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