ARRLWeb: Regulation-by-Bandwidth Petition "a Reasonable Middle Ground," League Says

NEWINGTON, CT, Feb 22, 2006--The ARRL says its Petition for Rule Making (RM-11306) to regulate the amateur bands by necessary bandwidth rather than by mode represents "a reasonable middle ground in a difficult regulatory area." In reply comments filed with the FCC February 21, the League said it was gratified to see more than 900 commenters responded to the admittedly "controversial" petition and noted that many "show the investment of a good deal of thought about the proposal." ARRL said it would have been concerned if the amateur community had not responded with a loud voice on all facets of the League's regulation-by-bandwidth proposal.

"ARRL continues to believe that its petition is a measured response to progress in digital telecommunications technology and successfully balances the interests of all, regardless of which of the polarized opinions in this proceeding, if any, constitutes a 'majority' view," the League's reply comments said. "To the extent that the success of this philosophy necessitates the participation and cooperation of all amateurs in the development of, and increased reliance on, modernized voluntary band plans, ARRL is optimistic that such participation and cooperation will be available" as it has in past "transitional phases" in Amateur Radio's history.

The ARRL is asking the FCC to replace the table at §97.305(c) with a new one that segments bands by necessary bandwidths ranging from 200 Hz to 100 kHz (see table "Proposed Band Segments and Bandwidths"). Unaffected by the ARRL's recommendations, if they're adopted, would be 160 and 60 meters. Other bands below 29 MHz would be segmented into subbands allowing maximum emission bandwidths of 200, 500 or 3.5 kHz, with an exception for AM phone.

The ARRL says the changes it's proposing to Part 97 constitute a balance "between the need to encourage wider bandwidth, faster digital communications and the need to reasonably accommodate all users in crowded bands." It's further expressed confidence in the Amateur Radio community's ability to handle the increased responsibility to establish the workable, accepted band plans the League's regulation-by-bandwidth regime would require.

The League's reply comments countered criticism that its petition represents "overregulation wrapped in a different cloak," that increased reliance--and confidence--in the ability of voluntary band plans to substitute for subband regulation by emission mode is misplaced, or that the ARRL's proposal caters to a small minority of digital enthusiasts and experimenters. Many of those who commented expressed a desire to leave things as they are, some because they feel the advent of digital technology may threaten their favorite mode.

"They are comfortable with the status quo, because the current regulations are not encouraging toward digital modes and, therefore, the current regulatory scheme, they feel, 'protects' them," the League said. "Their comfort level with the status quo is high for these licensees, and they have not hesitated to tell the Commission so."

"All should be accommodated by the regulatory structure of amateur subbands, and technology changes demand regulatory changes in this instance," the League emphasized. The ARRL said its plan "attempts to segment emission modes of similar bandwidths in a manner that accommodates the varied needs and interests of all, while insuring compatibility by grouping like-bandwidth emissions together."

Citing repeated efforts to gather input from the Amateur Radio community at large and from its members since its regulation-by-bandwidth concept was first aired in 2002, the League called the petition "the most thoroughly vetted regulatory proposal" it's ever developed.

"The ARRL petition does not favor one mode at the expense of another," the League reiterated in concluding its reply comments. "It merely allows expansion of the repertoire of options that amateurs may pursue compatibly."

A list of "Frequently Asked Questions" (FAQ) about the ARRL's petition is available on the ARRL Web site.

Proposed Band Segments and Bandwidths (The plan incorporates the ARRL's recommended exception of a maximum bandwidth of 9 kHz for double-sideband AM.)
160 Meters	Maximum Bandwidth
1.800-2.000 MHz	3.5 kHz

80/75 Meters
3.500-3.580 MHz	200 Hz
3.580-3.620 MHz	500 Hz
3.620-4.000 MHz	3.5 kHz*

40 Meters
7.000-7.035 MHz	200 Hz
7.035-7.100 MHz	500 Hz
7.100-7.300 MHz	3.5 kHz*

30 Meters
10.100-10.120 MHz	200 Hz
10.120-10.135 MHz	500 Hz
10.135-10.150 MHz	3.5 kHz*

20 Meters
14.000-14.065 MHz	200 Hz
14.065-14.100 MHz	500 Hz
14.100-14.350 MHz	3.5 kHz*

17 Meters
18.068-18.100 MHz	200 Hz
18.100-18.110 MHz	500 Hz
18.110-18.168 MHz	3.5 kHz

15 Meters
21.000-21.080 MHz	200 Hz
21.080-21.150 MHz	500 Hz
21.150-21.450 MHz	3.5 kHz*

12 Meters
24.890-24.920 MHz	200 Hz
24.920-24.930 MHz	500 Hz
24.930-24.990 MHz	3.5 kHz

10 Meters
28.000-28.050 MHz	200 Hz
28.050-28.120 MHz	500 Hz
28.120-29.000 MHz	3.5 kHz*
29.000-29.700 MHz	16 kHz

6 Meters
50.000-50.100 MHz	200 Hz
50.100-50.300 MHz	3.5 kHz
50.300-54.000 MHz	100 kHz

2 Meters
144.000-144.100	200 Hz
144.100-144.300	3.5 kHz
144.300-148.000	100 kHz

1.25 Meters
219.000-220.000 MHz	100 kHz
222.000-225.000 MHz	No specific bandwidth limit
Bands 70 cm and Above	No specific bandwidth limit

* The ARRL has proposed to modify §97.221(b) to permit stations to use automatic control while transmitting a RTTY or data emission on the 6 meter or shorter wavelength bands, and on the 28.120-28.189 MHz, 21.150-21.160 MHz, 14.100-14.112 MHz, 10.140-10.150 MHz, 7.100-7.105 MHz or 3.620-3.635 MHz segments.