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

[Dick Wilson]

Well put, IMO.

Dick

On 5/29/2016 10:35 AM, w6de wrote:
>
> 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 webby 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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