I know we have been through this.  And I thought we agreed with such a plan to have legal restrictions by sub band definitions by motion in 2019. 

I just got off the phone with the filer, AB2RA, a constituent, who asked me to call her.  Polite discussion-she seemed well informed.  Long-time ARRL member.  She claims she was with the group ARRL met with in DC a few years ago.  This is not Ted Rappaport and his followers. Ted, who I knew personally from Radio Club of America meetings and seminars seems to be out of action somewhere these days anyway. He called me to rant a time or two a few years ago that no wideband and/or automatic digital should be allowed anywhere outside the phone bands. Our position was a pretty reasonable middle ground.

This group of participants claim they agree with our band plan committee conclusions and the 2019 board motion on the subject and wanted to know why we did not implement it.  More importantly, Waterman and Lor Kutchens does now as well, as the caller told me as she spoke with Waterman. Could this be true or are they fabricating facts?  It appears our board motion of July 2019, a great solution, agrees with their position, so I am now pressed to understand the different in the older arguments.  If what they now claim today is true, then this may be something worth discussing. I recall how contentious this was and the meetings held back then resulted in an impasse.

  Eliminating the symbol rate without limitations and without restriction of greater than 500 Hz occupied bandwidth signals to a required sub-band is a recipe for trouble as few hams wanted that, members or not.  We have always recognized this. But a Gentlemen’s (and Ladies’) agreement really do not help in today’s amateur environment.  A single controlled or automatic winlink or other mode 2.8 KHz station with lots of traffic setting up shop anywhere and outside agreed limits will ruin operations for many weak signal hams-digital modes or CW.

This may end up like repeaters on a limited space ham band where the channels are full like we have on 2 meters in the Philly tristate area and I-95 corridor in 4 states.  Lots of conflict with cochannel repeaters ignoring coordination and also gentleman’s band planning to keep simplex channels clear and not use VHF SSB portions with FM because they can have no other channel to use.  Ask Riley Hollingsworth about that boiling issue. He spent 5 hours visiting me in my office last month discussing some such serious enforcement issues ending up on his desk (and fCC) and for which parties (clubs) had contacted me in frustration as well.

 Back to HF,  removal of restrictions then waiting 5 to 10 years to regulate by bandwidth after allowing 2.8 KHz bandwidth anywhere for additional rulemaking requests to go into effect will create major headaches.  No restriction proponents in the US will never go back to a wide bandwidth and auto control sub band after many years of no restrictions.  And the rest of the world does not equal the large number of active hams we have here that will be running their own mailbox servers wherever they can find room.  Look at the CW vs phone bands here.  SSB, the choice of newer hams other than FT-8  would likely be used all the way to the lower edge of the band on busy days with good propagation if it was only an unenforceable agreement and  not the law. This may be an opportunity.  Maybe we need to review the positions again.  What am I missing in their filing?  It seems persuasive if the representations therein are true.  Are they accurate?  Maybe this is not an opportunity, but I do not yet see why.

Bob Famiglio, K3RF,   610-359-7300

ARRL Atlantic Division Director

www.QRZ.com/db/K3RF

From: Boehner, James, N2ZZ (Dir, RK) <n2zz@arrl.org>
Sent: Monday, July 17, 2023 2:16 PM
To: Famiglio, Bob, K3RF (Dir, AD) <k3rf@arrl.org>; arrl-odv@reflector.arrl.org <arrl-odv@arrl.org>
Subject: RE: [arrl-odv:34989] Nrw filing today in reference to the bandwdth proceedings pending for years.

I usually do not respond to issues like this, but there is a pattern.

We have asked the FCC for relief by removing the 300-symbol rate, as we did 10 years ago.  We feel it is reasonable to apply a 2.8 kHz bandwidth limit as well, although the FCC did not agree with this in the past.  From my recollection, they did not want this, as they did not want to revisit this issue in the future should our needs change again.  There was controversy within the amateur radio community comments about removing the symbol rate at all.  We were reminded that we only represent 20% of hams.  FCC decided to do nothing.  STA’s are much safer for them.  Now we have several state EMD’s writing to the FCC chair with their support for removal of the symbol rate.  Texas SWIC sends letter as well.  This restriction is not in place anywhere else in the world. We actually have a slim chance that the FCC will finally do something.

Next comes this filing from the group below.  They want an immediate and long-lasting solution.  Good thought, but bad in execution.  There has been controversy in all our filings.  We may have beat down the symbol rate controversy somewhat, but we haven’t had universal approval with our HF band planning proposal.  I remember on a phone call with Steve Waterman he stated that “it would not work”.  I didn’t get details, as I was already 2 hours in on that call.

The situation is that we need to focus on the symbol rate removal, and once done, to hit our HF band planning hard.  Another survey if necessary.  The impact of the proposal below will serve only to confuse, add controversy and in the end, for the FCC to do nothing, as the FCC will conclude that hams just can’t get their act together.

Just my humble opinion.

‘73 de Jim N2ZZ

Director – Roanoke Division

Representing ARRL members in North Carolina, South Carolina, Virginia and West Virginia

ARRL – the national association for Amateur Radio

Facebook Page: ARRL Roanoke Division

Website: www.arrl-roanoke.org

From: arrl-odv <arrl-odv-bounces@reflector.arrl.org> On Behalf Of Famiglio, Bob, K3RF (Dir, AD)
Sent: Monday, July 17, 2023 12:27 PM
To: arrl-odv@reflector.arrl.org <arrl-odv@arrl.org>
Subject: [arrl-odv:34989] Nrw filing today in reference to the bandwdth proceedings pending for years.

I was alerted to this new FCC filing regarding the bandwidth proceedings.  One of the filers, Janis AB2RA, is an active Atlantic division constituent and sent me this link today and wants to discuss it with me.  It makes an interesting read.

https://www.fcc.gov/ecfs/document/107151170924997/1

Bob K3RF