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May 27, 2018
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W5YI News :

On June 27th, the FCC released an Order accepting separate requests to withdraw two Petitions for Rulemaking seeking to end regulating the Amateur Service by subband modes and replacing it with a “regulation by bandwidth” scheme.

Most countries of the world (including Canada) do not have their ham bands partitioned into emission subbands. Technology exists today (digital robots wandering the band) that can look for lightly used spectrum.

Petition by CTT

RM-11305 was been filed by the self-appointed Communications Think Tank (CTT) on June 20, 2005. They requested that the Commission "...discontinue mandatory segmentation of emission modes and the activities using these modes in the Amateur Service, and substitute a voluntary [bandplan] system of coordination to achieve greater, and more efficient, utilization of frequency allocations within the amateur radio bands."

The Communications Think Tank consists of eight long-term licensed radioamateurs who are also professional communications technicians and engineers. All reside in the Maryland, Pennsylvania, Ohio and Illinois area and seem to have an interest in digital voice communications and software defined radios.

“In the past few years there has been a growing observation that the lower portions of the bands are becoming less and less populated,” CTT said in their petition. “Conversely, the upper sections are becoming more active with new licensees trending toward phone modes.”

CTT added “The proposal to discontinue forced segregation by mode would drain pressure away from the problem of operators who make squatter’s claims on frequency space during times of congestion, since there would be more room and a greater range to move elsewhere.”

To support its argument that regulation by subband mode should be replaced, CTT conducted a detailed study using a spectrum analyzer on the 15, 20 and 40 meter bands. A usage chart validated their belief that CW occupancy of the HF bands is significantly less than phone use of the same bands at the same time.

Ned Stearns, AA7A, an avid CW DX operator from Scottsdale, Arizona, summed up RM-11305 by saying “What this proposal does is essentially abolish all mode guidelines and turn it over to users to decide if someone wants to work phone, digital, or CW on any particular area of the band. We would depend on amateurs to be good citizens and follow good bandplans, and the FCC would have nothing much to do with saying what goes on where inside the band. If you work digital modes, CW, or any narrow mode you will be at the mercy of any operator of wider modes to stay off your frequency. If you work weak signal CW, the present generation of SSB transceivers will affect your noise floor as far as several kHz outside the passband of the SSB signal. There will be no FCC rule saying SSB, AM and FM operates here and CW, RTTY, and Slow Scan operates over there. It will all be up to the moral character and common sense of the operator to not QRM incompatible modes. This is one more step towards turning amateur radio into a no-regulation service.”

Petition by ARRL

Five months after CTT filed their petition, the American Radio Relay League, Inc. (ARRL) submitted RM-11306 wanting basically the same thing, but in a slightly different way. On November 14, 2005, the League asked the FCC to "...comprehensively modify the means by which the extremely varied emission modes in the Amateur Radio Service are developed, experimented with, implemented, and regularly utilized in the course of normal Amateur Radio communications.”

ARRL CEO David Sumner, K1ZZ, had already discussed the subject of regulating by bandwidth in three "It Seems to Us ..." QST editorials: "Regulation by Bandwidth" in September 2004, "Narrowing the Bandwidth Issues" in April 2005 and "Self Regulation" in October 2005.

The League said its proposal recommends “...a shift in regulatory philosophy to encourage and enable development and refinement of digital techniques and advanced technologies.” It asked the FCC to replace the table at Sec. 97.305(c) with a new one that segments bands by necessary bandwidths ranging from 200 Hz to 100 kHz rather than mode.

The ARRL wanted all bands below 29 MHz (except 160 and 60 meters) to be segmented into subbands allowing maximum emission bandwidths of 200 or 500 Hz or 3.5 kHz with an exception for AM phone. 200 Hz would permit manual CW as well as PSK31; 500-Hz bandwidth would accommodate RTTY and data modes ...and 3.5 kHz could accommodate SSB and digital telephony.

Other proposals: 2.8 kHz would remain the bandwidth for 60-meter USB operation; 9 kHz for double-sideband AM and a 16 kHz bandwidth for analog FM voice, data, digital voice and multimedia at 29.0 to 29.7 MHz. A 100 kHz wide bandwidth, now permitted for RTTY and data in bands above 420 MHz, would be dropped to 50 MHz except for small segments at the beginning of the 6 and 2 meter bands.

"This petition seeks for the Amateur Radio Service the flexibility to experiment with new digital transmission methods and types to be developed in the future while permitting present operating modes to continue to be used for as long as there are radio amateurs who wish to use them," the League said. ARRL added that its proposal would also “...update the FCC's rules and eliminate the need for ‘cumbersome procedures’ to determine whether a new digital mode is legal under Part 97.” The FCC circulated both RM-11305 and RM-11306 on the same day for preliminary public comment. Comments were due February 6, 2006.

CW interests line up against proposals

Those opposed to the concept of “regulation by bandwidth” fear that their CW spectrum will be overrun by digital voice communications -or worse yet, wideband SSB. Those in favor want “space” in which to develop digital communications. This is clearly shaping up as a war between manual CW interests and modern communications.

Postings to the Commission’s Electronic Comment Filing System (ECFS) were enlightening. Over 300 comments were filed on RM-11305 and nearly 2,000 on RM-11306. Here is a sampling of some of what we found:

“This proposal (RM-11305) makes as much sense as asking the department of highways to remove all lines on highways, and allowing drivers to use their own judgment where to operate their vehicles. The ultimate result would be the widest and heaviest vehicle would occupy whatever space the operated decided he wanted. This proposal would ruin amateur radio by turning it into an uncontrolled free-for-all.” - Charles T. Rauch, W8JI, Barnesville, GA

“As an amateur licensee I operate mainly in CW mode on the lower HF bands, I recognize that it is time to explore solutions for alleviating the crowded conditions that exist in the phone segments of the bands. Although any changes in the current sub-band structure may adversely impact my preferred mode of CW, I recognize the need to quickly adopt a fix for the current problems and to foster the growth of digital and other advanced modes. I urge the Commission to approve and adopt RM-11305 in the spirit of deregulation of the Amateur Service....” - James Seaman, WA2AJM, Germantown, MD

“The question arises what is the problem with the current regulatory structure that has served, albeit with modifications over time, satisfactorily for many decades? The Amateur Radio Service has been, and is, calm, controlled, and markedly self regulating, using a minimum of the Commission's resources on a daily basis, [...except] for those occasional rogue operators. Converting this service into the free hunting preserve of those rogues is not in the best interest of the Amateur Radio Service nor in the best use of resources of the FCC once the inevitable conflict starts.” - Dr. Dennis O'Connor, K8DO, Hemlock, MI

“In my opinion, RM-11305 represents a takeover of the bands by voice users (and ultimate wideband data users) and an attempt to kill telegraphy. Telegraphy remains the second most popular mode with 30% usage (60% SSB and 10% data) and as such deserves the quiet enjoyment of spectrum as it does today. ...On RM-11306: The Commission should be aware that the ARRL did not seek a vote of members before filing this petition. In fact, many Board members promised that members would see a bandplan before the petition was filed. ...ARRL continues to make policy behind closed doors. Without fairness, there can be no trust. Without participation there can be no consensus.” - Charles L. Young, Jr., AG4YO, Cantonment, FL

“If the CTT petition is established without effective gentlemen’s agreements, the most popular modes will expand throughout the amateur radio bands at the expense of the other modes. With the current technology, high power SSB voice transmissions will displace almost all other communications modes except for a few islands of high power CW communications. Low power and weak signal communications will be lost in the mode battle between higher power stations. Less commonly used modes will be swamped by the majority’s enthusiasm for high power SSB. ...In contrast, the ARRL’s petition (RM-11306) offers a high flexibility in modes used and still protects the minority, from the excesses of the majority, through the force of FCC regulations.” - Nickolaus E. Leggett, N3NL, Reston, VA

“Failure of the Commission to maintain regulatory band separation by mode would result in decades of relative harmony and cooperation being replaced with chaos. The HF bands would become nothing more than a free-for-all, a mass brawl. This certainly would not contribute to ‘Continuation and extension of the amateur's unique ability to enhance international goodwill.’” - Robert G. Rightsell, AE4FA, Lexington, SC

“The ARRL appears to only be representing the few, and not the majority of its members. I believe that special interests are behind this proposal and therefore it is not in the best interest of the amateur community as a whole.” - Glen Powell, K9GP, Pocatello, ID

“ARRL proposes many revisions to existing regulations, most of which would not benefit the public or the Amateur Service as a whole. A very small segment of amateur operators, apparently desirous of utilizing HF digital telecommunications to access enhanced internet content while traveling to avoid payment for similar commercial satellite-based services, would be benefitted by adoption of the ARRL proposal at the expense of other amateurs.” - W. Lee McVey, W6EM, Leeds, AL

“The rules changes proposed in RM-11305 would result in spectrum-inefficient, wide bandwidth activity creating interference to the low power amateur radio experimenters.” - Scott A. McMullen, W5ESE, Dripping Springs, TX

“I wish to express my support for RM-11305. The bottom line in my opinion is that far too much amateur spectrum is wastefully and exclusively allocated to CW (Morse) operation. ...the amount of spectrum allocated exclusively to Morse hasn't changed proportionately to actual band use for decades. Morse is permitted on 100% of every HF amateur band while other modes are not....” - Bill Kleronomos, KD0HG, Berthoud, CO

“What we have with RM-11305 is really a request of a completely wide open range without a Sheriff or any regulations concerning incompatibility, ID of stations, interference remedies, and limits on bandwidth being used. While this sounds utopian and the authors of RM-11305 really believe that everyone will play nice and not engage in spectrum grabbing for his or her 25 kHz (or more) digital mode or broadcast quality FM mode, human nature will dictate against it.” - George McCouch, K3UD, Hopkinsville KY

“I am amazed at the arrogance of the ARRL and the “Think Tank” petitioners in not consulting with the rest of the Amateur Radio world. ARRL does not represent everyone in the Amateur Radio community,” - L. R. Wical, KH6IS, Trustee, lolani School Radio Club, Kaneohe, HI

“Many of us are disappointed with the group that sponsored RM-11305 rule making petition. While using lofty sounding language and purporting to represent the amateur community's highest aspirations, they represent instead the views of a tiny segment of amateur radio and seek to propagate wide bandwidth modes everywhere in the available spectrum. ...While not perfect, the RM-11306 proposal from the American Radio Relay League is a much better proposal and was better thought out. With modification it could be a good proposal.” - Roy Lincoln, WA4DOU, Elm City, NC

“I am adamantly opposed to the ARRL Proposal RM-11306... [If adopted] the effect will be interference to ongoing communications that were occupying the frequency first. Also, digital and analog signals in the same pass bands are not compatible. The human operator cannot just “tune-out” the offending signal with his ear/brain combination as he can with another analog signal. Please do not allow the 'de-humanization' of the Amateur Radio Bands.” - Paul Bilberry, N5DUP, Tuscola, TX

“The FCC should reject the ARRL’s ‘Regulation by Bandwidth’ petition RM-11306 because its adoption would significantly increase interference from unattended automatic stations.” - David H. Bernstein, AA6YQ, Wayland, MA

“I find it disturbing that a minority of radio operators are currently using public forums to generate negative comments towards the ARRL plan.... I sincerely hope the FCC seriously considers RM-11306 because it will certainly provide an opportunity to promote the development of the Radio Art as defined in Part 97.1, while continuing to effectively allow existing modes use of the Amateur service.” - Edwin C. Jones, MD, Ph.D., AE4TM, Loma Linda, CA

“Despite having been filed by the ‘National Association for Amateur Radio,’ the Petition represents the parochial thinking and desires of a very small group of very focused users and experimenters in digital technology. Its premise that segmenting the amateur allocations by bandwidth alone will solve whatever problems this group saw is flawed in many ways. The premise creates multiple, and often undesirable, side effects and impacts on the remainder of the amateur community which numbers an order of magnitude larger than the proponents of the Petition. And, the Petition tampers with automatic control, greatly broadening its potential for very harmful interference.” - Fred C. Jensen, K6DGW ,Auburn CA

Petitions withdrawn

On November 6, 2006, CTT requested that its RM-11305 petition be withdrawn stating that the FCC had addressed the need for more voice spectrum in WT Docket 04-140 which “refarmed” Novice spectrum to General and higher class voice frequencies.

On April 27, 2007, the ARRL made a similar request on its RM-11306 citing "widespread misconceptions" surrounding the petition as a primary reason for deciding to remove it from FCC consideration. The League continues, however, to support the concept of regulation by maximum emission bandwidth as a way to convert from analog to digital communication modes and will probably refile the Petition later.

With little fanfare, FCC’s Scot Stone (Deputy Chief of the Wireless Telecommunications Bureau’s Mobility Division) agreed to both requests last week and recalled them both.

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