Hi Howard,

You may be right. I hope you are. But when you look at the sheer number 
of opposed to favoring it has to be at least 80% opposed, if not even 
90%. That is overwhelming. It is true that almost all of the hams who 
claim they oppose the petition have not really read and understood the 
petition, but instead pasted Bonnie, KQ6XA's, technically incorrect 
information as a response. Will the FCC see through this and take this 
into consideration? Probably only to some degree.

I am not sure how hams can handle the interference. To my knowledge the 
ARRL Official Observers are not sending notifications to any of these 
stations. Same thing with any of the types of operations that appear to 
be scofflaws or at the very least borderline kinds of activities such as 
PropNet, APRS, ALE automatic sounding with unattended operation (when 
they operate in this manner with no control operator).

The FCC Enforcement Division will hopefully respond to my multi issue 
query for clarification on how hams should be expected to behave on each 
side of the equation. This includes those who operate such stations and 
those who are affected by such stations. It may be that they will 
interpret the rules to say that these kinds of operations are 
appropriate and we will have to continue to live with that or later on 
ask for specific changes in the rules.

The text data bandwidth issue may go away, at least on some bands, 
because wide modes (> 500 Hz) are specifically not to be operated under 
the new Region 2 band plans in many areas that they currently operate. 
While it does not directly have the force of law, it may be a tempering 
influence. If the ARRL had been able to get its request approved by the 
FCC to make band plans the force of law, there would be no more wide 
modes in the U.S. in the text data portion of the bands on 80 meters and 
nothing below 14.101 on 20 meters.

Many of those opposed to the petition are intentionally misrepresenting 
that this is an anti-wide bandwidth issue. It is not. They should direct 
their ire at the Region 2 Bandplan, not at a petition that is a 
reasonable compromise and would allow three times that bandwidth to as 
much as 1500 Hz in the text data portions of the bands.

Voice and image with reasonable quality, and perhaps larger file size 
mixed documents/data have larger throughput requirements and must have 
adequate bandwidth to be practical. While any bandwidths in excess of 
voice communications bandwidth would be inappropriate, due to the shared 
nature of HF amateur bands.

Part 97.307 Emission standards.

(2) No non-phone emission shall exceed the bandwidth of a communications 
quality phone emission of the same modulation type. The total bandwidth 
of an independent sideband emission (having B as the first symbol), or a 
multiplexed image and phone emission, shall not exceed that of a 
communications quality A3E emission.

Now this is currently being stretched a bit beyond the Region 2 band 
plan recommendation of 2700 Hz with eSSB, but the rules do not exactly 
specify a bandwidth and unless the FCC issues an interpretation on what 
that really means, or accepts the band plan, there is some leeway since 
DSB phone is considered acceptable in some areas of the bandplan.

73,

Rick, KV9U




Howard Brown wrote:
> Rick, I usually agree with your comments but I do not agree that the 
> petition is dead.
>
> The FCC has probably been waiting for the ham community to be 
> self-policing and handle this interference problem.  Can you suggest 
> any other reason that they have not cited the interfering stations?
>
> Since we have not been able to solve this through cooperation, the ham 
> community (at least part of it) is asking the FCC to solve it through 
> rules changes.  The FCC is smart enough to recognize the need to do 
> this, and I believe they will.  We may not like the solution but they 
> have been asked to deal with it formally and they probably will.
>
> 73,
> Howard K5HB

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