There are different views about the NPRM that is discussed in the N9NB
letter. I felt it was important for the other side of the issue have
"equal time".
The following is from Dick Norton, N6AA. I think Dick's main point is that
the realistic impact of the NPRM is that Pactor IV will be legal in the USA
- just like it is throughout the rest of the world.
I will leave it to people to contact either N9NB or N6AA if you want more
information.
Thanks
Tree N6TR
DISCLAIMER
The following are my personal views on the matter, and do not represent
views of any group or organization with which I may have a connection.
I am primarily active on-the-air in contests. Most of my activity is on CW.
I have no interest in having CW overridden by interference of any kind. I
do not operate digital modes and do not operate Winlink. However, I do
believe the Winlink community provides a valuable contribution to society,
and I am pleased to share the bands with them.
With particular respect to 160-meters, I am active in most 160-meter
contests, and have made thousands of contacts on 160, including hundreds
after-the-contest from ZD8AA last year.
INTRODUCTION
I don't subscribe to the need for detailed government regulation of how
amateurs use the ham bands, something essentially only present in the USA.
In almost all other countries, the hams dynamically allocate the bands,
which results in better use of the frequencies. In the USA, we do just that
on 160 meters between CW and phone, and it works fine.
In summary, not having government dictating what happens on particular
parts of our bands will result in better use of those bands. It works that
way in all other countries, and would work fine here. I don't think
amateurs should go to the FCC for law changes, every time they would like
50 kHz more or less of phone or CW privileges, or want a change in
bandwidth. We don't need detailed government regulation.
OVERALL THESIS
All of mankind's problems are not best solved by government regulation. In
the absence of government intervention, the imagined potential-interference
issues that some appear to be concerned about will be solved by the
realities of radio communication and the marketplace. We do not need the
government to protect us.
PACTOR IV vs PACTOR III
Realistically, the only current impact of eliminating the USA's symbol-rate
limitation would be to allow US amateurs to use Pactor IV protocol
data-transmission. Pactor IV permits transmission of data at 2 to 3 times
the rate of the presently allowed Pactor III, using the same, or even
slightly less bandwidth. Pactor III does satisfy the present symbol rate
limitation, where Pactor IV does not.
There is no benefit to continuing the forcing of USA digital-mode amateurs
to use the inefficient Pactor III mode. It takes more time to send data.
Using a mode that uses less bandwidth and takes significantly less time
will result in less interference, not more.
It was strange to see that a primary threat in the minds of some, who are
suggesting contacting the FCC with adverse comments, is Pactor IV,
something that is already widely used around the world. If the use of
Pactor IV would signal the end of CW, CW would have already died.
Pactor IV is currently used by amateurs in essentially all other countries.
Amateur Radio survives.
IMAGINED WIDE-BANDWIDTH INTERFERENCE
Doomsday-scenario wide-bandwidth modes that will destroy CW communication
will not be used because they simply won't work effectively. Interference
from CW signals will render such systems useless. For an example of this,
note that Winlink systems are currently effectively shut down on active
bands during weekends with big CW contests.
FCC DOESN'T LIMIT VOICE BANDWIDTH
The FCC places no bandwidth restriction on HF voice communication, other
than the general requirement of 97.303a. Ninety-nine plus percent of
amateur SSB communication uses a minimum of bandwidth. A handful of hi-fi
hams use more, and life goes on. Another handful use AM, with a similar
impact on ham radio's survival. We do fine without a government-imposed
phone bandwidth restriction, and will do fine without a government-imposed
digital bandwidth restriction.
With this history, it seems quite unlikely that the FCC will limit digital
bandwidth.
BPL HISTORY
US government regulation did not prevent Broadband over Power Lines from
destroying shortwave radio. BPL died because it was an inferior solution to
the task of connecting people to the web. The realities of radio
communication and the marketplace killed it. Large-bandwidth HF digital
systems that interfere with CW communication will not thrive either,
because they are an inferior solution. They won't work. There is no need
for government to ban them.
LEAVE THE FCC PROPOSAL ALONE
Both components of the League's petition were not necessary. The
bandwidth-restriction part is unnecessary. There are better solutions to
this issue than those proposed by the
detailed-government-regulation-will-save-us
advocates.
The FCC's proposal to eliminate the symbol-rate restriction is a good one.
It allows immediate use of the efficient Pactor IV protocol, and it even
permits wider-band experimentation, which might be practicable in regions
where interference is not a problem, such as in Alaska during the day on
80-meters.
The rest of the world has used Pactor IV for years. Let's not overreact to
predictions of doom.
73,
Dick Norton, N6AA
On Tue, Aug 23, 2016 at 7:10 AM, James Rodenkirch <Rodenkirch_LLC@msn.com>
wrote:
> To my fellow CW, RTTY, and other narrow band digital mode users:
>
> I mentioned at the last BVARC meeting that I would provide additional
> details regarding RM-11708. I have been in contact with Ted Rappaport N9NB
> regarding this, and I would like to copy to you what he sent me:
>
> "Today's ham radio RTTY stations use a well-known signaling convention
> based
> on the baudot code, and this code uses a speed of up to 300 baud, the
> maximum signaling speed allowed in the FCC rules for HF. This coding scheme
> has a natural emission bandwidth of just under 500 HZ. A fast CW signal has
> an emission bandwidth less than 200 HZ. Psk31 uses less than 100 HZ. Jt65
> uses about 200 HZ bandwidth or so.
>
> By asking the FCC to remove the 300 baud rate limit on HF, the ARRL was
> simply asking the FCC (in their petition 11708 filed in November 2013) to
> remove an antiquated term and remove the baud rate speed limit (which was
> naturally about 500 Hz bandwidth). That seemed fair enough. But, sadly,
> the
> ARRL asked the FCC to replace the existing 300 baud rate limit with a 2.8
> kHz emission bandwidth limit, the same bandwidth limit as SSB signals!
>
> Thus, the ARRL asked the FCC in Rm 11708 to allow any data signal,
> including
> future RTTY or pactor or new wideband marine modem data signaling types to
> be introduced with up to a 2.8 kHz emission bandwidth! This would wipe out
> the narrow RTTY and CW signals of today, and hog the low end of all the HF
> bands. The ARRL tried this same thing in 2005 but in the SSB spectrum with
> its failed RM 11306. In 2007 the ARRL withdrew its petition to the FCC
> since
> hams were very upset.
>
> Unfortunately, what's really bad now about RM 11708 is that the ARRL never
> withdrew it, and last week the FCC took it as a proposed rulemaking. This
> is
> the last stage before accepted law!
>
> What is abysmal is the FCC took the ARRL's ideas of eliminating 300 baud
> limit in HF, but has tentatively ruled that any data signal may use an
> UNLIMITED bandwidth. This means wide band signals of arbitrary bandwidth
> will key up on CW and RTTY stations!
>
> A published NPRM means the FCC is about to enact it as law, so unless there
> is MASSIVE outcry to both ARRL officials and the FCC in both the commenting
> period and the "reply to comment" period, the precious HF lower
> CW/data/RTTY
> bands may be lawfully overrun by serial tone military modems and digitized
> voice signals and lots of other stuff with vicious signal bandwidths of
> 2.8,5, 10, 20 and 25 kHz!!!! Big walls of impenetrable QRM!! Good bye CW
> and
> RTTY and DX! Hello Internet and Facebook for boaters -:( "
>
> What we are asking you to do is to contact the FCC and express your
> disapproval of this proposed rule. We have until October 11, 2016 to submit
> comments and reply comments by November 10, 2016.
>
> You may submit comments, identified by WT Docket No. 16-239, by any of the
> following methods:
>
> * Federal Communications Commission's Web site:
> <http://apps.fcc.gov/ecfs/> http://apps.fcc.gov/ecfs/. Follow the
> instructions for submitting comments.[CLICK ON "SUBMIT A FILING"]
>
> * Mail: Federal Communications Commission, 445 12th Street SW.,
> Washington, DC 20554.
>
> * People with Disabilities: Contact the FCC to request reasonable
> accommodations (accessible format documents, sign language interpreters,
> CART, etc.) by email: <mailto:FCC504@fcc.gov> FCC504@fcc.gov or phone:
> 202-418-0530 or TTY: 202-418-0432.
>
> There is a 60 day " comment" period after NPRM 11708 published in the
> federal register, and then after that 60 day window, there is a further 30
> day "reply to comment" window where everyone can critique and agree or
> disagree with some of the previously filed comments.
>
> "If we are to successfully revise (it's too late to repel) this frightful
> proposal, which is in the very last stages of official approval at the
> Commission (gulp!), we must have tens of thousands of well-reasoned replies
> that specially call for bandwidth limits!!! Both during the reply period,
> and then ALSO during the Reply to Comment period, we need tens of thousands
> of comments so the FCC sees this is a problem ! Otherwise, there is no hope
> and they will accept the NPRM as written and published in July 28,2016!"
> _________________
> Topband Reflector Archives - http://www.contesting.com/_topband
>
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