[AMRadio] FCC Proceeding warrants attention


Rob Atkinson ranchorobbo at gmail.com
Fri Dec 13 05:52:42 EST 2013


I'd say this is more important than deliberate QRM on 75 m. right now.

I plan to comment with the following view:

All of the reasons why a strict numerical bandwidth limit is a bad
idea have not changed or gone away.  It was a bad idea several years
ago and it still is now.

This includes for example, all the technical problems with hams
attempting to measure their bandwidth and the criteria for
measurement.

Again, if a ham is too wide, in any mode, there are already measures
available to deal with this, case by case that do not necessitate
draconian rules for all digital operators that may make occasional
experimentation impossible.

Being too wide for circumstances is an operating courtesy or legal
issue (inconsiderate QRM or deliberate QRM); it is not and should not
be a technical issue.   If digital stations are interfering or are
deemed too wide, they can be dealt with like any other mode of
operation; a special rule for bandwidth is not needed and is not a
solution.  If the station is operating with a poorly tuned or over
driven transmitter and the width is due to splatter, there are already
spectral purity rules that cover this and once again a new rule is not
needed.

The problem is enforcement or simply contacting the operator, i.e.
getting a legal ID from such a station.  The solution for the small
number of digital stations that cause problems, is to go back to
requiring an automatic CW ID at the end of each transmission.  This
can be easily programmed in, and can be fast and brief.  de K5UJ.  no
more is needed.  Then these stations can be identified without the
need for data decoding equipment, and corrective action, anything from
an email or OO card to FCC involvement, can be initiated by any other
ham.   As with any mode, if a digital station op listens and finds 10
kc clear, there should be no reason why he can't transmit a signal
that is 5, 6 or 8 kc wide, and as with any mode, they should have the
freedom to listen and make that determination, at least in the U.S.

I believe hams should advise FCC to keep the ARS free of strict
emission bandwidths.    Because the ARRL has chosen to pursue such a
limit for digital modes, I think the FCC should deny the petition.

Rob
K5UJ

On Thu, Dec 12, 2013 at 7:18 PM, Donald Chester <k4kyv at charter.net> wrote:
> ARRL has submitted its promised petition to the FCC to eliminate the Baud
> rate limit for digital data, and replace it with a maximum bandwidth limit
> of 2.8 kHz. This would allow digital modes that operate in the CW bands to
> transmit signals with bandwidths equivalent to that of SSB phone signals.
>
> The FCC received the petition on 21 November, 2013, and has assigned it
> Proceeding Number RM-11708. Interested persons may file statements opposing
> or supporting the Petition for Rulemaking within 30 days, which means the
> filing deadline is 20 December, 2013. As of this reading, 438 comments have
> been filed.
>
> Although the petition does not directly address AM, it bears attention from
> the AM community, since bandwidth regulation could ultimately affect our
> operating privileges. Already, one of the commenters has suggested imposing
> an 8 kHz bandwidth limit for AM in his submission, and many other comments,
> both pro and con, suggest resurrecting the defunct Regulation by Bandwidth
> proposal. An issue of concern would be the precedent of establishing
> specific bandwidth limits for any mode of operation on HF, other than what
> already exists on the channels in the 60m pseudo-band. I would suggest
> carefully reading over the proposal and comments, and submitting your own as
> you might deem appropriate.
>
> The Public Notice can be viewed at
> http://apps.fcc.gov/ecfs/document/view?id=7520959109
>
> Comments may be viewed at
> http://apps.fcc.gov/ecfs/comment_search/input?z=896ij   Type in  RM-11708
> in the box at the top labelled "Proceeding Number" and then click on "Search
> for Comments" at the bottom of the page.
>
> To file your own comments, go to
> http://apps.fcc.gov/ecfs/upload/display?z=nre5u
>
> A shortcut to file a brief comment may be found at
> http://apps.fcc.gov/ecfs/upload/display?z=bk610


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