FCC activates the Bandwidth process

<span style='font-size:17pt;line-height:100%'>FCC activates the Bandwidth process !</span>

The first proposal, submitted by the Communications Think Tank group on the June 20, 2005, has been assigned the Rule request number <span style='color:RED'><span style='font-size:21pt;line-height:100%'>RM-11305</span></span>.

The second proposal, submitted by the ARRL on November 4, 2005, has been assigned the Rule request number <span style='color:RED'><span style='font-size:21pt;line-height:100%'>RM-11306</span></span>.

These two requests are very different in their nature and deserve careful reading before making comments.  They <span style='color:blue'>DO NOT</span> achieve the same results and each has its drawbacks.  What advantages,  if any, are totally within the eye of the beholder.

A long time ago a novel was written dealing the American experience as observed outside of the U.S. that still has merit today.  That novel was titled “The Ugly American.”  In our dealings with these two proposals, “<span style='color:red'>WE</span>” should be mindful of the issues covered in that most revealing novel.  The U.S. Amateur radio operator has a tendency to view the hobby, as it relates to the U.S. rules, as a singularity.  “<span style='color:red'>WE</span>” tend to neglect how our efforts affect the rest of the world.


Bill.......WB6BNQ

 

A link to the Notices would be nice. Also, a link to make comments would be OK when and if available.

 

Home of the Electronic Comment FIling System:

http://www.fcc.gov/cgb/ecfs/

You can find everything from there. Look at the upper right of the screen for links for search for comments, file comments, and proceeding history.

If you click "search for comments", you'll see a place to enter a proceeding number. That will find the comments that other people have made, but if you click on the word "proceeding" you will come to a form that can look up the original document.


I've noticed the query engine seems to be pretty hosed this weekend. If you make a query and get "Server Error", your best bet is just wait a while and try later. Based on my general experience with managing systems like this, it will generally either fix itself within an hour or two, or it will remain broken until somebody comes to work in the morning and figures out what is wrong.

 

Despite the "headline" from Bill, WB6BNQ, the CTT's petition is mute on the matter of coordination by bandwidth, and was written by a small group active on digital modes, SSB, CW and AM.

I've asked Bill to consider re-wording his headline.

It seeks to discontinue mandatory, full-time segregation by mode, in what Petitioners believe will be an affirmative way to de-regulate and improve the utilization of spectrum.

It travels independently of the bandwidth-based regulatory scheme the group in Newington wishes to impose. The ARRL proposal is not mentioned in the CTT's Petition.

One thing both proposals have in common is that they each were widely discussed here on QRZ.com. Please check the archives for some interesting support and criticism.

Paul/VJB

 

<FONT FACE="times new roman" size="+15" color=red>

OH MY GOD!  WHAT DO WE DO NOW?</FONT>

Since I did  not read the "Ugly American", should I be worried?

K2WH

 

What the ARRL proposal REALLY says:

1. Eliminate the "cumbersome" FCC process for approving new modes, the STA process, and the public comment period for NPRM's and thereby deprive the radio amateur of his right of due process, currently guaranteed by law.

Does anybody know of the tallied results of bandwidth@arrl.org? The FCC always discloses comments on their NPRM's, but did ARRL disclose just how many approved or disapproved of their bandwidth petition? Of course not! The ARRL CEO would only say that there was "significant" support for the petition, without saying what "significant" was...

2. Eliminate "bothersome" regulations and replace them with bandplans (presumably ARRL bandplans!).

I.e. give the power over where radio amateurs are expected to operate to a few select members of the ARRL Executive Committee - the same committee that immediately granted every request made by Winlink without asking for any public comment.

Is this how you want things to be handled?

3. Eliminate all restrictions on where email robots (such as the Winlink Pactor-III robots), can operate, even anywhere in the phone bands, but be sure phone stations of the same bandwidth cannot interfere with the robot stations by giving them a "safe harbor"!

This was accomplished by sneaking in a total rewrite of Part 97.221.

Did you realize this?

4. Arrogantly expect the whole amateur radio world to accomodate FCC regulations by totally ignoring all restrictions on where email robots ("digimode or 'store- and-forward' stations") should operate that are part and parcel of the IRAU Region 1 bandplan.

I.e., ARRL, HF signals don't really travel worldwide, or across borders, do they! Must not, if you are serious!  


5. The future of ham radio is no longer communicating, such as ragchewing with another radio amateur in real time, or contesting, or DX chasing, or award chasing, but using the ham bands as an answering machine and leaving multimedia messages for a friend or for a third party.

Yes, "high-speed multimedia" on HF must truly be the future!

Or is it...Unfortunately, the most advanced error-free high-speed mode for multimedia is Pactor-III, which should blaze along at 225 characters per second, but, according to Winlink statistics, only achieves an average of 15 characters per second on HF in actual use, but takes up five times the bandwidth of Pactor-II, which should blaze along at 50 characters per second, but only averages 10 characters per second in actual use on HF, taking up a bandwidth of 500 Hz, all compared to a much more efficient ARQ mode, PSKmail, which achieves 5 characters per second in a bandwidth of only 100 Hz.

So, Pactor-III uses up a bandwidth that is 25 times as much as PSKmail, but only achieves a speed advantage of 3 times over PSKmail.

"High-speed multimedia" on HF? I'm from Missouri, so "show me" first, ARRL, and make irresponsible statements second...



Before you comment on the ARRL petition, PLEASE read the details very carefully -You might be surprised to find what it really says.

Skip, KH6TY

 

Bill, as emailed privately, I accept your interpretation and the connection you see between the two proposals.

As a practical matter, the system of coordination we use on HF has evolved and prevailed over a very long period of time. I believe we can date it back to when the HF allocations were, in those simple days, split roughly 50/50 between CW and "phone" emissions, with an overlay by license class.

It is a nice system that has been cluttered up by amendments to accomodate new modes without re-sizing those portions reserved for older modes now out of scale with their levels of activity. There is also the matter of licensed-based segments of the bands for licenses the FCC no longer issues. But since those segments are not exclusive reservations, our upper-class licensees are able to make use of that spectrum.

The amount of time that has passed shows the durability of the mode-based system, and I believe that it's because of the stability of the longstanding voluntary layout of activities. The concept put forth by the CTT relies on that stability and calls for a relaxation of regulatory constraints so that we may do the re-sizing on our own.

I don't remember you taking part in the extended discussions on QRZ.com and elsewhere, sorry, but I'm glad you now have taken an interest. As one of the Petitioners, I can say with authority that we are receptive to feedback and have cited some of it in the document itself. I'm grateful for your kind comments about our work in comparison to what has been offered by the group in Newington.

According to the FCC Public Notice , the formal Comment phase on both these petitions opened January 6th and runs for 30 days. You can expect additional fine-tuning, corrections, and refinement among the filings.

Best wishes,

Paul/VJB

 

Which is it Bill ? Having "very different" natures makes it hard to be "entwined".

If, as you say, both offerings fall far short of what is needed then I ask you to tell us all what is needed. Or is the status quo your solution ?

 

WB6BNQ wrote:

From The CTT document:

So you see, we know we do not live in a bubble. We've considered the International impact of our offering and attempt to bring U.S. allocations inline with the rest of the world.

 

Thumbs DOWN to both ARRL & CTT proposals.
All those guys are seeking remedy for a malaise that hasn't been satisfactorily identified!

If it ain't 'broke'...

Inept as FCC has proven to be, I'd rather FCC administer amateur regulations, bandplans, licensing etc with little input from those other guys!

Thumbs UP to status Quo!

 

I really hope we can muster a more reasoned response to these plans than this. The status quo is in the way in many cases. There must be room for change!

The problems these plans have been debated extensively already including maintaining the status quo. I think result of all the debate to date has been the identification of a problem. There is a lack of trust between amateurs that we can live together and develop for the future. The DX players don't trust the rag chewers, the digital people do not trust their peers using different modulation or coding schemes. The phone people do not trust the digital people. What a mess.

We tend to compare out best practice to those of our international partners while forgetting that many of them are no larger than a state in our country. It is a simple matter for a small government to allow for their amateurs to self regulate while it is a major problem for us. We are just too diverse a group.

My view is simple:

1.) Band planning is a must and it must have teeth.
     a.) We need a coordination organization.
     b.) We need enforcement
     c.) We need cooperation from FCC
     d.) We need mature behavior by all parties.

2.) We need to be sure that the most pervasive digital mode  is provided with sufficient space that those that use it are not tempted to migrate into those areas where phone activity traditionally dominates. They will cause severe interference and make a congestion problem worse.

Neither of these plans adequately address these concerns, but together they come close.

Why is the status quo unacceptable for the future? Well, the most compelling reason is that many commerical interests including BPL are looking closely at our our unused spectrum with envy and the FCC is looking for ways to shoe horn into all spectrum various interests that would be compatible sharing partners.

We must make better use of our spectrum and this means digital as well as traditional analog uses. Like it or not, digital is the wave of the future and we need to be ready to welcome it not restrict it.

How do I plan to comment, you might ask? Well, I have already commented on this in a number of the previous debates on this subject and I have contributed my thoughts to my League Officials. Now, I get my turn to make the comments that I think will stick. I agree in principle with the idea of segmentation by bandwidth. This has been my position from the beginning. The 4 items above about band planning are what I think need to be enacted in the regulations and/or acted upon when appropriate regulations have been enacted. The rest of the problem concerning maturity, I can not comment on. I comply with band plans and regulations and will continue to comply.

BTW, I have no axe to grind concerning digital modes. I'm mostly a QRP/QRPp CW operator and plan to continue this persuit. Should I move to digital, it will likely be to PSK31 because of narrow band factor that makes QRP/QRPp work effective by reducing the bandwidth and thus inproving the signal to noise ratio over other digital modes and even CW.

I'm finished, now let me put on my flame retardant garments. Have fun.

Ken

 

'BNQ is running a little late.

The Think Tank's Petition was assigned RM-11305 on June 20th of last year.

The ARRL's Petition) was assigned RM-11036 on November 14th of last year.

Read the proposals and save your time/effort for where it matters: the FCC. File your comments there, where they'll be seen by the rulemakers.

 

AE1X:

My view is simple:

1.) Band planning is a must and it must have teeth.
    a.) We need a coordination organization.
    b.) We need enforcement
    c.) We need cooperation from FCC
    d.) We need mature behavior by all parties.
<hr size=15 color=purple>
Surely you jest.  Band plan yes.  The rest is a pipe dream or an invitation to disaster.

<table border size=15 bordercolor=purple><td> a) Coordination organization: Wrong. Look what happened to repeater committees, infighting and political activism.<td><tr><td> b) Enforcement: The FCC is basically a paper tiger when it comes to amateur matters.  Just read about how long the FCC took in some recent convictions.<td><tr><td> c) Cooperation from the FCC:  Wait, I'm still laughing.<td><tr><td> d) Mature behavior:  From who?  The FCC or amateurs?  Either way, you won't get it.</table>


K2WH

 

Please Alvin,

Don't embarrass yourself.  Those dates are when the material was received by the FCC.  At that point they sit in a basket (so to speak) waiting for action. When the FCC is ready to deal with them, if ever, then they get assigned a Rule Making number.  That was done on the 6th of Jan 2005.

Please reference the following assignment notice :

http://gullfoss2.fcc.gov/prod....8307797

And here is the "BASKET" from which these proposals sat until being dealt with.  You will notice that all the ones still in there are all titled "PRM05WT" which stands for

PRM = Proposed Rule Making
  05 = year received (2000+ assumed)
 WT = Wireless Telecommunciations Bureau.

http://gullfoss2.fcc.gov/cgi-bin....PRM05WT


Bill....WB6BNQ

 

I AM AGAINST BOTH. NOTHINGS BROKE. WHY TRY TO FIX SOMETHING UNBROKEN....