James E. Whedbee, N0ECN, of Gladstone, Missouri, has petitioned the FCC to designate Morse (radiotelegraphy) Amateur Radio band segments as “symbol communication” subbands. The FCC has invited comments on his Petition for Rule Making (RM-11769), filed on May 2. Arguing that retaining the current regime of “legacy” CW subbands has proven to be grossly inefficient, Whedbee said he’d like to see the FCC delete all privilege restrictions that limit any part of the Amateur Radio spectrum to Morse code to the exclusion of other modes.

“Nostalgia for retention of Morse code telegraphy-only subbands is also an insufficient reason to avoid moving forward to [the] elimination of such subbands, because nothing about this Petition suggests the elimination of the mode itself, only that it not be the sole authorized mode in the subject subbands,” Whedbee told the FCC.

Whedbee characterized CW-only subbands as “an excessive regulatory constraint, as well as a poor use of the spectrum concerned.” He proposed that the FCC’s Part 97 rules reflect the “ultimate form of communication reproduced at the receiving end.” As he explained it, his regulatory scheme would break down modes into three categories — “symbol communication mode” — for CW, digital, and other emission modes that reproduce a discrete symbol on the receiving end — “voice mode,” and “image mode.”

“[C]ontinuing regulation by specific emission designator is proving to be onerous with changes to the state of the art,” Whedbee said. “Accordingly, to continue developing the state of the art in radiocommunications, Amateur Radio needs to clearly get away from regulating in that fashion and return to consideration of what the receiving end of the communication reproduces.”

He proposed that where the Part 97 rules refer to exclusive radiotelegraphy allocations — or subbands — privileges be changed to reflect symbol communication modes. Where the rules prohibit voice and image modes, he would revise the rules to reflect symbol communication modes. In situations where current rules prohibit symbol communication modes other than Morse, that voice and image modes would be permitted, “with an exception for manually keyed” radiotelegraphy.

For example, he would drop the distinction between 75 meters and 80 meters, authorizing symbol communication modes between 3.5 MHz and 3.65 MHz, and voice and image modes between 3.65 MHz and 4 MHz, with manual radiotelegraphy authorized throughout the band.

Whedbee told the FCC that, if his Petition is accepted for filing and put on public notice, he would submit an appendix spelling out proposed service rules as part of his Petition.

Commenters have 30 days to respond to Whedbee’s Petition.