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.

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