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