FCC OET 17-215: TROUBLE FOR AMATEUR RADIO?

The FCC has opened a new proceeding, offering to improve FCC service to people filing electronic comments, and modernize regulations. While this is a worthwhile endeavor, the potential for special interests using it for nefarious purposes is likely. The FCC intends this proceeding to benefit a broad range of subjects, including commercial radio/TV broadcasting, internet, mobile wireless, and other telecommunications. Alarmingly, the first three filings were about amateur radio. The Perens comment is the most damaging, and I did file responses to that one. Here are the current links to use to inform yourself. On this web site, nothing but the facts. More to come. UPDATED November 28, 2017.

Read for yourself:

My filings on the subject

Filings you should read and "REPLY" comment on BETWEEN November 1 and 29, 2017.
IMPORTANT: Regular comment period has EXPIRED on October 30. ALL comments now must be "REPLY" comments.

Bruce Perens' comments recommend:

  • Revise entire Part 97 Rules - will this be a spectrum auction to special interests? Amateur radio is being petitioned away. Several filings RM-11708 (now WT 16-239), RM-11759, and RM-11769 are examples. There are probably more coming, including a license structure reorganization from ARRL.
  • Delete all band segments for mode, bandwidth, and license class on all amateur bands. His claim is based on Canadian amateur rules. (Canadian incentive license is based on POWER limits. Think this will be enforceable in the USA? Will anyone follow a "voluntary" band plan?) How do you feel about your earned HF privileges being matched by Novice and Tech operators? Will people bother taking higher class exams any more? Does this serve the current Part 97 goal of providing a pool of trained radio operators and technically oriented people? Or should we "DUMB DOWN" the licensing exams even further? This is nothing new. Go back to 2005 and RM-11305 (which was withdrawn) and RM-11306 (ARRL initiative) that was soundly defeated in the rulemaking process. Read it all, Deja Vu all over again: href=http://www.w5yi.org/ama_news_article.php?id=190. W8JI, the designer of many amplifiers and other products and the MFJ antenna analyzer sums it up:
      This proposal (RM-11305) makes as much sense as asking the department of highways to remove all lines on highways, and allowing drivers to use their own judgment where to operate their vehicles. The ultimate result would be the widest and heaviest vehicle would occupy whatever space the operated decided he wanted. This proposal would ruin amateur radio by turning it into an uncontrolled free-for-all.
    - Charles T. Rauch, W8JI, Barnesville, GA
  • Elimination of all emission designators - anything goes, anywhere in the band. The new problem in 2017 is that many of the vehicles on the HF "road" described in the W8JI comments above are now not controlled by HUMAN drivers, they are ROBOT or ACDS email servers. How do you feel about HF email ROBOTS at 14.010 or 14.155 MHz?
  • Privatize any remaining band planning, probably to ARRL, which is accountable to no one any more. ARRL membership is less than 20% of all USA amateur operators. Does that small a group represent non members fairly? Does it even represent its own members fairly? With the FCC still in charge, we can voice our concerns in an open democratic forum that is accountable and professional, through rule making procedures.
  • Privatize licensing database - Can these guys sell your info to spammers? Will you trust them to keep a safe data base that will not be hacked and YOUR information (like Social Security Number) be sold on the dark web?
  • One year license term. Maybe it clears out some zombie inactive licenses. Do you want the yearly hassle of renewing?
  • Yearly $50 renewal fee, ostensibly to fund enforcement. Probably ARRL as issuing authority. Solves ARRL cash flow problems. How does it effect YOU? How will it effect seniors on a limited income? Many are concerned about the lack of growth in amateur radio, especially among younger people. Will higher license fees attract young people with limited funds to amateur radio or drive even more of them away?
  • Privatize all enforcement to a commercial organization, again probably ARRL. The FCC follows legal "due process" in enforcement, with an appeals process. Currently OO "Official Observers" as part of the "Amateur Auxiliary" carry only advisory level authority. "OO" authorizations are issued ONLY to ARRL members. Thus, 80% of the amateur population are ineligible to be OOs due to not being ARRL members. The monitoring reports now sent as advisory letters could become legally binding, and revoke YOUR license or impose fines, without recourse. Who are the fines payable to, under this system? If an ARRL OO becomes a "agent" of the federal goverment, does he have the authority to show up unannounced at your door and demand to inspect YOUR station or perform tests, without a warrant? Are they authorized to confiscate or disable your equipment without a court order? Do you think these are good ideas? Or would you rather keep the current arrangement for OO's to remain as "monitor and report to the FCC," with the FCC being the final arbiter. There is more complexity to this issue than the Perens comments lead us to believe.

Do you think you should voice YOUR opposition to this filing now before it becomes an official FCC Notice of Proposed Rule making?

In a TAPR conference, Bruce Perens likens ham radio operators to the "indigenous peoples" of America, otherwise known as Indians. How did colonization go for them?

This is NOT exaggeration, please read the facts for yourself in Bruce Perens' filings:

Perens cites in this reply another ARRL graphic, which shows NO growth. In an effort to "massage the data" on the Entry Level License Survey to something more palatable, ARRL ran a second survey where THEY chose who to include in the survey. Unfortunately, it came out nearly the same. Read the report for yourself: http://www.arrl.org/files/file/2017%20Board%20of%20Directors/July%202017%20Reports/_25%201707-ELL.pdf. In the ARRL report. it references the research done by AH0A. His raw data seems to me to show GROWTH (as shown in green) in recent times. Read the total amateurs right hand column for yourself. Maybe I just am no good at math. Of course, Advanced and Novice classes (shown in red) are declining, probably because most of these are "zombie" licenses that are not really in use, and also are a symptom of the aging ham population. But the overall populaton is replacing these defunct licensees, WHICH ARE NOT BEING ISSUED ANY MORE. After more than a decade, the Novice population should be ZERO, due to upgrading to Tech at least. (The Novice license was discontinued over a decade ago. In my opinion, it never should have been changed from one year, non-renewable, to RENEWABLE, since it was marketed as an "entry level" license. One year was too short, maybe should have been 2 years non-renewable, but then upgrade.) Anyway, we want to attract "makers" who can actually MAKE SOMETHING, not Beavis and Butthead. Let's not insult the talents and intellect of qualified technically oriented youth. See: http://ah0a.org/FCC/Licenses.html

Most of the OET 17-215 filngs have been relatively civil, given the intensity of the debate. I hope that it remains that way, and sticks to the facts. Internet neutrality has been a hot button issue recently. It is fascinating to read some of the FCC commissioner's posts on the FCC Daily Digest. It seems there are some intense debates coming on Internet Neutrality. I hope the debates and filings on ham radio stay factual and rational. Here is the Net Neutrality action to date:

Jerome Kutche N9LYA, a Winlink advocate.
https://www.fcc.gov/ecfs/filing/109041182522036

Eric Wolak; digital modes need updating
https://ecfsapi.fcc.gov/file/10907009520424/comment.txt

Steve Lampereur attempts to reboot the failed RM-11625. "I feel there are significant number of outdated rules that are, and have been for quite some time been hindering Radio Amateurs capability to experiment and innovate. I feel the existing regulatory framework will not keep up with development, and needs more than the traditional piecemeal approach where one rule is changed at a time. As long as ham radio continues to have a list of permitted emission designators, our regulations remain brittle and prone to rapid obsolescence. Even the ARRL seems to feel the status quo is no longer adequate, as evident by their comments in their July 2017 board meeting. While the league hasn't yet announced their vision of the future and conveyed it to their membership, it undoubtedly has to do with digital modes, and their potential. The problem with the rules currently is as every year passes the definitions of emission types/modes become increasingly more blurry, and unnecessarily restrictive. Just because the primary use of say D-Star is voice traffic, does not in my mind justify it as phone/voice instead of RTTY/data. The reality is that a single digital transmission should be expected to carry many modes."

While Lampereur is correct that the conflict between digital voice and analog voice will play out, just as the conflict between SSB and AM did in the 1950s, it will eventually lead to a choice of individual users. This choice will be made on economics of affordability and functionality. At present, there is no functionality offered by digital modes that offers better communications capability on HF than analog modes, without excessive cost. We have seen "the emperor's new clothes" over the years in the form of "Amplitude Compandored SSB" and a type 9800 digital modem by AOR selling for about $700. These are all "proprietary systems", not open source, like Codec2. They were buy a box and plug it in. No innovation here, any more than buying an SCS pactor modem for $1500 and using it for free HF email. Narrow band modes like FT8 ARE innovation: a digital mode that works with an entry level HF transceiver and a modest wire antenna that is capable of world wide communications, with effective signal levels BELOW the noise levels common in urban environments. Expensive? NO. Download FT8 free and use your existing computer sound card interface. We need MORE FT8 like innovation and less of the SCS equipment to attract new amateur operators.

The various digital voice modes fighting for market dominance on VHF are also not interoperable with each other. In other words, we have a digital "Tower of Babel" in which no one can talk to anyone else. In the event of an emergency, when communication is needed, will those digital modes be capable of filling the need? The market will choose digital voice over conventional analog modes if it ever attains equivalent or better performance levels, without excessive cost. The FCC also is not in the business of choosing winners and losers; who should win, Beta or VHS? The FCC has already gone a long way in WT 16-239 toward eliminating emission band widths or designators. We need to proceed with some caution. Otherwise, the elimination of essential groupings of incompatible modes and band widths will cause worse conflict than happened in the late 50s and the 60s. I insist that the "ROBOT" communications and "HUMAN" communications must be separated or there will be intolerable interference and conflict. In the future, in the VOICE/IMAGE sub bands, the market will eventually choose, just as SSB became popular once it became affordable, and delivered on its promises of effectiveness. Once the developers of Codec2 or whatever emerges as a PRACTICAL and AFFORDABLE mode, it will eventually become the standard. There is NO reason to demolish all band plans at this time to accomplish progress, any more than it was in the 1950s and 1960s. People are already legally experimenting with DSTAR, digital video, Codec2, and other digital voice emissions under the existing rules.
https://ecfsapi.fcc.gov/file/10907135173621/17-215-fcc-comments.pdf


For the most part, the rest of the filings are all from legitimate entrepreneurs and businesses, and address various private interests that have NO impact on amateur radio. Read them if you are interested, and comment during this period to have YOUR voice count. You already saw what happened in FCC WT 16-239. That all came from the ARRL in their petition RM-11708. It backfired big time, with NO band width limits in the CW/DATA segments of the HF bands. The period for REGULAR COMMENTS on OET 17-215 closed October 30, 2017. YOU can still file REPLY COMMENTS for 30 days AFTER that, until November 29, 2017.

73,
Janis
AB2RA
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