The ARRL says its Petition for Rule Making (RM-11306) to regulate the amateur bands by necessary bandwidth rather than by mode represents "a reasonable middle ground in a difficult regulatory area." In reply comments filed with the FCC February 21, the League said it was gratified to see more than 900 commenters responded to the admittedly "controversial" petition and noted that many "show the investment of a good deal of thought about the proposal." ARRL said it would have been concerned if the amateur community had not responded with a loud voice on all facets of the League's regulation-by-bandwidth proposal. "ARRL continues to believe that its petition is a measured response to progress in digital telecommunications technology and successfully balances the interests of all, regardless of which of the polarized opinions in this proceeding, if any, constitutes a 'majority' view," the League's reply comments said. "To the extent that the success of this philosophy necessitates the participation and cooperation of all amateurs in the development of, and increased reliance on, modernized voluntary band plans, ARRL is optimistic that such participation and cooperation will be available" as it has in past "transitional phases" in Amateur Radio's history. The ARRL is asking the FCC to replace the table at §97.305© with a new one that segments bands by necessary bandwidths ranging from 200 Hz to 100 kHz. Unaffected by the ARRL's recommendations, if they're adopted, would be 160 and 60 meters. Other bands below 29 MHz would be segmented into subbands allowing maximum emission bandwidths of 200 Hz, 500 Hz or 3.5 kHz, with an exception for AM phone. The ARRL says the changes it's proposing constitute a balance "between the need to encourage wider bandwidth, faster digital communications and the need to reasonably accommodate all users in crowded bands." The League's reply comments countered criticism that its petition represents "overregulation wrapped in a different cloak," that increased reliance--and confidence--in the ability of voluntary band plans to substitute for subband regulation by emission mode is misplaced, or that the ARRL's proposal caters to a small minority of digital enthusiasts and experimenters. Many of those who commented expressed a desire to leave things as they are, some because they feel the advent of digital technology may threaten their favorite mode. "They are comfortable with the status quo, because the current regulations are not encouraging toward digital modes and, therefore, the current regulatory scheme, they feel, 'protects' them," the League said. "The comfort level with the status quo is high for these licensees, and they have not hesitated to tell the Commission so." The League emphasized, "All should be accommodated by the regulatory structure of amateur subbands, and technology changes demand regulatory changes in this instance." Its plan, the League said, "attempts to segment emission modes of similar bandwidths in a manner that accommodates the varied needs and interests of all, while insuring compatibility by grouping like-bandwidth emissions together." Citing repeated efforts to gather input from the Amateur Radio community at large and from its members since its regulation-by-bandwidth concept was first aired in 2002, the League called the petition "the most thoroughly vetted regulatory proposal" it's ever developed. "The ARRL petition does not favor one mode at the expense of another," the League reiterated in concluding its reply comments. "It merely allows expansion of the repertoire of options that amateurs may pursue compatibly." The ARRL petition is available on the FCC Web site. Material from The ARRL Letter may be republished or reproduced in whole or in part in any form without additional permission. Credit must be given to The ARRL Letter and The American Radio Relay League.