[AMRadio] [CW] Elimination of CW-Only Sub-bands

Donald Chester k4kyv at charter.net
Mon May 16 15:34:47 EDT 2016

RM-11769 is the latest of a flood of rulemaking petitions that have been
filed to the FCC since the first of this year, but one I recommend we take
seriously, and respond with formal comments to the FCC ECFS at: 

The 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/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). The CW-only segments at 50.0-50.1 and
144.0-144.1 MHz segments would be expanded in similar fashion.

The petitioner has not proposed to eliminate what we know as the "CW bands";
these have been shared with RTTY and data ever since RTTY was first allowed,
shortly after WWII. The only CW bands affected would be the Novice and
Technician privileges on 80, 40 and 15, since Novices and Techs are
presently allowed to run only CW in those bands. The petitioner wants to
expand their privileges to RTTY/data. Privileges in the existing CW-only
sub-bands on 6M and 2M would be similarly expanded. ARRL proposed a similar
expansion in their petition RM-11759, now officially closed to comments.

The change in nomenclature of the sub-bands from CW/RTTY/data to "symbol"
is only a matter of semantics, similar to the change in the phone bands from
AM/SSB/NBFM/SSTV to "phone/image" and would have no effect on operating
privileges.  As I see it, that is the ONLY thing in this entire petition
that might actually have some merit.  What should concern us most, obscurely
buried way down in paragraph 17 of the Petition, is that this is in reality
a back-door regulation-by- bandwidth proposal, imposing specific numerical
limits to the occupied bandwidths of all modes of emission on all amateur
frequencies. This would change a longstanding regulatory policy, probably
dating back to the creation of the FCC all way up to now, which has been to
avoid specific bandwidth limits for most amateur radio transmissions, for
the stated reason of allowing amateurs the maximum flexibility for
experimentation and self-instruction in the radio art. 

Here is the pertinent excerpt from the Petition (scroll down to Paragraph


Specific bandwidth would serve no useful purpose and would impose an
additional enforcement burden on the FCC, and additional compliance burdens
on hams. There is no reason now to suddenly impose specific enumerated
limits to all modes, 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). Considering the current lack of FCC enforcement of existing rules,
particularly Part 15 and Part 18 limitations on harmful RFI radiation, and
inaction on all but the most egregious violations of rules against
deliberate interference by amateur operators, in is questionable that new
rules be added, directing the Commission to further micro-manage amateur
radio operation.

The greatest threat to CW operators in this, as well as the ARRL's recent
petition to change the 80/75m phone/CW/automatic controlled digital
sub-bands (RM-11759), is the matter of allowing digital data white noise to
operate throughout the narrow-band (CW)sub-bands with a nominal bandwidth up
to 2.8 kHz, the same as SSB phone and SSTV.  If wide-band digital signals
are to be allowed in the CW bands, why not SSB and SSTV?  Analogue SSB would
actually generate less QRM than digital  data white-noise hash to CW

The FCC released a 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,

Don k4kyv

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