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The ARRL says its request seeking an FCC declaratory ruling affirming the value of bandplans was mishandled by the FCC and misunderstood by the amateur community. In comments on RM-9259 filed with the FCC in May, the ARRL says it never intended to propose any changes to the amateur rules, and its request should not have been treated as a rulemaking petition. Unfortunately, I was unable to download the comments or replies posted on the ARRL web site listed below before I posted this. I will continue to try to access those files so I can find out what the ARRL actually intended. But for now, here is my "uninformed" opinion.
The ARRL said it does not dictate how bandplans are developed and was not asking to make specific bandplans mandatory or to accommodate certain uses to the exclusion of others. "Exactly the opposite is intended," the League's comments declared. "Voluntary bandplans should be voluntary, and adherence to them should remain voluntary. If this is actually the ARRL's standing, I don't see what the controversy is about or why they are involving the FCC since the bandplans in question are, and have been for quite some time, in effect.
The League said its only goal was to have the FCC interpret and clarify the scope of "good amateur practice" as the term is used in Part 97 of the Commission's rules. It wants the commission to affirm -- as the then-Chief of the Private Radio Bureau did in 1983 -- that, "given the widespread acceptance of bandplans in the Amateur Service, operation not in harmony with those plans, which results in interference to other amateur uses, is not good amateur practice." WHAT!? If the ARRL says the bandplans are voluntary, but asks the FCC to declare non compliance with the bandplan, NOT GOOD AMATEUR PRACTICE, isn't that the same as saying "Adherence to bandplans is mandatory for 'good amateur practice?'"
The ARRL reiterated that voluntary bandplans that enjoy general acceptance and adherence among hams are "indispensable" and a keystone to self regulation. I wonder if the problem is as widespread as it sounds from all the coverage it's receiving, or if this is another example of "squeaky wheel" politics?
The FCC's handling of the request as a rule making petition "has caused confusion in the amateur community," the League said. "This misunderstanding has led commenters to presume that to grant the request would provide absolute authority on the part of the League or to volunteer repeater coordinators" to decide bandplans with the force of rule, the League said. "Not so," the League's filing said. "Nothing gives nonvoluntary bandplans any more force or effect than is afforded by the amateur community that accepts, rejects, or modifies them." "Nothing gives nonvoluntary bandplans any more force or effect than is afforded by the amateur community that accepts, rejects, or modifies them." This is it in a nutshell. No bandplan -- voluntary or mandatory -- is going to be successful unless the amateur community accepts and uses it.
The ARRL's comments conclude by again asking the FCC to issue a declaratory ruling stating that "'good amateur practice' anticipates compliance with accepted, voluntary, international, nation, and regional bandplans adopted by cooperation and coordination among individuals and licensees."
A copy of the League's comments to the FCC is on the ARRLWeb page at http://www.arrl.org/announce/RM-9259-cmt.pdf.The ARRL's original comments are available at http://www.arrl.org/announce/RM-9259-rply.pdf. You need Adobe Acrobat Reader to see them and I couldn't get it to download. If you can get a copy of it, please forward it to me.
Should the FCC require renewal testing for Amateur Radio operators to retain their licenses? Should we be required to take a written exam for license renewal to keep the basics of "good amateur practice" fresh in our minds. This would help, wouldn't it?
Or maybe the solution lies in us taking a more serious approach to our self-regulation. Make "good amateur practice" your operating procedure ALL THE TIME.
