ARRL Seeks Input for New IARU Region 2 Band Plan

[WA3VJB]

Nice exchange, Steve.

As long as ARRL people are trotting out the IARU Region 2 Band Plan, they should probably figure out how to settle a contradiction within their own group's published material.

The magazine's web page says:

It would be inappropriate to incorporate Region 2 band plans into the FCC rules, and the ARRL has no plan to petition the FCC to do so.

But the IARU Region 2 Band Plan says:

It is suggested that Member Societies, in coordination with the authorities, incorporate it in their regulations and promote it widely with their radio amateur communities.

[wd8das]

Further response from the ARRL President: 

Hi Steve,
In the USA we are regulated by the FCC's Rules, not by this band plan. The
Region 2 band plan cannot require any licensee in the USA to measure
occupied bandwidth for any mode of operation, because it has no regulatory
force in this country. The Region 2 band plan does not even refer to
measurement of occupied bandwidth. Please don't over-react to the bandwidth
column. It does not obligate American hams to make any technical
measurements and imposes no burden on us. It is information that is desired
by Amateurs in some other countries, and that's all.
73 - Kay N3KN

[wd8das]

My further response to the ARRL President:

- - - - - - -
Kay wrote:

>The Region 2 band plan does not even refer to
>measurement of occupied bandwidth.

What is the point of assigning a maximum bandwidth to the various band
segments if it is not a measured bandwidth?  A parallel example:  A
speed limit sign on the side of the highway is meant to be used in
combination with the speedometer in your car.  If automobiles were not
equipped with speedometers, would speed limit signs be posted?

Assigning a max bandwidth will invariably result in claims that someone
is "wider" than the allowed maximum. Thus my earlier concern about
creating unnecessary stress and contention among amateurs.

>Please don't over-react to the bandwidth column.

Does the ARRL want my feedback, or not?  In your first email reply you
seemed to be trying to convince me I'm wrong, and now you are
suggesting that I am "over-reacting" and shouldn't worry.   Why do you
feel to you have "defend" the IARU Region 2 bandplan and argue in
support of the present plan?  I thought it was open to discussion.

> It does not obligate American hams

If the IARU Region 2 bandplan means nothing to American hams, why, in
fact, is the ARRL even working on it?  Why ask members for their
feedback on the bandplan?  It is the *American* Radio Relay League,
after all.   If, on the other hand, the ARRL has a significant play in
the Region 2 bandplan, then as a member of the League I would think
that my views would be welcomed - not rejected out of hand as wrong.

Steve WD8DAS

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Radio is your best entertainment value.
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[W3SLK]

Like I said over on the other medium Steve, they are nothing more than a bunch of ego-ists, parading about stating their self-importance by attending a 'hemispherical meeting'.

[Pete, WA2CWA]

Nice exchange, Steve.

As long as ARRL people are trotting out the IARU Region 2 Band Plan, they should probably figure out how to settle a contradiction within their own group's published material.

The magazine's web page says:

It would be inappropriate to incorporate Region 2 band plans into the FCC rules, and the ARRL has no plan to petition the FCC to do so.

But the IARU Region 2 Band Plan says:

It is suggested that Member Societies, in coordination with the authorities, incorporate it in their regulations and promote it widely with their radio amateur communities.

suggested -  "To offer for consideration or action; propose"
And, the ARRL says - " has no plan to petition the FCC to do so"

Seems clear, reasonable, and to the point.

Of course, you may want to petition all the other member countries in Region 2 to see how much of the current Region 2 band plan they already follow or plan to follow. You might also want to review the amateur rules and regulations of another Region 2 country (Bermuda). You probably wouldn't have much fun operating AM there without major equipment mods.

[W3SLK]

Pete said:

And, the ARRL says - " has no plan to petition the FCC to do so"

Then why even participate?? 

[wb4iuy]

Conversely, check out this post from over on the DigitalRadio forum due to a bunch of noise about some digital mode being limited due to bandwidth issues and not being documented as a legal mode:

> Following the recent discussions about the US license restrictions I
> was looking through the archive of QST mags at www.arrl.org
>
> On April 22, 1976 the FCC introduced Docket 20777, the QST report
> (page June 1976) says
>
> "Rather than further complicate the present rules," the Commission
> said, "with additional provisions to accomodate the petitioners'
> requests, we are herein proposing to delete all references to specific
> emission types in Part 97 of the Rules. "We propose, instead," the
> Commission continued, "to replace the present provisions with
> limitations on the permissible bandwidth which an amateur signal may
> occupy in the various amateur frequency bands. Within the authorised
> limitations any emission would be permitted."
>
> It would seem that deletion of emission types from Part 97 is exactly
> what is needed now to permit experimentation. Perhaps the FCC should
> be asked to re-introduce Docket 20777
>
> Trevor

[Pete, WA2CWA]

Pete said:

And, the ARRL says - " has no plan to petition the FCC to do so"

Then why even participate?? 

Duh! They're a member of the IARU. And, would you really want the the IARU to set International suggested guidelines/band plans, etc. without their participation.

[k4kyv]

> "Rather than further complicate the present rules," the Commission
> said, "with additional provisions to accomodate the petitioners'
> requests, we are herein proposing to delete all references to specific
> emission types in Part 97 of the Rules. "We propose, instead," the
> Commission continued, "to replace the present provisions with
> limitations on the permissible bandwidth which an amateur signal may
> occupy in the various amateur frequency bands. Within the authorised
> limitations any emission would be permitted."
>
> It would seem that deletion of emission types from Part 97 is exactly
> what is needed now to permit experimentation. Perhaps the FCC should
> be asked to re-introduce Docket 20777
>
> Trevor

The problem, like with the ARRL bandwidth proposal, is that it's a one-size-fits-all approach.  Like the present power limit bullshit.

20777 was touted by the FCC as "deregulation" (that word was in the title of the docket notice), but it would have outlawed AM on all amateur frequencies below 28 mHz, as well fast-scan TV in the 420-450 mHz band. George Orwell would have been proud.

There is be no need to eliminate or impose new restrictions on legacy modes, or to mandate specific enumerated bandwidth limits, in order to accommodate emission types not specifically provided for.  "Further complicating" the rules could be avoided by adding a simple footnote to the existing emissions tables that, "in addition to the emission types listed above, operators may transmit unspecified emission types whose necessary bandwidths do not exceed those of the specific emission types listed".

It was reported that Johnny Johnston "could not understand" why there was so much opposition to Docket 20777. He was quoted as P&M'ing at a radio club meeting or hamfest forum, "We had a good proposal. It was shot down by a few hams who want to keep on using the same transmitters they have had for 25 years".

[Steve - WB3HUZ]

In a word, yes. The ARRL is zero value added to the process.

Pete said:

And, the ARRL says - " has no plan to petition the FCC to do so"

Then why even participate?? 

Duh! They're a member of the IARU. And, would you really want the the IARU to set International suggested guidelines/band plans, etc. without their participation.

[W3SLK]

Pete said:

Duh! They're a member of the IARU. And, would you really want the the IARU to set International suggested guidelines/band plans, etc. without their participation.

Duh! Why waste the time if anything you do has no relevance to your country? Duh!

[Fred k2dx]

Since when did the ARRL ever give a flying rat's ass about what we think?

Sure, occasionally they go through the motions but the decision(s) have already been made. The latest great example being the proposed FM narrowbanding debacle. That should be a goldmine to the manufacturers/QST advertisers. There wasn't any input solicited from the knowlegable ARRL members and/or repeater sponsors. Repeater sponsors have a significant investment in both money and time with their repeaters. I know of one high profile repeater that will not be forced to change over and split its clear frequency so some little person can put an unused flea bag garage repeater on thanks to ARRL.

 I'm a dues paying member - since 1967 - as well as a repeater sponsor so I feel I have the right to complain. They can all go to hades as far as I'm concerned.

Kay Craigie is a woman climbing the ladder and hasn't a clue!  She ought to be saving the whales or something.

Newington seems to be following the lead of Washington, DC.

[Ed/KB1HYS]

The problem with listening to the consituents is that there is no money in it.
Washington, Newington, doesn't matter, same problem same effect. 

[Fred k2dx]

Within the past several days I heard the statement to the effect of: "They don't govern, they rule." It was directed at current politicians but seems to be equally applicable to the ARRL.

[W3SLK]

Fred said:

Since when did the ARRL ever give a flying rat's ass about what we think?

Now that speaks volumes!

[Opcom]

I'll read it tomorrow at work, and probably respond to it. If it's like most of the crap going on these days, it's going to favor the digital modes and give short shrift to the traditional modes. Especially AM.

We just got a request to respond to a survey here in TX wanting to know how we felt about them taking away some of the simplex 2 meter freqs to give them to D-STAR. If they keep track of the call sign, email address and phone numbers that they said were optional, but I gave them anyway, I'm probably not welcome at any of the TX VHF Society meetings. I explained that D-STAR completely ignores the amateur history of being totally independent of any infrastructure and instead depends on a very fragile infrastructure -- the Internet -- and pointed out what happened in Silicon Valley CA. Then I pointed out that D-STAR is outrageously over-priced and eliminates most hams from its over-rated system.

We've been dealing with a big push here in TX for D-STAR, and the more they push, the more I push back. I refuse to be ramrodded into some new digital mode that's dependent on the Internet, just because it's stylish. The old ham ways, depending only on ourselves, have worked well for a very long time. Why change them just because some eejit came up with a new digital mode?

</ anti-digital rant>

73,
ldb
K5WLF

Things that are supposed to be unbiquitous, yet add vulnerability layers to critical mission functions, are not looked well upon as primary resources.

Maybe if the 'powers that be' kill off enough analog repeaters, they think to drive/force users to the obtuse digital standard and thereby generate revenue on the backs of the communicators.

The main complaint about stealing slots from established repeaters.  In some areas, like Dallas, the place is flush with them, but eacxh group has as much right to the slots as anyone else. And how will it be decided which ones get axed in favor of the D-Star system? Follow the money..

I smell silicon and money boiling in a cauldron of snake oil.

A few years ago, it was the winlink2000/pactor III thing.
How heavily the advertising dollars did flow, from that patentholder and its technology licencees to the ARRL in those days.. 
The ham 'community' opposition to letting the robots fire up anywhere on the band made itself known to the FCC. The FCC did listen, and has ruled "no" to what the ARRL has pushed in the past.

As for the segregate -by-bandwidth issue, that was fought before and defeated. Maybe it is different now, but I would like to see AM requirements protected. A comment citing non-ignorable sources as to necessary bandwidth was used last time. In the end the FCC ruled that no changes to the rules were needed for bandwidth. The ARRL also ignores several modes in their previous comments. I realize this time is somewhat different but the arguments against statutory bandwidth limitations still hold.

History can repeat. The ham 'community' should make comments to the FCC and explain why any or all of it is a bad idea from many standpoints:
- pushed by money interests,
- not what the majority want,
- techncial issues,
- user cost burden,
- multiple points of failure,
- national security risk (Ur interwebz is downz, sir or madam! Pleez calls ur supurt teem in bombai.),
- general risk to the rules (hacking, criminals using the system to transmit data, etc),
- rights or desire of the repeater owners (clubs etc) to keep their slots,
- ease of continuing public service that is -inclusive- to all

The best effect might be for any commenter to make a separate comment for each "change" they do not like.

comment 1. D-star issues
comment 2. segregation by bandwidth
comment 3. imposed bandwidth limits
comment 4. ?

does the spectre of abolished modes appear again? ARRL wanted to do away with ISB before.

I hate this kind of mess. Sorry.

[WA3VJB]

TO: Band Planning Panel:

Vice President Rick Roderick - K5UR Chair
Director Tom Frenaye - K1KI
Director Dick Norton - N6AA
Mr. Steve Ford - WB8IMY
Mr. Chuck Skolaut - K0BOG
-----------
RESPONSE TO INVITATION FOR INPUT as part of the XVII Session of the IARU Region 2 General Assembly, taking place in Salinitas, Sonsonate, El Salvador from October 4 to 8, 2010.

\\\

As you repair and improve the IARU Region 2 Band Plan, please directly address and specifically accommodate the mode of AM in the layout of activities throughout HF.

For discussion, I offer a brief review of what contributed to the problems caused at a previous conference in Brazil by your former employee Paul Rinaldo when he unilaterally, and without published Board authority, recommended adding enumerated bandwidths to the voluntary IARU Region 2 plan during discussions at the time.

Let me start by succinctly recommending that you:

Remove from the Region 2 band plan the enumerated bandwidth specification for the mode of AM in all portions of the Amateur spectrum where phone activity is authorized.

Reference:
http://www.iaru-r2.org/wp-content/uploads/region-2-mf-hf-bandplan-e.pdf

This simple change would make the Region 2 plan consistent with the Region 1 plan, where those involved in a recent review accepted the premise that AM need not be constrained in ways where no problem has been found to exist.

Reference:
http://www.iaru-r2.org/wp-content/uploads/region-1-hf-bandplan-2006.pdf

Furthermore, the change would be consistent with wording in the Region 3 plan, which is mute against imposing any bandwidth specification on AM activity.

Reference:

http://www.iaru-r2.org/wp-content/uploads/region-3-hf-bandplan.pdf

Removing specific bandwidth parameters against AM now contained in Region 2's band plan would also make the U.S. position at the IARU (as expressed by the ARRL) consistent with the open, unspecified posture on AM bandwidth that the FCC has long maintained in Part 97.

It is important to note more broadly that the concept of segregation-by-bandwidth has been discredited among active, concerned U.S. licensees, as seen in the FCC's public record during the ARRL's failed Petition in the same matter to that federal regulatory agency.

Popular sentiment in that proceeding ran strongly opposed to this proposed substitute for the longstanding and accepted system of organizing activities on HF by a simple, broadbased reference to mode. It is widely known that Rinaldo was the architect and prime antagonist pushing the contrary proposal to use bandwidth as a means of coordinating the layout of modes and activities.

In addition, ARRL CEO Dave Sumner acknowledged before the petition was filed that sentiment among members ran against the idea.

The ARRL's attorney wisely abandoned the Petition and withdrew it before the FCC could consider the arguments arrayed against it. It was thus entirely inappropriate for Rinaldo to, soon after, apparently try to step around that expressed opposition and achieve a version of such segregation at the IARU regional conference that covers all U.S. licensees.

You today are to be commended for soliciting input from those of us affected by his actions, and for now having expressed a willingness to repair the damage he has caused.

Another (related) change I ask you to consider is to remove or seek exemption from the wording in the Region 2 Charter that calls on the ARRL to actively promote implementation by government regulators the prevailing IARU Region 2 voluntary band plan.

That wording today states:

"It is suggested that Member Societies, in coordination with the authorities, incorporate it in their regulations and promote it widely with their radio amateur communities."

(Source: http://www.iaru-r2.org/band-plan/)

There have been several statements made recently by League officials that the ARRL has no intention of seeking the force of law in having the FCC incorporate into Part 97 any elements of the IARU Band Plan.

That may be true, but as the representative Member Society, you are compelled by "suggestion" to support the wording the IARU has specified above, unless you take steps to the contrary. Otherwise, why have the wording in there, right?

In the prior regional conference in Brazil, given Rinaldo's intransigent behavior, this wording was perceived by many in the AM community to be a way for him to step around his defeated Petition at the FCC, and further his onetime agenda to segregate activities by bandwidth to the severe detriment of popular AM activity.

In summary, your challenge is to reassure those of us who have been shortchanged by his misguided actions to now fix the problems he caused when he encouraged the Region 2 delegates to put enumerated bandwidth on the books against AM.

In conjunction with those repairs, you have the opportunity to state on the record that the IARU's advocacy (in the wording above) is intended to apply only to the regulators of licensees in countries where there is no prevailing guidance in the law as to how activities are arrayed in spectrum allocated to radio hobbyists.

I am available to further discuss by conference call or with any of your individual representatives.

Should you need specific details about AM activity, please see http://amfone.net.  With more than 3,000 registered participants, please note that our part of the hobby is larger than many other activities and modes that are acknowledged in these regional band plans.

Please give consideration accordingly.

Thank you,

[AA4HA]

I shot this off to the band planning committee.
---------------------
To the ARRL Band Planning Committee,

Subject: 600 meter, 500 KHz frequency allocation.

I wish to encourage the expansion of amateur radio participation in the 495-499 KHz and 501-510 KHz portion of the spectrum to authorized licensees on a secondary basis. The limitations set forth under GMRR M09-1C as prepared by Fritz Raab, W1FR on 1 January, 2010 are acceptable and geographic set-aside frequencies to protect the non-directional beacons should be incorporated into the bandplan.

Modes of operation should be restricted to 150HA1A (CW or QRSS), 62H0J2B, 62H0F1B and 62H0G1D (PSK-31, FSK-31 and MSK-31). Power should be limited to 20 Watts ERP and no contesting should be allowed anywhere in the 600 meter band.

I believe that such an allocation will encourage the experimental nature of amateur radio and provide a new challenge for low power operations.

Sincerely,
Ms. Tisha Hayes/ AA4HA
-------------------------

[k4kyv]

Here's mine:

I suggest that the Region 2 Band Plan be changed to align with the Region 1
Band Plan, regarding AM phone. At present, in the Region 2 Plan has several
small segments marked with an asterisk (*) indicating  "DSB AM phone allowed
in this segment with a maximum bandwidth of 6 kHz."  This does not include
many of the frequencies presently used by AM operators in North America.
There is no prevision whatever for AM operation in the 160 metre band.

I suggest the footnote with the asterisk be deleted, and replaced with a
provision identical with the one in the Region 1 Band Plan, to read as
follows, to apply to ALL voice frequencies: "Amplitude modulation (AM) may
be used in the telephony sub-bands providing consideration is given to
adjacent channel users. (NRRL Davos 05)."


Donald Chester, k4kyv

[Pete, WA2CWA]

I hope everyone took note of this from the link in the initial post:
"The deadline line set by Region 2 for gathering input and formulating recommendations is rather short. Amateurs who would like to submit input should take the following steps:

    * First, study the existing IARU Region 2 band plan posted on the Region 2 Web site. The Region 1 and Region 3 band plans are also posted there, so be sure you are looking at the band plan for Region 2.
    * Next, formulate a clear statement of any change you propose. Include a brief explanation of why you think the change would be beneficial. Please include your name and call sign in your input.
    * Finally, send your input via e-mail no later than April 5, 2010. Messages will be automatically acknowledged."

[W3SLK]

Once again the (be)League(d) demonstrates how well it likes to screw us. 

[Pete, WA2CWA]

TO: Band Planning Panel:

Vice President Rick Roderick - K5UR Chair
Director Tom Frenaye - K1KI
Director Dick Norton - N6AA
Mr. Steve Ford - WB8IMY
Mr. Chuck Skolaut - K0BOG
-----------
RESPONSE TO INVITATION FOR INPUT as part of the XVII Session of the IARU Region 2 General Assembly, taking place in Salinitas, Sonsonate, El Salvador from October 4 to 8, 2010.

\\\

As you repair and improve the IARU Region 2 Band Plan, please directly address and specifically accommodate the mode of AM in the layout of activities throughout HF.

For discussion, I offer a brief review of what contributed to the problems caused at a previous conference in Brazil by your former employee Paul Rinaldo when he unilaterally, and without published Board authority, recommended adding enumerated bandwidths to the voluntary IARU Region 2 plan during discussions at the time.

Let me start by succinctly recommending that you:

Remove from the Region 2 band plan the enumerated bandwidth specification for the mode of AM in all portions of the Amateur spectrum where phone activity is authorized.

Reference:
http://www.iaru-r2.org/wp-content/uploads/region-2-mf-hf-bandplan-e.pdf

This simple change would make the Region 2 plan consistent with the Region 1 plan, where those involved in a recent review accepted the premise that AM need not be constrained in ways where no problem has been found to exist.

Reference:
http://www.iaru-r2.org/wp-content/uploads/region-1-hf-bandplan-2006.pdf

Furthermore, the change would be consistent with wording in the Region 3 plan, which is mute against imposing any bandwidth specification on AM activity.

Reference:

http://www.iaru-r2.org/wp-content/uploads/region-3-hf-bandplan.pdf

New IARU Region 1 band plan became effective March 29, 2010
See:  http://www.iaru-r1.org/index.php?option=com_remository&Itemid=173&func=download&id=67&chk=4f93e680045681b4344d9f5c64a1fca5&no_html=1

In their(Region 1) band plan, they identify Frequency - Max. Bandwidth - Preferred Mode
In frequency ranges where Phone and CW are allowed together, the Preferred Mode Column lists "All Modes". If you scroll down to "Definitions" - "All Modes" - CW, SSB, and those modes listed as Centres of Activity, plus AM (Consideration should be given to adjacent channel users).

Seems to me, they have AM covered here.

In the Region 3 band plan, "Phone" is listed throughout the various HF band segments. One should agree the both SSB and AM are considered "Phone" modes. If you scroll down to the "Legends" - "Phone" - Phone operation includes SSTV, FAX and modes with similar bandwidth not exceeding 2 kHz.

Looks like AM, for what it's worth, is covered here.

Removing specific bandwidth parameters against AM now contained in Region 2's band plan would also make the U.S. position at the IARU (as expressed by the ARRL) consistent with the open, unspecified posture on AM bandwidth that the FCC has long maintained in Part 97.

If maximum bandwidths are going to be retained for other modes in the Region 2 band plan, why should they remove them just for the AM mode? Makes no sense.

It is important to note more broadly that the concept of segregation-by-bandwidth has been discredited among active, concerned U.S. licensees, as seen in the FCC's public record during the ARRL's failed Petition in the same matter to that federal regulatory agency.

Wasn't the only petition(no bandwidth limitations - anarchy across all bands) that was discredited by concerned U.S. licensees. How quickly one tries to bury a boondoggle revolution.

[Opcom]

In addition to sending my comments on the Region 2 bandplan to the feedback email address provided, I also wrote directly to League officials.  This afternoon I received a reply from the President, Kay N3KN.
 
- - - - - - - -
Thank you for your comments. The Region 2 band plan accommodates DSB AM operation. For example, if you look at the segment 7100 - 7130, you will see a asterisk by the 2700 bandwidth. Then scroll to the bottom of the entire chart to find the reference for that asterisk, which says, "DSB AM allowed in this segment with a maximum bandwidth of 6 kHz."
 
 

6KHZ for AM? That is going to sound like someone talking behind a carpet, not to mention be difficult to understand with noise and deliberate interference from SSB operators. Dang it the ARRL is at it again. I suppose the ARRL is going to send me a free spectum analyzer so I can measure this? I will need one to pass the time tinkering because there won't be much point in putting the rig on the air orlistening in to youse guys till my tower is up.

They are going to have to be taught from Terman, George Sterling, and others that cannot be disputed. Again. I guess they forgot. Thre will also be a few who will go along with it by means of all kinds of schemes, such as an audio filter at the microphone as one inglorious buffoon suggested be forced upon communicators, does not limit transmitted bandwidth as an absolute, but the fellow probably does not know anything about audio processing and by that I don't mean the fancy stuff either.

I wonder if this is a prelude to channelization or just the usual "screw AM, screw your old and somewhat wide SSB military radios, and screw you too" attitude. I am not going to "buy more, now!", just to please these folks and their advertisers. Bandwidth-limiting proposals were tried before and shot down once the public got wind of it. Logic and reasons.

Make your comments to the FCC

Previously certain people, tried to get the FCC to regulate bandwidth to +/-2.8KC. and some others to +/-3KC. If the present attempt is not an outright attack on A3E as well as B8E and B9E, is a shallow attempt to "throw us a bone". I prefer the meat. I will take the meat away from that dog.

The following is from a comment of mine last time this bandwidth crap happened and contains quotes from professional literature representing the state of the art of voice communication in the past. Technology has evolved, but the human ear's requirements have not. I cite the examples of what is necessary for high quality voice communication as compared to "understandable" and "minimum", and ask what the technical reasons are for this and why other modes are not proposed to be restrictied to their own minimum performance, and call the reader to notice who has written these things, esecially since the one that was written by the head of the FCC indicates that more audio range is necessary for high quality voice communications, and F.E. Termans states the minimum for the quality of a 1947 long distance telephone line. Yeah IIRC people had to often ask for things to be repeated and to speak up with even those "high quality" voice communications.

Why the ARRL comes up with arbitrary nonsense figures is beyond me. Is there no one to teach them? Have they no books written by scientists and engineers? Only their own handbook in which they can write what they think is right? Mebby they don't want any more money from me nor do their advertisers.

Dear FCC,

I wish to comment, briefly, upon what is considered
to be appropriate AM communications practice for
good intelligibility.

I am sure there is a happy medium in all this, but it
is not necessarily below an enforced +/-3KHz and
certainly nowhere as low as +/-2.8KHz.

In light of the knowledge quoted below, which represents the
highest state of the art in classical AM comunications
practice, I ask that the FCC not impose statutory
limits on the bandwidth of AM signals. The gentlemans'
agreements and the voluntary limitations of AM modulating
audio frequnecies to what is necessary are enough. No statutotry
limits are called for, nor are they desirable.

I respectfully quote from these long recognized sources of
learned wisdom in the matter of AM communications systems:

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

"Understandable speech requires the reproduction of all
frequencies from about 250 to 2700 cycles, or sideband
frequencies ranging from 250 to 2700 cycles above and
below the carrier frequency."

FROM:  "RADIO ENGINEERING", second edition, 1937, chapter 9,
section 72, page 396, "Waves with Amplitude Modulation",
Frederick Emmons Terman, Sc.D., Professor of Electrical
Engineering, Stanford University.

--Commenters' Note: Mr. Terman's text says 'requires',
therefore this is taken as the minimum requirement for
speech to be 'understandable'. This does not necessarily
imply good communications quality, but merely
'understandability'.

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

"Modulation frequencies Corresponding to Typical Signals
(minimum frequency range that must be met)"

"Long-distance telephone quality.......250-3500 c/s."

FROM:  "RADIO ENGINEERING", third edition, 1947, chapter 9,
section 9-1, page 469, table 9-1 --Modulation frequencies
Corresponding to Typical Signals (minimum frequency range
that must be met)., Frederick Emmons Terman, Sc.D., Professor
of Electrical Engineering and Dean of theSchool of Engineering,
Stanford University. Past president, Institute of Radio Engineers.

--Commenter's note: Please consider the audio quality of long
distance telephone service in 1947.

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

"...For ordinary SSB telephony, M=3000 Hz. .."
"...For high quality SSB Telephony, M=4000Hz. ..."
"...For ordinary DSB telephony, M=6000 Hz. ..."
"...For high quality DSB Telephony, M=8000Hz. ..."

FROM:  "THE RADIO MANUAL", fourth edition, 1950, appendix 5,
page 859, "Table of necessary bandwidths", George E. Sterling,
Commissioner, Federal Communications Commission, and
Robert B. Monroe, Radio Engineer, Columbia Broadcasting
System, D. Van Nostrand Company, Inc. 4th edition, 1950.

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

"Frequencies up to at least 2,500 cycles, and preferrably 3500
cycles, are necessary for good speech intelligibility."

FROM: "RADIO HANDBOOK", fourteenth edition, 1956, chapter 12,
section 12-1, page 225, Editors and Engineers, Ltd., edited by
William I. Orr, W6SAI.

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

"...Mediocre reproduction may be restricted to 100-5000 c/s.,
while many radio receivers are limited to 100-3500c/s. It
should be remembered that the frequency range is taken as
overall, including the loss of sidebands and including the
loudspeaker. Wide frequency range is only comfortable to
the listener so long as other forms of distortion are
negligible."

FROM: "THE RADIOTRON DESIGNER'S HANDBOOK, THIRD EDITION", 1941,
chapter 5, page 32, "frequency distortion", THE RADIOTRON
DESIGNER'S HANDBOOK, THIRD EDITION", F. Langford Smith,
S.SC., Member I.R.E, M. I.R.E., A.M.I.E.E., A.M.I.E

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

At one time the ARRL (RM-11306) tried to get rid of ISB. That failed as well due to any rationale for such ridiculous action.

[k4kyv]

I don't think it is a good idea to directly contact the FCC on this matter, since there has been no NPRN released or petition submitted (that I know of) regarding bandwidth or the status of AM.  With bureaucratic regulators certain things are best left unsaid until the topic is first addressed for discussion by them, lest we inadvertently plant ideas in their heads.

FCC officials may not have recently given a thought to amateur radio modes and bandwidths, but after reading those comments, could think "hey, that might be a good idea.  Let's give it some thought."

IARU is not any kind of official governmental or inter-governmental agency.  It's more like an international version of ARRL, whose members are made up of the national amateur radio societies of participating nations ( ARRL, RSGB, etc).

Many hams confuse the IARU with the ITU.  They are not the same thing.

[Opcom]

Ok, I thought there was a petition, and I failed to find it.