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!"
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