The AM Forum

Today I read FCC Petition for Rulemaking #11769, which was filed on May 2, 2016. You can read it here: http://apps.fcc.gov/ecfs/comment/view?id=60001692464.

While the petition appears to be a request to amend Part 97 to eliminate exclusive CW subbands, there is a bit more to it. Buried deep in the petition, in Section 17, it states: "Petitioner further proposes...between 1.8 and 29.5 mHz the 20dB bandwidths be limited to 8000 Hz (i.e., double-sidebanded analog AM voice)".

Hmmm. I think this warrants some discussion here and some comments by us AM-ers and boat anchor enthusiasts to the F.C.C.

Frank
WO4K

It appears the only thing missing in this petition is a proposal to limit the 20 dB bandwidth of Part 15 RFI.

 ;D OMG  ;D

Craig,

20 db below the carrier eliminates the modulation.
Glad he specified +\- 4kHz. ;)

No he said 8KHz. that's + and - 8 KHz from the carrier.  ;D ;D ;D

It would be wrong to impose arbitrary numbers where no regulation is needed.

I got something to say about this and it apples to other such 'band width limit' proposals. It is TLDR, but I don't care.

I SWL AM on the ham bands a lot and don't think I have ever measured* persons conspicuously using the 'bandwidth' the proposal seeks to limit.

I think it's very rare but probably happens experimentally, that is, strong audio out that far may rarely occur the result of some quite rare experiment between a couple of hams. Even with no intentional frequency limits used in transmit, it is hard to imagine any sort of problem being caused that would affect this person enough for them to have a logical reason for the proposal. It's an emotionally charged issue but has to be considered logically.

Stations using all applicable modes may be occasionally playing around but I really fail to see how it is bothering anyone that doesn't want to be bothered.

I think it is completely 'within the rules' to experiment as long as it is not intentionally bothering anyone. There can be no reason for the proposal unless a real problem is being caused that affects the bands as a whole. Any single-ham complaints such as might be implied by this single-author proposal simply fall into the category of "Report the offender to the FCC".

Of the person(s) behind the proposal, I would demand evidence as a validation:

1. Documentation that this actually happens (time, date, recordings of the supposed offense, and test-instrument-produced analysis with industry standard output file). There must be many of these or it can't support the proposal.

2. Proof that interference is being caused. Acceptable evidence might be a digital recording of a chunk of band from an SDR or instrument where the sidebands from the presumed AM station are shown causing interference with a close by conversation AND the persons in that conversation are complaining about it or mentioning it using specific words like 'interference', etc. to describe what is happening. There must be many of these or it can't support the proposal.

In absence of factual scientific evidence and sufficient FCC complaints documenting that there is an actual problem, it could be guessed that the person(s) behind the proposal have a victim mentality combined with a hate for AM. Or that it's just the same tired old push from some old crab to get something to benefit himself at everyone else's expense. It does not seem mentally healthy nor a reason for action by a rule making body.

*R390 at 16KHz and spectrum analyzer on the IF.

Now to address the specific 'proposal' - he wants to eliminate CW and give more band space to digital. I'm sticking with the CW persons here. It's wrong and 'their space' should be respected. I disagree about under-utilization by CW operators. During periods when the bands are in heavy use by all modes (contest or otherwise) the CW and non-CW portions are filled about equally. If the CW sub bands are gone, believe me there will be many other emissions there and due to the nature of CW it would be harder to pursue that sort of activity with pleasure and ease especially with 1 watt, or even 100. The SSB, Image, and other modes would move into the sub band.

He complains about CW using 150hz, and proclaims digital to be 9Hz wide, but -OOPS!- he forgot about the high speed digital modes that are much wider than 150hz.

It's false to call sub bands nostalgic for a certain mode. Specious argument to get rid of 'em and move in with digital stations that will start up right on top of existing low power CW communications. Since the brass pounders can't decode or transmit that stuff unless it is also part of their specific hobby, including proprietary high dollar digital stuff, how can they inform the offending station that there is an existing QSO, or even know who is sending? He wants carte blache to run robots roughshod over CW hobbyists.

He goes on about progressive licensing, is in favor of it, and says that proficiency should be demonstrated (remember the CW test days?). OK when he designs and builds his first new type of ham radio MODEM, then the proficiency incentive argument he makes might have some value. "I designed MODEMs. Surely it is a simple thing for him to be incentivized by. If I had to do it then so should he". OOPS! that was in spirit what some CW grouches were saying at one time Morse was eliminated from the testing.. and it is just as wrong to say it now. He is just making an emotional point.

Some comments in the proposal (12) seem to show that he wishes all analog modes to stop and be replaced with digital modes, whether it is data/code, image, or voice coming from a MODEM. Key word revealed, he wants to do to ham radio what the FCC did to TV - make ty all digital. It would be a degradation of the national infrastructure and national Security to do that to ham radio. Anti-American, that is.

In (13) and forward, he even attacks FM. He wants to make it illegal to use the old 50KHz and 100KHZ channelized military gear. That stuff is so infrequently used that it can cause no valid interference complaints. That knocks out the nice PRC-68, PRC-77, VRC-12with full duplex, and whatever other patriotic old green rigs need the dust knocked off of them from time to time, as well as the older mobile FM stuff that a few people have converted and stuck in a rack for local chat.

Then to the AM thing. It is as illogical as the rest of the document. No regulation is needed there.

In (18) and (19), he says no changes are needed. Why? because it is already digital.

=================

The petition is poorly thought out from the "whole community" standpoint, of bad technical concept, selfish, and illogical. I will make sure all my CW and FM operating friends know about this too. I will comment to his petition when possible.

Thanks.

He does not want to eliminate CW. On HF, the CW sub-bands only apply to 80, 40, and 15M. The CW sub-bands are not unique to just CW. RTTY and data are there too. Actually, you can use CW anywhere on any of the bands and the only restriction is dependent on your license class. Personally, I think the proposal is frivolous, but it was written and presented well, and evidently it caught the attention of the FCC enough to issue an RM number. Basically, he proposes three modes:, voice, image, and symbol (CW, RTTY, data). I suspect the AM/FM stuff was an afterthought since there wasn't a lot of meat on that part. If you're going out on a limb, why not go a little further.

Thanks for clearing that up.

It's probably just something the author of the petition stuck on there in hopes of getting support from the FCC.

What's the limit for AM broadcasting? IMHO, we could ask for modification if the broadcast limit is different: the next generation of broadcast engineers has to learn their trade somewhere, and if Amateur rules are different than those for the AM Broadcast band, that would be an impediment to their education.

Come to think of it, why not just petition to eliminate that part of the proposal? The issues aren't related.

Bill, W4EWH

If I could never operate with audio well over twice as wide as that, I would be sickened at the restriction to the extent of seriously considering quitting this service forever. What a bunch of dumbed-down, miseducated conformists. Such people should have no power.

Thanks, folks, for bringing this to our attention. I have been fighting these kinds of "bandwidth control" proposals ever since I put on a large number of amateur bulletin transmissions (and made a mass mailing) to stop Docket 20777 back in 1977.

I am getting quite sick and disgusted by the same kind of proposal being submitted again and again and again.

Amateur radio operators who think like channelized "comm" operators and conventional-minded appliance operators who never experiment with good audio, and those who have tin ears who can't tell the difference should not be able to dictate to those who can and do.

Furthermore, there should be some sort of prohibition -- that can never be revoked -- to prevent this kind of proposal from ever being submitted to any regulatory body, and severe sanctions imposed on those who attempt to do so. The good guys should not have to deal with fighting this same battle again and again and again.

Experimenters have the right to use any bandwidth their experiments require so long as they do not intentionally interfere with others. This right should supersede any pretended "regulation" to the contrary.

In addition, there is no need for FCC-defined subbands of any kind. 160 meters gets by perfectly well without them.

73,

Kevin, WB4AIO.

No, FCC measures total bandwidth. 8Kc is 8Kc. +/-4Kc from carrier.

It really means any emission AT +/- 4Kc needs to be -20dBc for AM. Unless they actually put out a transmit mask it also means emissions closer to carrier can be much higher!!

The FCC typically will suggest a SSB bandwidth and assume X2 for AM.

Well stated Kevin.

If we all make reasoned, technical comments to the FCC maybe this kind of sillyness can be stopped.

Phil - AC0OB

Careful Kevin, in 2003 I was called a moron for thinking this could work across amateur radio. You see, we are not all as sophisticated as those who work 160M!  ;)

Only "gentlemen" operate on 160 meters.  ;)

There are many experimenters within the amateur radio hobby where "good audio" has no bearing on whatever "experiments" they may be doing and probably could care less.

The writer of the proposal is venting his ideas and feelings on how his restructure would benefit the entire amateur radio service. No different then the venting in your post. If you disagree wit the RM, voice your disapproval; you have 30 days to do so.


This is America. Anyone in the amateur radio service has the right to propose whatever they want to the FCC. It's up to the FCC if it moves forward.


Experimenters should not be granted any preferential treatment or rights over any other amateur radio activities or regulations. That's just plain wrong. As long as they comply with  FCC Title 47 CFR and Part 97, whatever activities they are involved with, should be fine.


The Novice and Tech licensees are still an active part of amateur radio. The CW sub-bands, along with power restrictions,  are also used by them.

When did I say otherwise?




When did I say otherwise?




So?


73,


Kevin, WB4AIO.

This has been all over the AM and Boatanchor reflectors for a couple days with lots of discussion about the possible ramifications which all leaves me wondering what the petitioners goal is....especially considering his TV translator relay license that was granted but cancelled the following year
 http://wireless2.fcc.gov/UlsApp/UlsSearch/license.jsp?licKey=3207507 
 and his cancelled amateur license just a few days ago??? 
http://wireless2.fcc.gov/UlsApp/UlsSearch/license.jsp?licKey=628040

You're reading it incorrectly.
See http://wireless2.fcc.gov/UlsApp/letterPdf/LetterPdfController?licId=628040&letterVersionId=69&autoLetterId=8930823&letterCode=AZ&radioServiceCode=HA&op=LetterPdf&licSide=Y&archive=null&letterTo=L

Who is the person who submitted the proposal and do we know anything about him??

                    _-_-

You can click on the previous FCC links to get his name, address, and call. You can click on his proposal on the FCC site and read a synopsis of his amateur radio history. You can Google his name or call.

And the real question is, what's the difference who it is? It's the proposal that is the issue.

The petitioner coins this phrase, “emission privilege system.” I almost stopped reading at this point. I felt my IQ dropping, but I continued. This phase borders on Orwellian newspeak.

The petitioner claims that he wants to reduce regulation. What nonsense. Get rid of the idea of privileges all together. The class system of licensing is the regulatory source of many (maybe all) the current sub-bands. Want to get rid of sub-bands, get rid of classes. The petitioner clearly missed this link and the RM is therefore incomplete. Based on this alone, the RM is poorly thought out and poorly written. It is a product of muddled thinking or maybe no thinking.

The frivolous and unenforceable bandwidth limits only further illustrate the inconsistency and confusion in the petitioner’s mind.How can one argue for less regulation by imposing more? Silly.

I won't waste time commenting on the technical errors in the RM.

The FCC should give the RM the consideration it deserves.

I ask because perhaps there is an agenda, or a purpose, personal or commercial behind it. If so, it would be useful to know. That's all.

Who knows what his reasoning is behind it.

All we know is he was recently upgraded from a Novice to a General.

But as Steve said, his petition is contradictory because he says he wants to deregulate ARS, but yet proposes to impose artificial limits on bandwidth and create a myriad of sub-bands via further regulation.

Again, if we all make reasoned, technical comments to the FCC in opposition to this petition it can be rejected by the FCC.

You can go to:

apps.fcc.gov/ecfs/comment_search/execute;ECFSSESSION=2fVLX9HKHMQ2tnJ8CY256mGL00pXlDnVqsgyqLmL6Jt1mL5qDjZd!2128758255!-1136457793?proceeding=RM-11769

and see the various comments.

Phil - AC0OB

link:

apps.fcc.gov/ecfs/comment_search/execute;ECFSSESSION=2fVLX9HKHMQ2tnJ8CY256mGL00pXlDnVqsgyqLmL6Jt1mL5qDjZd!2128758255!-1136457793?proceeding=RM-11769 (http://apps.fcc.gov/ecfs/comment_search/execute;ECFSSESSION=2fVLX9HKHMQ2tnJ8CY256mGL00pXlDnVqsgyqLmL6Jt1mL5qDjZd!2128758255!-1136457793?proceeding=RM-11769)

It would be my suggestion that as a group we craft a competent and professional quality response to this proposal. Do that either here in a thread, or via a "sign up" here in a thread, and edited/crafted via email.

Except for one or two of the comments submitted there is not much substance to the objections raised. Opinions are fine, but this is in the end a legal matter, at least to the extent that the FCC makes rules that have the weight of law. I think it would be useful to put together a "slam dunk" comment that whomever amongst us could "sign off" on. I certainly would do so.

What do you folks think?

                   _-_-

(while I suspect that the FCC will summarily reject this petition, they may not...)

I have already responded to the FCC with technical objections so I am out.

I think any response, if fashioned in a reasoned way, is acceptable but certainly responses with technical data and lingo may go further. Just stick to the topic.

Either way, whether it be a group response or an individual response, I would encourage a response; it's your right to exercise it.

Phil - AC0OB

This guy is on serious drugs ! What kind of horse pucky is this? I do not understand why people are constantly screwing with this bandwidth thing.The last thing the FCC wants to deal with is something more to enforce. In my view lets eliminate ALL sub-band mode restrictions. Let the class of license determine where operation takes place. In most other nations Amateur Radio regulations there is no"CW portion or "Phone portion" of each band.In this country, 160 meters is a shining example of that. It works.  Over the last 10 years or so I have noticed a sharp decline in activity on the HF bands. When docket 20777 was proposed in the middle 70s , there was much more activity as well as much less spectrum for voice communications. With the constant changing of operating trends, why impose a restriction of this type .The point of it is totally moot. I have yet to file my comments. I read the petition, The authors phone # is listed. I think I am going to give him a call. I suggest we all call him to express our displeasure and try to get him to withdraw his petition.
Tim WA1HnyLR