[AMRadio] AMRadio Digest, Vol 135, Issue 5

Donald Chester k4kyv at charter.net
Sat Apr 4 00:23:14 EDT 2015

> From: <manualman at juno.com>

> Roughly ten years ago the ARRL tried to do just that with RM-11306, band
allocations by bandwidth, 
> which could have segregated a lot of digital stuff into only specific
places in each
> amateur band. Too much misinformation floating around and pressure forced
them to retract the proposal. 

> At the same time, there was the really dumb proposal, RM-11305,
"formulated" by seven amateurs, 
> basically asking that all regulations and restrictions of
who-does-what-where, within a 
> license class be totally removed. Anywhere you set your dial, you would be
free to operate any mode 
> with any bandwidth you wanted. Fortunately, that one was retracted too.

> Pete, wa2cwa

RM-11306 was a re-hash of the infamous Docket 20777, which would have
outlawed AM on all amateur frequencies below 28.5 MHz, by imposing a strict
3.5 kHz limit on occupied bandwidth. One difference was that the League
proposal suggested a bandwidth limit based on NECESSARY bandwidth rather
than OCCUPIED bandwidth, plus they included a special FOOTNOTE to
specifically accommodate AM.  

Problem is, when a  rulemaking petition is submitted to the FCC, there is no
guarantee they will act on it exactly as the petitioner proposed; sometimes
the NPRM eventually issued is far different from the original petition.  In
fact, it may be quite the opposite of what the petitioner intended. So there
is no guarantee that the FCC would have gone along with the "necessary"
bandwidth standard and not adopt the more strict "occupied" bandwidth
standard.  Even if the rulemaking had passed exactly as originally proposed,
relegating AM to a mere footnote defining it as an EXCEPTION to a general
standard based on SSB practice would have left us in a precarious position,
since a footnote can very easily be deleted with little fanfare.

RM-11305 merely proposed to bring the US amateur band structure in line with
those of nearly every other nation in the world, and I doubt if other
countries see their amateur regulations as "dumb" or think that ours are
more intelligent than their own.  Our complex system of sub-bands and
sub-bands is the exception; even Canada, right next door, adopted a similar
change and eliminated their sub-bands many years ago. Even here in the US
the plan as proposed in RM-11305 has existed on 160m ever since the band was
(almost) fully restored to amateurs in the early 1980s, and for more than 30
years now it seems to have worked pretty well. In fact, the FCC denied a
petition several years ago by a group of amateurs  who wanted to extend
sub-band segmentation to that band.

Don k4kyv

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