ARLA/CLUSTER: Associação americana faz petição à FCC para que designe subbandas SÓ para CW como 'symbol communication'

[João Costa > CT1FBF]

Missouri radio amateur petitions FCC to designate 'symbol
communication' subbands

James E. Whedbee, N0ECN, of Gladstone, Missouri, has petitioned the
FCC to designate Morse (radiotelegraphy) Amateur Radio band segments
as 'symbol communication' subbands.

The FCC has invited comments on his Petition for Rule Making
(RM-11769), filed on May 2. Arguing that retaining the current regime
of "legacy" CW subbands has proven to be grossly inefficient, Whedbee
said he'd like to see the FCC delete all privilege restrictions that
limit any part of the Amateur Radio spectrum to Morse code to the
exclusion of other modes.

RM-11769 can be found on the web at,
http://apps.fcc.gov/ecfs/comment/view?id=60001692464 .

"Nostalgia for retention of Morse code telegraphy-only subbands is
also an insufficient reason to avoid moving forward to [the]
elimination of such subbands, because nothing about this Petition
suggests the elimination of the mode itself, only that it not be the
sole authorized mode in the subject subbands," Whedbee told the FCC.

Whedbee characterized CW-only subbands as "an excessive regulatory
constraint, as well as a poor use of the spectrum concerned."
He proposed that the FCC's Part 97 rules reflect the "ultimate form of
communication reproduced at the receiving end." As he explained it,
his regulatory scheme would break down modes into three categories -
"symbol communication mode" - for CW, digital, and other emission
modes that reproduce a discrete symbol on the receiving end - "voice
mode," and "image mode."

"[C]ontinuing regulation by specific emission designator is proving to
be onerous with changes to the state of the art," Whedbee said.
"Accordingly, to continue developing the state of the art in
radiocommunications, Amateur Radio needs to clearly get away from
regulating in that fashion and return to consideration of what the
receiving end of the communication reproduces."

He proposed that where the Part 97 rules refer to exclusive
radiotelegraphy allocations - or subbands - privileges be changed to
reflect symbol communication modes. Where the rules prohibit voice and
image modes, he would revise the rules to reflect symbol communication
modes. In situations where current rules prohibit symbol communication
modes other than Morse, that voice and image modes would be permitted,
"with an exception for manually keyed" radiotelegraphy.

For example, he would drop the distinction between 75 meters and 80
meters, authorizing symbol communication modes between 3.5 MHz and
3.65 MHz, and voice and image modes between 3.65 MHz and 4 MHz, with
manual radiotelegraphy authorized throughout the band.

Whedbee told the FCC that, if his Petition is accepted for filing and
put on public notice, he would submit an appendix spelling out
proposed service rules as part of his Petition.

Commenters have 30 days to respond