CURRENT STATUS OF RM-11769, RM-11759, RM-11708, WT 16-239,

NEWS FLASH: FCC PSHSB 17-344: ARRL/Winlink comments at FCC Puerto Rico Hearings

The ARRL and Winlink CEO Steve Waterman have filed comments attempting to bypass regulatory procedures.

These comments seek to immediately enact WT 16-239 provisions which abolish all emission band width limits on DATA modes on HF. This will allow ACDS "ROBOT" email with unlimited band width to operate anywhere in the CW/DATA segments of the HF amateur radio spectrum. If you use FT-8, PSK, Olivia, narrow band digital modes, or CW, this is important to you. THERE IS A FEBRUARY 21 DEADLINE TO FILE REPLY COMMENTS.

See this page for more: PSHSB17344.html.

The FCC has not yet issued a Report and Order on any of these Rule Making Proceedings. This is an update to my web site to provide most current information as of August 31, 2017. I monitor the FCC and other sources daily and will post any developments here as they happen. My hope is that the efforts of all the people who filed comments overwhelmingly rejecting these ill advised measures will soon come to fruition.

RM-11769 "eliminate CW" proposal has been mostly withdrawn by the original filer, Whedbee. He still hopes to implement part of it on 6 & 2 meters, which could harm satellite, moonbounce, and other weak signal work. It would be nice if Whedbee would spend some time on the air, instead of pursuing his primary hobby of tampering legally with legitimate amateur radio. Hopefully, RM-11769 is DOA now.

RM-11759 (75 meter phone band reduction by ARRL) comment period has ended without FCC generating a NPRM (Notice of Proposed Rule Making). They still have time to withdraw it, but it is unlikely. ARRL plans to file a new petition for "Entry Level License" soon, to hedge their bet on the "free upgrade" hidden in the fine print of RM-111759.

RM-11708 FCC generated a NPRM, WT 16-239. The comment period for both has ended. The NPRM WT 16-239 has been on the books for over a year now, without a final Report and Order. This whole proceeding is a rehash of the original ARRL Petition which resulted in the wildly unpopular RM-11306, which was rejected years ago. I hope the "Stay" Petition noted below has delayed forward motion until further study by the FCC. Their decision to abolish all band width limits on HF would be a disaster for amateur radio, unless appropriately confined to special segments of any HF band.

The WT 16-239 reflects the FCC's legitimate frustration with these repetitive initiatives to commercialize amateur HF spectrum. I truly believe that FCC is at the point they were with CB years ago, when they stopped issuing licenses and gave up enforcement because abuse was so pervasive it cost too much. In the current amateur radio case, it would have been more productive if FCC were to institute a moratorium on these filings, and prevent serial abusers of the FCC electronic systems from generating petitions without some kind of screening before issuing an automatic rulemaking.

ARRL has apparently adopted the mind set "If it ain't broke, fix it til it is". There is NOTHING wrong with HF or amateur population growth that cannot be fixed without these major upheavals. WT 16-239 as FCC has written it is a NUKE that will destroy amateur radio for a large segment of the population; specifically, it will ruin any chances of NARROW BAND innovations in digital modes. A current example of this is FT8 or WSJT-X. The "Squeaky Wheel" approach the ARRL has pursued only takes you so far. Then somebody decides to replace the bad wheel bearing. Or maybe they get a whole new car. This may be ARRL's last chance to focus regulatory initiatives on UHF/microwave (which will be lost to smartphones in the next few years) before they ruin it permanently for everyone. Over 80% of the existing amateur community has decided (by not joining) that ARRL IS IRRELEVANT; ARRL needs to reinvent itself to fix THAT, instead of tinkering with FCC rules to get marginal gains of newcomers who may join once, then move on. If ARRL can limit itself only to rational meaningful reform petitions with the FCC, the FCC can probably screen out petitions from individuals who habitually file repetitive counterproductive petitions on issues that have been settled long ago. Are you listening, James? PLEASE give it a rest. Take up knitting, stamp collecting, volunteer for a legal aid society and do some real good for people who cannot afford legal help.

I'm not the only one who has reached this conclusion:

The bad news is that the ARRL is not done tinkering with HF yet. I believe ARRL is speculating that the "free upgrade" for Novice and Tech operators hidden in RM-11759 fine print may be dismissed, even if the 75 meter phone band reduction is adopted in some form. I hope the FCC dismisses the entire RM-11759 "with prejudice" to prevent any further repetition of this waste of time. ARRL plans to reintroduce their old initiatives in a new petition for an "Entry Level HF License" soon. They have conducted their "survey". There is no petition with the FCC as of today, but you can count on something before 2017 ends. There is nothing new in the current ARRL effort that was not already dismissed during the NO CODE and "Novice HF Band Refarming" FCC actions nearly 20 years ago, even after their petition to reconsider it at the time. The FCC is opposed to increasing the number of amateur classes; as a VE, I have had to deal with half a dozen different flavors or Tech license, trying to figure out how to fairly give them credit for their previous tests. We do not need another "flavor" of Technician license to figure out.

FCC stated then in

Additionally, we are declining ARRL's request that Novice and Technician Class licensees be given voice and image privileges in certain segments of the 80, 40, 15 and 10 m bands.... However, we are concerned that giving Novice and Technician class licensees voice privileges in the other HF bands would be a disincentive for these licensees to improve their knowledge and skills and attain a higher class license. Passing the thirty-five question written examination for the intermediate class of license --the General Class-- is well within the capability of most, if not all, Technician and Technician Plus licensees, particularly given the study guides and other aids available from, among others, the ARRL.. ARRL requests and removing most of the "reward" for passing the examination..
Here is why that "new" ARRL petition to change the Technician class license should never get issued a rulemaking number by the FCC: /ARRL_EntryLevelLicence.html

These are my filings on the HF petitions of the ARRL and Whedbee, as part of the FCC record.

Wayne Green, W2NSD, and 73 Magazine, we miss you.....

These are the EX PARTE filings of the respected author, Ted Rappaport, N9NB and the joint efforts of The Ad Hoc Committee on Preservation of Narrow Band Short Wave Amateur Radio Communication, and the CW Operators' Club (
  ●  Ex Parte PowerPoint™ Presentation: Docket 16-239 Final.pptx
  ●  Ex Parte Letter: exparte letter 9 25 2016.docx
  ●  Winlink Info Part 1: compilation pt1.pdf
  ●  Handout given to FCC: Winlink Handout.pdf
  ●  Winlink Info Part 2: Compilation pt2.pdf
  ●  Letter Covering Above Part 2: September 26 2016 attachment.docx

Note - Not everyone may have a way to view PowerPoint presentations (.ppt and .pptx files). You can get one free at either:
  ●  OpenOffice Impress:    - or -
  ●  Free MS PowerPoint™ viewer:


We most certainly DO need to reach out to the next generation of "makers". Perhaps a technically inclined middle school student would be interested in amateur radio for a robotics project. Many people used to obtain a Tech license for more effective control of a model airplane, and never considered voice contacts on ham radio. Does this new license promote that kind of use of amateur radio? Do they need HF to accomplish their goals, or is VHF/UHF exactly what they need? Our perception of the "glory days" of HF amateur radio back in the late 50s (record sun spot cycle) may not be what young people of today are excited by. They now have portable devices capable of chatting with anyone (anywhere on the planet), even sending photos and text. Not so long ago, a 2 meter repeater with an autopatch was a compelling demonstration of technology; many repeaters do not even offer a phone patch any more. Why would the idea of limited communicating at much slower speeds at an intermittent connection (due to sunspots) appeal to them?

The target audience for the entry level HF license would likely be a budding "maker". He will be building something or adapting an existing device to his needs. Software defined radio is just such a medium, with the opportunity to experiment with the hardware and software. To succeed, we must adapt our licensing to appeal to that person. This is the correct young person target audience we should address, because they are interested in working with RF. They will make contacts, perhaps using the new narrow band QRP mode, FT8. Maybe they will improve FT8. Those QSOs will be with other ham operators. They will be mentored and assimilate into the amateur radio culture. They will possess the technical skills required to make a meaningful contribution to the state of the art.

Emphatically, I state that we do NOT need anyone simply seeking to dodge charges for sending commercial content email by amateur radio, who will never assimilate into our hobby. They are NOT interested in "experimenting and advancing the state of the radio art" (one of the stated goals in FCC Part 97). And they will not have or ever develop the skills necessary to do so. They do have a legitimate need - better and more affordable global internet connectivity - which the FCC and global corporations need to address in the commercial radio spectrum; but amateur radio was NOT a commercial email service at its inception, nor should it ever become one. Hams definitely do not need a new group who does not understand "listen before transmit" or proper adjustment of transmitters to avoid spurious output; these are only interested in pressing "send" for their email. To them, ham radio is just an AP or an appliance, Internet CB.

Recent efforts trying to turn the amateur radio service into Internet CB, Free email, are becoming more frequent. There already is a provision for that, and it is called - wait for it - CB! NO VE TESTING either. Internet CB is actually a good idea, because it is at microwave frequencies (where it delivers useful speed), it is accessible to non technical people without a test, and repeater systems that forward COMMERCIAL CONTENT messages are LEGAL. So, if you want Internet CB, check this out:


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73, Janis, AB2RA