Greetings, Over the past 24 hours, about 15 AM phone operators have sent the exact form letter email to me and a number of others regarding the IARU Region 2 band plan. The form letter contains several inaccurate statements and assumptions, as has been the case regarding this matter over the past couple of weeks. Again, there have only been about 15 emails and this is NOT an issue with anyone outside the AM community, and I have received replies from 9 of the 15 thanking me for providing a factual response and addressing the issue. Dave and I drafted the reply to each and I have sent that reply along with a copy to the Division Director. If you didn't see one of these, there is no need to worry as the letters were only from 3 divisions. Just in case you hear something from a member about the matter below is the original form letter email and the response I sent. You may use this as a background fact document if a response is warranted. 73 Joel W5ZN Thank you for letting me know of your concerns with regard to the band plan adopted recently by the member-societies of IARU Region 2. You sent your message to a number of individuals; because the ARRL is the representative organization in the IARU for radio amateurs of the United States, I am replying on their behalf. IARU regional band plans have been in existence for many years. They are developed, reviewed and approved at regional conferences of the IARU member-societies. The band plans provide voluntary guidelines that are intended to assist amateurs in making the most effective use of our limited frequency allocations. They are not restrictions and carry no regulatory authority. On behalf of the ARRL, I can assure you that there are no plans to propose incorporating any IARU band plan into the FCC rules. One virtue of voluntary band plans is that they are more flexible and can be amended more easily than the FCC rules; writing them into the rules would be counterproductive. The new IARU Region 2 band plan was developed by delegates to the Region 2 Conference from a number of countries. It does not align in every respect either with the FCC rules or with operating patterns followed by US amateurs. Unlike the United States, most countries do not have regulations setting out subbands for different types of emission. Even in the US the FCC rules do not provide much detail with regard to frequency use. As FCC amateur licensees we are obliged to cooperate with one another in selecting transmitting channels and making the most effective use of amateur service frequencies, and to follow good engineering and good amateur practice. Your message objects to the Region 2 band plan for "suggesting limits that are more severe than regulations from the governments in the region." However, the band plan does not contain "limits." As voluntary guidelines the band plan cannot by definition be "more severe" than regulations. And finally, if the band plan did not suggest an operating pattern that is a subset of the regulations it would serve no purpose. Your message refers to IARU President Larry Price as wishing "to discourage footnotes among the various regional plans he oversees." First, the IARU President does not "oversee" regional band plans. Each regional plan is developed by the member-societies of that region, in accordance with the constitution, bylaws and rules of the regional organization. The regional organizations are autonomous entities and do not answer to the IARU President. Second, Mr. Price's observation with regard to footnotes had nothing whatsoever to do with IARU band plans. Footnotes are not by their nature either good or bad; it depends on what they say. Mr. Price's observation had to do specifically with footnotes in the ITU Table of Frequency Allocations that prohibit amateur operation, or authorize sharing by additional services, in certain countries in certain parts of the bands that are allocated in the ITU Table to the amateur service. One of the goals of the IARU is to minimize such footnotes. On the other hand, there are other footnotes to the ITU Table that are extremely beneficial to Amateur Radio, such as the ones permitting amateur-satellite operation. In any case this is totally unrelated to IARU band planning activities, which are internal to the amateur service and to each regional IARU organization and have nothing whatever to do with the ITU. I hope this has reassured you that nothing will happen on January 1 that will in any way affect your use of AM. We are always seeking ways to improve the process of revision of the IARU Region 2 band plan and the ARRL Board of Directors, who determine the policy for ARRL's input to IARU Region 2, are always open to member input on future revisions that ARRL delegates may take to future Region 2 Conferences. I encourage you to communicate with the Division Director in your ARRL Division. Sincere 73, Joel Harrison, W5ZN ARRL President _____ : REQUEST TO AMEND THE IARU Region 2 BAND PLAN Effective Jan, 2008 To: Delegates and representatives, International Amateur Radio Union From: Concerned amateur licensee (ADD your name, and call) (ADD callbook hometown, email address) Subject: Region 2 Band Plan A substantial group of active licensees in the amateur community faces problems because of the Region 2 Band Plan developed at September's IARU meeting in Brazil. Please consider additional revisions to this plan before it is implemented so that it may win significant support from those of us who enjoy using Amplitude Modulation on the HF bands. "AMers" have a long and successful leadership role in coordinating our operations to minimize friction with incompatible modes and activities. The Region 2 plan fails to acknowledge this leadership as it imposes a bandwidth specification that would be impossible for us to meet. Government regulatory agencies throughout Region 2 have supported a variety of "phone" modes while avoiding or not emphasizing an enumeration of bandwidth. The U.S., where the numerically largest stronghold of AM activity exists, deliberately encourages such activity by instead mandating a technically clean signal, and imposing on operators a requirement to minimize the chance for interference. There have been no documented complaints against AM activity based on unreasonable bandwidth, according to Federal Communications Commission enforcement counsel Riley Hollingsworth. The system that does NOT use a bandwidth method to coordinate activities is prevalent throughout Region 2. It has worked well and has widespread acceptance as part of an otherwise voluntary layout of where such operations are situated. The IARU voluntary band plan for Region 2 would be at odds with regulations in the area's major countries including the U.S., Canada, and Mexico. Yet the plan can still win the support of AMers by simply deleting the numerical bandwidth specification, and including us among the other modes and activities you list in the main table. It is unfair and risky to place AM operations as a "footnote" to the table, as now written, since the IARU president, Larry Price, has made it clear he wishes to discourage footnotes among the various regional plans he oversees. Such a placement unwittingly portrays AM as an otherwise non-compliant mode. The preamble to the Region 2 plan encourages IARU member societies to lobby government regulators to formally adopt the plan's provisions. The combination of AM's placement and the regulatory advocacy accompanying the plan represents a direct threat to AM that the IARU may not have intended to convey. Come January you would be suggesting limits that are more severe than regulations from the governments in the region. This, at a time the IARU has traditionally encouraged the least restrictive environment. Please return to that approach so that active and concerned licensees can make the most of the spectrum allocated to amateurs for hobbyist and volunteer emergency use. Please revise the Region 2 plan to avoid numerical bandwidth specifications, and instead list generalized references to a signal's footprint. The terms "large," "medium," and "small" bandwidth utilization nicely provide a mnemonic that supports existing patterns of operating we all wish to promote. Avoiding numerical references further supports the coordination of new modes that may come from the category of digital communications. It would be unfortunate for the IARU to seek to impose an operating strategy that spurns a popular part of the hobby, that of using AM in a vintage, nostalgic environment of storytelling and technical pursuit. One of the U.S. clubs, the American Radio Relay League, recently conducted a survey among several regions that found nearly 20 percent of subscribers include AM as among their operating activities on HF. These numbers exceed those of "digital" buffs and several other activities you now recognize in the main table of your bandplan. AMers have done nothing to warrant being relegated to the status of a footnote, nor to have our leadership overlooked in the voluntary coordination of our activities that has long been recognized and praised on the bands. Please respond with your thoughts on actions you can quickly take to revise the Region 2 plan before it is implemented to bring it into compliance with how AM is accepted and viewed in the countries hoping to support your plan. Regards, (ADD your name/call) http://amfone.net/Amforum/index.php