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CW ops - our bands are being petitioned

This will probably never make it anywhere, but there is a General Class radio amateur, N0ECN, of Missouri USA who recently filed a petition calling for the “elimination” of the CW only sub-bands - citing that a CW-only sub-band is a “poor use of the radio spectrum…” and that “symbol communications” should be included.

I know a lot of you are CW operators, so it may be of particular interest to you to know about this:

http://apps.fcc.gov/ecfs/comment/view?id=60001692464

There’s a lot more to it than just the cw-only sub-bands, so you should read the entire document which is already being looked at in the QRZ forum:

Your problem is not the removal of CW sub-bands but that you have mandatory band plans in the US. Voluntary band plans seem to work most of the time in Europe. It should not be down to your licensing authority to decide how amateurs use their allocations. They should be ensuring amateurs stay inside their bands and intruders stay out.

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I didn’t have time to dig through the entire filing, but last I checked the only FCC mandated CW only sub-bands were the lower 100 kHz on 6m and 2m, and the Technician-class allocations on 80m, 40m, and 15m. Unless you’re thinking of the 100% voluntary, non-legally-binding ARRL band plans? Personally, I think that any FCC rules regarding use of the spectrum should be based on PEP and bandwidth, not mode.

I agree … and that is exactly how it is in the U.K. and most European countries.

73,
Walt (G3NYY)

In some Southern European countries (eg Portugal) the law states what are the frequency limits of each band and that the use of the spectrum within those band should be used accordingly the IARU band plans.

So, if we screw up… :frowning:

Until far it works FB…

73 de Pedro, CT1DBS

And that’s mostly how it works in the US, except of a couple instances.

For example, the 40m band is from 7.0-7.3 MHz. Below 7.125 MHz is allocated to CW, RTTY, and Data < 1 kHz bandwidth (above that is all modes). Within that lower chunk, Extra (highest) class licences can use the whole thing. General class can only use 7.025-7.125. Technician (lowest) class can use the same spectrum as General, but is limited to 200W PEP and CW only.

In fact, all HF Technician allocations below 28 MHz are limited to 200W CW (this is one of the instances). This petition would serve to allow Techs to use digital modes on frequencies they are already allowed to use.

The other instance where the FCC limits the mode is in the lower 100 kHz of the 6 and 2 meter bands. This was done to limit possible interference with Government users in the band immediately below them.

In Germany, The IARU bandplan has been made a legal Juris document, so while the government department BNetza have not defined what modes operate where, this conversion of the IARU document into a legal document make it no longer voluntary conformance. As Walt says, the IARU document covers bandwidth rather than specific modes. In addition to this, the specific German licence conditions cover power allowed, for example 750w PEP maximum 7-7.1MHz and 250w PEP maximum 7.1-7.2MHz, 25w ERP maximum on 50.08-51MHz. Class E (Novice) licences have less power and frequencies than Class A (Advanced/Full) licences.

…, the specific German licence conditions cover power allowed, for example 750w PEP maximum 7-7.1MHz and 250w PEP maximum 7.1-7.2MHz…
I am listening to a DL stn on 7144 kHz right now and he claims to run 1KW… !
If 250W PEP is a legal limit, there is clearly a lack of enforcement or lack of understanding amongst some DL operators of their license conditions, !
73
Ken

Here is the legal document reference:
http://www.gesetze-im-internet.de/afuv_2005/anlage_1.html
or for those who can’t read German- here’s the google translation:
https://translate.google.com/translate?sl=de&tl=en&js=y&prev=_t&hl=en&ie=UTF-8&u=http%3A%2F%2Fwww.gesetze-im-internet.de%2Fafuv_2005%2Fanlage_1.html&edit-text=

In any case this is getting somewhat off-topic from the original alert of a proposal to change CW frequencies in the US.
We probably shouldn’t have hi-jacked W3ATT’s thread.

To close this bit out - suffice to say different countries have different rules.

73 Ed.

What it does do is make very good use of our time. If you want to find a CW signal, you know where to look. No need to trawl the entire band searching for someone to work on the mode. Also it avoids the potential for complaints from SSB operators who often dislike hearing an adjacent CW signal within their receiver passband.

Hi Gerald,
That comment is 100% true for all modes - SSB, CW, Digital, RTTY - Voluntary band plans are good at grouping similar modes together. Even if the licence says that a particular mode can be used anywhere in the band having “centres of activity” for particular modes is the best reason (IMHO) for band plans.

Ed.

Mandatory band planning does stymie new development. For example if a wideband digital mode such as a DSSS (direct sequence spread spectrum) mode was developed that needed 100kHz bandwidth then it would not be allowed in countries which had bandwidth limits. I’m not talking about a 100kHz wide signal like some idiots have for a badly set up PSK31 setup (too much audio/RF) but a genuinely spread signal.

Of course the low probability of intercept of such a signal means you could probably develop and use it with a few buddies with little chance of being observed until you describe your new mode to all and sundry!

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With the maximum 2.7KHz bandwidth allowed in Germany on HF bands below 10 metres, the use of AM has already been killed, so its not just new modes, but old ones as well that are affected when a band plan becomes a legal document.

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You are right.
But the use of with IARU bandplan allow us define what to do with the spectrum. It’s diferent from having a strict legal boundary which tells you what you could do.

In the IARU R1 HF bandplan we have this in accordance definition :

“DEFINITIONS
All modes: CW, SSB and those modes listed as Centres of Activity, plus AM (Consideration should be given to adjacent channel users).”

This is not exactly what we have in Germany.

We have legal power restrictions, in CT/CU land. The worst case scenario is 200 W and the best 1500 W ERP (80-10m). The novice just use HF spectrum under supervision.

73 de Pedro, CT1DBS/CU3HF

That section was conveniently dropped when the IARU document was used to create the JURIS document. Interestingly, the DARC bandplan used to also include the use of AM as being possible on a non-interference basis. However the Juris document is the legal ruling.

A rule is a rule but I’m sorry to read: [quote=“DD5LP, post:15, topic:13175”]
That section was conveniently dropped when the IARU document was used to create the JURIS document.
[/quote]

73

From AT_Spring -Yahoogroups one can read the following from K1ZZ

"Dave et al,

First of all, apologies to those of you who are not regulated by the FCC. Feel free to delete this.

According to a quick search on the FCC website, N0ECN has filed 238 petitions and comments over the past 20 years. He likes to exercise his right to do so, which we all have under the rules adopted by the FCC consistent with the Administrative Procedure Act.

A petition for rulemaking is just the first step in a lengthy process. Except when spectrum is under threat, the ARRL seldom comments at this stage. Most such petitions never go anywhere, and preparing and filing comments eats up resources that are better devoted elsewhere.

In this case it looks as if what N0ECN is trying to accomplish is rather modest:

  1. Add what are now called data mode privileges for Novices and Techs to the HF bands where they can now operate CW, which the ARRL has already proposed to a more limited extent;

  2. Add data modes to the CW-only segments of 6 and 2 meters so they are more like the similar segments of the HF bands, which is not in itself a bad idea; and

  3. “Simplify” (in his view) the definitions of modes without actually changing very much.

As others have observed, the petition isn’t very persuasive and #3 would have unintended consequences. If the FCC does anything at all with it, it’s likely to be associated with other petitions on the same general subjects in a Notice of Proposed Rule Making or Notice of Inquiry.
At that point there will be ample opportunity to comment. In the meantime I wouldn’t lose any sleep over what is just one man’s opinion.

73,

Dave K1ZZ"

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