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@aol.com
[mailto:w3kd@aol.com]
Sent:
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:
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
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