[CW] FCC Actions

[K0HB]

--
 ><{{{{*>    http://www.home.earthlink.net/~k0hb   



>
> In any case, this is a disaster for CW traffic nets,
> most of which operate between 3600-3675 KHz.
>
> Also bad for RTTY users.
>

Don't blame me (grin).  If FCC had taken my advice back when ARRL came up
with their misbegotten 'refarming' plan, it wouldn't have been an issue.

Here is what I said back then, and I'd say again today.

--------------------------------------------------------------

                              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 consensus, 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 innovative modulation schemes and non-traditional 
   technologies. 


Respectfully submitted, 


H. Hans Brakob, K0HB