Lately, ARRL Board meeting minutes have been pretty dry affairs. Not so, the minutes from the June 8, 2021 ARRL Executive Committee meeting. These minutes feature a quite lengthy and detailed summary of the FCC Counsel’s report to the committee:
6. FCC Counsel: Mr. Siddall
Mr. Siddall presented highlights of his written report, noting that FCC staff is expected to start returning to their offices in September. He recapped recent meetings and conversations covering the need for a decision in the symbol rate proceeding, application fees that are expected to go into effect by the end of this summer, the band plan, VEC matters, and confirmation, that while the FCC will require email addresses in FCC Form 605 applications, they will not be made public.
The Committee next discussed RF Safety, with Mr. Siddall noting the RF Safety Committee’s work with the FCC, especially in determining how to evaluate mobile and handheld equipment. Mr. Carlson also discussed issues regarding equipment authorization concerns, including as related to testing.
Addressing spectrum matters, he explained that in the 5.850-5.895 GHz sub-band the FCC replaced the vehicular technology primary allocation with unlicensed WiFi that does not have allocation status. Vehicular operations could require cessation of interfering Amateur operations, and did so in at least one instance despite testing in only a very few geographic areas. Replacing it with unlicensed WiFi elevates our secondary allocation to de facto primary status. Unlike vehicular uses, unlicensed WiFi operators cannot shut down interfering Amateur operations, and must themselves avoid interfering with Amateurs. While generally this has not been effective where home routers are widespread, outdoor point-to-point and point-to-multipoint operations by Wireless Internet Service Providers (WISPs) in this segment are the most likely to interfere with Amateur operations, but know that they are required to cooperate with Amateurs to avoid interference or must shut down. The elimination from the sub-band of vehicular technology, which had been intended to operate nationwide on most roads and highways, eliminated the only non-federal primary user that could require Amateur operations to shut down. (Amateur operations remain secondary to federal government operations, as always.)
Responding to a question regarding the FCC’s timeline on addressing Amateur radio-specific issues, Mr. Siddall stated that with regard to the band plan, it would be most effective to submit it when the FCC is in a “receiving mode” on Amateur proceedings.
Mr. Siddall reported that he had, at the request of the Executive Committee, contacted FCC Chairwoman Rosenworcel’s office to respectfully express the ARRL’s frustration at the failure of the FCC to resolve Amateur Radio related proceedings, some of which have been languishing at the FCC for as long as eight (8) years and to urge the FCC to move forward on the resolution of the long overdue issues that are pending in the Wireless Bureau. These include:
- Docket 16-239 (symbol rate): Initiated by ARRL petition filed on Nov. 15, 2013; assigned RM- 11708. After receiving comments, the FCC adopted a Notice of Proposed Rulemaking (NPRM) proposing to delete the 300-baud symbol rate as requested, but declining to propose any bandwidth limitation in its place. This NPRM was adopted by the Commission on July 27, 2016, comments received, and remains pending.
- RM-11828 (Enhancing Technician Class Privileges) would, among other proposals, allow the entering (technician) class licensee to engage in and learn digital and voice communication on limited portions of the HF bands below 10 meters. Petition filed by ARRL on February 28, 2018, assigned RM-11828, comments received, and remains pending.
- RM-11759 (Rebalancing the 80/75 Meter Sub-bands) would relieve congestion that is particularly bad in portions of the band. CW and digital modes are squeezed below 3.600. Petition filed by ARRL on January 8, 2016, comments received, and remains pending.
- RM-11767 (Eliminating the 15 dB HF Amplifier Gain Limit ) would delete the 15 dB HF amplifier restriction originally adopted in 1978 within a set of rules, many since repealed, that intended to prevent use of Amateur HF amplifiers by CBers. Many modern amplifiers use LDMOS devices that have greater gain capabilities than tubes, but cannot be marketed in the U.S. without modification to limit gain. This petition was filed by Expert Linears America, LLC on April 7, 2016, comments received, and remains pending. Expert Linears filed a Petition for Waiver of the same rule on June 11, 2016. After receiving comment, the Wireless Bureau denied the waiver request on Dec. 27, 2016, finding in part that ruling on the waiver request would prejudice the outcome of the petition for rulemaking by prematurely deciding the issue.
Mr. Siddall noted that there are three items ripe for final decision. The symbol rate proceeding, in which there are two issues: removal of the 300 Baud limit, and adoption of a potential bandwidth limit as a replacement. A second item ready for decision is a petition requesting clarification of the term encrypted communication as used in the Amateur rules, which was put out for comment in December, 2019. Finally, a petition proposing that more VECs be authorized was placed on public comment earlier this year and can be acted upon by staff at any time. He added that the Administrative Procedures Act (APA) requires the FCC to issue NPRMs on the remaining matters referenced above before they can be decided.
Mr. Roderick voiced his deep personal displeasure with the lack of action by the FCC on Amateur matters that are impairing the Amateur Service, saying that “it is embarrassing that American Amateurs built upon its century-old tradition of message handling by developing many of the original digital message-handling techniques currently in widespread use, but due to a 1980’s-era rule are prevented from communicating with stations in other countries using the most efficient state-of-the-art digital techniques.” Continuing, Mr. Roderick commented that even more damaging is that the 1980’s-era rule, and the delay in addressing other Amateur proceedings, some of which have been languishing for over eight years, are collectively preventing the Amateur Service from advancing the skills of new Hams in both communications and technical phases of the advancement of the radio arts. Ending his comments, he shared his belief that efforts of the Amateur Service to recruit new Hams and interest students in STEM subjects are being thwarted by the lack of FCC action on long-pending matters that the ARRL has repeatedly urged the FCC to update and allow American Amateur Operators to join the rest of the world’s Amateurs in the experimentation and development of exciting new communication modes.
Individual Members of the Executive Committee expressed similar concerns in support of Mr. Roderick’s comments. The Committee formally requested that Mr. Siddall redouble his efforts to persuade the FCC to timely act on the pending Amateur matters listed above.
It really is kind of amazing how long it’s taken for some of these rules to be approved by the FCC. I guess it just goes to show a) how low a priority that amateur radio is at the FCC, and b) how depleted the FCC staff has become.
Club support
There was also an interesting bit about clubs during the CEO’s report:
Responding to a question regarding club engagement, the Committee discussed potential incentives to recruiting and renewing members through clubs. The Committee also discussed clarifying what the expectations should be between the League and hamfests/club events that request ARRL affiliation.
I’ve often said that the ARRL is missing the boat by not giving clubs more incentive to recruit and retain new members. The incentive for signing up new members isn’t so bad ($15), but clubs only get $2 for each renewal. $2 is hardly worth the effort. Hiking that amount to $25 for recruiting new members and at least $10 for each renewal would get more clubs to participate in this program.
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