FCC activates the Bandwidth process

Tom,

Thank you for a clear and concise explanation of why narrow and wide modes don't mix well. It's basic radio
theory, nothing more. Doesn't even take a lot of math
to show the facts.

Excellent point! And those other services are more regulated than the ARS.

btw, I'm still waiting for an answer to my question about why CTT wants to reduce Region 2 privileges for Generals to 7025-7150.

73 de Jim, N2EY

 

Hello Tom,

Thanks for your reply. Let me address a few of your points and maybe you can better understand what I am trying to say and what the CTT is trying, or maybe NOT trying, to do.

and why is this significant? It appears that you are trying to associate each of them with a much maligned group (AM'ers) for the purpose of discrediting them!

They each work "other" modes. I reviewed their activities also and I would place them in the category of well rounded radio amateurs. Here's the real fact: There are two members of the CTT, Ron W8LX is predominately a CW person who has NEVER worked AM as is the case with Mike W8MW who does not work AM at all!  Geez how did they get in there!

Tom this is just not true and you know that! AM, as a mode, is probably the most maligned and attacked mode in existence. You use that! It would be no different than if I said Tom W8JI is gay. I could follow that with "hey, I think he is a nice guy" and "I know lots of nice homosexuals". Then to follow that with "This isn't an insult, it's just a fact." would be an insult to my intelligence.

Tom you know clearly what you are doing! You misstate facts and then throw out comments about them and follow that with "I am just stating facts" and that's absurd!

See Tom, here is more, a clear case of you making assumptions, without really knowing!!

In your opinion the CTT acted this way but the fact is that you really don't know what the CTT did or how they did it! Because the conclusion does not keep with what you believe, you say "without properly analyzing data or considering problems" and that is not true. Seven very very experienced amateurs sat down and for a long time looked at problems and worked together coming up with solutions.

The key is that you were not involved in any way so you really don't know what we did. Your assumptions and conclusions are just that, not facts!

You know Tom, if you knew Bud as well as you would like everyone to believe, I find it difficult to believe that you didn't just pick up the phone and call Bud and ask him about it. Sometimes vetting a frustration has a theraputic effect and that is what Bud told me when I asked him.

Frankly I have seen you and Rich Measures call each other names and bash each other to the point that I had to stop reading what you put on the web. So I suppose that gives me call to quote from some of those raves of yours and spout conclusions about you as a result. Naw, I understand and if it bothered me, I would drop you an email or call you and ask you about it and I have never claimed to be an acquaintence of yours, although we have met, we have shared coffee and talked on the telephone and on the radio!

Tom, I think that is what the CTT is saying also. I also think that most amateurs fall into that category. Some unfortunately do not. Let's not dwell on the behavior of a few and let them set the bar for the rest of us.

But let's look at what you just said versus what you do! Your hot button is bandwidth and how wide rigs are. We all have seen that in your postings many times. Yet you designed or redesigned many of the amplifiers that Ameritron sells. Give a ham one of "your" amplifiers and let him create signal products that substantially add to his bandwidth. Why would you do this if your concern is pure and for the betterment of the hobby?

Bud this and Bud that, is not appropriate Tom. First you really do not know Bud. Second Bud is a member of the CTT but is not it's spokesman, as you keep trying to claim. Third he helped by providing some excellent insight regarding his experiences as an amateur, both technically and socially! To trash Bud as you seem to want to do and hold him up as the group spokesman is just totally wrong!

Tom, this is but another BIG example of where you went wrong in your thinking. Your lambasting Bud is for all of the wrong reasons.

I host Bud's website and the websites of a few other's. I found a hosting service that was significantly less expensive and nearly three weeks ago I switched all of the domains to my new service. There was a problem with Bud's web site and he did not have a recent backup. He lost many things including a lot of valuable Bolivian pictures that he had posted. Why didn't you mention them?

This is the kind of misunderstanding that results from your kind of attacks! You twist facts, without knowing, and add your own version of what they mean. You interpret. Then you say, ther it is, it is fact. No Tom, not really!

I am surprised at your assertion here! Why would you even say such a thing except that you wish to trash the CTT? Look at the backgrounds of the CTT participants. Others have. We are all radio amateurs from a diverse background, lots of time on the ham bands, in all modes, and all hold commercial FCC licenses as well as extra class amateur licenses. I think the CTT is a mix of exceptionally well qualified amateurs and just because you don't think so, makes me question why you would say such a thing!

Calling the CTT team unqualified and saying that they are a bunch of "yes men" is derrogatory. It shows that your intent is nothing more than an effort to trash the CTT because you don't agree with it's conclusions!

Our "narrow" group has looked at this objectively Tom. We don't call people names and we don't twist things to trash anyone. If you have no faith in the people that make up amateur radio, that's clearly a problem that you need to work out. Anyone who thinks, as you do, really needs to step back and ask themselves "why do I think that hams need rules and enforcement? why do we need little boxes to put ourselves in? and why would I want to sit on a radio and talk to anyone who thinks I am so "moronic" (your word Tom) that I can't be a gentleman?"

Give hams more credit than this Tom. We have doctors, lawyers, attorney, electricians, office workers, politicans (whoops) among us.  No part of ham radio is more important than any other. It's all a bunch of hot air being passed and doing it on SSB or CW or AM or RTTY or PSK31, it's still a bunch of guys getting together and enjoying talking about nothing! It's a hobby and I love it too Tom!

73 Larry

 

I see no flaw in the arguements that W8JI has advanced on why RM-11305 is too technically flawed to be considered either a good plan, sound reasoning or worthy of consideration. Therefore, I also oppose it as it reflects very poor judgement on the group who concocted it and is meant to benefit the few at the expense of many. The lofty verbage and appearance of being with the "greater good" of the amateur service in mind is a smokescreen.

 

Tom W8JI,

This is a good example of the harm that your tactics are responsible for. What guys like this fail to see is that you are representing your own conclusions and assumptions, not facts, and you twist everything to suit your conclusions. This poor guy probably believes that Harry Potter is a real person!

--Larry W8ER

 

Because without rules and enforcement, we'll have chaos. That's not theory or negativism - it's been proven by what has happened in other radio services without rules and enforcement.

In the case of "why subbands by mode/bandwidth?" the answers are a bit more complex, but here they are:

1) Narrow and wide modes don't mix well. Basic radio theory shows that. For example, if I'm running QRP PSK31 on 3579 kHz, and you listen for me with an AM receiver set for 16 kHz bandwidth, you might not hear me at all under certain conditions.

But sharpen up the receiver to 160 Hz (perfectly usable for PSK31) and turn on the BFO, and there I am!

2) We have limited bandspace available. Reserving some of it for more spectrum-efficient modes is an incentive to develop and use spectrum-efficient modes. It's the same principle as HOV lanes on a crowded highway.

It's really that simple. Getting the most out of our limited HF/MF bandspace means we need regulations to keep order. Maybe those regulations need some fine-tuning - but they don't need to be tossed out wholesale.

73 de Jim, N2EY

 

Police detectives have long known that a person's thoughts and actions reveal motive. It doesn't take a rocket scientist to recognize the motive behind RM-11305. Once a person begins to investigate the characters behind RM-11305, it becomes obvious what their motive really is. The fact that so many of us began reaching the same conclusions is testimony that its obvious on the face of it. Just look at the type of characters behind RM-11305 and look at the document itself and its crystal clear that it is self serving and bad for amateur radio as a whole. Its as plain as the nose on your face.

 

I don't believe that it has been demonstrated that our regulations require any fine tuning.

 

Hello Tom,
Thanks for your reply. Let me address a few of your points and maybe you can better understand what I am trying to say and what the CTT is trying, or maybe NOT trying, to do.

and why is this significant? It appears that you are trying to associate each of them with a much maligned group (AM'ers) for the purpose of discrediting them![/QUOTE]

No one knows who you guys are. You formed a group, picked a name that makes it sound like you are thinkers, and made a rule-making proposal that deeply affects every other amateur who is active or will be active on HF.

If you are going to represent every single amateur, all of us deserve to know the background of each person representing us.

I am simply pointing out what a Google search shows as the background of Think Tank members. We have a right to know the mindset and radio background of anyone who is willing to propose a rule that so radically affects us all.

If you have better information, publish it. Don't tell me how you guys use the hobby isn't important. You all met somehow.

This is a good example of how the Think Tank jumped the gun and submitted a proposal affecting us all without bringing the mainstream community on board. I think any amateur group really intending to do the right thing for the hobby would have introduced themselves. Since you didn't, I did the best I could using Google.

That's a very odd thing to say. It's very unusual and rare to use an untrue sexual reference about another person in a technical discussion about FCC rules.

It's a fact that a Google search turns up links that show most Think Tank members active on pages related to AM operation. AM isn't a dirty word; it isn't a nasty mode. It just shows most Think Tank members come up high in a search by callsign related to AM activity.

Why be ashamed or offended by that?

So the best solution you could find is to ask the FCC to abolish all rules governing bandwidth and mode? What problem were you "fixing"?

YOU say you are all smart and wonderful, and we should trust you. Why didn't the Think Tank let the community decide if the community wanted you to represent us?

Where are the background resumes that show us the experience of Think Tank members?

You'll never find a post where I call Rich Measures a name, or where I made any personal insults about him. I don't do that. (Your "gay" comment, however, is similar to inuendos Measures uses.)

The idea we can tear down all the fences, mix wide modes with narrow modes, and not make things worse is nothing short of moronic. RM-11305 makes absolutely no sense at all. It doesn't make sense socially, it doesn't make the least bit of sense technically.

You can see from the responses to the FCC page, if you do a search on those who agree with you, the majority of supporters are ESSB or AM operators. It is clearly a proposal that would benefit those using the widest modes.

As for the rest of this, none of this is about ME.

It's all about RM-11305 and what is behind the minds of the self-proclaimed "Think Tank" members who decided all on their own they were capable of submitting a proposal from which there will never be any going back.

Now I'm sure WD8BIL's spectrum shots of his analyzer just happened to disappear a few days after I put the link up through "random happenstance", just like the words RM-11305 disappeared from the AM Window pages through random happenstance at the same time.

Fortunately I have some of those words archived, and everyone can read them.

This isn't to make Bud out to be a bad guy. Just to prove that many people, including Bud, use bandwidths that extend fully to the limit and beyond FCC rules.

As top your question about Ameritron, let me say this. Ameritron had a choice of using cheap Russian tetrodes in amplifiers. The hard fact is when we tested tetrodes, they were 10-20 dB worse than any triode amp we had for IM products, and they could not be made better without significant expense. That was a HUGE factor in not using tetrodes.

But again, it's not about me. It would be if I was telling everyone six buddies and I decided we were so smart we could decide what was best for the 500,000 other people.

In that case it would be all about my operating habits, technical background, and what I do with my radios.

Right now it's all about the seven Think Tank members. No one knows who you are, we only have your word about how smart you are and how careful you were.

At the same time, most people know mixed modes can't work. Why don't you understand that?

What about

Mixing modes

73 Tom

 

Tom,

It is interesting to watch how you twist and turn things. There are some things that you just have no way of knowing and yet you throw it out there as if you have an inside track.

Right, but that's your requirement not the FCC's requirement! It's not a bad idea but the last time I checked Charles T. Rauch was not yet in charge of the FCC! So you take it upon yourself to criticize us because we followed the rules! Outrageous behavior on your part!

What you don't seem to understand is that the process itself is similar to a suggestion box but very controlled. Proposals are most of the time discarded by the FCC and never given an RM number. What is the criteria? I don't know nor do I care! The CTT proposal was a formal suggestion and anyone, even you Tom, can file one! Again, outrageous that you would criticize us for following procedure.

Next, you don't like the name "Communication Think Tank".  According to you we picked a name that makes it sound like we were thinkers! That is really funny Tom!

Here's what really happened. One of the CTT members complained about the logo that was being used at the top of the board that we used to communicate. I jokingly replaced the logo with a picture of Rodin's "Thinker" because we were burning the midnight oil -- thinking!It was a hoot and we all laughed. About two weeks later someone else popped up a message that referred to CTT and none of us could figure out what that person was talking about. When the person replied that it meant Communication Think Tank, we all nearly died laughing about it and despite the humor, it stuck!

The name was not the result of some overt action trying to come up with a name that lent some imagined credibility to our group,  AS YOU ASSUMED AND OFFERED AS A CRITICISM. We never sought to give ourselves a name, it just happened. You just didn't know but you act as though you did!

Many people, including you, have a view of what our hobby should be. You are not wrong, from your perspective and the CTT group is not wrong (as you suggest) from their perspective. We simply disagree!I am convinced that the real answer lies somewhere in between complete elimination of the sub band rules and allocating sub bands by bandwidth!

This process by the FCC is designed to pull that out of us! It takes suggestions that are relevant from the box and asks everybody to comment. It considers the comments and may ask questions and then issues an NPRM, if it thinks the matter needs attention. Remember the FCC may choose to pick this and pick that and write their own NPRM as a solution or they may even choose to do nothing. It is highly unlikely that they will take either 305 or 306 as it is written. That just doesn't happen!

That is exactly why it's not important to know who we are, which you seem to demand. Notice too Tom, that we have not chosen to put up a web page or web site with all known statements by WA8IJI or W8JI and just because he doesn't agree with us. God knows we have the capability but it isn't necessary! You may, as we all may, file our comments to the FCC (and you have) and they will sort it out. Have a little faith in the process Tom, if not faith in your fellow hams!

--Larry W8ER

 

Really?

Then why are you proposing complete elimination?

Why not propose what you really want?

Maybe.

FCC is not required to pay attention to the comments other than to accept them and read them.

Oh yes it does!

For example, there have been 18 proposals regarding Morse Code testing since July 2003.

At least two of those proposals simply said "Dump Element 1 and leave everything else alone".

The others were all over the map.

The recent NPRM on Morse Code testing proposes to simply dump Element 1 and leave everything else alone.

A count of all filings showed that a majority of those who commented want at least some Morse Code testing to remain in place.

But FCC isn't required to go by majority opinion.

And I don't think anyone will be really surprised if FCC simply drops Element 1 and leaves everything else alone.

Be careful what you ask for - you may just get it.

73 de Jim, N2EY

 

And you ignore the issues Larry.

The real issue is seven people after chatting on Internet (according to you) decided they would propose the FCC eliminate all mode and bandwidth restrictions.

Now you say:

Why then, if you are convinced the real answer lies between elimination of sub band rules and allocating sub bands by bandwidth, did you sign on to an RM that would be a disaster to our hobby?

Larry, this is a very serious issue.

We are faced with BPL, and the FCC does not want to act. We are faced with a regulation by the state of Florida that allows police to arrest people causing TVI, and the FCC has not acted to preempt that law.

The quickest way to get rid of us is to just wash their hands of us like they did with CB radio. The quickest way to that point is to turn our bands into any mode, any bandwidth, anywhere.

In the middle of a big BPL problem, the ARRL and CCT both burden the FCC by wasting more FCC manpower to process petitions that (as you admitted) the submitters themselves don't even agree with!

You may think it is a small thing, but it isn't. Getting the FCC involved in ANYTHING that can't be solved some other way is just begging for problems.

You are welcome to do that. You accused me of calling Measures names or something like that. Put up some post where I did that.

I have great faith in my fellow hams. I support anything that, as a body, they want to do.

I don't think people should present themselves as a Communications Think Tank based on a joke and then submit a proposal to the FCC that asks for all mode and bandwidth restrictions to be removed. I especially don't think someone should put their name on a paper asking for a rule making they don't 100% agree with and then depend on the FCC "sorting it out" and getting it right!

Larry, let's be careful here. The RM process is a very serious matter. It is our window to the FCC. We should be very careful not to put something before the FCC that we, as signers, are not 100 percent behind!

In my opinion the system needs a rework. I think the phone bands could be expanded, but at the same time we need better transmitter bandwidth specifications for all modes.

What we absolutely don't need are strong AM, FM, or SSB signals being able to move anywhere they choose with any bandwidth they feel like using.

You did not comment on my analysis of mixing modes and signals of different bandwidths.  It's a valid technical argument against RM-11305, and one that should have been addressed before RM-11305 was filed.

Filing an RM isn't a joke, and we should not depend on the FCC to correct our mistakes or omissions in a RM proceeding. We should take such things seriously, and drag the FCC into extra work the very least we can.

I hope the next time someone files, they don't do this:

Filing a RM petition you don't fully support and depending on the FCC to toss it out or change it does not seem like a good idea. Not caring about it seems an even worse idea.

We should take those procedures seriously. We likely already are considered a burden on FCC resources.

73  Tom

 

I agree 100% - on both counts.

Here's what I don't understand about both the ARRL and CTT petitions:

Why, in heaven's name, weren't these proposals adequately discussed and publicized *BEFORE* being sent to FCC?

Is there *any* real reason we hams can't come up with a comprehensive proposal that the vast majority of us can support - *BEFORE* it is sent to FCC?

Imagine if ARRL, or some other group, hammered out such a proposal in full view of all interested parties, got wide support for it, and then submitted it to FCC? Then when FCC put it up for comment, the comments would be so overwhelmingly positive that FCC could simply rubberstamp it.

Instead, FCC is bombarded by multiple proposals on all sorts of issues, all without consensus or even wide support.

Think about why FCC only allowed 30 days for comments.

73 de Jim, N2EY

 

I'm distressed to find out after all this time Larry isn't even fully in favor of the petition they submitted.

The "Think Tank" asked for this now:

ERRATUM
We respectfully request that the FCC remove a table referenced in Petition RM-11305, entitled

Proposed Changes, Section 97.301. It appears starting on page "v" and extends through "viii," inclusive.

It contains an error brought to our attention during the public vetting process. Our intention remains to ask that you grant us the flexibility in the use of all modes on all frequencies where applicable, and in line with, the IARU Bandplan Guidelines for Region 2.

We refer to our support for this IARU plan in page iii, paragaph four, and remain convinced this provides a workable band plan within which we can accomplish our stated goals without the future need to revisit the rulemaking process.

Submitted for the public record, -SMichael Wingfield et al
6931 Ryan Road
Medina, OH 44256

So they are actually changing their proposal after it was submitted!!!

There's a big danger in submitting RM petitions that aren't hashed out and looked carefully through prior to submission.

First, it makes us all look unprofessional.
Second, it wastes the FCC's time.

We can't even get enforcement of BPL violations despite the ARRL badgering them, and now we are tying them up with petitions the petitioners themselves considered flawed!

What are we trying to do? Get booted off the air?

73 Tom

 

Tom,

I will address you because Jim is holding your hand and answering you, answers him as well.

The RM process is a serious process and none of us ever took it any other way. You must understand the process and I'm afraid that many amateurs don't. I am getting the strong feeling that you don't either. This is not a pass fail process.  Many of the comments simply say I oppose 305 but do not say why. Hell this is not a voting process, it is a comment process as it is named!I am not ignorant either and the opposition I am sure will be noted but it is not what the FCC is looking for in this part of the process.

Ideally, if I were to have my personal way, I support 305. Since I am not a spokesman for the group, merely a member, I want you to understand that my comments to you are MY personal feelings and those that I conveyed to the CTT during the formulation of the proposal that was filed on June 20th.

Let's take a look at the BIG picture. We, despite the protestations of some, do have a problem with sub bands and the present alignment. You see that too as you said in your last reply to me. It has the bands poorly utilized (some more than others) but in general the popularity of phone modes is overwhelming. Turn on a receiver and listen, it's obvious.

Why has it gotten that way? Obviously the allocations were formulated a long time ago when the selection of modes was much simpler, CW or Phone, and the reasons for the allocation (AT THAT TIME) made sense! Since then we have pushed the newer modes in wherever we could get them .. oh PSK here and SSTV there etc. Before now, no one took a serious look at where it was all headed nor did anyone stand up to a worsening situation caused by the explosion of phone becoming an exceeding popular mode.

Let's step aside a second and look at what ham radio is really made up of. Again, turn on your receiver and listen! It seems everybody has a Jap transceiver connected to a damn Ameritron amplifier, has the accessorized microhone plugged in, and they sit and chat with their buddies. It's a given that there are other modes such as CW and RTTY and PSK32 etc but the enormous popularity of the old plug and play KenSUCom-Tron combination is here .. it's is getting more popular .. and it's never going away. Don't like it OK but that's how it is. Tom, you enjoy or CW but even though it is the second most popula it is way down the list and it isn't going to get more popular. In particular, when the forces that be, stop morse as a requirement for licensing, we are going to have an influx of activity from guys that don't know the code and don't care to. While CW will never go away as a mode it's popularity will continue to decline. Digital modes, barring something unforseen popping up, isn't going to burn the barn down either!

So what do we do here. Set up the allocation such that the modes align themselves by doing away with sub bands. I personally think it is the only correct answer! This is what the CTT proposes (in a nutshell) (big picture). It keeps us from revisiting this painful process 10 years from now to realign the damn sub bands again so that the spectrum allocated to the amateur service is again properly utilized.

Does the CTT proposal address all of the ills of such a realignment. NO emphatically NO! We never meant to because we understood that guys like Skip TY with far more digital experience than us were out there and claimed to be in the process of filing a proposal. He didn't. That would have brought three proposals forward each covering a piece of the puzzle and then there is SPARS who kept saying that they were going to file a proposal to cover this and that but they never got off of their butts to file anything!

If you understand the process you will clearly see that the CTT was not meant to be and end all. It was meant to introduce a concept, which I still think is valid!

Did we expect that the CTT proposal would be accepted in it's entirety without modification. Hell no! We even offered to help other groups any way we could, including  the offer to walk their proposal down to the FCC offices in Washington and assist them in the filing process! We expected others to add the necessary expertise to complete the picture.

So what do we have now? We still have a process that can address the very ills that I have outlined and you admitted exist. They will not be address completely as we saw, that is a total opening of the sub band structure. We will have to revisit reallocation in the future, a big goal of the CTT proposal was to eliminate this need. Will the bands be realigned, as I said, I suspect that the answer will lie somewhere in between the CTT proposal and a further complicated sub division by a new measurement "bandwidth".

But Tom you must understand that CW no longer enjoys special status. I know it is your primary interest but it's use is fading and the allocations, if we are to have them, must be appropriate. Others say hey give me a keyboard and PSK31 or give me a big old heavy AM rig. These all are valid uses of the hobby and NO ONE INTEREST has a right to exist at the expense of the other.

Let me address the AM or wider modes that you seem to have a passionate dislike for. Do they have a right to exist .. your damn right! Do they deserve the bad press that you and others have given them NO! "Reasonable" bandwidth  on some modes are wider than others. Restricting these modes is not the answer because at the very best you might recover a few khz here and few khz there. Opening up the bands is more of an answer because we are talking about hundreds of khz of space, not just a few here and there.

I support your dislike for operators who misuse and misadjust their transmitters. It is uncalled for but there are present regulation that cover these situations. The biggest problem here is ignorance by some of those who transmit improperly and also by operators who are the victim of their own receiving equipment and thier lack of understanding of its use. I applaud you and your website for the effort that you have undertaken in the process of education but I also am critical of your personal bias against wider modes that has turned off some of the very people that need to visit your pages.

To comment on your page on the mixing of modes. It's a nice piece of work BUT the concept is very narrow and thus the conclusion accurate but flawed. You refer constantly to signals as they relate to signals just above the noise floor. That is not real world!!! I listened to  160 and 75 meters and the bulk are in the -70 to -40 dbm range. I don't know how else to get this across, most of the signals that I listened to, over most of the band, were not at the noise floor! Thank you Ameritron! So here we have a SSB QSO in progress and a guy on CW calls CQ right in the middle of the SSB passband. The CW guy gets a contact and they have a whole QSO, right down to signal reports and rigs and the SSB guys kept right at it and so did the CW guys. Put the average scenario into your conclusions, not the extreme ones, and I will be much more impressed. We all don't work weak signal DX with beverages and foour square arrays Tom!

I apologize for the long post but I don't know how I could have put it in fewer words and I am sure that I missed or said something that is not clear. I believe that there is a huge amout of misunderstanding that is causing all of the venom to be spewed around here and other places. It has to do with a process that many hams don't understand and a group of guys that saw a problem and tried to do something, other than sit around and bitch about it! I am talking about the ARRL of course!!    

I would be glad to discuss anything about my views and the views that I imparted to the CTT and answer questions about the CTT, if they are appropriate, but I will turn the computer off at the point the conversation disentigrates into anything other than civility.

--Larry W8ER

 

Tom, one other thing:

You may cut the sarcasm and the twisting of what I say or we have concluded this conversation. And yes the process that we have entered allows for revisions and corrections. You clearly are pointing to things and twisting things and expressing your own conclusions and trying to make up your own rules and you are wrong!


--Larry W8ER