Why Should CW/RTTY Ops Care About ARRL RM 11708 / FCC Docket 16-239 NPRM?

Why Should CW/RTTY Ops Care About ARRL RM 11708 / FCC Docket 16-239 NPRM?

The FCC has recently announced a Notice of Proposed Rule Making, RM 11708 / Docket 16-239 NPRM, which will have significant implications for those amateur radio operators who enjoy CW and RTTY modes. The impetus for this proposed new rule was a petition from ARRL (2013) that all RTTY and data transmissions below 29.7 MHz be limited to a maximum bandwidth of 2.8 kHz.

In their response to ARRL’s petition, FCC has stated that,

“We decline, however, to propose to add a 2.8 kilohertz bandwidth limitation for RTTY and data emissions in the MF/HF bands as requested by the ARRL Petition.”

FCC further states that,

“We tentatively agree that a baud rate restriction has become unnecessary due to advances in modulation techniques, and no longer serves a useful purpose. Our rules do not impose a symbol rate limit on data emissions in any other amateur bands or in any other radio service. In addition, removing the baud rate restriction could encourage individuals to more fully utilize the amateur service in experimentation and could promote innovation, more efficient use of the radio spectrum currently allocated to the amateur service, and the ability of the amateur service to support public safety efforts in the event of an emergency…”

What does this mean for CW and RTTY operators?

If RM 11708 / Docket 16-239 NPRM is enacted later this year, digital transmission of unlimited bandwidth will be allowed on any segment of any band below 29.7 MHz.  Digital voice transmissions using 12.5 kHz wide C4FM (4 level FSK modulation) will probably be allowed to operate in the current CW/RTTY sub- bands, as will Pactor 4 , Winlink, and all other data modes.  WinLink, by the way, is popular with boaters, who use it as an encrypted HF -to-Internet gateway for email delivery.

It is important to note that many digital modes are encrypted, which means they cannot be monitored, and they may therefore constitute a valid threat to national security. The FCC rules do not clearly state how a human may identify such encrypted transmissions, meaning that the self policing nature of the hobby will be severely compromised if RM 11708 / Docket 16-239 NPRM is passed.

FCC is not proposing sub-bands for various modes in RM 11708 / Docket 16-239 NPRM.  It will be up to the amateur community to regulate itself.  Unfortunately, ARRL does not seem to appreciate the significant interference that narrow band modes like CW and RTTY will encounter as they compete with digital voice and data transmissions of unlimited bandwidth.  Our current CW/RTTY sub-bands will be gone forever.

What can We do?

First, take a look at the FCC’s RM 11708 / Docket 16-239 NPRM and ARRL’s 2013 Symbol Rate Petition to familiarize yourself with the issues.

The FCC is currently allowing comments to be filed on this rule for the next few weeks, probably until  October 11th. Spend some time thinking about the proposed rule, and then submit your comments to both the FCC and your ARRL representatives.

You may want to contact your ARRL representatives at the local, regional, and national levels to ask them to either rescind their Symbol Rate Petition or request that they add a request for a dedicated  CW/RTTY sub-band plan for each amateur HF band.

Some suggestions for inclusion in your comments:

The existing narrowband CW and RTTY modes are still providing valuable potential for emergency communications.

The narrowband modes should be protected from wideband digital transmissions by providing a dedicated band segment of 100 kHz for each amateur HF band.

Failure to provide a dedicated narrowband segment for each HF band, will  probably subject CW and RTTY operators to an unacceptable level of interference from wideband digital stations.


At this point, it looks like RM 11708 / Docket 16-239 NPRM will most likely become the law of the land within the next year.  There is still some time left for those of us who care about CW and RTTY to speak out in order to convince the ARRL and FCC that our CW and RTTY narrow band modes are important to us, and that these modes still  provide valuable communication potential that should be protected from the digital modes.

Please contact your representatives to express your thoughtful concerns regarding RM 11708 / Docket 16-239 NPRM:

EZFile Instructions for RM 11708 / Docket 16-239 NPRM

ARRL Officers

72, Paul  AA4XX

2 thoughts on “Why Should CW/RTTY Ops Care About ARRL RM 11708 / FCC Docket 16-239 NPRM?

  1. Thank you for taking the time to do the research, writing it up and providing a wake-up call for those of us who were clueless. Dan

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