8 April 2019

Before the Federal Communications Commission
Washington, D.C. 20554

Proceeding Number: RM-11828

Robert L. Atkinson, a licensee in the U.S. Amateur Radio Service holding an Amateur Extra Class license since 1975, and a Life Member of the ARRL, files the following comments by deadline:

Whether stated or not, one of the basic purposes of the ARRL's proposal, taken at face value at least, is to cause an increase in baseline American amateur radio activity on HF.   Informal discussions with many hams indicate that most do not find fault with this, but the devil is, as they say, in the details.   This is good news, because it means that the ARRL's proposal can work out to the satisfaction of a majority of concerned parties, provided FCC makes a few alterations.  I believe that this, along with an ARS public awareness program targeting adults in middle age, will help preserve the traditional amateur radio culture that is dying a bit every day.

However:

I question the omission of double side band full carrier (AM) radiotelephone mode privilege for the Technician class licensees on HF.  I am in favor of Technicians having all radiotelephone modes available to them on HF, that they can enjoy with their current privileges.  It is incongruous that Technicians, currently allowed to operate AM radiotelephone on all of their VHF and UHF allocations except 33 cm., are proposed to be excluded from AM should they gain analog voice transmission on HF.

I also favor them having permission to operate typically narrow data transmission modes, but as always, I prescribe a change to the rule for station identification for all modes other than analog voice and radiotelegraph, namely a programmed automatic call sign ID at the end of each transmission sent in international radiotelegraph code.  This would allow anyone with basic equipment to determine the source of digital transmissions, and should be a trivial matter to implement with modern software methods.

Robert Atkinson
FRN 2908671