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By David Sumner, K1ZZ
ARRL Chief Executive Officer
October 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 October issue of QST in the hope that both ARRL members and nonmembers might appreciate it and find it informative.
At its meeting in July the ARRL Board of Directors finalized a proposal to shift from FCC regulation of subbands by mode of emission to regulation by bandwidth. This capped a process that began with the adoption of a deceptively short motion at the July 2002 Board meeting: "Moved, that at the next practical opportunity the ARRL shall petition the FCC to revise Part 97 to regulate subbands by signal bandwidth instead of by mode." Turning that general principle into specifics has occupied a great deal of attention and generated considerable debate over the intervening three years.
The reason for making the change was explained on this page in the September 2004 issue. Briefly, the rules now governing digital emissions date to the days of mechanical teleprinters and are inadequate for current and future digital techniques. The regulations need to be modernized in order to encourage and guide the development and application of digital technology in the Amateur Radio Service, while avoiding negative consequences for modes currently in use.
One of the most significant points of debate has been with regard to striking the proper balance between regulation by the FCC and self-regulation by the Amateur Radio Service itself. To what extent should the federal regulatory authority concern itself with how amateurs use their allocations?
At one extreme is the view that the FCC should only police the band edges and protect the interests of the other services with which we share the radio spectrum; the federal government should not concern itself with how amateurs comport themselves to one another, since we should be capable of taking care of that ourselves. At the other extreme is the view that because individuals can't always be trusted to do the right thing on the basis of peer pressure alone, detailed rules backed up by enforcement authority are necessary to avoid confrontation and chaos on the bands.
There is not a "right answer," with all others being wrong, to this question. Most amateurs aren't even particularly interested in the answer. We just want to know what we should do to fit in. When asked politely to move their ragchew off the DX calling frequency, most newcomers to 6 meters don't respond by demanding to know where in the FCC regulations it says they must. Enthusiasts of classic AM equipment and slow-scan television don't spread out all over the phone bands; they congregate on a few spot frequencies. Except for a few hours of intense contest activity per year, on 160 meters the overwhelming majority of phone operators stay out of the low end of the band and CW operators stay out of the high end. Most of the time, most of us don't need FCC rules to tell us to do the right thing.
The position ultimately adopted by the ARRL Board--after lengthy debate and consideration of considerable membership input--is at neither extreme. In the Board's view, the FCC Rules should encourage efficient use of the spectrum by setting aside some parts of our bands for narrowband emissions. Beyond that, however, the details of how we amateurs use our allocated spectrum generally should not be set in stone. Attempts to ration spectrum access inevitably lead to inefficient use, especially when there is no timely way to adjust the limits.
Many of the concerns expressed about the Board's action since July have reflected the view that we need the FCC to adopt and enforce rules to protect us from one another. There is another way to address these concerns: through effective band planning processes within the amateur community.
One problem with relying on the FCC Rules to define subbands is that it is very difficult and time-consuming to change them. Addressing such issues is not on the FCC's list of priorities. Another problem is that the more we ask them to do, the more difficult it is to get their attention on other matters. Finally, the more detailed are our requests for rules and the more frequently we make them, the more likely it is that the FCC--where kudos are earned for deregulation--will simply say, "Organizing the internal affairs of a radio service isn't our job. Do it yourselves."
But to be honest, our internal processes are not as effective as they should be and need to be improved. The ARRL Board clearly acknowledged this in July. The minutes of the meeting (which are available online) show that the last in a series of proposed amendments to the "bandwidth petition" motion was to add the following language: "It is specifically understood that ARRL will promptly undertake a procedure to establish a band plan to be utilized with the proposed subband allocation petition, and until such time as that band plan is in place the existing band plan will be in force." This amendment was adopted unanimously.
When the ARRL Executive Committee decides the time is right--certainly not right away--a petition will be submitted to the FCC requesting rules changes reflecting the Board's decisions. But we do not have to wait to begin discussing improvements to the process of reviewing and revising band plans. Such processes must be international in scope, because radio signals do not respect borders. They must be transparent. They must be open to broad participation and full representation. They should favor and encourage consensus-building over straight up-or-down votes, but at the same time must lead to decisions being made and not to interminable debates without resolution.
It is a formidable challenge to put together band planning processes that will earn the broad support of the Amateur Radio community, but it is important that we do so. The need exists now, and will exist irrespective of what ultimately happens to the concept of regulation by bandwidth.
