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"It Seems to Us . . ." Regulation or Band Plan?

By David Sumner, K1ZZ
ARRL Chief Executive Officer
June 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 June issue of QST in the hope that both ARRL members and nonmembers might appreciate it and find it informative.


On this page in April we brought you up to date on the protracted effort by the ARRL Board of Directors to develop a petition for rule making seeking FCC regulation of amateur subbands by bandwidth instead of by mode of emission. For the second time in seven months, members were asked to comment. Hundreds of you did both times, and your comments helped clarify the issues. Many of you expressed concern about interference between incompatible modes and uses in the most popular HF bands.

Working against a June 30 deadline, the ARRL Executive Committee (EC)–the President, five Directors elected by their peers, and (without vote) the First Vice President and Executive Vice President–met all day Saturday, April 9 in Denver. The EC had a lengthy agenda, but the first and most complex item was to take up the remaining unresolved issues concerning the bandwidth petition.

As the discussion progressed it became increasingly apparent that the FCC rules are the wrong place to look for a solution to the incompatibility issue. Three guiding principles emerged:

  1. The FCC rules changes we are requesting must stand the test of time over at least the next 5 to 10 years, if not longer.

  2. We are in the early stages of a dramatic shift in amateur HF operating patterns. It is impossible to predict where this shift may lead. The FCC rules should not stand in the way of where technology takes us in our fulfillment of the bases and purposes of Amateur Radio. On the other hand, present operating modes (including AM) should continue to be permitted for as long as there are amateurs who wish to use them.

  3. The FCC rules cannot efficiently prevent conflicts in HF spectrum usage between amateurs pursuing different interests. Certainly there must be mechanisms to minimize interference between analog and digital stations, since they cannot compatibly share the same channel. However, using the FCC rules to subdivide the amateur HF bands is the wrong way to do it. It is too difficult and takes too long to change them. Responsibility for resolving conflicts must be shouldered by the amateur community itself. However, today's mechanisms for updating band plans are not adequate to the task; we need to develop and implement better mechanisms that will gain broad acceptance by amateurs and will be seen as adequately protecting their sometimes-
    conflicting interests.

Reflecting these principles, the EC is now recommending a nearly pure regime of regulation by bandwidth, dropping previous efforts to use the FCC rules to protect digital data from voice (and vice versa). This most definitely does not mean that the EC is favoring the expansion of one mode at the expense of another. All it means is that using the FCC rules as the arbiter is not the way to make the most efficient use of our limited allocations, especially when significant changes are underway. We have to find a good way to do it ourselves. The EC recommendations are presented in "Happenings" on page 72 of this issue.

Not all of the recommendations had unanimous support, but the package reflects a
consensus of the committee members. To emphasize, these are only committee recommendations. There will be ample opportunity for Board discussion prior to and at the July meeting, which means there is also time for members to share their views with their Division Directors.

The proposed framework for regulation by bandwidth takes into account existing operating patterns and requires only very minimal changes, such as shifting the 15-meter segment for automatically controlled digital stations. The idea is not to require amateurs to change how they use the bands today, but to accommodate changes in the future without having to resort to FCC rule making. At the same time, encouraging amateurs to use the minimum amount of spectrum necessary for the communications being conducted has been a basic ARRL principle since the 1920s; setting aside band segments for narrowband emissions,
200 Hz and 500 Hz respectively, is consistent with this principle.

It's been a long and winding road, but we believe we are nearing the end–at least with regard to the petition for rule making. But the discussion of how to achieve better band planning has just begun. If the FCC rules aren't the best tool for the job, we need a different one.

As we all know, radio signals don't stop at borders. Just as the FCC frequency allocations are made within a framework of international regulations, so must our decisions about how we use the amateur bands here in the United States take the rest of the world into account. Fortunately, we have a forum for dealing with international concerns within Amateur Radio: the 80-year-old International Amateur Radio Union (IARU). Each of the three IARU regions holds a conference every three years, which provides an opportunity for regular
review of band plans. The ARRL is a member of IARU Region 2 as well as of Region 3, on behalf of our Full members in the Pacific outside of Region 2.

Having said that, the EC recognizes that the existing mechanisms for reviewing and updating ARRL band plans are in need of significant improvement. Involving all of the potential stakeholders is key to gaining acceptance of the end result. Designing and implementing a process to accomplish that will not be easy, but we have the time to do it right–even if the ARRL Board decides to authorize the filing of the petition at its July meeting–while the FCC rule making process grinds forward.–David Sumner, K1ZZ



Page last modified: 09:01 AM, 11 May 2005 ET
Page author: awextra@arrl.org
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