[CW] (no subject)

[Bill Tippett]

K4KYV wrote:

>The problem is that so many of the submissions to the FCC regarding 60m. are 
making this a single-issue campaign for subbands, neglecting to comment on 
why it should be an AMATEUR band.

        You misunderstand how the NPRM process works.  The period for
making this point was during RM-10209 phase which began with public
notice on August 13, 2001.  The FCC accepted comments for 30 days with
a 15 day period for reply comments ending at the end of September 2001.
The FCC BOUGHT THE ARGUMENT and has now issued the NPRM, which means
it is in a fine-tuning phase and will most likely be adopted as 
published.  If you agree with NPRM 02-98 in its entirety, you need
do nothing.  Comments during the NPRM phase should primarily address
errors in the NPRM before it is adopted is law.

        In reading paragraph 40 (below), it is quite clear to me that
the FCC IS soliciting comment on the sub-banding issue, because I am
sure they noticed the inconsistency in ARRL's RM-10209 proposal compared 
to RM-10413 (Novice Refarming) and compared to current regulations.
It doesn't get much clearer than this to me: "We request comment on 
whether sub-banding is necessary and/or appropriate for the 5000 kHz 
band as well."

        There is no need to comment on what it right during the NPRM
phase...only what is wrong.  Making comments supporting the need for
5 MHz at this point is "like the tail wagging the dog" since the FCC
already bought those arguments or would not have issued the NPRM.

                                                73,  Bill  W4ZV

"40. The 5000 kHz Petition does not discuss sub-banding and ARRL's suggested
rules would allow all emission types to use the entire band.[94] We note
that several commenters suggest that sub-banding would be useful. We further
note that Section 97.305 of our Rules segregates digital modes from other
amateur station emission modes in the 3500 kHz and 7000 kHz bands to protect
narrow band emissions like data from wider emissions like single-side band
voice.[95] We request comment on whether sub-banding is necessary and/or
appropriate for the 5000 kHz band as well."