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Re: [RTTY] ARRL attack on current RTTY users

To: Dave AA6YQ <aa6yq@ambersoft.com>
Subject: Re: [RTTY] ARRL attack on current RTTY users
From: "Joe Subich, W4TV" <lists@subich.com>
Date: Sun, 24 Nov 2013 11:55:33 -0500
List-post: <rtty@contesting.com">mailto:rtty@contesting.com>

> In messaging systems like WinLink, users activate an unattended
> server. For this to work, users must know on what frequencies to
> call.

Looking at the Channel list on the Winlink2000 web site and listing *only PACTOR RMS servers* <http://www.winlink.org/RMSChannels> shows *59* frequencies "advertised" for 24 hour a day operation by *US* *stations* outside the frequencies authorized for automatic control
in 97.221.  That tells me that those *30 FCC licensees* are operating
automatically controlled stations outside the parameters of 97.221.

Some of these posted "watch" frequencies - places the systems will
respond to callers - include areas such as 7060-7100 KHz (19 systems -
including four systems in the 7076-7080 JT65/JT9 "center of activity"),
10122-10140 KHz (11 systems - including three systems each in the PSK31
and JT65 "centers of activity"),  14060-14080 KHz (7 systems), and
18097-18105 KHz (5 systems).

I have not investigated the "Winmor" software protocols but I see many
listed operating ("watch") frequencies outside the "automatic control"
bands with 24 hour a day operation ... and those are only the "public"
systems.

73,

   ... Joe, W4TV


On 11/24/2013 10:53 AM, Dave AA6YQ wrote:
In messaging systems like WinLink, users activate an unattended server. For 
this to work, users must know on what frequencies to
call.

See, for example,

<http://www.qsl.net/ve3lki/RMS/index.html>

Being Canadian, this station is not subject to 97.221; some of the frequencies it 
advertises are outside the "automatic control"
segments defined in 97.221.

     73,

            Dave, AA6YQ

-----Original Message-----
From: Joe Subich, W4TV [mailto:lists@subich.com]
Sent: Sunday, November 24, 2013 9:28 AM
To: Dave AA6YQ
Cc: rtty@contesting.com
Subject: Re: [RTTY] ARRL attack on current RTTY users




On 11/23/2013 8:58 PM, Dave AA6YQ wrote:
Your message is the first I've heard of automatically controlled stations 
ignoring the 500 hz bandwidth limitation within the
sub-bands specified by 97.221.

It's not just in the sub-bands defined by 97.221 ... it's where ever
the auto-responding systems are called.

  > Is this anecdotal, or is there hard evidence of this behavior?

Well, it's a little difficult to have callsigns and times since the
PACTOR protocol is proprietary, SCS refuses to publish it, and it
is impossible to decode without spending $2000 for one of SCS's
hardware modems.  However, he sudden appearance of the "burping,"
wide, noise like signal on top of narrow bandwidth QSOs is a good
indication of this behavior.

73,

     ... Joe, W4TV


         73,

               Dave, AA6YQ

-----Original Message-----
From: Joe Subich, W4TV [mailto:lists@subich.com]
Sent: Saturday, November 23, 2013 8:50 PM
To: Dave AA6YQ
Cc: rtty@contesting.com
Subject: Re: [RTTY] ARRL attack on current RTTY users


   > How is it different than an automatically controlled station as
   > described in 97.221?

A "scanning auto-responder" is a station described by 97.221 (c)(1).

However, operators of such systems claim they are not automatically
controlled (they are "controlled" by the interrogating station) and
thus not subject to 97.221 - including the bandwidth limitation.

73,

      ... Joe, W4TV


On 11/23/2013 8:21 PM, Dave AA6YQ wrote:
What's a "scanning auto-responder"? How is it different than an automatically 
controlled station as described in 97.221?

<http://www.w5yi.org/page.php?id=136>

          73,

                   Dave, AA6YQ


-----Original Message-----
From: RTTY [mailto:rtty-bounces@contesting.com] On Behalf Of Joe Subich, W4TV
Sent: Saturday, November 23, 2013 8:07 PM
To: rtty@contesting.com
Subject: Re: [RTTY] ARRL attack on current RTTY users


    > Has anyone reached a different conclusion?

The scanning "auto-responders" are not considered to be automatically
controlled.  That one reason they can pop-up anywhere "RTTY, data"
emissions are authorized.  The 500 Hz bandwidth does not apply to
them - and is routinely ignores by "automatically controlled" stations
in the "automatic control" sub-bands.

ARRL's assertion that "there is no proposal herein to change" rings
hollow because most of the PACTOR systems are not technically operated
under the "automatic control" rules.

73,

       ... Joe, W4TV


On 11/23/2013 7:45 PM, Dave AA6YQ wrote:
Section II.8 of

<http://www.arrl.org/files/media/News/Petition%20for%20Rule%20Making%20AS-FILED%2011%2015%202013.pdf>

restates the 500 hertz bandwidth limit on automatically controlled stations 
operating in the HF subbands specified by 97.221.
Footnote 11 says "there is no proposal herein to change the nominal bandwidth 
limitation for automatically controlled stations
transmitting data emissions".

Thus the ARRL's proposal would if adopted not result in any expansion in either 
the bandwidth or HF spectrum available to
automatically controlled stations.

Has anyone reached a different conclusion?

           73,

                  Dave, AA6YQ

-----Original Message-----
From: RTTY [mailto:rtty-bounces@contesting.com] On Behalf Of Kai
Sent: Saturday, November 23, 2013 6:21 PM
To: rtty@contesting.com
Subject: Re: [RTTY] ARRL attack on current RTTY users

John,
The appropriate course of action now would be to file comments about the ARRL
proposal (and just the proposal).
One approach may be, a step by step effort to defeat any BW greater than 2,200 
Hz::
(1) To keep the status quo, the BW should be 2,200 Hz.  That excludes no one,
adds no one, and keeps all current modes as before; allows for future innovation
and experimentation.
(2) That means 2800 is clearly outside the mainstream -- we must demonstrate now
that 2800 would injure current users without any real benefits.
[this is reasonable in view of the ARRL proposal, and stands a chance of 
prevailing]

if you want to go further, and alternative argument is:

(3) Current RTTY limit (up to 300 B, and 1 kHz T sep) requires just 1,500 Hz.
That satisfies everything including PACTOR-III-SL1.
Perhaps that's a rock bottom figure because it results in small reductions in
current amateur privileges, maybe not so bad except for the
PACTOR-III modes SL2-6. Then follow up with (2) again, that 2800 Hz will cause
harm.
[this one we think is reasonable, but it injures other current users, so less
chance of prevailing]

So I can see a clear case for 2,200 Hz, and a good case for 1,500 Hz.  But I can
not see a viable case for much below 1,500 Hz.
The another important thrust would be to demonstrate that anything greater than
2200 Hz belongs up there with image emissions and in the 60 m band channels
(where 2800 is already legal) because it is incompatible with amateur usage and
practice in the CW/digi frequencies.

73
Kai, KE4PT

On 11/23/2013 5:09 PM, John Grimm wrote:
I am in the process of drafting my comments.  Like Jim, I would appreciate even 
a bullet list of topics/issues which are deemed
important to include in those comments.  This would be very helpful to me as 
I've never filed comments before.

John / K0YQ

Message: 3
Date: Sat, 23 Nov 2013 13:36:05 -0600
From: "Jim N7US"<jim@n7us.net>
To:<rtty@contesting.com>
Subject: Re: [RTTY] ARRL attack on current RTTY users
Message-ID:<025601cee883$4168a560$c439f020$@net>
Content-Type: text/plain;       charset="us-ascii"

Would it be productive if a committee of "The Knowledgeable" got together to
draft an effective, succinct email to the ARRL directors that includes the
key problems with the proposal?  Each of us could either copy and paste it
in an email to our respective directors or modify/personalize it before
doing so.  It should include the impact on all modes and activities, not
only RTTY.

I understand it's already gone to the FCC, so responding to that is a
separate undertaking, and Don just created a web page on how to do that.  I
would think that the key points in the ARRL director email would probably be
the same ones to include in an FCC filing.

73, Jim N7US

                                        
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