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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. AB2RA

    AB2RA Ham Member QRZ Page

    Exactly right, for now.
    Some of have submitted counter petitions or petitions dealing with not being able to display the contents of transmissions.
    I wasn't clear on what this person wanted. That's why I suggested getting other people to vet it first. Get consensus.
    Way too many half baked badly thought out petitions like Whedbee's frequent misfires.
  2. K4KYV

    K4KYV Premium Subscriber Volunteer Moderator QRZ Page

    Exactly. So how did the AM prohibition under the new 10m Novice voice privileges make that any more difficult, since those radios and most other amateur gear used on 11m were primarily intended for SSB in the first place? Rigs already ubiquitously in the hands of CB/freebanders such as the FT-101 series made it just as easy for CBer-Novices to substitute a couple of crystals in their existing transceivers and re-congregate on 10m using SSB, as it would have been to hack an AM-only synthesised CB transceiver or swap transmit and receive crystals in an old 23-channel xtal rig to use it on 10m AM.

    But that's a moot point in any case, since it happened over 30 years ago and now the 11m CB band is like a ghost town, with only a few hard-core hobbyists and occasional truckers still left on an otherwise dead band. What is the intended purpose of prohibiting Techs-on-HF from using AM if this petition is indeed incorporated into the rules? The text of the Petition is silent on this issue, other than sub-section (16) in the proposed revision, as seen on p. 30.

    Ain't that the truth!
    Last edited: Mar 17, 2019
    AB2RA likes this.
  3. WA3VJB

    WA3VJB Ham Member QRZ Page

    I posted this to the AM Facebook page as well.

    ARRL people will see my comments soon enough so I don't mind previewing them here -- 1. No data to support their claim that growth would follow degraded licensing 2. Do we have actual victims? 3. linkage with disputed automated messaging on HF("Winlink") 4. Lack of majority support (League = less than 25% of licensees) 5. history of misguided proposals from this group.
    AB2RA likes this.
  4. W5LZ

    W5LZ Ham Member QRZ Page

    This appears to be a "discussion" to prove somebody wants to keep their job so comes up with more nonsense. I have to think that AM would only be used by a Novice (or anyone else) because that's all their transmitter would do. There is no particular benefit to the AM mode, and it does have some disadvantages...
  5. AA7EJ

    AA7EJ Ham Member QRZ Page

    Thanks for actually replying to my question /post objectively.
    It is refreshing.

    I cannot talk legalese , just broken English and hold naive opinion that US constitution allows me to petition the government without specifying that it has to be "group" petition.
    Personally and judging from other responses to my post - it would be futile to have to explain my position TWICE - to the group and then to the government.

    73 Shirley

    ... returning the frequency / discussion to normal usage....
  6. AB2RA

    AB2RA Ham Member QRZ Page

    Baloney. The point of amateur service is to allow technical experimentation. There are AM windows, one of which is at 29 MHz.
    People can build a simple voice transmitter and learn important techniques which lead to more experimentation.
    If you want to find technical discussions, go to the AM windows.
    If that's all their ham fest used transmitter will do, they deserve the chance to get on the air without spending hundreds of dollars, which is a barrier to HF participation.
    K4KYV likes this.
  7. AB2RA

    AB2RA Ham Member QRZ Page

    Glad I could help. Hams should try to be hospitable to newcomers. I just did what I was supposed to.
    I hope it helped.
    Again, it does not have to be a "group" filing from a business.
    YOU can do it. But I recommend you have it proof read by people who can advise you on the technical aspects of your idea.

    Good luck with it.
    73 Janis
  8. K4KYV

    K4KYV Premium Subscriber Volunteer Moderator QRZ Page

    Exactly. The natural progression of understanding radiocommunications technology would be: (1) to start out with CW, then (2) once comfortable with that technology, add a simple modulator to advance to AM. Once the fundamental mechanics of modulation are understood, (3) proceed to SSB. Finally, (4) delve into digital/data. The "data" connection with ham radio should be more profound than simply to boot up a computer, open a couple of programs, connect to the internet, and begin communicating with other computers on line. Allowing newcomers to start out with SSB privileges but then requiring an upgrade to operate AM, is ass-backwards.

    I wouldn't be opposed to adding limited data privileges, excluding automatic operation, to the existing CW privileges now enjoyed by Technicians. Those 80/40/15m privileges make to-day's de facto Novice bands, where a Novice or Tech licensee can communicate great distances on CW and develop code skills in the process. However, with the elimination of the code tests, new hams undeniably have a lot less incentive to go through the sometimes arduous process of learning to copy by ear since this is no longer a requirement for getting on the air, therefore the existing Novice/Tech HF CW privileges are underutilised. Adding limited data privileges might encourage a few of those Technicians to go beyond VHF-FM repeaters to try HF even if they have no interest in CW.

    I see no compelling reason to further expand voice privileges to HF, except for lifting the prohibition against AM in the 28.3-28.5 mc/s segment. Voice privileges now give Techs a reason to upgrade to General or higher, since this is required for operating phone on HF at all (except for 10m). If Techs are given the proposed voice privileges without exerting any further effort, many will be perfectly satisfied to stagnate for years with a plug 'n play transceiver on SSB in their new voice segments, with no incentive to advance beyond that. The General class written exam isn't that much more difficult to pass than was the Technician test; if those hams didn't already have enough drive to upgrade for HF voice privileges, HF phone probably wasn't very attractive or important to them in the first place. Nevertheless, many would happily use any HF voice privileges handed to them on a silver platter with no further effort required. I suspect this would noticeably degrade the overall quality of operators in the new segments. Maybe not be so much an issue for 75m, since the phone band is so wide that we can probably tolerate a 3.9-4.0 mc/s ghetto, but this would seriously degrade 40m, particularly for AM operation, since we have so little space for phone in that band, and Technicians' proposed new SSB privileges would cover our long-standing prime AM operating frequencies.
    AB2RA likes this.
  9. AB2RA

    AB2RA Ham Member QRZ Page

    What he said.
    I agree, the wide band ACDS email operations should not be included in any Tech HF DATA allocation.
    Especially becoming the control operator of such a system, when they have not been tested on even the user level knowledge.
    This is not an irrational Sailor Bogeyman. It is the whole reason for ARRL's starting this.
    I have also adopted your well thought out 10M position.
    I plan to file more in addition to the petition to dismiss, when the time is appropriate.
    For the present, the possibility of any or all of the open rule makings could be damaging, so its no to all.
    Here is my current laundry list.
    • REJECT RM-11828, RM-11708, RM-11759 and 16-239. (ARRL PETITION FCC ID 1022823795806.)
    • RM-11828 provides no proof it will increase participation in amateur radio or promote upgrades.
    • RM-11828 does not grant 10 meter privileges to Techs that they are qualified for: FM, AM, repeaters, and satellites.
      This should be changed to give parity with Tech's existing privileges, granting nearly 2 MHz more HF spectrum for Techs.
      It will provide the opportunity for Techs to experiment, advance their skills, and interact with higher class amateurs in a variety of modes, to be mentored.
      RM-11828 should be rejected, since it does not include this important benefit.
    • The current Technician beginner's license can be obtained after a one weekend course.
      The General exam is not a burdensome barrier to upgrading to HF privileges either.
      Study and take the test, as incentive licensing already provides.
    • RM-11828 grants Techs 55% of the total General HF VOICE allocations.
      This will reduce the incentive to upgrade.
    • RM-11828 grants Techs 50% of the 80 meter General VOICE allocation.
      This is too large. Old Novice CW segments were only 50 KHz.
      This will reduce the incentive to upgrade.
    • RM-11828 and RM-11759 seek to grant Technicians data privileges taken from the bottom 50 KHz of the current 80 M Extra Class phone band.
      This is contrary to the long standing FCC policy of incentive privileges.
      RM-11828 and RM-11759 should both be rejected.
    • RM-11828 includes 60% of the General VOICE allocation on 40 meters.
      At night, the upper 100 KHz of 40 meters has foreign broadcast interference.
      There should be NO 40 meter VOICE expansion for Techs.
      This will reduce the incentive to upgrade.
    • IARU region 1 & 3 only has 200 KHz for both DATA and VOICE, some of it secondary.
      RM-11828 grants substantial portions of the useable IARU Region 1 & 3 40 meter DATA AND VOICE allocation to Tech DATA.
      There should be NO 40 meter DATA privileges for Techs at all.
      This will also reduce the incentive to upgrade.
    • The Tech license does not cover General Question Pool G2E02(B), G2E03(D), G2E07(A), G2E09(C), G2E10(D), G2E12 (C), G8C06 (B), G8C07 (B), G8C01(B), G1E05(C), G1E11(C), G1E12(A), G1E13(D), which cover essential modern HF digital communications procedures.
      Existing HF DATA, FT8, and CW operations will be harmed.
      The General exam is not a burdensome barrier to upgrading to HF privileges either.
      Study and take the test, as incentive licensing already provides.
      I oppose granting any additional HF DATA privileges to existing or new Techs.
    • RM-11828 permits a Technician to be a control operator of a wide band automatic store and forward email repeater without any knowledge of its basic functions on a user level.
      Repeater operation on VHF and UHF uses local propagation.
      Consequences of incorrect operation on HF to FT8, CW and DATA are world wide.
      The General exam is not a burdensome barrier to upgrading to HF privileges either.
      Study and take the test, as incentive licensing already provides.
    • The FCC has not finished RM-11708 or Docket 16-239. The FCC should dismiss RM-11828 until it has finished work on Rm-11759, RM-11708 and 16-239.
      Existing FT8 and CW operations will be harmed.
    AC0OB likes this.
  10. AB2RA

    AB2RA Ham Member QRZ Page

    Thank you, you always well thought out comments in FCC filings.
    WA3VJB likes this.

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