[CW] Speak Now or Forever Hold Your Peace

[Bill Tippett]

Fellow CW Lovers!

        Some of you know that we participated in the ARRL 160 Bandplan
Committee last year.  While we were very pleased with the resulting
voluntary bandplan, it became clear to us that the bandplan lacked the
teeth to enforce mode segmentation on 160, so we filed a Rulemaking
Petition with the FCC on September 10.  Indeed, an SSB group on 1823 
continued their activity after the new bandplan was adopted by the 
ARRL Board last July.  They had been violating the previous ARRL bandplan
restricting SSB below 1840 for at least the past 17 years that we are 
personally aware of.  Fortunately, Riley Hollingsworth sent 3 warning 
letters to these amateurs this Fall.  While we certainly applaud his
actions, we remain concerned that it may be very risky to assume that
enforcement of voluntary bandplans will stand the test of time, 
especially if Mr. Hollingsworth should retire or move on and we get
the same level of enforcement we had before he arrived in 1998.

        We believe there will be increasing pressure on the 160 CW band
as sunspots decline, more activity migrates to the low bands and as more 
low-code (and eventually no-code) general class operators are licensed.
If you feel as we do that 160 CW deserves the same protection that
EVERY OTHER HF amateur band enjoys today, we encourage you to carefully
read our petition and comment to the FCC.  The petition was assigned
RM-10352 by the FCC on January 8 and there is now a 30 day window for 
public comment (closing on February 7).  In order to make it easy for
you to read, we have posted the entire petition at:

                http://users.vnet.net/btippett/rm_petition.htm

While the full Webpage including appendices appears lengthy, the petiton
itself (III on the Webpage) is the equivalent of 6 single-spaced pages.  
If that is too long, please read the Executive Summary (II on the same
webpage).  In brief, RM-10352 is basically NO CHANGE to present FCC
regulations with the SOLE exception of limiting wideband modes (SSB, AM 
and SSTV) to 1.843-2.000 MHz, which effectively protects an exclusive 
narrowband area below 1840 for CW and narrowband digital/data (PSK31, 
QRSS and whatever new narrowband digital modes may develop in the future).
CW would continue to be allowed on all amateur frequency allocations
consistent per FCC Part 97.305(a).

        The easiest way to comment is via this Webpage:

http://gullfoss2.fcc.gov/prod/ecfs/upload_v2.cgi

Just enter RM-10352 in the first box, fill in all the non-optional 
boxes and then enter your comment in the bottom box...it can be as 
simple as I support/do not support RM-10352.  Click "Send Brief 
Comment" and you are done!  If anyone has problems with this, W4ZV
will be happy to help you through the process.

        If you prefer to submit via E-mail, it's a bit more complicated, 
but it is described in detail here:

http://www.fcc.gov/e-file/email.html#datareq
 
If you have any problems, please contact W4ZV at btippett@alum.mit.edu
he will be happy to help you through the process.

        That's all there is to it.  Please take a few minutes NOW to 
carefully read our petition and, in your own words, comment to the FCC
before February 7.  We would hate to imagine that 160 could become 
full of local SSB nets that decide to migrate from 75meters in a few 
years, but should Hollingsworth move on, it could happen without the 
force of law that protects narrowband modes on all other HF bands!  
As someone once said "Speak now or forever hold your peace".

                                        73,

                                        Jeff K1ZM and Bill W4ZV

Reference information:

Current ARRL Voluntary 160 Bandplan:
http://www.arrl.org/FandES/field/regulations/bandplan.html#160m

IARU Regional Bandplans for all 3 IARU Regions:
http://www.iaru-r2.org/hf_e.htm

Current FCC Part 97.305(a) and 97.305(c) regulations:
http://www.arrl.org/FandES/field/regulations/news/part97/