RM's 11305 & 11306 - FCC Formally Dismisses

[Pete, WA2CWA]

FCC grants requests to withdraw both ARRL and CTT petitions, dated June 27, 2007:
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-07-2817A1.pdf

Will there be a next round 

[k4kyv]

It is unprecedented for ARRL to formally withdraw one of their petitions to the FCC before it is acted upon.  I wonder if the prior request by CTT to withdraw theirs had any influence on the ARRL's decision.

Of  course, at least as far as 75m is concerned, the phone band expansion pretty much accomplished what was sought by the CTT petition.

With the reduction, and finally the elimination of the code requirement, there is no reason for anyone who wishes to get into ham radio these days not to go for full privileges.  (Some may say too easy, but that's not the topic of discussion here.)  Therefore the code decision virtually eliminated the licence class subband restrictions as well.  I suspect inertia is what keeps hams off the extra/advanced portions today.

[Pete, WA2CWA]

It is unprecedented for ARRL to formally withdraw one of their petitions to the FCC before it is acted upon.  I wonder if the prior request by CTT to withdraw theirs had any influence on the ARRL's decision.

"The League cited "widespread misconceptions" surrounding the petition as a primary reason for deciding to remove it from FCC consideration. The ARRL left open the option of refiling the same or a similar petition in the future, however."

The full story is here:
http://www.remote.arrl.org/news/stories/2007/04/27/101/?nc=1

[Steve - WB3HUZ]

It will be back like a bad case of the ......

[WA3VJB]

In trying to look at this very pragmatically, I can't find much "in" it for the League to try to stage this fight again. Very poor cost-benefit ratio.

First, there's no "victim" here. There is no documentation that present-day users of digital modes are being unreasonably constrained by today's system of how we coordinate modes and activities. So there won't be an immediate hero and subscription campaign to follow.

Secondly, there's no proof that the future level of digital activity is imminently about to explode, and that such growth would be triggered by a rules change. Again, no tangible prospect for a payoff.

Now combine that with broad, well-reasoned opposition to the concept (seen among the Comments on file with the FCC), and it would be difficult to simply change a few particulars that the ARRL has failed to clearly present, to make it worth the risk of provoking the vast majority of licensees (filing Comments) who are against the idea itself.

Should their club try to rework this proposal, it will again prompt arguments that it's a boon for those who want to use ham radio to obtain email from the internet. That's a controversy on its own -- with telemetry streams that automatically transmit regardless of whether the frequency is clear.

There's also the sub-plot that the League wants a regulatory blank-check for digital activity so it can go back to agency emergency providers and offer encrypted message handling. There's grant money in that bitstream !

No, unless the League has really misunderstood its constituency, it will take the test-run of RM-11306 to heart and avoid another public spanking to answer what opponents have already tried to tell them. Unfortunately, by asserting that we are the ones misunderstanding things, they show every sign of wanting to try to push it again.

[Todd, KA1KAQ]

"The League cited "widespread misconceptions" surrounding the petition as a primary reason for deciding to remove it from FCC consideration.

I don't doubt that, Pete. I just think the misconceptions lie with the ARRL in this case, not the amateur community. But I guess at least this comment doesn't specify.

You're certainly right about the 'money' part, Paul. Another billion is in the pipeline to be divided between the states for Homeland Security issues. I'm sure the ARRL will find a way to get ahold of some.

[AG4YO]

I agree with Paul.  There is nothing to be lost by the ARRL for ditching the bandwidth band-planning idea. The number of supporters is really low, and if the FCC were to act on their own to implement something, the ARRL could always hold up it's hands and say "I told you so".

My guess is that if we see something filed quickly again, it would indicate a unusual internal pressure by the Winlink insiders. 

Also consider Riley's comments again telling the ESSB crowd to apply for broadcast licenses if they want to be radio stations.  We saw whining by the digital folks and ESSB folks concerning the AM exception in RM-11306. How do they (ARRL/FCC) allow AM to continue in a bandwidth regulation setting without making the same bandwidth available to ESSB and wideband data?  An exception seems the only way.  If they simply allow 8kHz bandwidth, the ESSB folks will be hot and heavy doing what the FCC already told them to stop doing. Digital interference would be worse from 8kHz wide data signals.

The best thing for the ARRL to do is nothing.

[k4kyv]

I see no problem with ESSB as long as it is used with common sense.  With the expanded phone bands there is plenty of room for all modes.  There is no reason SSB needs to be singled out to be limited to space shuttle audio.

If ESSB is successfully outlawed because of its "bandwidth", guess what mode will be next on the list.

[WA3VJB]

Not all the phone bands have been expanded, and the ESSB folks on 20m had generated enough complaints alleging irresponsible use that Riley was prompted to act.

To me, the spectrum consumed by contesting can be just as irresponsible, but where can anyone make a judgment about a mode and/or an activity before someone's ox gets gored ?

As far as Hollingsworth goes, he's got an easy case to enforce when a signal fails to meet technical standards. A bandwidth specification has never been among the numerical tests, but unwanted products that consume bandwidth are.

That's why an effective approach to all this is to nail the people with dirty signals regardless of mode.

Operational, compared to technical, can create a more difficult case to enforce. Both can consume spectrum and create interference to an extent that causes "too much" resentment, but operating requires a value judgment. 

I mentioned the impact of contesters because of Riley's unfortunate comments at Dayton. But the operational issue is also where the digital people are vulnerable in wanting the entire phone bands for automated email from the internet. It's where a combative tone among ESSB folks will hurt their cause, and it's where split Dog X-Ray activity can aggravate bystanders overrun by a pileup.

[AG4YO]

I don't see a problem with essb either unless the band is crowded. That was not the point.  the point is that the FCC's position on essb and the whining of the digital minority make it difficult to do a "one size fits all" bandwidth regulation plan that accounts for AM.

[k4kyv]

... and it's where split Dog X-Ray activity can aggravate bystanders overrun by a pileup.

Which wouldn't be necessary if all the HF phone bands had been expanded to the extent that 75m was, particularly 40m.  If the phone band had been extended down just to 7075, most of the split DX phone operation wouldn't be necessary, and proportionally, the phone band would have still have been a smaller percentage of the total than on 75/80.

Split phone operation on SSB is at least as wasteful of spectrum as AM is alleged to be, since in both cases, two sideband channels are occupied by one QSO.  And when the DX is rolling in on 40 or 20, there are usually far more ongoing split-frequency QSO's than there ever are simultaneous AM QSO's, even on 75/80m.

And I won't even stray into the subject arena of SSB DX contests.

[Pete, WA2CWA]

Although getting somewhat further away from the initial thread;

In my opinion, DX stations like the idea of running split frequency because it alleviates station pile-ups all over their operating frequency.  Also many DX stations have frequency restrictions where they can operate. Nothing new; it’s been going on for decades and both sides seem to be happy with it.

[k4kyv]

I like the idea of being able to ragchew with DX stations on their frequency.  It is now possible on 75, and to a certain extent on 40.  Before the phone band expansion here, and the limited expansion of the band in Europe, it was impossible on 40.  It was possible on 75, but most European ragchew type QSO's were down below 3750 where we couldn't operate.

If the rest of the world had the same allocation on 40m that we have, it would be our best DX band, better than 20m.  European QSO's would be at their best right at prime evening hours here, and 40m is the band probably the least affected by the sunspot cycle, so it would be reliable throughout the cycle.

Up until the late 30's, the rest of the world did have the same allocation on 40.  In N. America the entire band was CW only.  But during the Spanish Civil War hams in Spain were forced off the air and both sides of the conflict used the abandoned 40m for propaganda broadcasting (kind of like LORAN was stuck on our unused 160m band during the war).  The rest of the world quickly observed how useful 40m was for regional shortwave broadcasting, so they successfully  lobbied to reallocate it at the Cairo WARC that was held in 1938, I believe.

The only reason we got 40m phone after the war was because US and Canadian hams had all but abandoned the top end of the band for cw contacts, due to the broadcast QRM.  So it was agreed to open the top end up for phone to keep some amateur activity in the top end, since broadcast interests in this hemisphere were lobbying for 40m spectrum here, too.

[Steve - WB3HUZ]

Malicious interference has been happening for years too. An appeal to "tradition" is not a legitimate argument.

And usually what happens with split operations is TWO piles ups - one on the frequency the DX station is actually listening on, and one on the frequency he's calling on because a bunch of boneheads don't know how to listen.

Yet Riley claims these guys are good operators. Wow!

Although getting somewhat further away from the initial thread;

In my opinion, DX stations like the idea of running split frequency because it alleviates station pile-ups all over their operating frequency.  Also many DX stations have frequency restrictions where they can operate. Nothing new; it’s been going on for decades and both sides seem to be happy with it.

[Pete, WA2CWA]

Many split operations are announced or initiated by the DX station. One would assume the DX station listens first to the receive split frequency before announcing it, but then again, he may not hear the local chatter near that frequency. Some DX hunters on this side will try to spot or locate a "clear" frequency, but once the DX station gets rolling, it's hard to convince them to change. And there are many boneheads who never get the split operation frequency activity message, and will call endlessly on the DX station's frequency.