[KCDXC] Article Taken from .QRZ

[Mike ZooLoo]

HAMS PETITION TO OUTLAW HI-FI SSB
--Dirty, splattering signals also hit;
--Implications for contesters seen as well
--Hollingsworth clarifies basis for earlier advisory
letters/NEW

WASHINGTON (QRZ.com) -- On-air experimentation with
so-called High Fidelity or Enhanced Single Sideband
transmissions could be outlawed if the FCC adopts a
proposed rules change requested by two radio amateurs
on opposite sides of the country.

A petition for rulemaking was sent to the FCC and
accepted by the agency May 27th. It was not
immediately issued a Rulemaking Number so it was hard
to find in the public record. However, copies that
directly circulated among amateurs reveal that the
proposal calls for what many would consider severe
bandwidth limitations on HF phone.

A copy of the petition has since been posted at:FCC
Electronic Comment Filing System

The petition asks for a federally mandated bandwidth
limit of 2.8 kilohertz for SSB, which is well below
the extended bandwidth needed for what has been called
enhanced audio.

One of the two hams who submitted the petition told
the FCC they are motivated by interference problems
caused by two groups of single sideband operators.
These groups are portrayed by the petitioners as, in
both cases, having cast aside traditional voluntary
limits on bandwidth of roughly three kilohertz. The
petition therefore asks that these voluntary limits be
made mandatory to provide a clear enforcement
mechanism for regulators.

The petitioners, Michael Lonneke W�YR of Virginia, and
Melvin Ladisky W6FDR of California, said hams from one
of the groups come on during radio contests, and are 
found tweaking their transmitters to splatter
purposely to provide elbowroom on a very crowded band.
The two men characterize the other group as those who
experiment with high-fidelity audio, apparently trying
to replicate the sound of FM Broadcast stations.

QRZ.com and Newsline have recently reported on
advisory letters sent out by FCC Enforcement Counsel
Riley Hollingsworth, K4ZDH, who wrote to several
members of the enhanced SSB group telling them the
agency had received interference complaints. The
letters did not validate nor dispute the complaints,
but warned the stations that if such complaints
continued, the unresolved friction could trigger
petitions for rulemaking.  

One such petition is now at hand.

A Newsline reporter spoke with Lonneke, who declined
an early request to provide a copy of  his petition
for this report. He said he and Ladisky hold the same
views on the matter of excessive bandwidth causing
interference, and that they teamed up on the petition
to add strength to their call for regulatory
intervention. Lonneke declined further comment, and
said the petition will speak for itself if the FCC
chooses to assign it a rulemaking number and put it to
public comment.

Ladisky, upon hearing this report on the latest
edition of ARNewsline, contacted this reporter and
said they did not want to file such a petition but
were left with "no choice" 
after a failure to solve the problem through goodwill
and tolerance. He said:

"We don't oppose good audio or good sounding ssb only
the utilization of excessive bandwidth to accomplish
this thereby causing interference to other amateurs
trying to enjoy their contacts on the crowded ham
bands below 30Mhz. It makes no difference how the
excessive bw is achieved; by improper operation of
equipment or by choosing to xmit wide....the result is
the same.

Members of the enhanced SSB group have told QRZ.com
and Newsline they believe their experimentation with
improved audio is totally in line with the spirit of
ham radio, and that when conducted under appropriate
conditions, is justified in its consumption of
bandwidth as would be any other spectrum-intensive
activity, including contesting. 

NEW:But the FCC's Hollingsworth, reacting to such
comments, disagreed. Wednesday, June 25th, he
questioned the manipulation of an SSB signal to see
how wide it can go. Yet, website descriptions and
on-air discussions show it is such manipulation that
forms the basis of many of the activities of the
"hi-fi SSB" group now drawing fire from the
Petitioners and others. 

Hollingsworth spoke in a brief interview seeking
clarity for this report. He has not suggested the mode
of SSB was primarily commissioned for the amateur
service as a spectrum conservation mode, but agreed
this was one of the reasons it rose to popularity for
mainstream "phone" use on HF, along with improved
circuit efficiency and its suppressed carrier. 

Hollingsworth would not comment on the proposed
Petition, and another FCC official also declined to
comment ahead of when and if the agency assigns a
Rulemaking (RM) number to the document to officially
further it for public review and comment..

The petition, while primarily expressed as a complaint
against overly broad SSB activity, also mentions the
legacy mode of AM, and said it "does not create the
same problems that the burgeoning use of so-called
'Hi-Fi Single Sideband' creates." The document goes on
to affirm Amplitude Modulation as an activity "that
provides a large number of amateurs with an avenue for
experimentation and development." 

Nonetheless, the petition asks the FCC to impose a 5.6
kilohertz bandwidth limitation on AM, alongside the
proposed 2.8kHz restriction on SSB, and that the
constraints apply to all amateur phone bands below
28.8 megahertz.

Speaking generally, and not in relation to the
Petition, Hollingsworth said AM operators do not
appear to be deliberately broadening their signals. 

In comments posted to the bulletin board at the site
www.amwindow.org, the FCC official said "from an
enforcement/complaint standpoint, we have absolutely
no problem with AM operators. They are a great bunch,
generally they know radio, and they just want to work
AM and don't seem to be concerned with "how wide is
wide".

Hollingsworth continued "I have nothing against AM
except that I don't have enough time to operate it. I
paid a king's ransom to have my Valiant totally
refurbished (and it was worth every penny--it's
beautiful) and what I need is time to use it. In this
whole enhanced single sideband issue, I see no threat
to or complaint about AM from an enforcement
standpoint. I just wish I had 1% of the knowledge
about radio that AM'ers seem to have. 

�POSSIBLE RISK for COMPETITIVE RADIO OPERATORS?
In proposing a rigid standard of bandwidth to be used
as a yardstick for enforcement, the contest and DX
communities may also face stricter punishment. The
petition specifically requests enforcement against
"splatter from broad and overmodulated signals."

Consequently, it is conceivable that the proposal,
with its brickwall bandwidth standard, may raise the
number of complaints from people who receive
interference during such spectrum-intensive,
competitive radio events.

It is well known that during the excitement of a
contest or a DX-pileup, stations may exceed "proper"
modulation levels, creating spurious signal products
that cause interference on nearby frequencies. The
impact on adjacent operators is made worse with
amplified signal levels and high-gain antenna arrays.
Additionally, the receivers in some contemporary rigs
have AGC settings which may inadvertently make a
received signal seem broader than if measured to a
laboratory standard.

The petition suggests, but does not demand the
installation of audio filters on all amateur SSB
equipment capable of exceeding the proposed bandwidth.

Previous regulatory proposals based on bandwidth have
failed, including Docket 20777 from the mid 1970s. The
conclusion then was that having loosely-defined
technical standards allowed the greatest range of
experimentation in ham radio, as long as such signals
are clean. Present-day violations of splatter,
overdriven amplifiers, and poorly administered audio
lashups can already trigger enforcement action under
existing FCC rules governing the purity of signal..

At press time the petition by W�YR and W6FDR has not
been been assigned a Rule Making number designation. 
More on this story in future reports here,
and on Amateur Radio Newsline..  (ARNewsline, W5YI,
www.amwindow.org)

Disclosure notice:

This report is prepared for multiple internet and
audio outlets serving the amateur community.
References to other outlets are made with the
permission of those responsible.

The author of this report, WA3VJB, is active primarily
on AM. 

Edited by wa3vjb on June 24 2003,14:38 

__________________________________
Do you Yahoo!?
SBC Yahoo! DSL - Now only $29.95 per month!
http://sbc.yahoo.com