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[RTTY] Member comment procedure

To: rtty@contesting.com
Subject: [RTTY] Member comment procedure
From: RLVZ--- via RTTY <rtty@contesting.com>
Reply-to: RLVZ@aol.com
Date: Sun, 15 Mar 2015 13:53:10 -0400
List-post: <rtty@contesting.com">mailto:rtty@contesting.com>
I'd be grateful if someone would share a link to get me to the ARRL comment 
 site for the Proposed HF Band Plan Change.... as I'm ready to  comment.
 
Thanks,
K9OM
 
----------------------------------------------------------------------

>  On Mar 14, 2015, at 12:00 PM, rtty-request@contesting.com wrote:
>  
> The period for comments on ARRL's grossly misguided HF Band  Plan
> Change has roughly one month left.  The comment period ends  April 19.
> 
> Today, I submitted my comments very much along the  lines of those
> I posted here two weeks ago:
> 
> ARRL's  proposal misses the mark on *every count*.
> 
> It needs to be  completely rewritten to include:
> 
> 1) expand 80 meter data to  3675 not 3650 ...
> 2) move the "automatically controlled data" segments  to 3560-3570,
>    7110-7120, 14130-14140, 21180-21190 and  28280-28290 *ONLY* - with
>    *no automatic control on 60, 30,  17 or 12 meters* due to the limited
>    available  spectrum.
> 3) require *all* automatically controlled data stations -  including
>    "auto-responding stations" - operate in the  automatic control
>    (Section 97.211) sub-bands.
> 4)  require all automatically controlled data stations - including  "auto
>    responding stations" - implement fully functioning  "channel busy"
>    detectors which respond to 125% of the  [maximum] bandwidth to be
>    used including any "enhanced  speed" modes.  The channel must be idle
>    for at least  90 seconds before initiating *any* transmission or 90
>     seconds prior to receiving a call *when responding to interrogation*.
> 5)  require all automatically controlled data stations - including  "auto-
>    responding stations" and *US licensed amateurs*  operating systems
>    off shore - list their frequencies,  operating times, and control
>    operator telephone number in a  publicly accessible database
> 7) require all manually controlled digital  stations include either
>    visual means (e.g. spectrum display  or "waterfall") of determining
>    whether a frequency is busy  before transmitting *or* a channel busy
>    detector with the  same parameters as automatically controlled data
>     stations.
> 6) allow Novice/Technician licensees to use *only* RTTY (45.45  baud,
>    170 Hz shift) and PSK31 within their current  allocations and any
>    expanded 80 meter data  allocation.
> 
> I don't believe there should be any "grace period"  for automatically 
> controlled digital stations (including  "auto-responding stations") to 
> implement the *effective* channel busy  detection and establish a public
> database of schedule/contact  information.  In addition, I do not
> believe that automatically  controlled stations should *ever* operate
> outside an extremely limited  spectrum (e.g., 97.211 allocations) as
> automatic channel busy detection  can not be 100% effective and
> automatic operation is incompatible with  the first come first served
> (no "assigned channels") nature of amateur  radio.
> 
> As as early adopter of ACDS, participant in the Special  Temporary 
> Authorization issued to TAPR in the late 1970s for the study  of
> automatically controlled HF forwarding systems, and member of  ARRL's
> *first* ad hoc Digital committee, I believe ACDS are a blight on  amateur 
> radio and serve *no legitimate amateur purpose*.  The  claimed EMCOMM 
> role can be provided by *manually controlled and  monitored* stations 
> established in [limited] areas impacted by a  communications emergency 
> during the emergency and for limited drills  not to exceed four 
> [consecutive] hours per month.
> 
>  73,
> 
>    ... Joe,  W4TV


------------------------------

Message: 2
Date: Sat,  14 Mar 2015 13:16:21 -0400
From: "Joe Subich, W4TV"  <lists@subich.com>
To: Michael Zolno <luv.myipad3@me.com>,    "rtty@contesting.com"
<rtty@contesting.com>
Subject: Re: [RTTY] ARRL Request for Member  comment on Proposed HF
Band Plan Change
Message-ID:  <55046CE5.6050702@subich.com>
Content-Type: text/plain; charset=utf-8;  format=flowed


> Do you mind if I use your enumerated items for my  submission?

Not at all.  Feel free to expand on and improve them if  you wish.

The key points are that automatically controlled data systems  *must*
include effective channel busy detectors, their end users *must*  use
visual means to determine of the frequency is occupied or  automatic
channel busy detectors and that ACDS should be restricted to  very
narrow allocations where they will not interfere with the majority
of  CW and narrow bandwidth data users.

Further, ACDS serves *no legitimate  amateur purpose*.  The claimed
benefits for EMCOMM can be filled by  manually monitored and controlled
systems established as needed within the  impacted area during a
communications emergency.  No amateur, individual  or ACDS, is entitled
to occupy scarce HF spectrum 24 x 7 by ACDS to the  exclusion of all
other users.

73,

... Joe,  W4TV


On 2015-03-14 12:59 PM, Michael Zolno wrote:
>  Joe,
>
> Lots of good advice which I hope and pray will be followed.  Do you mind 
if I use your enumerated items for my submission?
>
>  Mike WH6YH
>
> Sent from my iPad
>
>> On Mar 14,  2015, at 12:00 PM, rtty-request@contesting.com wrote:
>>
>>  The period for comments on ARRL's grossly misguided HF Band Plan
>>  Change has roughly one month left.  The comment period ends April  19.
>>
>> Today, I submitted my comments very much along the  lines of those
>> I posted here two weeks ago:
>>
>>  ARRL's proposal misses the mark on *every count*.
>>
>> It  needs to be completely rewritten to include:
>>
>> 1) expand  80 meter data to 3675 not 3650 ...
>> 2) move the "automatically  controlled data" segments to 3560-3570,
>>      7110-7120, 14130-14140, 21180-21190 and 28280-28290 *ONLY* -  with
>>     *no automatic control on 60, 30, 17 or 12  meters* due to the limited
>>     available  spectrum.
>> 3) require *all* automatically controlled data stations -  including
>>     "auto-responding stations" - operate in  the automatic control
>>     (Section 97.211)  sub-bands.
>> 4) require all automatically controlled data stations -  including "auto
>>     responding stations" - implement  fully functioning "channel busy"
>>     detectors which  respond to 125% of the [maximum] bandwidth to be
>>      used including any "enhanced speed" modes.  The channel must be  
idle
>>     for at least 90 seconds before initiating  *any* transmission or 90
>>     seconds prior to  receiving a call *when responding to 
interrogation*.
>> 5) require all  automatically controlled data stations - including "auto-
>>   responding stations" and *US licensed amateurs* operating  systems
>>     off shore - list their frequencies,  operating times, and control
>>     operator telephone  number in a publicly accessible database
>> 7) require all manually  controlled digital stations include either
>>     visual  means (e.g. spectrum display or "waterfall") of determining
>>   whether a frequency is busy before transmitting *or* a channel  busy
>>     detector with the same parameters as  automatically controlled data
>>      stations.
>> 6) allow Novice/Technician licensees to use *only* RTTY  (45.45 baud,
>>     170 Hz shift) and PSK31 within their  current allocations and any
>>     expanded 80 meter  data allocation.
>>
>> I don't believe there should be any  "grace period" for automatically
>> controlled digital stations  (including "auto-responding stations") to
>> implement the *effective*  channel busy detection and establish a public
>> database of  schedule/contact information.  In addition, I do not
>> believe  that automatically controlled stations should *ever* operate
>> outside  an extremely limited spectrum (e.g., 97.211 allocations) as
>>  automatic channel busy detection can not be 100% effective and
>>  automatic operation is incompatible with the first come first served
>>  (no "assigned channels") nature of amateur radio.
>>
>> As as  early adopter of ACDS, participant in the Special Temporary
>>  Authorization issued to TAPR in the late 1970s for the study of
>>  automatically controlled HF forwarding systems, and member of ARRL's
>>  *first* ad hoc Digital committee, I believe ACDS are a blight on  
amateur
>> radio and serve *no legitimate amateur purpose*.  The  claimed EMCOMM
>> role can be provided by *manually controlled and  monitored* stations
>> established in [limited] areas impacted by a  communications emergency
>> during the emergency and for limited drills  not to exceed four
>> [consecutive] hours per  month.
>>
>> 73,
>>
>>      ... Joe, W4TV
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