FWD: Re: [CW] An AM View of the World

[Bill Tippett]

Dear Phil, et al:

        Let me summarize what I believe this issue is really about:

1.  Narrowband and wideband modes are technically incompatible.  The
FCC has long recognized this since the beginning of AM.  Why?  While
it is possible for a wideband user to filter narrowband interference
using a simple analog notch filter (or alternatively DSP today), the 
converse is not true.  There is little information content lost in 
voice transmissions when a narrowband notch filter is placed anywhere 
within the 3 kHz voice passband.  Conversely, a narrowband user 
cannot filter wideband signals since wideband interference completely 
fills his narrowband mode passband.  This is the technical basis for
mode segmentation which has been in place for all amateur HF bands, 
160 meters excluded, for as long as we have had wideband modes.

2.  Mode segmentation has worked very well on all HF amateur bands 
excluding 160 meters where it was never been implemented.  If you
check the past 3 years of FCC enforcement actions, you will find 
the only enforcement action (3 letters) for intermodal interference 
was on 160.  The 160 experience is instructive because it demonstrates 
the problems inherent with voluntary bandplans.  While 99.9% of us
will follow voluntary bandplans, there are always a few who will
not...unless it is a regulation.  Unfortunately there are always a 
few misguided souls who belive it it their right to ignore voluntary 
bandplans as the 1823 group did for 17 years I am personally aware 
of.  This simply does not happen on our other HF bands because people
know they will lose their license if they try it.  K4KYV made the
following statement recently:

"Recall that before Riley came on the scene, the local SSB group COULD HAVE 
set right down on 14,010 with impunity, presently existing legal subbands 
notwithstanding."

This is simply not true.  Intentionally operating SSB on 14010 would have 
resulted in quick FCC citations well before Special Counsel Hollingsworth 
arrived on the scene...the only thing he added was enforcement of voluntary 
bandplans.  While Hollingsworth did remove the group on 1823, I feel
it was very inefficient since it took 17 years to get any FCC action and 
was an unnecessary waste of FCC resources, since mode segmentation had 
already been proven to work with little or no FCC intervention on all
the other HF bands for many years.

        I believe most of your remaining comments have to do with 
the amount of spectrum set aside for wideband modes on our bands.
For the record, I agree that current wideband segments should be 
expanded on the 80, 40 (after upcoming WRC 2003 decisions) and 15 
meter bands and so stated in my response to ARRL's RM-10413 (Novice 
Refarming) repeated below.

        Where I part ways with both you and K4KYV is the idea that we
completely abolish mode segmentation on all bands.  As stated before,
we've been there and done that on 160 (with the problems cited above)
and should not repeat that experience elsewhere.  Rather than lightening
the FCC's workload, this would likely guarantee lifetime employment for 
several more Special Counsels which you and I would fund as taxpayers.
For those who are Libertarians, the result of total deregulation can 
be observed at any time by tuning your dial to 27 MHz.  

        An additional comment has to do with the experimentation issue.  
For your information, that "antiquated" CW mode was the mode used to 
make the first Transatlantic QSO between North America and Europe on 136 
kHz last year.  Granted it was using QRSS (~0.8 WPM) with spectragraphic
DSP to achieve ultra-narrowband filtering, but it was CW.  CW is also
regularly used for weak signal work whether it is moonbounce on the
VHF bands or working long path propagation modes on 160.  There will
surely be new narrowband digital modes (WSJT for example) which may
evolve into popular modes for weak signal work, but CW remains the weak
signal mode that has proven to work most effectively on the low bands
today...primarily because CW's very narrow bandwidth allows better 
rejection of both man-made and atmospheric noise most common on the low 
bands.  CW is just one of many narrowband modes which need protection
from wideband interference.  Even if CW eventually disappears, other
narrowband digital modes will need the same protection for the reasons
stated in paragraph #1 above.

        One final point for you or K4KYV to consider.  If you believe 
in voluntary bandplans, why are you resistant to legal segmentation?  
Both the current ARRL and all 3 IARU voluntary bandplans specify no 
wideband modes below 1840.  What difference does it make to a good
citizen whether this is voluntary or mandated?  If you already follow
voluntary bandplans, the impact would be zero.  For those who intend to 
violate them, their opposition is more understandable, but I hope you 
do not fall into that category.  

        I believe laws exist to protect citizens who obey laws 
(voluntary or mandated) from those who do not.  In my opinion, good 
(mode) fences make for good neighbors, which has already been proven 
to work well for many years on every HF band excluding 160. 

                                              73,  Bill  W4ZV

(My comment to the FCC regarding RM-10413):

Dear FCC:

        I strongly support the general concepts proposed in RM-10413 of
allowing Novice and Technician Plus licensees access to a broader range of
frequencies on the 80, 40 and 15 meter bands for Narrowband modes while
expanding frequency allocations for Wideband modes for higher class
licensees.  However, I question whether the ARRL proposal goes far enough
in providing additional Wideband spectrum.

        Listed below are the percentage of HF spectrum by band currently
allocated exclusively for Narrowband modes compared with proposed
allocation changes if proposed RM Petitions 10352 (160 meters) and 10413
(80, 40 and 15 meters) are adopted (other bands included for reference):

                  NARROWBAND ALLOCATIONS BY BAND

Band     Current %    Proposed %  Proposal    Narrowband/Total (kHz)
160         0            20       RM-10352      40 / 200
80         50            45       RM-10413     225 / 500
40         50            41.7     RM-10413     125 / 300
30        100           100       No change     50 / 50
20         42.9         42.9      No change    150 / 350
17         42.0         42.0      No change     42 / 100
15         44.4         44.4      RM-10413     200 / 450
12         40           40        No change     40 / 100
10         17.6         17.6      No change    300 / 1700

        As a co-sponsor of RM-10352, I believe 40 kHz or 20% of the 160
meter band is adequate for Narrowband modes on the Topband due to
activity levels and other considerations.  However, I question whether the
above Narrowband allocations for 80 and 15 meters may be larger than
necessary given the higher Wideband activity levels on these bands.  40
meters is a special case due to ITU Region 1 & 3 broadcast interference
above 7100 which may best be revisited after upcoming WRC 2003
decisions about a common worldwide amateur allocation for 40 meters.

        I am a strong advocate of Narrowband modes being a superior means
of communicating under adverse conditions including the interference, noise
and fading so common on the lower HF frequencies, and I strongly support
the ARRL's proposed expansion of Narrowband frequencies for Novice and
Technician Plus licensees.  However, I do urge the Commission to carefully
consider expanding the proposed Wideband allocations for 80 and 15 meters.

                                        Respectfully submitted,

                                        William R. Tippett  W4ZV