[CW] Fwd: [SEDXC] Here's the latest explanation as to what is going on with RM 11306

[Ed Tanton]

In fairness to everyone on either side of the recent controversy, I 
think you should all read this. To be completely honest, I'm not 
certain what it says... but still, I think we all need to read-and 
re-read-it until what it says vs what we think they said makes sense. 
I received this from the SEDXC Reflector. Try and not shoot either me 
or Bob as we are only the messengers.

>Hi all,
>    This was forwarded to me by one of the guys in the  Eastern Iowa DXA...
>Bob
>K4UEE
>
>In July 2002 the ARRL Board of Directors adopted the  following policy: "At
>the next practical opportunity the ARRL shall petition  the FCC to revise
>Part 97 to regulate subbands by signal bandwidth instead  of by mode." The
>Board's objective was to update rules that were written  long before the
>development of the current generation of digital modes so  that digital
>emissions can be appropriately regulated in the future, while  impacting
>traditional modes as little as possible.
>Turning that statement  of principle into a detailed petition proved to be
>no  easy task. The  Board received input from an ad hoc committee as well
>as  staff, and  twice solicited input directly from the ARRL membership.
>Hundreds  of  comments were received each time and helped inform the
>Board's   discussions. Finally, at its July 2005 meeting the Board
>concluded its   review of a draft petition and authorized its filing,
>following final  review  by the Executive Committee. The resulting petition
>was filed on  November 14,  2005 and was designated RM-11306 by the FCC,
>after which  additional comments  were filed by individuals directly with
>the  FCC.
>Once the FCC had dealt with two outstanding proceedings, WT Dockets  04-140
>and 05-235, we realized that the bandwidth petition was the next major
>Amateur Radio item in their hopper. On reviewing the RM-11306  petition,
>the  comments, and the rules changes adopted in Dockets 04-140  and 05-235
>it was  apparent that some of the proposals contained in the  petition had
>been  affected by the changes adopted in the other two  proceedings. It was
>also  apparent that some aspects of the petition  remained controversial.
>After reviewing the situation at its January 2007  meeting, the ARRL Board
>authorized General Counsel Chris Imlay, W3KD to  determine what changes to
>the petition had to be made to align it with the  new FCC rules, as well as
>which aspects of the petition were not  controversial and could reasonably
>be  expected to be included in an FCC  Notice of Proposed Rule Making.
>Chris did  so, and a meeting was held  with FCC staff on February 13. As
>are all such  meetings, this was made  a matter of public record by the
>filing of a notice  with the FCC  Secretary that immediately became part of
>the online record in   RM-11306.
>The FCC staff was provided with a shortened list, or subset, of  proposed
>rule changes from that contained in RM-11306. The list is included  with
>the  notice of the meeting. Because the proposals affecting the  bands
>above 28  MHz had not aroused much controversy, they were retained  in the
>shortened  list. Regulation by bandwidth rather than by mode of  emission
>remains  controversial below 28 MHz because of perceived  potential impact
>on  established operating patterns, so these proposals  were removed from
>the  list with one narrow exception. The exception is  necessary because,
>as  discussed on page 11 of the RM-11306 petition,  under the existing
>rules  there is presently no effective bandwidth  limit on HF digital
>operations.  Digital emissions using multiple  carriers, such as OFDM, can
>be designed for  any bandwidth while staying  within the existing rules.
>So, the subset of  proposed rule changes  given to the FCC on February 13
>includes a bandwidth  limit of 3 kHz on  RTTY and data emissions below 28
>MHz. It is important to  understand  that this does not increase the
>allowed bandwidth for RTTY and  data  emissions; it actually represents a
>new limitation that accommodates   existing practice but prevents future
>monopolization of large segments  of  our narrow MF/HF bands by a single
>digital station. Also, the limit  would  not apply to phone emissions.
>Some confusion has resulted from an  item that, through oversight, was not
>deleted when the list of proposed rule  changes was shortened. Because
>RM-11306 had proposed that bandwidths in most  of the band segments now
>used  for CW and RTTY be limited to 200 Hz and  500 Hz respectively, the
>existing  500-Hz bandwidth limit that applies  to certain automatically
>controlled  RTTY/data stations was redundant  and could be dropped.
>However, because the  subset of proposed rule  changes does not substitute
>regulation by bandwidth  for regulation by  mode of emission, the 500-Hz
>limit needs to be retained.  General  Counsel Imlay has filed an erratum
>with a corrected list of proposed   rule changes that makes it clear there
>should be no change to the  existing  Section 97.221. We regret the error.
>Some amateurs have  observed that the subset of proposed rule changes
>provides less protection  to CW, RTTY and other narrowband modes than was
>afforded by the ARRL's  proposals in RM-11306. This is true. However, it is
>not true that less  protection is afforded than is the case with the
>existing  rules. In  fact, protection against interference from wide
>digital modes  would be  increased, not decreased, by adoption even of the
>subset. The ARRL Board,  having studied the situation literally for years,
>continues  to support  the principles of regulation by bandwidth that are
>contained in  the  original RM-11306 petition. Regulation by bandwidth
>provides a better   regulatory framework, not only for the introduction of
>future digital   emissions but for the protection of traditional narrowband
>modes as well.  By  providing the FCC with a subset of the modifications
>proposed in  RM-11306  the ARRL has offered an alternative that, it is
>hoped, will  make it easier  for the FCC to move at least part of the way
>in that  direction.
>David Sumner, K1ZZ
>Chief Executive Officer, ARRL
>March 22,  2007

Ed Tanton

website: http://www.n4xy.com

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