Monday, September 4, 2017

FCC investigating technical regulations

This is mostly stuff I just communicated again to my Division Director.  But I plan to file comments directly, and encourage others to do the same.

I just read the blurb about the FCC Technological Advisory Council Investigating Technical Regulations.  And I was just going to inquire with the league about the status of the October 2013, proposal to modernize the rules for data transmissions.

I have stressed before that I am fine with doing away with the symbol rates, and establishing the proposed 2.8 kHz bandwidth limit for HF. But I am totally against not revising the bandwidth limits for above 50 MHz.  There is plenty of spectrum on the VHF/UHF bands, and other modes like image presently are not as limited as data is.


From: http://www.kb6nu.com/arrl-finally-realizes-status-quo-isnt-going-cut/
"From the committee’s vantage point, the status quo is no longer adequate: we need to have a vision of the future and convey it to our current membership. If we do not convey the need to change the paradigm, the ARRL’s relevancy will not move forward."


The first step in anything is admitting there is a problem.  Now if they follow through with comments that reflect something other than the status quo in this latest proceeding, I might feel this is more than hot air.

There are also some good points in The Future of Amateur Radio Is Not In The Numbers , by Chris Warren.

So I sincerely hope any league comments I read on this latest docket reflect some sort of different carve out in respect to bandwidth for data on the VHF/UHF bands.  If for some reason someone doesn't understand why data is important, you can skip down to "Internet Threats and Regulation and The Need for Speed and Digital Networks"portion of this document.

In my opinion we need a group such as TAPR to start getting more involved with the FCC and bypass the ARRL.  It's my impression that the League only cares about contesters and DXers because that is where most of their money comes from.

I remember back when I never really understood TAPR. I knew what the name stood for, so I always assumed they were the voice representing the digital aspects of the hobby. Then I heard a 2008 Rain report where Steve Bible explained TAPR. I wonder if there is any chance of TAPR taking up the role that I thought there were about? 

And as I stressed before, I feel its important to have a futuristic thought process when making comments as it takes many years for regulator changes to actually happen. And in that light, there is a 2012 webinar, where Chris Imlay W3KD and Ed Hare W1RFI predict and speculate what ham radio will be like in 25 years (2037).

So I encourage everyone to listen to that when you have the time, add your own thinking and start drafting your thoughts to the commission.  I believe they are referring to Subpart D, Technical Standards, which includes; 97.301 Authorized frequency bands, 97.303 Frequency sharing requirements, 97.305 Authorized emission types, 97.307 Emission standards, 97.309 RTTY and data emission codes, 97.311 SS emission types, 97.313 Transmitter power standards, 97.315 Certification of external RF power amplifiers, and 97.317 Standards for certification of external RF power amplifiers.

Now on to what I think:

I actually recommended basically do away with the bandwidth limits, and let gentlemans agreements take rule.  This was something that made sense to me from Bruce Peren's Dec 2012 Codec 2 filed comments. This is how a lot of other countries handle ham radio things.  As long as there is a list of permitted emission designators, our regulations remain brittle and prone to rapid obsolescence (and holding the rest of the world back).   Allow any emission that fits within the band.   Hams have always been responsible and share the bands on their own, without the authorities wielding a stick.

I think that seems logical moving forward.  All we are doing is taking up the FCC's time and screwing ourselves with this 10-15 year re-revising the rule, piece meal approach game like we have been playing, that really just impedes innovation.

I am sure from the leagues recent license survey, they are fully aware that in the next 10 or so years a large number of the existing ham population will have passed on.  A new group of hams who need better representation are the future ARRL customers/members.