What Was the ARRL Thinking?

It was recently revealed that in mid-July the ARRL Board instructed Washington Counsel David Siddall, K3ZJ, to take steps to obtain FCC approval for several changes to the Part 97 Amateur Radio Service rules. The requested changes we all should object to:

  • Require ALL digital mode stations operating with a bandwidth greater than 500 Hz to operate within the narrow 97.221(b) Automatically Controlled Digital Station (ACDS) sub bands, whether or not these stations are automatically controlled.
  • Require all automatically controlled digital mode stations less than 500 Hz bandwidth to operate only within the ACDS sub bands.

The full action is in the ARRL Board minutes, page 16:
http://www.arrl.org/files/file/2019%20Board%20of%20Directors/Final%20Min...

Bonnie Crystal, KQ6XA, founder of HFLink painted a clear picture:

"What ARRL wants, an Analogy:

  • There is a six-lane superhighway we've all used well for years, but now only bicycles and horse-drawn carts can use it.
  • Fast cars and trucks are forbidden on this highway.
  • All the fast cars and trucks must now use a single lane frontage road alongside the superhighway.
  • The bicycles and horse-drawn carts also have the right-of-way when using the frontage road."

While we at ARSFI fully appreciate the Director's other actions on digital matters, these items are simply crazy without expanding the 97.221(b) subbands. You can't responsibly sort and redirect the traffic to a place that can't handle it. On 40 meters, 17 meters and 12 meters, the subbands are only 5 kHz wide, enough for only a single QSO of fast digital data, or two, depending on the modes. Other narrow sub bands allow 3-6 simultaneous QSOs without interference. This is their answer to the highly contested RM-11831 petition at the FCC?

Bonnie Crystal calls this, "'Regulation By Bandwidth' + 'Regulation By Content' piled high upon 'Regulation by Absurdity'....but the absurdity would only apply to digital data signals, and not to anything else. That is a huge step back into the Technology Jail."

What does this mean for ALL hams with a digital interest?

If the ARRL gets their wish and you use and enjoy some of the following modes, you must do so entirely within the tiny subbands described by 97.221(b), originally intended only for automatic stations greater than 500 Hz in bandwidth. All the following modes operate with BW over 500 Hz or are employed with automatic features: (even little 50 Hz wide JS8Call!)

Pactor 1, 2 (auto) 3, 4
ARDOP 500 (auto), 1000, 2000
WINMOR 500 (auto), 1600
VARA
JS8Call (Auto, HB)
JTMS
JT65 (710 Hz)
AX.25 Packet
MT63-1000, 2000
Olivia 8-1000
Olivia 16-1000
Olivia 32-1000
Thor22
Thor25x4
Thor50x1
Thor50x2
Thor100
Q15x25 or NEWPSK
RTTYM
RTTY (variations 500-850 Hz BW)
ALE-AQC
MIL STD 188-110 / FED STD 1045
2G ALE
3G ALE
CLOVER2000
CLOVER2500
Hellschreiber x5, x9, 80
RDFT
MFSK32
MFSK64
MFSK128
MFSK64L
MFSK128L
DOMINOEX22
DOMINOEX44
DOMINOEX88
Contestia 8-1000
Contestia 16-1000
Contestia 32-1000
8PSK (all)
QPSK500
PSK250C6
PSK500C2
PSK500C4
PSK800C2
PSK1000C2
PSK63RC10
PSK63RC20
PSK63RC32
PSK125RC4
PSK125RC5
PSK125RC10
PSK125RC16
PSK250RC2
PSK250RC3
PSK250RC5
PSK250RC6
PSK250RC7
PSK500RC2
PSK500RC3
PSK500RC4
PSK800RC2
PSK1000R
PSK1000RC2
+more

Winlink, HFLink, NTSD, RRI, and numerous BBS systems operate automatically in the sub bands. Pile on the rest of the wide modes and traffic will likely come to a halt for everyone on most bands. ARSFI will be proposing expanded sub bands in response, count on it.

Angry yet? Let your ARRL Director know what you think! Remaining quiet will be a big mistake! If the FCC acts, it will take many years to repair. When the ARRL filing hits the FCC Electronic Filing System (ECFS), respond there with your comments, too!

FCC ECFS: https://fcc.gov/ecfs/ (Enter RM-11831 in the 'Proceedings' field, and click search at the bottom. To file a comment, click 'submit a filing'.)

ARRL Directors:
Atlantic Div: Tom Abernathy, W3TOM, [email protected], 301-257-6225
Central Div: Kermit Carlson, W9XA, [email protected], 630-879-0983
Dakota Div: Matt Holden, K0BBC, [email protected], 952-232-1984
Delta Div: David Norris, K5UZ, [email protected], 870-613-1606
Great Lakes Div: Dale Williams, WA8EFK, [email protected], 734-529-3232
Hudson Div: Ria Jairam, N2RJ, [email protected], 973-594-6275
Midwest Div: Rod Blocksome, K0DAS, [email protected], 319-393-8022
New England Div: Fred Hoppengarten, K1VR, [email protected], 781-259-0088
Northwest Div: Mike Ritz, W7VO, [email protected], 503-987-1269
Pacific Division: Jim Tiemstra, K6JAT, [email protected], 510-569-6963
Roanoke Div: Bud Hippisley, W2RU, [email protected], 540-576-2527
Rock Mountain Div: Jeff Ryan, K0RM, [email protected], 303-432-2886
Southeast Div: Greg Sarratt, W4OZK, [email protected], 256-337-3636
Southwest Div: Richard Norton, N6AA, [email protected], 310-455-1138 *Director Norton was the only one to vote against this absurd directive.
West Gulf Div: John Robert Stratton, N5AUS, [email protected], 512-455-6262

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