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Re: [RTTY] RM-11708

To: rtty@contesting.com
Subject: Re: [RTTY] RM-11708
From: W0MU Mike Fatchett <w0mu@w0mu.com>
Date: Mon, 09 Jun 2014 09:09:14 -0600
List-post: <rtty@contesting.com">mailto:rtty@contesting.com>
Paul.

Apparently you missed the email I received from the FCC that stated that the regulation quoted that allows them to pay a control op does not allow them to ignore any other rule. We are talking about allowing a club to pay for the control op. With their reasoning, if I wear a seat belt in a car, I should be able to legally speed.

William Cross Wrote:

"I agree that Section 97.113(a)(3)(iv) addresses compensation of a control operator of a club station in certain cases, and it applies to all club stations. That rule says nothing about interference and a club station transmission is subject to 97.101(d) just as the transmission by any other amateur station is. "

I spent about 2 minutes thinking about solutions to their problem and came up with alternative frequencies and just waiting for a few minutes. The issue with these broadcasts are that that ARRL does not have system that allows them to individually control each station, which could be another problem. I have been told that the system they built fires up all transmitters at the same time.

The FCC creates rules and regulations not laws.  Congress create laws.

It would appear that you do not mind intentional willful interference by anyone. If the ARRL can read between the lines and do it, then what stops anyone else? What does it say when the ARRL believes that they can squat on frequencies ignore certain rules and the excuse is that someone might squat on the frequencies that they are sqatting on. This is a bit hypocritical isn't it? The value of the message or practice is irrelevant unless the bulletins contains emergency traffic which takes priority over all other communications.

I believe that the ARRL has been very lucky that nobody has filed formal complaints about the transmissions or how they operate their station.

I personally do not want to see this happen and am in discussions with K1ZZ and my director. I would suggest that others should contact their directors and discuss how the ARRL can address this in a mature reasonable manner. If I was a winlink operator, this would certainly be a defense I would attempt to use.

Mike W0MU

On 6/9/2014 8:45 AM, Paul Stoetzer wrote:
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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