I have a different twist on this. Lets go ahead and allow data modes up to 3 kHz bandwidth. But if this is truly supposed to be regulation by bandwidth, then move these broader modes up into the phone portions. Narrower modes like RTTY, PSK31, CW, and others need space where they won't be overwhelmed by wider bandwidth sigals. I think there should be areas of each band with safe havens for the narrow modes. The current CW data mode sub-bands would be a good line of demarcation.
I am generally against the proposal because it is not truly regulation by bandwidth or not fully so. For example, the PSK31 region on 20 meters is 14.070 to 14.073 or 3 kHz wide. Why should one signal get to clobber a dozen signals? Also much of the QRM on the lower end of the bands is from stations who don't have ability to hear other modes. On my 756 Pro 2, I cannot hear a PSK31 or CW station if I am on RTTY and have the twin filters kicked it. At least PSK31, MFSK16, and Olivia stations have waterfall displays available and can see other activity near the intended transmit frequency. A common query on CW is QRL? It is the equivalent of "is this frequency in use?", on ssb. How are users these wider modes digital modes going to know if they are stepping on someone? What about HFpack? I have worked the narrow digital modes with HFpack members. I also know a local group of HFpackers who meet on 80 meter CW. The wider modes tend to reduce efficiency and squeeze out the little guy. 1 kHz Olivia may be the exception. But 3 kHz is 3 times as wide. It is strange that the ARRL proposed a 200 Hz bandwidth limit at the low end of 10 meters, but 3 kHz on the other HF bands. 10 meters is the HF band with the most space to begin with. This is really odd. It is not a perfect solution, but if 3 kHz data is necessary, lets truly regulate by bandwidth and put it in the phone bands. 73, Steve N6VL
