RM-11306 Blatant Anti-AM Comments

[W3NP]

Below is the second comment that W4VR has filed with the FCC. I didn't see anything on the FCC info portion that indicated that this was an additional comment.

Paul K2ORC...your tally would show this as adding to the "against" column the second time....wouldn't it?
This rant was posted on 01/13.

The "bolding" of some of the text was done by me.

W4VR's second comment:

"Additional comments. In the comments I recently filed in this proceeding I stated that AM operators
should abide by the ARRL Band Plan and not conduct their operations on the entire phone band due
to bandwidth incompatibility problems with SSB. I understand that this plan sets calling frequencies
as opposed to frequency segments. I also understand that due to the small number of operators
using AM, and by Gentlemen's Agreement, these AM operations generally refrain from operating
anywhere in the phone band and stay within a few kHz of the band plan calling frequencies to avoid
disrupting SSB communications in other parts of the band. This gentlemen's agreement has worked
well for many years, but many operators recently have deviated from this agreement and have
proceeded to create a tremendous amount of interference to SSB operations throughout the phone
bands. In this regard, the 9 kHz bandwidth the ARRL proposes for these operations is much too
generous and should be reduced by half. A 4.5 kHz bandwidth could be accomodated by transmitting
only one sideband with carrier (A3H) with no degradation in quality of the received signal. In fact, a
fraction of the transmitter power would be required to produce the same results as Double Sideband
AM. It is a well known fact that some amateur SSB transmitters are already capable of transmitting
A3H. The issue here is spectrum conservation while being able to share the band with modes that
are bandwidth compatible with each other. Should the FCC go along with the ARRL proposal to limit
AM transmissions to 9 kHz bandwidth, then the FCC should set aside a segment on each band for
such operations to reduce the impact on SSB operations in other parts of the band."

Here is his first comment that he filed on 01/11:

The ARRL bandwidth proposal appears workable with one exception, allowing double sideband AM 9
kHz. SSB was created to conserve spectrum and allow more stations to operate in a given
bandwidth. AM stations were allowed to operate in certain segments of each band in accordance
with the ARRL voluntary band plan to reduce destructive interference to SSB stations. In recent
years some of these AM stations have chosen to violate the band plan and operate anywhere in the
phone bands, creating harmful interference to SSB operations (this is particularly evident on the 80
meter band). If the FCC is to allow 9 kHz for these stations, rules should be implemented to restrict
these stations to a 4.5 kHz bandwidth (SSB AM) if they do not abide by the ARRL band plan.

[Glenn NY4NC]

That statement reeks of ignorance 

AM operators should abide by the ARRL Band Plan and not conduct their operations on the entire phone band due
to bandwidth incompatibility problems with SSB.

[Paul, K2ORC]

Dave W3NP wrote

Paul K2ORC...your tally would show this as adding to the "against" column the second time....wouldn't it?

Hi Dave,
The comment period on 11306 and 11305 is going to bring a few characters out of the woodwork and if past PRM comment periods are any indication, some of these people will try to "stuff" the ballot box. 

As for W4VR, I did not count his second comment as an additional "against" vote in the tally here.  I read each of the comments on the ECFS board and am trying to make sure that duplicative comments won't be counted. 

As the number of comments increases, this is going to become difficult, but I will try to keep the tally as accurate as I can.   
Paul K2ORC

[John Holotko]

That statement reeks of ignorance 

AM operators should abide by the ARRL Band Plan and not conduct their operations on the entire phone band due
to bandwidth incompatibility problems with SSB.

Well if he wants to play a tit for tat  game one could  also state the reverse argument that sideband is destructive to AM, especially when SSB'ers continue to operate right on top of or as close as they can get  to an AM QSO is the so called "am window".

[KA1ZGC]

Let the guy piss and moan all he wants. He doesn't understand that it doesn't make any difference whatsoever.

The comments process is there to allow interested parties to issue comments in support or in opposition to rulemaking proposals, not to make amendments to them. Unless you pack technical or bureaucratic clout (like the NTIA did for the 60-meter allocation), it is unlikely your comments are going to count for much more than a "yes" or "no" vote.

The fact that he wasted "additional comments" on further editorializing (like coming back two days later screaming "and another thing") won't impress anyone at the FCC any more than it does here, or have any real effect on the outcome.

Besides, it's no secret that the "AM window" is wall-to-wall sideband altogether too routinely.

It can make for some amusing reading, though.

--Thom
Killer Agony One Zipper Got Caught

[WA1GFZ]

slop bucket is in the am window as long as we let them.

may the strap be with you.