SB QST @ ARL $ARLB016
ARLB016 Missouri Radio Amateur Petitions FCC to Designate "Symbol
Communication" Subbands

ZCZC 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, http://apps.fcc.gov/ecfs/co
ment/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.

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/EX

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