[CW] RM-11306 up for public comment

[Donald Chester]

>From: scott mcmullen <scottamcmullen at yahoo.com>


>There are, however, a few specifics of the ARRL petition that are not well 
>thought out.

IMO, there are loads of specifics of the ARRL petition that are not well 
thought out.


>... "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.

We are in agreement on that issue.


>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.

There is nothing that says that the "sub-200 Hz" stations would have to pack 
themselves into that segment.  They would still have privileges to operate 
anywhere within the entire 300 kHz of the band they so choose.  During a 
major cw contest, cw stations can usually be heard up to about 7060 and 
higher.  This means merely that the cw activity would share the band with a 
few scattered RTTY and other types of data signals, just exactly as it does 
today.

Ever listen to 160m during a cw contest and during a non-contest weekend?  
During non-contest periods, 99.9% of the cw activity remains below 1840 kHz. 
  Diring a major 160m cw contest, cw activity is often heard as high as 1880 
kHz, with spots of non-contest cw activity all the way up to the top end, to 
avoid contest QRM.  Cw activity, contest and non-contest alike tends to 
congregate towards the bottom end of all hf bands, and extend upwards as 
necessary to accomodate the number of stations transmitting.  During periods 
of light cw activity, other modes would be free to use the spectrum.


>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"...
>As an active 160 meter operator, I've observed
>increased levels of "inconsiderate" activity, in which
>the above mentioned agreements are ignored.

This issue was already brought before the FCC in a previous petition, and 
the commission rejected it.  I am active on 160, both on cw and on phone.  I 
rarely hear phone activity below 1840 kHz, except during SSB contests, when 
SSB stations usually fully occupy the band all the way down to 1800 kHz.
Other than during contest weekends, it seems to me that the "gentlemen's 
agreement" works pretty well.  I see no justification to ask for new 
fulltime FCC restrictions to accomodate at most a few days of contest 
activity that occur throughout the entire year.

The contest problem could be better alleviated by the contest sponsors 
including ARRL and CQ Magazine, who could very easily mandate that contest 
operation comply with accepted band plans, under the penalty of 
disqualification from the contest.

Don K4KYV





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