[Mldxcc] ARLB016 Missouri Radio Amateur Petitions FCC to Designate "Symbol Communication" Subbands

[w6de]

I attempted to post this last night to the MLDXCC group and it didn’t go due to embedded formatting.  Here is another attempt.

 

I would like some review of the claims I am making in my reply to this FCC rule making, scroll down for the history. Please reply to me directly with specific things I may have gotten wrong.  There are only a few days remaining to submit comments.  I make no promises about incorporation of your comments and opinions, what I am looking for are errors in my reply. 

 

Thanks,

Dave, w6de

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

In reference to: RM-11769

RM-11769 should be denied. This rule making is not about efficient spectrum use nor 

is it about narrow bandwidth mode communications.  This rule making is about allowing 

wider band digital communications in the currently allocated CW and digital only bands.  

 

Regardless of the requestor’s intent of what these wider mode digital communications 

would be used for in the HF bands. In practical use the Amateur Radio community would 

likely use these modes for digital voice.  Digital Voice is another bandwidth hog and does 

not belong in the currently allocated CW and Digital allocation.  In addition, the even 

wider digital bandwidth communication modes proposed in RM-11769 for the HF “Voice” 

bands offer no rationale for their consideration.

 

In other FCC proceedings for regulated radio services, e.g.: VHF Aviation and Public 

Service bands, the FCC has discontinued wide band communication ‘channels’ and 

replaced them with narrower bandwidth ‘channels.’  This promotes better spectrum 

efficiency by allowing a greater number of communications channels within the same, or 

equivalent, spectrum space.  Wider signals, in the existing Amateur Radio allocations, 

are not the technological innovation the Amateur Radio Service needs.  

 

Paragraph 4, the requestor offers no substantiation of his “manifest 

under-utilization” claims.

 

Paragraph 3 and 4 with regards to the requestor’s claim “this has been proven 

grossly inefficient” the requestor offers flawed technical arguments about 

the use of CW Morse Code Telegraphy.  While attempting to define an efficient 

use of narrow bandwidth as an argument against CW—the issue of narrow bandwidth 

efficient communication modes is not again brought up as a subject of the 

requested rule making.  

 

Paragraph 5, the requestor implies that there currently exists a weak signal, very 

narrow band mode that can be decoded in a short period of time.  This is contrary to 

information theory and the teachings of Claude Shannon, Harry Nyquist et al.  

Never-the-less, RM-11769 is not about implementation of efficient spectrum use.

 

Paragraph 6 states “Nostalgia for retention of Morse Code telegraphy-only sub-bands…”  

This wording would lead one to believe that Morse Code Telegraphy (CW) is an obsolete 

and dead mode of communication.  This is not the case.  There is activity in the 

CW sub bands and there is evidence that it is healthy and increasing 

[Cite: “Is CW Dead,” Walter B. Fair, Jr., W5ALT, available by WEB search].

 

Paragraph 12 attempts to redefine communications with potential deleterious effects.  

The comment “...without intent to convey aural or visual information other than such 

symbol(s)” is especially troubling. In a shared mode environment where symbol mode 

communication processing might not detect a current “voice” or “picture” mode 

communication and thus interfere with the previously existing communication.  

Listening to a frequency and checking before using it should be the objective 

of all operators.

 

Paragraph 16 reveals the intent of the rule making is not a request to allow 

additional narrow band mode communication services above 1.8 MHz.  For MF and HF, 

RM-11769 defines a digital mode as occupying 2,800 Hz wide.  While not stating such use, 

this rule making will allow digital voice in the current digital and CW band allocations 

of the amateur radio services.

 

Paragraph 17 by requesting even wider modes of communication in the Amateur Radio 

Phone band allocations above 1.8 MHZ would create even higher levels of interfering 

communications in those bands.  Wider signals, in the existing HF Amateur Radio 

allocations, are not the technological innovation the Amateur Radio Service needs. 

 

Paragraphs 17 through and including paragraph 32 are all subjects of International 

agreements and ITU regulations and should be removed from this Rule Making.

 

Paragraphs 33 through and including paragraph 41 should be separated from this RM 

and separately submitted.  Combining licensing privileges, creating new mode 

classifications and reassigning frequency use allocations into a single Rule Making 

confuses the issues involved.

 

Paragraphs 17 through 33 are essentially a re-write of a portion the FCC’s 

part 97 regulations for the amateur radio service and should be the subject to a 

wider audience that normally given a Request for Rule making.  One would normally 

expect this wide a ranging change in regulations should be an issue from and/or 

before the FCC Board of Commissioners.

 

Respectfully submitted

David Engle, W6DE

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

From: EDCARC On Behalf Of Rick WA6NHC
Sent: 27 May, 2016 05:06
To: El Dorado County Amateur Radio Club
Subject: [EDCARC] ARLB016 Missouri Radio Amateur Petitions FCC to Designate "Symbol Communication" Subbands

 

  

I mentioned at tonight's meeting that I would forward this to the reflector, which I did in crude form during the meeting (in case I forgot).

Here is the ARRL announcement.

I feel that it is a grab of spectrum, by a ham, because he either wants more room to play with his digital mode toys and/or doesn't like CW.  To remove the CW portion (recognized by MUCH of the world) would cause significant damage to the operation of many stations, in particular the QRP stations (like SOTA).

And I'm here to tell you that (even though I'm not good at it) CW is still popular and is one of the most spectrum efficient modes we have (it puts ALL the signal on ONE frequency, not dispersing it by bandwidth).  The only acceptable (arguable) claim to efficiency is the JT modes (can decode below the noise floor) but they're also SLOW, painfully slow (a single QSO takes 6 minutes for the call, exchange and confirmation; that's 12 Q/hr, abysmal).

Please review the petition and respond, the timing on this is short.  

 

Rick wa6nhc



-------- Forwarded Message -------- 

 
 
SB QST @ ARL $ARLB016
ARLB016 Missouri Radio Amateur Petitions FCC to Designate "Symbol
Communication" Subbands
 
ZCZC AG16
QST de W1AW  
ARRL Bulletin 16  ARLB016
>From ARRL Headquarters  
Newington CT  May 12, 2016
To all radio amateurs 
 
SB QST ARL ARLB016
ARLB016 Missouri Radio Amateur Petitions FCC to Designate "Symbol
Communication" Subbands
 
James E. Whedbee, N0ECN, of Gladstone, Missouri, has petitioned the
FCC to designate Morse (radiotelegraphy) Amateur Radio band segments
as "symbol communication" subbands. The FCC has invited comments on
his Petition for Rule Making (RM-11769), filed on May 2. Arguing
that retaining the current regime of "legacy" CW subbands has proven
to be grossly inefficient, Whedbee said he'd like to see the FCC
delete all privilege restrictions that limit any part of the Amateur
Radio spectrum to Morse code to the exclusion of other modes.
 
[w6de edit: RM-11769 can be found on the web by doing a search for 60001692464  This is the FCC ID number for RM-11769.]
 
"Nostalgia for retention of Morse code telegraphy-only subbands is
also an insufficient reason to avoid moving forward to [the]
elimination of such subbands, because nothing about this Petition
suggests the elimination of the mode itself, only that it not be the
sole authorized mode in the subject subbands," Whedbee told the FCC.
 
Whedbee characterized CW-only subbands as "an excessive regulatory
constraint, as well as a poor use of the spectrum concerned." He
proposed that the FCC's Part 97 rules reflect the "ultimate form of
communication reproduced at the receiving end." As he explained it,
his regulatory scheme would break down modes into three categories -
"symbol communication mode" - for CW, digital, and other emission
modes that reproduce a discrete symbol on the receiving end - "voice
mode," and "image mode."
 
"[C]ontinuing regulation by specific emission designator is proving
to be onerous with changes to the state of the art," Whedbee said.
"Accordingly, to continue developing the state of the art in
radiocommunications, Amateur Radio needs to clearly get away from
regulating in that fashion and return to consideration of what the
receiving end of the communication reproduces."
 
He proposed that where the Part 97 rules refer to exclusive
radiotelegraphy allocations - or subbands - privileges be changed to
reflect symbol communication modes. Where the rules prohibit voice
and image modes, he would revise the rules to reflect symbol
communication modes. In situations where current rules prohibit
symbol communication modes other than Morse, that voice and image
modes would be permitted, "with an exception for manually keyed"
radiotelegraphy.
 
For example, he would drop the distinction between 75 meters and 80
meters, authorizing symbol communication modes between 3.5 MHz and
3.65 MHz, and voice and image modes between 3.65 MHz and 4 MHz, with
manual radiotelegraphy authorized throughout the band.
 
Whedbee told the FCC that, if his Petition is accepted for filing
and put on public notice, he would submit an appendix spelling out
proposed service rules as part of his Petition.
 
Commenters have 30 days to respond to Whedbee's Petition.
NNNN
/EX

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