Hello Greg - KØGW...
You had previously communicated to me your support of the ARRL RM-11708.
We are on opposite pages regarding this topic. Three things disturb me
greatly in what I see developing as a "us vs. them" scenario.
The first is the blatant disregard for the technical competence of the
digital community who oppose RM-11708. It is consistently being stated
the opposition is "misinformed". This implies ignorance of the topic
instead of acknowledging it is a debatable, opposing viewpoint.
Here's my opinion, ARRL is presenting an _immature_ response when faced
with credible opposition to their proposal. This is creating very bad PR
and, obviously, no one knows how to effectively manage "spin control" to
minimize the affect. All this would be unnecessary had the topic been
debated prior to rushing RM-11708 to the FCC for their blessing.
The second issue is that the FCC has previously denied a similar request
many years ago. They upheld the fundamental concept of keeping
narrow-bandwidth and wide-bandwidth signals separate in the bands. If
this were not the case, SSTV signals would have been moved into the
CW/Digital section at that time. They were not.
I believe the previous FCC decision is a foreshadow of their rejection
of RM-11708. It is the same argument, just different words. Lifting the
restrictions will create a "wide band" signal and it should be
restricted to the "wide-band" portion of the existing amateur radio
bands. I don't see any change in philosophy at the FCC regarding their
previous decision and I am puzzled why the ARRL believes it has.
Basically they have taken the same old pig and changed the color of the
lipstick.
Thirdly, trying to sneak RM-11708 through the system without discussion
and comment from those who will be affected. This was a very bad
management decision at HQ. I typically support the ARRL in general, but
this specific issue has left a bad taste in my mouth. I read very
immature responses to the opposition and the unwillingness to carrying
on a rational debate. It's just a /"Because I'm the mom, that's why!"/
argument.
Please review the information below, again. I hope this time you become
convinced RM-11708 should be withdrawn.
Respectfully submitted,
Bob Chudek - KØRC in MN
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-------- Original Message --------
Subject: [RTTY] Fwd: [CTDXCC] Rick Roderick's position
Resent-Date: Tue, 15 Apr 2014 11:42:56 -0500
Resent-From: Dick Kriss <aa5vu@att.net>
Resent-To: RTTY Reflector <rtty@contesting.com>
Date: Tue, 15 Apr 2014 10:53:33 -0400
From: aa5vu@att.net
To: CTDXCC Reflector <ctdxcc@kkn.net>, k3lr@k3lr.com, W4TV Joe Subich
<lists@subich.com>, n9nc@earthlink.net
Below is an open letter that I have written to the ARRL board of directors - it
appears below.
Please feel free to propagate this far and wide, and to add other technical
opinions, because these points must see the light of day!
We need others to actively write all ARRL directors, and to file comments at
the FCC website (late
Comments are still being accepted and DO matter!)
Please go on record at the FCC to stop this blatant attack on the protected low
end of the HF bands.
We need major activism, as the lobby group pushing RM11708 within the ARRL is
firm on their talking points (see the ARRL website) that completely ignore and
improperly characterize the vital technical issues below.
Please, I urge all hams interested in the continued enjoyment of CW, PSK31,
and RTTY to become active, to immediately file public comments at the FCC, and
to send your comments to all ARRL board members, whose emails appear below.
Imagine if you were a SSB operator, and all of a sudden the ARRL pushed a rule
making that would instantly introduce new SSTV signals with 25 khz bandwidths,
8 to 14 times the bandwidth of incumbent SSB signals. This is what is being
proposed for the CW and RTTY operators in the narrowband data portions of the
band.
Ham radio needs concerned members to immediately respond to the FCC comments
section, and to let ARRL board members know of our concern, and the facts of
this rule making that is consistently being ignored by many at the ARRL.
Thanks for the bandwidth. And more importantly, thanks in advance for your
activism- your hobby needs you like never before!
73,
Ted
Sent from smartphone - please forgive typos
Begin forwarded message:
From: Ted Rappaport <tedrappaport@verizon.net>
Date: April 15, 2014 1:22:03 AM EDT
To: "Sumner, Dave, K1ZZ" <dsumner@arrl.org>
Cc: Dan White <hdwhite@charter.net>, "Craigie, Kay, N3KN" <n3kn@verizon.net>, David Woolweaver <k5rav@ix.netcom.com>, "Stratton, John, N5AUS" <jrs@hamradio.us.com>, Rick Roderick <k5ur@aol.com>, Terry Gerdes <ab5k@hotmail.com>, "aa5au@bellsouth.net" <aa5au@bellsouth.net>, "aflowers@frontiernet.net" <aflowers@frontiernet.net>, "K3LR@K3LR.com" <K3LR@K3LR.com>, "n9nc@earthlink.net" <n9nc@earthlink.net>, "n3llr@arrl.org" <n3llr@arrl.org>, "w3tom@arrl.org" <w3tom@arrl.org>, "w9gig@arrl.com" <w9gig@arrl.com>,
"w9xa@arrl.org" <w9xa@arrl.org>, "k0gw@arrl.org" <k0gw@arrl.org>, "ka0ldg@arrl.org" <ka0ldg@arrl.org>, "k5uz@arrl.org" <k5uz@arrl.org>, "wb4rhq@arrl.org" <wb4rhq@arrl.org>, "k8je@arrl.org" <k8je@arrl.org>, "wa8efk@arrl.org" <wa8efk@arrl.org>, "n2ybb@arrl.org" <n2ybb@arrl.org>, "w2udt@arrl.org" <w2udt@arrl.org>, "k0ca@arrl.org" <k0ca@arrl.org>, "k0das@arrl.org" <k0das@arrl.org>, "k1ki@arrl.org" <k1ki@arrl.org>, "k1twf@arrl.org" <k1twf@arrl.org>, "k7cex@arrl.org"
<k7cex@arrl.org>, "ab7zq@arrl.org" <ab7zq@arrl.org>, "w6rgg@arrl.org" <w6rgg@arrl.org>, "k6jat@arrl.org" <k6jat@arrl.org>, "w4pwf@arrl.org" <w4pwf@arrl.org>, "n2zz@arrl.org" <n2zz@arrl.org>, "wy7fd@arrl.org" <wy7fd@arrl.org>, "n5zgt@arrl.org" <n5zgt@arrl.org>, "k4ac@arrl.org" <k4ac@arrl.org>, "aa6ml@arrl.org" <aa6ml@arrl.org>, "n6aa@arrl.org" <n6aa@arrl.org>, "n6vi@arrl.org" <n6vi@arrl.org>, "k5rav@arrl.org" <k5rav@arrl.org>, "jrs@hamradio.us.com" <jrs@hamradio.us.com>, W4TV Joe
Subich <lists@subich.com>, "n9nc@earthlink.net" <n9nc@earthlink.net>
Subject: Re: Rick Roderick's position
Dear ARRL Board of Directors, and other colleagues:
As a technical expert in wireless communications, a life member of the ARRL, a
past member of the FCC TAC, and as a past testifying expert in spectrum
matters before the US Congress, I urge you to immediately reconsider the
technical and political damage that RM-11708 will do (and is already doing) to
the hobby that all of us love.
I read the recent ARRL board of directors minutes from late March, and was
appalled to read section 4.2.4, where it was stated that those who disagree
with the rulemaking simply do not understand it. I spent over a week dialoging
by email with k1zz in mid-
March, but he refused to admit or consider the technical points below.
Thus, I now take these issues to the elected ARRL board for immediate
consideration, and I encourage others in the amateur community to do likewise.
A voluntary bandplan for RM-11708, as suggested by the ARRL in the CW-only
subbands, is not workable from a technical standpoint, as the ARRL's proposed
wideband data signals have 8 to 14 times the bandwidth of incumbent CW and RTTY
signals that are currently lawfully protected by the FCC from wider band SSB
signals.
If bandplans were workable for what is being proposed in RM-11708, the FCC
would have allowed CW and SSB stations to share all ham frequencies, and would
never have created a CW- only protected subband at the lower end of each HF
band (this protection stems from the FCC limit of 300 baud).
The ARRL proposal for rulemaking is simply promoting the introduction of SSB-
like data signals into the CW-only bands.
The proposed removal of the 300 baud limit destroys the interference protection
that incumbent RTTY, PSK31, and CW users currently enjoy and rely upon, since
an increase in baud rate and increase in bandwidth, as proposed by the ARRL in
RM-11708, increases the power spectral density (watts/Hz) in a radiated signal
within a given bandwidth, especially when M-ary keying is used. That is,
multilevel keying can allow extremely high baud rates, and very high (and
nearly uniform) power spectral densities (e.g., they become very strong
wideband interference).
The ARRL's
proposed RM-11708 would allow unlimited baud rates in a 2.8 kHz bandwidth,
creating digital interference signals with as much (and in fact much more)
interference
than is produced by SSB signals. The unlimited baud rate creates very dense
spectral interference over a wider bandwidth of 2.8 khz, and this will clobber
many CW or RTTY users trying to share a 2.8 kHz slice of spectrum.
Bandplanning simply cannot be done with such disparity of bandwidths, where
the newly proposed wideband data signals, when operated at baud rates greater
than 300 baud, will produce much greater interference and over a much wider
bandwidth than the incumbent CW and RTTY users.
In short, these proposed wide-band (2.8 kHz)
Data signals,with unlimited baud rates, will run roughshod over the vulnerable
narrowband signals (<500Hz bandwidth) of CW and RTTY/narrowband data--- that's
why the FCC deliberately protects narrowband users with the 300 baud limit at the
low end of the HF bands.
You see, the 300 baud limit is a very real protection mechanism designed
specifically to limit the power spectral density of all users in the CW-only
bands. The 300 baud law practically limits useable signals to about 500 Hz in
the low portion of the band. Wider band signals that are currently required by
law to remain below 300 baud are simply too inefficient and not commercially
viable to find use, hence the FCC was very wise to naturally protect narrowband
RTTY and CW users through the 300 baud limit. Wider-band signals, when operated
below 300 baud, do not appreciably interfere with today's CW and RTTY users due
to lower power spectral density. The baud rate is the key protector for
narrowband operations.
Removing the baud rate while simultaneously increasing the signal bandwidth
unleashes much greater interference, through higher power spectral densities,
over the wider bandwidths of 2.8 kHz. Regrettably for all incumbent CW and RTTY
users, this is precisely what RM-11708 proposes to do.
The ARRL is blatantly trying to remove the 300 Baud limit, which is the key to
protecting narrowband incumbent CW and RTTY/PSK31 users in the Lower portion of
the HF bands. And at the same time, the ARRL is trying to widen the channel
bandwidth to a SSB-like channel bandwidth within in the CW-only protected bands.
This flawed rulemaking is thus an end run on the existing FCC rules that
protect the CW-only subbands from SSB users.
This proposed new wide band data interference (without the limit of 300 baud)
will be as bad or worse than the interference of SSB signals operating in the
CW-only sub-bands.
Let there be no misunderstanding-- the above is completely factual from a
communications engineering perspective. Those who understand basic
communications theory are not missing this, and many of us have gone to great
lengths to explain this to leaders at ARRL. But the ARRL is continuing to
ignore us and these technical facts, at the detriment of it's own members that
use CW, RTTY, and PSK31 in the lower end of the HF bands.
ARRL leadership is ignoring, misstating, and misrepresenting the facts in this
issue, both on it's website, and now in it's board minutes, as is clearly shown
in section 4.2.4 of
its recent board minutes of late March.
I urge the ARRL to immediately correct and restate its minutes so that all
sides of the RM-11708 debate, and all ARRL members and their opinions are
fairly represented, and I urge the board of directors to immediately pull
RM-11708 from further consideration at the FCC, as it lacks the needed
interference protections for incumbent CW and RTTY/PSK31 users.
The 300 baud limit is the vital narrowband protection feature to CW and
RTTY/PSK31 users that the ARRL is trying to kill off, and in doing is trying to
kill off the protected CW subbands. RM 11708 is proposing to allow wideband
SSB-like interference (only now in digital form) in the CW-only subbands.
This rulemaking proposal, and now the recent minutes in section 4.2.4, do a
disservice to all CW, RTTY, and PSK31 users who rely on their legally protected
narrowband frequencies for low power and emergency communications, or for
enjoyment of contesting, DXing, or experimentation.
To recap: The 300 baud rate limit is the key natural bandwidth and power
spectral density protection mechanism that ensures interference protections for
today's CW and RTTY users, and the ARRL should honor and properly represent the
interests of these incumbent narrowband users (and ARRL members) at the low
ends of the bands. A vast part of the ARRL membership needs the ARRL to fairly
represent them, and to kill RM-11708 in its current form, and to rework the
plan to keep the vital FCC interference protections for narrowband users in
place.
73,
Ted Rappaport
N9NB
Sent from smartphone - please forgive typos
On Apr 14, 2014, at 7:28 PM, "Sumner, Dave, K1ZZ" <dsumner@arrl.org> wrote:
Dan, the minutes note at the very beginning that Rick was delayed. Read in
their entirety the meaning is clear.
I'm sure you will make the appropriate correction. Thanks in advance.
Dave
Sent from my Verizon Wireless 4G LTE DROID
Dan White <hdwhite@charter.net> wrote:
Hi Dave,
Thanks for bringing your observations of one of my emails, not sent to you, to
my attention. Perhaps the way the EC minutes were written has created some of
the confusion.
In Item 4.2.4, the EC minutes reiterate the same old previous rhetoric that "comments received
against RM-11708 were from those who misunderstood", followed immediately by a sentence that
states "Rick Roderick arrived at this point". My interpretation of this language was
that Rick had arrived at that point of view. Perhaps, while not said, it simply meant that Rick
arrived late to the meeting. I still do not know which is the case. If it is the later is correct,
and Rick arrived at the meeting at that point, then I apologize for my misinterpretation of the
wording (or lack of wording) used, and gladly accept that Rick did not arrive at that point (of
view). That would be refreshing to hear and I hope is the case.
However, anyone that continues this entrenched, unprofessional ARRL line of thinking,
that dissenting opinions are simply from the "misinformed" is out of line in my
opinion. This is simply an opinion that should not have been included in these minutes.
All it accomplished was to stir up many of us that read the minutes.
David, the handling of this whole issue has created one enormous mess that could have been
avoided. As a long time ARRL Life Member and Maxim Society Donor, I am very displeased with
the process that has led us all to this point. This proposal throws CW & RTTY under the
bus and does absolutely nothing to address the problem with the automatic stations.
Furthermore, it raises a serious question as to what the ARRL leadership sees as the future
of amateur radio in the "Second Century." Amateur Radio is most certainly not meant
to be a personal communications service to be used to post blogs to Facebook, routinely text
your non-ham buddies, or another ISP. These are not points I wish to debate with you, they
are simply my opinions after careful study and thought.
Because of these recent minutes and their wording, I went ahead and filed written comments in
opposition to RM-11708 with the FCC this morning. I am told they will most likely look over all
comments, regardless of timing. Hopefully the FCC will put a stop to this and a fresh approach can
begin. If not, then I do hope that Rick's committee will come up with a viable
"voluntary" band plan. Since there are a number of current automatic stations operating
at bandwidths greater than 500 Hz, in total disregard for FCC 97.221, one could sure question the
"voluntary" aspect of such a plan. Both my input to Band Planning and the FCC are
attached.
Hopefully you will re-look at the minutes and consider more thorough language next time.
Also, I hope we will not see the "comments against RM-11708 were from those who
misunderstood" language used again, it is down right offensive!
As for your responding to me on an email that was not sent to you, thanks. I am
copying you, ARRL leadership and others that my email WAS sent to, with this
response. If by chance I interpreted the EC minutes incorrectly then I do
apologize for any misunderstanding my email created. I do not, however, alter
my opinions of RM-11708, or my distaste for the language that keeps getting
used by the League to describe any dissenting viewpoints. On the matter of
RM-11708, I guess we will just agree to disagree!
Looking forward to seeing you at the Dayton Donor Reception next month!
73
Dan
W5DNT
---------- Forwarded message ----------
From: "Sumner, Dave, K1ZZ" <dsumner@arrl.org>
Date: Apr 14, 2014 3:31 PM
Subject: Rick Roderick's position
Cc:
Dan, in a recent email that was shared with me you said:
Per Item 4.2.4 it appears the ARRL remains entrenched in its position
and the so called band planning will likely be more of the same, not a
real solution. Very disappointing that the ARRL thinks those of us
that don't agree "simply don't understand." Per these minutes, it
indicates that is K5UR's position. I thought he was going to give this
a fair shake, but per these minutes, I will retract that opinion
immediately.
You’re being very unfair to Rick Roderick. Please reread the item in the minutes. It
says nothing at all about Rick’s position.
His committee has more than 300 comments to consider. Neither Rick nor, to the
best of my knowledge, any other committee member has a predetermined view of
the band planning issue.
73,
Dave Sumner, K1ZZ
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