[CW] Elimination of CW-Only Sub-bands

Joe K2UF joe at k2uf.com
Thu May 12 18:19:39 EDT 2016


Another nail in the amateur radio coffin. 
 
73  Joe K2UF

  _____  

From: CW [mailto:cw-bounces at mailman.qth.net] On Behalf Of Marshall Emm
Sent: Thursday, May 12, 2016 6:08 PM
To: cw at mailman.qth.net
Subject: [CW] Elimination of CW-Only Sub-bands


This was in the ARRL Letter (and at ARRL.org):


Missouri Radio Amateur Petitions FCC to Designate "Symbol Communication"
Subbands


TAGS: amateur radio, amateur radio spectrum, fcc, morse code, petition, Rule
Making, rules, voice mode   
05/11/2016


James E. Whedbee, N0ECN, of Gladstone, Missouri, has petitioned the FCC to
designate Morse (radiotelegraphy) Amateur Radio band segments as "symbol
communication" subbands. The FCC has invited comments on his Petition for
Rule Making (RM-11769), filed on May 2. Arguing that retaining the current
regime of "legacy" CW subbands has proven to be grossly inefficient, Whedbee
said he'd like to see the FCC delete all privilege restrictions that limit
any part of the Amateur Radio spectrum to Morse code to the exclusion of
other modes.


"Nostalgia for retention of Morse code telegraphy-only subbands is also an
insufficient reason to avoid moving forward to [the] elimination of such
subbands, because nothing about this Petition suggests the elimination of
the mode itself, only that it not be the sole authorized mode in the subject
subbands," Whedbee told the FCC.


Whedbee characterized CW-only subbands as "an excessive regulatory
constraint, as well as a poor use of the spectrum concerned." He proposed
that the FCC's Part 97 rules reflect the "ultimate form of communication
reproduced at the receiving end." As he explained it, his regulatory scheme
would break down modes into three categories - "symbol communication mode" -
for CW, digital, and other emission modes that reproduce a discrete symbol
on the receiving end - "voice mode," and "image mode."


"[C]ontinuing regulation by specific emission designator is proving to be
onerous with changes to the state of the art," Whedbee said. "Accordingly,
to continue developing the state of the art in radiocommunications, Amateur
Radio needs to clearly get away from regulating in that fashion and return
to consideration of what the receiving end of the communication reproduces."


He proposed that where the Part 97 rules refer to exclusive radiotelegraphy
allocations - or subbands - privileges be changed to reflect symbol
communication modes. Where the rules prohibit voice and image modes, he
would revise the rules to reflect symbol communication modes. In situations
where current rules prohibit symbol communication modes other than Morse,
that voice and image modes would be permitted, "with an exception for
manually keyed" radiotelegraphy.


For example, he would drop the distinction between 75 meters and 80 meters,
authorizing symbol communication modes between 3.5 MHz and 3.65 MHz, and
voice and image modes between 3.65 MHz and 4 MHz, with manual
radiotelegraphy authorized throughout the band.


Whedbee told the FCC that, if his Petition is accepted for filing and put on
public notice, he would submit an appendix spelling out proposed service
rules as part of his Petition.


Commenters have 30 days to respond to Whedbee's Petition.
  
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