I used to write for an engineering trade magazine, Test&Measurement World. If anything that I’d written had caused “widespread misconception” it was undoubtedly because it was poorly written, and the fault was mine. It was most definitely not the fault of my readers.
Maybe it’s just me, but everything I’ve read from the ARRL on this issue sounds high-handed. Instead of taking the blame for a poorly-written proposal, they continually try to assert that the problem is not with their proposal, but with the amateur radio community. Calling a glaring mistake an “unintentional editorial error” (isn’t “unintentional error” redundant?) doesn’t really instill confidence now, does it?
At any rate, kudos to the ARRL Board and ARRL President Joel Harrison, W5ZN, for taking a step back on this issue. Let’s hope we can build a more solid consensus next time around…….Dan
From the April 27, 2007 issue of the ARRL Letter:
The ARRL has withdrawn its controversial November 2005 Petition for Rule Making (RM-11306), calling on the FCC to establish a regulatory regime to segment bands by necessary bandwidth rather than by emission mode. The League cited “widespread misconceptions” surrounding the petition as a primary reason for deciding to remove it from FCC consideration. The ARRL left open the option of refiling the same or a similar petition in the future, however.
“The withdrawal of the petition will permit a full discussion and consideration of options at the July 2007 meeting of the ARRL Board of Directors,” said ARRL President Joel Harrison, W5ZN. “The petition then can be recast with a better explanation of its scope and the reasons for the proposed changes.”
The ARRL Executive Committee recommended withdrawing the petition when it met by teleconference April 10. The ARRL Board of Directors subsequently okayed the EC’s recommendation by mail vote.
The ARRL Board continues to support the concept of regulation by maximum emission bandwidth as a way to facilitate the eventual transition from analog to digital communication modes. ARRL CEO David Sumner, K1ZZ, emphasized that the League seeks a regulatory framework that’s “fully compatible with both narrowband and wideband analog emission modes now in common use” on the ham bands.
Sumner expressed the hope that a refiled regulation-by-bandwidth petition would “address — and hopefully avoid — widespread misconceptions” about RM-11306, either in its original form or as amended earlier this year. Irrespective of the present controversy over the petition’s proposals, he pointed out, the League repeatedly sought comment on its regulation-by-bandwidth concepts before filing its petition with the FCC.
The ARRL first sounded out the Amateur Radio community regarding regulation-by-bandwidth three years ago. A September 2004 “It Seems to Us . . .” QST editorial “Regulation by Bandwidth” followed, explaining the concept and its rationale. Hundreds of subsequent comments from ARRL members and others “helped to bring the issues on which the amateur community was not in agreement into focus.”
That led to a second editorial, “Narrowing the Bandwidth Issues,” in April 2005 QST, soliciting additional comments on the plan’s most contentious points. That drew hundreds more constructive and critical comments, and the ARRL took all input into account in developing a draft petition for the Board’s consideration. The ARRL filed the petition in November 2005, and the FCC put it on public notice in January 2006.
In all, the amateur community has posted upward of 1000 comments on RM-11306. While some comments appropriately reflected concerns about the proposed substantial shift in regulatory philosophy, others tended to reflect a lack of understanding of existing rules, of the ARRL’s proposals, or both. Some expressed the view that the League was attempting to promote or legitimize particular data modes, such as Winlink.
“The petition, in fact, had nothing specifically to do with Winlink or any other particular data mode,” Sumner maintains. “It was, rather, a means of facilitating data experimentation, which is somewhat stifled under the current rules” that apply almost exclusively to analog modes.
A major distraction in the public debate related to automatically controlled data stations, and assertions that adopting the League’s petition would permit such facilities to run roughshod over CW and other traditional modes. Sumner says automatic control is not even an essential component of the League’s regulation-by-bandwidth proposals, which would leave in place restrictions on automatically controlled stations.
Revisions to RM-11306 the ARRL filed earlier this year to accommodate changes in Part 97 that occurred since November 2005 only seemed to generate additional controversy and lead to further confusion, Sumner concedes. Those revisions would have largely confined regulation by bandwidth to the VHF and UHF bands.
One misunderstanding resulting from an unintentional editorial error in the League’s revisions gave rise to concerns that the ARRL’s proposed 3 kHz bandwidth limitation for data emissions represented an expansion of the currently permitted maximum bandwidth. Quite the contrary, Sumner explains.
“In fact, 3 kHz bandwidth would have been a new limitation, because the present baud rate limit applies to individual carriers,” he said. “Therefore, for emissions such as OFDM [orthogonal frequency-division multiplexing], which use multiple carriers, there is no effective bandwidth limit in the HF bands now.” Sumner notes that under current rules, a single OFDM signal could conceivably — and legally — occupy an entire HF band.
Harrison assured that the League intends to offer a “far better explanation” of the consequences of regulation by bandwidth before filing a new petition proposing that regulatory concept, “so that the misunderstandings that occurred with respect to RM-11306 do not happen again.”