There are presently no subbands on 160m, so that's why it's not
My planned comments (as usual) to the ARRL are to suggest that 160m be
segmented into subbands. That'll fall to deaf ears (as usual), so when
the FCC asks for comments on the proposal, I'll suggest it to them."
That is correct. This is a proposal to redefine the subbands, and would not
affect 160m because topband does not have any subbands.
I'm afraid this one might generate some unintended consequences. They are
proposing four different bandwidth subbands, some of which exclude certain
specific modes, plus the exception for AM phone. This would appear to be
combined with the existing licence class segmentation. The result would be
an extremely complex matrix of subbands, defined by various combinations of
bandwidth, emission modes and licence privileges.
There has to be a better way to accomplish the stated purpose of the
While, yes, subbands do not exist on 160 meters, the proposed subbands of
3650-3725, 7100-7125, 14,100 - 14,150 and 21,150 - 21,200 to include digital
up to 3 KHz but phone emissions would be prohibited.
And, the proposal is for 3 bandwidths subbands not 4.
Throughout the synopsis, it refers to HF digital modes only.
However, in the "Planned ARRL petition to the FCC to regulate subbands by
bandwidth" there is, in part:
The following is a band-by-band summary of the changes proposed in the table at
Â 97.305(e). For details see "Proposed Rules Changes." The proposed changes
are intended and are believed to be consistent with the Commission's proposal
for "refarming" the Novice Class subbands proposed in WT Docket No. 04-140, and
which is now pending.
â 160 m band: This petition does not propose segmenting the 160-meter band
but would allow bandwidths from 0 to 3 kHz throughout (while permitting DSB-AM
and ISB). ARRL's band plan recommends that the band be segmented informally by
mode. ARRL does not suggest band segmentation in this band by regulation.
However, should the Commission determine at some time in the future that
segmentation by regulation is in the public interest, it is recommended that
the segmentation be accomplished by bandwidth limits and not by emission mode,
in accordance with the recommendations in this Petition."
It would seem that the door is open even if only a little.
I fully recognize there are many strong views on this subject. However, while
no change or implementation is perfect, further consideration of INCLUDING a
subband on 160 meters along with the HF bands for the same reasons specified
seems worthy and prudent. This would allow for similar experimentation on 160
meters along with its unique propagation conditions and minimizing potential
As described in the ARRL petition announcement:
"The regulation of emission modes in Amateur Radio Service
allocations is a limiting factor with respect to Amateur Radio
experimentation," a synopsis of the petition concludes. "It leads to
attempts to put new technology into a regulatory framework that was
designed only to deal with older analog emissions." In order to
implement digital technologies, an underlying assumption in 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."
73, Jim, K1PX
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