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. AC0GT

    AC0GT Ham Member QRZ Page

    What I mean by absurdity is a petition that the FCC would not conceivably implement. Something the FCC could dismiss completely would not be posted for comment from the public. I believe this petition from the ARRL gets so much discussion on QRZ is because we could see the FCC actually make the changes proposed. I believe this is what so many fear, and not always for the most logical and rational of reasons.

    I can agree that the speed and ease by which such petitions can be made encourages the FCC to post for comment far more petitions than they might have done in the past. Because of such ease it can mean lower quality of petitions getting through. What it does though is allow the FCC to get feedback on what the public feels is best for Amateur radio and act accordingly. The truly absurd are not likely to get posted for comment. The merely badly written petitions can still be posted, but being badly written does not mean the petition is devoid of merit.

    Thanks, and I enjoyed your commentary as well.
  2. K4KYV

    K4KYV Premium Subscriber Volunteer Moderator QRZ Page

    With the very next sequential RM number following Tech Enhancement and a good example of bordering on the truly absurd, this one appeared on ECFS just days afterwards, open to public comments. Skimming through the comments it appears to be drawing overwhelming opposition, while Tech Enhancement garners about 50-50 support vs opposition.

  3. AC0GT

    AC0GT Ham Member QRZ Page

    Because the "Tyro" proposal is viewed as bordering on absurdity few people are even bothering to discuss it. I searched for the comments on both RM-11829 and RM-11828. I saw RM-11829 received 162 comments so far, and I'll take your word that they have been overwhelmingly in opposition. RM-11828 received 1194 comments, and my sampling of the comments agrees with yours that it's about 50/50 support vs. opposition.

    If this ARRL proposal was in fact absurd, had no merit, etc. then it would have faded into the background by now like the Tyro proposal. If it were without merit then there would not be much to say in support. If it were truly absurd then few would fear it being implemented to the point they be compelled to comment.

    I believe the argument that few Technician license holders were asked what they wanted, and therefore the polling is without merit, is hollow. This was a polling of ARRL members, many of them holding Extra and General licenses, asking what they thought an entry level license should look like. This is in effect asking them what they want newly licensed Amateurs to see when entering Amateur radio. They responded that instead of a new license that they'd prefer those with a Technician license to have increased access to HF frequencies. This isn't Technician license holders asking for a handout as this is often portrayed. This is experienced Amateurs granting the FCC permission to share some of the bandwidth with them in the hope they upgrade.

    If this was in fact based on a polling of those holding a Technician license then I can see the argument that this is a handout. The fact that the number of Technician license holders was small gives the polling FAR GREATER MERIT because now it cannot be the "kids these days" asking for something without any cost to them. It's experienced licensed Amateurs giving up some of their exclusive bandwidth in the hope to retain more Amateurs in the future, and also recruit more that have not yet obtained a license.

    I still see this commentary on the polling as a lose-lose case for Technician privileges. If they were not giving feedback then it's because they have no interest in HF and therefore do not deserve additional privileges. If they were polled and responded in favor then they are just asking for a handout. Well, they were not a significant portion of the polling, and the people that responded still considered this a good idea. What's the argument then? The polling has no merit because they weren't a significant portion of the responses. Okay then, let's poll them. If they are in favor then should we make this change? Or, as I suspect, would they simply be called lazy and ignorant for not taking the easy 35 question test for General? If those with a Technician license are opposed? Well, then OBVIOUSLY we can't do this because now the Technician license holders don't want it.

    What do all of you need to hear from the current pool of Technician license holders to convince you that this is a good idea? I'm guessing nothing they say could change anyone's mind on this. So, why all the concern that they were such a small portion of those in the poll results?
  4. AC0OB

    AC0OB Platinum Subscriber Platinum Subscriber QRZ Page

    Did the ARRL reveal the license class for each questionnaire's response, or are you simply hypothesizing as to what might have happened?

    The same thing I would ask of any of my students in that I would want to see some form of personal motivation and interest from the licensee that if they really seek more privileges, they will study and pass the tests for the higher license classification.

    If my students want to enter the field of physics or engineering and enjoy the privileges and personal satisfaction from those fields they must show 1) interest, 3) motivation , and 3) show me they know the material via lab work and tests.

    I have never seen a "free" or gimmie grade result in technical accomplishment or personal satisfaction.

    How many would like to see free passing grades given to aerospace engineers or medical doctors without them showing they can design and test an airplane or fix a patients hernia, respectively?

    Not me!

    Last edited: May 7, 2019
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  5. AC0GT

    AC0GT Ham Member QRZ Page

    The ARRL gave the counts for each license class in the results for their surveys. The people with Extra and General were easily over 80% of those that responded in both surveys. Those with Extra were either the plurality of those polled or the majority. I couldn't find the poll results right away otherwise I would have provided a link. It's out there, they didn't match up how person or license class answered the questions but it was clear that those with a Technician license would not have changed the results much.

    Why didn't you just say that nothing the Technician license holders said in a poll would have mattered in convincing you this petition was a good idea?

    Get a grip. This is not a license to design railway bridges or fly an airplane, it's a license to operate a radio for non-commercial communications. This is a minor change in the modes and bandwidth allowed for Technicians to operate on bands they've already been tested over, and with modes they've already been tested over. This isn't all that different than when 60 meters was added to the band plan but no one was required to test before getting access to that bandwidth.

    The FCC allows people to operate marine SSB HF radios with output up to 1000 watts, no testing, and only having to fill out a form and pay a fee. I think we can allow those with a Technician license access to some Amateur HF bandwidth when transmitting less than 200 watts.
  6. AC0OB

    AC0OB Platinum Subscriber Platinum Subscriber QRZ Page

    Because I had a non-emotional and technically reasoned response stated in my own words, not your words.

    You missed the analogy. Without the incentive to know more and do better, and testing out, handing you a freebie accomplishes nothing. Your comparison to the 60 meter band plan is faulty. Extra, Advanced, and General class licenses were given access to 60 meters, a channelized band with severe restrictions such as 50 watts max ERP, and USB only. No privileges were given to the Technician class. Go ahead and operate there if you must.

    I thought we were speaking to the topic of Amateur HF privileges, not going off on a tangent regarding Marine privileges. Again your comparisons lack any real logical linkages.

    So no, none of your weak and "gripless" tangential arguments have convinced me that handing out freebies accomplishes anything.

    Last edited: May 7, 2019
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  7. AC0GT

    AC0GT Ham Member QRZ Page

    Most people call that "spin". You responded to my question, by typing words to my screen, but you didn't actually answer the question. All you gave me was that you'd explain to those holding a Technician license that if they wanted more access to HF that they'd have to upgrade to General. That's not soliciting feedback, that's explaining your opinion to them.

    Well your analogy went a bit too far and raised the stakes far beyond what is under discussion. This isn't a matter of life and death.

    Right, no privileges were given to Technician. That was kind of the point. Privileges change from time to time for all license classes. This petition is not asking for much, just a minor update in privileges to those already licensed, kind of like what happened with the addition of the 60 meter band.

    It's called an analogy. No analogy is perfect but in this case it's very close. The FCC allows far more privileges to people that fill out some paperwork and give them a few bucks than what is asked for here. If the FCC can tolerate this, on commercial and emergency frequencies, then they can tolerate a far smaller piece of HF for someone that took some tests for the privileges.

    It's only a "freebie" to those already licensed. I'm thinking of the future Amateurs. I'd much rather we see Technician get "restructured out", like Advanced and Novice were, and a new license created in its place but this petition isn't too bad. Maybe instead of getting so hung up on "freebies" for those already licensed perhaps you could consider the impact this update in privileges might have on future licensed Amateurs. It won't be a "freebie" for them because to them it will simply be what they gain after they take the test. There's still plenty to gain in upgrading to General and Extra. They simply won't know the difference, it will all be new to them.

    Do you believe the FCC will keep Technician privileges as they are forever? That there will never again be an adjustment like what happened with 60 meters? Or any of a number of other changes to privileges over the decades? Just how long do you believe the FCC will keep Technician privileges as CW only below 25 MHz?
  8. AC0OB

    AC0OB Platinum Subscriber Platinum Subscriber QRZ Page

    Correct in that what you have stated thus far are either protracted fabrications or total BS.

    I had rather see people "earn" their privileges as I have stated previously. A future impact for not having people earn their privileges through education and testing, is a chaotic situation in which ARS licenses become "no-test" handouts.

    You can call it "restructuring" as long a you like, but restructuring is simply another distraction for freebees.

    Neither you nor I can predict the future or what the FCC will do unless you are a certified Savant.

    And your 60 meter example is simply another misleading, superficial, and implausible comparison.

    So no, your restructuring statements and tangential arguments have not convinced me otherwise.

    I have sent my comments to the FCC. You are free to do the same.


    Last edited: May 7, 2019
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  9. K4KYV

    K4KYV Premium Subscriber Volunteer Moderator QRZ Page

    A bit late for that. The deadline for comments was 12 April. HOWEVER, the FCC generally accepts "reply comments" up to 30 days past the initial deadline, which would fall due 12 May, 5 days from to-day.

    To be on the safe side, I would recommend formally entering anything submitting this late date as a "reply comment", and word your comments in such a manner as to be in "reply" to previous comments submitted, and be sure to cite the name(s) of specific commenters you are responding to. Enough has already been said, that about anything you add could be construed as a "response" to something in someone else's previous submission. Scroll back through the list of submissions, and be sure to cite only specific items "Received:4/12/2019" or before.


    Inevitably, comments will continue to come in after the deadline, and they will be posted on ECFS. But the possibility exists that items with the date stamped past the deadline may not be fully considered by the FCC, or even considered at all.
  10. AC0OB

    AC0OB Platinum Subscriber Platinum Subscriber QRZ Page

    Right, there is a process in which to present your comments to the FCC and everyone has a right to express those views.


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