[Ground-station] 2200 m - 70 cm bandwidth limits

[Michelle Thompson]

Thank you Ron. These comments are excellent.

I carried the 70 cm 6 MHz bandwidth limit to the meeting and proposed it as
soon as practical. It was accepted.

We had started from 2200 m and were working "down" the chart to 70 cm.

As soon as I could, and as often as I thought tolerable, I spoke up for no
bandwidth limits at all. I referenced the wording from the R&O about
voluntary community band plans being preferable to any band-planning or
band management coming from the FCC.

I took this wording from the FCC as opening up an opportunity for us. I
tried to present it as such to the meeting attendees. This is what set my
strategy for this meeting. It was attended by a highly qualified and
motivated set of people. I am very grateful for the opportunity to
participate, and owe a thank you to David Siddall for inviting me. I would
not have known about this meeting and effort otherwise.

The FCC really does not want to be in the loop of managing implementations
of radio tech in our bands. Getting things like symbol rate and bandwidth
limits out of the regulatory framework benefits the radio service directly,
and also benefits the FCC because it simplifies regulations. Let's give
them what they want.

I tend to focus on the good. What about the bad?

Abuse exists. Bad actors exist. Control freaks exist. There are non-trivial
numbers of people that honestly believe they "own" the bands and can
dictate how this resource should be used.

This is not a positive attitude.

Bad actors and abusers can be dealt with by rules that already exist.
Enforcement is not as good as it should be, but we can improve it.
Voluntary community standards coming from organizations that exist to serve
the community (such as ARRL) are the right way forward.

We have to take ownership of our bands in order to make the most of our
radio service. Eliminating what are essentially implementation details in
the regulatory framework is a huge step forward. This is a very important
thing to do.

The responsibility for managing what's been granted to us will rightly fall
upon citizens and organizations that care and curate one of the four
fundamental forces of nature - the electromagnetic spectrum. This is such a
tremendously special privilege, and should not be squandered. We need to
bring the broadest possible constituency to this resource. It belongs to
all of us.

I looked for and took any opportunity to speak up for "none" in the
bandwidth limit column of the chart we were working off of on the slide
deck in the Zoom call. My baseline was maximum freedom.

I acknowledged Fred Kemmerer's stated concerns about highly negative
reactions to doing this from the amateur community. He didn't think we
could remove these bandwidth limits without suffering enormous backlash. I
suggested that since there would be a negative reaction *regardless* of the
ARRL's position in this comment, that "we should go long".

By saying this, I mean both the sports reference and in terms of thinking
of the future. We can honor the present and the past with technology,
available today. We actually can, and should, remove objections and go the
extra mile to reassure.

Steve Stroh had already (correctly and competently) pointed out earlier in
the meeting that we should be thinking of the future. He explained that
computing power and SDR functionality were already fully capable of "listen
and avoid" behavior. I tried to cite and reiterate what he said, because
making rare changes to regulatory frameworks with fear rarely results in
good rules. This is a very rare opportunity to make significant changes to
the regulatory framework. We have to take full, and not partial or halting
or frightened or incremental, advantage of it.

I took what Steve said and re-stated it firmly; that cognitive radio
techniques that are now 30 years old are available to us, today. We can and
should get on with it. We can do this much more easily without bandwidth
limits.

Rick Roderick K5UR spoke up clearly, confidently, and well about the role
of government. We do not want the FCC to micromanage our spectrum.

There was some discussion about modulation modes and designators, and
whether digital voice is digital or audio, and what that means for "digital
voice" on the bands.

This is a regulatory thing. Your radio emission is categorized and
regulated. The FCC tells you what particular type of emission mode is
allowed, where, in the bands.

Take a moment and glance over this list here.

https://www.apcointl.org/services/radio-frequency-management/emission-designators/

This classification system comes from the ITU.

Each type of radio emission is classified according to its bandwidth,
method of modulation, nature of the modulating signal, and type of
information transmitted on the carrier signal. The transmitter doesn't
matter - the designator defines what happens over the air.

Here's a good summary article:
https://en.wikipedia.org/wiki/Types_of_radio_emissions

Note that in every category, there is a "none of the above" to handle cases
that were not envisioned.

Several times during the meeting it was claimed that this system is
"horribly outdated". No proof was offered for this assertion.

However, if there's a potential opportunity for ORI work on updating the
emissions designator system, then let me know what you think?

Removing the bandwidth limitation dramatically improves experimental and
innovative potential for communities like ours.

What can you do to help? When the news drops - *write* about this,
*support* marketing and publicity efforts about this, and *spread* the
word.

This will be happening very soon and I'll do all I can to help get *you*
involved. Look for communications about this and please help amplify. Word
of mouth is still the best way to get ideas across, and we have an amazing
community.

Thank you for helping us achieve ambitious things!

I hope you are looking forward to 2024 as much as I am.

-Michelle Thompson



On Wed, Dec 27, 2023 at 9:56 PM Ron Economos via Ground-Station
<ground-station at lists.openresearch.institute> wrote:

> Here's my comment that I already filed.
>
> https://www.fcc.gov/ecfs/search/search-filings/filing/121888430078
>
> Basically in total agreement, although I hedged my bets a little on 6 and
> 2 meters. Also, the 97.307(f)(2) footnote should be considered. It's there
> to limit the bandwidth of video.
>
> There was one other comment filed a little early by K1JST, but also in
> agreement on 70 cm.
>
> https://www.fcc.gov/ecfs/search/search-filings/filing/1204195521733
>
> Ron W6RZ
> On 12/27/23 19:25, Michelle Thompson via Ground-Station wrote:
>
> Just concluded: a meeting about bandwidth limits on 2200 m through 70 cm
> US amateur radio bands. The ARRL recommendation to the FCC will be “none”
> across the board.
>
> Rationale Document writing to be coordinated by David Siddall.
>
> -Michelle Thompson
>
>
>
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