By Dave Jensen, W7DGJ

We’ve addressed the ARRL in T&E on previous occasions and it’s always a hot button topic. Whenever comments about the League show up on QRZ.com -- whether they are positive or negative -- a lengthy discussion follows centering around the organization and whether those in charge are following the “right” path. This may be natural considering the rough environment that social media engenders when a diverse group gets its juices flowing. But hey . . . that’s just part of the fun of being an amateur radio operator!

One of the focus areas for the ARRL has always been spectrum defense. I wasn’t aware of it until the last year, but the League has a separate “giving” mechanism that goes directly to this effort. Even those who argue about the many things the ARRL is doing wrong in membership rates, publishing or education would agree that advocacy/spectrum defense is not something to let up on. I’ve made a couple of small donations personally over the last year directed solely to the ARRL’s spectrum defense initiative (linked here) because I knew that these funds would go directly to an area of need.

Recently I enjoyed a conversation with a former ARRL Director, Ria Jairam (N2RJ). I noted Ria’s strong opinions on this topic and the fact that she was particularly well-informed about advocacy (and even of the history behind spectrum defense). Ria submitted her comments to me as a Guest Editorial, which I am reprinting in full in my column this issue. Please contribute to the Forum discussion at the close of her editorial and the two of us will be watching the thread as it expands.

73 for now, Dave Jensen, W7DGJ

Amateur radio advocacy – who will speak for us?

By Ria Jairam, N2RJ

We’ve heard both sides of the ARRL’s current problems (and latest shenanigans) here on QRZ. Despite the naysayers, one theme always comes out in the defense of the League – who will speak for us when the big, bad commercial interests come to take our bands?  And exactly how does advocacy for amateur radio happen . . . is the ARRL really the only game in town?

The Early Days: WW I and How Maxim Won the Day for Amateur Radio

Let’s go back to the early days when “The Old Man,” Hiram Percy Maxim, ran the show. In 1917, World War I silenced all amateur radio. When the world was finally at peace again, amateurs anxiously awaited the ‘all-clear’ so they could get their stations back on the air. Unfortunately, the Department of the Navy had other plans.

Apparently, that part of Government wanted to be the master controller of the airwaves. The ARRL, led by Hiram Percy Maxim, mobilized its membership and lobbied Congress to restore amateur radio. As a result of these efforts, amateur radio was fully restored in 1919. Without this mobilization by Maxim and his League of ARRL members, we would not be enjoying the amateur radio services as we do today.

The Modern Threat Landscape and ARRL

Today there are plenty of new threats, perhaps not of the same magnitude as in 1919, but similar concern needs to be expressed about our effectiveness to fend them off. These new threats range from outright loss of frequencies to new sharing agreements with incompatible emissions, to hefty fees for spectrum use. A small but visible example of how these can “sting” the amateur radio operator is the $35 fee now applied when going for a license. That one was courtesy of the RAYBAUMS Act, a broad telecommunications legislation that -- almost as an afterthought -- included an unnecessary fee structure for amateur radio.

So, the ARRL has indeed been there as our advocate. And I for one would applaud them for doing what they are doing in that department. But there are some nuances today which should guide our approach to advocacy.

Not Just Lawyers Talking to the FCC

It is important to remember that ARRL’s advocacy isn’t just a lawyer writing comments to the FCC. That is certainly the end-product, but it’s not where it begins in Connecticut. There is a fair amount of research involved in getting these comments ready. I have worked with ARRL’s FCC counsel, David Siddall (K3ZJ) on several advocacy matters, and from what I have observed, it always starts with a heavy dose of fact-finding and research. This may involve anything from evaluating imported radios to usage of the bands by various modes. ARRL’s band planning committee, the team with the difficult task of pleasing no one and ensuring that all are equally miserable, forges consensus and works with stakeholders on band usage. I’ve attended some of those meetings as a member; there were lots of opinions but also some very careful and considerate fact-finding. To me, this is where the real core of advocacy lies, and the ARRL does it well.

One of the biggest contributors to advocacy -- by far -- has been the ARRL Lab. What an important part of advocacy they have become! In fact, they are unsung heroes because they use science and engineering to help determine policy. The most recent example of this was the proposed use of shortwave spectrum by high frequency traders. The lab did careful evaluation and determined that their proposal would be harmful to amateur radio and other users of the bands. They provided not just the justification for opposing this proposal, but the evidence to back up their claims.

The ARRL Lab is now, more than ever, an important part of ARRL’s advocacy efforts.

The ARRL is Not the Only Game in Town – and Shouldn’t Be

Is the ARRL the only organization who should be doing advocacy? Absolutely not. In fact, the ARRL itself even encourages others to comment to the FCC and Congress. Any challenges that the ARRL faces have always included a request for others, even individual amateur operators, to provide input and assist in advocacy.

To show you how effective some of these non-ARRL advocacy efforts have been, consider the removal of the Morse Code requirement from amateur licensing. This example shows that some of the biggest changes to amateur radio policy have occurred in spite of the ARRL’s positions. Anyone who has been reading the QRZ forums as long as I have would have witnessed the huge discussion threads and heated arguments that resulted when that the “no code” policy change came about. But the ARRL didn’t initially support code test removal!

Instead, the ARRL position supported retaining the code requirement for the Extra Class license. It was Bruce Perens (K6BP) who formed an organization called “No Code International” who successfully lobbied for the code test removal for all license classes. In the end, the FCC went with that solution rather than the ARRL’s and completely removed Morse Code testing as an amateur radio license requirement. Was that a good or bad thing? [DGJ comment: Time will tell, and you can still get a good argument going on the QRZ forums with the topic.]

A 501c3 is Limited in Lobbying Efforts -- Do We Need Something Else?

The IRS places limits on certain types of nonprofits. For a 501c3 like the ARRL, lobbying cannot be its main purpose. It can do limited advocacy, but not lobbying in the Washington DC sense -- certainly without attempts to influence politicians or political candidates.  The ARRL is now involved in getting some tricky legislation passed (one of which is to help hams in homeowner associations obtain permission to put up antennas) but it is limited in these activities due to the nature of their IRS status.

Other organizations have a separate political arm, which doesn’t rely on member dues but instead relies on donations. I believe that it may be time to consider this model. A ham radio political action committee (PAC) would be free of many of the IRS restrictions that plague 501c3 organizations such as the ARRL. And if it had enough money, it could get some real lobbying done. My former ARRL board colleague, John Robert Stratton (N5AUS) has tried this idea with some success. John formed the “Texas Ham PAC” and has had some legislative victories for antenna legislation in his home State.

That’s not to say the ARRL can’t continue what It’s doing. The League has an extremely competent legal practice before the FCC. The ARRL can and should continue to advocate on behalf of amateur radio. However, we may need to shift tactics as we get deeper into legislative activity.

So -- What Can You Do?

First of all, be engaged and stay aware of any topic that can influence amateur radio. Remember that this is not just the threat of spectrum loss . . . It can also be additional hoops we are forced to jump through (such as those $35 license fees) or the thousands of dollars that the US Forest Service would like to collect from repeater owners. Also, listen for the general tenor of the FCC and how they view amateur radio in the context of public good. The ARRL does a good job at this and subscribing to their bulletins and checking the website regularly can keep you informed. The QRZ forums, particularly the News section (and maybe even Ham Radio Discussions) can be useful as well since so many issues pop up there while they are in their earliest stages. Sometimes, just rumors of changes!

Secondly, learn to put your thoughts on paper in the proper format. You don’t have to write Pulitzer Prize winning material to advocate for amateur radio, but you should keep your thoughts concise and to the point. And most importantly, on-topic. As an example of a recent FCC comment, here is something that I drafted for ARDC: https://www.fcc.gov/ecfs/document/101222568300867/1

Your input doesn’t have to be that long. For individual comments, focus on something you are passionate about and write about that. Write your own comments rather than copying and pasting the comments of others. Diversity of thought and opinions is what matters here. These comments are placed on the ECFS, which is the Electronic Comments Filing System. It’s basically a website to submit comments.

The comment period for any petition lasts 30 days from publication in the Federal Register, and reply comments are due 15 days after that. You’ll hear about an “NPRM,” which is a “Notice of Proposed Rulemaking” and they are usually the start of any rule change. The important thing you must know is the docket number for your comment, and the ARRL will list those as a news item on their website or in member bulletins.

You can put your comments up as text but you can also attach a document like a PDF. Late submissions may or may not be considered but on-time submissions are always read. At some point the FCC has to close comments, but the good news is that you’ll get at least two bites at the apple – the first is the initial comment period and there is a later reply period. Sometimes larger issues are broken into multiple parts, and in that case there is a further notice of proposed rulemaking and you’ll get an additional comment and reply comment period.

What’s Next?

Instead of just commenting in an angry discussion thread, I hope you’ll have something to write which can help you become more active in advocacy. As I mentioned earlier, starting a Political Action Committee focused on amateur radio would be a great idea. Hopefully someone gets inspired with that idea, because we sure need it -- not to replace the ARRL, but to supplement it with the lobbying that the ARRL cannot do on its own. And finally, please do support the ARRL’s advocacy efforts. They’re not the only game in town but they are a very important voice for all of us.

Until next time, 73!

Ria Jairam, N2RJ, originally from Trinidad and Tobago has been a licensed radio amateur since 1997, having first learned of ham radio in high school, being mentored by one of her teachers and then getting her license. She is a regular participant on the QRZ forums, a past District Chair of YLRL, a past Director of ARRL and a current Director of ARDC. She enjoys CW, FT8, APRS, contesting, DXing and attending ham radio conventions across the world.

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