I've been debating whether or not to post this to the list but since
I've had no answer to my original question, I did get a reply but no
answer on how to proceed with a formal complaint,
File it with the FCC at FCCham@fcc.gov or call (717) 338-2577 (see:
http://transition.fcc.gov/eb/AmaCmpl.html) and specify the RMBS station
listed as guarding the frequency in the WinLink RMBS Frequency list
here: http://www2.winlink.org:8081/GatewayChannels.aspx
On 7,062 the interfering RMBS (PACTOR robot) was likely N0IA on 7063.9
(center frequency) in Deltona, FL. On 10,130 the interfering RMBS could
have been N0IA on 10,133.9 or KN6KB on 10,131.5 from Rockledge, FL.
Without a human readable ID, it is entirely valid to identify the
potentially interfering station by frequency against the published
schedule of operating frequencies and times.
For general information, N0IA is also the *LID* who regularly QRMs
RTTY DX on 18106.2 while KB6BT in Portland, OR is listed on 18108.
I recommend that *anyone* receiving interference from PACTOR RMBS
operations - whether it be to RTTY, JT65, JT9, PSK31/63 or split
phone operations on 40 meters - file a complaint requesting that
the FCC monitoring service and Enforcement Bureau investigate and
determine if these RMBS operations are engaging in "Prohibited
Transmissions" as defined by §97.113(a)(5) "Communications, on a
regular basis, which could reasonably be furnished alternatively
through other radio services." The frequency and volume of Winlink
RMBS activity and published schedules would seem to put them in the
"on a regular basis" category and there are companies and organizations
like: INMARSAT, Globalstar, Intellisat Services, SailMail, XGate,
Global Marine Networks, OCENS, ShipCom, Global Xpress, KKL Radio,
AugTec and CruiseEmail all providing equivalent alternate service
in other radio services.
73,
... Joe, W4TV
On 2014-06-08 10:00 PM, Ron Kolarik wrote:
I've been debating whether or not to post this to the list but since I've had
no answer to my original question, I did get a reply but no answer on how to
proceed with a formal complaint, here's what I asked and what I got back
from K1ZZ. My reply to this is available if anyone wants to see it, a bit long
though and probably not for the list.
Ron
K0IDT
Sent: Wednesday, May 14, 2014 11:48 PM
To: Craigie, Kay, N3KN
Cc: Roderick, Rick (1st Vice President); Fenstermaker, James, K9JF;
k0qb@arrl.org; Sumner, Dave, K1ZZ; Isely,Dick (Dir,Cl); Ahrens, Cliff, K0CA;
Lisenco, Mike (DIR, Hudson); Woolweaver, David ( Dir, WG); Vallio, Bob (Dir,
PC); Price, Brennan, N4QX
Subject: RM-11708 and a query
To the ARRL
I'm writing in support of the recent emails from W4TV and N9NB to pull
and reconsider RM-11708. I won't repeat the points already made except
to state that the RM was produced with no input from the amateur community
and completely ignores the IARU Region 2 bandplan. As written there is no
protection for current narrow bandwidth users and the suggestion that some
future bandplan will correct the problems the RM will cause is ridiculous.
Why cause the problems in the first place? K1ZZ has pointed out that Canada
allows 6kHz emissions almost everywhere as a reason to allow 2.8kHz in
the US narrow band segments. Has anyone at HQ actually listened to the mess
on 40m in the early evenings? There is spanish language and VE SSB clear down
to 7050kHz, doesn't leave much room for the rest of us and RM-11708 proposes
to add unidentifiable wideband digital to the mix. Which leads me to my query.
I would like to file a formal complaint but don't know where or who to send it
to.
I also don't know who I need to file the complaint against since the offender(s)
never identify in a mode I can understand. This past week I had the opportunity
to represent Nebraska as W1AW/0, thank you for that, I was strictly RTTY
and the interference from the unattended stations made things difficult. I
avoided
the auto sub-bands because it's impossible to operate on a clear frequency there
without one of the store and forward boxes just firing up at will. On 40m I had
to move down to 7062 to find a vacancy, running for over an hour before a
Pactor box lit up on my tx frequency, please don't tell me about the hidden
transmitter effect there is also reciprocal receiving to take into account. I
can only
assume I was interferred with by the side of the link with no intelligence
present.
30m same thing, moved down to 10130 well away from the auto sub band and sure
enough
another Pactor box fired up this time on the 1-2kHz above my tx frequency where
I had
a pileup going. Some of the DX stations also missed a chance to work me on 30m
as
they are only allowed digital above 10140. The 30m interference continued on
and off
over several hours, the only thing I could do was wait for the station to
deliver what I
guess was some very important email that just couldn't wait. In the past when
these
automated stations had CW id's I did identify one that was causing problems and
sent
a polite email, the response of "the frequency is published" was the reply,
that's the entire
reply. Since that time it seems most of the stations have turned off their cw
id. Any
suggestions on how to deal with the ongoing interferrence or who to refer the
complaint to
would be appreciated.
Now according to the RM some of the rules are archaic and outdated, it may be
wise to
evaluate the rules concerning unattended operation and easing the current
interferrence
problems, they were written a long time ago after all. The current IARU Region
2 bandplan
requests that unattended operation be limited on HF. The automated store and
forward
stations have had several decades to develop and deploy effective "busy
channel" detection
and have failed miserably at it. It may be time to further restrict or remove
them from HF.
While eliminating outdated rules it might also be good to revisit the use of
Pactor as a mode
since the stations are not easily identified and there is absolutely no way to
verify content
if you're not part of the ARQ link.
Thanks for listening,
Ron Kolarik
K0IDT
From: Sumner, Dave, K1ZZ
To: 'Ron Kolarik' ; Craigie, Kay, N3KN
Cc: Roderick, Rick (1st Vice President) ; Fenstermaker, James, K9JF ;
k0qb@arrl.org ; Isely,Dick (Dir,Cl) ; Ahrens, Cliff, K0CA ; Lisenco, Mike (DIR,
Hudson) ; Woolweaver, David ( Dir, WG) ; Vallio, Bob (Dir, PC) ; Price,
Brennan, N4QX
Sent: Wednesday, May 21, 2014 10:50 AM
Subject: RE: RM-11708 and a query
Ron, thanks for your message. Kay Craigie asked me to respond, but travel to
the Dayton Hamvention has put me a bit behind.
First of all, thanks for helping to make W1AW/0 available from Nebraska. Yours
was the first state to repeat, and it's interesting to see that the QSO demand
was even greater the second time around.
Regarding RM-11708, it is important to keep in mind that the petition does not seek to
"allow" HF data emissions with 2.8 kHz bandwidth. Such emissions are already
allowed, with no limit as to bandwidth. The rules changes proposed in RM-11708 are very
limited. The existing 1980-era HF symbol rate limits are based on the old Bell telephone
modems; otherwise there is nothing special about them. In 1980 they served as a surrogate
for a bandwidth limit, but with more modern data modes they no longer serve that
function. All RM-11708 proposes is to replace the symbol rate limits with a bandwidth
limit that accommodates the data modes that are already in use while prohibiting the use
of wider bandwidth modes in the future.
The petition has two objectives: to permit more efficient use of the bandwidth
that is already being employed and to prevent the deployment of data modes with
wider bandwidths. Currently the only thing standing in the way of the latter is
that up to now operation has been done with conventional SSB transceivers, but
with the dramatic increase in the popularity of software defined radios that
barrier no longer exists.
The scope of the petition is deliberately limited. It does not purport to
address issues such as automatically controlled digital stations and proposes
no related rules changes. The petition may not offer a solution to every
existing problem but that is no reason to not support what it would accomplish,
namely heading off the development of wider bandwidth HF data emissions than
are now in use. One of the consequences of doing nothing is that the quest for
higher data rates will be forced in the direction of wider bandwidths, with no
regulatory barrier to that development.
With respect, addressing issues through band planning is not "ridiculous." Band
planning is not perfect, but it works pretty well except perhaps during periods of
unusually intense activity. The FCC rules take precedence over voluntary band planning
but we cannot expect (nor would we want) the FCC to resolve all of the compatibility
issues among various modes. The last time the FCC did so had a very unfortunate result:
the 80 meter RTTY/data subband was compressed from 250 kHz down to 100 kHz, with severe
consequences for CW, RTTY and data operators. The FCC gave short shrift to our petition
for reconsideration at the time, but a common thought heard recently is that it may be
time to reintroduce the subject.
Internationally, our 10 MHz allocation is secondary to the fixed service and we
are obligated to avoid interfering with stations in the fixed service; that is
the reason for the 200 watt power limit and the reason why there are so many
non-amateur signals in the band. Working around them is a challenge in the best
of times and it may not always be possible to do everything in the band that we
would like, but we're far better off having the secondary allocation than not
having it.
Quite a few ARRL Official Observers are capable of identifying stations using
the various data modes including Pactor, although monitoring message content of
ARQ modes is more difficult. We can request that OOs monitor specific
frequencies at specific times if illegal operation is suspected, but short term
frequency conflicts are best dealt with by using the VFO knob. There was a
rather amusing one at the start of the Colorado and New York operations last
night on 40 CW: W1AW/0 was on 7029 listening up 1 and W1AW/2 was on 7030
listening up 1. The New York op QSY'ed after a few minutes.
73,
Dave Sumner, K1ZZ
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