[AMRadio] Subbands and AM

[Donald Chester]

Following the release of Docket 02-98 which includes a proposal for a new 
amateur band at 5250-5400, there has been an ongoing debate whether this new 
band should be sliced up into subbands.  An apparently organised effort by 
the same people who petitioned the FCC for subbands on 160 has resulted in 
dozens of comments to the Commission requesting that the band be divided.

It has been pointed out in some of the comments that it is no longer a 
simple matter of creating "cw" and "phone" subbands.  At present, AM, double 
sideband without carrier, SSB, FM and slowscan TV are permitted in the 
"phone" bands, while CW, RTTY, PSK-31 and other narrowband digital modes are 
premitted in te "CW" subbands.  Although CW is allowed throughout each 
amateur band, other digital modes are restricted to the "CW" subbands.  With 
the emergence of new digital communication methods, we may soon have digital 
modes that occupy far more bandwidth than the traditional narrowband modes.  
Probable examples include digital voice and image transmission.

Already in the 02-98 comments, some of the pro-subband people are calling 
for not two, but THREE subbands: CW-only, CW/digital and CW/phone. They 
claim that some digital communication already creates undue QRM to CW 
operators, as they forsee new, wideband digital modes in the near future.  
Could you imagine the complicated mess that would result, if we had three 
mode subbands, combined with the various licence class subdivisions, on all 
amateur bands?

I am afraid that if the pro-subband people convince the FCC that the amateur 
community wants the bands sliced up, the Commission will balk at the idea of 
further complicating an already complex subband system and revisit the idea 
originally proposed under Docket 20777 back in the 70's: creating subbands 
based solely on BANDWIDTH, with no reference to specific modes.  That one 
was touted by Johnny Johnston as "Deregulation", but it just happened that 
the proposed "wideband" subbands limited all signals to SSB bandwidth.  
Under 20777, AM was to have been "deregulated" out of existence.  Those whe 
were active on AM in the mid 1970's will recall it was only after a long, 
bitter letter writing campaign, mostly from the AM community, that the FCC 
ultimately rejected the concept of slicing up the bands by signal bandwidth.

Even if a new bandwidth docket included provisions for AM this time around, 
we still would be saddled with specific bandwidth limits, much as exists in 
Canada today.  The Canadian authorities apparently have an unwritten policy 
of not enforcing this rule at present, but a change in policy could occur.  
Also, specific bandwidth limits could easily become a vehicle for selective 
enforcement.  Aa expressed at the recent FCC Forum at Dayton 2002, the FCC's 
current thinking is not to impose specific bandwidth limits to amateur radio 
signals, since this would stifle experimentation.

With too much pressure coming out of the amateur community asking for 
subbands, the FCC just might change its mind and opt for specific bandwidth 
limits as an easy way out of an otherwise impossibly complex subband system. 
  If this happens, considering the past 30 years of history at the FCC in 
Washington, I would almost guarantee that some kind of new, undesirable 
restriction would be imposed on AM operation.

THAT IS WHY I STRONGLY URGE EVERYONE TO FILE COMMENTS TO DOCKET 02-98 ASKING 
THE FCC THAT 60M. NOT BE DIVIDED INTO SUBBANDS.


It is very easy to file comments electronically.  First, go to

              http://www.fcc.gov/e-file/ecfs.html

To the left, you will see a menu under the heading "ECFS main links". You 
can click on "Search for Filed Comments" to read what has already been 
submitted (this requires Acrobat Reader; if you don't have it, it can be 
quickly downloaded off the Net).  To submit comments of your own, click 
"Submit a Filing".  A form will pop up with instructions. A window opens up 
where you can directly type in "brief" comments, or you can compose your 
filing in text form and paste into the window, or send as an attachment.  
Instructions are given.  There are also detailed instructions on how to file 
your comments by normal e-mail.

The pro-subband people are taking advantage of the ease of e-filing and 
attempting to "stuff the ballot box" with pro-subband comments.  The FCC 
needs to be aware that this is NOT the near-unanimous desire of the amateur 
community.

AND WE DON'T WANT DOCKET 20777 TO REAR ITS UGLY HEAD AGAIN!

Don, K4KYV

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