Unlike the ARRL I do not see an urgent need for regulatory changes in the amateur service for it to  fulfill its 47 C.F.R. §97.1(a) obligations which is a reversal to the ARRL's historical support for limited symbol rate. Like many things they are looking to deeply into the past and not enough into the future of modern digital communication capabilities. I urge you to DISMISS EXISTING RM-11708 and FCC WT 16-239.

The changes I feel that need to be made may be considered quite sweeping by some only because they have vested interests in keeping many things the same.

We need to realize that the proliferation of Software Defined Receivers along with the ubiquity of computers among operators Is a real paradigm change that the ARRL seems to not want to recognize. $20 high performance Software Defined and enabled receivers that enable reception from 100KHz to giga hertz are a fact today but because many are living through the change they are almost unaware if its significance.

Not only can we now capture and decode signals 25dB below the noise floor, we can record the messages electronically and forward them on another band or across the internet using only a few keystrokes with our computers. Our experience with disasters are that they are local. We only need one hop out of the disaster area to an internet connection to move the data digitally. While this one hop may originate from several areas in need and require several individuals hopping out of the disaster area it is still limited by the originating source where the need is. We should be using our time developing better communication capabilities and methods in addition to practicing older methods. As an example, why not FT8 “long message” vs voice for getting data out where voice may not work? 

We need to recognize modes such as RTTY to be equivalent to AM and start the push to digital modes that are both data and voice. As in the past move forward / encourage the use of new methods, discourage legacy methods that consume high power and bandwidth for the information they carry.

Not tying bandwidth and symbol rate together is a good start but identifying specific frequencies for those interested to meet up on would cluster those of like mind together. As in JT65 and FT8 for example.

With the ARRL’s comment about using Pactor I cringe for two reasons. First, Wide Band Digital , like Pactor, is something we should be going away from. We have many digital modes including digital voice on HF on the horizon that looks promising.  For digital, we get more than 10 QSO’s in just 2.5 Kc’s of Upper sideband. I assume the ARRL expects to get more advertising revenue if Pactor 4 is authorized but I would rather see a non proprietary method specified or referenced. Once again we have increasing activity in weak signal communication and the ARRL is promoting Pactor, a rearward looking technology.


I am not in favor or the Amateur Radio Parity Act of 2017. 12 H.R. 555. It seems too many ways are available for others to restrict us installing antennas that we need to operate properly. Once again this seems like the ARRL is OK with “anything” so that they can claim the did “Something” for their members.