ARRL draft HF Band Plan Proposal and FCC RM-11708
What the ARRL doesn't want you to find out!

Current Status of RM-11769, RM-11759, RM-11708, WT 16-239,
ARRL HF 75 Meter Phone Reduction and Free Digital EMail Petitions

Note - below information is historical. Please see above link instead.

If you have not sent your comments to ARRL on the new band plan, you need to read this and respond NOW - BEFORE APRIL 19, 2015.

If you have not been following FCC RM 11708, this is a wake up call; you need to read that and file FCC comments YESTERDAY. I will include links in this article that you can use to do research and form your own opinion. In any case, it is urgent that you take action NOW to be sure that significant and damaging changes to the hobby do not occur.

First I will present the short form comment method to simplify your comment procedure. If you already have your mind made up, this will get you the most impact for your comment by protecting 40 meter weak signal work on CW,RTTY, PSK-31, and SSB, while still maximizing the possibility of restoring CW, RTTY, and PSK-31 to 80 meters. This aligns with the goals of FISTS CW preservation organization, as I read in an email forward which will be linked to below. This is a screen shot of the actual form you will see at the ARRL when you use this short-form link to comment:

The short form itself is at: http://www.arrl.org/bandplan.
Here is the original FISTS CW preservation email urging their members to comment: http://alabamacontestgroup.org/fwd-fists-updates-bandplan-and-rule-movement-important/.

Directions for how to file long-form at ARRL and FCC are at the end of the article.

Here are my reasons you should urgently take action on this issue NOW.

I will present evidence here that may convince you to believe that the current action by ARRL (1) has not allowed adequate time for comment on this significant escalation of original FCC RM 11708 which has significant negative comment filed with the FCC (2) has not subjected the band planning committee's report to peer review by technically qualified solar cycle experts and ARRL members who do weak signal narrow band work on the most popular modes including CW, RTTY, PSK31 and other data modes, and SSB (3) has failed to adequately protect their interests as a new mode which has demanded 15% of all amateur HF spectrum as a goal (4) has signed a memorandum of understanding with a special interest group outside the ARRL membership which is contrary to the interest of the membership (5) is again initiating FCC regulatory action that is damaging to the hobby without adequate member input (6) is exposing to significant risk civilians which may be caused by using amateur radio for primary communication (not back up) that should be with the Coast Guard or other agencies that are prepared to respond to emergencies (7) is proposing a use of amateur radio that may be commercial (email that should be handled by business providers such as Sailmail) which will saturate the HF bands and prevent their traditional. You should consider these issues and decide for yourself if the original evidence, provided here for your examination, justifies it.

ARRL has set forth a new band plan with less than a month comment period from its publication in QST April 2015. This is a significant change from the original FCC RM 11708, which requested only modification of "symbol rate" specifications.

This new action now reassigns 50 KHz of amateur spectrum under mandatory FCC rules and establishes a new category in "voluntary" band plans for digital modes which are significantly wider than those currently permitted.

The article makes some alarming statements, which I will discuss later, but I present them first here, so that you can see what triggered my "BS alarm". Read them for yourself and see if you think they area a cause for concern.

From April 2015 QST (page number noted)

1. "committee has recommended that the FCC be petitioned to move the boundary between the 80 meter RTTY/data band and the 75 meter phone/ image band from 3600 to 3650" (page 70).

2. "Add 80 meter RTTY/data privileges for Novices and Technicians" (page 70)

3. "After reviewing members' comments, and bearing in mind the fact that most communications on 40 meters by American amateurs is with other stations in North Americal and not DX" (page 70)

4. "the committee concluded that it is not realistic to try to bring the ARRL band plan for 40 meters into alignment with the rest of the world."

5. "The comment deadline is April 19, 2015. This should give the HF band planning committee sufficient time to analyze members' input and prepare its final report prior to the July 17 - 18 meeting of the Board" (page 71)



I could continue, but these are the statements which you can read in the magazine to verify their accuracy. My immediate reaction to the quotes presented above:
  1. If there are existing problems with the automated digital modes which have not been corrected, why have those problems not been corrected before additional band space is permanently granted by FCC action?
  2. Is there justification for less qualified operators engaging in modes for which there has been proven interference issues with existing modes? Will they be able or willing to correct interference issues on their own?
  3. This statement is clear evidence that the HF Band Planning Committee does not have representation from other users of the HF spectrum, nor does it have anyone with a knowledge of solar cycles and activity. Right now, the major DX activity is on the upper bands at the top of the cycle. In 5 or 6 years, the activity will shift to the lower bands, including 40 meters. The existing report MUST be peer reviewed by someone with professional degrees and experience with solar cycles like K7RA, as well as ARRL members who have HF experience proven by ranking on DXCC. Based on this alone, I ask that the report and all action be subjected to immediate injunction and all action ceased until such peer review takes place and adequate comment from the ARRL membership and amateur community can examine such glaring lapses of judgement as demonstrated by the ARRL Band Planning Committee.
  4. This statement is proof that the HF Band Planning Committee has not evaluated the impact on amateur HF activities in IARU Regions 1 and 3. (NOTE: Region 2 is essentially North and South America). Even communication to Region 2 South America would be significantly impacted.
  5. I also recommend that any further FCC proposals by the ARRL regarding license class sub bands, actual band assignments, or anything similar, be subject to a 6 month public review and discussion process and a direct survey of the entire membership of ARRL. If this is incorporated in the ARRL constitution as an amendment, it would prevent further problems. There have been other significant instances of ARRL action in the past to justify this safeguard.

While I am completely in favor of ham radio supporting emergency communications and the nautical community, I have concerns that use of wide band digital modes may be problematic. For a long time, 14.313 has been a resource for worldwide communication for ocean going vessels. I had a local friend who began a global circumnavigation with his sailboat, and he kept in touch with area hams on the radio. This service is presently available to General class hams who have the experience to use it effectively. Including Novice and Technician class licenses who only have digital access and lack the knowledge to use it correctly could be dangerous and interfere with other ongoing communications. I am always in favor of reaching out to others and encouraging them to join the hobby. But I have to reiterate that this is AMATEUR radio, not a commercial internet service, and we are legally prohibited from "pecuniary" interests. Amateur Radio Operators always stand ready to aid in emergency operations. I monitored the operations that Satern and others did in the Haiti hurricane disaster with interest.

I suggest that you should read QST for yourself, with the ARRL comments and band charts for each band and evaluate the impact on your HF amateur activity. Project any problems that you think might occur from explosive growth which results in 15% occupancy of your favorite band by automated wide band digital emissions. Imagine the impact of these automated stations which do not have a functional "channel busy" detection scheme, as proven by prior experience with the existing use. Imagine the use of these devices by Novice or Technician class operators, who have not passed a test on advanced HF techniques included in the General class exam. Oh yes, and imagine the use by (non-ham) bootleggers, with no means of effectively monitoring their activities. Will this become "free internet" for people who do not want to pay for such commercial providers like Sailmail? Will this be used for nefarious purposes for illegal or violent activities to evade Homeland Security monitoring of conventional email? Does the FCC have adequate monitoring personnel or will ARRL OO's be given the necessary expensive hardware modems (at whose expense?) to do the job?

You, as an ARRL member, ham operator interested in preservation of the hobby and its good reputation, and a responsible American citizen, need to think and ACT NOW.

I am going to include a listing of what I consider important online resources for you to review below. Some of them express my opinion better than I can. Some of them are actual audio clips of interference that has already occurred from automatically controlled HF digital modes with no "frequency is in use" detection, even without the proposed changes to the FCC rules or voluntary band plans. Consider the frustration you have experienced as a carbon life form arguing with some artificial life form based on a hunk of silicon whose prime directive programming is self preservation. Some links are actual advertisements of equipment for use by people currently outside the ham community.

IMPORTANT LINKS:


On use of ham radio as a primary communications method for boats, in the case of the BOUNTY sinking:
If this has yet not grabbed your attention, you really need to look at the following:

And this information I found on a discussion group:

Charles Brabham:

There is absolutely nothing "experimental" about WinLink, which uses a commercial modem to provide HF eMail service that has been available on commercial frequencies for a very long time.

Experimenting is when you try something new, with hopes that it will be beneficial. - Not when you insist upon using something old and inappropriate, ignoring the fact that it is detrimental and flouts the law.

We are specifically prohibited by the federal government in the PART97 regulations from providing, on a regular basis, communications which are available outside of amateur radio. WinLink is identical in almost every respect to SailMail, one of many commercial email over HF services, one which uses the exactly the same equipment and software as WinLink. - The differences between the two being that SailMail costs 20 bucks a month and operates PACTOR III on the channelized commercial spectrum it was designed and intended for, instead of polluting the ham bands and interfering with ham radio operators communications as WinLink does - for free.

The interference issues related to WinLink on HF are partly due to the commercial PACTOR III modem having no provision for detecting any kind of signal except other PACTOR signals, partly due to the WinLink administrator specifying that all automated WinLink servers on HF turn off the little bit of signal detection the modem does have, and partly due to the PACTOR III signal automatically causing itself to spread out wider in reaction to improved band conditions - the exact opposite of good operating practice within amateur radio's shared spectrum. Ham radio QSOs which are fortunate enough not to be overwhelmed by the initial PACTOR III transmissions are then enveloped when the signal widens, without the WinLink server operator's knowledge or intervention.

Because of these factors, PACTOR III interferes with legitimate, legal ham radio communications without operator intervention, simply by being utilized with amateur radios shared spectrum instead of the channelized commercial spectrum that it was designed for.

The WinLink administrator and the operators of the WinLink servers are aware of these issues but operate this inappropriate equipment on ham radio HF frequencies anyway, making the interference they cause every day "willful interference", which is specifically prohibited in the FCC's PART97 regulations that define and protect amateur radio.

These are not just Lids, but Lids who set up an automated system that interferes with legal amateur radio transmissions on HF all day, every day. It is literally impossible to operate the PACTOR III modem legally on the HF amateur radio bands, due to its design and operating characteristics.

73 DE Charles Brabham, N5PVL
http://www.uspacket.org



If you are not convinced by the previous links, please read the following memorandum of understanding between your ARRL and the interests linked to above
MEMORANDUM OF UNDERSTANDING
BETWEEN
UNITED STATES POWER SQUADRONS®
AND
AMERICAN RADIO RELAY LEAGUE INC


HOW TO FILE COMMENTS WITH THE ARRL ON HF BAND PLAN AND FCC RM 11708:


The following is an open letter I sent to ARRL officers....

Date: Tue, 24 Mar 2015 14:19:49 -0400
From: AB2RA Janis <ab2ra@*****.***>
Subject: Questions about band plan proposal - urgent
To: w3tom@arrl.org, n3kn@arrl.org, dsumner@arrl.org, k5ur@arrl.org

  1. Did you vote in favor of the Band Plan Proposals as printed in April 2015 QST?
  2. Would you consider extending the comment date to May 30, 2015, since the actual plan was only published in the QST in April, to allow adequate member input?
  3. Have you sent an email or postal mail survey to the Atlantic Section members you represent soliciting their input during this process? I do not recall receiving such a communication.
  4. This new action is a repetition and extension of prior FCC filings. This new action is in spite of almost universal negative comments on the FCC website. I am concerned that you may not have reviewed the already negative impact of the existing presence of this mode as it stands, before proceeding with expanding it, without addressing the issues it currently has raised first before adding spectrum in locations that are certain to exacerbate the problem.

    I have spent some time researching this and listening on the air recently to educate myself on the issues.

    Have you reviewed the comments in the previous FCC filing on RM 11708:

    Note: there is not a saveSSB.com site - YET!
    Do you really want to have that too?
  5. The committee report says it "concluded that it is not realistic to try to bring the ARRL band plan for 40 meters into alignment with the rest of the world." It also states that "most communication on 40 meters by American amateurs is with other stations in North America, not DX."

    This last statement is patently false and contrary to common practice in CW, SSB, and RTTY contest or daily operation. The first statement is indication of a cavalier attitude toward the ham community OUTSIDE the US who will experience interference from the proposed wide band digital operation.

    I suggest that it is prudent to immediately prohibit ALL such operation on 40 meters to avoid interference by unmanned automatic stations that cannot or will not first check for channel activity on this already crowded band. Further, if such operation is considered, it should be at the TOP of 40 meters as is done on 30 meters, which does NOT overlap amateur assignments in IARU Regions 1 and 3. This would solve all problems of incompatibility with Regions 1 and 3. The wide band digital mode is incompatible with legacy modes or narrow band digital modes and moving it to the top of 40 meters would not hamper its functionality if the intended range is truly "local". General SSB and Extra/Advanced SSB could be adjusted (along with the AM window at 7290) downward to compensate for the repurposing of the top end of 40 meters.

  6. The committee proposes conversion of the Extra phone sub band on 80 meters, due to lack of occupancy. This again is an indication of the band plan committee's deliberate or accidental ignorance of propagation cycles. During the solar maxima, population shifts to 20 thru 10 meters. It returns to 40 and 80 meters during the minima. I again recommend that the wide band modes be located at the TOP of 80 meters as well as 40 meters, as is currently done on 30 meters, to avoid interference with incompatible modes (essentially all other ham activity) and to prevent interference with IARU regions 1 and 3. Appropriate downward adjustments of General and Advanced portions could be made. The shrinkage of the Extra phone band would then be at the TOP of its assignment. With the move of the wide band modes out of the existing CW and narrow band RTTY assignment might be adequate and solve the incompatibility between modes. Or consider merging the Extra and Advanced phone segments on this band as it often done on the other HF bands.
  7. I further recommend that the findings of the current band planning committee be subject to peer review by a committee representing the major portion of the ham community, not just the digital community and the yacht owners, before any such report can proceed to the ARRL board of directors. This new peer review committee should be comprised of representatives who are currently in the upper tier of DXCC, one from each specialty: SSB, CW, and RTTY. Another peer review member should be a degreed expert on propagation with a reputation like K7RA. Other possible representatives could be included to get a balanced representation of actual amateurs, not a narrow interest group.

    While I am glad to see increased participation in the hobby, I am very concerned about its use as a replacement for commercial internet service of business use. I am old enough to remember the debates about whether it was appropriate to call the pizza shop on the 2 meter autopatch for carryout. There are cell phones for this now. Further, reliance solely on amateur radio for the only emergency radio on a vessel invites disaster and threatens lives. If you can afford a boat, you can surely buy a FCC type accepted marine radio and/or a satellite based cell phone.

  8. I also recommend that any further FCC proposals by the ARRL regarding license class sub bands, actual band assignments, or anything similar, be subject to a 6 month review and discussion process and a direct survey of the entire membership of ARRL. If this is incorporated in the ARRL constitution as an amendment, it would prevent further problems.
I look forward to your response.
2015 July ARRL Board Minutes Summary
Back to RM-11708 Article Index
Back to Wireless Girl Home Page

73,
Janis Carson
AB2RA