digital rule making

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 also operate only within the ACDS 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, this action is 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 sub bands 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 only 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."
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