[CW] RM-11306 up for public comment

Sat Jan 14 18:50:36 EST 2006

I concur with almost the entire response.  I especially like the statements
about 160 meters, and it is beyond me why we have to continue to mix narrow
and wide band operations over the entire width of this band, which is
virtually unused in its upper portions, most of the time. In times past,
must of this band was forbidden to amateurs in certain portions of the
country or world, because of radio-location, and there were very narrow
operating portions where most operators could transmit.  That is no longer
the case, and the prohibition no longer exists, and we need to get out of
the 1950-60 mentality on it.  But, I dont believe our responses to the ARRL
proposal, concerning 160 meters will have any affect on the FCCs action
here, since It was not part of their proposal.

Regarding your statement:
"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."

One should ALWAYS listen to, and  inquire whether a freqeuncy is in use,
before procediing to transmit on it.

The subject of 40 meters is a very sore point, as you so well point out.
The rest of the world has or will shortly be authorized the 7.1-7.2 MHZ
spectrum, yet here we sit with a potential of loosing a very large portion
of this band to wide band operations such as SSB and image, just when we
are soon able to NOT have to work split for DX SSB operations.  At the very
least is should stay 50/50 with the lower 100 KC for narrow band, and the
upper 100 KC to work direct SSB/Image with Europe and Asia.  That least the
top 100 KC for domestic and Region 2 DX, giving the SSBders 2/3 and the
narrow band operators 1/3 of the band.  Even at that, I am sure there will
be much bitching and moaning by those who want to take over
total control for wide band operations.  We will always have those who will
come up and say "CW isnt restricted to just the lower portions, but can go
anywhere on the bands"  True, but have they heard the comments made by SSB
operators about CW QRM on "their" signals?
Danny

----- Original Message ----- 
From: "scott mcmullen" <scottamcmullen at yahoo.com>
To: <cw at mailman.qth.net>
Sent: Saturday, January 14, 2006 6:21 PM
Subject: [CW] RM-11306 up for public comment

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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