[AMRadio] New analog phone bandwidth petition

Robert Bethman oldrotorheadsarge at outlook.com
Sun May 15 16:51:23 EDT 2016

I can't determine if this individual is licensed or not.  Even an address lookup finds nothing.

It is obvious that he has intentions that are not in the best interests of the Amateur Service in a very broad way.

I will definitely read the entirety, and craft a formal comment shortly.

Regards, N0DGN

-----Original Message-----
From: AMRadio [mailto:amradio-bounces at mailman.qth.net] On Behalf Of Donald Chester
Sent: Sunday, May 15, 2016 3:38 PM
To: 'Rob Atkinson' <ranchorobbo at gmail.com>; 'Discussion of AM Radio in the Amateur Service' <amradio at mailman.qth.net>
Subject: Re: [AMRadio] New analog phone bandwidth petition

The latest (RM-11769) in a flood of rulemaking petitions filed to the FCC since the first of this year, is one that the AM community should take seriously, and hopefully respond with formal comments to the FCC's ECFS.

This proposal ostensibly requests the FCC to eliminate all references to specific modes currently allowed in the CW/RTTY/data sub-bands, re-designating those modes under the blanket term "symbol". Secondly the proposal seeks to expand the current CW-only Novice and Technician HF privileges to include all forms of RTTY/data up to a maximum bandwidth of
2.8 kHz (the same as the nominal bandwidth of SSB). CW-only privileges at
50.0-50.1 and 144.0-144.1 MHz would be expanded in similar fashion.

What should concern us most of all is obscurely buried way down in paragraph
17 of the Petition. This is in reality a back-door bandwidth proposal, imposing specific numerical limits to the occupied bandwidths of all modes of emission on all amateur frequencies. AM would be limited to a maximum occupied bandwidth of 8 kHz. This would change a long-standing FCC policy to avoid specific bandwidth limitations for most amateur radio transmissions.

Here is the pertinent excerpt from the Petition:

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). . .


As one can see, this would impose an identical bandwidth limit to SSB and to AM. In any case it would impose an additional enforcement burden on the FCC, and additional compliance burdens on hams. While 8.0 KHz may seem to many to be a reasonable bandwidth for the usual AM signal, there is no compelling reason at this time to suddenly impose specific enumerated limits to AM or any other mode, especially considering that band congestion has fallen off in recent years compared to what we have endured in the past. The current bandwidth rules, based on "good engineering and amateur practice" were intentionally left vague to allow amateurs the maximum flexibility for experimentation and self-instruction in the radio art. See §97.307(a) and (c).

As just one example, what is wrong with running additional bandwidth with a clean signal when a certain band is lightly occupied, as on 75m and 160m during daylight hours, when an undistorted signal of twice that bandwidth would unlikely cause anyone a problem?

Given the current lack of FCC enforcement of existing rules, particularly Part 15 and Part 18 limitations on harmful RFI radiation, and the FCC's apparent inaction on all but the most egregious violations of rules against deliberate ham-on-ham interference, what would be the point to now add new rules directing the Commission to further micro-manage amateur radio operation?

The FCC released the Public Notice on 11 May 2016, announcing this Petition as RM-11769. Interested persons may file statements opposing or supporting this Petition within 30 days, with the deadline for comments falling on 10 June, 2016. 

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