RM-11828: FCC invites comments on ARRL petition to give Technicians HF phone privileges.

Discussion in 'Amplitude Modulation' started by K4KYV, Mar 15, 2019.

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  1. K4KYV

    K4KYV Premium Subscriber Volunteer Moderator QRZ Page

    As predicted, the deadline for public comments has passed, but they are still coming in and the FCC is posting them on ECFS.

    Here is ARRL's "Reply" to all the comments submitted to the FCC up to the deadline. You will notice they make only a couple of brief, fleeting references to "voice privileges"; their reply is devoted almost exclusively the issue of Digital Communications.

    https://ecfsapi.fcc.gov/file/10430651927593/ARRL Reply FCC RM-11828 04_2019.pdf
  2. AB2RA

    AB2RA Ham Member QRZ Page

    This is one of the best I have seen:
    https://ecfsapi.fcc.gov/file/10429133671169/Comments to FCC RM 11828.docx
  3. ND6M

    ND6M Ham Member QRZ Page

  4. WA3VJB

    WA3VJB Ham Member QRZ Page

    I am encouraged by the writing style of the new lawyer for the ARRL, David Siddall, compared with the previous counsel.

    Regardless of the improved clarity, the basis for the group's petition remains unsupported by marketing research, relevant opinion poll, or any legitimate cause-and-effect documentation.

    The group's Reply Comment asserts "the interests of young STEM candidates understandably lean toward digital technologies and the accompanying computer programming aspects." Yet, the ARRL did not seek input from any "young STEM candidates," as to whether they would be interested in the hobby of Amateur Radio.

    That's both a marketing problem and a mismatch with the intended audience. The Petition should be withdrawn or killed outright by the FCC as it deliberates the lack of merit.
  5. AC0OB

    AC0OB Platinum Subscriber Platinum Subscriber QRZ Page

  6. AC0GT

    AC0GT Ham Member QRZ Page

    Okay but I have one question, how long does everyone expect the FCC to enforce CW only bandwidth for Technicians below 25 MHz?

    CW only bandwidth was an anachronism in 1990 when the "no-code" Technician license was created. It was still an anachronism in 2000 when the FCC reduced Morse code testing for all license classes to 5 WPM. In 2007, when the FCC did away with all Morse code testing to get a license, that CW only bandwidth was still an anachronism. Now it's 2019, how much longer can we expect the FCC to continue with this policy of CW only transmissions below 25 MHz by Technician license holders? A policy that was written in 1951?

    I believe the ARRL petition to be poorly written, and many of the arguments bordering on the absurd. What doesn't change though is that the need or desire to operate CW among the newly licensed is decreasing. I have no idea if the FCC will take this petition seriously, but posting it for comments does seem to indicate that they placed some merit in it. The FCC may indeed shoot this petition down. What it does show is that people are considering a change to the license structure, and it will be interesting to see the future commentary and analysis on this and similar matters.

    I will say one thing, this certainly got people's attention. If this was completely without merit, and simply an absurdity, then no one would be talking about it. Agreed?
  7. AC0GT

    AC0GT Ham Member QRZ Page

    I found it to be a pile of condescending BS. Let's take a couple paragraphs as examples.

    Let's see if I have this straight. CW is a digital mode. Technician license holders have privileges to operate CW on many HF bands. There's few people with a Technician license operating CW on HF. Therefore those with a Technician license don't have any interest in digital modes.

    Here's my hypothesis. Experienced CW operators know machine generated Morse code when they hear it. Computers have a long history of not doing well in receiving Morse code accurately. When a Technician operates CW by computer then the experienced operators simply move the VFO out of the reach of Technician operators rather than try to send code for a computer to interpret. I'm not saying ALL experienced operators would do this, only that there is enough of them out there that this discourages Technician holders from continuing. That's because CW is not a digital mode, and comparing CW to any digital mode does not follow.

    This is just Technician bashing at it's pinnacle. Allow me to interpret...
    "We can't have any Technician holders operate on 80 meters! They'd just interfere with us doing real life saving work!"

    I believe the FCC has some finely tuned BS detectors. They will look at this and not see a potential for interference, I believe they will see an opportunity to add thousands of experienced radio operators to 80 meters overnight.

    Emergency communications are not done with CW any more, not with any regularity anyway. If there is concern on the diminished capacity of Amateur radio to come into action and participate in any real emergency, and if HF is indeed valuable spectrum to perform this communication, then we need people on HF phone early and often. That way they gain experience before they are needed.

    This commentary by Mr. Overstreet was not a case for keeping the status quo, it was a commentary on how Amateur radio is losing their grip on reality.
  8. K7JEM

    K7JEM Ham Member QRZ Page

    Wow. That comment was hard to read. It is apparent that he has no firm grasp on grammar and sentence structure, as well as misrepresenting things in general through the use of logical fallacies and bad comparisons.
    AC0GT likes this.
  9. AC0GT

    AC0GT Ham Member QRZ Page

    Indeed. Here's another gem from Mr. Overstreet.

    I thought the Amateur radio service exists precisely for the purpose of training future professional electronics technicians and engineers. I'm so glad Mr. Overstreet corrected the record on this.

    In reading many of the comments here and on the FCC website I'm getting deja vu all over again. I saw the same arguments made 20 years ago, when the FCC first indicated they were willing to end Morse code testing for Amateur radio licensing, as I do today.

    One example was a common argument on not expanding Technician privileges to get access to 10 meter phone was that the Technician exam did not properly prepare operators for such privileges. The FCC simply responded that a Morse code exam did not prepare a Technician Plus for these privileges either, so if a Technician license holder is unprepared for these privileges then the Amateur radio community has failed in providing an appropriate question pool for the privileges already granted by the FCC for those with a Technician Plus license. Sure enough I saw a lot of people realize this was not going to go well for them and the question pool had a handful of questions added to cover privileges that had existed by that time for over a decade.

    What's the argument now for not allowing Technician license holders phone privileges on 80 meters? That they do not comprehend the nuance of operating on that band compared to 10 meters? Or (if people feel a need to not just give a cutting remark but also a twist to the knife) compared to 11 meters? If Technician license holders do not comprehend the nuance of operating on 80 meters then the Amateur radio community has failed to properly prepare Technician license holders for the privileges they've held for close to 30 years now.

    I could conceive that this is something of a slippery slope argument, that it is easy to argue that if Technician license holders should be allowed greater access to 80 meters then those holding General and Advanced licenses should be granted all the same operating privileges of Extra. What that tells me is that the licensing system we have now is in need of serious scrutiny. We need to reconsider the testing and privileges of every license class, not just Technician. We need new licensing and new testing, not just more patches on top of decades old patches.

    Let's have licenses that test based on the privileges granted, not some concoction of what someone believes would create an incentive to upgrade. Not everyone will have the same incentive. Not everyone has the same goals in mind from getting a license. No other licensing I can find in the USA is based on withholding privileges solely for the purpose of incentivizing an upgrade to the next level of privileges. There may be a few other nations that have incentive licensing for Amateur radio, that doesn't make it a wise choice for us.

    There is no incentive licensing in the current FCC Amateur radio licensing, because additional HF operating privileges are not an incentive any more. As examples I give the large numbers of people with Technician licenses, as well as the large numbers of people holding on to their Advanced and Novice licenses for nearly 20 years beyond the last time either was newly issued.

    The arguments for this update in Technician privileges is the hope it will bring more to upgrade. I believe it will fail. The arguments against is just the same 30 year old Technician bashing. It wasn't an argument then and it's not an argument now.

    Where does that leave us? About 30 years overdue for a new licensing scheme.
  10. WA3VJB

    WA3VJB Ham Member QRZ Page

    Kurt, I am reading with appreciation your two, most-recent postings on this thread. The "AM Forum" concerns itself with this specific part of the hobby -- AM on HF -- and I'll welcome you as you take part in this thread on the ARRL's petition.

    To reply, I'll say I am not a big fan of using regulatory methods of achieving good behavior or to promote a mode or activity; nor do I think a regulatory approach is an efficient way of recruiting and retaining candidates for an Amateur license. Thus, I don't believe the current licensing structure is having much effect on levels of activity or long-term participation in the hobby.

    I hope you filed Comments and Reply Comments into the FCC's public database on this and related petitions. Your eloquence and thoughtful presentation of your points is valuable for agency staff to consider.

    To a couple of your points:

    "If this was completely without merit, and simply an absurdity, then no one would be talking about it. Agreed?"

    I disagree. There have been many misguided, bone-headed proposals from the ARRL over the years that are more provocative than anything else. An infamous example is the League's failed segregation-by-bandwidth scheme, that they were forced to withdraw as poorly written and very heavily opposed. I consider it an absurdity, and thousands of Commenters agreed.

    Regarding the prospective deliberation by FCC staff before rendering a decision, you say "... posting it for comments does seem to indicate that they placed some merit in it."

    Not necessarily. In what I consider the old days, when 12 physical copies of a Petition or Comment had to be delivered to the FCC, the agency had a far higher bar to reach before staff would move a proposal to the public forum. With the advent of the Electronic Comment Filing System, it has become far easier for anyone to participate in the FCC's rule making process, including the initiation of proposals like this one.

    The quality of such Petitions has declined, in my opinion, as a result, but I am very satisfied that the FCC's infrastructure now enables a rapid response from active, concerned licensees.

    Thanks again for being on here with us, and regards.
    AC0OB likes this.

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