[Boatanchors] Petition to eliminate exclusive CW bands

[Glen Zook]

There is one thing that the petition does and that is to allow wider "WinLink" and other unattended data streams which will, basically, "wipe out" other forms of data including CW on a regular basis.  "WinLink" is used primarily by boaters to circumvent having to pay for Internet access while afloat.  It also "back doors" the ARRL petition to remove phone operation from the 3600 kHz to 3650 kHz allocation.

It will not take very many "WinLink" and other wide band data emissions to make operation by the vast majority of amateur radio operators difficult, if not impossible.  This is just another of the ARRL's bandwidth proposals which, previously, have been "shot down" by the vast majority of responding personnel.
 Glen, K9STH 
Website: http://k9sth.net

      From: Jim Wiley <jwiley at gci.net>
 To: manualman at juno.com; boatanchors at mailman.qth.net 
 Sent: Sunday, May 15, 2016 4:30 PM
 Subject: Re: [Boatanchors] Petition to eliminate exclusive CW bands
   
It appears that this issue is once again generating oceans of 
misinformation surrounding small islands of fact.

Points:

(1)  No one will lose anything!  The CW bands are not "going away".

(2)  CW will remain an authorized mode for all bands and all amateur 
frequencies.  Ref:  FCC part 97 rules, section 97.  See 47 CFR 
97.305(a).  The correct mode designator for "CW" is 150HA1A, which has a 
nominal bandwidth of 150 Hz.

(3) Each "exclusive CW segment" already includes authorizations for RTTY 
and data transmission.  Data transmissions must use publicly documented 
formats and codes.  There are some additional rules that apply to 
undocumented codes, but for the most part, they are also permitted with 
some additional reporting requirements and restrictions that must be 
observed.

(4) Currently authorized CW, data, and RTTY modes are already,  by 
definition,  narrowband emissions.  FSK (RTTY) and data emissions must 
be limited to a maximum data rate of 300 baud (excepting the 10 meter 
band, which permits 1200 baud rates) with a maximum mark/space shift of 
1 kHz for all MF and HF bands, including 10 meters.    The vast majority 
of stations use 170 Hz shift.

After reading  the petition, I do not see any significant change between 
the proposal and the part 97 rules as they exist today.  The only change 
would appear to be in the terminology used to describe the modes, for 
example changing existing descriptions to "symbol communications".

There is, however, one change proposed that would expand "conventional" 
AM  transmissions between 1.8 and 29.7 MHz to 8 kHz bandwidth (2 kHz 
more than allowed by current rules), and to 20 kHz bandwidth on 6 
meters, 2 meters and, and 1 1/4 meters, and even higher bandwidths at 
430 MHz and higher.  I am not commenting on this portion of the petition.

But, returning to the original "scare" message, my opinion is that the 
petitioner is in error as to the supposed point of the issue concerning 
CW subbands, and I would not be surprised if the filing is rejected by 
the FCC.

FWIW