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@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@pobox.com To: arrl-odv@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.