THE ARRL COMMENTS ON RM-8926 THAT'S NOTEWORTHLY

Frederick Maia in 1995 sent a purposal to the the FCC (RM-8926) to put
information bulletins above 30 MHz. This is a footnote from the ARRL
comment, and worth a read


"Maia criticizes the inherent infeasibility of information bulletin and
regular scheduled code practice from W1AW to "listen before
transmitting". The League believes the regularly published, widely
disseminated schedule of the W1AW bulletins and code practice, the
limited duration of each, and the advance warning transmissions are
sufficient to address that concern. However, it should also be noted
that such a capability, even if feasible, is not particularly
practical, given the dynamic propagation characteristics in the amateur
MF and HF bands. For W1AW operator (or any amateur radio operator) to
listen in New England before transmitting is not a guarantee against
interference to other amateur stations. If W1AW is in the skip zone of
a station transmitting, W1AW will not hear the transmitted signal. That
does not mean, however, that the intended receiving station is in the
skip zone of W1AW. Nor are electronic circuits to determine frequency
activity successful at HF. One reason is the noise level varies
constantly by both types and amplitude. It is difficult, therefore, to
discern signal from noise in these bands by use of a squelch circuit.
The problem is further complicated by the fact that HF frequencies are
not channelized, and receiver bandwidths vary from amateur station to
amateur station. These matters, however, are no more a problem for
one-way information bulletins from W1AW then they are for any amateur
station engaged in two-way communication, and do not offer any support
for the allegation that HF bulletins, voice, cw, or data, are somehow
improper on the HF bands."

ARRL comments on RM-8626 footnote #4