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By David Sumner, K1ZZ
ARRL Chief Executive Officer
April 1, 2005
Editor's note: Typically, only ARRL members get to read the "It Seems to Us ..." editorials that run each month in QST. We're posting this editorial that appears in the April, 2005 issue of QST in the hope that both ARRL members and nonmembers might appreciate it and find it informative.
At its January meeting the ARRL Board of Directors resolved several of the outstanding issues concerning our planned petition to the FCC to regulate Amateur Radio subbands principally by signal bandwidth rather than by mode of emission. At least two issues remain. The petition will not be filed until they are also resolved--probably in the latter half of the year, and certainly not before then.
To recap briefly, in July 2002 the Board decided that the ARRL would petition the FCC to regulate subbands by bandwidth instead of by mode "at the earliest practical opportunity." At the time this was essentially a statement of principle, since there were many details to be worked out before a petition could be submitted. What led to the decision was set out on this page in the September 2004 issue. The driving force was the realization that rules written in the days of mechanical teleprinters are ill-suited to regulating present and future digital modes. Detailed information on the draft petition is available at http://www.arrl.org/announce/bandwidth.html.
Since then, turning the principle into reality has consumed a lot of the time and attention of ARRL volunteers and staff. The purpose of the September 2004 editorial was to invite members to review and comment on the work that had been done to that point. Hundreds of you took us up on the offer and provided reams of very useful input.
When the ARRL Executive Committee met last October 16 to review your input the committee found considerable support for the concept of the petition, along with constructive suggestions for revisions to reduce both the impact of the changes on current amateur operations and possible unintended consequences. The Executive Committee formulated five recommendations for changes to the draft petition:
·A segment for 3-kHz bandwidth (no phone) of 10.135-10.150 MHz to accommodate existing and planned future digital operations.
·Deletion of the word "continuous" from the description of test transmissions that are authorized on most frequencies above 51 MHz.
·Simplification of proposed changes to §97.309 to clarify that FCC-licensed amateur stations may use any published digital code as long as other rules are observed.
·Restoration of the existing rules that permit automatically controlled digital stations in narrow HF subbands.
·A rule prohibiting so-called semi-automatic digital operation on frequencies where phone is permitted below 28 MHz.
The first three of these recommendations are not particularly controversial. The change at 10 MHz is consistent with current practice; the other two are clarifications rather than changes in intent. However, the last two of the EC's recommendations set off a new round of discussion when they became public after the meeting. A few days before the January Board Meeting the Executive Committee met by telephone conference and decided to rescind its fourth recommendation. No consensus could be reached with regard to the fifth.
In its turn, the Board decided to adopt the first three recommendations but to ask the Executive Committee (the membership of which has changed in the meantime) to give the last two further study. The Board's instructions read: "The Executive Committee shall, not later than June 30, 2005, further consider and evaluate the ramifications of retaining, deleting or amending §97.221(b) and/or §97.221(c) regarding automatic control of digital emissions. This evaluation shall include, but not be limited to, the effect of these rules, and the effect of proposed changes in these rules, on APRS and other current and planned digital communications in the HF bands." The Board will review the Executive Committee's evaluation at its July meeting and will give the amended draft petition further consideration at that time.
In other words, the remaining issues have less to do with the question of regulating by mode of emission vs. bandwidth than with the question of control. Traditionally, a control operator has been required to be on duty at an Amateur Radio station any time it is transmitting. A few specific, tightly crafted exceptions have been made to this general rule to facilitate repeater, beacon, auxiliary, and automatic message forwarding operations.
§97.221(b) permits packet autoforwarding and unattended APRS, among other things, in narrow segments of the HF bands. §97.221(c) is less restrictive with regard to frequency but much more restrictive in other respects, and permits a RTTY or data station to be automatically controlled only as long as the bandwidth does not exceed 500 Hz and the station does not initiate communication, but only responds to stations operating under active (local or remote) control.
The principal issues remaining to be resolved are:
·Should the narrow segments for automatic digital operation be maintained? If so, are any changes needed?
·Should semi-automatic digital operation be allowed where phone is permitted? If so, are any new rules needed to protect other operations? If not, are some additional segments for non-voice operation at up to 3-kHz bandwidth needed?
If you have any thoughts you would like to share, please send them to bandwidth@arrl.org. Your comments will be shared with your own Director and will be reported to the Executive Committee.
To repeat: the petition has not been finalized and definitely will not be filed prior to the July meeting of the Board. Once adopted, FCC rules tend to remain in place for many years. It's worth all the time it takes to get it right.
