RM-11828 (HF Privileges for Technicians) Deadline for Filing Comments is Imminent

Discussion in 'Amplitude Modulation - AM Fans' started by K4KYV, Mar 21, 2019.

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  1. K4KYV

    K4KYV Subscriber QRZ Page

    On March 15, ARRL announced the FCC inviting comments on rulemaking petition RM-11828 (expand Technicians' HF privileges on 80, 40 and 15m), and that interested parties had 30 days to comment. No specific deadline date for filing comments is given in the ARRL bulletin, but it's important to know that the deadline for filing comments is March 30, not April 15.


    Even though the ARRL news bulletin is dated March 15, the FCC's Public Notice is dated Feb 28, 2019. The FCC Notice was already posted two weeks before the ARRL announcement.


    The 30-day countdown for the comment deadline begins on the FCC's official posting date of the Petition, not the date of the ARRL news bulletin.

    As of to-day, March 20, we have only nine more days before the deadline.
  2. WA3VJB

    WA3VJB Ham Member QRZ Page

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  3. K4KYV

    K4KYV Subscriber QRZ Page

    I haven't read that in full just yet, but skimming through it, it seems comprehensive and well written. IMO, the AM community needs to submit specific comments citing and emphasising the AM issue, along with your other concerns. Most of the other issues with this proposal are already repeatedly covered from multiple perspectives in the multitude of 600-plus comments submitted so far, but from the samples I have examined, I have seen little or no mention pro- or con of the AM prohibition.
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  4. K4VA

    K4VA XML Subscriber QRZ Page

    Wow! That is well-written and quite an interesting read! Thank you for posting the link.
    AC0OB likes this.
  5. WA3VJB

    WA3VJB Ham Member QRZ Page

    He spent considerable time on it, and from the depth of detail, has been at the issue for a while.
    I can't blame him for including the sidebar about who knew what at the FCC (Waterman's phone call) but to my eyes it was a little distracting from his central premise and logic behind his opposition.
    In other proceedings that I have reviewed over the years, filers will often put material into their documentation that does not seem on-point at first. Subsequent deliberations, including the Reply Comment period that will follow this proceeding, provide an opportunity both to elaborate and link the extraneous material, but also to use it as ammunition against Comments that were not anticipated at the time it was written.
    It's a good process, the FCC's Electronic Comment Filing System, and the permanence of the Public Record can, itself, be used in future proceedings.


    To Don's point about the subordinate issue of excluding AM from this proposed reapportionment of privileges, yes, I can see where those of us in the AM Community would do well to question why it is in there. The ARRL Petition fails to explain why AM is singled out, and we thus have an opportunity to showcase why such bias is bad against the mode and activity in our hobbyist environment.

    I will give it some thought over the weekend and come up with something, and hope others will too.
    Last edited: Mar 22, 2019
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  6. K4KYV

    K4KYV Subscriber QRZ Page

    A phone call to the ECFS Help Desk cleared up confusion regarding the deadline for comments. The employee explained that ECFS received the Petition from the Petitioner (ARRL), assigned and posted RM-number 11828 on the 28th of February, 2018. This is the date it was posted internally at the bureau. ECFS in turn released the Public Notice on the 13th of March, 2019. She stated that the deadline for filing comments falls 30 days after the release of the Public notice, which will fall on the 12th of April, 2019.
  7. NN4RH

    NN4RH Premium Subscriber QRZ Page

    February 28, 2018, is when the FCC received it.
  8. W2WDX

    W2WDX Subscriber QRZ Page

    Actually while well constructed and researched, I don't think it's well written and undermines its own intent. It has the stink of "conspiracy theory" all over it, and deviates from the core concerns of a governing body; that being regulatory oversight and rule making. All the talk about ARRL dysfunction and "family legal dynasties" and other such conspiratorial conjecture which a large part of the document encompasses, does not directly address the regulatory issues at hand. The simple "illegal use" issues are more important compared to why the ARRL submitted the proposal. The document undermines its intent by citing or trying to find evidence of conspiracy, instead of just simply dealing with the consequence of adoption of such a proposal. "Conspiracy theorists" are tedious to regulators and come off as goof balls with their own agenda, and just appear to be stacking the deck in favor of their position with bluster.

    The document goes so far as to actually being potentially libelous; publicly citing individuals and making claims of impropriety. Additionally, whether those claims are true or not is not the issue. These statements makes the document a potato to hot for the FCC to handle, or even to use as a basis for consideration of proposed rule making.
    Last edited: Mar 24, 2019
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  9. K4VA

    K4VA XML Subscriber QRZ Page

    I agree, "well-constructed" would have been a better choice of words than "well-written". Thanks
  10. AC0OB

    AC0OB Subscriber QRZ Page

    Whether it's potentially libelous or not is up to the attorneys and if one has documented proof, well...

    However, if there is some kind of influence peddling or lobbying going on behind the scenes that needs to brought forth, then so be it.

    I do think we need to express our concerns about AM being excepted as a mode of operation and am still questioning as to why that is the case.

    K4KYV likes this.

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