ARRL Files Reply Comments RM11306 via Chris Imlay

[Tom WA3KLR]

Late this afternoon, I spotted the 14 page reply comment filed by Christopher Imlay for the League on RM-11306 Comments.  I downloaded the large document for serious study since it is too big to just read on-line.

I printed it out and I have only taken one skim through it so far.

I found the document to be revolting.  I will study it further.

[WA3VJB]

Yes Tom, revolting is a good word for it.

Their "reply" that tries to dismiss the valid concerns expressed by their would-be constituents is about the most patronizing filing I've seen from the group in Newington in the 30 years I've tracked their behavior.

Their anticipated treatment of Comments that do not coincide with their agenda is why it became very important for the AM community to register its protest against being portrayed as a non-compliant exception to their scheme.

Thanks again to all who participated.

[K1MVP]

Yes Tom, revolting is a good word for it.

Their "reply" that tries to dismiss the valid concerns expressed by their would-be constituents is about the most patronizing filing I've seen from the group in Newington in the 30 years I've tracked their behavior.

Their anticipated treatment of Comments that do not coincide with their agenda is why it became very important for the AM community to register its protest against being portrayed as a non-compliant exception to their scheme.

Thanks again to all who participated.
 

Paul,
The ARRL has called out the "fire brigade" now that the "ship" is about to sink,
with all these lawyers, in a "last ditch" effort to save their "butts".

They are calling out "SOS",-"-SOS", and the problem seems to be they do not
know what to use, AM, or CW,--as most of these guys have NOT used either
modes for years,--or they NEVER did know these "old modes".

Too busy,--using the "new digital" modes and sending e-mails on their "yachts".

I started to read Mr. Imlay`s comments, but I only got through the first two
pages,--and all I could think,--was more "slick" lawyer talk.
No wonder the ARRL,--is in trouble,--all the membership fees must be going
to pay these attorneys.

                                         73, K1MVP 
 

[WA3VJB]

Actually Rene, I don't hold Chris responsible for this.
He's just doing what his client has told him to do.

Frankly, he has not demonstrated his best writing skills in either the Petition or the Reply Comment you started to read. I don't think he's totally on board, and professionally maybe gave it less than 100 percent so he could still sleep at night.

Last time I saw him was last year on Capitol Hill. He was accompanying onetime League president Jim Haynie to a hearing. Chris didn't look good -- maybe it was the company he was keeping -- and I know he's left some nice offices in downtown Washington for what I understand is an old house in the suburbs converted into a law office.

But even as the League's fortunes continue to slide don't worry about Chris, he's got some broadcast industry clients on the roster that'll keep the bills paid.

[w3jn]

Huh.  Interesting revelation.  Yet some candidates for division director are pre-banned from running due to "potential conflicts of interest".

The ol' boys network is alive and well in Newington.  Help stamp out new and creative ideas!

73 John

[WA3VJB]

One of our own has successfully slipped into the ECFS a day late and filed a Reply Comment berating the League for it's reaction to the dramatically negative turnout against its bandwidth scheme:

http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6518329488

YO, Tom !
I especially liked your line
"Particularly insulting to all participants in this proceeding is the Petitioner's ... characterization of rejection commentary as products of fear or cowardice."

Very similar to political lines I've heard suggesting if you disagree you're un-patriotic.

[W1DAN]

Hi all:

Tom's comments are very well thought out and written. Thanks Tom!

How can I read Chris Imlay's comments?

Dan
W1DAN

[Tom WA3KLR]

You can read his reply comment here brother (614 kb pdf) :

http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6518329398

[W1DAN]

Hi All:

I wanna put this into the FCC. Comments are appreciated. Thanks!


Here are my comments about the Amateur Radio Relay League’s General Counsel’s response to the comments of proposal RM11306.

Mr. Imlay states that the Amateur service sub-bands should be be re-organized as per the ARRL bandwidth suggestion. The ARRL seeks for the Amateur Radio Service to experiment with new digital transmission methods while permitting and not detracting from the continued use of present operating modes as long as there are radio amateurs who wish to use them. Digital modes are already currently used and experimented with in the current bands. In this proposal, there is no definition of the bandwidth measurement procedure and practices. Who is to say a mode is no longer used…the ARRL?

There were 900 comments (around 80% of them negative) to this proposal. The ARRL says they notified hams, and asked for input. While their notices did exist in their publications one would have to search for them. Their notifications were not as public as to include a mailing to all US amateur radio operators (as they do for fund raising). It was not easily found by non-ARRL members, suggesting an inherent bias toward the response of ARRL members. Comments about regulation by bandwidth were solicited by the ARRL, and then ignored.

It is mis-stated that those who use traditional modes do not see a need to change the rules. I know of many hams that use both traditional modes and the latest digital methods and see the gains to be had by future digital modes. This is a generalization that can only be corrected by reading all of the 900 or so comments. The bands could be organized better, but this is not the most efficient proposal.

Mr. Imlay states that the polarized arguments validate the proposal. How? To me this is just stirring up a hornet’s nest and does not provide the best result that everyone will be happy with. More than the minimum number or people will be unhappy if this proposal becomes law. With the majority of comments being negative I feel there is a better solution.

Mr. Imlay states that there is no inherent incompatibility between analog and digital transmissions of a similar bandwidth. This is technically not possible, as is shown by the interference to and from current digital modes on the amateur bands as well as HD radio/analog, DRM/analog and ATSC/NTSC television’s analog/digital cross interference problems that exist today.

Mr. Imlay states that all are accomodated in this proposal. All are not accommodated as shown by the reply comments. Mr. Imlay states that this proposal successfully balances the interest of all regardless of the opinions of those commenting. Mr. Imlay is choosing to ignore the dissenter’s opinions. With the majority of the 900 comments dissenting, I feel there can be a better solution. If this shortsighted planning is implemented, many people will have to live with a non-optimum solution for many years to come.

Creating an analog phone limit of 3.5khz would limit the design and testing of digital creation of analog signals as well as the current double sideband AM analog methods and is a change of the current bandwidth requirements that is not necessary. The special provision for DSB-AM discourages the use of AM as it limits the bandwidth from the currently provided rules.

Automated digital systems would interfere with existing communications and would not protect other users. The fact that “there is no incompatibility” is wrong, and is not based in history or engineering studies. Current analog users generally listen before transmitting. Robot stations do not have this capability. Thus, a digital mode would be able to use the bandwidth at the expense of another analog or digital signal.

Interference between a mixture of emission modes are kept to a minimum is wrong and cannot be controlled. Mr. Imlay finally agrees that cross mode interference will happen, and states that it will be minimal. This can only be determined by actual usage studies.

The statement that the ARRL doesn’t not favor one mode at the expense of another is by definition wrong. Any digital mode will by default take up bandwidth that an analog mode can no longer use. The only way to allow for digital with no tradeoff of analog is to open up new bands for digital modes only (and we know this will not happen). While I agree that digital modes should grow, dividing them by bandwidth ignores the spectral and error correction encoding makeup of the digital signals. This plan also ignores the real world digital and analog decoding systems that cannot error-correct from cross interference.

In summary, the document Mr. Imlay offers contains mis-statements and inaccuracies as to what the total Amateur Radio Service wishes for the future of Amateur Radio. We can do better and we should take the time to do so from studied scientific and social methods.

Thank you for your consideration.
Dan Brown
W1DAN
Natick, MA

[KB2WIG]

To all,
"
Two

The Amateur is Loyal ...  He owes his amateur radio to the American Radio Relay League, an he  ofers it his unswerving loyalty."

You all are disloyal to the one orginization that protests you from the great radio void. If it were not for the League, you all would be dirt underfoot... How dare you dissagre with the One true League, the protecture of all our liberties....  go back to your den you vipers, and be cited for treason.  << especially Paul, Tom and even Dan, who I've heard is the worst of them all >>






"Give a man fire, and he is warm for one day, set him on fire, and he is warm for the rest of his life."

[Pete, WA2CWA]

Dan: A few comments based on my interpretation of what you wrote. A sort of "thinking out loud". And, there is no intent here to lambaste what you wrote. Comments are in red:

Hi All:

I wanna put this into the FCC. Comments are appreciated. Thanks!


Here are my comments about the Amateur Radio Relay League’s General Counsel’s response to the comments of proposal RM11306.

Mr. Imlay states that the Amateur service sub-bands should be be re-organized as per the ARRL bandwidth suggestion. The ARRL seeks for the Amateur Radio Service to experiment with new digital transmission methods while permitting and not detracting from the continued use of present operating modes as long as there are radio amateurs who wish to use them. Digital modes are already currently used and experimented with in the current bands. In this proposal, there is no definition of the bandwidth measurement procedure and practices. Who is to say a mode is no longer used…the ARRL?

ARRL proposal calls for "necessary bandwidth" rather than "occupied bandwidth" pursuant with good operating practices. Actual signal bandwidth would not have to be measured. Their proposal does not add a time line to any mode.

There were 900 comments (around 80% of them negative) to this proposal. The ARRL says they notified hams, and asked for input. While their notices did exist in their publications one would have to search for them. Their notifications were not as public as to include a mailing to all US amateur radio operators (as they do for fund raising). It was not easily found by non-ARRL members, suggesting an inherent bias toward the response of ARRL members. Comments about regulation by bandwidth were solicited by the ARRL, and then ignored.

"search" I call it reading. All of the "notices" were on the home page of the ARRL web site. We're back to reading again.
Comments et al: See Executive Committee minutes, 1/17/05, see BoD meeting, 1/21-22/05, see Executive Committee minutes 4/8/05, see BoD meeting 7/15-15/05
Member comments were received and a number of them were discussed, and voted upon to either incorporate into the proposal, reject, or table for a later discussion. Obviously the person(s) commenting needed to have a compelling argument why certain things needed to be modified, thrown out, etc. for the BoD to take it into consideration.


It is mis-stated that those who use traditional modes do not see a need to change the rules. I know of many hams that use both traditional modes and the latest digital methods and see the gains to be had by future digital modes. This is a generalization that can only be corrected by reading all of the 900 or so comments. The bands could be organized better, but this is not the most efficient proposal.

Just sounds like you're whining. Can"t you point them to a possible solution(s); i.e. there were 900 plus comments filed.

Mr. Imlay states that the polarized arguments validate the proposal. How? To me this is just stirring up a hornet’s nest and does not provide the best result that everyone will be happy with. More than the minimum number or people will be unhappy if this proposal becomes law. With the majority of comments being negative I feel there is a better solution.

Just sounds like you're whining. Can"t you point them to a possible solution(s); i.e. there were 900 plus comments filed.

Mr. Imlay states that there is no inherent incompatibility between analog and digital transmissions of a similar bandwidth. This is technically not possible, as is shown by the interference to and from current digital modes on the amateur bands as well as HD radio/analog, DRM/analog and ATSC/NTSC television’s analog/digital cross interference problems that exist today.

Mr. Imlay states that all are accomodated in this proposal. All are not accommodated as shown by the reply comments. Mr. Imlay states that this proposal successfully balances the interest of all regardless of the opinions of those commenting. Mr. Imlay is choosing to ignore the dissenter’s opinions. With the majority of the 900 comments dissenting, I feel there can be a better solution. If this shortsighted planning is implemented, many people will have to live with a non-optimum solution for many years to come.

Again, point them to a possible solution(s).

Creating an analog phone limit of 3.5khz would limit the design and testing of digital creation of analog signals as well as the current double sideband AM analog methods and is a change of the current bandwidth requirements that is not necessary. The special provision for DSB-AM discourages the use of AM as it limits the bandwidth from the currently provided rules.

Tell them to retain Section 97.207, ISB permitted in HF phone bands. The proposal seeks to remove ISB since the petitioners believe it's no longer being used.I personally can't see how providing a 9 kHz bandwidth for AM discourages its use. Current bandwidth rules currently are vague and nebulous and totally dependent on good operating practices.

Automated digital systems would interfere with existing communications and would not protect other users. The fact that “there is no incompatibility” is wrong, and is not based in history or engineering studies. Current analog users generally listen before transmitting. Robot stations do not have this capability. Thus, a digital mode would be able to use the bandwidth at the expense of another analog or digital signal.

Tell them to retain Section 97.221 which keeps the automated and semi-automated systems confined to their current area of the HF bands.

Interference between a mixture of emission modes are kept to a minimum is wrong and cannot be controlled. Mr. Imlay finally agrees that cross mode interference will happen, and states that it will be minimal. This can only be determined by actual usage studies.

The statement that the ARRL doesn’t not favor one mode at the expense of another is by definition wrong. Any digital mode will by default take up bandwidth that an analog mode can no longer use. The only way to allow for digital with no tradeoff of analog is to open up new bands for digital modes only (and we know this will not happen). While I agree that digital modes should grow, dividing them by bandwidth ignores the spectral and error correction encoding makeup of the digital signals. This plan also ignores the real world digital and analog decoding systems that cannot error-correct from cross interference.

I see no favoritism here. The scenario goes both ways. Any analog mode will by default take up bandwidth that a digital mode can no longer use. (I forgot this >> doesn’t not, should be doesn't)

In summary, the document Mr. Imlay offers contains mis-statements and inaccuracies as to what the total Amateur Radio Service wishes for the future of Amateur Radio. We can do better and we should take the time to do so from studied scientific and social methods.

What do you think are the wishes for the future of the Amateur Radio Service?

Thank you for your consideration.
Dan Brown
W1DAN
Natick, MA

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[K1MVP]

Pete,
With regards to your comments to W1DAN`s VERY WELL stuctured comments
in reply to Mr. Imlay`s "dissertation" to the FCC for the ARRL,--I would say
as we used to say when I worked for Boeing Aircraft, back in the late 60`s,
YOU MUST BE A DIEHARD UNION MAN, YES?

                                       73, K1MVP

[Pete, WA2CWA]

Pete,
With regards to your comments to W1DAN`s VERY WELL stuctured comments
in reply to Mr. Imlay`s "dissertation" to the FCC for the ARRL,--I would say
as we used to say when I worked for Boeing Aircraft, back in the late 60`s,
YOU MUST BE A DIEHARD UNION MAN, YES?

                                       73, K1MVP

Actually more than half of my career was spent in the corporate management structure. i.e. being one of the “suits”, “bottom line” focused person, “bean counter” type profit driven manager, etc. The early part of my career was just a lowly engineer. Never been a “DIEHARD UNION MAN” but I’ve played the character at times.

[W1DAN]

Hi Pete:

Thanks for taking the time to comment on this. You have some good ideas as to how to better steer my suggestions to help make a more efficient solution. I appreciate your efforts and will study them.

I was not whining, and need to tighten my writing up a bit. BTW, Mr. Imlay's comments were pretty repetitive. I am grown up and see the realistic tradeoffs here. I also do see we need to open the bands up more for digital (of which I am exited about in many areas). To me it seems that the ARRL had decided to offer this solution that has not been exaustively researched, nor the options presented given full consideration.

I tend to think that there are many hams who have good engineering backgrounds that would help in this area. The ARRL should take advantage of their experience.

One thing that I have not stated above is that I feel the ARRL has done alot for ham radio in the past. I do appreciate what good they have done. On this item, we all should strive to make a better solution. The ideals of a democratic process should really be in full force here.


Thanks again,

73
Dan
W1DAN

[Pete, WA2CWA]

Hi Pete:

Thanks for taking the time to comment on this. You have some good ideas as to how to better steer my suggestions to help make a more efficient solution. I appreciate your efforts and will study them.

I was not whining, and need to tighten my writing up a bit. BTW, Mr. Imlay's comments were pretty repetitive. I am grown up and see the realistic tradeoffs here. I also do see we need to open the bands up more for digital (of which I am exited about in many areas). To me it seems that the ARRL had decided to offer this solution that has not been exaustively researched, nor the options presented given full consideration.

I tend to think that there are many hams who have good engineering backgrounds that would help in this area. The ARRL should take advantage of their experience.

One thing that I have not stated above is that I feel the ARRL has done alot for ham radio in the past. I do appreciate what good they have done. On this item, we all should strive to make a better solution. The ideals of a democratic process should really be in full force here.

Thanks again,

73
Dan
W1DAN

Dan:
I knew you really weren't whning; my brain just wasn't pulling up the right word.

If nothing else, the active debates over the past many months, and the commenting process, has given amateurs a lot more awareness to the "politics and processes of amateur radio". I would hope the ARRL, and especially the Directors, who are trying to sculpture the future of the Amateur Radio Service also consider modifying their own processes and procedures to be in line with this same future. I jokingly have stated several times in other threads, "this isn't grandpa's radio anymore". This also applies to the ARRL management and the Directors who are there to represent their members at the conference table and in voting. Some of their 20th century procedures need to turn the page into the 21st century.

[WA3VJB]

Unfortunately, Pete, there is an awful lot of institutional resistance to change at the ARRL. In the old, pre-internet, pre-email days, the printed page was the only conduit anyone could use in regulatory matters to exchange thoughts and ideas. In that environment, the League's elected officials were entrusted to keep track of regulatory threats and to distill their proposals for confronting them so that we, their constituents, could see tangible value in their work.

That system was supported by us pretty well, because there was no alternative.

Today, they're still acting as what Phil has called the Benevolent Mother, at a time we can independently obtain such information and propose ideas.

The linchpin in the League's modernization, if it is to ever happen, is that they will have to surrender some power that they believe they still hold, and exchange or interact with constituents on such deliberations at a far higher and frequent level than what we see.

Meantime, they will continue to get spanked very publicly when they fail to take into account the fact we can step around them, compete with them, and trump them in the regulatory arena they seem to think they "control" all by themselves.

Have you calculated the League's batting average in recent petitions from them that are approved compared to years past?

And how many times in recent years have we seen ARRL petitions lumped in at lateral stature with others?

It's a message from the FCC that regulators no longer consider the League's schemes as anything more worthy than ideas from any other groups or individuals.  Newington, based on the Reply Comment they filed to RM-11306, does not realize it is at their peril that they keep misbehaving this way.


It need not be a confrontational scenario. But the longer they wait, the more of us there shall be who are skeptical they ever will consider the thoughts of outsiders beyond their internal political structure.

[W3SLK]

Very well put, Paul. Their incessant 'dancing around the issues' and 'behind the curtain' shananigans tends to lean more towards a political candidate running for re-election and got caught with his hand in the 'nookie jar'.
Pete, one story doesn't absolve them of their transgressions. If this becomes more the rule rather than the exception, it would force me to change my opinion. But the ad hoc article like this is going to sway my opinion one iota.