In comments to the FCC on a series of Technological Advisory Council (TAC) spectrum management policy recommendations, ARRL said that while some of the Council’s recommendations are valid, it would be “highly inappropriate” to generalize about applying them broadly in all radio services. The comments, filed on January 31, were in response to a December 1, 2017, Public Notice in ET Docket No. 17–340. 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.
“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.
– ARRL HQ web site arrl.org 3/31/2018
For decades now, the FCC has suffered through a number of hindrances of both personnel and financial deficiencies. As a result, the FCC has not made significant changes to the Amateur Service in some time. In spite of urgings by the ARRL and others, the FCC clings to policies that technology and currently available equipment have made practically irrelevant or insignificant. One case in point is the baud rate limit for HF frequencies. Digital hams are quite familiar with this limitation and the technological ambiguity surrounding it.
It is strange that the TAC is focused on spectrum management in these seemingly un–enforceable matters when there are long standing issues still to be addressed.
Where is this new sense of urgency coming from within the FCC? I may be from commercial lobbyist for spectrum hungry business that want to peddle their brand of hardware over the interests of other services (like ham radio).
The ARRL comments to the FCC go on to say:
“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.” – see above
Is this the case? Just how is the ARRL or any other ham supposed to “resolve” deliberate, willful, and constant interference from other hams or “pirate” broadcasts. The ARRL sure does not have that authority. The FCC has “resolved” few cases of such interference over the past decade. Even then, it took months, or even years to happen.
Even the ARRL admits the weakness in the FCC Enforcement Bureau:
“ARRL also supported the creation of a public database of past radio–related enforcement activities. ‘Given the very limited, and, recently, severely diminished, availability of [FCC] field enforcement resources, it is urgent to publicize those enforcement actions that pertain to intentional or harmful interference in order to maximize the deterrence value of each one,’ ARRL said” – ARRL HQ web site
Given the minimal action on the part of that department of limited resource, it seems the database would be very small indeed – if created at all.
Do we, as the rank and file of amateur radio, sit and wait for “resolution”? Or, do we demand more responsive action from all parties (ARRL, FCC, etc). And, just how do we provoke such improvements?
One way, may be to deal with the FCC directly. Issue our own complaints in our own words. Demand our own agenda. But then again, that takes the willingness of individuals to make the effort and give it some serious thought...then write to the FCC with the concerns.
I have to believe that Chairman Ajit Pai is not ignorant nor complacent to the concerns of the Amateur Radio Service licensees. What is lacking is a loud and consistent voice from amateurs like you. Not as an irritant, but as genuinely concerned active participants in the oversight process. Without your voice, what are these five Commissioners to believe. One thing is for sure, they should not believe that everything they think is true, and right, and accepted by those they seek to govern. They need your voice in their ear to guide them. Without it, we may as well turn in our license and retire bored and idle.
The same is true for the ARRL Board of Directors. Given the last kerfuffle dusted up because of actions proposed by the board. That proposal caused concerned members to speak out to be heard. The result was The ARRL proceeded to both scold, and accept at the same time, the opinion of the members. Whether members who complained were right, correctly informed, or just upset – their voice caused action.
Abdicating our voice to others is not a solution either. Often that
abdication gives way to paths we do not want to go down. Those we entrust
with our voice often fail us. Some even become deluded by an
over–inflated sense of importance and forget whom they serve.
Tell us what is on your mind. Maybe we will publish your opinion here.
Rev. 1.00 2018-02-02 AD5XJ