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Re: [RTTY] Fwd: RE: RM-11708 Outside US

To: rtty@contesting.com
Subject: Re: [RTTY] Fwd: RE: RM-11708 Outside US
From: "Joe Subich, W4TV" <lists@subich.com>
Date: Tue, 22 Apr 2014 18:15:36 -0400
List-post: <rtty@contesting.com">mailto:rtty@contesting.com>

Of course K1ZZ spins the story again to promote the Board's misguided policies ...

> The ARRL petition simply seeks to replace the obsolete symbol rate
> limit ... with a bandwidth limit that includes the data emissions
> that are already in common use.

The proposed bandwidth limit includes *many* data emissions that are
not in "common use" and are not even permitted - specifically PACTOR 4,
STANAG, MS-110, ALE, etc.  While PACTOR 4 may never be a significant
interference problem (if RMS system operators follow the rules), the
other 2.8 KHz modes with their high symbol rates and high spectral
power density (high average power) will be an absolute disaster in
the narrow bandwidth portions of the amateur bands.  These modes are
totally new to amateur radio, have no current users and represent no
current spectrum loading in the CW/RTTY portions of the HF bands.

It is these potential interference sources that K1ZZ and the PACTOR
clique seek to ignore.  However, interference and competition for
bandwidth from these modes are the very essence of what I have been
warning are the "unintended consequences" of ARRL's ill-conceived
proposal.

Again, it is time for K1ZZ to stop minimizing the effects of RM-11708.
If ARRL want to eliminate the symbol rate, then eliminate the current
prohibition against RTTY and data modes in the wideband portions of
the HF bands, *put the wideband data modes with other wideband modes*,
ask for a reasonable 300 or 500 Hz limit for all narrowband modes
(just like the Commission imposed on narrowband *image*), ask for a
complete prohibition on all encryption and proprietary protocols, and
require that all data encoding be completely transparent.  Regulation
by bandwidth is nothing new - the FCC has practiced that concept since
AM first appeared on the scene more than 80 years ago.

It is time for K1ZZ to admit that the goal of the Board of Directors -
or at least a majority of the directors - appears to be elimination
of the separation between wideband and narrow band modes as a prelude
to Canadian style "anything goes" regulatory system.  They apparently
don't care if it destroys CW and RTTY, and K1ZZ will generate any
propaganda necessary in order to promote the boards' agenda, right,
wrong or indifferent.

Frankly it's a damn shame that none of the board have the guts to stand
up and say "this will kill amateur radio as we know it" or do anything
to derail this runaway freight train.  Without changes to RM-11708,
within five years wideband data will so choke the traditional CW and
RTTY portions of the band that the pressure to allow it anywhere (after
all "it's the same bandwidth as an SSB signal") will be unstoppable.
Before anyone can blink an eye, with wideband digital everywhere the
amateur HF spectrum will be overrun with de facto encrypted (using non-
standard encoding) STANAG, MS-110, ALE and derivative modes with no way
for the ARRL OOs or the FCC to know who is transmitting and what is
being transmitted.

That, my friends, will be the end of amateur radio - all because a
couple of PACTOR 4 zealots do not care about the unintended
consequences of their short sightedness and the rest of the board
isn't willing to stand up and say "wait a minute!"  The technology
is available for all of the unintended consequences *today* - unlike
the nebulous multi-tone, 300 baud wideband SDR based signal K1ZZ
likes to point to as a reason for 2.8 KHz instead of 300 baud limit.
However, it is the very 30 baud limit ARRL seeks to eliminate that
prevents the *immediate deployment* of these other technologies and
modes.

73,

   ... Joe, W4TV


On 4/22/2014 5:02 PM, Dick Flanagan wrote:
[Forwarded with permission]

On 2014-04-21 10:43 AM, Sumner, Dave, K1ZZ wrote:

Gerry,

I see that your comments are among those received by the ARRL HF Band
Planning Committee, so as an ARRL member you have not been
disenfranchised. As far as FCC comments are concerned, the comment
deadline was last December 23 and the deadline for reply comments was
15 days later. There has been no extension of either deadline.

Regarding the substance of your comments, correct me if I am wrong but
my impression is that the amateur regulations in the UK only specify
frequency bands and power levels, and do not limit either the
bandwidth or symbol rate of data emissions. The current symbol rate
limit in the FCC regulations is very unusual and indeed may be unique.
Other countries take a different approach. For example, in our
neighboring country of Canada there is a bandwidth limit of 6 kHz in
most of the MF/HF bands with no mode restrictions.

The ARRL petition simply seeks to replace the obsolete symbol rate
limit -- which because of advances in technology no longer has the
effect of limiting bandwidth -- with a bandwidth limit that includes
the data emissions that are already in common use. We believe it is
important to get such a limit into effect before the inevitable
development of broader data emissions using SDR technology.

73,
Dave Sumner, K1ZZ



-----Original Message-----
From: Dick Flanagan [mailto:dick@k7vc.com]
Sent: Friday, April 18, 2014 9:49 AM
To: Ron Kolarik
Cc: Sumner, Dave, K1ZZ
Subject: Re: RM-11708 Outside US

I suggest you and many others query Dave Sumner K1ZZ via k1zz@arrl.org
as he is deeply involved in the International Amateur Radio Union
(IARU) preparations for the next World Amateur Radio Conference
(WARC).

If Dave can't find a receptive ear with his contacts, I don't know who
can.

--
Dick Flanagan K7VC
dick@k7vc.com

On 2014-04-17 9:39 AM, Ron Kolarik wrote:
Hi Gerry,

On the first page where you enter your address there should be a check
box for domestic or international addresses.

73,
Ron
K0IDT

----- Original Message ----- From: "Gerry McGowan" <m0vaa@yahoo.com>
To: <rtty@contesting.com>
Sent: Thursday, April 17, 2014 7:03 AM
Subject: [RTTY] RM-11708 Outside US


Hi,
I've been following progress on this from the UK. The implications
extend Worldwide.

I'm a member of ARRL and have submitted my opinion of the filing to
ARRL via the web.
I feel somewhat disenfranchised as I can find no-one to represent non
US members within the ARRL structure who I can approach to represent
my views.

I've tried filing comments with FCC via their website but cannot get
past the first page as it restricts submissions to US citizens by the
use of drop down menu for 'State' and needs a zip code.

Anyone any idea how I can proceed ?

Thanks

Gerry M0VAA
RTTY DXCC #2608, RTTY WAS, and avid low power RTTY contester.!

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