[AMRadio] New analog phone bandwidth petition

mark lexnonscripta at usa.com
Sun May 15 10:36:00 EDT 2016

Thank You for this information.

I would propose that those of us who wish to respond to this petition 
become better acquainted with reasons NOT to limit the bandwidth, in 
whatever form we can. Perhaps people a little more knowledgeable on the 
subject can offer a few points as to why this is a bad idea, as well as 
reasons to promote wider bandwidths.  We dont have to merely give 
reasons in opposition, but benefits.

Once a list is compiled, we can write individual letters referencing the 

Just a thought.


Mark KD9CXH - formerly KA9FBX
> 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.
> 73
> Rob
> K5UJ
> ---------- 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"
> radiotelegraphy.
> 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.
> /EX
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