OPPOSE RM-11306

Peter A Markavage pmarkavage at JUNO.COM
Mon Feb 6 13:27:13 EST 2006


> On Mon, 6 Feb 2006 10:58:43 -0500 "Todd, KA1KAQ" <ka1kaq at gmail.com> 
> writes:
> > On 2/5/06, Peter A Markavage <pmarkavage at juno.com> wrote:
> > > So why don't you just tell them to retain Section 97.221 of the
rules (keeps Winlink for moving from their designated area)
> > 
> > Not a bad idea, Pete. Other than the automated/unattended email part,
that is.
> > 
> > > There are no AM restrictions; they just defined a max bandwidth of 
9 KHz. More accurately, AM's definition is handled as a special 
> > 'exception' rather than a 'rule'. While it doesn't appear as a
restriction today, it makes it a whole lot easier to add later by either
changing 
> the exception, or removing it all together.
> 
**** If you read my response to RM-11306, I indicated that a better
approach is to remove the the Exemption Note, Note 1, and make each 
> HF phone band, with the exception of 60 meters, have a max bandwidth 
of 9 KHz. This still allows for strong band planning, and removes 
> the AM'ers stigma of a note exemption.
> 
>  
> > > FCC has already indicated current rules stifle experimentation with
new  modes so they're out to make changes. I'm not sure how this is so,
other than requiring some Type Acceptance or approval from them. Hams
have experimented for decades on HF as well as above, with no ill
affects. In cases where  more-than-normal intereference could be
encountered (packet comes to mind), it  appears to have been tested on
the under-utilized VHF/UHF spectrum before turning it loose in the HF
spectrum. Just an observation on my  part, mind you.
> 
**** NO, any experimentation with new types of modes on the HF bands,that
are not already covered in Sections 97.305, 307, or  others, have to go
through the submission of a proposal to the FCC, then an NRPM, and the
rest of the same legal stuff we're going  through now. These Sections all
have to be modified before the mode  can legality be used which can be a
long drawn out process. So, the point is, under the current rules, these
sections as  written, stifle mode experimentation and use on the HF
bands.
> 
> > Particularly with the ARRL's request for loosening or removing  the
need for attended operation, a case could be made for putting it  all
> into an area of spectrum up there, instead of the most densely
populated and used HF bands. Maybe it could share 220 space with  UPS?
You can also express your opinion for RM-11305, any mode, any where; i.e.
jungle law or can you picture FM transmissions on 75 meters. We already
have 'jungle law', Pete. Just listen on the phone  portions of 75 any
night, or 40 and above most days. Much of it results  from too many
operators trying to share too little space, while large chunks of the
bands sit idle, if not entirely empty. If anything, opening up the bands
to phone (SSB as well as AM) would reduce  the level of problems by
allowing all users to share the same space, instead of giving
preferential treatment to some specific  group(s).
 RM-11305 is the first proposal I've seen that tries to get us in step
with the rest of the world's amateur operators. As someone pointed  out
in another venue, even Cuba is less restrictive when it comes to
frequency access.
Or is your real feeling that US hams aren't capable of enjoying  the same
use of frequency spectrum the rest of the world uses,  without having
someone dictate to them how and where to operate and how  to behave? Why
are we restricted from using subbands while our  neighbors to the north
can be heard there regularly?
> 
**** Having rules that only say(as in RM-11305), "here are your band 
edges", play nice between them is not going to work.It allows any  type
of mode and any width of transmitted bandwidth to wander  anywhere they
want within the band edge limitations. Technically, I  could develop some
ATV type mode and almost occupy an entire ham  band. I believe the
Amateur Radio Service has a tradition for rules and  regulations within
the Service just like most of the other Services  under the wing of the
Federal Government. I care less about what  privileges other amateurs
have in other countries. Trying to compare or equate the actions of
foreign governments on how they do their  "business", to how we do our
government "business", is not a  rational approach.
> > 
> Of course, some may not care to help define the future of the  Amateur
Radio Service.
> > 
> If the future of amateur radio in the US is one of increased regulation
and the push of automated digital services over actual human
communications, we have no future. Rather than trying to regulate every
little aspect in favor of someone's favorite mode  or the group that will
bring in more money to the Newington coffers,  why not institute fewer
regulations (many of which are obsolete or unnecessary in today's world)
and allow the FCC to spend their 
 time enforcing rules that affect everyone? Rather than 'more 
government'  in some hope of instilling the correct behavior on the
bands, why not  put
 the responsibility where it belongs - with the individual operator? It's
a whole lot easier to prove intentional interference than to prove
someone's signal was .2khz too wide. What we need are regulations that
treat all modes equally instead  of penalizing the majority in favor of
the minority, and make the individual accountable at the same time. It's
amateur radio after  all, not an extension of the wireless internet.
Despite the temporary increase in cash for the ARRL that their suggested
changes are  clearly designed to bring in, if approved we will see the 
commercialization  of our bands that has been predicted for years, via
the backdoor, courtesy of the Amateur Radio Retail Lobby.
> > 
> > de Todd/'Boomer'  KA1KAQ
> 
**** Changes are going to come from the FCC whether the ARRL or any other
group proposes them. By providing them(FCC) with input now we  may be
able to help their decision making process and, at the same  time, help
formulate the future direction of the Amateur Radio  Service. The problem
most people face is separating "hobby radio"  from Amateur Radio Service.
I suspect the FCC cares little for the  "hobby" aspects of amateur radio.
> > 
> 
> Pete, wa2cwa
> > 

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