[AMRadio] Confusion over Docket 20777

[Donald Chester]

I'm afraid there has been some confusion over Docket 20777, because of the 
subject line of a previous posting. This was a proposal that came out in 
1976, which would have redefined the subbands by bandwidth instead of mode. 
The proposed bandwidth standards on all HF bands below 28 mHz would have 
been 350 Hz and 3.5 kHz. Of course, that would have precluded AM on 160 
through 15m. The AM community that existed at that time generated a lot of 
comments in opposition, something the FCC had not expected. The prevailing 
opinion of that day was that AM was dead, and that practically no-one still 
used it. As a result of the unanticipated opposition, the bandwidth 
proposals under the docket were rejected. I remember Johnny Johnston pissing 
and moaning at an FCC forum, "We had a good proposal, but it was shot down 
by a handful of hams who want to keep on using the same rigs they have had 
for 25 years."

The present issue is what is contained in Minute 64 adopted at the most 
recent ARRL Board of Directors meeting on July 19-20, 2002:
(Source: http://www.arrl.org/announce/board-0207/ )

64. On motion of Mr. Frenaye, seconded by Mr. Stinson, it was VOTED that at 
the next practical opportunity the ARRL shall petition the FCC to revise 
Part 97 to regulate subbands by signal bandwidth instead of by mode.

This is precisely what Docket 20777 proposed, but so far the only thing that 
has actually taken place is that the ARRL Board of Directors made a decision 
that the League will eventually file a petition to the FCC. The reasoning 
behind it is that certain digital modes don't fit the present subband 
structure - they are too wide for the cw bands and not allowed in the phone 
bands.  League officials assert that this reflects no intent to place 
limitatations on AM. According to Dave Sumner, K1ZZ,

"The Board has given us no instruction as to what the petition should 
propose with regard to bandwidth. Absent instructions to the contrary, what 
we draft will not propose new restrictions. But it's certainly true that in 
going from a regulatory regime based on mode of emission to one based on 
bandwidth there are bound to be consequences, intended and otherwise, that 
will have to be considered very carefully. In any event, the Board will get 
a look at it before it goes anywhere."

That is the problem - the possibility of unintended consequences. You never 
know how the FCC will react to a petition. They often make what appear to be 
totally arbitrary decisions and come up with proposed rulemakings completely 
different from what was originally petitioned. The concern here is that they 
might propose something that would "incidentally" have an adverse effect on 
AM. That is precisely what happened with the p.e.p. power limit.

To avoid confusion when writing to anyone on this issue - ARRL or FCC 
officials or to other amateurs, any reference to Docket 20777 should be 
accompanied by a clear explanation that this was a bandwidth proposal under 
consideration by the Commission 26 years ago, and it is mentioned now only 
because the text of Minute 64 appears so similar.

Don K4KYV


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