[CW] An AM View of the World

[Bill Tippett]

On the FCC ECFS site, K2PG wrote (regarding NPRM ET 02-98):

"In Paragraph 40 of ET 02-98, the Commission asks if emission subbands 
should be mandated on the 5250-5400 kHz band.  Such subbanding by 
government fiat serves only to overregulate the Amateur Radio Service. 
It does not allow for flexibility to choose emission modes according to
prevailing usage patterns on the amateur bands.  It also tends to stifle
experimentation.  The undesirable results of FCC-mandated emission subbands
may be heard on the other HF bands.  The segments reserved for narrowband
emission modes such as CW telegraphy (Class A1A emission) are often lightly
used, particularly in the case of the 3500 kHz band. But the segments where 
wideband modes, such as AM and SSB telephony (Class A3E and J3E emission, 
respectively), are permitted are often horribly crowded. Subbanding has had 
the effect of setting up de facto 'American-free' zones, in which foreign
amateur radio stations may use voice and other wideband modes, but 
Americans may not.  Because wideband modes prevail on the frequencies in
question, American stations refrain from using narrowband modes there and
the foreign stations will not communicate with Americans using narrowband 
modes on the frequencies in question.  Although the proposed 5250-5400 kHz
allocation will be an amateur band only in the United States, the lack of
government-mandated emission subbands will give users of this band more 
freedom to move about to avoid interfering with the fixed and mobile 
stations that will continue to be the primary users of this band. 
Currently, the United States is the only country in the world that imposes
government-mandated emission subbands on its radio amateurs.  It is time to 
amend Section 97.305 of the Commission's Rules to repeal any and all such
division of all of our bands into such emission subbands."

        Questions that come to my mind follow the quoted comments:

"The undesirable results of FCC-mandated emission subbands may be heard 
on the other HF bands.  The segments reserved for narrowband emission 
modes such as CW telegraphy (Class A1A emission) are often lightly
used, particularly in the case of the 3500 kHz band."

1.  This reminds me of the SSB group on 1823.  When told that they 
were on top of CW DX there, their response was typically "CW DX?
I don't hear any DX.  We aren't moving."  It's unlikely most stations
can hear weak signal DX, low power beacons, or digital modes unless they 
have the technical capability to do so (i.e. Beverages or other receiving
antennas, Spectrascan DSP software, etc.)  Of course the 1823 group
could hear the S9+++ USA CW stations calling the DX but they chose to
ignore them.  In my experience, most domestic wideband communications on 
the lower bands are local ragchew nets.  There's nothing wrong with that 
but I don't particularly think they should occupy the entire band.

"It also tends to stifle experimentation.

2.  Exactly how much experimentation is done on AM and SSB?  The most
I've heard seems to be how far they can stretch Amendment One without 
getting warning letters from Hollingsworth.  Check out FCC enforcement 
letters below and you'll note most of the violations over the 3 years 
of records are using SSB, AM or FM modes.  Most true experimentation is 
being done today with weak-signal CW, QRSS CW and the new digital modes 
(PSK31, WSJT, QRSS, etc.)

        http://www.arrl.org/news/enforcement_logs/

"But the segments where wideband modes, such as AM and SSB telephony 
(Class A3E and J3E emission, respectively), are permitted are often 
horribly crowded."

3.  Could this be because those modes are horribly spectrum-inefficient?
The lastest rage of some AM'ers is high-fidelity AM which may be in 
violation of FCC regulations if it is wider than 6 kHz total bandwidth.
They seem to want to emulate Broadcast stations which have spectrum
spacing of 10 kHz.  Is using antiquated wideband modes like AM truly 
advancing the state-of-the-art?  I don't think so.  

"Subbanding has had the effect of setting up de facto 'American-free' 
zones, in which foreign amateur radio stations may use voice and other 
wideband modes, but Americans may not.  Because wideband modes prevail 
on the frequencies inquestion, American stations refrain from using 
narrowband modes there and the foreign stations will not communicate 
with Americans using narrowband modes on the frequencies in question."

4.  In fact, on the 75 meter band where the phone subband has expanded
below 3800 over the past twenty years, most of the 3750-3790 area has 
been taken over by domestic nets, which force DX stations below 3750 
or into the small 3790-3800 "DX window".  As a matter of fact, most
DX operations there use split frequency to avoid their weaker signals 
being covered by stronger local USA signals.  If subbands did not
exist, I suspect the entire 80M band would be taken over by the same 
type of local domestic nets that cover the 75M band today.  

"Although the proposed 5250-5400 kHz allocation will be an amateur band 
only in the United States, the lack of government-mandated emission 
subbands will give users of this band more freedom to move about to avoid
interfering with the fixed and mobile stations that will continue to be 
the primary users of this band."

5.  If this were really true, I wonder why we had the case of the group
on 1823 refusing to move for 17 years?  They weren't interfering with 
any other service but their own, in violation of their own ARRL and IARU
Region 2 voluntary bandplans.  What makes us think they would be better 
behaved on 5 MHz?

"Currently, the United States is the only country in the world that 
imposes government-mandated emission subbands on its radio amateurs."

6.  This is simply not true.  I am most familiar with 160 meters but 
there are also sub-bands on 10 meters in some countries, and there may 
be others as well.  

        For those who feel we need no government regulation whatsoever, 
they need look no further than 27 MHz for an example of the chaos that 
would result.  We've "been there and done that" and I don't think we
need to repeat that experience on our amateur bands.

                                                73,  Bill  W4ZV