[RTTY] ARRL RM-11708 Letter and response

[Gordon Bousman]

I wrote to the ARRL the other day regarding the issues with the RM-11708
proposal.  Below is my email and two responses from the ARRL:

Ms Kay C. Cragie N3KN

President, ARRL



Dear Ms. Cragie,



I am writing to express my huge disappointment that the ARRL submitted
the *ARRL
Symbol Rate Petition for Rule Making, RM-11708 *without ever first
soliciting comments from its membership.  You have angered many traditional
users of the so-called “outdated” traditional digital modes such as RTTY,
PSK, and JT65/9 with your actions.  The ARRL failed to identify the source
behind the demand for the changes in the symbol rates and have thus left
many members to resort to speculation as to what are the true reasons that
drove the ARRL to submit the petition.  Many believe that the real reason
for the petition is to allow the proprietary Pactor-4 code to be allowed to
operate within the digital portions of the HF bands.



What the ARRL failed to consider is that:

1)       Pactor-4 operations are generally unattended and thus there is no
ability or intent to listen if the frequency is already in use.

2)      The wide bandwidth of Pactor-4 transmissions will QRM any adjacent
traditional digital transmission such as more narrow RTTY or PSK.

3)      Pactor-4 code is proprietary and therefore other spectrum users
(including FCC enforcement) will not be able identify the Pactor-4 station
using any publicly available decoding software.  Essentially this means
that these transmissions are thus effectively encrypted which is a
violation of the amateur spirit of using open source codes.

4)      Wideband and narrow-band emissions need to be separated, something
your petition failed to recommend (i.e. set aside a segment such as
14.140-14.150 for wide-band)

5)      Pactor-4 transmissions in the RTTY sub-band will negatively impact
operation in future RTTY contests….including the ARRL RTTY Roundup.

6)      The petition was only to support a much smaller population of users
for high-speed internet message forwarding rather a larger majority of
traditional digital users.

7)      In actuality, the CW operators WILL be impacted (contrary to the
ARRL briefing paper) because Pactor-4 interference in the RTTY sub-bands
will force RTTY operators to move down lower into the CW portions of the
bands.



In summary, this petition was very poorly managed from the beginning,
especially by the failure of the ARRL to solicit membership
feedback/comments prior to submitting it to the FCC.  I ask that the ARRL
reconsider the *complete* ramifications of the petition and that the ARRL
either withdraw it so that it can be modified to address some of the above
mentioned points or to submit yet another erratum filing regarding your
proposal.


Respectfully,  Gordon Bousman, NW7D



…..and here is the response that I received from Kay Cragie, N3KN, ARRL
President:


"Dear Gordon,

Thank you for taking the time to write to me and for your obvious concern
for the wellbeing of Amateur Radio. You have seen the briefing paper
explaining the rationale for the symbol rate petition, and there is nothing
more I can add to that by way of information for your consideration.



The petition will not be withdrawn, and the ARRL Board of Directors will
continue to look towards the future of our radio service.



73 and best holiday wishes,

Kay N3KN"



..…and a response from Dave Sumner, K1ZZ,  CEO, ARRL:


"Gordon, based on your expressed concerns you should be among the most
ardent supporters of the ARRL petition. Here’s why.



Until now, higher HF data rates have been implemented within an SSB
bandwidth. With SDRs that no longer has to be the case. Under the existing
rules the evolutionary path for higher HF data rates is through SDRs and
OFDM. The rules currently place no limit on the bandwidth of such
emissions; they could legally use 6 kHz (as is permitted in Canada), or
even 12 kHz or more. One of the principal objectives of the ARRL petition
is to establish a limit where none presently exists.



It’s true that the petition will permit the use of Pactor-4 by
FCC-regulated stations, but Pactor-4 bandwidth is little more than that of
other HF data emissions in legal use in the US and your comments with
respect to Pactor-4 are equally true with respect to those. That’s not to
say no problems exist, but they are outside the scope of the petition.



73,

David Sumner, K1ZZ

Chief Executive Officer, ARRL"


I remain very concerned that the ARRL RM-11708 petition was half-baked, it
should of least also included a band-plan so that
wide-band digital emissions would be separated from the narrow-width RTTY,
PSK, etc. emissions.  I suspect that if the petition is approved, then an
after-the-fact band plan will need to be implemented to mitigate the
anticipated chaos.


73 Gordon NW7D