Topband: Speak Now or Forever Hold Your Peace
Bill Tippett
btippett@alum.mit.edu
Mon, 14 Jan 2002 15:39:16 +0000
Gentlemen:
It's show time at the FCC and ARRL. As President George Bush
would say, "You are either for us or against us and it's time to decide".
The above was inserted to get your attention...HI! - But, all
kidding aside, as a user and supporter of 160M, we hope at the end
of the day you will agree with us that formal mode segmentation by the
FCC on Topband, which is in complete harmony with our ARRL bandplan,
offers us all an improvement we all can live with and a rational
approach to dealing with 160M operations as we head into the new
millenium. We both respectfully ask for your support of our
RM-10352 petition.
73, Jeff K1ZM and Bill W4ZV
>***************
>The ARRL Letter
>Vol. 21, No. 02
>January 11, 2002
>***************
>
>==>FCC INVITES COMMENTS ON FOUR AMATEUR RADIO PETITIONS
>
>The FCC is seeking comments on four Amateur Radio rule making petitions
>filed recently and put on public notice this week. Comments are due by
>February 7, 2002, in petitions seeking to legally separate wideband and
>narrowband modes on 160 meters; to allow hams to bequeath their call signs
>"in memoriam" to a specific club; to expand HF operating privileges for
>Novice and Tech Plus operators; and to permit retransmission on amateur
>frequencies of NASA manned spacecraft communications.
>
>A proposal from veteran Top Band operators and contesters Bill Tippett,
>W4ZV, and Jeff Briggs, K1ZM, asks the FCC to subdivide 160 meters into
>mode-specific subbands. The petition, submitted to the FCC last September,
>has been designated as RM-10352. Tippett and Briggs contend that the ARRL
>band plan for 160 meters--modified last year after lengthy consideration by
>the ad hoc ARRL 160-Meter Band Plan Committee on which both men sat--does
>not go far enough and is unenforceable. They want the FCC to prohibit SSB,
>AM and other wideband modes below 1.843 MHz--something the revised ARRL band
>plan <http://www.arrl.org/FandES/field/regulations/bandplan.html#160m>
>already recommends.
Dear Topband Friends!
Many of you know that we participated in the ARRL 160 Bandplan
Committee last year. While we were very pleased with the resulting
voluntary bandplan, it became clear to us that the bandplan lacked the
teeth to enforce mode segmentation on 160, so we filed a Rulemaking
Petition with the FCC on September 10. Indeed, an SSB group on 1823
continued their activity after the voluntary bandplan was adopted by the
ARRL Board in July until Riley Hollingsworth sent 3 warning letters on
September 12. While we applaud Mr. Hollingsworth's actions, we remain
concerned that it may be very risky to assume that enforcement of
voluntary bandplans will stand the test of time, especially if Mr.
Hollingsworth should retire.
We believe there will be increasing pressure on the 160 CW band
as sunspots decline, more activity migrates to the low bands and as more
low-code (and eventually no-code) general class operators are licensed.
If you feel as we do that 160 CW deserves the same segmentation that
every other HF amateur band enjoys today, we encourage you to carefully
read our petition and comment to the FCC. The petition was assigned
RM-10352 by the FCC on January 8 and there is now a 30 day window for
public comment (closing on February 7). In order to make it easy for
you to read, we have posted the entire petition at:
http://users.vnet.net/btippett/rm_petition.htm
While the full Webpage including appendices appears lengthy, the petiton
itself (III on the Webpage) is the equivalent of 6 single-spaced pages.
If that is too long, you can read the Executive Summary (II on the same
page). The bottom line of our petition is that we are requesting one
simple change in FCC Part Part 97.305(c). Namely, to restrict wideband
modes (phone and image) to 1843-2000 which is consistent with ARRL's 160
Meter Bandplan and with all 3 IARU Regional Bandplans. All other aspects
of ARRL's voluntary bandplan are entirely adequate "as is" in our opinion.
The FCC will accept comments for 30 days and there are three
methods to do this. The simplest method is to post your reply on
this Webpage:
http://gullfoss2.fcc.gov/cgi-bin/websql/prod/ecfs/upload_v2.hts
Simply enter RM-10352 in box #1 (CAUTION...enter RM and NOT rm as it
is case sensitive!), fill in all the non-optional boxes (3, 7, 8, 9,
10 leaving COMMENT as is in 12) and then click "Send Cover Sheet to
FCC". After the screen is changed, you can now send a BRIEF COMMENT
(bottom box on page) simply by typing in your statement but remember
to hit "Enter" or "Return" on your keyboard at the end of each line
in the box. When you are finished, click "Send Brief Comment".
That's all there is to it!
If you prefer to submit via E-mail, it is clearly described here:
http://www.fcc.gov/e-file/email.html#datareq
You just send an E-mail to ecfs@fcc.gov with only the following in the
body of the message:
get form youraddress@yourISP.net For example:
get form K1ZM@aol.com
You will then receive two messages from the FCC robot. One is "ECFS
E-Mail INSTRUCTIONS" and one is "ECFS E-Mail Form". The format is
fairly simple but must be followed precisely. We included an example
below to help guide you. Simply fill in the "ECFS E-Mail Form" that
you receive from the FCC robot, add your comments in plain text after
<TEXT>, and send the E-mail to ecfs@fcc.gov (***IMPORTANT*** Leave
the Subject in your E-mail BLANK or RM-10352...if the words "Get Form"
which is in the response form you receive from the FCC are left in,
your message will not be accepted!) You should then get a confirmation
with 2 lines like this if the robot accepted your comment:
ECFS Received your Submission/Request at 01/09/2002 19:36:14 Eastern Time
ECFS Accepted your Submission at 01/09/2002 19:36:28 Eastern Time
If you have any problems, or need to turn off HTML in your
E-mail (FCC accepts "plain text" only), please contact Bill W4ZV at the
address in "From:" at the top of this page and he will be happy to help
you through the process. If you cannot turn off HTML (some AOL users),
send your post to Bill and he can remove the HTML and submit for you
in plain text...just send your message to him instead of ecfs@fcc.gov
BEGIN EXAMPLE************************************************************
ECFS - E-mail Filing
<PROCEEDING> RM-10352
<DATE> 01/09/2002
<NAME> William R. Tippett
<ADDRESS1> P.O. Box 37
<ADDRESS2>
<CITY> New London
<STATE> NC
<ZIP> 28127
<LAW-FIRM>
<ATTORNEY>
<DOCUMENT-TYPE> CO
<PHONE-NUMBER> XXX-XXX-XXXX
<DESCRIPTION> Email Comment
<CONTACT-EMAIL> btippett@alum.mit.edu
<TEXT>
Dear FCC:
Subsequent to filing our petition on September 10, 2001, Mr.
Riley Hollingsworth issued 3 FCC enforcement letters on September 12.
Three amateur stations were consistently violating ARRL's Voluntary 160M
Bandplan adopted in July by using SSB on 1823 kHz (below the Bandplan
limit of 1843). I feel this underscores the need for a change in FCC
law which is not dependent upon voluntary compliance. In addition to
benefits already stated in our petition, I believe adoption of RM-10352
will reduce the future workload for the FCC's enforcement branch.
Sincerely,
William R. Tippett W4ZV
END EXAMPLE************************************************************
The last method is via US Mail and that procedure is described
on ARRL's Webpage at:
http://www.arrl.org/FandES/field/regulations/news/filing_hints.html
(NOTE: I discovered this page has incorrect address info and ARRL should
be updating it Monday...if the very bottom of the page says:
"Page last modified: 10:46 AM, 19 Mar 2000 ET"
please wait until the corrections are made)
That's all there is to it. Please take a few minutes NOW to
carefully read our petition and, in your own words, make comments to
the FCC. As someone once said "Speak now or forever hold your peace".
We would also like to note that the ARRL Board of Directors will
be discussing RM-10352 during their meeting at the end of this week. In
addition to filing comments with the FCC you should give any comments to
your ARRL Director before their meeting. You can contact your director
by sending an E-mail to hiscall@arrl.org. If you don't know his call,
they are listed in the front of QST and here:
http://www.arrl.org/divisions/
73 & TU,
Jeff K1ZM and Bill W4ZV