| Forwarded with permission of Ted as he does a much better job of putting 
ink to ether than I do. 
I've commented against RM-11708.
I'm curious what the contest community thinks as this will have an 
impact on the cw/rtty sub bands? 
Rich - N5ZC
-------- Forwarded Message --------
Subject: 	Re: [CTDXCC] Why everyone and anyone who likes/wants CW and 
RTTY needs to know 
Date:   Fri, 12 Aug 2016 21:35:55 -0400
From:   Ted <tsrwvcomm@aol.com>
To:     Richard Thorne <rthorne@rthorne.net>
I don't know that community, but you sure can forward  it - it's very 
important. 
Sent from smartphone, please excuse typos
On Aug 12, 2016, at 8:36 PM, Richard Thorne <rthorne@rthorne.net 
<mailto:rthorne@rthorne.net>> wrote: 
 
Hi Ted,
I'm curious, have you attempted to get this information to the CQ 
Contest reflector.  Are you getting any feed back from other contester's? 
I sure appreciate you driving this subject matter.
Hope all is well.
Rich - N5ZC
On 8/12/2016 11:03 AM, Ted Rappaport N9NB via CTDXCC wrote:
 
Hi y’all:
Life is short, and this great hobby has enough room for everyone!
Pactor, DX, Winlink, SSB, CW, RTTY, etc...... We can all coexist, but 
the HF spectrum is very limited, and sadly the FCC is about to sign 
into law a really grave error that will completely disrupt CW/RTTY if 
you don’t read and file comments at the FCC about NPRM 11708 and WT 
16239. We must write to both our ARRL officials at all levels, as 
well as file public comments at the FCC.
The FCC is about to make this officially law, but is taking last 
ditch comments from now (up until October 5th or so) and then during 
a one month “Reply to Comments” phase. this is our LAST CHANCE to 
really get the base of CW/RTTY users to write in to ARRL and FCC 
officials to modify this law.... NPRM RM 11708 cannot be repelled at 
this point, only modified, unless a miracle occurs and ARRL recinds 
it – not likely unless tens of thousands of us write to ARRL 
officials while also filing comments.
Here is what RM 11708 will enable, if it is passed into law as the 
FCC is proposing in its NPRM 11708 published on July 28, 2016. Note 
the FCC ignored ARRL’s request for a 2.8 kHz bandwidth to replace the 
300 baud limit, and instead is proposing an **unlimited** bandwidth 
limit with no baud rate limit. Unfortunately, neither the ARRL or FCC 
have recognized the resulting interference that will occur to the 
narrowband CW and RTTY users, and have never once considered a 200 Hz 
bandwidth emission limit on the lower 50 kHz and 500 Hz emission 
bandwidth limit on the lower 100 kHz of every HF band (That is what 
is needed for protection, and we must write in by the tens of 
thousands!!! To ARRL and to FCC! See footnote 37in their July NPRM, 
very short shrift given to this argument!). Here is what will happen 
if CW/RTTY apathy continues: 
1. SSB and voice operations will be freely allowed in all the 
CW/Data/RTTY segments of HF with unlimited bandwidth,as long as the 
signals are digitized into data first. This opens up the CW/RTTY 
lower end HF bands to digitized voice using 12.5khz c4fm stations, 
since the FCC has not proposed a bandwidth limitation. And this is 
not a conspiricy theory, its real. 
2. If the rule passes without any bandwidth limit, or with the ARRL’s 
suggested 2.8 kHz bandwidth limit on the low end, Pactor will be 
permitted and conversations will be encrypted as part of the 
protocol.  And if there were to be a way to listen in, it’s going to 
require a the purchase of a Pactor 4 modem which is not cheap.  
Meaning you have no ability to identify the call sign of a station 
short of engaging in a Pactor 4 based conversation. No way for OO’s 
to find offending station since no CW id is needed. 
3. A lot of the Automatic Data stations (the auto repeaters that are 
already causing great QRM) are tied in with the watercraft and 
boating crowd. Which means the stations would ring the coastline 
using new data services in the CW/Data part of the band to log into 
Facebook, check weather, and make dinner reservations.  So unless you 
are beaming north, you are going to be pointing toward one of those 
stations.
4. At about 2.4 Khz per station for Pactor 4, and with MANY more 
stations active (the P4 speeds make email via HF a lot faster and 
less painful, which will drive more users after this NPRM is 
legalized), it won’t take much to swamp all the traditional RTTY 
segment.  That pushes the RTTY guys down into the top of the CW 
segment. And not to even mention digitized voice signals that will be 
allowed there, too!
No matter how you slice it, that means trouble for the RTTY operators 
up front, and more congestion for the CW bands as a result.  Of 
course the SSB guys having defeated essentially the same proposal 10 
years ago (ARRL TRIED TO PASS RM 11306 in 2005, but rescinded it in 
2007 because the SSB operators made enough noise to get the ARRL to 
pull it from the FCC consideration---- CW and RTTY apathy has failed 
to make enough noise, and now this is about to become law). Now, it 
has gone too far, and CW/RTTY people have not been heard, and this is 
about to remove the enjoyment of our bands forever! PLEASE GET 
ACTIVE. THIS IS REAL. Please don’t take this lightly and do nothing, 
please get your CW/RTTY friends engaged. Read the NPRM!
Lets give Pactor 4 and Winlink its due at 100 kHz and above from the 
low end of HF, but lets also preserve the lowest 50 kHz for CW and 
lowest 100 kHz for RTTY by urgently requesting bandwidth limits that 
preserve CW and RTTY.
Tell your ARRL official and write in tothe FCC –we need tens of 
thousands of thoughtful responses! 
73 ted n9nb
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