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

Donald Chester k4kyv at charter.net
Wed May 18 00:19:06 EDT 2016

Looking over the comments to RM-11769, I see it has already drawn over 300

I took a random sample of about a dozen comments, and the good news is that
every single one I looked at was opposed to the petition.  The bad news is,
apparently, many CW operators have misinterpreted what is being proposed,
and have been led to believe that the petition asks to "eliminate the
exclusive CW sub-bands" and allow RTTY, data and other digital noise in our
traditional CW bands.  Typically, the comments I read went something like
this, "I have been operating CW for 40 years.  Please leave the CW bands
alone."  In reality, RTTY/data/digital noise has already been allowed for
years; the "CW bands" haven't been “exclusively CW” since RTTY was first
introduced to amateur privileges, right after WWII. There are no
“exclusively CW” sub-bands on HF.  

The only thing that is "exclusively CW" on HF are Novice and Technician
privileges. The bottom 100 kHz of 6m and 2m are the only exclusively CW
amateur band segments.  What the guy is proposing for HF in this regard is
to change the name of the “CW/RTTY/data” sub-bands to "symbol" in the
wording of Part 97 rules, consistently as the phone bands were previously
re-named "phone" instead of AM/SSB/SSTV - just a matter of semantics, except
for the part about allowing Novices and Techs to run  RTTY and digital data
on HF (which I oppose, since with the General class exam so easy, let them
upgrade if they want to run digital hash on HF). But he does want to
eliminate the exclusively-CW rule and add RTTY/data to the 50.0-50.1 MHz and
144.0-144.1 MHz segments.

As I  see it, we have a problem because of what appears to be a widespread
misinterpretation of the petition; this may cause the FCC to simply consider
95% of the commenters ill-informed and blow off the comments in opposition.
That means some of us should compose some well thought-out comments,
expressing opposition to the bandwidth proposals.  A few of the commenters
did apparently get a better grasp of exactly what is being proposed, and
expressed opposition to allowing digital data with a bandwidth of up to 2.8
kHz in the so-called CW bands.  If they are to open the CW bands up to
2.8-kHz wide digital hash, they might just as well allow SSB too, which
would actually cause less disruption to CW operation than would 2.8 kHz of
digital white noise.

This petitioner is also proposing specific, enumerated bandwidth limits for
ALL modes used in amateur radio, which 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 maximum 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.  This proposal would make no distinction
between the bandwidths of double-sideband AM and that of single-sideband;
they would both be limited to 8 kHz maximum.  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). 

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 in now adding
new rules directing the Commission to further micro-manage amateur radio

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. 

Don k4kyv

PS:  To view the comments submitted  so far, go to the FCC web page below.
You may have to manually copy and paste the URL into the address bar of your
browser, since the Reflector software may add line breaks that render the
link inoperative.


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