[CW] Part 15 Alert

[Will White]

Several points well argued, and well taken.  Yes, I too have been guilty
sometimes of being complacent about threats to our spectrum, as for the most
part recently they have been aimed at bands that I have little interest in (432
and up). I too had assumed HF was safer than safe, and that more BW would be
forthcoming, and for a long time to come.

My perspective has been changed by the recent spate of hustles by various
"hi-tech" corporate interests for Part 15 protection. Without getting down to
cases, for the moment, which most of us are all to familiar with anyhow, I urge
everyone to be vigilant, but not paranoid, keep an eye on FCC Dockets (and take
a few minutes to submit a thoughtful comment about the value of the amateur
radio *service*) as they come up, check ARRL & QRZ web sites for alerts, and
write, phone, otherwise lobby your Reps. and Senators, FCC Commissioners and
other key Fed-people.

I think also that all of us, and the ARRL most of all since their main task on
our behalf for now is defense of spectrum, need to do a better job at digging up
and naming the industries, specific technologies, and individual companies and
trade associations that are agitating for "Part 15 protection" and other
incursions into our bands, and going further to write, phone, lobby our rivals
directly, politely, firmly. This lets them know that we hams are not just a
bunch of socially-handicapped geeks fiddling with gadgets in the basement/attic,
and that we are greater in number and more politically active and savvy than
they thought, and just maybe that keeps enough pressure on them to persue other
alternatives for their products. In most cases I have heard of, their exist
technically superior alternatives to using our bands, or parts of them, but they
either are marginally more costly, or defer because of development and
construction issues, profitability by (*gasp*) more than a fiscal quarter!
Pointing out to these companies that it is in their own longer term financial
interst to opt for quality over the fast buck, and to behave as responsible and
honest corporate citizens (seize the issues of the day!)

As for HF specifically, I think US companies may be deterred from making plays
for parts of our bands by the ionosphere and the ITU. That 5 MHz hi-speed
data-over-AC lines will leak, and will bounce around the globe, and likewise
whatever the FCC does or doesnt do, other 5 MHz signals and noise from DX *will*
get into the data lines. And there are a number of other technical issues with
HF for data/Part 15 gadgets/etc. that make me wonder whether there are any
engineers at all working for these companies, let alone *RF* engineers?!

Ultimately, as for HF and amateur radio, the lack of technical sense and
sophistication on the part of many supposed high-technology companies (who often
seem to fail utterly to understand and take account of the most basic of
electrical and electronic laws and principles and lack "low-tech" savvy at all)
may be a great boon. I have seen an number of pitches and grabs for our VHF+
bands made by the LEO satellite businesses and others be rejected flatly by the
FCC because of their arrogant ignorance, their supposition that the FCC and
current band users are dumbies and they need'nt take the trouble to do any
research and make a real argument why they sould have access to spectrum. Still,
I am going to make a greater effort now to keep up with what is going on with
spectrum issues, lest we find ourselves going down a slippery slope a bit at a
time, and I hope you do (or continue to do) the same.

73 DE WILL KD7BFX

Donald Chester wrote:

> I checked the final comments on Docket 02-98 last night, before starting on
> my reply comments. It looks like the greatest threat to
> amateur radio right now is NOT shortwave broadcasters or
> commercial/government interests who may want to reallocate our frequencies
> to other radio services. Actually, HF seems pretty deserted these days, so
> you would think there would be loads of spectrum available to us. The
> existing WARC bands could be expanded, and more new bands could be created
> all over the HF spectrum.
>
> The threat I now see is the proliferation of unlicensed Part 15 devices.
> Amongst the comments, Part 15 interests are expressing concern about ALL
> THREE of the proposed new bands; this includes the proposed 2400-2402 mHz,
> 60m and 135.7-137.8 kHz allocations. We all know about the power industry
> and power line carrier systems, but yet another industry is opposing us on
> 60m. They are trying to establish home delivery of high speed data over
> power lines. Evidently they reached some agreement with the FCC that they
> could operate if they filter out ham frequencies, but they are moaning and
> groaning about the existing systems that already use the 5 mHz spectrum,
> both because of potential interference from hams and the fact that they
> would have to shut down systems that cause harmful interference to amateur
> communication on the new band. A similar concern comes from some outfit that
> is using the UHF/microwave spectrum for some other Part 15 gadget.
>
> Part 15 devices are, by definition, supposed to operate with the prior
> understanding that they are completely unprotected. The industry knew from
> the beginning that if there is a problem from licensed services,
> satisfactory resolution is completely in their lap. But now they are trying
> to gain protection through the FCC, saying that since there so many users of
> these devices, including individuals as well as electric power distributors,
> that it would be in the public interest to extend FCC protection to
> unlicensed devices because Part 15 users are so much more numerous than
> hams. If this stuff continues to proliferate, the entire non-broadcast radio
> spectrum will eventually become tied up. There will be no need for EPCA,
> because you won't be able to receive anything through the buzzies from all
> this rubbish anyway.
>
> Use of the radio spectrum under Part 15 began with the clear understanding
> that these devices had no government protection whatever. Now unlicensed
> interests are seeking minimal protection through the FCC. It doesn't take a
> rocket scientist to figure out that as this technology expands, they will
> continue asking for more frequencies and more protection. I am already
> hearing non-powerline interference in the lower frequency shortwave
> broadcast bands and in between. How much longer before unlicensed interests
> begin lobbying to trash the ham bands as well? If nothing is done to
> discourage this pollution of the radio spectrum, it will eventually end up
> worse than LORAN ever was on 160.
>
> Don K4KYV
>

--
Will White, KD7BFX
Seattle WA US
King County, Grid CN87tq
ITU Zone 6, CQ Zone 3
***************************************************
"The wireless telegraph is not difficult to understand.
The ordinary telegraph is like a very long cat.
You pull the tail in New York, and it meows in Los Angeles.
The wireless is the same, only without the cat."
                                                      - Albert Einstein
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