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

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

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  1. K4KYV

    K4KYV Subscriber QRZ Page

    There IS a CB connection. The only apparent reason for the SSB-only restriction is to make the proposed new HF privileges consistent with existing 10m privileges. The 10m Tech/Novice sub-band was created as a result of the League's original "Novice Enhancement" petition. The stated purpose of the prohibition of AM it the original Petition was the League's (bogus) fear that CBers would acquire easy-to-get Novice tickets en masse and then hack their 11m transceivers to work on 10m, turning the new segment into a de facto CB sub-band right in the middle of the ham band.

    Your observations regarding the current state of CB is a convincing reason why there would be no need for such a restriction to-day, and why the rules should be changed to allow AM in the existing 10m segment. The League's current Petition states no reason for the proposed SSB-only restriction.

    This is not to say that I am in support any new HF phone privileges for Technicians, other than allowing them to use AM in their existing 10m segment, on the contrary. OTOH, I see no problem with adding RTTY/data to their existing CW privileges in the 80, 40 and 15m bands.

    As for the SSB-only restriction positioning AM as a "premium mode", IMO, I isn't a good idea to have any additional rules prohibiting AM in any phone segment. Such things have a way of gaining momentum and then expanding under the right circumstances.

    My current thinking is to comment in opposition to the proposed new HF phone segments for Technicians, but in support of a limited RTTY/data expansion of their existing CW privileges. In addition, I plan to propose adding AM privileges to the existing 10m phone segment, and that if the FCC does decide to go ahead and grant Technicians new phone privileges on HF, contrary to my opposition, that these new privileges should include AM.
     
    AF7XT, AC0OB and K4VA like this.
  2. N2EY

    N2EY Premium Subscriber QRZ Page

    I don't think it was "bogus" at all. Not back when it was proposed, anyway.

    When it was first proposed that Novices get 10 meter privileges, the CB/freeband boom was growing fast. There were a number of CB sets which used tx/rx crystal pairs that, when swapped (rx crystal in the tx socket, tx crystal in the rx socket), permitted operation on the lower end of 10 meters.

    Novices got 10 meter privileges in 1972 - but only CW! The idea was that the intruders would be discouraged by the "beeps"....

    SSB for Novices on 10 came later.
     
    AF7XT and KD0CAC like this.
  3. WA3VJB

    WA3VJB Ham Member QRZ Page

    Among the nearly 60 Comments already in the FCC's database, this well-written rebuttal against RM-11828 by prominent AMer AB2RA, Janis.

    https://ecfsapi.fcc.gov/file/10314271330556/petition to dismiss RM-11828.pdf

    Does anyone on here need any guidance as to how to file into the FCC's Electronic Comment Filing System? It's really easy and worth your time to be "on record" with your views, as an active, concerned licensee.
     
    KD0CAC and AB2RA like this.
  4. K8EA

    K8EA Premium Subscriber QRZ Page

    I just quickly scanned the 30 page document but did take notice of this footnote: "the Instant Petition does not serve as a substitute for, nor does it supersede RM-11759." So the ARRL position seems to remain the same on RM-11759 which gives away the current extra class exclusivity of the 3600-3700 phone band. I need to read this closer but as a 53 year ham and extra class since 1977 (and life member of the ARRL) I am curious as to how this new "Instant Petition" will impact RM-11759 and the possible loss of ANY exclusive extra class privileges. There's a lot of gobbledygook in these 30 pages. I will carefully read it this weekend. It just came in to my email box. In the meantime, anybody have any input on my comments? We've got to be vigilant here.
     
    KD0CAC, AB2RA and K4VA like this.
  5. K4KYV

    K4KYV Subscriber QRZ Page

    ...in 1987, IIRC. By then, hardly any CB transceivers still used crystals. The expansion to 40 channels happened a decade earlier, in 1977. Nearly all 40-channel radios used frequency synthesis, not a set of individual crystals for each channel.

    "Freebanders" used SSB almost exclusively, and looked down their noses at CBers who used AM. In fact, they didn't even consider themselves "CBers" at all, but called themselves "sidebanders"; "CBers" were the riff-raff and they were the ones who operated AM.

    The problem I had then with SSB-only on the new 10m novice band, and would have to-day with the proposed expanded Technician privileges, is the same as the problem I have with the UK/Canada/Australia "Foundation" licence prohibition of homebrew equipment, requiring that all transmitters be commercially built. If "Technician" class is to be our entry-level licence, then newcomers should be free and encouraged to start out by putting together a simple low-power AM transmitter, or modifying a discarded CB transceiver to their licensed amateur frequencies, just as back in the day we modified WWII Command sets or constructed simple 1 and 2-tube crystal controlled transmitters to use with our Novice CW privileges. Not many hams, even seasoned Extra Class, have the technical know-how, shop tools, test equipment and parts sources necessary to construct even a bare-bones basic SSB transmitter, so this restriction, like the UK's Foundation licence, immediately directs newcomers by default to the plug 'n play route, discouraging the admittedly very few who might be curious enough to try to get on the air with a simple transmitter they built themselves.
     
    AB2RA, K4VA and AD5HR like this.
  6. AB2RA

    AB2RA Ham Member QRZ Page

    I welcome the point made in this thread about AM. I had not considered that.
    Also the sneaky RM-11759 Tech DATA hidden in that proceeding, which is still open.
    I also made the point that Techs should have full 10M, which would include AM & FM, at their power privileges, and that was overlooked a SECOND time by the ARRL on restructuring. Techs know how to do FM, and some are more proficient at satellite than most extras. I was around the first time they tried to do this. Wide band automatic DATA was not included at that time. This time, that is what it is all about.

    Now there is more at stake, for FT8 and CW fans. Tech gets 100% of General allocation on the bands involved.
    They can be the Control Op of an automatically controlled email store and forward station without passing a test on even a USER level information for that mode.
    This is a promotion of free HF email for yachts. It gets the known pirates who can't pass General legal.
    Here is the truth, right from Lor Kutchin's own words:
    https://ecfsapi.fcc.gov/file/101311670501116/FINAL REPLY 2019 16-239.pdf

    On the bands involved in RM-11828, Techs get 55% of the General VOICE allocation. Will Generals like the congestion?
    Alternative: Study the General material. Take the Test. Pass the test (kids can do it). Earn the privileges.
    The HOA antenna restrictions and other factors are far more significant barriers to HF operation by any class license.

    Here is a simple, step by step, easy if you never filed before, only 10 minutes tops.
    Pick what you want in the talking points, or disagree completely. But only 3 weeks left, so comment NOW.

    Short comment, type live into a box on the form:
    http://wireless-girl.com/HowToFile11828Express.html

    Upload a document you prepared in advance (must be .doc or .pdf):
    http://wireless-girl.com/HowToFile11828STD.html

    [​IMG]
     
    AF7XT likes this.
  7. K7JEM

    K7JEM Ham Member QRZ Page

    Appeal to fear is a weak argument. Bogeymen are only believed by children and those unable to muster rational thought processing.
     
  8. AB2RA

    AB2RA Ham Member QRZ Page

    Past consistent behavior supports a strong argument.
    http://www.zerobeat.net/bandplan-dissent.html

    And there we go again, the Sailor Bogeyman.......

    https://ecfsapi.fcc.gov/file/10100754910405/MATTHEW PITTS REBUTTAL1.pdf

    Rational people see things like this, and do not respond with fear, its something else.
    I don't fear you. I plan to stop you, and the ARRL, til they wake up. There is a new BOD, and I have hopes for their success.
    Stick to the facts, not ad hominem. That is the weak argument.
     
  9. K7JEM

    K7JEM Ham Member QRZ Page

    I think you are using the sailor bogeyman to promote your opposition the this tech enhancement proposal, which is pretty obvious. People with a brain will be able to see through it, and understand the "appeal to fear" that it is.
     
    N6HCM and AB2RA like this.
  10. AB2RA

    AB2RA Ham Member QRZ Page

    BTW, Lor Kutchins concerns were not with compliance and reporting known pirates to the FCC for prosecution.
    He knew for a long time this was going on, and just let it go. Only now that it is out in the open is it an issue.
    To him and Dave Skolnick (Seven Seas Cruising Association) it was a public relations problem.
    Also, the Golden Globe yacht race was concerned about violation of their race rules. The piracy of amateur calls was secondary.
    https://ecfsapi.fcc.gov/file/101311670501116/FINAL REPLY 2019 16-239.pdf

    Ordering repairs or parts for your boat, posting to Facebook or blogs is disseminating programming to the public (broadcasting), and other things like email to your friends are not reprehensible. Using HF radio to participate in a race for a $100,000 cash prize is OK too. When Dave Skolnick operates a business sailing other people's yachts to a specified location, and uses HF radio to facilitate it, he is providing a valuable service, that's fine with me too. But that is what commercial voice marine radio and Sailmail is for, as a commercial service for only $25 a month. Note now that Sailmail, operated by Seven Seas Cruising Association is now a monopoly because it put all its competitors out of the HF email business. The same people operate an email system in the amateur spectrum. Cause for concern.

    On amateur radio, its not OK. 97.113 (5) Communications, on a regular basis, which could reasonably be furnished alternatively through other radio services.

    Routinely doing so while unlicensed is also not OK, and that is now out in the open.
    https://ecfsapi.fcc.gov/file/7521315143.pdf
    https://ecfsapi.fcc.gov/file/1214762322850/SSCA 12_18 REPLY Final.pdf

    Facts. Not fear. Nothing personal.
    And you have the right to your opinion, and can file that at the FCC like anyone else.
    But the facts are the facts.
     

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