I wrote the enclosed article for the August edition of my local ham club
newsletter (Radio Club of Redmond) regarding the RM-11708 proposal.
Special thanks goes to Joe Subich for allow me to quote him in my article:
*FCC advances RM-11708 to Comment Period*
By: Gordon Bousman, NW7D
After a long period of inaction, the FCC on July 28th, finally moved the
controversial RM-11708 proposed rulemaking to a 60-day comment period
(NPRM, Notice of Proposed Rulemaking). The proposal which was filed by the
ARRL back in November, 2013, was thought to be a dead issue but has now
been revived and is moving along once again through the FCC rulemaking
process.
The ARRL proposal recommended raising the current 300 baud rate limitation
to 1800 baud for HF bands (i.e. equivalent to 2.8 KHz bandwidth) for
amateur digital communications (signal bandwidth increases in conjunction
with higher baud rates). While the ARRL petition recommended a new
limitation of 2.8 KHz, apparently the FCC believes that it should remove
any baud rate (symbol rate) limitation whatsoever as reflected in their
document. The FCC argues that any bandwidth limitation would discourage
advancement in new digital technologies. This is in direct conflict with
general philosophies held in the amateur community in recent years to
support more advanced *narrow-band *digital modes.
The background on this proposal is that allegedly, the ARRL board was
convinced to make the FCC proposal in order that Pactor-4, with its 1800
baud rate could be used in the HF digital sub-bands to co-exist with RTTY.
The argument was made that Pactor-4 was useful to enable emergency
communications. However, many will argue that in the case of a true
national emergency, there are other modes that would be more efficient in
message handling compared to Pactor-4’s wide bandwidth mode especially
since it is limited for use only by operators who possess the proprietary
Pactor-4 hardware and licensed software. The ARRL proposal would have
had more merit if it were to support open-source software and restricted
from the traditional CW/Digital band segments but that is not the case in
their proposal for Pactor-4, which seems to demonstrate biased support of
expensive proprietary hardware & licensed software.
Many traditional RTTY operators were upset with the original RM-11708
proposal when it was first introduced because if implemented, the remaining
spectrum available for RTTY, PSK, JT65, etc. would be significantly reduced
thus pushing RTTY/PSK and other digital operators further down into the CW
portion of the band (thus impacting the operations of CW operators as
well). Further, unless one owns the proprietary Pactor-4 equipment (~$2K)
and purchases a license, there is no means by which to monitor the
proprietary Pactor-4 transmissions for our supposed amateur self-policing,
or even for FCC monitoring for that matter. Thus many argue that this
essentially amounts to encrypted communications within the amateur service,
which of course is strictly prohibited.
Amateurs can read the proposal at:
http://transition.fcc.gov/Daily_Releases/Daily_Business/2016/db0728/FCC-16-96A1.pdf
Comments are due by no later than September 25, 2016.
It can only be imagined that most of the major HF transceiver manufacturers
must think very poorly of this ill-thought-out proposal since nearly every
supplier touts the use of RTTY, PSK, and other digital modes with its
respective transceivers even to the point of providing on-screen decoding
of RTTY with most new transceivers.
RTTY, digital, (and CW) operators are encouraged to submit a comment to the
FCC to argue that the proposal adversely impacts the traditional use of the
CW/Digital sub-bands in order to only serve a small minority of amateur
users (who would be using encrypted Pactor-4 communications) while
negatively impacting a much larger community of CW and narrow-band digital
users (JT65, PSK, RTTY, etc.). Even the ARRL itself, which sponsors a
RTTY contest in January, would witness a negative impact during their RTTY
Roundup contest from their own proposal due to heavy Pactor-4 QRM in the
RTTY and digital sub-bands.
A compromise suggestion might be made to limit such proprietary encrypted
Pactor-4 communications and other wide-bandwidth modes to above .125 in the
bands such as 14125 Khz (or possibly even higher). It should be noted that
slow-scan TV, which can be somewhat compared to a wide-band digital
transmission, operates even much higher in the 20M band at 14230 & 14233
KHz.
An even better proposal to protect narrow-band modes was written just
recently by Joe Subich, W4TV:
“*The point that needs to be made is that symbol rate cannot be increased
independent of bandwidth. Increasing the symbol rate will automatically
increase the occupied bandwidth (and potential QRM to traditional users).
The Commission really needs to move past the 1920's regulation based on
modulation type. Once that idea of Voice/Image vs. RTTY/DATA is
eliminated, it becomes appropriate to apply a maximum bandwidth of 400 Hz
in the current "RTTY/DATA" allocations (sufficient for 45/75 baud RTTY,
PSK31/63/125, PACTOR (1), and the "narrow" versions of
Olivia/MFSK/Contestia/DominoEX/etc.) and a bandwidth limitation of 2.7 KHz
(as is the case on 60 Meters) in the rest of the HF bands below 29.5 MHz
with a specific (6 KHz) exception for traditional double sideband AM).
Eliminating the outdated Voice/Image vs. RTTY/DATA distinction is not a
blanket bandwidth limit or a limitation on symbol rated but it protects
users of narrow bandwidth modes against uncontrolled interference while
allowing continued development of higher speed, wider bandwidth digital
modes in the rest of the bands - with the exception of 30 meters (which has
no "wide" segment) and 60 meters where only specific modes are permitted*.”
(Joe Subich, W4TV)
As an amateur who was inactive for many years, I was attracted back into
our hobby primarily due to the unique digital modes of computerized RTTY
and PSK. I fear that this poorly thought out proposal is going to
detrimental to a large majority of our members (narrow-band Digital and CW
operators) only so that a minority population of amateur users can operate
their encrypted Pactor-4 wide-band mode in the midst of our already jammed
narrow-band digital and CW sub-bands. The ARRL does some wonderful things
for our hobby, but they failed to thoroughly consider the adverse impact to
a majority of its members via this proposal. I urge you to submit a
comment to the FCC opposing this very poorly thought out proposal and
instead constructively suggest a restricted narrow-bandwidth band segment
for CW and narrow-width digital work...and if Pactor-4 has to be absolutely
allowed, at least keep it above the CW/Digital portions of our precious
bands in order that there is not QRM mayhem. To submit a comment about
this proposal, go to https://www.fcc.gov/ecfs/filings and search for
RM-11708.
Current comments can be read at:
https://www.fcc.gov/ecfs/search/filings?proceedings_name=RM-11708&sort=date_disseminated,DESC
Gordon Bousman, NW7D
(*The opinions expressed in this article are solely that of the author and
do not necessarily reflect the opinion or position of the Radio Club of
Redmond or any other organization—except for possibly nearly every current
RTTY, PSK, JT65, and possibly many CW operators).*
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