True - the Commission and legislators are different animals. However,
"talking points" for those interested in filing comments against
RM-11708 cant hurt. Here is a start:
1) there is no overwhelming *need* for symbol rates greater than 300
baud and bandwidths up to 2.8 KHz in the amateur service.
2) 99% of all non-voice and non-image activity in the affected spectrum
is using narrow bandwidth modes (modes less than 500 Hz0
3) the frequencies impacted are already crowded - automatic and semi-
automatic RMBS operations continue to create significant interference
- witness the hours long QRM to FT5ZM on 40 meters that denied many
a once in a lifetime chance to work Amsterdam on 40 meters and the
heavy interference to RTTY contest operations during major contests
just this year alone.
4) current data operations do not have effective "channel busy"
detectors to prevent interference to other users.
5) International organizations are already complaining about the
widespread interference from the RMBS operations that would benefit
from wider bandwidth See:
<http://uska.ch/fileadmin/download/iaru/interim_meetings/vienna2013/VIE13-C4-04_NRL.pdf>
6) The only protocol that would *benefit* from increasing the symbol
rate is PACTOR 4 which uses encryption and can not be decoded by
individual users or ARRL Official Observers without spending
several thousand dollars on proprietary hardware from one German
company.
7) The only use for these higher symbol rates is to create a private
internet access system to allow users to bypass satellite or
commercial maritime internet access charges.
8) For more than 80 years the Commission has had a policy of protecting
narrow bandwidth modes against interference from wide bandwidth modes
- see paragraph 19 and footnote 89 on page 12 here:
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-149A1.pdf>
9) RM-11708 fixes one small problem - there is no current bandwidth
limit for digital modes - but creates a whole host of unintended
consequences. The current lack of a bandwidth limit is due to the
*inability* of anyone to foresee digital modes which used multiple
tones or high baud rates with "channel equalization" when the
current 300 baud limit was instituted. The original limit for
FSK (300 baud and 1000 Hz shift represented a de facto 1500 Hz
bandwidth) and was never extended to cover multiple tone modes
like PACTOR 3.
10) The "unintended consequences" of RM-11708 are worse than the
remote possibility that someone will develop and popularize a
multi-tone protocol with 300 baud symbol rate that occupies
several KHz.
11) The Commission should consider adjusting the rules to allow
RTTY and DATA on all frequencies where CW is currently permitted
and limit the bandwidth to 400 or 500 Hz in the areas currently
allocated for "narrow bandwidth" modes. This would limit the
bandwidth of data emissions to 2.8 KHz ("communications quality"
voice) in the "phone bands" - 97.307(f)(2) and provide a place
for current PACTOR 3 to prevent "outlawing" it. This would also
allow for the growth of new mixed voice and data modes like
STANAG, MS-110 and ALE without requiring they use separate
frequencies depending on whether the "payload" is digital voice
or text.
12) The Commission should modify the rules to require than all
amateur protocols be fully documented - including data compression,
modulation and encoding - and prohibit the user of proprietary
protocols such as AMBE or PACTOR 4 that require purchasing hard-
ware or a software license from a specific vendor.
13) The commission should specifically prohibit encryption of any
nature, prohibit variable key encoding, require all encoding keys
to be public (and published).
73,
... Joe, W4TV
On 4/16/2014 5:45 PM, Ron Kolarik wrote:
Paul the FCC and ARRL are different critters than legislators. There was
a recent
RM from the ARRL that got flooded with form responses and when it was
pointed
out to the commission they were not real happy campers.....they even made a
footnote about the source in the denial.
Ron
K0IDT
----- Original Message ----- From: "paul ecker" <eckerpw@yahoo.com>
To: <rtty@contesting.com>
Sent: Wednesday, April 16, 2014 3:08 PM
Subject: [RTTY] Suggested RM-11708 Letter Needed
Message: 6
Date: Wed, 16 Apr 2014 14:57:16 -0500
From: "Jeff AC0C" <keepwalking188@ac0c.com>
To: "paul ecker" <eckerpw@yahoo.com>, <rtty@contesting.com>
Subject: Re: [RTTY]
Message-ID: <9A0D1B36787742208B4A91FCF6EDF108@w520>
Content-Type: text/plain; format=flowed; charset="iso-8859-1";
reply-type=original
Well- OK but I think at minimum you need to promulgate some principle
talking points that folks should include in their submission.
Jeff- I understand your point but; Just as an aside "Form" letters from
thousands if not millions of Veterans have stopped many pieces of
onerous legislation in their tracks. Politicians listen to numbers, not
sure why ARRL or FCC wouldn't. It seems to me we are at the point of
pulling out all stops. Why play by their rules.
73 Paul
Paul,
The problem is the FCC does not like form letters - they consider it spam.
And the ARRL will want to lump a form letter from X-number of guys into one
as well.
It's best if you write it out just like you have it here, from the heart.
It would count more for either audience.
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