[CW] Elimination of CW-Only Sub-bands

Tue May 17 20:42:50 EDT 2016

Looking over the comments to RM-11769, I see it has already drawn over 300 responses. 

I took a random sample of about a dozen comments, and the good news is that every single one I looked at was opposed to the petition.  The bad news is, apparently, many CW operators have misinterpreted what is being proposed, and have been led to believe that the petition asks to "eliminate the exclusive CW sub-bands" and allow RTTY, data and other digital noise in our traditional CW bands.  Typically, the comments I read went something like this, "I have been operating CW for 40 years.  Please leave the CW bands alone."  In reality, RTTY/data/digital noise has already been allowed for years; the "CW bands" haven't been “exclusively CW” since RTTY was first introduced to amateur privileges, right after WWII. There are no “exclusively CW” sub-bands on HF.  

The only thing that is "exclusively CW" on HF are Novice and Technician privileges. The bottom 100 kHz of 6m and 2m are the only exclusively CW amateur band segments.  What the guy is proposing for HF in this regard is to change the name of the “CW/RTTY/data” sub-bands to "symbol" in the wording of Part 97 rules, consistently as the phone bands were previously re-named "phone" instead of AM/SSB/SSTV - just a matter of semantics, except for the part about allowing Novices and Techs to run  RTTY and digital data on HF (which I oppose, since with the General class exam so easy, let them upgrade if they want to run digital hash on HF). But he does want to eliminate the exclusively-CW rule and add RTTY/data to the 50.0-50.1 MHz and 144.0-144.1 MHz segments.

As I  see it, we have a problem because of what appears to be a widespread misinterpretation of the petition; this may cause the FCC to simply consider 95% of the commenters ill-informed and blow off the comments in opposition.  That means some of us should compose some well thought-out comments, expressing opposition to the bandwidth proposals.  A few of the commenters did apparently get a better grasp of exactly what is being proposed, and expressed opposition to allowing digital data with a bandwidth of up to 2.8 kHz in the so-called CW bands.  If they are to open the CW bands up to 2.8-kHz wide digital hash, they might just as well allow SSB too, which would actually cause less disruption to CW operation than would 2.8 kHz of digital white noise.

This petitioner is also proposing specific, enumerated bandwidth limits for ALL modes used in amateur radio, which would impose an additional enforcement burden on the FCC and additional compliance burdens on hams. While 8.0 KHz may seem to many to be a reasonable maximum bandwidth for the usual AM signal, there is no compelling reason at this time to suddenly impose specific, enumerated limits to AM or any other mode, especially considering that band congestion has fallen off in recent years compared to what we have endured in the past.  This proposal would make no distinction between the bandwidths of double-sideband AM and that of single-sideband; they would both be limited to 8 kHz maximum.  The current bandwidth rules, based on "good engineering and amateur practice" were intentionally left vague to allow amateurs the maximum flexibility for experimentation and self-instruction in the radio art. See §97.307(a) and (c). 

Given the current lack of FCC enforcement of existing rules, particularly Part 15 and Part 18 limitations on harmful RFI radiation, and the FCC's apparent inaction on all but the most egregious violations of rules against deliberate ham-on-ham interference, what would be the point in now adding new rules directing the Commission to further micro-manage amateur radio operation?

The FCC released the Public Notice on 11 May 2016, announcing this Petition as RM-11769. Interested persons may file statements opposing or supporting this Petition within 30 days, with the deadline for comments falling on 10 June, 2016. 

Don k4kyv

PS:  To view the comments submitted  so far, go to the FCC web page below.  You may have to manually copy and paste the URL into the address bar of your browser, since the Reflector software may add line breaks that render the link inoperative.

http://apps.fcc.gov/ecfs/comment_search_solr/doSearch?proceeding=RM-11769&applicant=&lawfirm=&author=&disseminated.minDate=&disseminated.maxDate=&received.minDate=&received.maxDate=&dateCommentPeriod.minDate=&dateCommentPeriod.maxDate=&dateReplyComment.minDate=&dateReplyComment.maxDate=&address.city=&address.state.stateCd=&address.zip=&daNumber=&fileNumber=&bureauIdentificationNumber=&reportNumber=&submissionType=&__checkbox_exParte=true

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