[CW] RM-11306 up for public comment

[scott mcmullen]

The ARRL's "regulation by bandwidth" proposal is up for
comment on the FCC's "Electronic Comment Filing System".

The ARRL's proposal and how to comment on it are 
described at:

http://www.arrl.org/news/stories/2006/01/09/2/?nc=1

Here are my comments; what do you all think?

Comments on Petition RM-11306

Concerning Amendment of Part 97 Rules to regulate the Amateur Radio High Frequency Allocations by
Necessary Bandwidth rather than by mode.

The concept of regulating the Amateur Radio wavelengths 
by necessary bandwidth rather than by mode is a sensible idea, and I believe that the Federal
Communications Commission should give the petition filed by the ARRL serious consideration.

There are, however, a few specifics of the ARRL petition that are not well thought out. First, I
am opposed to permitting semi-automatic RTTY or data operation on any frequency authorized for
such emission type's bandwidth. "Semi-automatic" station operation is defined in
97.221 (c)(1) as:

"The station is responding to interrogation by a station under local or remote control."

Under the current rules (97.221)(c), this type of semi-automatic station operation is permitted in
any data segment if it occupies a bandwidth of less than 500 Hz. The ARRL's petition would remove
this bandwidth restriction, and permit semi-automatic station operation in any segment for which
the used mode's "necessary bandwidth" would allow it.

I believe that the type of operation descibed by 97.221(c) should be permitted only within the
same segments as 
fully automatic operation, though I believe these 
segments should be widened to accommodate the
increased level of interest in semi-automatic operation. The reason why semi-automatic operation
is incompatible with traditional interactive High Frequency activity is because of the existence
of "skip zones" on the HF wavelengths. The "ARRL Handbook for Radio Communications" (2003 edition)
describes skip zones (p 21.8):

	The term skip zone is closely related to MUF      
      (Maximum Usable Frequency). When two stations 
      are unable to communicate with each other on a  
      particular frequency because the ionosphere is
	unable to refract the signal from one to the 
      other through the required angle - that is, the
      frequency is below the MUF - the
	stations are said to be in the skip zone for 
      that frequency.

So this means, in effect, that two stations 200 miles apart may be unable to hear each other, but
both are able to hear other stations 800 or 1000 miles away. The two stations are within each
other's "skip zone". This means that it is difficult to distinguish if a channel is
unoccupied unless one listens to it for some time, and first makes an inquiry about whether the
frequency is occupied. A nearby station within ones "skip zone" 
could be transmitting, but be unheard.

For this reason, "semi-automatic" station operation is 
not compatible with traditional interactive amateur radio activity, and should be assigned band
segments that can 
be then be avoided by other stations.

Another issue with the ARRLs' petition is the small 
size of the sub-200Hz bandwidth allocated on the 40 
meter band. The size of the sub-200 Hz allocation is 
only 35 KHz (7000-7035 KHz).  During ARRL Field Day 
2005 (the most popular on-the-air operating activity 
in North America), 503,205 contacts of the 1,217,693 completed during the event were made using CW
(a 
sub-200Hz mode), representing about 41.3% of the 
total activity. 21,766 were made using digital modes, 
and the bulk (692,722) used phone. Some unknown portion 
of the 21,766 (1.8%) used PSK31, a sub-200 Hz digital emission type that would naturally share the
same allocations with CW. So something approaching 41.5-42%
of amateur activity on 40 meters would be packed into 35 KHz of the 300 KHz available on the 40
meter band. That seems like a punitive allocation for some of the most popular modes on HF. A more
reasonable segment would be 7000-7065 KHz.

I think also that the time is right to bring the 160 
meter band within the "regulation by bandwidth" 
framework. Currently, activity of any emission type is allowed to operate anywhere within the 160
meter band, 
and the band is divided according to "Gentlemen's Agreements", which are described on the ARRL web
site 
on a page titled the "Considerate Operator's Frequency Guide"

http://www.arrl.org/FandES/field/regulations/conop.html.

As an active 160 meter operator, I've observed 
increased levels of "inconsiderate" activity, in which 
the above mentioned agreements are ignored. I think 
this represents the right time to establish 160 meter
subbands by "necessary bandwidth", and a reasonable 
sub-200Hz bandwidth segment of the 200 KHz wide 160m 
band would be about 50 KHz wide; 1800-1850 KHz.

Thany you for the opportunity to comment.

Respectfully Submitted,

Scott A. McMullen W5ESE 
ARRL Life Member


Scott McMullen, W5ESE
http://www.geocities.com/scottamcmullen
scottamcmullen at yahoo.com
Dripping Springs, Texas

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