Posts Tagged ‘FCC’
Filed as #satire #humor #fakenews
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The FCC has invited public comments on two proposals to change the licensing requirements for amateur radio operators. Both of these proposals are aimed at attracting and retaining new amateur radio licensees.
The first one is the “Tyro” license proposal from Gary/AD0WU that creates a new license class with minimal licensing requirements and operating privileges on the 70 cm band. See the complete proposal on the FCC website.
I find this proposal severely flawed with way too many details that would need to be written into Part 97. For example, the proposal establishes 99 specific repeater/simplex channels in the 430 MHz portion of the band. Oh, and the repeaters use a non-standard 9 MHz offset. There’s lots more in the proposal that make it a non-starter.
Still there is a nugget of an idea in here: a GMRS-like entry-level amateur radio license that is super easy to get. This could be an easy-peasy gateway into ham radio for kids, spouses and family members. However, I expect the FCC to just dismiss this petition without serious consideration.
The second proposal is from the ARRL (see this ARRL news item):
The FCC has invited public comments on ARRL’s 2018 Petition for Rule Making, now designated as RM-11828, which asks the FCC to expand HF privileges for Technician licensees to include limited phone privileges on 75, 40, and 15 meters, plus RTTY and digital mode privileges on 80, 40, 15, and 10 meters.
The proposal would “add limited High Frequency (HF) data and telephony privileges to those currently available to Technician Class Amateur licensees.” The objective is to sweeten the Technician privileges to both attract new licensees and to retain existing Technicians (and maybe get them interested in moving up to General). There is an assumption/belief/hope that providing some HF telephony and digital privileges will accomplish these goals.
I am disappointed in the lack of data-driven analysis in support of this proposal. The ARRL filing claims that they “studied the comparable entry level license class operating privileges of other countries” but provided no data. There are different licensing schemes around the world…maybe we should compare and learn something from them. The data they did provide was survey data of ARRL members…which is really just an opinion poll: what do you think we should do with the licensing structure? This is not a great way to create public policy.
What’s the Objective?
Let’s start with the objective, which the ARRL petition says is “developing improved operating capabilities, increasing emergency communications participation, improving technical self-training, and increasing growth overall in the Amateur Radio Service.” I think this is a reasonable goal.
For some reason, every time there is a concern about improving and growing amateur radio, the proposed solution is a change in the licensing structure (usually to make it easier to obtain operating privileges). If the only tool you have is a hammer, everything looks like a nail. While the licensing structure should be improved over time, it should not be the first (or only) tool to apply. The ARRL needs to take a much more strategic approach to working towards the objective. Fortunately, I see positive signs they are moving in the right direction. See ARRL CEO Howard/WB2ITX Speaks.
Back To Licensing
There is a worthy idea in the ARRL proposal:
Change the entry level license (Technician) to provide a taste of HF phone and digital privileges, so it attracts more people to the hobby AND get them more deeply engaged. This might actually work.
I am not an unbiased observer because I have plenty of fun playing around with radios on frequencies above 50 MHz. I originally thought I would be a Technician for life but gradually got pulled into the fun below 30 MHz. So part of my brain says “Technicians just need to figure out how to have fun on VHF/UHF.” There is a lot to be said for having the entry level license be focused on VHF/UHF to learn basic radio operating. HF can come later.
Another part of my brain sees the excitement and growing popularity of the WSJT-X digital modes, especially FT8. Why do Technicians get to use CW on some of the HF bands but not other digital modes? That seems kind of silly in the year 2019. And making HF contacts with other states and countries on SSB is lots of fun, too.
Another question to ask is “what harm could be done by this proposal?” We could see a lot more activity in the portions of the HF bands Technicians are given. Maybe so much that those subbands get overrun with signals…seems like a potential problem. Some people have argued that giving Technicians these HF privileges will cause them to not upgrade to General. That seems like a low risk…if they get hooked on HF operating, they will upgrade to get access to additional spectrum.
There are really two assumptions in play here:
- Attract Assumption: More people will be attracted to ham radio due to the expanded Technician HF privileges.
- Retain Assumption: That Technicians will be more engaged in ham radio activity due to the expanded HF privileges (perhaps upgrading to higher license classes).
The distribution of US amateur radio licenses is roughly Amateur Extra (20%), General (23%) and Technician (50%), the remaining 7% are Novice and Advanced. So roughly half of US radio amateurs have decided to get their “VHF oriented” license while the other half have gone on to get an “HF privileged” license. Frankly, I don’t see the General license exam as a big barrier…I see people studying for it in our license classes and 90% of them are successful on the exam. But the exam is yet another thing to do, so it does represent an obstacle to overcome, just not a big one. What I do see them struggling with actually getting on the air with HF. See Getting On HF: The Fiddle Factor. Easier licensing is not going to address that problem.
Who Wants HF?
A lot of Technicians are just fine with the operating privileges they have. I even noted some Tech’s complaining they are tired of OF hams telling them they need to fall in love with HF. Interesting. I don’t have reliable data on what Technicians think but I see several types of Technicians that are quite happy with their existing privileges:
- Family/Friend Communicators – these folks are not hard core radio amateurs but they got their license to communicate with friends and family.
- Outdoor Enthusiasts – these folks use ham radio to augment their outdoor activities: hiking, biking, offroad driving, camping, fishing, etc.
- Emcomm and Public Service Volunteers – these hams are involved in local emergency response, support of served agencies (Red Cross, Salvation Army, etc.) or providing communications support for marathons, parades, charity walks, etc.
- Technical Experimenters – many radio amateurs are into experimenting with technology and the bands above 50 MHz offer a lot of opportunity for that.
I don’t know what percentage of Technicians are unconcerned about HF privileges but it is significant (half of them? perhaps more?) Providing HF privileges to this group will not have much of an effect. It seems like the ARRL should have data on this before serving up a proposal to change the licensing structure.
What do I think? I think this proposal most likely will not make a significant difference with regard to attracting and retaining new radio hams. Something else is needed to do that, such as effective training programs, strong local clubs and mentors available to help newbies get started and build skills.
But it might just work. Maybe HF is the bright shiny object that will motivate people to pursue amateur radio.
So count me as agnostic on this proposal. I won’t be filing comments with the FCC. What do you think?
73 Bob K0NR
For some reason, the FCC continues to pour money into its hell-bent roundup of FM pirate broadcasters! I suspect much of this 'tough stance' is more politically motivated than for the reasons that they state, but the FCC seems to have plenty of will-power and the necessary funding ... it's too bad that they couldn't put the same zeal into getting on top of or making a start on the huge growing noise problem throughout the radio spectrum. I guess rounding up pirates is much easier than tackling the far more important noise issues, now growing so rapidly that many radio amateurs just throw up their hands in surrender and close up shop for good. Even commercial users of the spectrum are being negatively affected by the growing noise floor, as the growing Internet of Things connected devices produce even more radio crud.
It now seems that the FCC may get a further boost in its crackdown if a new bipartisan proposed federal law becomes reality. A May 9, 2018, article in Radio World reports the tabling of the new bill in the US Congress called the PIRATE Act or "Preventing Illegal Radio Abuse Through Enforcement Act". It would also be nice to see the PAIN Act (Preventing All Illegal Noise) in the RF spectrum but I see no Washington appetite for this much-needed FCC oversight.
The continued obsession for rounding up FM pirate broadcasters is fascinating in its own right. "It is time to take these pirates off the air by hiking the penalties and working with the Federal Communication Commission on enforcement", stated Rep. Leonard Lance (R-NJ).
"As reported in Radio World, the PIRATE Act proposes to hike the fine for violations to as much as $100,000 per day, with a maximum fine of $2 million. The rules currently allow the FCC to impose a maximum daily penalty of about $19,200 per day. At a Congressional hearing on the bill in March, New York State Broadcasters Association President David Donovan told lawmakers that illegal operators are undermining the nation’s Emergency Alert System, causing invasive and insidious interference, pose potential public health problems due to overexposure to radio frequency radiation, and interfere with airport communications."
It is apparent from reading investigative reports, that each acted-upon complaint requires a substantial investment of time and money as in the April 24 Notice of Apparent Liability for a case in Paterson, New Jersey ... it seems that NJ and NY are 'pirate hotbeds'. By the end of the investigation, a team of fully-equipped FCC field agents had visited the pirate's site(s) on eight different occasions, a considerable investment in time, energy and money. In the end, a $25,000 penalty has been proposed for the offender.
I am not a fan of illegal pirate radio broadcasting in any form but the reasons stated by the FCC for the ongoing pirate purges seem somewhat shaky. In all of the investigative reports that I've read, I have yet to find any that were reported to cause "interference with airport communications" and I question the assertion that the low power levels used by most pirates are going to "pose potential public health problems due to overexposure to radio frequency radiation". One more likely reason may be the strong lobby pressure from broadcasters who see the possible loss of advertising revenue. I'm sure that many Washington electees receive healthy campaign donations from state broadcasters as well.
Although many pirate radio ops seemingly solicit advertising revenue, overall it can't be much of a threat to mainstream broadcasters. Is it just the NAB Washington lobby that is fuelling the FCC pirate craze or is it muscle-flexing from the new administration, wanting to look tough on "crime" and radio-pirates are just easy low-hanging fruit? I suspect that it may be more of the latter.
The FCC's 'Pirate Action' postings make for interesting reading as does the fascinating Westword article on pirate radio activity in Ward, Colorado, and the recent attempted FCC take-down of stations in operation since 1997!
There's no question that a lot of FCC resources are being used to eliminate unlicenced QRM. What will it take to see the same attack on unlicenced QRN as well?
In this video, I expound on another point of view regarding the ARRL petition to the FCC. The petition requests an expansion of operating privileges of Technician-class operators in the USA. The ARRL believes that giving broader shortwave access, using digital communications, to Technicians, will better entice the Techs to upgrade to General or Amateur Extra. In this video, I discuss this a bit.
If you are wondering why I’ve made a few videos about this topic, when the topic has been the hot item on many forums already, I believe that the drama will not cease until well after the FCC makes a decision, because this is a relevant topic, and one that has a significant impact on the amateur radio community at large. It is not a trivial conversation about which type of coax is best suited for Arctic field activity.
After some replies came from various viewers, I clarify my point. I stand corrected.
I failed to mention that there are a limited few slices of VOICE (SSB) spectrum on HF that the petition seeks for the Tech licensee. The ARRL states, “ARRL has asked the FCC to expand HF privileges for Technician licensees to include limited phone privileges on 75, 40, and 15 meters, plus RTTY and digital mode privileges on 80, 40, 15, and 10 meters.”
More specifically, “ARRL proposes to provide Technician licensees, present and future, with phone privileges at 3.900 to 4.000 MHz, 7.225 to 7.300 MHz, and 21.350 to 21.450 MHz, plus RTTY and digital privileges in current Technician allocations on 80, 40, 15, and 10 meters. The ARRL petition points out the explosion in popularity of various digital modes over the past 2 decades. Under the ARRL plan, the maximum HF power level for Technician operators would remain at 200 W PEP. The few remaining Novice licensees would gain no new privileges under the League’s proposal.” Reference: http://www.arrl.org/news/arrl-requests-expanded-hf-privileges-for-technician-licensees
My point holds: give some reason to desire to upgrade to a higher class. Do this by granting HF operations on lower bands (lower in frequency than 10 Meters), with more than a CW-only privilege.
If a tech can only use CW on 80m, but doesn’t know CW, then it is likely she won’t ever try making contacts on 80m. Hence, no exposure to the magic of 80-meter DX. If, however, the Tech can dabble with digital or limited SSB, on 80m, then she gets a real, practical exposure to the magic, and may well upgrade. Why do you think a General, who has limits, would ever upgrade? What am I missing here?
The following video expands this idea:
The truth is, I see a strong argument for just ONE license, permanent. Or a temporary entry-level training ticket, then the permanent. But, that would make us like some other countries. That can’t be good.
The original video to which this new video continues is here:
Some viewers are asking me why I am making a video while driving. They try to convince me that talking while driving is too distracting. My answer is here:
73 de NW7US
I have my opinion on ARRL asking FCC to grant more HF privileges to Technician-class licensees.
I verbalize them in this video:
After you hear my comments, please leave your comments.
Thanks, 73 de NW7US dit dit
It seems like the FCC's recent interest in doing an in depth study of the growing RF spectrum noise floor has taken a new twist.
The FCC's apparent lack of real action in gathering the data needed to make serious inroads into RF noise pollution has drawn the attention of the ARRL, which voiced their concerns in a recent ARRL Letter as well as in their formal response to the FCC.
In response to the FCC's Public Notice (ET Docket No. 17-340) Spectrum Management proposals.
The ARRL "took the opportunity to strongly urge the FCC to reinstate a 2016 TAC noise floor study, which, ARRL asserted, apparently was terminated before it even got started." It would seem that the proposed in-depth study never even happened and the term 'noise' has morphed into an 'interference' issue!
The FCC's paper proposed a number of guiding 'principles' in going forward with spectrum management policies, loosely based on the concept that more emphasis on eliminating 'interference' should be placed on receivers along with continued development of transmitter spectral purity and that with increased spectrum crowding, users will simply have to expect and accept certain, as yet unspecified, levels of interference!
It sounds suspiciously as if the FCC has decided that the source of any noise / interference problems have become too large to control and have passed the buck to equipment manufacturers in order to solve the growing problem for users!
“Indeed, it is difficult to imagine how the Commission can now…suggest the adoption of specific spectrum management principles, incorporating such concepts as receiver immunity, HCTs [harm claim thresholds], and interference temperature determinations without having…a firm grasp on ambient noise levels in basic RF environments and geographical areas,” the League told the FCC.
In their series of guiding principles relating to 'interference realities', the FCC has issued a number of broad, somewhat ambiguous statements, that might be interpreted in any number of odd ways ...
"Principle #1 -- Harmful interference is affected by the characteristics of both a transmitting service and a nearby receiving service in frequency, space or time;
Principle #2 – All [radio] services should plan for non-harmful interference from signals that are nearby in frequency, space or time, both now and for any changes that occur in the future;
Principle #3 – Even under ideal conditions, the electromagnetic environment is unpredictable. Operators should expect and plan for occasional service degradation or interruption. The Commission should not base its rules on exceptional events;
Principle #4 – Receivers are responsible for mitigating interference outside their assigned channels;
Principle #5 – Systems are expected to use techniques at all layers of the stack to mitigate degradation from interference;
Principle #6 – Transmitters are responsible for minimizing the amount of their transmitted energy that appears outside their assigned frequencies and licensed areas;
Principle #7 – Services under FCC jurisdiction are expected to disclose the relevant standards, guidelines and operating characteristics of their systems to the Commission if they expect protection from harmful interference;"
The ARRL response argued that:
“Requiring better performance from receivers or RF-susceptible devices is a valid, reasonable, and long overdue requirement,” ARRL said, “but the major goal of doing so should be to prevent instances of interference ..."
Specifically they argue that amateurs are unique users and able to recognize harmful interference beyond their control and should not be subjected to the same restrictions (ie. get ready to accept new levels of yet undefined interference levels) as commercial users.
"ARRL argued, however, that the Amateur Service should not be subject to receiver immunity standards, because licensees employ a wide range of propagation, emissions, bandwidths, power levels, receivers, and antennas, making any receiver performance standards arbitrary and compromising the Service’s experimental nature. They also are able to differentiate between interference from nearby spurious or out-of-band signals and that caused by receiver deficiencies. The HCT concept does not fit the Amateur Service particularly well, either, the League said; any interference hams suffer from each other is resolved cooperatively. Brute-force overload also occurs occasionally but is resolved by licensees without FCC intervention."
The ARRL seems somewhat forgetful when it comes to several long-standing complaints of inappropriate amateur-generated interference and bad behaviours which have been ignored for far too long ... problems well beyond 'cooperative resolution' by affected amateurs.
Although the ARRL does agree with many of the FCC's proposals, they doggedly insist that the FCC's apparent quashing of their original noise data investigations is critical to going forward:
“That, in ARRL’s view, is a big mistake,” the League contended. “No system of spectrum management incorporating [harm claim thresholds] and receiver immunity levels can be accurately implemented” without the noise study data.
“That study is more important now than ever before,” ARRL concluded, “and it is increasingly urgent as a prerequisite for any new spectrum management policies.”
With Washington's drastic cutbacks in FCC field-office investigators and overall budget trimming, it seems that the FCC is still relentlessly driven to eradicate all forms of illegal (pirate) broadcasting. It's a pity that they don't display the same zeal for dealing with the illegal imports and distribution of the offshore equipment that is quickly killing our ability to hear anything on the ham bands ... without selling-off and moving to several acres in the country.
The FCC has authorized amateur radio use of the 630 and 2200-meter bands, effective October 16, 2017, providing registration procedures have been followed and no objections are received within 30 days.
The PLC (Power Line Communications) database is live and hams may begin registering immediately. They may begin operating on 472 kHz (630 meters) and 137 kHz (2200 meters) as early as October 16 if they register today and receive no objection in the next 30 days. Hams may not operate on the bands without going through this process.
Please fill out the UPC Form, today, to register your station, even if you don’t have any plans on transmitting on these new bands.
It is imperative that all amateurs register, even if they don’t plan to use these bands in the near future, as the FCC rules prohibit UTC (the Utilities Technology Council) from deploying PLC in these bands closer than one (1) kilometer from registered stations. Registration now will protect your ability to use our new MF/LF bands in the future.