Ham Radio -- "Below the Radar"
William Cross, W3TN, a staff member in the FCC's Wireless Telecommunications Bureau, and Riley Hollingsworth, Special Counsel for the Spectrum Enforcement Division of the FCC's Enforcement Bureau, spoke at the FCC Forum on Saturday afternoon at the 2008 Dayton Hamvention®. Cross opened by explaining just where Amateur Radio falls in the FCC's bureaucracy: "The Mobility Division of Wireless Telecommunications Bureau has the oversight of the Amateur Radio Service. We handle the day-to-day administration of the Amateur Service and some of the rulemaking activities that affect the Amateur Radio Service," Cross said. "The Gettysburg office handles applications, licensing -- including vanity calls -- and the ULS. Within the Commission, other bureaus also make rules that affect you. The Office of Engineering and Technology handles spectrum allocations and equipment issues. Our Managing Director's Office is the office that handles matters relating to fees, such as the fees relating to vanity call signs, the Debt Collection Improvement Act matters, the need for Federal Registration Numbers."
Bill Cross, W3TN
Cross divided comments into two areas: Proceedings where the Commission has issued a decision and rulemaking requests that have been filed with the FCC, but which are pending resolution by the Commission.
Calling the past year "interesting, because it has been a quiet year on the regulatory front," he said that no big rulemaking items were released. "This being an election year, there doesn't seem to be any legislation on Capitol Hill that is of direct interest or impact on the Amateur Service. This year is a good time for Amateur Radio to be flying 'below the radar,' and that's where ham radio is right now in terms of the big picture -- below the radar," Cross said. "We wrapped up a couple of Petitions for Rulemaking [PRM] that were pending and it doesn't look like (at least in the near future) there will be anything else coming out."
One of the cases the FCC issued a decision on was what Cross referred to as the Miller Order. This Order, released May 7, dismissed a PRM from Mark Miller, N5RFX. Miller sought three points: To delete the FCC's 2006 addition to how it defines data, to amend the rules to prohibit automatically controlled stations from transmitting on frequency segments other than those specified in Section 97.221(b), and to replace the symbol rate limits in Section 97.307(f) with bandwidth limitations.
"The effect of these changes," Cross explained, "when taken together, would have been, as [Miller] said, 'A small number of wider bandwidth modes, including Pactor III, would no longer be authorized.' Translating that into English, what he was asking for was 'bye-bye Winlink.' Don't get me wrong -- Winlink as a communications system seems to have become the 'Brussels sprouts of ham radio' -- you either love it or you hate it. And trying to bury it under ketchup or hollandaise sauce hasn't changed the basic like or dislike for Winlink. Most of the controversy here seems to swirl around how certain licensees use it. Some use it for a radio e-mail system. Others use it for getting weather maps while they are on sailboats in places the brave dare not go. Others use it for their personal business activities, such as buying and selling stocks. These uses are really a Section 97.113, a 'prohibited communications' question, not a technology question."
Cross mentioned that there are "some things coming down the pike that you want to keep track of. The ARRL has a pending petition, -- RM 11325 -- that requests that we amend the rules that apply to the power stations may use when transmitting spread-spectrum emissions -- BPL. The DC Circuit Court of Appeals remanded the FCC's final BPL rules. The Court did not vacate the rules, so they are still in effect. There will be another proceeding to address what the Court told the Commission it had to address."
The Northern California Packet Association has filed a request for clarification that the FCC define what is meant by the term "simultaneously" as it is used when defining a repeater. "The issue here is that in California," Cross explained, "D-STAR repeaters have been coordinated on channels that are set aside for auxiliary stations, on the basis that, because there is a delay in retransmission of the signal, the retransmission is not simultaneous, and therefore the repeating station is not a repeater." Cross said others have advanced what he calls "the duck argument: If the station looks like a repeater, if it functions like a repeater, and it sounds like a repeater, it should be treated as a repeater -- and confined to the repeater subbands. A decision on this will be coming [from the Commission] shortly."
When Hollingsworth stepped up to the podium, he spoke about what he called "the magic of radio," saying, "we need to realize the debt we owe to those who work so hard to further the goals of Amateur Radio, whether it's the Emergency Communications participants, club members, teachers, VEs, the League. One of the richest rewards in doing something is to experience joy in doing it. And with so many people working so hard on their own time to further the goals of Amateur Radio, we're all a little more free to enjoy radio and to make it fun as well as a public service."
Saying that "things have calmed down a lot in the Amateur Radio Service," Hollingsworth explained, "[that] when it comes to the Amateur Radio Service, there's one enforcement tool we need very badly and we just don't have it -- and that's straitjackets," he deadpanned, eliciting guffaws from the crowd of more than 150 people. "Some days I want to ask, 'Why can't everybody just get along?'"
Hollingsworth noted that since the 75 and 80 meter phone band has been expanded, "a lot of these regular small groups, ragchews and some of the Nets should consider "spreading out, because a lot of the regular operations every night are clumped together. Yes, there are still interference issues and interference allegations, but if everybody would spread out a little bit, now, it's going to take a real change of habit by a group that has used the same frequency for 40 years to talk across the state, but you really need to spread out and take advantage [of the band] expansion."
He also noted that interest in Morse code "seems to be higher than ever before." On the enforcement side, Hollingsworth said he has noticed "no difference in enforcement problems related to no-code, and I think I'm seeing more young people at events that I go to." He reminded forumites that only 1 percent of Amateur Radio licensees filed comments in the Morse code Proceeding. "I see the new code keys for sale here, and I always see a big crowd of people around anything related to code or code keyers. I think the interest has really peaked."
Hollingsworth pointed out a 12 year old boy who sat in the front row. When asked, the boy responded he received his license three years ago when he was 9. "The future President of the League might be sitting right there," Hollingsworth explained, pointing at the boy. "That's our future, right there, and we're depending on you. We need a lot more young people and I think that Morse code seems to interest young people -- hopefully they're getting tired of instant messengers and the Internet. Last night someone told me about a 14 year old Net Control Operator on a national Net."
Calling for "more courtesy" on the Amateur Radio bands, Hollingsworth said, "This fighting amongst yourselves is the worst thing that you can do. You have some rude operators and operators who don't care and who are hateful and bitter about life in general, but every group has that, whether it's doctors, electricians, lawyers, plumbers, whatever, every group has a certain percentage of people like that. What you have to do is to remind yourself every day to stay on the high road and report to us if you can't resolve a problem after you've given it a chance to go away. There are plenty of ugly situations in the world and you don't have to add to them. Now, there are a few idiots in your Service who know all the answers, only because they haven't thought of all the questions. They just want recognition and reaction. Don't give it to them. Don't be baited. Don't feel insulted -- they are their own worst punishment. Don't dignify them with a response."
Hollingsworth implored the audience to "never let the Commission get by again with handing you 10 to 12 years of neglect. You have to stay vigilant. Even though the bands may sound better to you, you have to be vigilant to protect your Service, and be part of the solution -- not the problem -- and operate as if the whole world is listening, because generally it is."