On Jul 30, 2:23?pm, Steve Bonine wrote:
wrote:
What *should* be done, IMHO, is for amateur organizations to do the
legwork up-front. IOW,
I think the way to do a proposal is:
1) Gather up lots of opinions from the amateur community
2) Write a draft proposal
3) Present it to the amateur community, with clear explanation of what
is proposed and why.
4) Gather more opinions by means of surveys, polls, etc.
5) Rework the draft proposal based on the input received
6 Repeat steps 3 through 5 until a proposal gets a clear and
compelling majority of support from the amateur community, and the
opposition's points are dealt with.IOW, build a consensus *first*
7) Submit the proposal to FCC, including the survey/poll results.

I suspect that that's what the ARRL thinks they're doing now.

With all due respect, it may be what they think they are doing, but
it's not what they *are* doing.

For example, was the original "Regulation By Bandwidth" proposal shown
in QST and on the website where it could be seen by all? I don't
recall that - instead, I recall it being described, but not the whole
text given out.

Was there a questionaire of all ARRL members about the proposal
*before* it was sent to FCC?

Were the results of such research published, and the proposal modified
because of it?

The problem is that on any issue that's controversial, step 6 is going
to be tough, if not impossible. Think of how hard it is to get a
"compelling majority of support from the amateur community" on the issue
of what the code requirements should be for the various classes of license.

I think the biggest part of that difficulty is lack of clear
communications.

Imagine if there had been a detailed survey of all ARRL members, or
all US hams, on that very subject back in 2003 or so.

Imagine if the results of such a survey were made public, so that
everyone could see that X percent of US hams support Y amount of code-
testing for license class Z

Imagine if a proposal were crafted to follow that information, and the
information presented to FCC along with the proposal.

And imagine if there were creative options proposed on divisive
issues. For example, look at how Canada solved the Morse code test
issue. Why wasn't something like that proposed by ARRL? (I put it in
my comments, btw).

If all that were done, FCC would assign an RM number and then be
flooded with supportive comments. FCC could then easily rubber-stamp
approval of the proposal.

Contentious issues tend to split the amateur radio community into
segments that are unlikely to agree on any single proposal. No matter
what you end up with, there is going to be a significant fraction of the
fraternity that will file negative comments.

Of course. But having a significant fraction opposed is a lot better
than having a *majority* opposed!

For example, I have to wonder whether the regulation by bandwidth
proposal died because the ARRL didn't work hard enough for consensus, or
because the amateur radio community is simply opposed to any regulation
by bandwidth proposal. I honestly don't know; perhaps if ARRL had
worked harder for consensus, there would have been less negative
comments filed.

I think it's a combination of factors.

First off, the "RBB" proposal would have allowed data modes in the
'phone subbands. A lot of hams didn't like that, even though RBB also
widened those subbands.

What really ticked off a lot of folks was that RBB would have changed
the rules on "robot" data stations.

The kicker, IMHO, was that ARRL did not do the hard work to get the
support *before* submitting the proposal. All that did was galvanize
the opposition to action.

And it's not just an ARRL problem. Look at the "Communications Think
Tank" proposal, and how much opposition it generated! Made RBB look
popular by comparison.

Then there are the comments from the NON-ham-radio community. BPL, for
example . . . there are plenty of segments that will file comments
against whatever the ARRL might come up with. There's nothing that they
can do about that.

No, there isn't. But if you look at the various Part 97 RM and NPRM
comments that have come down the pipe in the past decade or two, the
vast majority are from already-licensed hams. It's really a rare event
when a nonham sends in comments.

But doing it that way takes a lot of grunt work, time, and effort.
Also takes compromise.

And without the compromise, the work, time, and effort go for naught. I
have not observed that hams, in general, are eager to compromise.

Well, we'll have to disagree about that. What I've seen is that people
in general and hams in particular are willing to compromise *if* what
is proposed is a true compromise - which means you give some and you
get some.

For example, consider again the RBB proposal. It offered the HF 'phone
op slightly wider subbands - and the possibility of having to deal
with wide data signals from robots all over those subbands! Not a good
compromise.

Or consider the CW op. RBB offered *narrower* subbands and the
possibility of robot QRM all over those narrower subbands! (Yes, I
know CW can legally be used anywhere, but how much actual real CW
operation goes on in the 'phone subbands?)

The end result was a coalition of "NO!"

Now suppose RBB had included things like a slice of CW-only space for
the CW ops, a slice of no-data space for the 'phone ops, and a slice
of "all modes" space for everybody. The result might have been very
different.

The big mistake ARRL (and CTT, and many others) make is that they
don't really know how popular their proposals are *before* submitting
them to FCC.

Whatever is the point of *any* amateur radio group submitting a Part
97 proposal that generates 70, 80, 90% negative comments? All that
does is annoy FCC, IMHO.

73 de Jim, N2EY