[CW] "Refarming" = Reassignment

[Karl J. Zuk]

I looked at the comments to the FCC regarding the ARRL's proposal for 
rulemaking RM-10413 which would slice away at the CW allocations in favor of 
SSB operators. The comments run about 4 to 1 in favor of the SSB crowd. Some 
of the comments are as simple as "I am against this proposal." Please take 
the time to file your comments before the May 16 deadline so we do not lose 
additional spectrum space dedicated to CW and other digital modes.

To file your comment, go to: 
http://gullfoss2.fcc.gov/prod/ecfs/upload_v2.cgi
and enter RM-10413.

Here is a draft of the comments I will file shortly. Your ideas and 
suggestions would be appreciated. Many thanks, Karl Zuk N2KZ

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554


In the Matter of 	)
	)
Amendment of Part 97 of the Commission�s 	) 	RM-10413
Amateur Service Rules Governing 	)
Operating Privileges 	)
To: The Commission
COMMENT REGARDING PETITION FOR RULE MAKING

1. Importance of Current Allocations
The "Novice" amateur radio spectrum allocations continue to be a training 
ground for all amateurs wishing to improve their skills in Morse. They 
remain to be a set of allocations where people of similar skill levels 
congregate to learn from each other in a well-organized domain. This 
petition of rule making negates this distinction and destroys the incentive 
to improve operator skills. "Novice" band segments are specifically 
allocated to effectively serve people learning to communicate in Morse 
without intimidation from seasoned operators sending at higher speeds; and 
to encourage CW operation now and in the future.
The ARRL proposal would be most damaging in the already overcrowded 40 meter 
band, especially during nighttime hours when the 7100 kHz to 7150 kHz 
spectrum is often filled with international broadcasters. It is much easier 
for narrowband CW and other digital modes to co-exist with broadcasters in 
this crowded and over-used spectrum than to encourage and endorse broadband 
modes like amateur radio SSB to compete for this space.
2. Removes Important Incentives
The ARRL should not encourage operators to abandon or discount CW, the most 
reliable and simple mode of transmission, especially during a period 
necessitating high preparedness for homeland security. CW has been relied 
upon for decades as the most reliable means of communication during 
emergencies. Do not clutter these essential allocations with unneeded, 
inefficient and less-reliable broadband transmissions.

3. Flawed Portrayal of a Casual Poll
The ARRL did not mention their poll was a preamble to a petition of rule 
making when presented on-line and in print. It appeared as an entertaining 
playful poll similar to others often seen on the ARRL web site and QRZ.com 
and eham.net. It was not portrayed as a meaningful poll with serious 
consequences. The underlying effect of reducing the size of allocations for 
exclusive CW operation was not emphasized until very late in the ARRL's 
polling and notification process. This was long after they had achieved the 
results that would support their intent. After tallying the inconclusive 
results, the ARRL went further and devised their own scheme for a revised 
band plan without further polling or seeking input from the rank-and-file of 
their membership and the amateur radio community in general. Less than 5,000 
replies, possibly not unique and of unknown origin, became a representative 
sample of 700,000 licensed amateurs to support the desires of the ARRL. This 
poll is not a credible source of accurate information or a firm foundation 
for a rulemaking proposal. Never was the term "refarming" properly defined 
as "reassignment."
4. Author Background
The author of this comment is a member of The ARRL and holds an extra class 
amateur radio license, N2KZ and a General Radiotelephone Operators License. 
Accreditations include active volunteer examiner status with the ARRL and 
the W5YI National Radio Examiners. The author has been employed as a 
broadcast engineer since 1968, currently working with CBS Television in New 
York City.
5. Summary
Therefore, I respectfully ask The Commission to retain the current 
allocations as provided in Part 97 of FCC regulations. Digital modes, 
created either manually by operators or by computer assistance, continue to 
grow in importance as a reliable and spectrum-efficient communication 
method. Please retain the allocations necessary to continue current CW 
operation, and encourage the development of new digital modes. Spectrum 
dedicated primarily to CW should not be diminished at this critical time. I 
urge The Commission to secure these pivotal allocations for utilization 
today and to encourage the continuation of digital modes of operation for 
generations to come.
Respectfully submitted,
Karl J. Zuk - N2KZ







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