion is 11306.  That is dangerous ground there.

11305 offers a direction for our future and whether it passes or not is not the issue. The issue is the proposal was accepted and is be considered right next to the ARRL!!

 No more one sheriff towns for our hobby.

[k4kyv]

Just thinking out loud at this time, still trying to organise ideas for comments. But first I am carefully reading over and digesting the petitions, highlighting pertinent points.

One idea that comes to mind right away is that the stated objectives of the ARRL petition could be accomplished simply by adding additional "emission standards" to the existing table in Sec. 97.307 of the regulations, to the effect that an amateur station may transmit other modes not specifically mentioned in the list of authorised emission types for each wavelength band, so long as the "necessary bandwidth" does not exceed X number of kHz.

We should keep in mind the important distinction between "occupied bandwidth" and "necessary bandwidth" as discussed in the petition.  As I read it, the proposed bandwidth figures would be guidelines replacing the existing mode designators, not specific limits to the actual bandwidth used, just as there are no specific bandwidth limits in the present rules.  The biggest problem I have is with relegating AM to a "footnote."  And there is no guarantee that the FCC would come out with a proposal identical to what the ARRL has petitioned. They might just conveniently omit any "footnote" for AM, as in Docket 20777.   Recall what happened with incentive licensing.  The original petition was to return to the old Class A/ Class B restricted phone band system, but the FCC instead came up with the idea of dividing the bands into segments.

NBFM which is presently allowed in the lower frequency phone bands, as I read the petition, would be eliminated along with ISB.

One form of band segmentation I might still go along with would to limit automatic and semi-automatic operation to a narrow portion of each band, for the same reason that repeaters are limited to certain portions of the VHF/UHF bands.

Regarding RM-11305, I would take it a step further and eliminate the licence class subbands as well, since the concept of Incentive Licensing has pretty much already been gutted by previous "restructuring." For example, what is the point of continuing to have Extra Class cw subbands, now that the code speed requirement for Extra has been reduced to the former Novice level, and is now the same as that of all the other licence classes allowed to use cw on hf?  Originally, these choice segments for working DX provided an "incentive" to increase one's code speed to 20 WPM, but now the FCC is  proposing to get rid of the code test altogether. 

The "crowded conditions" and QRM the anti-AM'ers are whining about could be much more effectively alleviated by opening up the vast wasteland of unused spectrum below 3700 kc/s, than by outlawing AM.