[CW] Baud Rate Petition

[Donald Chester]

The ARRL's Baud Rate petition was assigned RM-11708 on 21 November. The
deadline for filing comments is in just a few days, the 20th of December. So
far over 400 comments have been submitted, as of the last time I checked the
FCC site. This means we have only a few days remaining to make a submission.

Something that might be of concern to CW operators is that if the rules are
changed as proposed in this petition, digital modes would be allowed to
transmit signals of  the same nominal bandwidth as SSB, 2.8 kHz, across the
entire CW sub-bands.  

If this is to be allowed, what is the point of having  sub-bands at all? Why
not just make all the bands like 160 with no mode restrictions in the rules.
Digital data would still not be allowed in the "phone" bands under this
proposal, yet digital voice and digital SSTV would be allowed in the voice
sub-bands. A digital signal is a digital signal, regardless of the  content
of the digital data, whether text, voice or images, so why even bother with
the distinction?

My suggestion would be to maintain protected segments at the bottom ends of
each HF band for narrow-band modes, much like the segments at the low ends
of 2m and 6m, and allow wide-band digital stuff only in the phone bands. The
existing phone bands could even be slightly expanded to accommodate the
additional digital signals and still afford better protection to CW and
other narrow-band signals, if wide band digital operation is removed from
the  "cw" bands and moved to the "phone" bands.

I don't think the "subbands by bandwith" as in the defunct ARRL bandwidth
proposal of a few years ago is a good idea. I would be leery of the
precedent set by any specific numerical bandwidth limitation for any mode on
HF. The digital stuff allowed in the phone bands  could be given a
non-specific limitation, something like "not to exceed the bandwidth of a
communications quality SSB signal". I notice that many of the commenters to
this petition are using this opportunity to propose re-activation of the
defunct  subbands-by-bandwidth proposal, which was abandoned some years ago
before the comment period even ended.

I would encourage all CW enthusiasts to carefully read this petition and
scan through the comments submitted  so far, and compose your own thoughts
to the FCC in response. Many of the comments that have come in so far merely
parrot what was published in the QST editorial and stated in the petition,
without including any new ideas. The FCC is looking for additional
justification pro- or con, not  merely repetition of what has already been
submitted. The information below should be helpful for using the FCC's
Electronic Comment Filing System.


The Public Notice can be viewed at
http://apps.fcc.gov/ecfs/document/view?id=7520959109 

Comments may be viewed at
http://apps.fcc.gov/ecfs/comment_search/input?z=896ij  Type in RM-11708 in
the box at the top labelled "Proceeding Number".  The original petition can
be viewed by going to the last page of the comment list. The first page
displays the most recent comments, while the last page displays the earliest
comments and the original petition.

To file your own comments, go to http://apps.fcc.gov/ecfs/comment 

You will see a menu on the right-hand side of the page with links for
submitting a full-fledged lengthy comment, and for a shortcut to type in and
submit a brief comment much like you would do to send an e-mail.

Don k4kyv


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