I did not want to give the impression that their proposal was not appropriate. I just worry about the chance of passage of several issues by the FCC when they have done practically nothing for amateur radio over the last decade. There is a concern by the narrow band digital users and CW enthusiasts that wide band digital will usurp their spectrum, and it is truly understood. On 80 meters, the digital and CW enthusiasts were dealt a horrible blow when the 75-meter phone band was extended down to 3600 kHz. However, my recollection when there were comments solicited by the FCC on our HF spectrum plan, there were precious few comments by our cw/digital community and most were from Extra class SSB users that didn't want to lose their lower 50 kHz. The digital/cw community came out in droves to negatively comment on our symbol rate issue, though. I remember that our HF band plan would have solved most issues, moving wideband digital and ACDS stations above 3600 and keeping the narrowband digital/CW alone, under 3600. The only casualties would be the Extra Class SSB users that would lose a small amount of spectrum. If Waterman has changed his opinion, that is huge. I want it all also, but the question is feasibility. I think this would be a slam-dunk if there were FCC Commissioners that were hams, as some would understand the issues involved. However, the more parts of this, the more complexity, and the more controversy. As we have seen, it is much easier for them to do nothing. We, of course, could go away from a simple requested task (removal of the symbol rate) and put together a proposal that encompasses all users with multiple parts that would handle several of our petitions that have been ignored. We would look good to our members. We may even be lucky enough to have the FCC consider that we had agreement within the ham community and move it forward. Or it could be completely ignored. As I was thinking of a win-loss chart, I suppose if this symbol rate issue is dropped again, the winners would be the CW/Narrowband Digital/SSB communities as nothing would change. The losers would be Emergency Communications and furtherance of technology in the Amateur Radio Service. Interestingly, I've been told that some iterations of VARA in common use have already exceeded the symbol rate. I must leave that discussion to someone more technical minded. So, I'm not trying to be argumentative, just want to state my opinions and concerns. I remember my Director, Dennis Bodson W4PWF (SK) asking why we had a symbol rate limitation anyway at the 2013 2nd board meeting which led to him seconding a motion to abolish it, so I might just be a bit closer to this issue. Thanks to all for your tolerance. '73 de Jim N2ZZ Director - Roanoke Division Representing ARRL members in North Carolina, South Carolina, Virginia and West Virginia ARRL - the national association for Amateur Radio Facebook Page: ARRL Roanoke Division Website: www.arrl-roanoke.org<http://www.arrl-roanoke.org/> [Text, logo Description automatically generated] From: Famiglio, Bob, K3RF (Dir, AD) <k3rf@arrl.org> Sent: Monday, July 17, 2023 3:18 PM To: Boehner, James, N2ZZ (Dir, RK) <n2zz@arrl.org>; arrl-odv@reflector.arrl.org <arrl-odv@arrl.org> Cc: Famiglio, Bob, K3RF (Dir, AD) <k3rf@arrl.org> Subject: RE: [arrl-odv:34989] Nrw filing today in reference to the bandwdth proceedings pending for years. I know we have been through this. And I thought we agreed with such a plan to have legal restrictions by sub band definitions by motion in 2019. I just got off the phone with the filer, AB2RA, a constituent, who asked me to call her. Polite discussion-she seemed well informed. Long-time ARRL member. She claims she was with the group ARRL met with in DC a few years ago. This is not Ted Rappaport and his followers. Ted, who I knew personally from Radio Club of America meetings and seminars seems to be out of action somewhere these days anyway. He called me to rant a time or two a few years ago that no wideband and/or automatic digital should be allowed anywhere outside the phone bands. Our position was a pretty reasonable middle ground. This group of participants claim they agree with our band plan committee conclusions and the 2019 board motion on the subject and wanted to know why we did not implement it. More importantly, Waterman and Lor Kutchens does now as well, as the caller told me as she spoke with Waterman. Could this be true or are they fabricating facts? It appears our board motion of July 2019, a great solution, agrees with their position, so I am now pressed to understand the different in the older arguments. If what they now claim today is true, then this may be something worth discussing. I recall how contentious this was and the meetings held back then resulted in an impasse. Eliminating the symbol rate without limitations and without restriction of greater than 500 Hz occupied bandwidth signals to a required sub-band is a recipe for trouble as few hams wanted that, members or not. We have always recognized this. But a Gentlemen's (and Ladies') agreement really do not help in today's amateur environment. A single controlled or automatic winlink or other mode 2.8 KHz station with lots of traffic setting up shop anywhere and outside agreed limits will ruin operations for many weak signal hams-digital modes or CW. This may end up like repeaters on a limited space ham band where the channels are full like we have on 2 meters in the Philly tristate area and I-95 corridor in 4 states. Lots of conflict with cochannel repeaters ignoring coordination and also gentleman's band planning to keep simplex channels clear and not use VHF SSB portions with FM because they can have no other channel to use. Ask Riley Hollingsworth about that boiling issue. He spent 5 hours visiting me in my office last month discussing some such serious enforcement issues ending up on his desk (and fCC) and for which parties (clubs) had contacted me in frustration as well. Back to HF, removal of restrictions then waiting 5 to 10 years to regulate by bandwidth after allowing 2.8 KHz bandwidth anywhere for additional rulemaking requests to go into effect will create major headaches. No restriction proponents in the US will never go back to a wide bandwidth and auto control sub band after many years of no restrictions. And the rest of the world does not equal the large number of active hams we have here that will be running their own mailbox servers wherever they can find room. Look at the CW vs phone bands here. SSB, the choice of newer hams other than FT-8 would likely be used all the way to the lower edge of the band on busy days with good propagation if it was only an unenforceable agreement and not the law. This may be an opportunity. Maybe we need to review the positions again. What am I missing in their filing? It seems persuasive if the representations therein are true. Are they accurate? Maybe this is not an opportunity, but I do not yet see why. Bob Famiglio, K3RF, 610-359-7300 ARRL Atlantic Division Director www.QRZ.com/db/K3RF<http://www.QRZ.com/db/K3RF> From: Boehner, James, N2ZZ (Dir, RK) <n2zz@arrl.org<mailto:n2zz@arrl.org>> Sent: Monday, July 17, 2023 2:16 PM To: Famiglio, Bob, K3RF (Dir, AD) <k3rf@arrl.org<mailto:k3rf@arrl.org>>; arrl-odv@reflector.arrl.org<mailto:arrl-odv@reflector.arrl.org> <arrl-odv@arrl.org<mailto:arrl-odv@arrl.org>> Subject: RE: [arrl-odv:34989] Nrw filing today in reference to the bandwdth proceedings pending for years. I usually do not respond to issues like this, but there is a pattern. We have asked the FCC for relief by removing the 300-symbol rate, as we did 10 years ago. We feel it is reasonable to apply a 2.8 kHz bandwidth limit as well, although the FCC did not agree with this in the past. From my recollection, they did not want this, as they did not want to revisit this issue in the future should our needs change again. There was controversy within the amateur radio community comments about removing the symbol rate at all. We were reminded that we only represent 20% of hams. FCC decided to do nothing. STA's are much safer for them. Now we have several state EMD's writing to the FCC chair with their support for removal of the symbol rate. Texas SWIC sends letter as well. This restriction is not in place anywhere else in the world. We actually have a slim chance that the FCC will finally do something. Next comes this filing from the group below. They want an immediate and long-lasting solution. Good thought, but bad in execution. There has been controversy in all our filings. We may have beat down the symbol rate controversy somewhat, but we haven't had universal approval with our HF band planning proposal. I remember on a phone call with Steve Waterman he stated that "it would not work". I didn't get details, as I was already 2 hours in on that call. The situation is that we need to focus on the symbol rate removal, and once done, to hit our HF band planning hard. Another survey if necessary. The impact of the proposal below will serve only to confuse, add controversy and in the end, for the FCC to do nothing, as the FCC will conclude that hams just can't get their act together. Just my humble opinion. '73 de Jim N2ZZ Director - Roanoke Division Representing ARRL members in North Carolina, South Carolina, Virginia and West Virginia ARRL - the national association for Amateur Radio Facebook Page: ARRL Roanoke Division Website: www.arrl-roanoke.org<http://www.arrl-roanoke.org/> [Text, logo Description automatically generated] From: arrl-odv <arrl-odv-bounces@reflector.arrl.org<mailto:arrl-odv-bounces@reflector.arrl.org>> On Behalf Of Famiglio, Bob, K3RF (Dir, AD) Sent: Monday, July 17, 2023 12:27 PM To: arrl-odv@reflector.arrl.org<mailto:arrl-odv@reflector.arrl.org> <arrl-odv@arrl.org<mailto:arrl-odv@arrl.org>> Subject: [arrl-odv:34989] Nrw filing today in reference to the bandwdth proceedings pending for years. I was alerted to this new FCC filing regarding the bandwidth proceedings. One of the filers, Janis AB2RA, is an active Atlantic division constituent and sent me this link today and wants to discuss it with me. It makes an interesting read. https://www.fcc.gov/ecfs/document/107151170924997/1 Bob K3RF
