Newington group fails to practice preach

[WA3VJB]

ET Docket 06-89
"Creation of a Spectrum Sharing Inovation Test Bed"

The ARRL has provided additional material to illustrate defective thinking in its approach taken with the Rules governing the Amateur Service.

As it expresses support for the Commission's concept of a spectrum Test Bed, the group in Newington has unwittingly admitted there are problems with the League's promotion of certain propriety digital technologies which were said to be the impetus behind its earlier proposal to regulate by bandwidth..

Newington's lawyer now criticizes the FCC for suggesting "that certain technologies may be compatible with incumbents, merely assuming the success of interference avoidance mechanisms."

And even though the ARRL has done that very thing itself, with its proposals for automatic communications without automatic power reduction strategies. the new document asserts such assumptions that interference will naturally be avoided "are in many cases no more than hopeful speculation."

On Page 4 of the eleven-page Comment filed July 10 by the ARRL, the document puts the League on record as saying there should be an opportunity to evaluate the compatibility of proposed uses of spectrum PRIOR to actually authorizing them. This stance may further doom the League's "bandwidth proposal" which has been soundly discredited in the public comment phase of the FCC's proceeding that will eventually lead to a decision by the agency.

The bandwidth scheme would be at odds with this latest ARRL document that now opposes "spectrum allocation decisionmaking based on no more than the relative success of private sector marketing of a technology by its own advocates."

The proprietary digital protocols the Newington group has endorsed and promotes were shoved by its advocates through a closed-door, masonic style political proceeding.

Read it for yourself:

http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6518398040

[Steve - WB3HUZ]

The proprietary digital protocols the Newington group has endorsed and promotes were shoved by its advocates through a closed-door, masonic style political proceeding.

"And everyone knows that the Masons are satanic," said a little voice in the wilderness.

[WA3VJB]

I wondered whether I ought to be using a comparison to a masonic-style political system, because I don't mean to malign the Masons as much as I hope to provide a way to grasp the similarly secret deliberations and decision-making that the group in Newington prefers. (The Masons do not have to answer to outsiders and they don't claim to represent anyone but their members. The ARRL must answer to all the constituents it claims to represent, and that is not possible within the group's current system of cooking up regulatory schemes.)

Let's return to the point of the posting, which is to show the latest example in a long series of contradictory and piecemeal "strategies" if one could call them that, from the little publishing and subscription outfit in Newington.

The filing is by the same attorney hired by the League to refute the overwhelming opposition filed as Comments to the scheme to regulate Amateur signals on HF by an untested system based on bandwidth, and thus abandon the longstanding and generally successful and accepted system that uses sub-bands and voluntary cooperation.

The counsel's latest attempt includes the same flippant attitude toward the FCC as seen in the Reply to Comments filed against its bandwidth scheme.
Example: "as a means of properly refocusing the Commission's spectrum planning effort toward technical compatibility determinations based on actual testing."

What arrogance for the ARRL to judge the merit of the FCC's "focus," or to even draw conclusions in assuming it understands what that focus may be!

This is laughable when considering how Newington sought to impose its bandwidth-based system of spectrum planning without regard to incumbent users, and without any proposed "actual testing" to see if operators could make such a system work. It was among the shortcomings Commenters roundly criticised, and which may consequently prompt the FCC to reject the ARRL's petition.

There are more examples in this latest filing of not practicing what it has preached in not only the bandwidth scheme but also the proposed abandoning of automatic power control for telemetry robots, and its promotion of spread-spectrum transmissions in the Amateur bands.

The League's lawyer asserts the Test Bed, the proposal on which the Comment is filed, would help "evaluate cumulative effects on the noise floor, and on ambient noise levels, of multiple devices and systems."

None of these effects has been documented as a basis for ARRL's own regulatory proposals that would affect incumbent users.

But, if you really want to see a group that talks out of both sides of its mouth, check out its point No. 6 (page 5 of the PDF).
As context, we would have been expected (under the ARRL's discredited bandwidth proposal) to resolve interference with automated stations with signals of bandwidth similar to transmissions uttered by humans, or, in effect, to argue with a robot.

The ARRL's attorney at that time failed to acknowledge such concerns expressed in the Comments that ran 8:1 opposed to its discredited bandwidth scheme. Yet, in the League's latest Comment, it excoriates the FCC for what the ARRL considers "two different models in spectrum planning in recent years," and calls one of those "the chaos model," that, in the League's words "is essentially an unmanaged spectrum plan."

This is the very system envisioned by those who rejected the ARRL's bandwidth-based coordination scheme.

There's plenty more in this latest document. Great reading, and it provides the likely basis for a few Reply Comments that may give the League (another) good spanking.

[Steve - WB3HUZ]

I couldn't agree more. Seems to be a lack of strategy. Has the ARRL ever published a strategic plan?

[WA1GFZ]

Steve,
They have a plan. Increase the paying members to buy rice boxes.

[Steve - WB3HUZ]

I asked if they ever published one. It's fun to take shots at the ARRL, but not very productive (yea, I know it's hard to believe I actually asked a serious question). I don't see any reason why the ARRL should have something on paper for ALL to see, that talks about where they want the organization and amateur radio to be in 1, 5, 10 years. Otherwise, they are just floundering along, reacting to what comes their way. But that's just me.