CTT Proposal is assigned an RM number by the FCC

[Ed KB1HVS]

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

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

The FCC Acknowledges Receipt of Comments From …
Edward Keyes
…and Thank You for Your Comments

Your Confirmation Number is: '2006113937257 ' 
Date Received: Jan 13 2006 
Docket: RM-11305 

Number of Files Transmitted:  1
 
     Dunno why I had trouble. Maybe I was getting QRMed   I am very much in support of RM-11305 and i hope it id adopted.

[WD8BIL]

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

Frank,the 75 meter problem is a factor of overcrowding for the most part. Allowing any mode anywhere in the band would help reduce the friction.

Consider driving: There's far more road rage on congested freeways than there is on country roads.

 

[John Holotko]

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

Frank,the 75 meter problem is a factor of overcrowding for the most part. Allowing any mode anywhere in the band would help reduce the friction.

Consider driving: There's far more road rage on congested freeways than there is on country roads.

 

Exactly right. I never hear the kinds of problems when I listen down on 160 that I hear on 75. Likewise I seldom experience the kind of problems on 40 that I do on 75.  The more breathing room the better.  The more relaxed it becomes.

[Pete, WA2CWA]

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.

I'm willing to bet that the petitioners would still be happy if they only got this.

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.

Your first two sentences are correct and the significance of "occupied" vs. "necessary" bandwidth seems to always get lost in any discussions. Further, your phrase "relegating AM to a footnote" tweaked me early on when I saw it in the early drafts, but Sumner and Company were unwilling to change the Table of bands and defined bandwidths to include the 9 KHz(for AM) on each specified HF band.

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.

If you agree in part with RM-11306, then your statement above, which is an excellent proposal to limit this type of operation by legal, not voluntary methods, to portions of each band, should be added to your comments.



[/size]

[k4kyv]

I wanna make sure about this -- we're only supposed to provide comments to the two RM's,  NOT to comments submitted for the RM's from others, right?  Mark K3MSB

You can submit comments specifically in response to someone else's comment, and enter it as a "reply comment."  Usually the deadline for reply comments runs 30 days or so beyond  the cutoff date for initial comments.

Since this would be in response to petitions by individuals, not a Notice of Proposed Rulemaking by the FCC, I am not 100% sure if the same reply comment procedures apply.

[Pete, WA2CWA]

I wanna make sure about this -- we're only supposed to provide comments to the two RM's,  NOT to comments submitted for the RM's from others, right?   

Mark K3MSB

I personally would not get into "he said" " he said" from other comment posters  kind of stuff when you file a comment. The issue is the petitions and their content. Of course, with carefully worded english, you can always refute other posters comments indirectly.
i.e. Poster says "AM sucks - not good for anything"; you say AM has made me a better amateur radio operator and person, and I hug my wife and kids every day, etc. etc.

[W2INR]

Typically the he said, she said's are ignored by the FCC . The are looking for comments on the proposed items only Mark.

[k4kyv]

Typically the he said, she said's are ignored by the FCC . The are looking for comments on the proposed items only Mark.

The FCC invites your response to comments filed by others.

To make a specific reply to comments already submitted by another party, open the    
Electronic Comment Filing System web page at  http://www.fcc.gov/cgb/ecfs/. To the right of the page, find ECFS Main Links.  Click on Submit a Filing. That will bring up a page entitled Electronic Comment File Submission.

On the "Cover Sheet" form, go to item 12. Document Type (required) .  The space should already be filled with the word COMMENT.  Now click on the downward pointing arrow at the extreme right of the space.  This will bring up a long menu of filings.  Scroll down and click on REPLY TO COMMENTS.
Then follow the instructions under Send Comment Files to FCC (Attachments) to submit your response.

[WA3VJB]

It may clutter up both your response and the database of Comments filed if you were to take the time to confront the Comments of others filed in this initial phase of the proceeding.

The REPLY phase is consecutive, not concurrent, and is the place where such rejoinders are anticipated. The Electronic Comment Filing System, according to how other rulemaking proceedings look, is not ordinarily in the style of a BBS where people have a floating conversation on points and counter-points.

That said, if you file a Comment toward the end of the 30-day period, you will be equipped with knowledge of points others have made, and can incorporate them into your Comment either directly or by inference.

Although it is not stated in the instructions for the ECFS, the opening date and duration of the Comment and Reply Comment sequences are important windows as to whether your submission is accepted in what is known as a "timely filed fashion," in effect, constraining Comments to the Comment phase (30 days from Jan. 6th) and Reply Comments after that.

Many people include in the filing itself the date,  as well as their name, call sign, and callbook address. This allows anyone including the agency to print out your document with all the information. Notice that the ECFS header contains your identification and the date you filed it, but this does not appear in your actual document.

Paul/VJB

[W2INR]

Don you are correct but - - - - are we going to end up in a pssing contest with someones comment that deserves no attention at all or address the item that most threatens the hobby? That would be 11306 not discontents and miserable ham types.

I say address the issue clearly not qualify the idiots in our hobby.


ADDED COMMENT:

This is my first time in this process so I may be wrong but I feel we need to stay focused on what the main issue is.

[k4kyv]

The following web page has appeared, in opposition to RM-11305.

http://www.w8ji.com/rm-11305.htm

There is a link off that page that goes to:

http://www.w8ji.com/supporters.htm

[kc2ifr]

Boy......after reading the stuff on this a$$ holes site.....I cant believe the negitive spin he puts on all the "facts". This is the kind of lies and half truths that we have to put up with. Kinda makes u wonder what is happening to this hobby.

[Steve - WB3HUZ]

One must remember, W8JI is a weak signal, CW, DX snob who thinks such operation is the epitome of amateur radio. All other activities must defer to his personal interests. That is tyranny. Thus, thus the democratic approach of the CCT is an anathema to him. His arguments only follow, but they are flawed since they are based on worst case hypotheticals, false straw-men and ad-hominem. It would be funny, if it weren't so sad.

[WV Hoopie]

W8JI: More Sh** in him than a Christmas turkey.


73's
Hoopie,

[Steve - WB3HUZ]

I made some claims in my previous post. Below I substantiate. My comments in bold.


====
If  you support the  ARRL's RM-11306  plan and file  comments, please  mention 160  needing regulated  band segments.

To be fair  and get a good  picture of how  RM-11305 can  affect us, we  should look  at  operators  who support  RM-11305.  These are the  operators who are  pushing for freedom to move to  be able to operate  any bandwidth mode  on any frequency  their license  class allows.


Ad-hominem. The claim here is just because someone supports 11305, they are bad characters. My God! These guys want freedom. They must be evil. But he did preface it with, to be fair, so I guess if what follows is unfair, it's OK.

After that,  please look at  what RM-11305  means in the text  below. You'll see  why it is  imperative  RM-11305 be  stopped cold.

The text below are just W8JI opinions, based on flawed analysis, faulty logic, and no documentation. What the proposal means is something completely different. Notice, he does not request the reader to go and actually read 11305. Instead, just take his word for it.

This is taken  right from  RM-11305 on the  FCC site:
  
"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."

What They  Want 
 The self-anointed "Think  Tank"  is asking ALL FCC  regulations and  restrictions of  who-does-what-where,  within a license  class, be  removed!!!  Anywhere you  decide to set your  dial you would be  free to operate  any mode.

Notice the derisive name calling. The Think Tank is no more self-appointed than he is with his comments. His tyrannical nature shines through here. "How dare these self-appointed one speak or even have an opinion." Notice his objection to freedom. Quite revealing.

He also utilizes incomplete information or a half truth by claiming the proposal means that "Anywhere you  decide to set your  dial you would be  free to operate  any mode." He left off the part about a band plan and the bigger part about not interfering or following the frequency is in use rule. He attempts to pander to the worst fears of others, by hinting at complete anarchy and massive interference. He's laying the ground work for later claims.



What This  Means

Let's consider  what anyone could  legally do as an  Extra class holder  if RM-11305 is  adopted as  written. The  following is the  result of RM11305  passing:

I like AM  phone, and I could  go on any mode  anywhere on any  amateur band.  There would be no  FCC restrictions.  What I do would be  up to my own good  nature and judgment. It's  early in the day,  the band is pretty  dead. I decide to  start talking to  my buddies 200  miles away on 7015  kHz AM. We get in  a 10 minute per  transmission roundtable, and  the occupation of  the frequency  lasts well after  sunset. During  that time, my  Viking I driving  an amplifier is  occupying from  7000 to 7030 kHz  with a -50dBc or  stronger signal at  1500 watts PEP. I  now legally raise  the noise and QRM  floor  substantially for  anyone operating  between 7000 and  7030kHz or higher.  I have effectively  shut down the  entire useable 40M  long distance CW  portion. No one  can do anything  about it! I  was there first,  so the channel is  mine.

This tactic is called a strawman. The idea is to put forth the absolute worst case scenario (at least to people like W8JI, DX hounds) and argue from it, as though such a situation would pertain universally. Such an approach is flawed. It's a fallacy.
 

My friends want  to try a new mode.  We go to 14,035  KHz FM and operate  until daylight on  a puny band with  15kHz wide FM.  Since we were  there first, or at  least we thought  we were, we stay  long after the  band opens to  Asia. Even if we  knew better, we  could simply  pretend we were  there first and  deny all requests  to move. We could  take out 14,027 to  14,043 kHz over  much of the world  with 1500 watt FM  signals and be  legal.  

Another strawman, invalid as the previous. 

 

If you are on  PSK working a PSK  station and I  can't hear you or  recognize your  signal, I could  open right up with  1.5kW SSB or worse  yet with 1.5kW PEP  HiFi AM right on top of you. It  would be up to you  to get my  attention and ask  me to move, and up  to me to be a  "nice  guy" and  move.


Another strawman, invalid as the previous. He also plays to the worst fears or digital operators - the dreaded phone interference. 

If I hear a SSB  station on 3500kHz  USB, and wanted to  work him....I  could. Never mind  that W3AAA is  trying to work a  European on 3505  and the IM3  products of my transmitter at  -33dB PEP have  placed a 3/4 watt  SSB splatter on  3505.

Another strawman, invalid as the previous. I love how he just pulls numbers out of the air. No factual basis for any of it.
  

 
 In  my opinion, the  above scenarios  coupled with the  obvious attitude  of supporters  is  what  makes this  proposal moronic.  No intelligent  thoughtful  considerate amateur operator  would ever  think amateur  radio would  benefit or improve  by allowing any  operator to  operate any mode  on any frequency  within his class  of license, yet  this is what  RM-11305 asks for!


A  complete mischaracterization of the proposal. 11305 still calls for a band plan. Also notice the name calling again. In other words, if you disagree with me you are a moron, unintelligent, thoughtless and inconsiderate.

Check out this logic.

"... the  above scenarios [which are bogus strawmen] coupled with the  obvious attitude  of supporters  is  what  makes this  proposal moronic." Huh? How would the attitude of supporters have anything to do with scenarios he MADE UP? He has not even supplied any evidence (a statement by ANY supporter, let alone ALL) as to the attitude of the supporters. Further, he lumps ALL supporters together, a dangerous thing to do, in general. It's even worse to do so without providing any data. This is a lame attempt to link any supporter of the proposal with the type of operation described. Since he claims such operation is bad, those who support it, by extension, are bad. This amounts to either a blatant attempt at smear tactics, or weak and faulty logic leading to a foolish conclusion. Neither one is acceptable.

Right now, an Extra class licensee can operate CW anywhere in the amateur radio bands. Using his logic, such freedom should be banned because a CW operator could jam an SSB net providing emergency comms for Hurricane Katrina, resulting in hundreds of deaths. Yea, I can be absurd too.

  
Please,  let's not let any  small group drive  a nail in the  coffin of amateur  radio by turning  it into a licensed  form of freeband CB  where anyone can  do anything they want!

Ah yes. A bogus amateur radio argument is never complete without the obligitory reference to CB radio. What no reference to Hitler, or someone's mother?

He also makes the claim the proposal will drive a nail in the coffin of amateur radio but provides no evidence or proof (sorry, stawmen don't count). This is a gratuitous assertion and, as such, is just a easily gratuitously denied. RM-11305 will not drive a nail in the coffin of amateur radio. See, how easy this bogus argument stuff is to spew forth?


A west coast  amateur said it  best in the  following comment  from the Topband  Reflector:

  "Any  self-appointed  group that has the  arrogance to call  themselves the "Communications  Think Tank"  gives me the  shivers to start  with, but the content of their  proposal lays  waste to even the  pretense of  intelligent thought.  I'm  not at all against  change in our  hobby, and I'm  willing to accept the fact  that change might  come in the form  of regulations  that negatively impact  my own operating  preferences.   I'm trying to keep  an open mind on  RM-11306 from the  ARRL (band  allocations by  bandwidth), but RM-11305 from the  "Communications  Think Tank"  is just plain  stupid. 

It would be interesting if a group put a proposal forth that perfectly agreed with his views, if the name Communications Think Tank would be so unacceptable to him. When one does not have a cogent argument at the core of the issue, they will nitpick at the periphery. Stating that a name a bland as Communication Think Tank gives you shivers, comes off as a histrionic.

 Here's an excerpt  from the filing:
  
"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."
  
What  kind of thought  process could come  up with that  conclusion? 

Yes, what kind of thought process? Illustrate why the idea is bad or the thought process is flawed. That's right, when you have nothing, just ask open-ended questions.

 RM-11305 goes on  to suggest that  the ARRL and the  Official Observer system would  establish and  enforce new and  flexible voluntary  band/mode plans ... as if  any of that has  ever worked well  in the past.

It's never been done in the past, so any references to such are simply incorrect.
  
WD8BIL  appears to be the  leader/spokesman  of the  "Communications  Think Tank", and  this quote from  him (per Amateur  Radio Newsline  Report 1455 dated July 1,  2005) might give  some insight into  the real intent of  the petition:
  
"Under  heavy - for  example - phone  operation right  now, particularly on  some of the lower  bands where  overcrowding in  the peak hours is just  horrendous it  gives us the  opportunity to  spread out into areas of the bands  that are under  utilized."

Yep, we wouldn't want to fully utilize the spectrum alloted. That would be bad!
  
RM-11305  is so silly I find  it difficult to  believe the FCC  would give it serious  consideration, but  who knows these days."

Not one cogent argument given. Not one rebuttal. Just claim it's silly and poof, it is. Magic! And W8JI thinks this guy said it best. Wow!

 

Let Your Voice  Be Heard!

We really can't  afford to allow a  group of AM  operators hijack  any frequency they  want. While they  cleverly write the  petition as  something for the  good of all, the  fact is the bands  work really well  right now for most  people. The only  operators without  enough room are  the people who  choose to run wide  modes or choose to  use substandard  equipment. They  are the frequency  hogs, and they  need to be kept  penned up. We need  to discourage band  hogging, not  encourage it.

"Keep them penned up." Those who run a mode different than W8JI are akin to animals. Lovely.

Also notice the false premise: only those who run wide modes (not further defined) and those with substandard equipment (once again, not further defined) don't have enough room. Seems to me, many who run sideband complain about having too little room. I guess W8JI considers SSB a wide mode, anyone who runs it a frequency hog and a user of substandard equipment. Nothing like condemning the vast majority those who operate on HF.

Also notice the sense of ownership of frequencies. If an AMer wants to use a frequency, any frequency, even if it is not in use, they are hijacking it. Last time I checked my dictionary, hijack, when used as a verb, meant to take arbitrarily or by force. How could an AMer (or any other operator) take an unused frequency by force, unless one thinks they are entitled to the frequency EVEN when they are not using it? And this guy has the nerve to call the Communications Think Tank arrogant.


To file against  RM-11305 please click  on this FCC link  and fill in the  form. You can type  in a "brief  comment". 

Please help  save amateur radio  from crackpots  like K1MAN! I'd  like this hobby to  last many more  years, and not be  turned into  licensed CB. Of  course the jammers  and wideband phone  operators want  more space, but  should digital and  CW operators give  up space to  accommodate those  who use three or  more times the  necessary bandwidth for  broadcast-style  QSO's?

OK, now we get a substantial argument, a reference to K1MAN and another one to CB. Not!

Notice how he equates wideband phone operators (whatever this means, since he still hasn't defined it) to jammers. When I speak of faulty logic, this is what I mean. No reasonable person would equate illegal operation (jamming) to legal operation phone (be it AM or SSB - both are perfectly legal under Part 97). But when you don't really have a legitimate argument, you have to resort to such lowbrow tactics.

Also notice the flawed term necessary bandwidth. This is another undefined term that appears to mean any bandwidth wider than W8JI deems appropriate. Since all amateur radio communication, other than emergency communications, are non-essential, any mode/bandwidth uses more than is necessary. It's ALL unnecessary communication.

What, pray tell, may a "broadcast-style QSO" be? Even when this guy makes up terms, he is illogical. A broadcast is a one-way transmission. A QSO is a two (multi-way) transmission. Can you say oxymoron?


I think not,  and I hope you  agree! Let's not  turn 500,000  licensed amateurs  who are now going  into a  "no-code"  phase loose on the  world. We don't  need to add to the existing problems,  we need to reduce  them. We need  solid bandwidth  guidelines, not  rules that  encourage bad  behavior.  

Yes, he thinks not. Clearly, no thinking going on! Yet another number pulled from the air. Where is even one piece of documentation showing 500,000 amateurs are "going into a no-code phase" (whatever this means)? Even if this were true, it is irrelevant, unless you believe learning the code will ensure you never become one of those dreaded wideband phone operators who hijacks frequencies.

This entire piece is rather disjointed, undocumented, illogical and just plain incorrect. If this is the best effort to be mounted against 11305, we have little to fear.

[W3SLK]

Steve said:

Can you say oxymoron?

No, but what he should be saying is "Imamoron!" Brought to you by the fine designer of Ameritron amps. Tom Rauch. To paraphrase Rich Measures"...Rauch means smoke..." I think he's been smoking too much lately.

[Jim, W5JO]

Rauch is on Boatanchors@the porch pushing his agenda.  If anyone pays to subscribe to it, they could take him to task.

[WD8BIL]

Tom has much personally invested in the status quo. When that happens, all threats are targets for the type of un-substantiated attacks as this.

Most reasonable people see it for what it is.

Knowing Tom personally, I fully understand where he's coming from and , more importantly, WHY.
Our proposal comes from a belief, at least on my part, in the inherent good. Yes, we have some rotton apples, and they make a lot of noise. But, for the most part, operators are civil.

Obviously, Tom has a low opinion of phone operators and people in general. This comes across very strong in his rantings.

We all have an idea of how things should be. In the end, his is ONE voice.... same as mine.

[Steve - WB3HUZ]

"Yes, we have some rotton apples, and they make a lot of noise."

This is another fallacious argument used by W8JI. It's called spotlighting. You point out the very visible few of a group and the claim everyone associated with the visible few are bad too. And by extension, so are their ideas. It's rather sad that he chooses to utilize arguments that wouldn't muster in a high school debate club. I'm glad he's speaking out. It will only help the cause of 11305.

[Ed KB1HVS]

W8JI  Has a FB webste and I enjoyed what I read there. Until I got to the RM-11305  supporters page. Apparently some of the comments, opinions and quotes he has used from the AM community are very much taken out of context. Cant get anywhere with me by doing that. AM is what drew me into this hobby and I enjoy the mode and the people who use it. Naturally I will do what I can to try to protect it.

[W3NP]

I was just reading the latest comments on RM-11306 and W4VR has now made an additional comment which is aimed at "lawless" AM'ers that are beginning to '"deviate" from the "bandplan" and are now running loose all over the band wrecking havoc on what he infers to be the only legitimate phone mode - SSB. He is also ( like W8JI) advocating penning us up on assigned frequencies.

[John Holotko]

The following web page has appeared, in opposition to RM-11305.

http://www.w8ji.com/rm-11305.htm

There is a link off that page that goes to:

http://www.w8ji.com/supporters.htm

I don't understand his point. Matter of fact he doesn'tseem to be making any point. If anything he is also contradicting himself. He is certainly not  making a viable case for why the bands should't be open. First of all he accuses AM'ers  of wasting space but then he says he uses AM. If AM is  so wasteful then why bother ? Then he praises AM'ers and says he greatly respect them but then goes on to talk about AM'ers as a fringe group and as the scourge of ham radio. Why  is that ? If he respects AM'ers why is he so offended by the idea of AM'ers having more space  with which to operate ? If AM'ers are such a small fringe group as he claims  then why is he so threatened by a proposal to open up the bands. If anything it would benefit non-Amer's just as much or more than AM'er's. Look how much underused space  exists on the lower half of  the 75meter band which AM'ers and SSB'ers cannot use because we are not allowed to. Would it not benefit AM'ers and SSB'ers alike if that space  could be utilized.  We have a  similar band plan already in place on 160 meters and I don't see  what the problem is.  This guys reasoning will only assure the bands remain segregated, overcrowded and nobody gains anything, not the AM'ers not the non-AM"ers. So, other than making a web page and tooting his own horn (or hoisting his own petard)  I don't see what point this gentleman is making other than saying, "lets keep the bands overcrowded and overused or underused as they are now".  Makes no sense to me.

[Art]

I think you have hit it on the nose. . . Mr. Rauch seems a bit Baxtardish  . . .  look up Rich Measures and Tom Rauch in the same google . . .  I don't think you will get a felony affidavit but he has been known to use threats of law suits to pursue his technical disagreements. 'another facet of the gem . . .

[John Holotko]

I also like the way he picks on the no-code  operators and calls to restrict them. Instead of taking his snobbish approach and turning our backs on the new operators and restricting them wouldn't it  make more sense if we as hams reach out to them and try to encourage them  and teach them to do REAL radio the RIGHT  way ??  Unfortunately guys like =w8ji prefer the turn your  back on em and then piss and moan approach. Guys like this do little to promote and expand  the hobby. Instead they show a self  centered, snobbish side that if  anything will turn off new ops. and discourage them.  I also love the way he equatea the AM community and the new ops/with K1MAN.  Fortunatelyguyslike w8ji are in a minority, I think there are a lot more hams that would rather expand their horizons, open to new ideas, and embrace young new  operators in a positive light  and help them to hone their skills and become good ops. Unfortunately w8ji seems to come from a narrow world  that cannot accept  new  people and new ideas.

[W2INR]

It just goes to show you what "dumbing down" the hobby has done for us.