Below is an open letter that I have written to the ARRL board of directors - it
appears below.
Please feel free to propagate this far and wide, and to add other technical
opinions, because these points must see the light of day!
We need others to actively write all ARRL directors, and to file comments at
the FCC website (late
Comments are still being accepted and DO matter!)
Please go on record at the FCC to stop this blatant attack on the protected low
end of the HF bands.
We need major activism, as the lobby group pushing RM11708 within the ARRL is
firm on their talking points (see the ARRL website) that completely ignore and
improperly characterize the vital technical issues below.
Please, I urge all hams interested in the continued enjoyment of CW, PSK31,
and RTTY to become active, to immediately file public comments at the FCC, and
to send your comments to all ARRL board members, whose emails appear below.
Imagine if you were a SSB operator, and all of a sudden the ARRL pushed a rule
making that would instantly introduce new SSTV signals with 25 khz bandwidths,
8 to 14 times the bandwidth of incumbent SSB signals. This is what is being
proposed for the CW and RTTY operators in the narrowband data portions of the
band.
Ham radio needs concerned members to immediately respond to the FCC comments
section, and to let ARRL board members know of our concern, and the facts of
this rule making that is consistently being ignored by many at the ARRL.
Thanks for the bandwidth. And more importantly, thanks in advance for your
activism- your hobby needs you like never before!
73,
Ted
Sent from smartphone - please forgive typos
Begin forwarded message:
> From: Ted Rappaport <tedrappaport@verizon.net>
> Date: April 15, 2014 1:22:03 AM EDT
> To: "Sumner, Dave, K1ZZ" <dsumner@arrl.org>
> Cc: Dan White <hdwhite@charter.net>, "Craigie, Kay, N3KN" <n3kn@verizon.net>,
> David Woolweaver <k5rav@ix.netcom.com>, "Stratton, John, N5AUS"
> <jrs@hamradio.us.com>, Rick Roderick <k5ur@aol.com>, Terry Gerdes
> <ab5k@hotmail.com>, "aa5au@bellsouth.net" <aa5au@bellsouth.net>,
> "aflowers@frontiernet.net" <aflowers@frontiernet.net>, "K3LR@K3LR.com"
> <K3LR@K3LR.com>, "n9nc@earthlink.net" <n9nc@earthlink.net>, "n3llr@arrl.org"
> <n3llr@arrl.org>, "w3tom@arrl.org" <w3tom@arrl.org>, "w9gig@arrl.com"
> <w9gig@arrl.com>, "w9xa@arrl.org" <w9xa@arrl.org>, "k0gw@arrl.org"
> <k0gw@arrl.org>, "ka0ldg@arrl.org" <ka0ldg@arrl.org>, "k5uz@arrl.org"
> <k5uz@arrl.org>, "wb4rhq@arrl.org" <wb4rhq@arrl.org>, "k8je@arrl.org"
> <k8je@arrl.org>, "wa8efk@arrl.org" <wa8efk@arrl.org>, "n2ybb@arrl.org"
> <n2ybb@arrl.org>, "w2udt@arrl.org" <w2udt@arrl.org>, "k0ca@arrl.org"
> <k0ca@arrl.org>, "k0das@arrl.org" <k0das@arrl.org>, "k1ki@arrl.org"
> <k1ki@arrl.org>, "k1twf@arrl.org" <k1twf@arrl.org>, "k7cex@arrl.org"
> <k7cex@arrl.org>, "ab7zq@arrl.org" <ab7zq@arrl.org>, "w6rgg@arrl.org"
> <w6rgg@arrl.org>, "k6jat@arrl.org" <k6jat@arrl.org>, "w4pwf@arrl.org"
> <w4pwf@arrl.org>, "n2zz@arrl.org" <n2zz@arrl.org>, "wy7fd@arrl.org"
> <wy7fd@arrl.org>, "n5zgt@arrl.org" <n5zgt@arrl.org>, "k4ac@arrl.org"
> <k4ac@arrl.org>, "aa6ml@arrl.org" <aa6ml@arrl.org>, "n6aa@arrl.org"
> <n6aa@arrl.org>, "n6vi@arrl.org" <n6vi@arrl.org>, "k5rav@arrl.org"
> <k5rav@arrl.org>, "jrs@hamradio.us.com" <jrs@hamradio.us.com>, W4TV Joe
> Subich <lists@subich.com>, "n9nc@earthlink.net" <n9nc@earthlink.net>
> Subject: Re: Rick Roderick's position
>
> Dear ARRL Board of Directors, and other colleagues:
>
> As a technical expert in wireless communications, a life member of the ARRL,
> a past member of the FCC TAC, and as a past testifying expert in spectrum
> matters before the US Congress, I urge you to immediately reconsider the
> technical and political damage that RM-11708 will do (and is already doing)
> to the hobby that all of us love.
>
> I read the recent ARRL board of directors minutes from late March, and was
> appalled to read section 4.2.4, where it was stated that those who disagree
> with the rulemaking simply do not understand it. I spent over a week
> dialoging by email with k1zz in mid-
> March, but he refused to admit or consider the technical points below.
>
> Thus, I now take these issues to the elected ARRL board for immediate
> consideration, and I encourage others in the amateur community to do likewise.
>
> A voluntary bandplan for RM-11708, as suggested by the ARRL in the CW-only
> subbands, is not workable from a technical standpoint, as the ARRL's proposed
> wideband data signals have 8 to 14 times the bandwidth of incumbent CW and
> RTTY signals that are currently lawfully protected by the FCC from wider band
> SSB signals.
>
> If bandplans were workable for what is being proposed in RM-11708, the FCC
> would have allowed CW and SSB stations to share all ham frequencies, and
> would never have created a CW- only protected subband at the lower end of
> each HF band (this protection stems from the FCC limit of 300 baud).
>
> The ARRL proposal for rulemaking is simply promoting the introduction of SSB-
> like data signals into the CW-only bands.
>
> The proposed removal of the 300 baud limit destroys the interference
> protection that incumbent RTTY, PSK31, and CW users currently enjoy and rely
> upon, since an increase in baud rate and increase in bandwidth, as proposed
> by the ARRL in RM-11708, increases the power spectral density (watts/Hz) in a
> radiated signal within a given bandwidth, especially when M-ary keying is
> used. That is, multilevel keying can allow extremely high baud rates, and
> very high (and nearly uniform) power spectral densities (e.g., they become
> very strong wideband interference).
>
> The ARRL's
> proposed RM-11708 would allow unlimited baud rates in a 2.8 kHz bandwidth,
> creating digital interference signals with as much (and in fact much more)
> interference
> than is produced by SSB signals. The unlimited baud rate creates very dense
> spectral interference over a wider bandwidth of 2.8 khz, and this will
> clobber many CW or RTTY users trying to share a 2.8 kHz slice of spectrum.
>
> Bandplanning simply cannot be done with such disparity of bandwidths, where
> the newly proposed wideband data signals, when operated at baud rates greater
> than 300 baud, will produce much greater interference and over a much wider
> bandwidth than the incumbent CW and RTTY users.
>
> In short, these proposed wide-band (2.8 kHz)
> Data signals,with unlimited baud rates, will run roughshod over the
> vulnerable narrowband signals (<500Hz bandwidth) of CW and RTTY/narrowband
> data--- that's why the FCC deliberately protects narrowband users with the
> 300 baud limit at the low end of the HF bands.
>
> You see, the 300 baud limit is a very real protection mechanism designed
> specifically to limit the power spectral density of all users in the CW-only
> bands. The 300 baud law practically limits useable signals to about 500 Hz in
> the low portion of the band. Wider band signals that are currently required
> by law to remain below 300 baud are simply too inefficient and not
> commercially viable to find use, hence the FCC was very wise to naturally
> protect narrowband RTTY and CW users through the 300 baud limit. Wider-band
> signals, when operated below 300 baud, do not appreciably interfere with
> today's CW and RTTY users due to lower power spectral density. The baud rate
> is the key protector for narrowband operations.
>
> Removing the baud rate while simultaneously increasing the signal bandwidth
> unleashes much greater interference, through higher power spectral densities,
> over the wider bandwidths of 2.8 kHz. Regrettably for all incumbent CW and
> RTTY users, this is precisely what RM-11708 proposes to do.
>
> The ARRL is blatantly trying to remove the 300 Baud limit, which is the key
> to protecting narrowband incumbent CW and RTTY/PSK31 users in the Lower
> portion of the HF bands. And at the same time, the ARRL is trying to widen
> the channel bandwidth to a SSB-like channel bandwidth within in the CW-only
> protected bands.
>
> This flawed rulemaking is thus an end run on the existing FCC rules that
> protect the CW-only subbands from SSB users.
>
> This proposed new wide band data interference (without the limit of 300 baud)
> will be as bad or worse than the interference of SSB signals operating in the
> CW-only sub-bands.
>
> Let there be no misunderstanding-- the above is completely factual from a
> communications engineering perspective. Those who understand basic
> communications theory are not missing this, and many of us have gone to great
> lengths to explain this to leaders at ARRL. But the ARRL is continuing to
> ignore us and these technical facts, at the detriment of it's own members
> that use CW, RTTY, and PSK31 in the lower end of the HF bands.
>
> ARRL leadership is ignoring, misstating, and misrepresenting the facts in
> this issue, both on it's website, and now in it's board minutes, as is
> clearly shown in section 4.2.4 of
> its recent board minutes of late March.
>
> I urge the ARRL to immediately correct and restate its minutes so that all
> sides of the RM-11708 debate, and all ARRL members and their opinions are
> fairly represented, and I urge the board of directors to immediately pull
> RM-11708 from further consideration at the FCC, as it lacks the needed
> interference protections for incumbent CW and RTTY/PSK31 users.
>
> The 300 baud limit is the vital narrowband protection feature to CW and
> RTTY/PSK31 users that the ARRL is trying to kill off, and in doing is trying
> to kill off the protected CW subbands. RM 11708 is proposing to allow
> wideband SSB-like interference (only now in digital form) in the CW-only
> subbands.
>
> This rulemaking proposal, and now the recent minutes in section 4.2.4, do a
> disservice to all CW, RTTY, and PSK31 users who rely on their legally
> protected narrowband frequencies for low power and emergency communications,
> or for enjoyment of contesting, DXing, or experimentation.
>
> To recap: The 300 baud rate limit is the key natural bandwidth and power
> spectral density protection mechanism that ensures interference protections
> for today's CW and RTTY users, and the ARRL should honor and properly
> represent the interests of these incumbent narrowband users (and ARRL
> members) at the low ends of the bands. A vast part of the ARRL membership
> needs the ARRL to fairly represent them, and to kill RM-11708 in its current
> form, and to rework the plan to keep the vital FCC interference protections
> for narrowband users in place.
>
> 73,
> Ted Rappaport
> N9NB
>
> Sent from smartphone - please forgive typos
>
> On Apr 14, 2014, at 7:28 PM, "Sumner, Dave, K1ZZ" <dsumner@arrl.org> wrote:
>
>> Dan, the minutes note at the very beginning that Rick was delayed. Read in
>> their entirety the meaning is clear.
>>
>> I'm sure you will make the appropriate correction. Thanks in advance.
>>
>> Dave
>>
>>
>> Sent from my Verizon Wireless 4G LTE DROID
>>
>>
>> Dan White <hdwhite@charter.net> wrote:
>>
>> Hi Dave,
>>
>> Thanks for bringing your observations of one of my emails, not sent to you,
>> to my attention. Perhaps the way the EC minutes were written has created
>> some of the confusion.
>>
>> In Item 4.2.4, the EC minutes reiterate the same old previous rhetoric that
>> "comments received against RM-11708 were from those who misunderstood",
>> followed immediately by a sentence that states "Rick Roderick arrived at
>> this point". My interpretation of this language was that Rick had arrived at
>> that point of view. Perhaps, while not said, it simply meant that Rick
>> arrived late to the meeting. I still do not know which is the case. If it is
>> the later is correct, and Rick arrived at the meeting at that point, then I
>> apologize for my misinterpretation of the wording (or lack of wording) used,
>> and gladly accept that Rick did not arrive at that point (of view). That
>> would be refreshing to hear and I hope is the case.
>>
>> However, anyone that continues this entrenched, unprofessional ARRL line of
>> thinking, that dissenting opinions are simply from the "misinformed" is out
>> of line in my opinion. This is simply an opinion that should not have been
>> included in these minutes. All it accomplished was to stir up many of us
>> that read the minutes.
>>
>> David, the handling of this whole issue has created one enormous mess that
>> could have been avoided. As a long time ARRL Life Member and Maxim Society
>> Donor, I am very displeased with the process that has led us all to this
>> point. This proposal throws CW & RTTY under the bus and does absolutely
>> nothing to address the problem with the automatic stations. Furthermore, it
>> raises a serious question as to what the ARRL leadership sees as the future
>> of amateur radio in the "Second Century." Amateur Radio is most certainly
>> not meant to be a personal communications service to be used to post blogs
>> to Facebook, routinely text your non-ham buddies, or another ISP. These are
>> not points I wish to debate with you, they are simply my opinions after
>> careful study and thought.
>>
>> Because of these recent minutes and their wording, I went ahead and filed
>> written comments in opposition to RM-11708 with the FCC this morning. I am
>> told they will most likely look over all comments, regardless of timing.
>> Hopefully the FCC will put a stop to this and a fresh approach can begin. If
>> not, then I do hope that Rick's committee will come up with a viable
>> "voluntary" band plan. Since there are a number of current automatic
>> stations operating at bandwidths greater than 500 Hz, in total disregard for
>> FCC 97.221, one could sure question the "voluntary" aspect of such a plan.
>> Both my input to Band Planning and the FCC are attached.
>>
>> Hopefully you will re-look at the minutes and consider more thorough
>> language next time. Also, I hope we will not see the "comments against
>> RM-11708 were from those who misunderstood" language used again, it is down
>> right offensive!
>>
>> As for your responding to me on an email that was not sent to you, thanks. I
>> am copying you, ARRL leadership and others that my email WAS sent to, with
>> this response. If by chance I interpreted the EC minutes incorrectly then I
>> do apologize for any misunderstanding my email created. I do not, however,
>> alter my opinions of RM-11708, or my distaste for the language that keeps
>> getting used by the League to describe any dissenting viewpoints. On the
>> matter of RM-11708, I guess we will just agree to disagree!
>>
>> Looking forward to seeing you at the Dayton Donor Reception next month!
>>
>> 73
>> Dan
>> W5DNT
>>
>>
>>
>>
>>> ---------- Forwarded message ----------
>>> From: "Sumner, Dave, K1ZZ" <dsumner@arrl.org>
>>> Date: Apr 14, 2014 3:31 PM
>>> Subject: Rick Roderick's position
>>>
>>> Cc:
>>>
>>> Dan, in a recent email that was shared with me you said:
>>>
>>>
>>>
>>>> Per Item 4.2.4 it appears the ARRL remains entrenched in its position
>>>
>>>> and the so called band planning will likely be more of the same, not a
>>>
>>>> real solution. Very disappointing that the ARRL thinks those of us
>>>
>>>> that don't agree "simply don't understand." Per these minutes, it
>>>
>>>> indicates that is K5UR's position. I thought he was going to give this
>>>
>>>> a fair shake, but per these minutes, I will retract that opinion
>>>
>>>> immediately.
>>>
>>>
>>>
>>> You’re being very unfair to Rick Roderick. Please reread the item in the
>>> minutes. It says nothing at all about Rick’s position.
>>>
>>>
>>>
>>> His committee has more than 300 comments to consider. Neither Rick nor, to
>>> the best of my knowledge, any other committee member has a predetermined
>>> view of the band planning issue.
>>>
>>>
>>>
>>> 73,
>>>
>>> Dave Sumner, K1ZZ
>>>
>>>
>>
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