[160m] FCC Filing for narrow mode segment

[Tom Rauch]

> I haven't had a chance to review the entire text of the rulemaking
> petition, but isn't this a bit disingenuous?
> 
> After all, aren't what Bill and Jeff calling for is essentially 
> mode-segregation like we have on every other HF band? 

No. NONE of our bands restrict CW, although data modes are  
restricted from some phone bands. The reasoning is technical, and 
very simple for anyone to understand.  

First, a narrow mode can be removed from a wide mode effectively 
with little or no loss in intelligibility of information on the wide mode.

The reverse is not true, a wide mode totally destroys a narrower 
mode and can not be "notched out".

Second, narrow modes almost always get through marginal 
conditions better. It would be a needless handicap to restrict a 
more space-efficient mode from use in areas where wide modes 
are permitted.   
 
> And isn't the mode-segregation we have on every other HF band involve
> placeing digital modes low, analog modes high, and CW everywhere?

No. Not in the RM.  
 
> Wouldn't that affect digital modes like PSK? Digital modes are
> currently permitted EVERYWHERE on 160m. If RM-10352 is made law,
> wouldn't they be restricted to 1800-1843 kHz?

No. There is no reason to. 

First, RTTY is not an extremely useful mode for 160 meters 
because of multipath propagation. Second, PSK and other very 
narrow modes really are no worse than CW for causing interference 
to phone transmissions.

PSK people really don't need a lot of space even with hundreds of 
users. A few kHz around 1810-15 or 1840-43 would good enough, 
and that would align them with the rest of the world.

PSK and MFSK need (since users primarily run low power) 
protection from strong wide signals, just like CW does. The 
amateur world is more than DX, more than local SSB ragchews, 
more than contests, and more than CW. We have to consider the 
future of ALL modes, especially modes that show we are doing 
something useful or innovative with our privileges to have spectrum.

The only people this RM will affect are those who wilfully violate the 
present bandplan.
73, Tom W8JI
W8JI@contesting.com