FCC

Filings with the FCC

To my way of thinking, only these two principles should govern amateur radio licensing:

1. Protection of the user, the public, and the environment from any hazards of electronic communications and associated equipment.
2. Protection of the limited spectrum from unqualified or inefficient usage.

These principles are reflected in these filings, to the extent that they are relevant to the subject proceedings.

Elimination of Morse Code as a licensing requirement 05-235
As of the closing gavel of the World Administrative Radio Conference 2003 (WARC-2003)
knowledge or profociency in Morse Code is no longer an international treaty
requirement for amateur radio operation below 30 MHz.
I am for the elimination of Morse Code testing for amateur licensing but favor retaining such tests for any who wish to use Morse Code on the air, as an endorsement.

Broadband Over Powerline 03-104
In the name of progress, the FCC proposes to make over-the-air frequencies from
at least 2 to 30 MHz useless by allowing widespread broadband data
transmission using existing power lines as media. This demonstrates significant
political savvy juxstaposed against weak technical competence.

Broadband over Power Line (BPL) 04-37
Nonetheless, the FCC went forward this new technology, swayed by powerful monied interests and showing their own disregard for and lack of understanding of the technical art of Radio and its intrinsic value. Realizing that it was all political and economic and not technical, and pressed for time, I filed a much shorter, more barbed and less veiled response to the actual Notice of Proposed RuleMaking (NPRM).

To see what other people say about such matters, go to the fcc.gov ECFS search page and enter just the proceeding number, like "04-37". You get pages and pages of results.

To make your own filings on these or other matters, go to FCC Electronic Comment File Submission page where you can either upload a file of pre-prepared comments, or just type them in briefly right there. They seem to leave the comment system open even after the proceedings are closed, but for your comments to count (i.e., for the FCC to be legally required to read and consider them) they must be submitted by the filing deadline, which varies from proceeding to proceeding. Surf around the site and submission pages to find out the particulars on your issue.

60 Meters 02-98
Amateur Radio has long suffered lack of a high frequency
(shortwave) band between 4 and 7 MHz (75 and 40 meters).
As a result of this action, five upper sideband only channels
were added at 5330.5, 5346.5, 5366.5, 5371.5, and 5403.5 KHz
at local midnight, 2003 July 3.

Band Plan Re-arrangement
I don't even remember filing this, but a google search for something else turned up these comments to the American Radio Relay League on how to deal with re-arranging the privileges on the high frequency bands, particularly with respect to the old Novice bands:

"One must realize that there is no longer any power in the tiny gradations of HF incentives. All of the choices you give maintain a privilege distinction between General, Advanced, and Extra which should be eliminated in the same spirit of simplification by which Novice and Advanced class licenses are no longer issued.

"Here is what I recommend:

"Above 30 MHz, all licenses except Novice have all amateur privileges. (No change.)

"Below 30 MHz, Novice and Tech Plus have all CW bands (including 30, 20, 17, 12), limited to 250 watts. General and above have all amateur privileges. Non-phone bands are reduced to 1/3 or less of the whole band. For example, 3500-3600 and 7000-7100 non-phone. 3600-4000 and 7100-7300 phone. Data modes besides CW to be counted as non-phone and shared by agreement rather than regulation. There are no longer any Extra or Advanced sub-bands. There is no need for an exclusive gathering place or special access for these classes.

"The Extra class license is distinct because of its special VE status and callsign access only.

"General, Advanced and Extra have all amateur privileges. The realization that drives this is that there are now two major categories of amateurs and three licenses. The two categories are VHF and above "local users" for which the Technician license is provided, and those who do something more, typically but not exclusively HF. General class is for these who are more serious. Extra is for the leadership but there is no need to segregate them on the air. The days when someone aspired to upgrade just to attain access to 3510 are long gone.

"An intermediate step from "local user" to "everything" is Technician with Morse credit. This still provides a little CW incentive and oppportunity for practice. The current system of little sub-bands all over HF over emphasizes HF, over complicates the allocations, burdens the licensing and regulatory processes, and presumes an appeal to upgraders that is just as out-dated as the long-gone crowds in the Novice bands are. If we're really going to re-farm the Novice bands and/or re-arrange all the bands, we need to do it with modern realities in mind. We must really learn to stop redrawing the same old charts with slightly different boundaries and to re-plan our allocations from a new perspective."

License Restructuring 98-143
The basic idea proposed by Jan Tarsala, WB6VRN, and myself was that there should be only one class of amateur radio operator license but that endorsements with additional testing be made available for specialized operations such as Morse Code, High Power, Digital Modes, Satellites, and so forth.

n5bf-at-amsat-dot-org
return to n5bf/6 Ham Radio
updated 2006 January 28