Bernie, are you going to handle the reply for us, or would you prefer several of us to send our own replies, each with slightly different viewpoints and likely conflicting info? 73, Art ----- Original Message ----- From: "WA3VJB Annapolis" <WA3VJB@amfone.net> Cc: <K1KI@ARRL.ORG> Sent: Monday, August 26, 2002 5:45 AM Subject: Bandwidth Proposal To: Directors and Vice-Directors (nationally) From: Paul Courson, WA3VJB, League Member, Advanced Class, licensed since 1971 You undoubtedly have become aware of New England Director Tom Frenaye's motion to explore the idea of defining by bandwidth the distribution of operating activities on the shortwave ham bands. He has told me the motivation was primarily to determine where to place operating activity involving the specialty of digital technology. I believe there should not be a bandwidth-based proposal in the first place, and respectfully ask that you not pursue a Petition for Rulemaking along these lines. The Federal Communications Commission has been totally correct in avoiding such prescriptions in its regulations, and deliberately leaving vague the technical parameters we must operate within. I write to you today seeking your preliminary thoughts on the issue, and to inform you that the FCC in 1976 considered and rejected a similar plan with the failure of Docket 20777. The League would do well to research the basis for that proceeding and the reasons why it was unsuccessful. Twenty-five years after the FCC voted down that proposal, it remains true that limiting by bandwidth would substitute one set of unacceptably constraining parameters for another. Yes, there is a need to resolve the issue of where to situate operating activities involving digital technology, but such technologies have no greater or lesser claim on spectrum than all the other modes and activities we are authorized to experiment with on the shortwave ham bands. Creating space for additional technologies is best handled as a function of operating coordination, NOT the imposition of boundaries based on technical parameters. Such boundaries have historically been established by mode, but that method of definition is clearly obsolete. Operating coordination, by contrast, involves human thought, allows flexibility by band conditions, and encourages coordination to distribute the "load" of operating activities on a given band for the greatest satisfaction of all players. There can be no favoritism by mode or activity, since all such non-emergency communication is considered equally deserving of space. Should that prevailing regulatory assumption change, the successor must consider questions of merit for each mode or activity in order for it to be allowed a place on our bands. This would involve judgments against standards that have not been developed. Meantime, we struggle to operate against an outdated system of separation established when it was a simple choice of "CW" or "Phone" as equally popular modes. Discontinuing rigid, inefficient sub-band segregation, and encouraging dynamic operating strategies of self-coordination is the best scenario that can be hoped for. Compliance with such a system shall be commensurate with a hobbyist radio service; that is to say, it won't be perfect because it does not have to be. I speak from a specialty involving enthusiasts for the heritage mode of Amplitude Modulation. Our vintage activity resembles that of CW, where much of the technical discovery has long been completed, yet where certain skills continue to be refined and perpetuated. Our operating also resembles contesting and DX-ing when it comes to consumption of bandwidth for an enjoyable pursuit. Since we are a specialty, our numbers do not comprise a substantial lobby. We have historically been under-represented in League publications and in political deliberations such as those involving representatives in your position. I am happy to report that in the past 10 years, QST has implemented regular coverage of vintage radio, and that in recent years I have gotten a friendly reception among ARRL officials. In case you haven't had the opportunity to participate in the warm and inviting sound of enhanced audio AM, I would like to invite you to sample this nostalgic facet of the hobby where we pay great respect to part of radio's heritage. We enjoy the support of the Quarter Century Wireless Association, the Antique Wireless Association, the National Association of Broadcasters, and the Society of Broadcast Engineers, among groups you probably have heard of. Within our ranks, we have at least two prominent internet websites, and a publication with some 8,000 subscribers entitled Electric Radio. Please tell me that you can include us in your deliberations as they unfold, rather than keeping us on the outside and reacting after any plan has taken shape. I understand there may be an ad hoc committee empanelled to assist Mr. Rinaldo and Mr. Imlay as they determine whether there is a valid foundation for such a Petition. We would like to be part of such a panel. I look forward to your reply, Paul Courson 202-215-3885 Pursuing vintage radio on the shortwave ham bands! www.amfone.net www.amwindow.org