[AMRadio] New analog phone bandwidth petition


Mike Bracey mikebracey at att.net
Sun May 15 16:57:13 EDT 2016


Hi Don,
I would like to comment to the FCC. However, I must have taken too much allergy medication today. I can't seem to find the place to file a comment on the FCC website.
73, Mike / KE5YTV

      From: Donald Chester <k4kyv at charter.net>
 To: 'Rob Atkinson' <ranchorobbo at gmail.com>; 'Discussion of AM Radio in the Amateur Service' <amradio at mailman.qth.net> 
 Sent: Sunday, May 15, 2016 2:38 PM
 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.
http://apps.fcc.gov/ecfs/upload/display

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). . .

http://apps.fcc.gov/ecfs/comment/view?id=60001692464


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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