[SCCC] Sumner on RM-11306

[W6ph at aol.com]

Hi Guys,
        Sorry that this didn't come through the first time.  This is from 
Dave Sumner and complements Dick Norton's previous message.  The sky may not be 
falling after all.
                                           Kurt, W6PH

This from K1KI to a YCCC member, not me.  de W6PH

Thanks for your message. Here is some background on the subject you raised.
>
>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 emissi!
ons be
low 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




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