ARRL draft bandwith proposal

Meeting October 16 in Dallas, Texas, the ARRL Executive Committee (EC) devoted much of its fall session to a discussion of comments received on ARRL's draft FCC petition seeking regulation of sub-bands by bandwidth
rather than by emission mode.

The EC also authorized the filing of a Petition for Reconsideration in response to the BPL Report and Order (R&O) in ET Docket 04-37, which the FCC adopted October 14. Drafting and filing the petition must await release of the actual R&O, which should happen in a few weeks.

Responding to a synopsis of the bandwidth petition and
proposed rule changes posted on the ARRL Web site, several hundred League members and others in the ham radio community offered comments and suggestions.

"The Executive Committee found considerable support for the concept of the petition," said ARRL CEO David Sumner, K1ZZ, "along with constructive suggestions to reduce both the impact of the changes on current amateur operations, as well as possible unintended consequences." Sumner's "It
Seems to Us . . ." editorial, "Regulation by Bandwidth," in September QST addressed the bandwidth petition.

Earlier this year, the EC decided to make a synopsis and explanation of the petition available to ARRL members before filing it with the FCC. At this month's meeting, the EC agreed to submit several recommended amendments to the proposed rules changes to the ARRL Board of Directors
for its consideration in January. These include:

• Retention of rules permitting automatically controlled digital stations (packet and other digital modes) in narrow HF subbands. The draft petition had proposed dropping these provisions.

• A rule prohibiting so-called semi-automatic digital operation (automatic control in response to a communication initiated by a live operator) on frequencies below 28 MHz where phone is permitted. This addressed a
concern that "robot" digital stations might take over the phone bands.

• A segment for 3 kHz bandwidth (no phone) emissions at 10.135-10.150 MHz to accommodate existing and planned digital operations.

• Deletion of the word "continuous" from the description of test transmissions authorized on most frequencies above 51 MHz.

• Simplification of proposed changes to §97.309 to clarify that FCC-licensed amateur stations may use any published digital code as long as other rules are observed.

"These recommendations are not intended to be the final word on the draft petition, but are intended to address the major issues raised to date," Sumner emphasized.

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

The EC also authorized ARRL General Counsel Chris Imlay, W3KD, to "prepare to pursue other available remedies as to procedural and substantive defects" in the BPL proceeding.

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

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