Comment periods are now over for RM-11305. The overwhelming majority of comments were against RM-11305.
This is taken right from RM-11305 on the FCC site:
"This petition is centered on the premise that all operating interests and emission types enjoy equal status in the amateur service, with emergency communications taking priority. Operation of an amateur station includes a "listen before transmit" function that involves searching for a vacant spot on the dial. Recognizing that all non-emergency communications are of a hobbyist and experimental nature, we propose access to any vacant frequency for any amateur activity within the scope of privileges granted by license class."
Who They Are
The Think Tank is a small group of amateurs, mostly AM operators, who live around the Midwest.
What They Want
The self-anointed "Think Tank" is asking ALL FCC regulations and restrictions of who-does-what-where, within a license class, be removed!!! Anywhere you decide to set your dial you would be free to operate any mode.
Now don't get me wrong, I love Boatanchors and enjoy some AM operation. But the fact is we probably really don't want people operating any rig with any bandwidth on any mode on any frequency the owner chooses.
They submitted a petition for rule making that would deeply affect all HF operators even though they freely admit the submission was flawed and was not completely thought through.
What This All Means
Imagine what could happen if someone decides to start an AM or SSB net on 3510, 70205, 14025, or on a PSK frequency?
Let's consider what anyone could legally do as an Extra class holder if RM-11305 is adopted as written. The following is the result of RM11305 passing:
I like AM phone, and I could go on any mode anywhere on any amateur band. There would be no FCC restrictions. What I do would be up to my own good nature and judgment. It's early in the day, the band is pretty dead. I decide to start talking to my buddies 200 miles away on 7015 kHz AM. We get in a 10 minute per transmission roundtable, and the occupation of the frequency lasts well after sunset. During that time, my Viking I driving an amplifier is occupying from 7000 to 7030 kHz with a -50dBc or stronger signal at 1500 watts PEP. I now legally raise the noise and QRM floor substantially for anyone operating between 7000 and 7030kHz or higher. I have effectively shut down the entire useable 40M long distance CW portion. No one can do anything about it! I was there first, so the channel is mine.
My friends want to try a new mode. We go to 14,035 KHz FM and operate until daylight on a puny band with 15kHz wide FM. Since we were there first, or at least we thought we were, we stay long after the band opens to Asia. Even if we knew better, we could simply pretend we were there first and deny all requests to move. We could take out 14,027 to 14,043 kHz over much of the world with 1500 watt FM signals and be legal.
If you are on PSK working a PSK station and I can't hear you or recognize your signal, I could open right up with 1.5kW SSB or worse yet with 1.5kW PEP HiFi AM right on top of you. It would be up to you to get my attention and ask me to move, and up to me to be a "nice guy" and move.
If I hear a SSB station on 3500kHz USB, and wanted to work him....I could. Never mind that W3AAA is trying to work a European on 3505 and the IM3 products of my transmitter at -33dB PEP have placed a 3/4 watt SSB splatter on 3505.
In my opinion, the above scenarios coupled with the obvious attitude of supporters is what makes this proposal moronic. No intelligent thoughtful considerate amateur operator would ever think amateur radio would benefit or improve by allowing any operator to operate any mode on any frequency within his class of license, yet this is what RM-11305 asks for!
A west coast amateur said it best in the following comment from the Topband Reflector:
"Any self-appointed group that has the arrogance to call themselves the
"Communications Think Tank" gives me the shivers to start with, but the
content of their proposal lays waste to even the pretense of intelligent
thought. I'm not at all against change in our hobby, and I'm willing to
accept the fact that change might come in the form of regulations that
negatively impact my own operating preferences. I'm trying to keep an
open mind on RM-11306 from the ARRL (band allocations by bandwidth), but
RM-11305 from the "Communications Think Tank" is just plain stupid.
Here's an excerpt from the filing:
"Our proposal, if approved, would reduce potential friction among operators
when bands are in heavy use and congested, especially during contests.
Greater flexibility in selection of operating frequencies will enhance
cooperation between those who choose to participate in organized operating events and those who do not."
What kind of thought process could come up with that conclusion?
RM-11305 goes on to suggest that the ARRL and the Official Observer
system would establish and enforce new and flexible voluntary band/mode
plans ... as if any of that has ever worked well in the past.
WD8BIL appears to be the leader/spokesman of the "Communications Think
Tank", and this quote from him (per Amateur Radio Newsline Report 1455
dated July 1, 2005) might give some insight into the real intent of the
"Under heavy - for example - phone operation right now,
particularly on some of the lower bands where overcrowding in the peak
hours is just horrendous it gives us the opportunity to spread out into
areas of the bands that are under utilized."
RM-11305 is so silly I find it difficult to believe the FCC would give
it serious consideration, but who knows these days."