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ARRL seeks comment on
draft 'Bandwidth' petition

The ARRL wants members' comments on a planned petition to the FCC seeking to regulate amateur subbands by bandwidth rather than by mode.

The ARRL Board of Directors adopted the petition's guiding principle - to create a regulatory environment more accommodating to newer technologies - two years ago, and it wrapped up its review of a draft petition in late July.

"The main objective is to make appropriate provision for digital modes in the HF amateur bands, while preserving amateurs' prerogatives to use the traditional modes," said ARRL CEO David Sumner, K1ZZ. "Regulation by Bandwidth" is the title of Sumner's "It Seems to Us . . ." editorial in
September QST.

The draft petition represents expert input from the ARRL Ad Hoc HF Digital Committee. ARRL staff also provided an interim report, and the Board reviewed a draft petition when it met last January. An ARRL Executive Committee review followed. The EC decided to make a synopsis and
explanation of the petition available to ARRL members before it goes to the FCC.

"The regulation of emission modes in Amateur Radio Service allocations is a limiting factor with respect to Amateur Radio experimentation," the petition synopsis concludes. "It leads to attempts to put new technology into a regulatory framework that was designed only to deal with older
analog emissions." To implement digital technologies, an underlying assumption of the League's draft petition is to provide for an intermediate bandwidth - between what's needed for the legacy CW and phone modes - in the middle of certain bands.

As drafted, the ARRL's bandwidth petition would preserve double-sideband AM unchanged, but it would stop short of opening the phone bands to digital and other modes of the same bandwidth.

FCC rules now permit RTTY and data emissions throughout the HF CW subbands, although informal agreements typically keep RTTY and data signals out of those parts of the CW band generally used for CW. The ARRL's petition proposes to limit bandwidth in the CW subbands to 200 Hz,
which also will accommodate data modes such as PSK31.

In addition, the League's proposal would limit bandwidth in the existing "RTTY/data subbands" to either 500 Hz or 3 kHz, with phone emissions specifically prohibited in certain subbands where 3 kHz would be permitted. Under the proposal, these would include 3650-3725, 7100-7125,
14,100-14,150 and 21,150-21,200 kHz.

"The reason for this is to encourage the development of higher-speed data communications in these subbands by preventing them from becoming de facto 'expanded phone bands.'" Sumner explained.

The new proposals take into account the ARRL's prior "Novice refarming" petition to expand some HF phone bands, included in the FCC Notice of Proposed Rule Making in WT Docket 04-140.

Amateurs typically won't have to be able to measure the bandwidth of their signals, Sumner says, since the bandwidths proposed are more than sufficient for "clean" signals using traditional HF modes.

The ARRL proposal would eliminate bandwidth restrictions in the 222-225 MHz band--beyond a requirement to keep signals confined within the band.

Sumner encouraged ARRL members to review the synopsis of the petition and the specific rule changes the League plans to propose. Direct questions or comments - favorable or otherwise - via e-mail bandwidth@arrl.org. ARRL staff members will respond to any questions, while comments will be forwarded to your ARRL division director. Members also are welcome to comment directly to their ARRL directors,
also listed on page 15 in QST.

 

 

Source: ARRL Letter - courtesy of The American Radio Relay League

 

 

 

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