bradk4rt at verizon.net bradk4rt at verizon.net
Thu Oct 31 23:15:11 EDT 2013

 Hello Pete,

I'm not sure we're talking about the same thing. I'm talking about IARU policy that might be used to support an argument before the 
FCC that proposes to restrict AM signal bandwidth, or other rules that would detrimentally impact AM use. I'm not talking about 
conspiracy, which I think someone referred to earlier. 

Not to say that the low level FCC staff attorneys who review the petition and comments are not smart, but to my knowledge 
NONE of them are amateur radio operators, and my perception is that NONE of them care about amateur radio because the FCC's 
focus remains on commercial telecommunications. In a proposed rulemaking affecting amateur radio, my understanding is that low 
level staff plow through all comments and summarize them in an internal memorandum, which includes a few stand-out quoted remarks 
from the comments received, then they forward that memo to the more experienced FCC lawyers up the chain who draft the recommendation 
that goes to the Commission. Understandably, the more senior FCC lawyers could give considerable weight to ARRL because it is a national 
organization, which purports to represent the interests and views of the majority of hams in the U.S. ARRL brass and/or ARRL attorney 
usually have a face to face meeting with FCC lawyers prior to the rule-making decision to argue its position in person (this has long been 

done in the commercial arena as well). That being said, ARRL's position does not always carry the day.  The individual comments from Joe 

and Jane ham, many of which represent the views and experiences of the actual spectrum and/or mode users, are given whatever weight they 

merit in the eyes of those FCC staffers who review them.   

Therein lies a danger - that at some point ARRL, which, as far as I can tell, is at best an iffy friend of AM, petitions FCC to restrict AM bandwidth 

pointing to some IARU, French, or Martian regulation essentially saying "This is the restriction placed on AM by the government of [fill in the blank] 

and therefore the FCC should adopt this regulation for U.S. hams because [fill in the blank]." If I recall correctly, I believe this was the approach used 

to eliminate the Morse Code examination requirement after ARRL attended an IARU conference and voted for the IARU proposal to eliminate that 

testing element.  The IARU policy that gave rise to this thread may not be the vehicle that threatens AM - or could it be?

Are AM operators sufficiently organized to effectively and timely respond to something like the above if it happens? Does there exist a single 

organization that could effectively (logically, scientifically and rationally) represent the views of AM operators before the FCC through the filing of 

comments in proper form and with hams who are technically and socially capable of meeting face to face with FCC?  Such will be required if

AM is indeed threatened and its meaningful preservation is to have at least a fighting chance.  Hopefully, none of this will happen - but AM 

operators must remain vigilant and question and rationally discuss such things as has been done in this thread.

Brad K4RT

On 10/31/13, manualman at juno.com wrote:

The FCC is smarter then that. Of course, I would also love to see that
argument to the FCC. I'm sure it would have to be a very carefully
crafted piece of fiction.

And, don't rule out the rest of the U.S. amateur population either.
Anyone can write a petition to the FCC to argue an adoption of any weird
idea that pops into their brain as it relates to amateur radio.

Pete, wa2cwa

On Thu, 31 Oct 2013 19:36:10 -0500 (CDT) bradk4rt at verizon.net writes:
> I think the concern is that the ARRL could point to what IARU has 
> adopted in arguing to FCC that the Commission adopt the same here 
> for U.S. hams.
> Brad K4RT 

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