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Mark, K6HX recently asked what people are thinking regarding the “looming spectrum crisis” and the various “spectrum inventory” acts that are currently winding their way through Congress. Mark and I seem to be more or less in agreement regarding what may be around the corner:

When we say that our “ham radio political leaders” should remain vigilant against possible spectrum reallocation, I think that we are shifting the responsibility (and in the future, likely the blame) to them, when the responsibility really lies with us. We as radio amateurs are simply not doing enough to justify our use of UHF+ spectrum. When we rely on political action committees to justify our use of this valuable public resource, we should be working hard to provide them with every possible justification that they can use. It isn’t Congress who is placing these frequencies in peril: it is our own inactivity which does so. If we lose 1.2GHz, or 220Mhz, or any of our other allocations, it will be because we frankly aren’t using them enough. If I thought that these frequencies could be effectively used to give Internet broadband to millions of underserved Americans, I’d have to say “take those frequencies, we will miss them, but we had our chance with them”.

Mark hits the nail right on the head with this statement. If we lose any bands it’s our own fault for lack of activity on them. While I don’t think 70cm (think PAVE PAWS) and below are in danger, everything else is fair game, and this includes my beloved 33cm. I am very much a “life begins at 50MHz” kind of amateur and I wish we would see more use of the GHz bands, especially 12cm (2.4GHz) but I realize that most Hams hardly venture above 148MHz, and 95% of the experimentation in the community is below 30MHz. What does this mean when the Feds come knocking on the ARRL’s door asking for spectrum?

Game Over Man! Game Over!

Amateur Radio, in its current state, cannot justify the spectrum it’s given. Period. Full Stop. No amount of wharrgarbling about public service or what kind of value we provide is going to change that. Go ahead and read the ARRL’s Frequency Allocation page and ask yourself how many bands you’ve used in the past week, month, or year. Heck, even go back five years. I bet that most of you have never gone above 2M. Anthony, K3NG, takes an even more dower view in the comments section which I have a hard time disagreeing with:

Even if we would start using these bands more, I’m not sure that would be enough to keep them from being reallocated, even if we could get 50% of our active amateurs on them. If we calculate how many bits/hertz are currently being used in our spectrum versus what would be used if reallocated, and perhaps even take it a step further to model the geographical aspects and frequency reuse, it’s hard to objectively argue against mobile wireless use of these bands. Unfortunately we’re not going to be able to depend on the classic defense based on emcomm use or experimentation; the potential public benefit is just too great…

So, the question is, what can we do? I think we have two options, both of which, if they happen, will cause lamentations the like we have never seen across QRZ and eHam.

#1 Roll over – This is obvious. We lose, they win their spectrum, and we’re further sidelined into obscurity. While I don’t think this will happen and I’m sure that many of you agree, there is a distinct chance that the FCC will make a power grab for the “greater good” and legislate some of our bands out of existence without giving us a second look. Why? Because the amount of people served by expanded wireless service is pretty much a “no brainer” kind of decision. Since everyone on the federal level is hopping on the “broadband for everyone” bandwagon, passing off this kind of action will easily pass the “public approval” sniff test.

#2 Play lets make a deal – We play the cards we’ve been given and we proactively start making plans to give up bands and if we see the writing on the wall, we proactively approach the FCC with options. While, yes, you are correct, this approach did not work out well for Neville Chamberlain (Please note, I am *not* comparing the FCC to Hitler) we might be able to salvage concessions that guarantee the future of the hobby and bands. Give up 1.25M, 23cm, and 3300-3500 MHz for a law or something to guarantee the rest of our spectrum? I’d be OK with that.

These are not going to be easy decisions that are forthcoming if the Feds start scrounging for spectrum. I am pretty sure we’re going to lose any battle that comes to it. I think we as a hobby need to start figuring out what we are going to do now rather then run around like chickens with our heads cut off when the tax man cometh.

The other obvious part to this is that we should also start pushing the use of more of our spectrum. Why am I not seeing the ARRL start pushing for simple 2.4GHz data projects? With the demise of packet radio beyond APRS and the HUGE FREAKING SWATH OF IPv4 ADDRESS SPACE we have why don’t we see a organized effort for creating low cost homebrew builds? Instead, the ARRL is focusing on 40M while the HSMM page is so old it has dust on it. Way to go ARRL.

Mark, K6HX writes another good article regarding the NSC and ARRL letters and does some math on what we might expect to see if we tried to find evidence on Ham Radio operation while mobile:

There are only about 660,000 or so hams licensed in the U.S. The vast majority of these do not operate mobile. The vast majority of those do probably spend most of their time listening. In such a case, we’d expect that the number of accidents caused to be much lower than those caused by cell phones, even if mobile operation was every bit as dangerous as using a cell phone. The overall instance of accidents may be only 0.1% or less of the levels we see from cell phones. One study estimated that 6000 accidents might have been caused by cell phones in California in 2001. Even if ham radio were as dangerous, we might expect to see only six accidents in the entire year from ham radio operation.

Now, the are some other variables at work that would be interesting to toss around:

• A lot of amateur radio operators are older, would cause the rates to trend upwards?
• Are amateur radio operators more distracted when we have to fiddle around, find a mic, adjust the radio, etc?
• Is a study done in 2001 going to accurately reflect numbers in 2009?

However, the kicker of this whole article is not the post by Mark, but a comment done by Schley Cox:

I operate mobile with amateur radio using Morse code. I copy in my head, my eyes never leave the road in front of me and my right hand (sending hand) is not more than 2 inches from the bottom of the steering wheel. I tune my radio by ear only. I work a narrow range of frequencies without ever looking at the radio. Compare all these situations with using a cell phone, or even a mobile radio using a microphone.

My right and left brain don’t have much to do with each other and it doesn’t seem distracting to me to both send and receive Morse code while driving on stretches of highway. If I need both hands on the wheel while sending I simply send AS and the other operator knows to wait for a while. I don’t have to explain to her (or him) why I am stopping sending.

I don’t operate at all on busy highways. Period. There’s not even time to send AS somewhere (like I-65) while careening between lanes at 80 mph trying to keep from getting rear ended by the rush behind.

Holy crap, where do I begin? Mark makes the statement in a later comment that “This is precisely the kind of argument that I think we should all view with skepticism.” and I wholeheartedly agree. I’m scared the Mr. Cox can think he can do CW in his head and fully concentrate on driving. I will give credit to him for at least realize that doing it on a busy highway is bad, but I hope he isn’t sharing the road with me while I commute. Mark is right to point out that distractions come in all different shapes and sizes while driving: people in the car, twiddling the A/C, and using a mobile phone. It’s foolhardy to think that we are somehow above all that.

Late in July, the ARRL wrote a letter to the National Safety Council regarding the operation of amateur radio while mobile. Joel Harrison, W5ZN, president of the ARRL wrote lobbied (lets not kid ourselves, that what the ARRL does) the NSC to help them ensure that Amateur Radio is not caught up in no-cell-phones-while-driving laws by waving the bloody shirt of public service.

Amateur radio operators provide essential emergency communications when regular communications channels are disrupted by disaster. Through formal agreements with federal agencies… Amateur Radio volunteers protect lives using their own equipment without compensation. The ability of Hams to communicate and help protect the lives of those in danger would be seriously hindered if… governments do not ensure that Amateur Radio operators can continue the use of their mobile radios while on the road.

Now, don’t get me wrong. I use my FT-7800 in my car on an almost daily basis. I am by no means innocent and I did write my representatives when Massachusetts tried to pass a cell phone ban in 2008. It’s my hobby, I enjoy it, and in the car is the only time I get the “play radio” for the most part. I enjoy talking to my friends via it. I try to be responsible, however, I think that if anyone tells you that they are 100% concentrated on driving while they are playing radio, they’re a bold-faced liar.

President Janet Froetscher of the NSC’s response is very political and does a great job at walking right down the middle by giving a response without giving a response. While everyone is touting the NSC’s statement saying that “NSC does not support legislative bans or prohibition on [amateur radio] use” and counting it as a victory, however, the letter from the NSC says some very different things:

We are not aware of evidence that using amateur radios while driving has significant crash risks. We also have no evidence that using two-way radios while driving poses significant crash risks. Until such a time as compelling, peer-reviewed scientific research is presented that denotes significant risks associated with the use of amatuer radios, two-way radios or other communication devices, the NSC does not support legislative bans or prohibition on their use.

Sounds like we’re in the clear, right? Well, kind of. Indeed, there is no evidence that using two-way radios while driving poses significant crash risks, but what evidence are we citing that shows there isn’t a link? From the ARRL policy statement on mobile operation:

is aware of no evidence that [mobile] operation contributes to driver inattention. Quite the contrary: Radio amateurs are public service-minded individuals who
utilize their radio-equipped motor vehicles to assist others, and they are focused on driving in the execution of that function.

Hmmm… That doesn’t sound like compelling, peer-reviewed scientific research to me. What did the ARRL present in their letter to the NSC?

As ARRL Chief Executive Officer David Sumner has observed based on more than 40 years of experience, “Simplex, two-way radio operation is simply different than duplex, cell phone use. Two-way radio operation in moving vehicles has been going on for decades without highway safety being an issue. The fact that cell phones have come along does not change that.”

This is, by definition, anecdotal evidence. Plus, would you really trust this if the National Association for Juggling president state that, after 40 years of experience, he observed that juggling is completely different from cell phone use and has been going on for decades without highway safety being an issue? I wouldn’t and neither should you. When I read this back in August, I did find this a bit amusing as the first thing that popped into my head is the final scene in the movie Thank You for Smoking. The protagonist, who used to lobby for the Tobacco industry, is talking to clients in a meeting regarding cell phone usage:

Gentlemen, practice these words in front of the mirror: Although we are constantly exploring the subject, currently there is no direct evidence that links cellphone usage to brain cancer.

Amateur Radio is in the same position. There is currently no direct evidence that links mobile operation with accidents. The kicker is that there is no evidence that mobile operation is safe either. From what I can tell, there have been no studies regarding the issue. I think that if the ARRL was really interested in safety concerns, they would commission a third party study on this. However, like any special interest group (again, this is exactly what they are and I have no problem with it) their primary interest is promoting their interests.

Froetscher also made a statement to the ARRL that I have not seen mentioned in any coverage of the letter either:

I appreciate your focus on the use of amateur radios for emergency communications during disasters. I encourage ARRL to adopt best practices for the safe operation of vehicles that confines use of amateur radios while driving only to disaster emergencies. You may want to consider documenting this through a formal policy for all of your members.

This is the political equivalent of the NSC saying “…and the horse you rode in on.” By the ARRL using Amateur Radio’s disaster communications as a shield to hide behind in order to avoid being banned under distracted driving laws, the NSC called them out on it. If we, as amateurs,  “provide essential emergency communications when regular communications channels are disrupted by disaster”, why is the ARRL telling its members to avoid using their radios while mobile unless there is an emergency? While the obvious answer is “because we want to play radio” I don’t think the ARRL is going to say that. So, instead, since the ARRL is touting the response, I look forward to them working with the NSC to re-draft their policy to limit mobile Amateur Radio use to only emergency and disaster situations.