[Mldxcc] [NCCC] FCC NRPM RM-11708

Mon Dec 9 19:31:39 EST 2013

Cross posting this to MLDXCC as well.

We need to comment on the proposal as it stands, not as we would like it to be - even though you are free to make suggestions as part of your response.

Of course if any of our lawyers would like to draft a counter proposal I am sure we have the technical talent in NCCC and other clubs to create a better NRPM.

NOTE: The deadline for public comments is November 21, so don't delay.

73,
Steve
W1SRD

________________________________
 From: Alan Maenchen <ad6e at arrl.net>
To: Steve Dyer <w1srd at yahoo.com> 
Cc: "k6dgw at foothill.net" <k6dgw at foothill.net>; NCCC Main Reflector <nccc at contesting.com> 
Sent: Monday, December 9, 2013 4:22 PM
Subject: Re: [NCCC] FCC NRPM RM-11708

Tks Steve,

The text of 11708 is frightful in the common terminology errors. I first smiled at the term "bauds" which is like saying "y'alls" .. but it gets worse with outright confusion between baud, bit rate, and symbol rate .. and probable unfamiliarity with bandwidth vs baud relationship. Sure seems like amateur hour.

Anyway, I actually like the idea of a digital bandwidth limit rather than a baud limit since it would allow experimentation with stuff like partial response filtering.  The problem is the bandwidth proposed is 2.8kHz !!!  Why so wide? This makes no sense to me at all.  If the intent is to facilitate experimentation with advanced modulation techniques, then maybe 1kHz would make more sense? Then allow 2.8kHz in the "phone" sub-bands where that sort of bandwidth is more normal.

I know that's a bit tight for ham FSK, but maybe that can be grandfathered as an ancient but revered scheme?  Sort of like CW?  Or maybe it's time to move on. We don't tolerate spark anymore.

73, Alan AD6E

On Mon, Dec 9, 2013 at 10:55 PM, Steve Dyer <w1srd at yahoo.com> wrote:

There has been extensive discussion of this on the RTTY reflector. The general consensus of the technical experts there is this is a BAD proposal and does not serve to benefit the larger amateur community and will potentially have a negative impact on both  CW, RTTY and other digital mode users.
>
>The question I would like answered is exactly who does benefit from this proposal? As far as I can tell only those that want to use PACTOR4 and other bandwidth hogging protocols.
>
>The ARRL proposal is couched in the language of technological advancement which makes no sense. Every recent important digital technology uses *LESS* bandwidth -- not more. 
>
>Also note the ARRL filed an amendment and removed the symbol rate request and made it a blanket 2.8 kHz bandwidth maximum
 *anywhere* in the CW/digital sub-bands.
>Mixing wide band and narrow band signals makes zero sense. 
>W8JI wrote a good article about why this is a bad thing. http://www.w8ji.com/mixing_wide_and_narrow_modes.htm
>
>I strongly encourage everyone to read and make their own decision then file a comment on this.
>
>AA5AU posted this guide on how to comment:
>
>http://aa5au.com/fcc/how-to-comment.html
>
>73,
>Steve
>W1SRD
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>________________________________
> From: Fred Jensen <k6dgw at foothill.net>
>To: NCCC Main Reflector <nccc at contesting.com> 
>Sent: Sunday, December 8, 2013 2:41 PM
>Subject: [NCCC] FCC NRPM RM-11708
> 
>
>I'm curious about the effect of the ARRL Petition For Rulemaking that 
>has resulted in RM-11708, and I'd sure like to hear from those who know 
>more than I do about digital communications.
>
>Some time back, ARRL filed a petition commonly known as "Regulation by 
>Bandwidth," which was ultimately amended to cover only bands above 10m 
>after a firestorm of criticism [OK, maybe "firestorm" is a bit harsh 
>:-)].  One of the primary complaints was that the ad hoc committee that 
>came up with it was dominated by proponents of digital modes, and 
>indeed, there was some drama associated with the proceedings.  I believe 
>the basis for most of the negative comments was that
 it would replace 
>segregation into sub-bands by mode with segregation by bandwidth ... 
>ergo digital signals in phone sub-bands.
>
>This current petition seems to simply remove a symbol-rate limitation 
>and impose a BW of 2.8KHz regardless of digital system or symbol rate. 
>It does not seem to change where in the bands you can use digital modes, 
>but I'm not a lawyer nor do I play one on TV, and reading 47CFR97 isn't 
>easy.
>
>From what I *do* know about modulation techniques and digital modes, 
>the current petition looks pretty tame and harmless to hamdom in 
>general.  Just not sure I'm right.
>
>73,
>
>Fred K6DGW
>- Northern California Contest Club
>- CU in the 2014 Cal QSO Party 4-5 Oct 2014
>- www.cqp.org
>
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