AG16
QST de W1AW  
ARRL Bulletin 16  ARLB016
>From ARRL Headquarters  
Newington CT  May 12, 2016
To all radio amateurs 

SB QST ARL ARLB016
ARLB016 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,
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 to Whedbee's Petition.