Thanks, Dick. With your abstention I can announce the vote officially as 14 in favor, one abstention. There are several examples of automatically controlled digital stations being impacted, culled from the comments submitted to bandplan@www.arrl.org, that Chris will include in the petition. 73, David Sumner, K1ZZ Secretary -----Original Message----- From: Richard J. Norton [mailto:richardjnorton@gmail.com] Sent: Thursday, December 07, 2006 3:54 PM To: arrl-odv Subject: Reconsideration Petition Considerations Please excuse me for not rapidly jumping aboard the reconsideration petition bandwagon. I'm still of the belief that there is a better way to handle this, and I'm not even convinced that filing the petition with the proposed justifications is in our best interests. I've spent a little time looking at this, and have even talked to a few of you on the telephone to clarify facts and assess opinion. My conclusions follow. RECONSIDERATION PHILOSOPHY - 97.221 FOOT IN THE DOOR As I understand it, the justification for requesting reconsideration is the allegation that the FCC "made a mistake" in not allowing part 97.221 automatically controlled digital stations to continue to operate between 3620 and 3635 kHz. The corrective action proposed is is to both move the general/advanced-class CW and digital band-edge up to 3635, and also move the lower end of the extra class phone band to 3635. In addition to permitting the automatically controlled digital stations to continue operation, CW and other digital users would then also have access to 3600 - 3635. There are things that might convince me that there was a real problem that needed correction. One of these would be the actual existence of any "automatically controlled digital stations" that presently use 3620 - 3635. I personally do not know of any, and in the comments from ARRL members I've read, have yet to see a, "My automatically controlled digital station on 80 meters will be impacted." AN ALTERNATIVE PHILOSOPHY I had earlier suggested proposing leaving the lower-edge of the extra-class phone band at 3600, and allowing general/advanced CW and digital to share the entire extra-class phone segment. The ODV-reflector was told that, "procedurally there's no way to get there from here via reconsideration." Further research shows that this could indeed be proposed as being a fix, but it might seem more "fix-related" to propose that only 3600 - 3635 be shared. Note that we could even propose sharing only 3620 - 3635, or even reassigning only 3620 - 3635 to automatic stations, as a fix in a reconsideration petition. For the sharing concept, it has been pointed out to me that some additional language would have to developed for parts 97.305 and 97.307, in addition to the four simple changes that appear to be needed in part 97.301 for the EC's proposal. Whereas minimization of text-changes might be an objective, and in the professional judgement of some might even facilitate acceptance, a text-change minimization objective is quite different from "procedurally no way." Philosophically I support minimization of detailed FCC regulation of our amateur bands, in matters such as mode and or bandwidth. I believe flexibility permits more efficient use of our allocated frequencies. This is how amateur frequencies are allocated in essentially every other country in the world other than the USA. In the USA sharing frequencies between modes works on 160 meters and even 40 meters. I am aware that some of you do not share my view. SUMMARY I believe that there is a better fix available than the one proposed by the EC, the sharing of phone and digital-CW. In addition to the more efficient occupancy, note that sharing phone and digital would permit basic communication on voice, with the possibility of exchanging data on the same frequency. I remain unconvinced that proposing the EC's recommended plan is even desirable. If we are saying automatically controlled digital stations are going to be harmed, I hope we have some specific examples of these stations that will actually be harmed in case the FCC requests them. Otherwise it might appear that the petition is simply a disagreement over what the phone band lower limit should be. Being unsure if the proposed reconsideration proposal is in the League's best interests, I think I'll simply abstain from voting. I'm of course open to listening to other points of view. 73, Dick Norton, N6AA