ARRL speaks on Regulation by Bandwidth

The League said this petition was vetted. Hogwash... with whom was this petition vetted by? I wish the League would backup their statements such as this with programmatic facts.

As far as we all know, this petition was created by a singularly biased ad-hoc committee. And based on overwhelming opposition, the league received individual comments to this petition. Of which, the league did not modify to any degree the original proposal -- based on what was suspected to be valuable public input.

Again, they are following their own agenda and ignoring the reasoned and overwhelming majority of naysayers from throughout the Nation -- as evidenced in the FCC's received comments regarding RM-11306..

The League has lost a 20+ member due to this statement.

 

People are outraged at the condescending tone the League's lawyer took in filing the "Reply Comment" on behalf of his client.

See the excellent discussion underway at:

Talk & Opinions/QRZ.com

If you want a good laugh, check how your ARRL has carefully considered the concerns, protests, and opposition filed against their scheme. The ratio of those opposed is about 8:1.

"League Reply Comment to the FCC"

There now is a groundswell among people who are indignant that their concerns have been dismissed by the group in Newington in such a cavalier fashion. You will see additional Reply Comments on the FCC website, directly responding to the Petitioner's spin on the response generated. Contribute if you are as moved as others.

Paul/VJB

 

This has me sooo pissed off that I can't even think straight!

Eight to One OPPOSE

ARRL are you listening?

Vet this:
Get your heads out of your third point of contact!


end

 

The ARRL, self described as the "National Association For Amateur Radio"--though it represents only about 20% of licensed amateurs in the U S, has made, perhaps, its biggest mistake (and there have been many) of the past 6 years.  This NPRM will, if implemented, benefit only a small percentage of amateurs in this country to the detriment of the majority.  It is a self-serving proposal which during the initial comment period the vast majority of those providing input did not support.

The unsound nature of the original proposal is exceeded only by the "in your face" tone of the ARRL's reply comments.  Arrogant is probably not an inappropriate description of the League's approach.  

I say all of this with great regret.  As a Life Member of the League and a former Section Manager it is very disturbing to witness what the ARRL has become over the past six years in particular---out of touch and out for the dollar.  Given how the organization is constructed it is, sadly, not too likely that things will improve any time soon.  It would take an organized, concerted effort on a national basis to vote out the majority of the current Board of Directors and replace them with those who will not put personal interests and power above the common good of amateur radio.  I don't see it happening.  If, and hopefully when, this ill conceived proposal fails it would be a very good thing if the League got the message now being sent to it.  But, again, given the present ARRL structure and heirarchy I don't see that happening either.  Too many BOD members and League staff apparently are convinced that they know far better than everyone else what is good for amateur radio.  Tragically, they don't and the tragedy is compounded by the fact that they simply will not listen, or even attempt to listen, to their membership.

 

The ARRL BOD is just too caught up in their own perception of self importance. Looks like they forgot to get a second opinion during their vetting process.

They are just plain out of control.

Respectfully, Ed k3tj

 

I'm an ARRL member and proud to be one. But regarding "Regulation by Bandwidth", I'm completely opposed to it. I'm convinced this is a thinly veiled attempt to get the Enhanced SSB'er off the air. Notice that the maximum bandwith is 3.5 KHz but there is an exception for AM. If this were truly Regulation by Bandwidth, the maximum bandwith would be 6 KHz regardless of mode. The only relevant criteria would be the bandwidth. What they have created is a complex scheme to prevent the E-SSB'ers from having any legal use of the bands. It's not Regulation by Bandwidth at all because the mode is intertwined in the regulations. Frankly I object because it is far too complex. And what is wrong with E-SSB? It's no better or worse than AM. It's just different and may actually be helping to attract new hams to the declining ranks. I'm not interested in either E-SSB or AM, but I have no problem sharing the bands with people that are. We don't need any more than 2 sub-bands, one-half Digital and the other half Analog with no consideration to the mode or bandwidth. Digital is defined to be any mode where the carrier power goes from zero to full power with no intermediate states (not counting risetime). Analog is any mode where the power can be modulated to any value between zero and full power. Examples of digital would be CW, Digital Audio, RTTY, Packet, etc. Examples of analog would be AM, SSB, E-SSB, FM, SSTV. It appears to me that more regulation will only stifle the spirt of Amateur Radio which is defined by the FCC to be a medium to experiment via radio. If everything is going to be regulated in advance, where does that leave the experimenter? In the end, if regulation increases, I predict there will be little difference between operating on the ham bands and operating on your cell phone.
73, Bob

 

K3TJ & N7WR both see the situation clearly.

This wouldn't have been a bad proposal if Pactor robots had been corraled. The ARRL BOD however see digital modes as their future salvation and began with being sold on the idea from day one. They didn't listen to any input that came from the members or non members that suggested otherwise.
If the membership kicked them to the curb for a year or two, Dave Sumner would sit up and take notice.

 

Most of the Rest of the World with whom we share these bands has already got the "Regulation by Bandwidth" right and are only waiting for the US Hams to catch up...

I enjoy all the humorous ranting against the ARRL, Winlink, PACTOR, Digital Modes, the Internet, the Price of Tea in China....


Bottom Line:

Some form of Regulation by Bandwidth is inevitable....

If only to keep us compatible with the rest of the world with who we share these bands....

 

Albert,

It was the ARRL that filed the petition without very much comment or input from the membership.... and to me, that is the main problem. For years the ARRL has been touting the membership itself as being the ARRL and in theory the establishment in Newington only serves the membership. The membership of the ARRL was not really asked to participate in the planning process that would have had a full vetting of the petition as it was being put together.

What we now have is ARRL members attacking the ARRL because of the petition. Do members really think that they ARE the ARRL? I think not. If they did, why would they attack themselves? The perception seems to be that there is this gated castle in Newington from which pronouncements are issued to the peasantry dwelling outside the gates in the hinterlands. These peasants know their place in the scheme of things and realize that their opinions are not going to change policy even though they are 'encouraged' to contact their elected ARRL representatives over certain issues.

What this has led to is a wide disconnect between the membership and the hirearchy in Newington. We are seeing this manifested by the way members are reacting to RM-11306 AND the ARRL's reply comments which come off as an in your face repudiation of what you as a member may or may not think of what you think of them.
Frankly, it is more than a bit arrogant. When the membership attacks the organization that they are members of, it should set off alarms.

On the other hand the CTT group is just that. A group of hams who got together and created what they thought to be a better proposal. This is different in that the CTT group does not have a membership to answer to and does not otherwise represent anyone except the group itself. The ARRL has magnitudes more responsibility for the petition that was sent to the FCC because they represent (in theory) 150,000+ hams and seem to claim that they represent all of Amateur Radio in the US.

As I mentioned in anothe post, 10,000 hams took the time to send the FCC 1 original and 8 copies of comments concerning the RM issued for Incentive Licensing. They were overwhelmingly in opposition to the the RM, probably by the same 8/1 margine we are seeing for RM-11306. Presuably, the ARRL had a lot less membership in 1967-68 than it has today because there were only
36% of the hams we have today and I would think that the ARRL had a larger percentage of total hams as a membership base back then. Logically it should follow that a high percentage of those hams who took the time to comment were ARRL members. They were not seriously listened to then, and the present membership is not being listened to now.

To paraphrase on oft repeated warning... If we do not learn from history we are doomed to repeat it.

73
George
K3UD

 

First off, procedurally, it is about 3 weeks too late for Comments.  And, as of February 22, the last permissible Reply Comments to any filed Comments.  Actually, regulation 47CFR1.405(b) states that one only has 15 days following the particular statement with which to file.  Referring to statements or comments being made within the permitted 30 days after Public Notice.

For example, the Reply Comments of one Dr.Dr. Ed Jones, AE4TM, to the Comments filed by CQ Communications, are untimely and the FCC is free to ignore them (as, perhaps they should, IMO).  Why?  CQ's Comments were filed on January 27.  Jones waited until well after the time allotted in accordance with 47CFR1.405(b).  He filed his on February 22, which is much more than the 15 business days allotted in the regulation.

You can always tell when its five minutes to midnight, as the ARRL files its Comments or Replies on what it thinks is the last permissible day.  Notice how cagy they were in that they didn't file their Reply to anyone's specific Comments, as they are supposed to do.  Why?  Probably an attempt to avoid the cut off time issue.  So, really, their Reply technically is too late for any filed comments, except those filed on February 7, the last day for Comments.  The FCC may or may not consider anything filed at this point.

Now, along with careful and incisive comments on what is wrong with the approach, why not point out to the FCC that the ARRL represents far less than half (actually less than 1/4) of all US licensed amateurs?

In this case, the ARRL acted improperly by misconstruing the issue.  A Trojan Horse, if I've ever seen one, as its intent to "uncorral" Winlink email robots demonstrates.  Since the ARRL uses the implication of its name in its testimony (that it IS the National Association for Amateur Radio), and that its proposal is in the best interest of the vast majority of US amateurs, it is incumbent on us to remind the FCC that in a statistical sense, they do not represent the majority.

As a dues paying member of the ARRL, I am ashamed to ask this question:  If there is a shred of evidence that RM-11306 wasn't submitted in bad faith, well, then, SHOW ME.  And, I'm not from Missouri.  (Member comments solicited on bandwidth in general, not on the petition itself.  Member comments never published for all to see.  No prior mention of elimination of sequester of digi-bots.  Petition was not published in its entirety prior to submittal to the FCC)

If an entity that claims to represent amateur radio dares behave this way before the FCC, the FCC needs to be reminded of the actual number of amateurs that it represents, with or without its membership's consent.

With a plurality of about 8 to 1 in negative comments, one can draw a reasonable conclusion that the ARRL was not acting with the support or concurrence of even the majority of its membership.

As a member of the ARRL, I have said this before, and will repeat it here.  Others have said it too.  The entire BOD and paid Officer cadre needs to be replaced.  Dropping memberships in protest and such is NOT the right thing to do at this point.  Sending letters and emails to Sumner won't work either.  A waste of time.  Stay a member and help fix the problem for the sake of the future of amateur radio.

We need to pursue remedies that will remove those responsible.

73,

Lee
W6EM

 

George thank you for the post.

I can confirm that the "CTT" consisted of a group of guys disillusioned by the Cone of Silence around regulatory deliberations in Newington, and who were motivated to express our feeling of not being included by taking independent action ourselves.

As we did our work among us, we then proffered an idea to collect feedback here and on a wide variety of other reflectors, BBS, and group email headers. The FCC designated the proposal as RM-11305, and the Comments filed to the FCC website (majority opposed) are pretty much in line with the concerns expressed here.

As a member of the "CTT" I have the standing to say the response has been fine with us, and there's no poison held toward anyone.

We are, however, disappointed that most people taking part in the proceeding don't think Amateurs can behave if we are not restricted by mandatory, full-time segregation of modes. I feel that we could sort it out, and I did not find any evidence to compel me to change my mind.

Remaining at issue, there is still a need to match the size of reserved segments to the typical or projected number of users. We continue to feel that rising digital modes need a non-exclusive place to grow, but based on concerns expressed in both '305 and '306, that they need to be confined to an incubator (a word YOU coined, George, thank you) until such time there are enough operators and technical standards to warrant a review whether to let them out of the crib.

In my Reply Comment to RM-11306, I have proposed making a category of digital communications that has loose technical standards but tight operating standards. This would provide both the incentive and the environment for responsible development.

The League has not shown any genuine interest in receiving feedback that disagrees with their internal political stance, but it no longer is up to the ARRL. It's up to the FCC to pull elements from the Comments filed, and to decide whether any changes are available among the cross-purposes considered.

Paul/VJB

 

Lee, you were writing while I was writing --

Actually, you may also have seen a Motion for Extension that has since been filed into the FCC record for RM-11306. This provides the FCC with an official request that they consider additional responses to the provocative Reply Comment filed by the ARRL containing their interpretation of the filings that are 8:1 opposed to them.

The League's lawyer filed their group's unsavory Reply Comment probably around 4PM, eastern time, on the last day of the official filing window. I know this because I filed my Reply Comment around 4:30P and was pleased to see it on the FCC website by the time I got home that night. It is right after the one from Newington.

Electronic filings continued to take place until 11:59PM, which is how the others you see in there, got in. They were not processed into the system and could not be seen until the next day. However, there was time, in this case, to quickly sample what the ARRL had coughed up, and to squeeze a Reply to Petitioner in there as the record shows.

If the FCC acts favorably on the request for an extension, the responses now being filed on their website may come under official consideration. I urge folks to file such a response if they're as irritated as I was with the League's "response."

Paul/VJB

 

“Remaining at issue, there is still a need to match the size of reserved segments to the typical or projected number of users. We continue to feel that rising digital modes need a non-exclusive place to grow

The issue in a nut shell isn’t it, what is Amateur Radio, now and in the future.

CTT and the ARRL BOD would seem to be sold on a “Vision” of Multi-Media content delivery (what ever that is) and last mile delivery of email over Amateur radio services. Is this a valid, accepted “Vision” in the community, and who, besides the CTT and the ARRL BOD thinks this a “Vision” that the community endorses?

Another claim that is made by both the CTT and the ARRL BOD is that experimentation is being harmed, and that there is a demand for these sorts of services. As Clair Peller once famously said, “Where’s the Beef?”

Where’s the traffic analysis that shows that WinLink is being constrained by the current regulations, or for that matter, traffic content analysis that shows that the traffic being moved by WinLink is within both within the spirit and current regulatory standards of the Amateur service. Where’s the proof that digital experimentation is being constrained?

WinLInk, by adopting a proprietary, PACTOR III, modulation standard prevents traditional peer monitoring of traffic content analysis. Add on top of this, a recent move by the ARRL BOD to put forward an RM to allow encryption, on VHF and higher frequencies, there is very little reason to trust those who propose such measures as having the best interest of all the Amateur community in mind. The implication of all these moves is one of moving the Amateur Service to a future that only some elite group seem to endorse, that’s not Democracy in my book.

If the CTT and the ARRL BOD want to effect change in the way spectrum is regulated and move the Amateur Service to a new “Vision”, then they need to do it in an open and public way. As they say, “Fresh air and sunshine is the best disinfectant”.

 

Lee, W6EM is absolutely right that now is not the time to quit the ARRL in protest. Its the time to Vote.

As a life member, I won't quit. I had a nice experience with the ARRL a few years ago. I called them for something or other and told them I was a lifer. The reply I got was surprising. The person told me that they would get around to it but since I was not a paying member it would be last on her list of "to do's".

I am also the former State Director for PA Army MARS. We don't use Amateur frequencies. I am here to tell you that when an automatic packtor station comes up on frequency, it blows us off the frequency. End of story.

It doesn't listen, it doesn't care and whether its an emergency net or a BS session it takes over. ALE is just as bad.

And the ARRL BOD wants to make that legal in the Amateur side of things. I won't quit, I'll vote!

How would the DX'ers among us take it if an automated station came up on frequency during a big Dxpedition like 3Y0X and blew them away?

The ARRL BOD doesn't seem to mind.

I have to ask myself, for a volunteer group, who is paying their way? They certainly are not acting on our behalf.

But hey, as a lifer, I am not a paying member. What say do I have?

Well, one vote.

But, if there are many, we may stop this garbage.

Respectfully, Ed k3tj

PS: thanks to N6CRR for the Clair Peller reminder. I loved those spots.