[CW] extended opportunity to comment on 04-140

[N2EY at aol.com]

In a message dated 8/19/04 6:48:08 PM Eastern Daylight Time, 
k4kyv at hotmail.com writes:


> Do we REALLY need all that specturm on 80m? 

Depends on who "we" is.

 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~.

But it's not just about CW.


> 
> 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.

Not exactly.

Currently the HF data rules are a hodgepodge of odd requirements dating from 
another era. For example, the *content* of a signal is now considered the 
determining factor by FCC. If you want to use digital voice  - regardless of 
bandwidth used - you have to do it in the "voice" subband. OTOH, "data" modes 
cannot exceed 300 baud (IIRC) - again regardless of bandwidth. Want to put a 
"PSK3100" station on 80 or 75 meters? Sorry, it's not allowed, even though the 
signal is narrower than AM voice. 

What the proposal tries to do is to sweep away the various 
content/mode/symbol rate stuff and focus on one issue: occupied bandwidth. I think that's a good 
idea, in prinicple anyway.

But all those digital/data modes need space. That's why it's not a good idea 
to just widen 75 meter down to 3600.

> 
> 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.

Not really...

The Novice and Advanced subbands will probably disappear as the licenses do, 
leaving us with just 3 license classes and subband types.  That's about what 
we have now.

> 
> 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.

We don't have *any* CW-only subbands on amateur HF now - it's *all* shared 
with digital modes. If it were up to me, the lowest 15-20% of each band would be 
CW only. 

There's also the DX-phone issue. As the US 'phone bands widen, the DX 'phones 
move lower in the band to get away from US QRM. You want 'em on 3550?

One more issue: You mention modern equipment above. One of the purposes of 
the ARS is to encourage experimentation and education. This includes stuff like 
historic preservation and, even more important, simply fooling around with 
basic equipment. And what better place than 80 meters? (That's why one of the 
original Novice bands is there - 40 and 15 came later). Even in 2004, there 
should be a place where a new ham, or one new to radio construction, can put a 
simple rig on the air (like a direct-conversion CW transceiver) and find some room 
to use it. 

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

Yep.

You watch - all of these proposals, and the restructuring proposals, will 
probably all be bundled into one NPRM at some time in the future. That's why it's 
important to comment on them now, to help shape that NPRM.

73 de Jim, N2EY