November 2006 - arrl-odv - reflector.arrl.org

[arrl-odv:14847] Re: Petition to Reconsider?
by Sumner, Dave, K1ZZ 28 Nov '06

28 Nov '06

Bonnie's argument will be moot when the FCC issues its erratum. However, the only reason Pactor III can be used is that its technical characteristics are documented publicly. See http://www.arrl.org/FandES/field/regulations/techchar/ There it states that Pactor III is J2D. Dave -----Original Message----- From: Andy Oppel [mailto:andy_oppel@earthlink.net] Sent: Tuesday, November 28, 2006 12:50 AM To: arrl-odv Subject: [arrl-odv:14845] Re: Petition to Reconsider? We have a previous member, KQ6XA claiming that Pactor III is G1D / G1B / G1C and not J2D and therefore not affected by the rule change. Her arguments sound convincing and I just don't know enough to be able to see the error in them (assuming there is one). It's this soft of debate that underscores the folly of regulating by emission mode -- we waste time and energy arguing over what mode is being used than where wider signals should be placed in the band allocations. -- Andy Oppel, N6AJO At 09:11 AM 11/24/2006, Tom Frenaye wrote: >At 11:06 AM 11/24/2006, w3kd(a)aol.com wrote: > > Kay, good points, all. Sadly, however, there is only a very > limited time to file (or not file) a petition for reconsideration. > It would be due by the 15th of December. Since the timetable is > statutory, FCC can't waive it. So we must fish or cut bait by the > 15th of December; a short fuse indeed for membership input. > >Since I sent out the last summary of input on WT 04-140 a week or so >ago, another 250+ comments have come in to the >bandplanning(a)www.arrl.org e-mail address - and are all available >here -> http://www.arrl.org/members-only/mailresp.html > >I've attached an easier-to-use summary of those last 250+ comments >as a MS Word file. I'll also send summaries to the Directors who >previously wanted just to see input from their own Divisions. > >My comments on this last bunch: > >1) Of the 250+ comments, 90 are from the Northwestern >Division. The WWA Section Manager sent out a message to his SM >mailing list encouraging members to send input. Most other >Divisions had less than additional messages. > >2) The strongest input comes from wideband digital users (like Pactor III). > >3) There are much fewer comments from people who say they like the >changes - this last batch of input is pretty one-sided, saying that >the ARRL has to ask the FCC to reconsider some portions of >04-140. The comments were much more focused than the first group. > >4) At least ten people sent in copies of letters they have sent to >FCC Commissioners, to their Congressmen and their Senators. I'm not >sure that's a good thing, even if most letters were pretty factual >(and too technical). > >5) A large portion of the Winlink/Pactor III comments and >Congressional letters appear to have been generated by encouraging >it from the Winlink >folks(K4CJX). > >6) Our web article said that we'd take input until a week after WT >04-140 was published in the Federal Register - until Nov >22nd. There are still some comments coming in today though. > > >The newest group of e-mails doesn't change my mind - I do think we >need to file a Petition for Reconsideration. Even if the FCC comes >out with a statement about J2D, we should probably plan to include a >request to fix it in the petition. I still think we should ask for >SSB to go down only to 3700 (or 3650 as a fall back), and allow auto >control in a small segment to be consistent with the current >practice on other bands. There are dozens of messages with very >quotable input from hams involved in EmComm in state or local EOCs >that can be used to support the digital issues. > > -- Tom > > >===== >e-mail: k1ki(a)arrl.org ARRL New England Division >Director http://www.arrl.org/ >Tom Frenaye, K1KI, P O Box J, West Suffield CT 06093 Phone: 860-668-5444

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[arrl-odv:14846] Re: Petition For Reconsideration
by Henry R. Leggette 28 Nov '06

28 Nov '06

Thanks, Dave! Henry - WD4Q ----- Original Message ----- From: Sumner, Dave, K1ZZ To: arrl-odv Sent: Monday, November 27, 2006 2:46 PM Subject: [arrl-odv:14844] Re: Petition For Reconsideration Section 14.2 of the Director's Workbook (on line for ODV at http://www.arrl.org/members-only/ODV/workbook/) has what is still a pretty good, brief discussion of FCC administrative procedures including petitions for reconsideration and for stays of effective date. Dave -----Original Message----- From: w3kd(a)aol.com [mailto:w3kd@aol.com] Sent: Monday, November 27, 2006 1:37 PM To: arrl-odv Subject: [arrl-odv:14843] Re: Petition For Reconsideration No, Henry, if we file a Petition for Reconsideration, NONE of the rules would be stayed; all would go into effect on December 15. The filing of a Petition for Reconsideration does NOT stay the new rules. They would all go into effect while the FCC is pondering our filing, if we file one. In order to obtain a stay of the effective date of the rules, we would have to file a request for a stay. That is very hard to justify. We would have to make a showing that Amateurs would be irreparably harmed, and that there is a high likelihood that we would prevail on the merits of the argument on reconsideration: a tough showing to make in advance. So, nothing would be held up until the reconsideration has been settled. AMSAT just asked the same question, incidentally. They are very much concerned about the orbital debris rules and the pre-space notification obligations. They are filing a petition for reconsideration only on that issue. 73, Chris W3KD -----Original Message----- From: wd4q(a)bellsouth.net To: arrl-odv(a)reflector.arrl.org Sent: Mon, 27 Nov 2006 12:44 PM Subject: [arrl-odv:14842] Re: Petition For Reconsideration Chris, If we file a petition for reconsideration for only one or two portions, such as 80 meters, would the complete FCC regulations go into effect on December 15, 2006? Will everything be held up until after the reconsideration has been settle? Henry

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[arrl-odv:14845] Re: Petition to Reconsider?
by Andy Oppel 28 Nov '06

28 Nov '06

We have a previous member, KQ6XA claiming that Pactor III is G1D / G1B / G1C and not J2D and therefore not affected by the rule change. Her arguments sound convincing and I just don't know enough to be able to see the error in them (assuming there is one). It's this soft of debate that underscores the folly of regulating by emission mode -- we waste time and energy arguing over what mode is being used than where wider signals should be placed in the band allocations. -- Andy Oppel, N6AJO At 09:11 AM 11/24/2006, Tom Frenaye wrote: >At 11:06 AM 11/24/2006, w3kd(a)aol.com wrote: > > Kay, good points, all. Sadly, however, there is only a very > limited time to file (or not file) a petition for reconsideration. > It would be due by the 15th of December. Since the timetable is > statutory, FCC can't waive it. So we must fish or cut bait by the > 15th of December; a short fuse indeed for membership input. > >Since I sent out the last summary of input on WT 04-140 a week or so >ago, another 250+ comments have come in to the >bandplanning(a)www.arrl.org e-mail address - and are all available >here -> http://www.arrl.org/members-only/mailresp.html > >I've attached an easier-to-use summary of those last 250+ comments >as a MS Word file. I'll also send summaries to the Directors who >previously wanted just to see input from their own Divisions. > >My comments on this last bunch: > >1) Of the 250+ comments, 90 are from the Northwestern >Division. The WWA Section Manager sent out a message to his SM >mailing list encouraging members to send input. Most other >Divisions had less than additional messages. > >2) The strongest input comes from wideband digital users (like Pactor III). > >3) There are much fewer comments from people who say they like the >changes - this last batch of input is pretty one-sided, saying that >the ARRL has to ask the FCC to reconsider some portions of >04-140. The comments were much more focused than the first group. > >4) At least ten people sent in copies of letters they have sent to >FCC Commissioners, to their Congressmen and their Senators. I'm not >sure that's a good thing, even if most letters were pretty factual >(and too technical). > >5) A large portion of the Winlink/Pactor III comments and >Congressional letters appear to have been generated by encouraging >it from the Winlink >folks(K4CJX). > >6) Our web article said that we'd take input until a week after WT >04-140 was published in the Federal Register - until Nov >22nd. There are still some comments coming in today though. > > >The newest group of e-mails doesn't change my mind - I do think we >need to file a Petition for Reconsideration. Even if the FCC comes >out with a statement about J2D, we should probably plan to include a >request to fix it in the petition. I still think we should ask for >SSB to go down only to 3700 (or 3650 as a fall back), and allow auto >control in a small segment to be consistent with the current >practice on other bands. There are dozens of messages with very >quotable input from hams involved in EmComm in state or local EOCs >that can be used to support the digital issues. > > -- Tom > > >===== >e-mail: k1ki(a)arrl.org ARRL New England Division >Director http://www.arrl.org/ >Tom Frenaye, K1KI, P O Box J, West Suffield CT 06093 Phone: 860-668-5444

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[arrl-odv:14844] Re: Petition For Reconsideration
by Sumner, Dave, K1ZZ 27 Nov '06

27 Nov '06

Section 14.2 of the Director's Workbook (on line for ODV at http://www.arrl.org/members-only/ODV/workbook/) has what is still a pretty good, brief discussion of FCC administrative procedures including petitions for reconsideration and for stays of effective date. Dave -----Original Message----- From: w3kd(a)aol.com [mailto:w3kd@aol.com] Sent: Monday, November 27, 2006 1:37 PM To: arrl-odv Subject: [arrl-odv:14843] Re: Petition For Reconsideration No, Henry, if we file a Petition for Reconsideration, NONE of the rules would be stayed; all would go into effect on December 15. The filing of a Petition for Reconsideration does NOT stay the new rules. They would all go into effect while the FCC is pondering our filing, if we file one. In order to obtain a stay of the effective date of the rules, we would have to file a request for a stay. That is very hard to justify. We would have to make a showing that Amateurs would be irreparably harmed, and that there is a high likelihood that we would prevail on the merits of the argument on reconsideration: a tough showing to make in advance. So, nothing would be held up until the reconsideration has been settled. AMSAT just asked the same question, incidentally. They are very much concerned about the orbital debris rules and the pre-space notification obligations. They are filing a petition for reconsideration only on that issue. 73, Chris W3KD -----Original Message----- From: wd4q(a)bellsouth.net To: arrl-odv(a)reflector.arrl.org Sent: Mon, 27 Nov 2006 12:44 PM Subject: [arrl-odv:14842] Re: Petition For Reconsideration Chris, If we file a petition for reconsideration for only one or two portions, such as 80 meters, would the complete FCC regulations go into effect on December 15, 2006? Will everything be held up until after the reconsideration has been settle? Henry

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[arrl-odv:14843] Re: Petition For Reconsideration
by w3kd＠aol.com 27 Nov '06

27 Nov '06

No, Henry, if we file a Petition for Reconsideration, NONE of the rules would be stayed; all would go into effect on December 15. The filing of a Petition for Reconsideration does NOT stay the new rules. They would all go into effect while the FCC is pondering our filing, if we file one. In order to obtain a stay of the effective date of the rules, we would have to file a request for a stay. That is very hard to justify. We would have to make a showing that Amateurs would be irreparably harmed, and that there is a high likelihood that we would prevail on the merits of the argument on reconsideration: a tough showing to make in advance. So, nothing would be held up until the reconsideration has been settled. AMSAT just asked the same question, incidentally. They are very much concerned about the orbital debris rules and the pre-space notification obligations. They are filing a petition for reconsideration only on that issue. 73, Chris W3KD -----Original Message----- From: wd4q(a)bellsouth.net To: arrl-odv(a)reflector.arrl.org Sent: Mon, 27 Nov 2006 12:44 PM Subject: [arrl-odv:14842] Re: Petition For Reconsideration Chris, If we file a petition for reconsideration for only one or two portions, such as 80 meters, would the complete FCC regulations go into effect on December 15, 2006? Will everything be held up until after the reconsideration has been settle? Henry ----- Original Message ----- From: John Bellows To: arrl-odv Sent: Monday, November 27, 2006 9:40 AM Subject: RE: [arrl-odv:14839] Re: Petition For Reconsideration If I recall correctly, as recently as November of 2004 FCC supported a reallocation of the amateur service spectrum to allow the amateur service community flexibility among operating interests as new operating interest and technologies emerge. (Order DA-04 3661) The FCC comments were consistent with its actions in other services to encourage development of new digital technologies. It is hard to see how FCC’s decision to expand the 75 meter phone band to 3600 kHz and its lack of thought as to the implications to the digital modes in 04-140 is consistent with 04-3661. Cross’s comment about the great majority of negative comments on the Regulation by Bandwidth Petition suggests more trouble ahead. I’m beginning to question whether ARRL should pay any attention to pronouncements and “suggestions” of FCC in its Orders. All too often it seems FCC’s memory of its own guidance has the life expectancy of a fruit fly. My initial reaction was not to support a Petition for Reconsideration. It seemed to me the negative portions of the Order were akin to a wound that is unpleasant but will heal in time. Filing a Petition for Reconsideration would be like picking at the wound; all it would do is cause it to take longer to heal. I’m not as sure now. After a bit more thought it seems that if we believe we were right in our Petition we ought to seek Reconsideration, particularly regarding the 75 meter phone band to 3600 kHz and the implications to the digital modes in 04-14. That portion of the Order is simply at odds with the FCC’s prior statements regarding fostering new operating modes and encouraging the development of new digital techniques. With all due respect to the devotee’s of the 75 meter phone band, there are few places in the Amateur spectrum less likely to be an incubator of new modes or new digital techniques. We thoroughly gathered comment from the community prior to filing the Petition and came to a collective judgment. If our only function is to stick a finger in the air to see which way the wind is blowing the only qualification for Board membership ought to be the ability to count. If we thought 3725 kHz should be the bottom of the 75 meter phone band in our Petition we ought to stick by that decision absent compelling information to the contrary. No matter what we decide we will irritate a portion of members and the Amateur community. If that is inevitable we might as well stick with the carefully thought out position in our original Petition. Time is very short so delaying a decision is effectively a decision not to petition for reconsideration. 73, Jay, KØQB -----Original Message----- From: w3kd(a)aol.com [mailto:w3kd@aol.com] Sent: Monday, November 27, 2006 7:59 AM To: arrl-odv Subject: [arrl-odv:14839] Re: Petition For Reconsideration Dick, I should note for the Board's information, in light of your thoughtful analysis below, that though the Regulation by Bandwidth petition of ARRL's was strongly supported by Cross early on, long before we filed it, there are dark clouds on the horizon with respect to it. Cross did note to me on the phone a few days ago, when I was discussing with him the fixing of the J2D issue in 04-140, which I mentioned would be satisfactorily resolved by the Regulation by Bandwidth rule changes, Cross noted that the great majority of the comments on that petition were negative (which is true, of course). I don't know what that means, but it may mean that he is going to have a very tough time going ahead with it as the result. He said that most of the opposing comments argued that there was no need for the shift to regulation by bandwidth. I didn't debate that with him at the time, but it may not be safe to rely on that petition in lieu of fixing the 04-140 problems. It also points up the need for some lobbying at FCC on Regulation by Bandwidth. 73, Chris W3KD -----Original Message----- From: dick(a)pobox.com To: arrl-odv(a)reflector.arrl.org Sent: Fri, 24 Nov 2006 4:53 PM Subject: [arrl-odv:14834] Re: Petition For Reconsideration 24 NOV 2006 - 1550 CST Political Considerations About A Petition For Reconsideration What little comment I have directly received, 2 emails and 2 in-person at Fort Wayne last weekend, and the comments that Tom Frenaye has sent to me (not including the second batch), I question what ARRL will gain vs what it will lose it we file a petition for reconsideration. 1. In the Central Division, it appears most people understand the FCC has screwed up, not the ARRL. What anger and disgust I have seen/heard has been directed at that august regulatory body. 2. Those hams who have done their homework, realize this is an FCC-created problem and have little hope that big changes can be made before 15 DEC. Those who appear to just now be realizing what is changing on 80 Meters are the most unhappy, and are the ones I have little sympathy for... most of them have been hams for quite a few more than the last five years and they have done little, or nothing to make their opinions and ideas heard until now. 3. Because of the limited time for filing a petition to reconsider, we do not have enough time to gather a decent cross-section of opinions and ideas from the amateur radio community. We really need an organized effort along the lines of what was done for Novice sub-band re-farming five plus years ago. 4. If we file a petition for reconsideration, we will acquire a great deal of anger from various groups: the CW users who are being squeezed into smaller protected sub-bands, the Pactor III (Winlink users), and the phone operators who will view such a petition as a double-cross similar to the incentive licensing debacle many years ago. In the blame game, we will be letting the FCC off the hook and risking our nascent improvement (reduction of losses) in ARRL membership. I have mixed feelings about the present configuration of the about-to-be- activated HF sub-band changes. But I think a far better approach than a petition to reconsider is to get our regulation by bandwidth proposal to the R&O stage. Assuming the mechanism for modifying the sub-band allocations by bandwidth is turned over to the amateur radio community (unknown right now), the FCC's screw-ups in the WT O4-140 R&O could hopefully be resolved by the amateur radio community without having to wait another five or more years. - Dick, W9GIG Check out the new AOL. Most comprehensive set of free safety and security tools, free access to millions of high-quality videos from across the web, free AOL Mail and more. ________________________________________________________________________ Check out the new AOL. Most comprehensive set of free safety and security tools, free access to millions of high-quality videos from across the web, free AOL Mail and more.

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[arrl-odv:14842] Re: Petition For Reconsideration
by Henry R. Leggette 27 Nov '06

27 Nov '06

Chris, If we file a petition for reconsideration for only one or two portions, such as 80 meters, would the complete FCC regulations go into effect on December 15, 2006? Will everything be held up until after the reconsideration has been settle? Henry ----- Original Message ----- From: John Bellows To: arrl-odv Sent: Monday, November 27, 2006 9:40 AM Subject: RE: [arrl-odv:14839] Re: Petition For Reconsideration If I recall correctly, as recently as November of 2004 FCC supported a reallocation of the amateur service spectrum to allow the amateur service community flexibility among operating interests as new operating interest and technologies emerge. (Order DA-04 3661) The FCC comments were consistent with its actions in other services to encourage development of new digital technologies. It is hard to see how FCC's decision to expand the 75 meter phone band to 3600 kHz and its lack of thought as to the implications to the digital modes in 04-140 is consistent with 04-3661. Cross's comment about the great majority of negative comments on the Regulation by Bandwidth Petition suggests more trouble ahead. I'm beginning to question whether ARRL should pay any attention to pronouncements and "suggestions" of FCC in its Orders. All too often it seems FCC's memory of its own guidance has the life expectancy of a fruit fly. My initial reaction was not to support a Petition for Reconsideration. It seemed to me the negative portions of the Order were akin to a wound that is unpleasant but will heal in time. Filing a Petition for Reconsideration would be like picking at the wound; all it would do is cause it to take longer to heal. I'm not as sure now. After a bit more thought it seems that if we believe we were right in our Petition we ought to seek Reconsideration, particularly regarding the 75 meter phone band to 3600 kHz and the implications to the digital modes in 04-14. That portion of the Order is simply at odds with the FCC's prior statements regarding fostering new operating modes and encouraging the development of new digital techniques. With all due respect to the devotee's of the 75 meter phone band, there are few places in the Amateur spectrum less likely to be an incubator of new modes or new digital techniques. We thoroughly gathered comment from the community prior to filing the Petition and came to a collective judgment. If our only function is to stick a finger in the air to see which way the wind is blowing the only qualification for Board membership ought to be the ability to count. If we thought 3725 kHz should be the bottom of the 75 meter phone band in our Petition we ought to stick by that decision absent compelling information to the contrary. No matter what we decide we will irritate a portion of members and the Amateur community. If that is inevitable we might as well stick with the carefully thought out position in our original Petition. Time is very short so delaying a decision is effectively a decision not to petition for reconsideration. 73, Jay, KØQB -----Original Message----- From: w3kd(a)aol.com [mailto:w3kd@aol.com] Sent: Monday, November 27, 2006 7:59 AM To: arrl-odv Subject: [arrl-odv:14839] Re: Petition For Reconsideration Dick, I should note for the Board's information, in light of your thoughtful analysis below, that though the Regulation by Bandwidth petition of ARRL's was strongly supported by Cross early on, long before we filed it, there are dark clouds on the horizon with respect to it. Cross did note to me on the phone a few days ago, when I was discussing with him the fixing of the J2D issue in 04-140, which I mentioned would be satisfactorily resolved by the Regulation by Bandwidth rule changes, Cross noted that the great majority of the comments on that petition were negative (which is true, of course). I don't know what that means, but it may mean that he is going to have a very tough time going ahead with it as the result. He said that most of the opposing comments argued that there was no need for the shift to regulation by bandwidth. I didn't debate that with him at the time, but it may not be safe to rely on that petition in lieu of fixing the 04-140 problems. It also points up the need for some lobbying at FCC on Regulation by Bandwidth. 73, Chris W3KD -----Original Message----- From: dick(a)pobox.com To: arrl-odv(a)reflector.arrl.org Sent: Fri, 24 Nov 2006 4:53 PM Subject: [arrl-odv:14834] Re: Petition For Reconsideration 24 NOV 2006 - 1550 CST Political Considerations About A Petition For Reconsideration What little comment I have directly received, 2 emails and 2 in-person at Fort Wayne last weekend, and the comments that Tom Frenaye has sent to me (not including the second batch), I question what ARRL will gain vs what it will lose it we file a petition for reconsideration. 1. In the Central Division, it appears most people understand the FCC has screwed up, not the ARRL. What anger and disgust I have seen/heard has been directed at that august regulatory body. 2. Those hams who have done their homework, realize this is an FCC-created problem and have little hope that big changes can be made before 15 DEC. Those who appear to just now be realizing what is changing on 80 Meters are the most unhappy, and are the ones I have little sympathy for... most of them have been hams for quite a few more than the last five years and they have done little, or nothing to make their opinions and ideas heard until now. 3. Because of the limited time for filing a petition to reconsider, we do not have enough time to gather a decent cross-section of opinions and ideas from the amateur radio community. We really need an organized effort along the lines of what was done for Novice sub-band re-farming five plus years ago. 4. If we file a petition for reconsideration, we will acquire a great deal of anger from various groups: the CW users who are being squeezed into smaller protected sub-bands, the Pactor III (Winlink users), and the phone operators who will view such a petition as a double-cross similar to the incentive licensing debacle many years ago. In the blame game, we will be letting the FCC off the hook and risking our nascent improvement (reduction of losses) in ARRL membership. I have mixed feelings about the present configuration of the about-to-be- activated HF sub-band changes. But I think a far better approach than a petition to reconsider is to get our regulation by bandwidth proposal to the R&O stage. Assuming the mechanism for modifying the sub-band allocations by bandwidth is turned over to the amateur radio community (unknown right now), the FCC's screw-ups in the WT O4-140 R&O could hopefully be resolved by the amateur radio community without having to wait another five or more years. - Dick, W9GIG ------------------------------------------------------------------------------ Check out the new AOL. Most comprehensive set of free safety and security tools, free access to millions of high-quality videos from across the web, free AOL Mail and more.

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RE: [arrl-odv:14839] Re: Petition For Reconsideration
by John Bellows 27 Nov '06

27 Nov '06

If I recall correctly, as recently as November of 2004 FCC supported a reallocation of the amateur service spectrum to allow the amateur service community flexibility among operating interests as new operating interest and technologies emerge. (Order DA-04 3661) The FCC comments were consistent with its actions in other services to encourage development of new digital technologies. It is hard to see how FCCs decision to expand the 75 meter phone band to 3600 kHz and its lack of thought as to the implications to the digital modes in 04-140 is consistent with 04-3661. Crosss comment about the great majority of negative comments on the Regulation by Bandwidth Petition suggests more trouble ahead. Im beginning to question whether ARRL should pay any attention to pronouncements and suggestions of FCC in its Orders. All too often it seems FCCs memory of its own guidance has the life expectancy of a fruit fly. My initial reaction was not to support a Petition for Reconsideration. It seemed to me the negative portions of the Order were akin to a wound that is unpleasant but will heal in time. Filing a Petition for Reconsideration would be like picking at the wound; all it would do is cause it to take longer to heal. Im not as sure now. After a bit more thought it seems that if we believe we were right in our Petition we ought to seek Reconsideration, particularly regarding the 75 meter phone band to 3600 kHz and the implications to the digital modes in 04-14. That portion of the Order is simply at odds with the FCCs prior statements regarding fostering new operating modes and encouraging the development of new digital techniques. With all due respect to the devotees of the 75 meter phone band, there are few places in the Amateur spectrum less likely to be an incubator of new modes or new digital techniques. We thoroughly gathered comment from the community prior to filing the Petition and came to a collective judgment. If our only function is to stick a finger in the air to see which way the wind is blowing the only qualification for Board membership ought to be the ability to count. If we thought 3725 kHz should be the bottom of the 75 meter phone band in our Petition we ought to stick by that decision absent compelling information to the contrary. No matter what we decide we will irritate a portion of members and the Amateur community. If that is inevitable we might as well stick with the carefully thought out position in our original Petition. Time is very short so delaying a decision is effectively a decision not to petition for reconsideration. 73, Jay, KØQB -----Original Message----- From: w3kd(a)aol.com [mailto:w3kd@aol.com] Sent: Monday, November 27, 2006 7:59 AM To: arrl-odv Subject: [arrl-odv:14839] Re: Petition For Reconsideration Dick, I should note for the Board's information, in light of your thoughtful analysis below, that though the Regulation by Bandwidth petition of ARRL's was strongly supported by Cross early on, long before we filed it, there are dark clouds on the horizon with respect to it. Cross did note to me on the phone a few days ago, when I was discussing with him the fixing of the J2D issue in 04-140, which I mentioned would be satisfactorily resolved by the Regulation by Bandwidth rule changes, Cross noted that the great majority of the comments on that petition were negative (which is true, of course). I don't know what that means, but it may mean that he is going to have a very tough time going ahead with it as the result. He said that most of the opposing comments argued that there was no need for the shift to regulation by bandwidth. I didn't debate that with him at the time, but it may not be safe to rely on that petition in lieu of fixing the 04-140 problems. It also points up the need for some lobbying at FCC on Regulation by Bandwidth. 73, Chris W3KD -----Original Message----- From: dick(a)pobox.com To: arrl-odv(a)reflector.arrl.org Sent: Fri, 24 Nov 2006 4:53 PM Subject: [arrl-odv:14834] Re: Petition For Reconsideration 24 NOV 2006 - 1550 CST Political Considerations About A Petition For Reconsideration What little comment I have directly received, 2 emails and 2 in-person at Fort Wayne last weekend, and the comments that Tom Frenaye has sent to me (not including the second batch), I question what ARRL will gain vs what it will lose it we file a petition for reconsideration. 1. In the Central Division, it appears most people understand the FCC has screwed up, not the ARRL. What anger and disgust I have seen/heard has been directed at that august regulatory body. 2. Those hams who have done their homework, realize this is an FCC-created problem and have little hope that big changes can be made before 15 DEC. Those who appear to just now be realizing what is changing on 80 Meters are the most unhappy, and are the ones I have little sympathy for... most of them have been hams for quite a few more than the last five years and they have done little, or nothing to make their opinions and ideas heard until now. 3. Because of the limited time for filing a petition to reconsider, we do not have enough time to gather a decent cross-section of opinions and ideas from the amateur radio community. We really need an organized effort along the lines of what was done for Novice sub-band re-farming five plus years ago. 4. If we file a petition for reconsideration, we will acquire a great deal of anger from various groups: the CW users who are being squeezed into smaller protected sub-bands, the Pactor III (Winlink users), and the phone operators who will view such a petition as a double-cross similar to the incentive licensing debacle many years ago. In the blame game, we will be letting the FCC off the hook and risking our nascent improvement (reduction of losses) in ARRL membership. I have mixed feelings about the present configuration of the about-to-be- activated HF sub-band changes. But I think a far better approach than a petition to reconsider is to get our regulation by bandwidth proposal to the R&O stage. Assuming the mechanism for modifying the sub-band allocations by bandwidth is turned over to the amateur radio community (unknown right now), the FCC's screw-ups in the WT O4-140 R&O could hopefully be resolved by the amateur radio community without having to wait another five or more years. - Dick, W9GIG _____ <http://pr.atwola.com/promoclk/1615326657x4311227241x4298082137/aol?redi r=http%3A%2F%2Fwww%2Eaol%2Ecom%2Fnewaol> Check out the new AOL. Most comprehensive set of free safety and security tools, free access to millions of high-quality videos from across the web, free AOL Mail and more.

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[arrl-odv:14840] ARRL v FCC and USA (BPL Appeal)
by w3kd＠aol.com 27 Nov '06

27 Nov '06

Greetings. Just a minor update. The City of Manassas has late-filed a Motion for Leave to Intervene and for Enlargement of Time in the BPL Court Appeal (copy attached). The City argues that it should be allowed to intervene late. Such petitions were due November 9, and Manassas filed on the 21st. As you can see, they have no reason for the late filing, but argued that no party would be harmed by the delay, which is likely to be persuasive to the Court Clerk. We will see. That can work to our advantage, since Manassas is a good example of bad BPL and FCC inaction in addressing interference issues. Chris ________________________________________________________________________ Check out the new AOL. Most comprehensive set of free safety and security tools, free access to millions of high-quality videos from across the web, free AOL Mail and more.

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[arrl-odv:14839] Re: Petition For Reconsideration
by w3kd＠aol.com 27 Nov '06

27 Nov '06

Dick, I should note for the Board's information, in light of your thoughtful analysis below, that though the Regulation by Bandwidth petition of ARRL's was strongly supported by Cross early on, long before we filed it, there are dark clouds on the horizon with respect to it. Cross did note to me on the phone a few days ago, when I was discussing with him the fixing of the J2D issue in 04-140, which I mentioned would be satisfactorily resolved by the Regulation by Bandwidth rule changes, Cross noted that the great majority of the comments on that petition were negative (which is true, of course). I don't know what that means, but it may mean that he is going to have a very tough time going ahead with it as the result. He said that most of the opposing comments argued that there was no need for the shift to regulation by bandwidth. I didn't debate that with him at the time, but it may not be safe to rely on that petition in lieu of fixing the 04-140 problems. It also points up the need for some lobbying at FCC on Regulation by Bandwidth. 73, Chris W3KD -----Original Message----- From: dick(a)pobox.com To: arrl-odv(a)reflector.arrl.org Sent: Fri, 24 Nov 2006 4:53 PM Subject: [arrl-odv:14834] Re: Petition For Reconsideration 24 NOV 2006 - 1550 CST Political Considerations About A Petition For Reconsideration What little comment I have directly received, 2 emails and 2 in-person at Fort Wayne last weekend, and the comments that Tom Frenaye has sent to me (not including the second batch), I question what ARRL will gain vs what it will lose it we file a petition for reconsideration. 1. In the Central Division, it appears most people understand the FCC has screwed up, not the ARRL. What anger and disgust I have seen/heard has been directed at that august regulatory body. 2. Those hams who have done their homework, realize this is an FCC-created problem and have little hope that big changes can be made before 15 DEC. Those who appear to just now be realizing what is changing on 80 Meters are the most unhappy, and are the ones I have little sympathy for... most of them have been hams for quite a few more than the last five years and they have done little, or nothing to make their opinions and ideas heard until now. 3. Because of the limited time for filing a petition to reconsider, we do not have enough time to gather a decent cross-section of opinions and ideas from the amateur radio community. We really need an organized effort along the lines of what was done for Novice sub-band re-farming five plus years ago. 4. If we file a petition for reconsideration, we will acquire a great deal of anger from various groups: the CW users who are being squeezed into smaller protected sub-bands, the Pactor III (Winlink users), and the phone operators who will view such a petition as a double-cross similar to the incentive licensing debacle many years ago. In the blame game, we will be letting the FCC off the hook and risking our nascent improvement (reduction of losses) in ARRL membership. I have mixed feelings about the present configuration of the about-to-be- activated HF sub-band changes. But I think a far better approach than a petition to reconsider is to get our regulation by bandwidth proposal to the R&O stage. Assuming the mechanism for modifying the sub-band allocations by bandwidth is turned over to the amateur radio community (unknown right now), the FCC's screw-ups in the WT O4-140 R&O could hopefully be resolved by the amateur radio community without having to wait another five or more years. - Dick, W9GIG ________________________________________________________________________ Check out the new AOL. Most comprehensive set of free safety and security tools, free access to millions of high-quality videos from across the web, free AOL Mail and more.

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[arrl-odv:14838] New on-line program
by William Sawders 26 Nov '06

26 Nov '06

I felt that EchoLink was a good program for hams who couldn't get on the air because they live in areas with CCR's, etc. This new program just blows me away. It's not "ham radio", but check this out. Unbelievable. Download for a 60 free day test. Go to "register". It's kind of scary. Bill Sawders, K7ZM ARRL Vice Director Northwestern Division

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