[CW] Confusion over RM-11769, RM-11759 and RM-11708

[Donald Chester]

I hope this will help clear up some of the confusion over the recent spate
of Petitions to the FCC.  RM-11769, submitted by James Edwin Whedbee, N0ECN,
proposes to change the wording in Part 97 rules to rename the CW/RTTY/data
sub-bands "Symbol", which would be consistent with the FCC's prior decision
to rename the AM/SSB/SSTV segments as "Phone/Image". This would have no
effect on operating privileges. The confusion comes from the misleading
title of the Petition:  "... to Redesignate Sub-bands from Exclusively Morse
Code to Narrowband Modes, including CW and other purposes." In an attempt to
write his petition in a legalistic style of English, Whedbee has muddled his
clarity of meaning.

The proposed change in wording in Part 97 to "Symbol" is purely semantic; it
wouldn't actually change a thing,  since the so-called the "CW bands" are
already shared with RTTY and "data" and have been for decades.  The
remaining "CW-only" sub-bands are at 50-50.1 and 144-144.1 MHz, in addition
to the 80, 40 and 15m CW privileges granted to Novices and Techs after the
old Novice bands were eliminated. Whedbee proposes to allow RTTY and "data"
in the 6m and 2m CW segments, and to allow Novices and Technicians to use
RTTY/data in the 80m/40m/15m segments where they are presently allowed CW
only, but these are separate issues altogether, and have nothing to do with
the proposal to change the nomenclature of the CW/RTTY/data sub-bands to
"Symbol.

The overwhelming majority of comments opposing this petition appear to be
coming from CW operators concerned about the degradation they worry that the
proposed changes would cause to CW operation. The confusing wording of the
title and text in the petition have obviously led to misinterpretation by
many of those who submitted comments; many of those comments miss the point.
The real issue of concern is SPECIFIC BANDWIDTH LIMITS that would be imposed
on all modes used by amateurs in the HF bands. Under the current rules (with
a few exceptions), no specific, numerical bandwidth limits are prescribed in
Part 97.  The non-phone sub-bands (the ones we often call the 'cw bands',
which Whedbee wants to call 'Symbol' sub-bands) are currently limited to
narrow-bandwidth signals by the FCC's cap on symbol-rate, 300 bauds on
frequencies below 28 MHz.  Keeping data speeds within the current maximum
baud-rate inherently limits the bandwidths of RTTY and data modes, without
the need for specific bandwidth limitations in the rules. 

In November 2013, ARRL submitted a Petition to the FCC, RM-11708, to delete
the current 300-baud cap on symbol rate and replace this with a specific
bandwidth limit of 2.8 kHz in the band segments where RTTY and data
transmission are allowed. Whedbee's Petition includes an identical bandwidth
provision for amateur bands between 1.8 and 29.5 MHz.  What I suspect is the
major concern to CW operators, is that these proposals (both Whedbee's and
ARRL's) would allow RTTY/data signals operating in the so-called "CW bands"
to occupy up to 2.8 kHz, the SAME NOMINAL BANDWIDTH as SSB phone.  If
digital data and its attendant white-noise interference is to be allowed to
transmit in the traditional CW bands at the same bandwidth as SSB, what's
the point of even having separate narrow-band and wide-band segments in the
first place?

Whedbee further proposes specific bandwidth limits for all the rest of the
modes used by amateurs, including a one-size-fits-all 8 kHz limit in the
160-10m bands, that would apply equally to AM, SSB, narrow-band FM, and
SSTV.  He also duplicates the ARRL proposal (RM-11759) to TAKE AWAY 50 kHz
from the 75m phone band, by moving the boundary between phone and RTTY/data
from 3600 kHz to 3650 kHz.

In summary, in this mix we have three distinctly separate petitions and
several distinct proposals:

RM-11708, ARRL  (lift the cap on baud-rate and impose a specific 2800 Hz
bandwidth limit in the CW/RTTY/data segments)
http://apps.fcc.gov/ecfs/comment/view?id=6017477458 

RM-11759, ARRL  (move the 80/75m boundary from 3600 kHz to 3650, allow
Novices/Technicians to use RTTY and data on 80, 40 & 15m)
http://apps.fcc.gov/ecfs/comment/view?id=60001518667 

RM-11769, Whedbee (all the above, PLUS re-name non-phone sub-bands to
"symbol", allow RTTY/data in the CW-only segments of 6m and 2m, impose
SPECIFIC BANDWIDTH LIMITS to ALL MODES including AM and SSB)
http://apps.fcc.gov/ecfs/comment/view?id=60001692464 

The threat to CW operators is NOT re-naming the traditional CW sub-bands as
"Symbol" or allowing RTTY/data to share those segments (this is already
permitted in the rules), but allowing digital and other forms of data
transmission in the CW bands up to 2.8 kHz bandwidth, the same as SSB.  This
was first proposed by ARRL, now followed by Whedbee.

The primary concern of AM operators, and in fact all phone operators, should
be the proposed imposition of a specifically defined 8-kHz bandwidth limit.
Specific bandwidth limits should in fact be a concern to all amateurs as
well as to the FCC, due to the new compliance and enforcement issues this
would bring.

The official deadline for submitting comments to the Petition expired on the
10th of June, but there is an additional 30-day period for Replies to
Comments.  The deadline for a Reply to Comments is 30 days after the DATE
THAT COMMENT WAS POSTED, under the "Date Posted" column in the ECFA list.
This is a way you can still get your input to the FCC; just locate a comment
near the end of the list,  one that you find particularly relevant to the
issue as you see it, and reply, pro- or con. For the comment list, go to:

http://apps.fcc.gov/ecfs/comment_search_solr/doSearch?proceeding=RM-11769&ap
plicant=&lawfirm=&author=&disseminated.minDate=&disseminated.maxDate=&receiv
ed.minDate=&received.maxDate=&dateCommentPeriod.minDate=&dateCommentPeriod.m
axDate=&dateReplyComment.minDate=&dateReplyComment.maxDate=&address.city=&ad
dress.state.stateCd=&address.zip=&daNumber=&fileNumber=&bureauIdentification
Number=&reportNumber=&submissionType=&__checkbox_exParte=true 


Don k4kyv