ARRL FILES REGULATION-BY-BANDWIDTH PETITION

Doing their own thing again... and it is not in your best intrest !

 

Instead of this, why isn't the League pushing for a 200 to 300khz expansion on 60 meters? We could use the room there instead of this ridiculous "channelization" that exists now. I'm afraid that the ARRL has lost contact with the present needs of the WHOLE amateur community, not just the ones who want to experiment with developing digital modes. I realize that the digital modes are important for EMCOM, but getting more spectrum that is useful for emergency communications is more important. 60 meters may be the day/night band that would be extremely useful for emergency communications, especially during the sunspot low we are experiencing now. And for KA2LIM, I completely agree with you.
                        73 - Fred.

 

We should all support this ARRL petition to the FCC. It greatly expands our freedom on the HF bands for all hams in USA.


Change Needed Now
Bandwidth-based spectrum management is needed now, and for the future of the Amateur Radio Service. No one loses any spectrum at all in this change. Everyone gains more flexibility to operate.

More Freedom for HF Operators
This is a good thing for ham radio in America.
It brings us closer to the level of freedom that is enjoyed by hams in other countries.

New Petition Is Updated
The plan has gone through many changes in several years of development. It includes some excellent new points that are very positive for ham radio. I highly recommend, to everyone who is interested, read the petition completely and form your own opinion. Don't rely upon false ideas from those who simply sit on their keister and complain about everything.

Good Bye Mode-Based Content Constraints
Most USA operators have never known anything else than being under the thumb of our present system of mode-based rules and highly restrictive mode-subbands. That system has kept us more tightly constrained than any other hams in the world, hampering innovation, and in some cases working against our communications with other countries. As communication technology has progressed, the antiquated rules are now at the point that they are antithetical to the very essence of the Amateur Radio Service!

Technology Jail Breakout
To those who are content to live in a technology jail; to those who resist any kind of change, even when change means more freedom... I've got a simple message for them:

The hams of USA want freedom on HF like the rest of the world already has!

Thank You ARRL
Thank you to all the ARRL staff, the committees, and everyone who has worked so hard to put this petition together. Hammering out a good compromise between all the different (competing) factions of ham radio isn't easy.

No Boogie Men
Now, we see a few operators want to use this issue as a soapbox to finagle a private frequency reserve for their favorite mode of operating. Others are trying to twist this into their vendetta against pactor or Robot Boogie Men. But this isn't about robots or HF email, and it isn't about playing favorites. It is about providing band space for everyone in ham radio today to operate freely with their choice of method; it is about space for the new hams who will soon be on HF; and it is about providing a foundation for the hams who will be on the air many years from now.

The Real Issue
This issue is about bandwidth-based spectrum instead of mode-based spectrum. Simple as that. It doesn't favor any particular mode or method of operation.

Better FCC Rules, More Freedom
Sure, the petition is a little complicated... FCC rules are complicated. Let's focus on the facts. The fact is that this enables us to move forward technologically, without being held back by antiquated rules governing the content of what we transmit. The rest of the world's hams already have this freedom. We pride ourselves as a free country. This petition isn't perfect, but it is more free than anything we have had in my lifetime as a ham.

Does This Petition Carry Us Far Enough?
I just read it... I personally think the space devoted to 200Hz is a little too much and probably unnecessary. FCC could end up just combining the 200Hz and 500Hz into one 500Hz segment, for simplification. Also, I believe that the 3.5kHz segment on 40 meters needs to extend down to 7075kHz, so that USA can be compatible for communication with the rest of the world on this valuable international band, especially during emergencies. The band segments could then be allocated in a ratio of "80% 3.5kHz" to "20% 500kHz". This would balance out to enable fair and equal distribution of the number of QSOs in each segment. Perhaps the petition shows undue favoritism for AM phone. Instead of that, a better way would be a 10kHz bandwidth overlay in parts of larger HF ham bands at reduced average power level. This would allow AM but not preclude other transmission methods with similar bandwidth occupancy effects. Obviously, the ARRL has bowed to tradition in these areas in their efforts to accommodate the status quo. So I ask, does the petition's plan go far enough toward providing enough freedom for wider bandwidths and new technologies? Time will tell.

Support for the Petition
My suggestions, above, are minor compared to the overall benefit that this change gives us on HF. Overall, I believe this change in FCC rules is our chance to gain more freedom on the HF bands. Bandwidth-based spectrum management is basically one of the best things happening for HF ham radio in USA in the 40 years that I've been a ham.

Therefore, I am voicing my support and hope for the success of the rulemaking procedure that this ARRL petition is initiating.

73 --- Bonnie KQ6XA

PS: Read the Petition. Form your own opinion.

















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Some excerpts of the important text of the Petition for Rulemaking:
PETITION FOR RULE MAKING
ARRL, the National Association for Amateur Radio, also known as the American Radio Relay League, Incorporated (ARRL), by counsel and pursuant to Section 1.401 of the Commission’s Rules, 47 C.F.R. §1.401, hereby respectfully requests that the Commission issue at an early date a Notice of Proposed Rule Making, proposing changes requested herein in the rules governing the Amateur Radio Service. The rule changes proposed in this Petition would comprehensively modify the means by which the extremely varied emission modes in the Amateur Radio Service are developed, experimented with, implemented, and regularly utilized in the course of normal Amateur Radio communications. In short, the Petition proposes Amateur band segmentation not by emission types, but by bandwidth maxima. This petition seeks for the Amateur Radio Service the flexibility to experiment with new digital transmission methods and types to be developed in the future, while permitting present operating modes to continue to be used for as long as there are radio amateurs who wish to use them. The changes proposed in the attached Appendix will also update the Commission’s rules, and eliminate much of the currently cumbersome procedures for determining whether a new digital communications technology is or is not permitted under the Part 97 regulations. As good cause for the rule changes proposed in the attached Appendix, ARRL states as follows:
I. Introduction and Background
1. The Amateur Radio Service rules limit emission types that can be deployed in the Amateur Service. The reason for this is largely historical, rather than practical. In this Petition, ARRL suggests a shift in regulatory philosophy, which is the Amateur Radio version of a change from a “command and control” model for Amateur Radio regulation to one based on facilitating research, development, experimentation and refinement of Amateur Radio digital communications techniques and advanced technologies. 1 In order to encourage the implementation of new technologies in the Amateur Radio Service, the rules must be modified to more flexibly accommodate use of such technologies. 2 The philosophy espoused herein is to regulate bands by maximum bandwidth rather than specific or defined emission modes. This is to make it easier for new types of emissions to be introduced compatibly among incumbent emission types, while reducing or eliminating the regulatory burden of interpreting or applying rules to new technologies in the context of a presently cumbersome regulatory matrix. This can be done, and ARRL believes that the attached Appendix does that, without prohibiting or significantly restricting use of current Amateur radio technologies and emission modes. Care has
1 Indeed, in WT Docket No. 98-143, The Commission encouraged the Amateur community to complete discussions and seek consensus regarding implementation of new and more modern communications technologies within the Amateur Service. This Petition is a necessary component of that effort.
2. There is a pronounced trend in the Amateur Service toward digital communications, without necessarily replacing analog modes. It is apparent therefore that both analog and digital modes will be used in the same bands at the same times for the foreseeable future. For regulatory purposes, the most important parameter is the bandwidth of the transmitted signal. Generally, established Amateur practice, current rules and accepted national, regional and local band plans provide narrow-bandwidth signals at the lower frequency range of each band with wider bandwidth emission types in the upper portions. In order to implement digital technologies, there appears to be a need for an intermediate bandwidth in the middle of certain bands. ARRL has developed this plan based on the following key principles:
(a) The rule changes to be implemented must withstand the test of time over the next ten years, if not longer. The impetus for the changes is to permit greater flexibility for Amateur Radio operators to develop, experiment with, and implement technologies that are not yet envisioned, while permitting present operating modes to continue to be used as long as there are licensees who wish to use them.
(b) We are in the early stages of a dramatic shift in Amateur operating patterns, especially in the High Frequency (HF) bands. It is impossible to determine now where this shift may lead. The Commission’s Rules should not stand in the way of where technology takes Amateur Radio in its fulfillment of the bases and purposes of the Amateur Radio Service (47 C.F.R. §97.1).
© The Commission’s rules alone cannot, and should not be expected to effectively prevent conflicts in HF spectrum usage between Amateurs pursuing different operating interests on-air. Responsibility for resolving conflicts in shared spectrum must be shouldered by the Amateur community itself. Voluntary band planning must be adequate and must gain broad acceptance by amateurs as the best means of protecting their individual interests. Traditionally, these cooperative methods have worked satisfactorily.
III. Bandwidth Segmentation by Regulation
12. Having a narrow bandwidth segment and a wide bandwidth segment in a given allocation would tend to keep signals of roughly the same bandwidth in their own spectrum. The specific bandwidth limits, once incorporated in the Rules, would allow a more natural development of new digital technologies. It would also satisfactorily protect incumbent analog

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services to a reasonable extent, just as Amateurs do now, using dynamic frequency selection methods.
13. The principal change to the Commission’s rules proposed herein is to eliminate, to the maximum extent possible, the specific protocols or modes of emissions from the rules. The difficulty in doing this is the determination of the proper maximum bandwidth in a given band. ARRL was guided in the preparation of the attached Appendix by advice from an Ad Hoc Digital Committee formed to advise the ARRL on issues that arise from the development of new high-frequency digital data modes of operation, and by extensive input from ARRL members. The proposed Appendix constitutes a balance, in ARRL’s view, between the need to encourage wider bandwidth, faster digital communications and the need to reasonably accommodate all users in crowded bands. The HF allocations offer the least opportunity for frequency re-use, and the higher UHF and microwave bands offer the most flexibility in this respect. The higher frequency bands, therefore, properly offer the widest available bandwidths. These premises, and the proposed Appendix which implements them, promote the most efficient use of spectrum shared among Amateur licensees. The recommendations of ARRL’s Ad Hoc Digital Committee were to delete the symbol rate limitations in Sections 97.307(f)(3) and (4); to segment the bands below 28.0 MHz by nominal bandwidths of 200, 500 and 2700 Hz as upper limits; and to require that digital data protocols be published, so that they can be duplicated and monitored to protect against intruders. The Committee was aware of the bandwidths and frequency segments under consideration by Region 1 of the International Amateur Radio Union. A bandwidth of 200 Hz was chosen to accommodate Morse telegraphy and the narrowest RTTY/data emissions. A bandwidth of 500 Hz would permit the foregoing modes and a wide range of RTTY/data modes and some image modes yet to be designed. IARU Region 1 studies chose a bandwidth of 2700

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11 With respect to the 60-meter band, which under current rules (47 C.F.R. § 97.303(s)) atypically specifies 2.8 kHz maximum bandwidth on specific channelized segments as a matter of specific, coordinated protection for Federal systems operating in the same band segment, no change to that maximum bandwidth is proposed herein.
12 Nor is the proposal a means of expanding telephony subbands. The specification of bandwidth only will have the regulatory effect of permitting telephony operation in, for example, the 14.100-14.150 MHz segment and the 10.135-10.150 MHz segment, where presently, it is not permitted by rule. However, it is not the ARRL’s intent to encourage telephony operation in those segments. Rather, such matters should be regulated by voluntary band planning.
Hz for SSB telephony and to accommodate digital voice and higher speed data. The Rules already specify a bandwidth of 2800 Hz for SSB voice in the 60-meter band. As the issue is a maximum regulatory bandwidth, not current practice, which varies from approximately 2400 to 2800 Hz, a bandwidth of 3500 Hz is recommended in the proposed Appendix for the wide bandwidth segments in order to encourage maximum flexibility. The proposed rules also specify that “bandwidth” will be defined in terms of necessary bandwidth rather than occupied bandwidth, to reduce undue concern by operators about determinations by measurement of occupied bandwidth.11 Some radio amateurs who have discussed this issue with ARRL representatives have expressed concern that permitting bandwidths up to 3.5 kHz for HF digital communications is an overly generous accommodation for digital communications users at HF. However, it is no expansion of present operating authority whatsoever: there is presently no effective bandwidth limit on HF digital operations. The existing bandwidth limit of 500 Hz applies only to automatically controlled stations where the station is responding to interrogation by a station under local or remote control. See, 47 C.F.R. §97.221©. In fact, in the band segments proposed in the attached Appendix to be limited to 200 or 500 kHz, there is greater protection proposed for narrowband emission modes than exists today. 12

APPENDIX A
PROPOSED RULE CHANGES
Part 97 of Chapter I of Title 47 of the Code of Federal Regulation is proposed to be amended as follows:
Section 97.3(a)(8) is amended to read as follows:
(8) Bandwidth. For a given class of emission, the width of the frequency band which is just sufficient to ensure the transmission of information at the rate and with the quality required under specified conditions (See the definition of Necessary Bandwidth in Section 2.1 of this Chapter and Section 97.101(a) of this Part).
Section 97.3(a)(42) is amended to read as follows:
(42) Spurious Emission. For the purposes of this Part, emission on a frequency or frequencies which are outside the allocated frequency band and which may be reduced without affecting the corresponding transmission of information. Spurious emissions include harmonic emissions, parasitic emissions, intermodulation products and frequency conversion products.
Section 97.109(e) is amended to read as follows:
§97.109 Station control.
(a)…
*****
(e) No station may be automatically controlled while transmitting third party communications, except a station transmitting a RTTY or data emission. All messages that are retransmitted must originate at a station that is being locally or remotely controlled.
Section 97.119 is amended to read as follows:
§ 97.119 Station identification.
*****
(b)…
(1) By a CW or MCW emission. When keyed by an automatic device used only for identification, the speed must not exceed 20 words per minute;

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(2) By a phone emission in the English language where a bandwidth of at least 3.5 kHz is authorized. Use of a standard phonetic alphabet as an aid for correct station identification is encouraged;
(3) By the same emission as used for the communication.
(4) (Deleted)
Section 97.221 is amended to read as follows:
§ 97.221 Automatically controlled stations transmitting RTTY or data emissions.
*****
(b) A station may be automatically controlled while transmitting a RTTY or data emission on the 6 m or shorter wavelength bands, and on the 28.120-28.189 MHz, 21.150-21.160 MHz, 14.100-14.112 MHz, 10.140-10.150 MHz, 7.100-7.105 MHz, or 3.620-3.635 MHz segments.
© A station transmitting a RTTY or data emission may be automatically controlled on any other frequency authorized for such emission types provided that the station is responding to interrogation by a station under local or remote control.
(1) (Deleted)
(2) (Deleted)
Section 97.305 is amended to read as follows:
§ 97.305 Authorized emission types.
(a) An amateur station may transmit a CW emission on any frequency authorized to the control operator except for the frequencies in the 60 m band.
(b) A station may transmit a test emission on any frequency authorized to the control operator for brief periods for experimental purposes. Test transmissions are authorized in the segments 51-54 MHz, 144.1-148.0 MHz and on all bands above 222 MHz.
© Pulse emissions are permitted on all bands authorized to the control operator above 902 MHz except in the 23 cm and 3 cm bands.
(d) SS emissions are permitted on all bands authorized to the control operator above 420 MHz.
(e) Except as otherwise provided in this Section, a station may transmit any emission on any frequency authorized to the control operator subject to the following bandwidth limitations:

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Wavelength band Frequencies authorized Maximum bandwidth Standards See §97.307(f) paragraph:
160 m Entire band 3.5 kHz (1)
80 m 3.500-3.580 MHz 200 Hz
80m 3.580-3.620 MHz 500 Hz
75 m 3.620-4.000 MHz 3.5 kHz (1)
60 m 5.1675 MHz 2.8 kHz See §97.401©
-do- 5.332, 5.348, 5.368, 5.373 and 5.405 MHz 2.8 kHz See §97.301(s)
40 m 7.000-7.035 MHz 200 Hz
-do- 7.035-7.075 MHz 500 Hz
-do- 7.075-7.100 MHz 500 Hz (2)
-do- 7.100-7.300 MHz 3.5 kHz (1)
30 m 10.100-10.120 MHz 200 Hz
-do- 10.120-10.135 MHz 500 Hz
-do- 10.135-10.150 MHz 3.5 kHz
20 m 14.000-14.065 MHz 200 Hz
-do- 14.065-14.100 MHz 500 Hz
-do- 14.100-14.350 MHz 3.5 kHz (1)
17 m 18.068-18.100 MHz 200 Hz
-do- 18.100-18.110 MHz 500 Hz
-do- 18.110-18.168 MHz 3.5 kHz (1)
15 m 21.000-21.080 MHz 200 Hz
-do- 21.080-21.150 MHz 500 Hz
-do- 21.150-21.450 MHz 3.5 kHz (1)
12 m 24.890-24.920 MHz 200 Hz
-do- 24.920-24.930 MHz 500 Hz
-do- 24.930-24.990 MHz 3.5 kHz (1)
10 m 28.000-28.050 MHz 200 Hz
-do- 28.050-28.120 MHz 500 Hz
-do- 28.120-29.000 MHz 3.5 kHz (1)
-do- 29.000-29.700 MHz 16 kHz
6 m 50.000-50.100 MHz 200 Hz
-do- 50.100-50.300 MHz 3.5 kHz
-do- 50.300-54 MHz 100 kHz
2 m 144.0-144.1 MHz 200 Hz
-do- 144.1-144.3 MHz 3.5 kHz
-do- 144.3-148.0 MHz 100 kHz
1.25 m 219-220 MHz 100 kHz
-do- 222-225 MHz - (3)
70 cm Entire band - (3)
33 cm Entire band - (3)
23 cm Entire band - (3)

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13 cm Entire band - (3)
9 cm Entire band - (3)
5 cm Entire band - (3)
3 cm Entire band - (3)
1.2 cm Entire band - (3)
6 mm Entire band - (3)
4 mm Entire band - (3)
2.5 mm Entire band - (3)
1 mm Entire band - (3)
- Above 300 GHz -

Section 97.307(f) is amended to read as follows:
§ 97.307 Emission standards.
*****
(f) The following standards and limitations apply to transmissions on the frequencies specified in § 97.305(e) of this Part.
(1) The 3.5 kHz maximum bandwidth does not apply to double-sideband amplitude-modulated phone A3E emissions which are limited to bandwidths of up to 9 kHz.
(2) Phone and image emissions with a maximum bandwidth of 3.5 kHz may be transmitted only by stations located in ITU Regions 1 and 3, and by stations located within ITU Region 2 that are west of 130° West longitude or south of 20° North latitude.
(3) No specific bandwidth limitations apply except that the entire emission must be within the allocated band to meet the requirements of §97.307(d).
(4) through (13) (Deleted)
Section 97.309 is amended to read as follows:
§ 97.309 RTTY and data emission codes.
(a) Where authorized by §97.305(e) and §97.307(f) of this Part, an amateur station may transmit a RTTY or data emission using published digital codes for the purpose of facilitating communications.
(b) When deemed necessary by the FCC’s Enforcement Bureau to assure compliance with the FCC Rules, a station must:
(1) Cease the transmission using the unspecified digital code;
(2) Restrict transmissions of any digital code to the extent instructed; and
(3) Maintain a record, convertible to the original information, of all digital communications transmitted.

 

Am I missing something in their document,
it appears to regulate emissions by bandwidth
as stated,but I couldn't find a segregation keeping
"slimmer" bandwidth signals out of the other areas,
I.E. I am trying to do AM with AE6IP or KC9ECI and
suddenly get slammed by an unwelcome burst from winlink.

Digital modes need their own home not to disrupt other
modes and vice/versa.

Am I missing this on the document somewhere ?
 
I want to know the whole story before I comment to the FCC one way or another.

 

The SSB signal will "lose". Every time.

Every Amateur needs to burn these two images into his/her brain. The only two things you need to know to voice your opinion are:

1. The two images above.

2. 10% of users are trying to take spectrum from 90% of users.

You will see people try to confuse you with technical jargon designed to take emphasis from the two points above. They will try to take away your freedom to enjoy SSB, AM and CW by allowing interference from digital signals. They will try to take away CW spectrum by making it easier for digital users to run you off. They will say robot digital signals mixed with people using radio are ok. They will try to get your to ignore that the ARRL plan favors Winlink and could legislate CW NTS and Packet nets off the air. Don't be fooled by smoke and mirrors. Just say no!

 

Bob,

This plan is the regulatory portion. There must and will be a bandplan portion. The unfortunate part is that there is not segregation in the regulations.

Ken

 

I'm with you on this. I have been pressing my Division Director for this limitation during the entire process. I will formulate my personal comments based on this issue, but I do support the thrust of this petition. This will free all of us to experiment with different things without having to QSY to an appropriate frequency each time the experiment is changed.

Ken

 

HI Fred I think you might find out thatthe 60 meter band is NOT exclusively amateur freq. Hams are at best a secondary user. NTIA is involved with as well as the primary users on the channelization. As far as expanding any HF freq. we can get, Great.

RGB

 

What does the FCC think about band planning by bandwidth?

Here is a pretty solid indication (again.)

FCC QUOTE from NPRM RM-10740, 11/2004.

"Discussion. As an initial matter, we note that one of the purposes of the amateur service is to contribute to the advancement of the radio art.(1) We believe that amateur radio operators using amateur service spectrum to develop new communications systems are using the service in a manner that is consistent with the basis and purpose of the amateur service. We also believe that our Rules should not be an impediment to amateur radio operator's development of new or improved communication systems. In this regard, we note that the reason amateur radio operators currently may not transmit communications that combine image emission types and data emission types on HF frequency segments where data emissions are authorized is not a technical reason, but rather is because our Rules do not authorize stations to transmit both image and data emission types on any HF frequency segments. (2) We also note that amateur radio operators apparently have developed communication systems and technologies that transmit both image and data emission types, and that they are using these systems for communicating. For this reason, we are persuaded that our Rules are not in harmony with current emission and operating practices and that our Rules may be impeding amateur radio operators in advancing the radio art."

Then there is the quote from the former Chief of Engineering and technology stating:

"headroom for increases in data rates to more closely match those available on wireline networks and, in the future, on commercial wireless networks as well." and he goes on to quote: "as the rest of the telecommunications world makes the transition to digital techniques - and there are very few exceptions to that trend - the amateur service will look antiquated if it is not making progress in that direction as well."

Again, in the above NPRM RM-10740, 11/2004, they also describe how they expect the domestic Amateur radio spectrum to be regulated:

"Voluntary band planning allows amateur stations that desire to pursue different operating activities to pursue these activities by dividing or segmenting the amateur service spectrum. Voluntary band planning also allows the amateur service community the flexibility to 'reallocate' the amateur service spectrum among operating interests as new operating interests and technologies emerge or operating interests and technologies fall into disfavor."

Current services and modes mean little when it comes to providing an opportunity for further developments in digital techology. In addition, band segmentation may also occur without the use of hard-coded regulatory formal rulings, which take years to change. Yes, it will place more responsibility on the Amateur community, but like CW today, which is allowed anywhere on our HF Spectrum, each mode will find its "spot." What is here today, may well be history when replaced with more enabling technology. This does not mean that there won't be room for new and old modes as well. The size of these segments will vary with the popularity of each mode of operation, as they expand or shrink over time.



Steve, k4cjx

 

Regarding ARRL petitions....About 10 years ago, I felt that the ARRL had lost touch with MY realities as a ham, and certainly, did not represent my views in any way, shape or form.  I think they only contacted me around election time, asking me to vote for people I didn't even know.  At a recent luncheon with some of the local hams, I even heard an Extra of many years say, "I wish I wasn't an ARRL member anymore, but I paid for a lifetime membership over 20 years ago, and it was so cheap back then that I'll just leave like that".  As a matter of fact, QST seemed to be turning more and more into an advertisement catalog, with maybe one or two really good articles that I cared to read.  Therefore, I just let my membership expire.  Since then, they haven't done anything extreme to win me back other than continue to raise their fee every so often and, frankly folks, I don't think they care to win me back.  So...I guess I'll just continue to be an "independent" for now..."soree mon"!

Saludos desde San Antonio, Texas,
73 WP4KTF

 

Fred (AA7BQ),

Do you support the ARRL or not? Please feel free to explain your response.

Dr Ed AE4TM

 

As if it's not bad enough that the FCC seems to be trying to destroy the Amateur service by causing deeper divisions in our ranks, most likley with an eye on other uses of our frequencies, now ARRL is proposing changes that will cause additional conflict between different mode operators just to benefit a few. I cannot believe that any digital participants (current or future) are being held back by lack of spectrum. I also have trouble with the claim that development of additional digital technology (that will benefit the whole of the service)is being squelched by the Present allocation system.

 

I can't find that document. There is a Final Order on RM-10740 dated November 24, 2004, but it does not contain that quote.

RM-10740 was a petition by some hams to limit SSB bandwidth to 2.8 kHz, basically to put a stop to the hi-fi SSB modes.

As far as I can tell there was no NPRM on this petition. It was simply denied outright by the FCC in the order issued in November 2004.

You sure that's the right number, RM-10740?

(Later ... After digging around the ECFS and WTB sites for awhile...)

I think you meant NPRM WT Docket 04-140 (FCC Document 04-79). That quote does appears on Page 10, paragraph 16, in the commentary about the so-called "Miller petition" to allow image modes and restrict bandwidth to 500Hz in the cw/data subbands on HF.

If you're going to quote from a document, in the future can you at least please reference it correctly? Thanks.

 

The FCC is not likely to consider this scheme from the group in Newington because:

-- It proposes to use the federal regulatory structure to favor a specific mode and activity

-- The Amateur community overwhelmingly rejected a very similar proposal from the FCC 30 years ago

-- The group in Newington failed to show proof that the greater community supports their scheme

-- The scheme is not accompanied by any proposed layout to minimize friction among incompatible modes and activities