[RTTY] ARRL RM-11708 Letter and response

[Dave AA6YQ]

If "one of the principal objectives of the ARRL petition is to establish a limit where none presently exists", that objective could
have been expeditiously accomplished by simply proposing a bandwidth limit of 2200 hertz. Such a limit would maintain the status quo
in terms of legal modes (e.g. Pactor III) without introducing the many negative consequences of the petition in its current form,
and the vigorous opposition these consequences have motivated. This approach would have provided time for a more reasoned
consideration of wider bandwidths, employing an inclusive process and leading to a second petition with broader support from the
amateur radio community.

If the FCC rejects the petition because of its many negative consequences,  an objective that nearly everyone supports -- "establish
a limit where none presently exists" -- will remain unaccomplished.

        73,

                Dave, AA6YQ



-----Original Message-----
From: RTTY [mailto:rtty-bounces at contesting.com] On Behalf Of Gordon Bousman
Sent: Tuesday, December 24, 2013 3:26 PM
To: rtty at contesting.com
Subject: [RTTY] ARRL RM-11708 Letter and response

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  You have angered many traditional users of the so-called "outdated"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
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