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By David Sumner, K1ZZ
ARRL Chief Executive Officer
June 1, 2004
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 2004 issue of QST in the hope that both ARRL members and nonmembers might appreciate it and find it informative.
On April 15, that most auspicious of days on the American calendar, the FCC released a long-awaited Notice of Proposed Rule Making (NPRM) and Order addressing many aspects of the Amateur Radio Service rules. In fact, the NPRM had been awaited for so long that many had forgotten it was coming and initially confused it with license restructuring, a separate issue that is a long way from the NPRM stage.
Dubbed an omnibus proceeding because it deals with a great variety of topics, the NPRM and Order disposes of 19 separate petitions for rule making and one informal request submitted to the FCC by individuals and groups, including the ARRL, over a two-year period. A dozen petitions and portions of others were denied outright because the FCC was not persuaded that the proposals were either necessary or in the public interest. The remaining proposals, along with several offered by the FCC on its own motion, have been offered for public comment with a deadline of June 15 and a reply comment deadline of June 30.
One significant proposal is the so-called "refarming" of the Novice bands. Ever since the Technician license became the route of choice into Amateur Radio and especially since the Novice license became unavailable, the HF CW bands where Novices are authorized to operate have been underutilized relative to the rest of the HF bands. Radio spectrum access is a precious resource, and it would be poor spectrum management to maintain the status quo. So, following a 2001 survey that garnered more than 4700 responses, the ARRL proposed to put the 80, 40 and 15 meter Novice bands to better use. Impressed by the scope of the survey and the volume of responses, the FCC said it had decided to propose what the ARRL had requested (although there are a few minor discrepancies in the proposed rules that will have to be sorted out). If adopted, the following changes will result:
Another significant proposal comes from the FCC itself, to eliminate rules originally adopted in 1978 to address the so-called "CB linear" problem. Opposed at the time by the ARRL and equipment manufacturers as regulatory overkill, these rules have prevented the marketing of legitimate amateur amplifiers for use with HF QRP rigs, as well as some amplifiers for 6 meters.
A proposal that originated with Kenwood Communications Corp would make it possible for amateurs to use the "Sky Command" feature offered on some Kenwood equipment. Under this proposal, auxiliary stations would be permitted to operate on 2 meters above 144.5 MHz, except in the 145.8-146.0 MHz segment that is designated by band plan for satellite operations. Of course, the rule change would apply to all amateur stations, not just to Kenwood owners, and would facilitate the operation of amateur stations by remote control.
Other proposals included in the NPRM address the following topics:
The FCC's NPRM and Order in WT Docket No. 04-140 is 71 pages long and includes much more detail than can be summarized here. Many amateurs will be interested in reading about the proposals that were denied, including several from the ARRL. The complete document is available at the FCC Web site, hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-04-79A1.doc or hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-04-79A1.pdf.
If you're interested in filing comments, read the document carefully--at least the portion that deals with the topic you wish to address--and follow the instructions. Remember that FCC rule making is not a simple nose- counting exercise; one solid argument outweighs a ream of comments of the "I support xxx" or "I oppose yyy" variety.
Of course, the ARRL will be filing comments as well. In the
coming weeks the ARRL Executive Committee, with input from the rest of the
Board, will carefully review the entire document. As always, your ARRL Director
will be pleased to hear from you about any concerns you may have.