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Re: [RTTY] RM-11708

To: W0MU Mike Fatchett <w0mu@w0mu.com>
Subject: Re: [RTTY] RM-11708
From: Paul Stoetzer <n8hm@arrl.net>
Date: Mon, 9 Jun 2014 10:45:25 -0400
List-post: <rtty@contesting.com">mailto:rtty@contesting.com>
The ARRL has a very reasonable interpretation of the regulation. In
our system of law, reading between the lines is required.

73,

Paul, N8HM

On Mon, Jun 9, 2014 at 10:42 AM, W0MU Mike Fatchett <w0mu@w0mu.com> wrote:
> The ARRL does not care about deliberate interference.  They do it on a daily
> basis with the bulletins and code practice sessions and they either don't
> care or talked themselves into believing that the FCC gave them permission
> to do so by reading between the lines of a regulation that simply allows
> them to pay a control op.
>
> Mike W0MU
>
>
> On 6/9/2014 7:28 AM, Terry wrote:
>>
>> Ron,
>>
>> This is a great example of the deterioration of our amateur bands all
>> directly traceable to ARRL actions.  The www.SaveRtty.com team is working
>> on
>> a new chapter that will be released soon that connects the dots between
>> the
>> ARRL Board, Winlink and developing recreational boater and HF email
>> products.
>>
>> In your interference example we have the ARRL endorsed ("recreational
>> boater
>> product") Winlink interfering with the ARRL W1AW/0 Centennial operation
>> and
>> the official response from K1ZZ at ARRL HQ is "short term frequency
>> conflicts are best dealt with by using the VFO knob".
>>   In reviewing all of the ARRL BOD minutes perhaps we missed the part
>> where
>> the ARRL BOD exempting Winlink from the ARRL Considerate Operators Guide?
>> http://www.arrl.org/considerate-operator   Perhaps that exemption will be
>> first on the agenda at the next BOD meeting.  ;-)
>>
>> Thanks for posting this.   Great info.
>>
>> Terry AB5K
>>
>>
>>
>> -----Original Message-----
>> From: RTTY [mailto:rtty-bounces@contesting.com] On Behalf Of Ron Kolarik
>> Sent: Sunday, June 08, 2014 9:01 PM
>> To: RTTY
>> Subject: [RTTY] RM-11708
>>
>> 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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