NU9N SSB Audio News Editorial - July, 2003

FCC RM-10740 Comment Period Expired

July 26th was the expiration date for comment filing on RM-10740.

I would like to thank all of you who filed an opposing position to additional bandwidth regulations. It looks like it will die an ugly death based on the high number of comments against any new bandwidth rulemaking. The last time I counted, it was about 150 against and 20 for new bandwidth regulations.

To view comments already filed, click here.

Use " RM-10740 " in the " Proceeding " field of the form (first field) after clicking and connecting the above link.

For those of you who are interested, below is a copy of my official comments filed with the FCC for RM-10740.

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Reference: RM-10740

I strongly reject any new rulemaking policy that would impose 5.6 kHz RF bandwidth limits on AM (A3E) or 2.8 kHz RF bandwidth limits on SSB (J3E) modes of HF operation.

The Amateur Radio HF spectrum has enjoyed sufficient freedom of experimentation through loose rule interpretation regarding occupied bandwidth since its inception.

The AM mode of operation, (A3E) has been an Amateur Radio staple for decades and is still enjoyed by many operators who find this mode both challenging and rewarding for its technical merit, warm sounding audio characteristics supported by RF bandwidths beyond 5.6 kHz inherent in classic equipment that has been either home-brewed, restored or commercially built. This traditional mode has led to a community of highly skilled and technically knowledgeable operators who's talents and contributions to the Amateur Radio service have been nothing short of necessary for the development of this hobby as we know it today. Also, there has been a resurgence of operators who are passionate about the art and science of quality A3E emissions, which has always been at the heart and soul of Amateur Radio.

To impose a 5.6 kHz RF bandwidth restriction to AM (A3E), is to (1) murder a vast majority of equipment that has been in service for decades, as well as new commercial equipment available on the market, (2) kill the operations of both new and seasoned Amateurs who have enjoyed the fruits of their hard earned labor and (3) slaughter the very spirit of this nostalgic part of the hobby that has led to numerous advancements of the state of the art, not to mention the technical merits, camaraderie and friendships enjoyed. This has been the result of the past and current bandwidth freedoms that are currently enjoyed by so many.

For these reasons, I profoundly reject any new rule(s) or law imposing an RF bandwidth limitation of 5.6 kHz regarding the AM (A3E) mode of operation on HF.

Furthermore, with HF SSB (J3E formerly A3J) being the half-bandwidth child of AM (A3E), I would apply the same philosophy and reasoning. J3E inherently occupies one half of the RF spectrum as that of A3E, while producing the same AF quality. SSB (J3E) is already, by default, a bandwidth conserving mode regardless of the resulting and desired RF/AF bandwidth occupied, simply in light of the fact that its RF and AF spectrum are equal if properly adjusted. And, in respect to the removal of the carrier and opposite sideband, J3E bandwidths beyond 2.8 kHz is and has been suitable and compatible for all SSB operations, regardless of its bandwidth. There have always been interference issues on the HF bands regardless of mode or bandwidth, and because of the shared nature of Amateur Radio, there will continue to be interference issues. New Bandwidth rules can not nor will not change this reality of a shared service!

For these reasons, I profoundly reject any new rule(s) imposing an RF bandwidth limitation of 2.8 kHz regarding the SSB (J3E) mode of operation on HF.

The scope and versatility of Amateur Radio encompasses many interests and pursuits within the mandated and experimental aspect of this service. All current aspects of Amateur Radio should be supported without prejudice and without restricting the interests of the majority or the many, in spite of the few with an agenda who would vote to destroy the freedoms that we all now currently enjoy.

If used in a conscientious and responsible manner, as with all Amateur Radio operations, both A3E and J3E, without any new RF bandwidth limitations, can continue to enjoy bandwidths that support quality emissions without being an offense or menace to the operations of others using narrower bandwidths. The friction and issues that led to the petitions filed by W0YR and W6FDR have not been, in my view, a bandwidth issue, but rather, one of acceptance and co-existence of new ideas and techniques used in this shared service.

Summary:
The solution is not, and never will be one of bandwidth management, but rather one of anger management, and of being more tolerant of ideas and pursuits not necessarily shared by those who resist change and progress.

I vote to keep the heart, soul and spirit of Amateur Radio alive by rejecting any new bandwidth rule(s) for A3E or J3E on HF, which would otherwise and inherently destroy the freedom of experimentation that has been enjoyed by so many from the very beginning.

New laws rarely change the hearts of men, and always diminish the freedom of all.

Sincerely,

John M. Anning, NU9N