Bob Vallio asked me to reply to this member. His letter is atached. Maybe it will be of some help to others of you. Dave K1ZZ -----Original Message----- From: Sumner, Dave, K1ZZ Sent: Wednesday, October 13, 2004 4:44 PM To: 'k6dgw@arrl.net' Cc: Vallio, Bob (Dir, Pacific) Subject: Reply to letter to Bob Vallio Fred C Jensen, K6DGW 670 Old Airport Rd Auburn, CA 95603-9567 Dear Fred: Bob Vallio has forwarded your thoughtful September 4 letter to me and has asked me to reply. First, I am glad that you recognize the need for some changes in the rules. Simply leaving things the way they are and hoping for the best is not a responsible position for us to take as the national organization for Amateur Radio. The present rules were written at a time when virtually all amateur communication was analog. Provisions regarding digital emissions have been grafted on and are an inadequate guide as amateurs explore a wider range of digital possibilities. At present, with a few exceptions, there is no limit to the bandwidth that an amateur digital signal may occupy. The principal exception with regard to HF is that automatically controlled stations operating outside the narrow subbands designated for RTTY or data emissions under automatic control are limited to 500 Hz. Aside from that, the FCC rules permit them to operate anywhere in the CW/RTTY/data subbands, at any bandwidth, as long as the technical characteristics are documented publicly. The rules are also silent with regard to the bandwidth of a digital voice emission. While some amateurs may want to try digital voice similar to DRM (10 kHz bandwidth monaural, 20 kHz stereo), most would look askance at a single amateur station occupying that much of a limited HF resource. So, bandwidth limits are needed. Reasonable people can differ on what the limits should be and how much spectrum should be designated for which bandwidths. Another thing on which reasonable people can differ is how much should be determined by regulation and how much by "good practice" as a subset of the regulations. For example, you are quite right that analog and digital signals are poor co-channel sharing partners. On the other hand, federal regulations cannot be changed very quickly or easily to accommodate changes in operating patterns. The trend toward greater use of digital modes is likely to continue. Subbands are essentially a form of rationing. If subbands are established based on present operating patterns, activities that otherwise would grow in popularity will be starved for spectrum. On the other hand, if they are based on assumptions about future operating patterns they will still be wrong since the assumptions are unlikely to be entirely accurate. One of our self-imposed ground rules for the development of the draft bandwidth petition was that we would not reconsider decisions made by the ARRL Board with regard to "refarming" of the Novice bands, including the phone band expansions proposed at that time (and since proposed by the FCC in its NPRM in WT Docket 04-140). To address your specific questions: 1. This initiative began with the ARRL Board's direction at the July 2002 meeting "that at the next practical opportunity the ARRL shall petition the FCC to revise Part 97 to regulate subbands by signal bandwidth instead of by mode." Input was not limited to the Ad Hoc HF Digital Committee, nor were all of that committee's recommendations reflected in the initial draft that was circulated to the ARRL Board members in January 2004. Other groups are working within the ARRL on different aspects of new technologies, under the umbrella of the Technology Task Force; these include the Digital Voice Working Group and the High-Speed and Multimedia (HSMM) Working Group. 2. The synopsis is not the complete petition. A draft petition does exist, but is the work product of our General Counsel and has not yet been released outside the ARRL Board. However, every rule change contemplated in the draft has been published with the synopsis. 3. Yes. 4. There is no proposal to change the definition of "Phone." It would remain as defined in 97.3(c)(5). 5. Permitting bandwidths of 100 kHz would allow higher data rates, an objective of the HSMM Working Group. Whether that could actually be accommodated in a given area would depend on local conditions. 6. Membership input is solicited in different ways depending on the situation. In this case, the Board had adopted a broad principle in July 2002. Practical application of the principle is very complex and raises a number of issues. Therefore, the Executive Committee felt that a thorough explanation should be shared with members before the petition is filed. The membership input is being digested and reviewed, and I'm sure will result in some changes before the petition goes forward. Finally, with regard to Vic Poor's transmittal letter, I must tell you that I do not read it the same way you do. But in any case, the synopsis of the petition stands on its own. The Ad Hoc HF Digital Committee's report was just one input. 73, David Sumner, K1ZZ Chief Executive Officer, ARRL