Does the ARRL Bandwidth Plan Go Far Enough?

Does the ARRL Bandwith Proposal Go Far Enough?

As discussion begins concerning the petition filed by the American Radio Relay League (ARRL) to regulate usage by bandwidth, some Amateurs are saying the plan does not go far enough in providing space for digital use to grow. The ARRL plan calls for segmentation of the amateur bands by bandwidth in 200hz, 500hz, and 3.5khz segments.

In the "Digital Connection" section of the December edition of CQ Magazine, author Don Rotolo (N2IRZ) calls for the addition of a 25khz segment on the most popular HF bands, saying that 3.5khz does not provide enough bandwidth for decent data rates. He describes data rates at 3.5khz by saying that for large events (like Hurricane Katrina), amateurs will not be able to send data over the air at any more than a "snail's pace". He confirms that with the bandwidth limitation of 3.5khz provided by the ARRL, higher data rates become impossible. The point by Mr. Rotolo raises an important question: Does the ARRL Proposal go far enough?


History

The limitations on data rates posed by current HF mode based regulations have been discussed in many QRZ.COM articles over the past two years, many by me. This argument appears elsewhere in comments made to the FCC concerning the invalidity of no-code arguments alleging that telegraphy testing prevents the ARS from attracting the "younger generation". My own point to the FCC and here on QRZ has been that the "younger generation" want more internet type services. Uses such as music downloads, video, file transfer, etc that younger users want require data rates which are not possible on HF given the ARRL proposal and current bandwidth limitations.

Most recently I made comments in opposition to the ARRL Petition for regulation by bandwidth by saying that the limitation on data rates renders the "modern" digital services proposed for HF under the plan "old technology and not cutting edge". Example: Compared to internet email, Winlink moves at a "snail's pace", which also supports Mr. Rotolo's conclusion.


AM and FM

Perhaps the one thing most egregious to digital proponents in the ARRL bandwidth plan has been an exemption in the 3.5khz band segment for AM. Mr. Rotolo confirms that this exception has raised quite a ruckus in the digital community. It begs the question, if an exception is created for AM why not an exception for 25khz data? Perhaps a more valid question might be, "why not an exception over the years for FM on HF?" Relevence?

Recently on QRZ, KC2YNP asked why many radios did not have FM modes for HF. The best reply came from Joe, K7JEM, who said, "FM is not used on HF for a lot of reasons. The first issue is the bandwidth. FM is 3 to 6 times wider than an SSB signal, so on crowded bands it doesn't make much sense. Normal FM is only allowed above 29 MHz..." And to Joe's point, FM would have taken up more bandwidth than AM, ensuring less SSB QSOs could occupy the bands. Would operators who barely tolerate AM and are unwilling to tolerate FM signals on HF be prone to accept a 25khz wide data signal?


God and Digital

An old saying goes, "When God wants to really punish us, he gives us what we want!" There is no better sentiment when examining the ARRL Petition. Without universal input, the ARRL plan reflects the needs of a narrow group of digital users and simply ignores the actual issues involved. The best example is the plan's call for a 35khz segment for the 200hz bandwidth applications which would include all CW and most digital users (narrowband digital modes). Phone modes would gain some spectrum but have to contend with 3.5khz automatic stations. The biggest winners are the 500hz digital modes which would get 70khz in bandwidth. This includes wider PSK modes and the Pactor II modems as used by Winlink 2K. As Mr. Rotolo notes, the plan forgets about digital rates requiring higher bandwidth on most popular HF modes.


Solving the Problem

If we don't want automatic data stations and wideband digital in the voice bands, where do put them? If we need more room for CW which is still the second most popular mode, where do we go? If we don't want eight data QSOs at 25khz to displace a hundred SSB QSOs on HF, what do we do? If you want to send data over HF and need 25khz, where do you go?

A few years ago I was in charge of a large group of youngsters in their early teens. We had one soccer field, but we had three groups. One wanted baseball, one football, and the other soccer. The solution was to mark off a section 25 yards wide at mid field for touch football, at one end the baseball group moved the goal around and used it at one corner as a backstop for a baseball diamond, and the other group used the remaining end of the field for "half-court" soccer. No group was perfectly happy, but after 10 minutes they were having too much fun to care.

The obvious solution to the CW versus Digital versus SSB/AM issue is to divide the soccer field in 3 parts. Why this is such an onerous concept to digital proponents is perplexing to say the least. For almost 2 years I have discussed a (not set in stone) bandplan that called for 3 band segments or "modes" identified basically CW, Analog Voice, and Other. The "other" segment would contain all modes not CW and/or Analog Voice (AM/SSB) but including new digital modes.

The sample plan called for (using 40 and 20 meters as an example) 60khz for "CW", 90khz for "Other/Digital", and the current amount for "Analog Voice". It also encouraged the "Other" mode segment to use bandwidth bandplanning. The thought process is that when and if CW and Analog Voice lose popularity, the "Other" segment could be expanded in either direction taking up nearly the entire band if digital proponents’ predictions are true. At that time the entire band would have bandwidth control.


What We Should Not Do

What we should not do is all go out and file bandplan petitions at least not until the FCC decides whether to act on the League's filing. In predictable style, the FCC misunderstood the many restructuring petitions as some sort of mandate to delete code testing, and would likely adopt something in the bandplanning arena that we would be struggling to fix for years to come. What we should do is unite and bid the FCC not accept the ARRL petition for action. We should ask that it be dismissed and the ARRL directed to come up with a better plan.

The FCC has not mandated a bandwidth based bandplan! That said, we do our fellow amateurs who have a genuine interest in digital applications a disservice by not asking for some solution to their mode issues. We need to unite and demand that the ARRL (or some other organization) sit with a cross-section of all Amateurs to hammer out a solution. It must take the realities of HF propogation, use, and possible bit rates into consideration.

Given the sample "three mode band plan" discussed here, Mr. Rotolo could/would indeed have 25khz for higher data rates on most HF bands in the "other" segment. Can the ARRL plan promise as much without taking spectrum away from CW or analog voice modes? Yet by wanting the world, the proponents of the ARRL plan effectively snub narrowband digital modes by attempting to wedge them into 35khz with CW, and wide band users (25khz) by ignoring them altogether.

Whatever your interest, let's insist that whatever plan we support for adoption is fair.

 

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 and 500Hz is probably unnecessary. FCC could end up just combining everything into 3kHz or 3.5kHz bandwidth, with other provisions for wider bandwidths, like the rest of the world already does. This would enable USA hams to communicate with the rest of the world on the valuable 40 meter international band, especially during emergencies. Perhaps the petition shows undue favoritism for AM phone. Instead of that, a better way would be a two-step 10kHz (or more) bandwidth overlay mask in the HF bands with emissions that are outside the 3kHz bandwidth allowed 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, but there are other ways to enable AM without defining it on a mode basis.

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.

















.

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

10
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

11
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;

22
(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:

23
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)

24
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.

 

Wow,--Some things DO NOT CHANGE,--another "soapbox"
rant from KQ6XA.
I guess if one SHOUTS LOUD ENOUGH and LONG
ENOUGH the desired results will come about.

73, K1MVP

 

and your solution is?

Steve, k4cjx

 

Sounds like regurgitated grass as what cows chew on....
Whatever happens gonna happen anyway we like it or not.

 

Geeze, next they'll outlaw my spark-gap,
and make me use that Amplitude Modulation thing.
wayyy to complicated for me..

 

After reading the ARRL’s Petition for Rulemaking, it has become obvious to me that it is so poorly drafted that it should never see the light of day. Regardless of where you support or oppose the concept of regulation by bandwidth, what the ARRL wrote contains errors that are simply unacceptable.

There are at least three major faults with the draft submitted by the ARRL. First, it uses expressions that are not defined. Second, it defines bandwidth to be whatever is “just sufficient to ensure the transmission of information at the rate and with the quality required under specified conditions.” This means a 200Hz bandwidth signal can occupy as much frequency spectrum as it needs. The result of this is that my 3.0 kHz SSB signal meets the definition of a 200 Hz bandwidth signal as it is “just sufficient to ensure the transmission of information at the rate and with the quality required under specified conditions.” Finally, the proposal allows semiautomatic operation to occur throughout the Amateur bands. Each of these is discussed below.

Bad writing for changes to Part 97 does make a difference. For example, the proposed language for Section 97.3(a)(8) uses the language “a given class of emission” but fails to define what a “given class of emission” is. Is a “given class of emission” defined by its bandwidth, modulation mode, information being transmitted, or something else? This term is not defined in Part 97 nor is it defined in the proposed change.

Another example of bad writing occurs in the proposed language for Section 97.3(a)(42). Here we find the language “allocated frequency band.” Does anyone know what an “allocated frequency band” is? Again, the language is not defined in Part 97 nor is it defined in the proposed rule changes.

The definition of terms must be contained within Part 97. It is not an accident that Part 97 starts with a long list of definitions.

Next, whoever drafted the proposed changes to Section 97.3(a)(42) has attempted to define a “spurious emission.” Unfortunately, they adopted the very poor language of the existing Part 97.3(a)(8) which reads:

Bandwidth. The width of a frequency band outside of which the mean power of the transmitted signal is attenuated at least 26 dB below the mean power of the transmitted signal within the band.

The problem with this definition is that the expression “frequency band” normally means something like the 40 meter Amateur band. In this definition it means the amount of frequency spectrum occupied by a particular signal.

The unfortunate thing is that this poor drafting has been used in the proposed Section 97.3(a)(42). It reads:

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.

Notice how this new definition of spurious emission uses the language “frequency band” just like it was used in the existing Section 97.3(a)(8). Rather than trying to make the language of Part 97 more clear, the ARRL’s proposed changes make it more difficult to understand. And of course, one reading of this very sloppy drafting is to say that any emissions that fall within the “frequency band” (using the common definition of frequency band such as the 40 meter band) are not spurious emissions. So if I am transmitting on a frequency of 7.15 MHz and I am splattering from 7.0 MHz to 7.3 MHz, that is NOT spurious emissions. Is that what the ARRL intends? I hope not!

The next issue is the logic of this proposed change. The ARRL is proposing a new definition of bandwidth. The new proposed Section 97.3(a)(8) is as follows:

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).

Here is the current definition of bandwidth:

Bandwidth. The width of a frequency band outside of which the mean power of the transmitted signal is attenuated at least 26 dB below the mean power of the transmitted signal within the band.

Now I am just guessing but I think the reason for this proposed change is because most Hams do not have the means to measure the bandwidth of their transmitted signal. I don’t and I certainly do not have any plans in the near future to invest in the necessary equipment to do so.

Remember that “given class of emission” is undefined as I previously pointed out but my guess is that this is being used to mean the various maximum bandwidths allowed for the various sub-bands. In other words I am guessing that a “given class of emission” means one of the maximum bandwidth signals such as 200 Hz, 500 Hz, 3.5 kHz, etc. Well under the current bandwidth definition, a signal that has a 200 Hz bandwidth must be attenuated by at least 26 dB at the edges of the signal. The problem is that under the ARRL’s proposed definition of bandwidth, there is no such requirement. If the signal were attenuated by .0000001 dB (or less) at its edges as long as the signal width was “just sufficient to ensure the transmission of information at the rate and with the quality required under specified conditions” it would be acceptable. Under the ARRL’s proposed changes, that same signal might be attenuated by 26 dB at 3.5 kHz and still meet the requirements for a 200 Hz bandwidth signal as long as it was “just sufficient to ensure the transmission of information at the rate and with the quality required under specified conditions.” This means that a normal SSB signal (or any other legal signal) whose bandwidth was “just sufficient to ensure the transmission of information at the rate and with the quality required under specified conditions” could be transmitted anywhere in the Amateur bands.

This is a giant problem. Not only did the writer of this proposed rule change not write with any degree of clarity, the writer did not even think about the consequences of what was written. And if the writer and reviewers haven’t thought about the simple consequences of what they have written, I suggest they haven’t even begun to think about the consequences of this entire proposed rule change.

My final point is the proposed rule change itself. As it is written, I believe it is a poor idea. The proposed change concedes than what is commonly referred to as “fully automatic control” is problematic in the HF bands (see Paragraph 15 of the Petition for Rule Making). The reason that this type of operation is a problem is that stations operating under such control can and do initiate transmissions that interfere with ongoing communications. This point is conceded in Paragraph 15. Then the proposed change tries to reason that what is commonly called “semi-automatic control” should be allowed to operate freely within the HF sub-bands where other similar bandwidth operation is allowed (see Paragraph 16 of the Petition for Rule Making). Unfortunately, stations operating under semi-automatic control can and do interfere with ongoing communications as well. While one of the stations operating under semi-automatic control has an operator present who can insure the particular frequency is not being used, the station without an operator present does not do so. It is very common in high frequency operation that only one end of a two-way communication can detect that a particular frequency is in use. If the only end that could make this determination is the station without an operator being present, then the ongoing communications will experience interference. This is not a hypothetical point as it does currently happen with great frequency. The obvious solution is to segment both fully automatic and semi-automatic operation to a small portion of the available frequency bands to preclude such interference.

If this proposed rule change sees the light of day at the FCC in its current form, I believe that it must be rejected.

 

AG4YO:"The "other" segment would contain all modes not CW and/or Analog Voice (AM/SSB) but including new digital modes."

Why can't your other segment include all modes?

73,

Mark N5RFX

 

IMHO, THE ARRL IS WRONG AND SO IS BONNIE.

 

The solution is obvious. KQ6XA and K4CJX should take up their QRMing digital activity on the 27 MHz band
and stop proposing solutions to a non-problem.

After 49 Pages that proved hthat the majority of hams do not want this crap forced on them, the two of you continue to ignore the wishes of most of the other hams
and just bray away here in a new thread when you can't seem to get your way.

Hardly surprising...

 

Ya know, Steve,--I have commented little if any, on
this "new" bandwidth management issue.

But I HAVE commented plenty on the restructuring
proposals out there both here on QRZ and the FCC
EFCS comment website.
The "restructuring" issue has been my "pet peeve" and
these other issues (BPL, Bandwitdh) etc, are just part of the "bigger picture" IMO, as to why ham radio is in the
"mess" its in.

I don`t pretend to have all the answers, BUT I also
know that the "big boys" in Newington don`t either.
I strongly believe that the "seeds" for this mess
were because of a lack of leadership, in that the
ARRL  "reacted" to something they should have
seen coming a long time ago.

I DO NOT believe that the HF bands should be
turned into an "alternative internet", in spite of
what some believe.

I also DO believe that one of the biggest mistakes
was the turning over of the exam system from
the FCC to the NCVEC,--and that has led to
a "credibility" issue with these "watered down"
exams,IMO.

It does NOT take a "phi beta kappa" to see that its
going to take more than just "intellectuals" to fix
this mess,--Its going to take guys with some technical
expertise , experience, AND common sense.
I fail to see much of any, lately coming from the ARRL,
especially in the area of common sense.
All I sense,--is "fear", or "what is going to happen if
we don`t get the numbers up".
So thats "my take" on this mess.

                          73, K1MVP

 

Here's a solution:

1. Leave analog voice alone.  Don't change a thing with the rules -- it's been working (for the most part).  Perfection it's not, but it's better than unleashing a pile of "Bandwidth Cops" telling everyone that their Phishfinder Ic@m bandscopes says we're illegal.  That's a big can of worms that needs to be left unopened.

2. Limit Digi-Wigi to some number that we can all live with.  20 kHz doesn't seem unreasonable to me when 50 or 100 kHz or more of spectum can be observed unused any given day or night (not always, but quite often).  I wish I was more of an expert at HF Digi modes so I could offer an opinion, but I can say this: I was in New Orleans, and the CQ Article speaks the truth.  As well as we did, we could have really knocked their socks off with decent basic file transfer rates over HF.  I know everyone wants to keep their little piece of HF, but you know what?  If we keep up this fighting over who can use 6 kHz of SSB or who shouldn't be using some digi mode, none of us will have any HF at all!  Think it's not possible?  Keep living in your fantasy worlds.  A commercial, rapid deployable HF system could easily be designed for emergency use and our freqs could very well be harvested for it.  Think about it.  While you guys are worried about being able to operate QRPppppp.....  on 7060 (or whatever damn freq it is -- why 7040 or 7120 isn't as good is beyond me) with some kind of guarantee of zero QRM, the whole damned thing could go.  Same goes for every other "special" interest mode.  The best way to ensure our bands are kept for our use is to use them for real, useful, and efficient emergency communications when the country needs us.  And if the bands aren't used in support of a real-world emergency, they should be used as efficiently as possible.  10s or 100s of kHz of "no-man's land" in our bands is counter-productive.

3. I say open the bands up.  We already have intentional QRM rules, and resources should be used heavily enforcing that instead of scarcely enforcing too many rules.  Basically, I say let's all "play nice" and quit acting like you own a frequency, understand that band conditions can change on occasion, and be adult about moving your QSO a couple kHz away.  The only time anyone should be worried about what is going on beyond their bandpass is when you need to exercise your VFOs and move if band conditions change.  I for the life of me can't understand why you all care so much about what mode is in use 10, 20 or 100 kHz away from where you are.  If I want to use AM on 3760, and there isn't anyone +/-5 kHz away (verified by asking), who cares?  Same with CW on 14.250 or SSB on 7100.  I just don't get what the problem is.  Nobody is guaranteed 100% QRM-free use of HF.  Why act like it's some right you all are entitled to?  If there's a contest on some weekend that I'm not participating in, I simply find something else to do.  You are not guaranteed exclusive use of the bands to "hang with your buds" on your "normal" frequency.  Is it fun?  Do I do it? YES!!  But I don't bit...I mean complain incessantly when a couple days a year I can't.  Could be contests, CMEs, noise, or just lousy band conditions that create it, but the point is don't whine about it!  I can't help but think there's some unsaid reason or fear about why the 160m bandplan (or many other countries' bandplans) shouldn't be implemented.  It obviously works -- 2m is another decent example, albeit a non-worldwide band.  Did you know there's nothing in the FCC rules that says I can't use FM on 144.1 or SSB on 147.5.  There's more to life than getting on the same freq with the same guys night after night after night.  It won't kill you to put the mic down.  Really.  Try it sometime.

So I leave you with this: Why is it okay to cram into 150 kHz sometimes while 300 adjacent kHz is vitually silent?  Why should I care that a few guys are using CW or AM or PSK 20 kHz away from my current bandpass??  Why claim that something "ain't broke" when clearly it is?  Why shoot ourselves in the foot one more time with the ARRL's proposal?  Why won't the Canadian bandplan work in the US?  What are you all really afraid of?

Joe, N3JI

 

This is no reason why an amateur should be permitted to download music, video files, perform misc file transfers etc on HF.  The only exception would be in times of emergency, and in those times I'd do it anyway if neccessary and explain myself to the FCC later.

This is something that needs to be impressed upon the FCC.  Just because we can do this type of activity on HF does not mean we should allow it (extenuating circumstances notwithstanding).

If the "younger generation" wants to download music and video, perhaps they should acquaint themselves with the internet.  Just call Al Gore.

 

Unfortunately, Joe, that makes way too much sense to be taken seriously.

73,
Phil

 

Breaker-Breaker 10-4 good buddy, Not that far down the road. At least it will be a nice equipment upgrade.