[AMRadio] New analog phone bandwidth petition

Rob Atkinson ranchorobbo at gmail.com
Sun May 15 08:44:35 EDT 2016

AM operators:

As many know by now, a ham in Missouri, James E. Whedbee N0ECN, has
filed a petition for a rule change that is described as having to do
with something harmless called a "symbol rate."

The reality is that it is a stealth bandwidth limit petition.  Buried
in the text at paragraph 17 is a clause that would limit all analog
phone below 28.5 MHz to 8 kc at the -20 dB points:

17.   Petitioner further proposes that for Voice and Image modes below
1.8 MHz, the 20 dB

bandwidth be limited to 1300 Hertz (i.e., Codec 2 digital voice);
between 1.8 and 29.5 MHz, the

20 dB bandwidths be limited to 8000 Hertz (i.e., double-sidebanded
analog AM voice); ...

Here we go again just like 10 years ago with the failed "regulation by
bandwidth" proposal from ARRL.

For all the same reasons, we need to be against this by filing
comments with FCC, who currently can't even catch a lot of the
deliberate QRM and guys running 5 KW RF amplifiers.   Imagine having
to bandwidth limit your HT-9 or Gates broadcast rig.   Oh, it can
probably be done in some way, but do we need it?  Does every AM
operator need this regardless of band conditions, time of day, power
level, and modulation method because some guy who doesn't even seem to
be active thinks we need it (or he needs it).

The ARRL news report is below with more information.


---------- Forwarded message ----------

ARLB016 Missouri Radio Amateur Petitions FCC to Designate "Symbol
Communication" Subbands

James E. Whedbee, N0ECN, of Gladstone, Missouri, has petitioned the
FCC to designate Morse (radiotelegraphy) Amateur Radio band segments
as "symbol communication" subbands. The FCC has invited comments on
his Petition for Rule Making (RM-11769), filed on May 2. Arguing
that retaining the current regime of "legacy" CW subbands has proven
to be grossly inefficient, Whedbee said he'd like to see the FCC
delete all privilege restrictions that limit any part of the Amateur
Radio spectrum to Morse code to the exclusion of other modes.

RM-11769 can be found on the web at,
http://apps.fcc.gov/ecfs/comment/view?id=60001692464 .

"Nostalgia for retention of Morse code telegraphy-only subbands is
also an insufficient reason to avoid moving forward to [the]
elimination of such subbands, because nothing about this Petition
suggests the elimination of the mode itself, only that it not be the
sole authorized mode in the subject subbands," Whedbee told the FCC.

Whedbee characterized CW-only subbands as "an excessive regulatory
constraint, as well as a poor use of the spectrum concerned." He
proposed that the FCC's Part 97 rules reflect the "ultimate form of
communication reproduced at the receiving end." As he explained it,
his regulatory scheme would break down modes into three categories -
"symbol communication mode" - for CW, digital, and other emission
modes that reproduce a discrete symbol on the receiving end - "voice
mode," and "image mode."

"[C]ontinuing regulation by specific emission designator is proving
to be onerous with changes to the state of the art," Whedbee said.
"Accordingly, to continue developing the state of the art in
radiocommunications, Amateur Radio needs to clearly get away from
regulating in that fashion and return to consideration of what the
receiving end of the communication reproduces."

He proposed that where the Part 97 rules refer to exclusive
radiotelegraphy allocations - or subbands - privileges be changed to
reflect symbol communication modes. Where the rules prohibit voice
and image modes, he would revise the rules to reflect symbol
communication modes. In situations where current rules prohibit
symbol communication modes other than Morse, that voice and image
modes would be permitted, "with an exception for manually keyed"

For example, he would drop the distinction between 75 meters and 80
meters, authorizing symbol communication modes between 3.5 MHz and
3.65 MHz, and voice and image modes between 3.65 MHz and 4 MHz, with
manual radiotelegraphy authorized throughout the band.

Whedbee told the FCC that, if his Petition is accepted for filing
and put on public notice, he would submit an appendix spelling out
proposed service rules as part of his Petition.

Commenters have 30 days to respond to Whedbee's Petition.

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