[CW] Refarming
KØHB
[email protected]
Fri, 19 Apr 2002 05:06:24 +0100
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of )
)
Amendment of Part 97 of the Commission's ) RM-10413
Amateur Service Rules Governing )
Operating Privileges )
)
PERSONAL COMMENTS OF HANS BRAKOB, K0HB
OVERVIEW
These comments are in response to the ARRL proposal for "refarming"
the existing HF "Novice sub-bands".
I. Discussion:
The ARRL petition does not address the implementation of
new technologies as repeatedly requested by the Commission in
WT Docket 98-143. It simply proposes to eliminate the Novice
segments and reshuffle that spectrum among existing legacy
modes. Rather than gain concensus, the ARRL polling method
produced a popularity poll among several non-responsive (to
98-143) choices.
Rather than just "more of the same old stuff", I propose
that the Commission take this opportunity to provide the
Amateur Radio service with a new incentive to concentrate
on paragraph 97.1(b) of the Commission's Rules.
97.1(b) Continuation and extension of the amateur's proven
ability to contribute to the advancement of the
radio art.
While I agree that the declining Novice license population
no longer justifies several significant chunks of spectrum
as a "reservation" for improving their Morse skills, and that
these "reservations" have outlived their regulatory purpose,
I propose that we retain these 50-year old "reservations" and
convert them to a new purpose which will ensure the future
Amateur Radio service continues our "proven ability to
contribute to the advancement".
II Proposal:
A. To "de-populate" the current Novice segments, I propose
that all Novice (and Technician with code credit) licensees
be authorized to use Morse code in the same band segments
now authorized for General class licensees.
B. I propose that the current Novice sub-bands be set aside
as a new "Experimental Reservation" for non-traditional
and experimental modes such as digitized voice, digitized
image, and other "forward looking" communications methods.
C. I propose that the current power output level of 200W
be retained for those segments, and additionally propose
that transmitters in those segments must be equipped with
auto-adaptive circuitry to reduce output to the lowest
level consistent with reliable communications.
D. I recommend that the Commission grant broad discretion
to amateurs operating in this "experimental reservation"
as to inovative modulation schemes and non-traditional
technologies.
Respectfully submitted,
H. Hans Brakob, K0HB
1610 Weston Lane
Plymouth, MN 55447-2855
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