I got a prompt response.... Dave K8BBM
>Date: 23-Mar-2007 08:59:13 -0500
>From: "Sumner, Dave, K1ZZ" <email@example.com>
>To: <firstname.lastname@example.org>, "Bellows, John (Dir, Dakota)"
> "Greenheck, Twila (Vice Dir, Dakota)" <email@example.com>, "Harrison,
> Joel (President)" <firstname.lastname@example.org>, "Craigie, Kay (1st
Vice President)" <email@example.com>
>Subject: RE: RM 11306
>Thanks for your message. Here is some background on the subject
>In July 2002 the ARRL Board of Directors adopted the following
policy: "At the next practical opportunity the ARRL shall
petition the FCC to revise Part 97 to regulate subbands by signal
bandwidth instead of by mode." The Board's objective was to
update rules that were written long before the development of the
current generation of digital modes so that digital emissions can
be appropriately regulated in the future, while impacting
traditional modes as little as possible.
>Turning that statement of principle into a detailed petition
proved to be no easy task. The Board received input from an ad
hoc committee as well as staff, and twice solicited input
directly from the ARRL membership. Hundreds of comments were
received each time and helped inform the Board's discussions.
Finally, at its July 2005 meeting the Board concluded its review
of a draft petition and authorized its filing, following final
review by the Executive Committee. The resulting petition was
filed on November 14, 2005 and was designated RM-11306 by the
FCC, after which additional comments were filed by individuals
directly with the FCC.
>Once the FCC had dealt with two outstanding proceedings, WT
Dockets 04-140 and 05-235, we realized that the bandwidth
petition was the next major Amateur Radio item in their hopper.
On reviewing the RM-11306 petition, the comments, and the rules
changes adopted in Dockets 04-140 and 05-235 it was apparent that
some of the proposals contained in the petition had been affected
by the changes adopted in the other two proceedings. It was also
apparent that some aspects of the petition remained controversial.
>After reviewing the situation at its January 2007 meeting, the
ARRL Board authorized General Counsel Chris Imlay, W3KD to
determine what changes to the petition had to be made to align it
with the new FCC rules, as well as which aspects of the petition
were not controversial and could reasonably be expected to be
included in an FCC Notice of Proposed Rule Making. Chris did so,
and a meeting was held with FCC staff on February 13. As are all
such meetings, this was made a matter of public record by the
filing of a notice with the FCC Secretary that immediately became
part of the online record in RM-11306.
>The FCC staff was provided with a shortened list, or subset, of
proposed rule changes from that contained in RM-11306. The list
is included with the notice of the meeting. Because the proposals
affecting the bands above 28 MHz had not aroused much
controversy, they were retained in the shortened list. Regulation
by bandwidth rather than by mode of emission remains
controversial below 28 MHz because of perceived potential impact
on established operating patterns, so these proposals were
removed from the list with one narrow exception. The exception is
necessary because, as discussed on page 11 of the RM-11306
petition, under the existing rules there is presently no
effective bandwidth limit on HF digital operations. Digital
emissions using multiple carriers, such as OFDM, can be designed
for any bandwidth while staying within the existing rules. So,
the subset of proposed rule changes given to the FCC on February
13 includes a bandwidth limit of 3 kHz on RTTY and data emissions
below 28 MHz. It is important to understand that this does not
increase the allowed bandwidth for RTTY and data emissions; it
actually represents a new limitation that accommodates existing
practice but prevents future monopolization of large segments of
our narrow MF/HF bands by a single digital station. Also, the
limit would not apply to phone emissions.
>Some confusion has resulted from an item that, through
oversight, was not deleted when the list of proposed rule changes
was shortened. Because RM-11306 had proposed that bandwidths in
most of the band segments now used for CW and RTTY be limited to
200 Hz and 500 Hz respectively, the existing 500-Hz bandwidth
limit that applies to certain automatically controlled RTTY/data
stations was redundant and could be dropped. However, because the
subset of proposed rule changes does not substitute regulation by
bandwidth for regulation by mode of emission, the 500-Hz limit
needs to be retained. General Counsel Imlay has filed an erratum
with a corrected list of proposed rule changes that makes it
clear there should be no change to the existing Section 97.221.
We regret the error.
>Some amateurs have observed that the subset of proposed rule
changes provides less protection to CW, RTTY and other narrowband
modes than was afforded by the ARRL's proposals in RM-11306. This
is true. However, it is not true that less protection is afforded
than is the case with the existing rules. In fact, protection
against interference from wide digital modes would be increased,
not decreased, by adoption even of the subset.
>The ARRL Board, having studied the situation literally for
years, continues to support the principles of regulation by
bandwidth that are contained in the original RM-11306 petition.
Regulation by bandwidth provides a better regulatory framework,
not only for the introduction of future digital emissions but for
the protection of traditional narrowband modes as well. By
providing the FCC with a subset of the modifications proposed in
RM-11306 the ARRL has offered an alternative that, it is hoped,
will make it easier for the FCC to move at least part of the way
in that direction.
>David Sumner, K1ZZ
>Chief Executive Officer, ARRL
>March 22, 2007
>From: firstname.lastname@example.org [mailto:email@example.com]
>Sent: Friday, March 23, 2007 9:50 AM
>To: Bellows, John (Dir, Dakota); Greenheck, Twila (Vice Dir,
>Sumner, Dave, K1ZZ; Harrison, Joel (President); Craigie, Kay
>Subject: RM 11306
>I have great concerns about the league filing in this matter that
>would regulate by bandwidth and would like some explanation of
>this issue so I can prepare my own comments for the record. I
>sense a grave mistake has been made by the league in the filing.
> The absence of communication from the league is most detrimental
>to its image, to our moral as members, and to the issue at hand.
>If a mistake has been made by leadership, let's own up to it and
>get on with rectifying the situation.
>As a dedicated CW op, lots of QRP, I have been struggling with
>"encroachment" on frequencies usually inhabited by CW, with a
>great number of ditigal signals. I guess any sense of bandplan
>or gentleman's operator frequency guide has gone out the window.
>Dave Heintzleman, league member
>firstname.lastname@example.org or above at srt.com
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