FCC Denies In Part ARRL Petition on ReconRobot Waiver

[W3WN]

http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-675A1.pdf

It's only a matter of time, now, before we lose 70 cm. I had selected some pertiment quotes, but they're too long to fit in here. Suffice to say, everyone needs to read this!

Essentially all of the ARRL's concerns save one were brushed aside. The one that was granted was the request that the wording of the manual and labeling should be updated to reflect that officially & legally, the ReconScout is a secondary user of 70 cm, after the Government and Amateur services, and must accept interference from these services.

Oh, and the issue of the "uncertified devices" that ReconRobot has been selling? Refererred to the Enforcement Bureau. Uh-huh.

Now, anyone want to take wagers on how long it will be before the "secondary basis" is ignored by law enforcement, and/or the allegations are addressed by the Enforcement Bureau?

[n2ize]

What I don;t understand is this. If this ReconRobot is such an important device and is an important tool for potential life and death situations in law enforcement than why would they want to put it on a frequency where it is a secondary user and must accept interference to begin with ? Wouldn't it make sense to put it on some other frequency ? What if the device malfunctions due to interference from primary users ? Or, is it just that the company that makes it is playing on peoples ignorance ?

For that matter they could put it on the RC portion of 2.4 Ghz. With the spread spectrum technology being used up there it is doubtful that users will interfere with each other.

Of course the American government never met a corporation that it didn't like so, no surprise that are using 70 cm with the blessing of the Feces.

All in all I think it will be a non-issue. Issues of interference from/to the Recon device will probably be few and far between, if any at all. And, if the device does malfunction due to interference well, so be it. Such is the result of an inferior product that is using frequencies prone to interference from other services. Might even be a great opportunity for a competitor to market a "reliable, interference free" unit.

[PA5COR]

We in Europe see an atttack as well, our 430 - 440 MHz 70 cm band here was slashed first with LPD ( Low Power Devices) from 433.075 to 444.750 max 10 mW output, handhelds, car security systems, broadband wireless earphones, annd everything you can think off started to wash into our primary band.

Last year our version of the FCC decided to take the upper 2 MHz and downgrade us to secondary user and gave licenses to DGPS ( landbased GPS) for agricultural use out, completely laying waste there because they can use more power and vertical antenna's outdoor for a arge range.
Our repeaters there were banned ( 7.6 MHz shift) even when the neighbouring countries didn't agree with it, and kept the 2 MHz for the hams.
Lots of interference now there, the hams now upped the power and directional antenna's to the Netherlands to combat the interferece.

We can try to fight, we did, and the answer was simply "get lost" .

Looks with the attacks on 23 cm we will loose the higher frequencies to the commercial users, add the interference of the modems working on the mains wiring and we are in for lots of trouble.

Here we keep fighting every way we can, but commercial pressure is big....

[n2ize]

Too much money involved. Radio spectrum is a very valuable commodity these days and government works strictly for business

[KG4CGC]

People still using radio? As smart (and dumb) as we are as humans, I find it hard to believe that after 100+ years that we haven't figured out, beyond radio.

[N8YX]

Could be that the ARRL needs better (or more visible) legal representation in Washington.

[WØTKX]

I don't think we will lose all of 70cm, but crowded metro areas with a lot of repeaters may get squeezed. The weak signal stuff will probably co-exist just fine. 900 MHz is a good place for repeaters, and 2 meter repeaters with little activity might get scrutinized a little more.

But I'm surprised that these new services are not being placed in the vacated television spectrum. I wonder if it has more to do with the availability of cheap 70cm RF devices than spectrum. It's always about the money, and businesses are more valuable than people.

Maybe if these new ventures would hire some of us hamsters?

[KC2UGV]

Could be that the ARRL needs better (or more visible) legal representation in Washington.

There would be no way for the ARRL to compete with the better funded corporate lobbyist who share offices with the same representatives they are lobbying.

[W3WN]

I don't think we will lose all of 70cm, but crowded metro areas with a lot of repeaters may get squeezed. The weak signal stuff will probably co-exist just fine. 900 MHz is a good place for repeaters, and 2 meter repeaters with little activity might get scrutinized a little more.

But I'm surprised that these new services are not being placed in the vacated television spectrum. I wonder if it has more to do with the availability of cheap 70cm RF devices than spectrum. It's always about the money, and businesses are more valuable than people.

Maybe if these new ventures would hire some of us hamsters?Keep in mind we've already lost 420 - 430 MHz in the "Line A" area, the zone going 90 miles from the Canadian border. Originally withdrawn to "protect" Canadian Land-Mobile users, then give to US Land-Mobile users in that area for their use.

Keep in mind that we have a federal bill to reallocate -- that is to say, sell -- 20 MHz of 70 cm spectrum (Amateur & GMRS/FRS areas) in Congress.

No, I fear the worse for 70 cm. And it's not a question of our lobbyist... it all comes down to money. And we don't have it.

[N8YX]

There would be no way for the ARRL to compete with the better funded corporate lobbyist who share offices with the same representatives they are lobbying.
Therein lies the fix to THAT.

[N8YX]

Keep in mind we've already lost 420 - 430 MHz in the "Line A" area, the zone going 90 miles from the Canadian border. Originally withdrawn to "protect" Canadian Land-Mobile users, then give to US Land-Mobile users in that area for their use.

Keep in mind that we have a federal bill to reallocate -- that is to say, sell -- 20 MHz of 70 cm spectrum (Amateur & GMRS/FRS areas) in Congress.

No, I fear the worse for 70 cm. And it's not a question of our lobbyist... it all comes down to money. And we don't have it.
When radios are outlawed...good luck shutting all of the freebanders down.

[KC2UGV]

Therein lies the fix to THAT.

We fix that, and we fix 98% of problems in our country. However, in order to fix that, we now need money, since corporations (Who place those lobbyists there) are people, and money=speech.

[W2NAP]

shame to cause i like operating 440

[n2ize]

shame to cause i like operating 440

We haven't lost 440 yet and, we may not lose it. 30 years ago people we arguing that we are on the virge of losing 440 and a good chunk of 2 meters and HF. 30 years later that has not materialized

[WØTKX]

I would think the potential for interference from other services would get these new users to find other frequencies. Really don't understand why it's being done, with plenty of VHF and UHF spectrum to go around.

Maybe 6 and 10 meter repeaters will get more popular. :dunno:

[W3WN]

We haven't lost 440 yet and, we may not lose it. 30 years ago people we arguing that we are on the virge of losing 440 and a good chunk of 2 meters and HF. 30 years later that has not materializedWe haven't lost ALL of the band, but significant portions of the country have lost SOME of it.

Let's not forget those areas of the country in the neighborhood of a PAVE PAWS radar system, where 440 use (especially repeaters) is either extremely curtailed or outright banned, to avoid interference with military radars. Something which has always been a possibility, but only became a reality the last few years.

[W3WN]

I would think the potential for interference from other services would get these new users to find other frequencies. Really don't understand why it's being done, with plenty of VHF and UHF spectrum to go around.

Maybe 6 and 10 meter repeaters will get more popular. :dunno:Because inside the Beltway, money and power talk. Amateur Radio operators have neither, at least as far as the elected goniffs, er, polticians are concerned.

[NQ6U]

All I know is that once Recon Robot starts selling it's wares in earnest, I'm gonna start using certain portions of the 70cm bands a lot more than I have in the past.

[W3WN]

Here's what scares me most about the whole thing:

Let's say that there is an incident involving use of a ReconRobot that goes... poorly. Exactly what I leave to your imagination, suffice to say that for the purpose of this example, the unit fails to operate as expected.

So the authorities start looking for reasons. And lo & behold! There's a ham radio antenna nearby! Well, it's just GOT to be interference from the damn ham, right?

...never mind that it may not be a 70 cm band antenna, that the ham (if it is a ham) may not have been on the band or even home at the time, and Part 15 & Part 90 waivers be damned. The users, who may not be aware of (or care about) all of the technical nuances, point the finger of guilt at the antenna and it's owner. You can extrapolate from there. And it won't be pretty.

Farfetched? Maybe. But imagine some poor schmuck getting grilled on the witness stand, being charged as the guilty party, trying to prove the he or she didn't do anything... and trying to point out the little technicalities involved. I can just hear a prosecutor thunder "Never mind Part 15, never mind the FCC license... how COULD you operate when you KNEW or HAD TO KNOW that you COULD be interferring with a Police Operation! And look what happened!"

[W4RLR]

We haven't lost ALL of the band, but significant portions of the country have lost SOME of it.

Let's not forget those areas of the country in the neighborhood of a PAVE PAWS radar system, where 440 use (especially repeaters) is either extremely curtailed or outright banned, to avoid interference with military radars. Something which has always been a possibility, but only became a reality the last few years.That's one of the reasons that it is not very popular in these parts. The one 440 repeater we have on the common tower we share grows cobwebs.

[N8YX]

That's one of the reasons that it is not very popular in these parts. The one 440 repeater we have on the common tower we share grows cobwebs.
And how can this be?

I place the blame squarely at the feet of the "closed repeater" owners whose systems are nothing more than a command-and-control system for their families or (back in the pre-cellphone days) a cheap(?) way for a select group to have a privatized chat channel.

You're now reaping what you've sowed, a$$bags. :angry:

Meanwhile, everyone you chased off is now playing on 6/2M FM simplex, 10M SSB or one of the other HF bands/modes,..

[X-Rated]

That's one of the reasons that it is not very popular in these parts. The one 440 repeater we have on the common tower we share grows cobwebs.

Around these parts, you can't put up a 440 repeater because all of the pairs are assigned.

[N8YX]

Around these parts, you can't put up a 440 repeater because all of the pairs are assigned.
But how many of those pairs are actually occupied...and used?

[X-Rated]

But how many of those pairs are actually occupied...and used?

I can try to come up with the numbers. I know that they are not all used. I think the local one down the street is fubared. But you still can't just put up a repeater without the blessing of the coordinator.

[WX7P]

And how can this be?

I place the blame squarely at the feet of the "closed repeater" owners whose systems are nothing more than a command-and-control system for their families or (back in the pre-cellphone days) a cheap(?) way for a select group to have a privatized chat channel.

You're now reaping what you've sowed, a$$bags. :angry:

Meanwhile, everyone you chased off is now playing on 6/2M FM simplex, 10M SSB or one of the other HF bands/modes,..

Exactamundo, John.

While not as bad as SoCal, NorCal used to have a shitload of "closed" repeaters. I always thought that was BS.

Pave Paws pretty much wiped out 440 around here because of Beale AFB.

[WX7P]

I can try to come up with the numbers. I know that they are not all used. I think the local one down the street is fubared. But you still can't just put up a repeater without the blessing of the coordinator.

Jerry, is your avatar that Canadian lunatic wifey?

[W3WN]

Around these parts, you can't put up a 440 repeater because all of the pairs are assigned.
Same here. There are a lot of empty pairs on both 2 and 70 cm, but because they are "assigned" no one else can be allocated them.

I know of one 440 repeater pair that has never actually been used... in fact, at one point, when W3SRL was trying to find a frequency pair, he discovered this ham had let his ticket lapse & was almost beyond the grace period... but so long as he keeps "renewing" every 6 months, the WPaRC won't budge.

Let's not even discuss the repeater pairs that KR3P has confiscated for his own use...

But nothing will change. I've talked about the situation with several repeater owners, and they're all afraid that if Joe is ever replaced, he and his dad will walk -- with the software (that WPaRC bought), the data, everything, and they'll have to start from scratch. So nobody is willing to do anything.

So the upshot is that anyone who wants to get a repeater going is stuck. And if the pair "owner" closes the machine, or won't put one up in the first place... tough noogies.

[N8YX]

So the upshot is that anyone who wants to get a repeater going is stuck. And if the pair "owner" closes the machine, or won't put one up in the first place... tough noogies.
This is where the FCC and the ARRL need to work jointly in establishing a usage justification clause. Don't have a machine up on the pair? You lose it. Have a semi-private pair with one or two users per week? Lose it.

Automated data collection software exists, and can be pressed into service for determining traffic loads. Heck, if a working stiff like me can afford to buy one of the higher-end packages, the ARRL should have no problem equipping its "oversight committee" with same.

[X-Rated]

Jerry, is your avatar that Canadian lunatic wifey?

No, that is not the Canadian lunatic wifey. It is the Alaskan lunatic wifey from Wasilla. I thought so many people around here were so enamored with her, no one could miss her.


http://www.youtube.com/watch?v=gV-vWrU27Go

[N8YX]

No, that is not the Canadian lunatic wifey. It is the Alaskan lunatic wifey from Wasilla. I thought so many people around here were so enamored with her, no one could miss her.
Didn't have her foot in her mouth. Went straight over my head.

ETA: Has teh crazy eyes.

[W3WN]

This is where the FCC and the ARRL need to work jointly in establishing a usage justification clause. Don't have a machine up on the pair? You lose it. Have a semi-private pair with one or two users per week? Lose it.

Automated data collection software exists, and can be pressed into service for determining traffic loads. Heck, if a working stiff like me can afford to buy one of the higher-end packages, the ARRL should have no problem equipping its "oversight committee" with same.The ARRL in the past has avoided getting tangled in these issues... remember all the kvetching & moaning back in the late '70's & early '80's about the alleged plans for the ARRL to "take over" repeater coordination and force out all the local councils?

The FCC has also in the past deferred on this issue. And frankly, I don't believe we should involve the FCC any more than we have to.

[KC2UGV]

This is where the FCC and the ARRL need to work jointly in establishing a usage justification clause. Don't have a machine up on the pair? You lose it. Have a semi-private pair with one or two users per week? Lose it.

Automated data collection software exists, and can be pressed into service for determining traffic loads. Heck, if a working stiff like me can afford to buy one of the higher-end packages, the ARRL should have no problem equipping its "oversight committee" with same.

I think most people are ignoring a simple fact about repeater pairs:

Sure, the coordination council has more "weight" when it comes to interference complaints. However, one must be interfering, and proof submitted to the FCC in order to even bring them into the picture.

Empty, assigned pair? Set up a repeater there if you like. IF, and only IF you interfere, do you have to move. You can't possibly interfere with nothing.

[X-Rated]

I think most people are ignoring a simple fact about repeater pairs:

Sure, the coordination council has more "weight" when it comes to interference complaints. However, one must be interfering, and proof submitted to the FCC in order to even bring them into the picture.

Empty, assigned pair? Set up a repeater there if you like. IF, and only IF you interfere, do you have to move. You can't possibly interfere with nothing.

Like I would want to spend the money on a repeater that can be taken off the air at a whim.

[W3WN]

I think most people are ignoring a simple fact about repeater pairs:

Sure, the coordination council has more "weight" when it comes to interference complaints. However, one must be interfering, and proof submitted to the FCC in order to even bring them into the picture.

Empty, assigned pair? Set up a repeater there if you like. IF, and only IF you interfere, do you have to move. You can't possibly interfere with nothing.Quite true. But if you set up a non-coordinated repeater these days, and a coordinated repeater comes on the air on the same pair, you lose. Even if you were there first.

And, sad to say, there are people who would arrange for that to happen just for the satisfaction of throwing the non-coordinated machine off the air for flounting the establishment.

[KC2UGV]

Like I would want to spend the money on a repeater that can be taken off the air at a whim.

It can't be taken off the air on a whim. Interference must be proven. One can not interfere with nothing.

[KC2UGV]

Quite true. But if you set up a non-coordinated repeater these days, and a coordinated repeater comes on the air on the same pair, you lose. Even if you were there first.


And, then that pair is not dead anymore, correct?



And, sad to say, there are people who would arrange for that to happen just for the satisfaction of throwing the non-coordinated machine off the air for flounting the establishment.

It's most probably true. However, the FCC doesn't take too kindly to people throwing around their authority to harass people. Again, interference must be proven.

[X-Rated]

It can't be taken off the air on a whim. Interference must be proven. One can not interfere with nothing.

The coordinated repeater will need only to get back on and they have the right of way. I mean, I am a pessimist. I see me putting up a repeater on top of a building and the coordinated operators come back after 6 months or so and I have to move. Rinse and repeat.

We need coordinators who promote "use it or lose it" but the good old boys look out for their own.

[W3WN]

Well, here's the scenario Corey:

You want to put up a repeater for your active group. You check the band(s) and find a pair that appears to have no repeater on it. You check the repeater directory, and it may or may not show an assignment, but clearly there is no machine, so it either was never built or went off the air. (And I'm presuming that you check for PL or a closed repeater etc. in this example, I'm glossing over all the minute details)

So you check with the area or regional Repeater Coordinator. And he tells you no. Either the channel is assigned, or there is another co-channel assignment near enough that there would be interference.

But you go ahead and put your machine on anyway.

So a year or three goes by. And the channel assignee either comes back to life, so to speak, with a new machine... or circumstances change, the channel is officially reassigned for any of a number of reasons, and a "new" machine is put on the air. And interference results.

You lose.

What? You didn't check with the repeater coordinator first? Too bad. You should have. You lose.

The FCC has stated, time & again, that if there is interference between two repeaters, and one is coordinated & one isn't, it's up to the non-coordinated repeater to resolve the interference. Up to & including change frequencies, or even shutting down. I can't imagine a situation in the past were a non-coordinated machine was given preference, even if it was there first. And there have been one or two where a machine may have lost coordination (politics? in repeater coordination? Nah), stayed on the air, and then got forced to move or go QRT because a "new" coordinated machine sprang up.

The whole thing is ridiculous when you consider how many frequency pairs are under utilized, or assigned to dead/dormant/non-existant machines. But ego and politics come into play. There are people who simply have to own a repeater, to show how important they are (ie how big their ego is) even if no one else is allowed to use it.

Logically, you would think that some of the owners of the less active repeaters would consider mergers and taking one or two off the air. But logic has little to do with this.

[KC2UGV]

I do understand that "you lose" if the assigned pair comes back alive. However, until that happens, you are free to use the pair, and no interference can be claimed.

Seriously, what's the likelihood of a pair coming back to life? Slim, unless someone is gunning for you.

And, in the meantime, guess what? That spectrum is BEING USED.

[N8YX]

... But ego and politics come into play...
The needs of the many outweigh the needs of the few.

If it's a matter of losing our bands over this, "good-old-boy system" be damned. The ARRL needs to take the lead in restructuring the coordinating committees, thereby eliminating the bottlenecks to wider-scale usage. That is, if the organization really does represent all amateurs.

[N8YX]

Seriously, what's the likelihood of a pair coming back to life? Slim, unless someone is gunning for you.

And, in the meantime, guess what? That spectrum is BEING USED.
It's happened around here.

The outcome wasn't pretty.

The system needs to change. "Going rogue" only works in Wasillia.

[X-Rated]

I do understand that "you lose" if the assigned pair comes back alive. However, until that happens, you are free to use the pair, and no interference can be claimed.

Seriously, what's the likelihood of a pair coming back to life? Slim, unless someone is gunning for you.

And, in the meantime, guess what? That spectrum is BEING USED.

Oh to be young again.

[KC2UGV]

Oh to be young again.

The youngin's are the ones who will be the majority of hams, eventually :)

[W3WN]

The coordinated repeater will need only to get back on and they have the right of way. I mean, I am a pessimist. I see me putting up a repeater on top of a building and the coordinated operators come back after 6 months or so and I have to move. Rinse and repeat.

We need coordinators who promote "use it or lose it" but the good old boys look out for their own.Precisely.

Now I can't speak for other areas, but in WPa, the Repeater Council has been under the control of KR3P and his father, N3EJY, for a good many years. If Joe doesn't like you, you will have difficulty getting a repeater pair or holding onto one. Sadly, I know this from first-hand experience.

[W3WN]

The needs of the many outweigh the needs of the few.

If it's a matter of losing our bands over this, "good-old-boy system" be damned. The ARRL needs to take the lead in restructuring the coordinating committees, thereby eliminating the bottlenecks to wider-scale usage. That is, if the organization really does represent all amateurs.

Fred, I agree with you in principle. But let's be honest... were the League staff to actually try this, you and I both know that there would be screaming from on high about how the League was trying to control everything to the detriment of the every day ham, yada yada yada. The anti-ARRL zealotry would have a field day, and those in positions of quasi-authority that would be ousted or at best neutralized would be right up front screaming just as loud.

This is another example of "damned if you do, damned if you don't" when it comes to the ARRL. So many want the League to take charge of things, but there are also so many who are dead set against it.

[KØWVM]

Exactamundo, John.

While not as bad as SoCal, NorCal used to have a shitload of "closed" repeaters. I always thought that was BS.

Pave Paws pretty much wiped out 440 around here because of Beale AFB.

Also home of the U-2 btw...

[KØWVM]

Here's what scares me most about the whole thing:

Let's say that there is an incident involving use of a ReconRobot that goes... poorly. Exactly what I leave to your imagination, suffice to say that for the purpose of this example, the unit fails to operate as expected.

So the authorities start looking for reasons. And lo & behold! There's a ham radio antenna nearby! Well, it's just GOT to be interference from the damn ham, right?

...never mind that it may not be a 70 cm band antenna, that the ham (if it is a ham) may not have been on the band or even home at the time, and Part 15 & Part 90 waivers be damned. The users, who may not be aware of (or care about) all of the technical nuances, point the finger of guilt at the antenna and it's owner. You can extrapolate from there. And it won't be pretty.

Farfetched? Maybe. But imagine some poor schmuck getting grilled on the witness stand, being charged as the guilty party, trying to prove the he or she didn't do anything... and trying to point out the little technicalities involved. I can just hear a prosecutor thunder "Never mind Part 15, never mind the FCC license... how COULD you operate when you KNEW or HAD TO KNOW that you COULD be interferring with a Police Operation! And look what happened!"

And I would fire back, "It wasn't in use at the time and you'll have to prove to the jury where I was interfering with a Police Operation!" "You yourself should know what Part 15 says and that can't be argued." "Even IF I were using it at the time, how can you prove I was showing malisicious intent?"

If any police agencies are smart, they should have the equipment in hand and probably one would be a field strength meter. But that might mean having someone assisting them in it's use.

[W3WN]

Well, so would I, if not in those exact words. But not everyone would have the presence of mind to do so. Worse, a jury might not pay attention to what you're saying, but how you're saying it... come off looking defensive (even if accurate and truthfull) and they might conclude that you're the one hiding something. One never knows.

For example:
Frank N3XI used to run a small catering business over in the West End. (He's no longer doing so. Long story involving his now ex-wife). When they were remodeling the place, every time he was told by an inspector to change or upgrade something, he did... after getting a permit, of course... only to see his tax appraisals constantly raised. He took the City to court. And lost. Now, from what he told me, it seems that the witnesses for the City kept bringing up some details (sorry, I forget the exact details) regarding why this all happened -- and it clearly indicated that the appraisals were only being raised to bring in more tax revenue, not because of an actual increase in value. Frank's lawyer kept objecting. The judge kept ruling in his favor. Yet he lost. Because the jury indicated that despite that pesky little technicality, well, if the City people kept bringing it up, then it must be true, right?

Let's hope that it never comes to this.

[n2ize]

Better idea. Why not put the recon-robot on frequencies that are not uysed by licensed radio services ? The 2.5 Ghz radio control frequencies come immediatly to mind. With todays spread spectrum technology, i.e frequency hooping, etc. you can have severa different rc units running simultaneously and in close proximity to one another and they won;t interfere with each other. I am sure Recon-the-Robot can operate similarly with greater reliability than putting it on freq with powerful licensed radio stations.

[KK4AMI]

Better idea. Why not put the recon-robot on frequencies that are not uysed by licensed radio services ? The 2.5 Ghz radio control frequencies come immediatly to mind. With todays spread spectrum technology, i.e frequency hooping, etc. you can have severa different rc units running simultaneously and in close proximity to one another and they won;t interfere with each other. I am sure Recon-the-Robot can operate similarly with greater reliability than putting it on freq with powerful licensed radio stations.

I believe the company wanted a third operating channel for their little throw-able robot. They do claim the 400 MHz signal does better penetrating buildings and tunnels. What would be the extent of interference from Amateur Radio? The TV signal is a very low powered 250 mW signal to a directional receiver antenna. The TV signal from the robot is 6 MHz wide and the Ham signal is what, only 25 kHz. The robots would only experience occasional use, mostly indoor and of short duration. We used these kinds of robots in Iraq. I'm all for anything that saves a cop or police dog. Too many of them get shot walking blindly into stupid domestic disputes.

[NQ6U]

I believe the company wanted a third operating channel for their little throw-able robot. They do claim the 400 MHz signal does better penetrating buildings and tunnels. What would be the extent of interference from Amateur Radio?

It probably wouldn't interfere with amateur radio. The concern is that this may turn out to be the proverbial camel's nose under the tent. They start with this little low-powered unit operating on a secondary basis than, next thing you know, we're being hustled off the band entirely to make room for other LE equipment. It's not as if Public Service doesn't already have huge blocks of spectrum.