The recent ARRL proposal reeks of Docket 20777, the 1976 proposal which sought to "deregulate" amateur radio by defining subbands by bandwidth, rather than by emission mode. The narrowband subbands proposed under Docket 20777 remained the same as the CW/RTTY subbands then in existence, so nobody really gained any priveliges. This proceeding would have "deregulated" certain modes, such as DSBSC and AM, out of the 160-15 meter bands. It was vehemently opposed and the FCC never adopted it. In dealing with the FCC, one must watch for unintended consequences. The League's proposal may give us some relief from current overregulation of our radio service. But it may spawn some new, originally unintended restrictions. Even if such "heritage" modes as AM and wide-shift RTTY are protected under the League's proposal, this proposal still calls for the micromanagement of amateur radio that has been the hallmark of FCC regulation in this country for decades, in that it continues to call for the division of our bands into subbands. A far better solution would be to petition the FCC to simply delete most of Sections 97.305, 97.307, and 97.309 from the Rules, substituting the liberal provisions of Part 5. Part 5 governs the Experimental Radio Service, in which I also hold a license. Eliminating 97.305 eliminates the outdated emission subbands. This would eliminate the de facto "American-free" zones on our DX bands and on 40 meters, where hams in the rest of the world can and do operate voice while Americans do not dare to. As a result, Americans do not use those frequencies and they go to waste in this country (although the 40 meter frequencies in question are used by CW and data stations during the day. The CW activity slides down the band at night, as the frequencies fill up with foreign SSB stations.) The United States is one of the few countries, if not the ONLY remaining country, still prescribing such subbands. Canada abolished subbands several years ago. Eliminating the other two sections eliminates the need to seek Special Temporary Authorization if one wants to try a new emission mode. It would also eliminate the asinine restrictions on data communications. While teenage kids may send text, voice, and images digitally over the Internet, we hams are limited to sending 300 baud text on HF radio, with the FCC even dictating the type of code that we may use! This is a disgrace, an embarrassment, and it totally contradicts Section 97.1, which calls for amateur radio providing a pool of trained radio operators who can advance the communications art. 300 baud ASCII and slow-speed Baudot do nothing of the sort! The British are experimenting with OFDM for digitally transmitting voice in a 3-6 kHz channel. Quality approaches that of FM broadcast radio! OFDM was invented in New Jersey by Bell Laboratories. Yet, the current straitjacket of FCC regulations precludes us from using that mode here. While the ARRL proposal may provide some relief, the elimination of the offending sections of Part 97 would be much better. Suppose someone develops a new emission mode that does not conform to whichever limits are ultimately imposed under any rule changes that result from the League's proposal? Then we are "back to square one", hobbled once again by outdated rules. True deregulation renders Part 97 future proof. Of course, there is nothing wrong with our "heritage" modes, either. I work and enjoy both CW and AM. The beauty of CW is its simplicity and the way in which it transcends language barriers. Even though AM is old fashioned, there is an AM subculture on our bands that is highly technically oriented. Some of these AM'ers are actually using cutting edge technology! An example is WA1QIX, who has designed and built several transmitters using Class E solid state PA sections. These transmitters achieve over 90% efficiency! The broadcast industry is just beginning to market such equipment. Unlike the "plug and play" crowd that purchases "plastic radios" to see how many QSL cards they can collect, these AM'ers work on their own equipment. They build their own equipment. And they help one another. This is far more in keeping with the spirit of traditional amateur radio. We need to get rid of subbands, period. I am thoroughly sick and tired of being a second-class citizen relative to my Canadian and European colleagues.