[CW] extended opportunity to comment on 04-140

[Donald Chester]

>i felt that it wouldn't hurt too much to allow
>radiotelephone between 3725-3750 kilohertz

Do we REALLY need all that specturm on 80m?  With the amount of cw activity 
I hear throughout the year, 3500-3600 could easily accomode, to a 
comfortable level, all the cw activity, including DX, ragchewing and net 
operation. The only time I hear the cw portion of the band filled anywhere 
near capacity is during contests, and even then, the activity pretty much 
peters out somewhere between 3600 and 3700. This is assuming reasonalble 
state of the art equipment with good frequency stability, and selectivity < 
500~.

It looks like ARRL is now proposing redefining subbands by a combination of 
bandwidth and emission mode.  There would be a < 200~ subband for cw and 
other narrow modes, a 3 khz subband for digital modes excluding voice, 
another 3 khz subband that would include voice but exclude digital, and an 
exception to allow 9 khz for DSB AM voice.

Combined with licence class segmentation, it looks like we would end up with 
a complicated matrix of subbands defined by mode, bandwidth and licence 
class, even more complex than the overly complicated subband structure that 
exists today.

I haven't had time to study the proposed petition which is posted on the 
ARRL website in detail, but at first reading, it looks like cw would have to 
share spectrum with narrowband digital modes throughout the "reserved" 
portion, which would be considerably less than the existing "cw" bands.

If the FCC goes along with the League's proposal, wouldn't it make the 
"refarming" part of 04-140 a moot point?

Don K4KYV

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