[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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