[RTTY] Please file your comments with RM-11708 with teh FCC and your ARRL Director

[RTTY]

 > For two-tone RTTY, the limits are 300 baud AND 1 kHz maximum tone
 > separation,

That is only true because neither the Commission or anyone else could
have foreseen multiple tone FSK or channel equalization methods when
the rules were written.  That was still the case well into the late
1980s when the rules for automatically controlled digital operations
were written.  Unfortunately, PACTOR II maintained the 500 Hz bandwidth
and when PACTOR III with its multiple channel modes was introduced
nobody thought to ask the Commission to apply the 1500 Hz limit.  It
is likely, they would have done something if a timely complaint had
been made but once the mode became generally used they were reluctant
to order it withdrawn from use.

> The correct arguments to make are:
> (1) Remove the archaic 300 baud language AND
> (2) take ALL that occupy more than (for example) 500  Hz (digital and
> analog)ABOVE the CW/digital boundary.\
 >
 > It becomes regulation by bandwidth, but that is the right thing to
 > do.

It is no different than the regulatory system that has been in place
for 80+ years.  Regulations protecting narrow bandwidth modes from
the asymmetric interference caused by wide bandwidth modes have been
the norm since the FCC restricted phone to only part of each amateur
band.

If the Commission were to allow RTTY and data every where CW is now
authorized, apply a 500 Hz (or 300 Hz) limit in the current "CW bands"
and explicitly limit all modes except ISB and AM to 2.8 KHz instead of
the vague "bandwidth of a communications grade voice signal", the
regulations would become content agnostic.  That is, it would not
matter if the source of the modulation was voice, image, keyboard
to keyboard or computer to computer communications.  That environment
would allow innovation to flourish - particularly mixed data modes -
and would continue to protect traditional narrow bandwidth modes from
catastrophic interference levels while at the same time give the high
speed data transfer folks an opportunity.

The only other additions I would make would be:

1) all protocols, modulations, and encoding systems must be fully
    disclosed.  All encoding keys must be public, variable key
    encoding would not be permitted.
2) proprietary protocols - those that require the purchase of a
    software license or specific hardware in order to decode - would
    not be permitted (e.g., AMBE or PACTOR III/IV).
3) all automatically controlled stations must include effective
    channel busy detectors for both wideband and narrow band as well
    as analog and digital signals.
4) any modulation/protocol not generally monitored "by ear" must
    have a "waterfall" or spectrum display capable of showing any
    other signal on the frequency so the operator can avoid causing
    interference.  Any mode/modulation/protocol that lacks visual
    means for determining whether a frequency is busy must include
    an effective software channel busy detector.
5) automatically controlled digital stations would not be permitted
    in the narrow band segments of any band or 160 and 30 meters.

73,

    ... Joe, W4TV


On 4/16/2014 11:42 AM, Kai wrote:
> Terry Under current FCC rules, the 300 baud limit does NOT limit
> bandwidth except for two-tone RTTY signals. Note for example that
> PACTOR-3 occupies 2.2 kHz and uses a baud rate of 100. There is no BW
> limit for non-FSK signaling (like PACTOR-3).  The 300 baud limit does
> not stop 2.2 kHz wide PACTOR-3. PACTOR-3 does not use "two-tones" so
> the 1 kHz FSK limit does not apply. It occupies 2.2 kHz.  That is the
> TRUE situation today, which RM-11708 leverages to argue for a
> bandwidth limit, as in "we don't understand". It is OK to remove the
>  baud rate limit since it doesn't limit BW of non-FSK modulations.
> But what is NOT OK is the 2800 Hz limit, like "the ARRL do not
> understand this."
>
> For two-tone RTTY, the limits are 300 baud AND 1 kHz maximum tone
> separation, so the maximum permitted band width is 300+1.2*1000 =
> 1500 Hz. Amateur RTTY, what we we all use today occupies
> 45.45+1.2*170 = 250 Hz.
>
> Watch out for the deceptive part of RM-11708. Today there is indeed
> NO bandwidth limit in the CW/digital band segments, and yes, RM-11708
> would impose a limit of 2800 Hz. Now the deceptive part:  The effect
> will be to enable PACTOR-4 which also has a 2.2-2.4 BW (depending on
> what you use for your source material), but operates at a much higher
> baud rate. The ARRL are right but deceptive. There is no BW limit
> now, but the deception is that a BW limit as high as 2800 Hz will
> devastate the incumbent fragile narrow band digital modes such as
> PSK31, JT65, J9. and amateur-RTTY.
>
> The correct arguments to make are: (1) Remove the archaic 300 baud
> language AND (2) take ALL that occupy more than (for example) 500  Hz
> (digital and analog)ABOVE the CW/digital boundary. That is, put them
> in the "phone sections" of the bands where there are already wide
> band digital and analog signals like ATV, HF-D-STAR, and AM.
>
> It becomes regulation by bandwidth, but that is the right thing to
> do. We's still have to contend with PACTOR-1 and others that occupy
> less than 500 Hz, but in my opinion, that is manageable.
>
> Wide and narrow band digital mode just do not mix well in the same
> spectrum.
>
> 73 Kai, KE4PT
>
> On 4/15/2014 10:40 AM, Terry wrote:
>> Folks,
>>
>> It's still not too late to file comments regarding RM-11708.
>> Also please copy your directors on your comments.   If anyone needs
>> help in the filing, please let me know as I have helped a couple of
>> folks with their filings.
>>
>> The current 300 baud limit is a very real protection mechanism
>> designed specifically to limit the power spectral density of all
>> users in the CW-only bands. The 300 baud law practically limits
>> useable signals to about 500 Hz in the low portion of the band.
>> Wider band signals that are currently required by law to remain
>> below 300 baud are simply too inefficient and not commercially
>> viable to find use, hence the FCC was very wise to naturally
>> protect narrowband RTTY and CW users through the 300 baud limit.
>> Wider-band signals, when operated below 300 baud, do not
>> appreciably interfere with today's CW and RTTY users due to lower
>> power spectral  density. The baud rate is the key protector for
>> narrowband operations.
>>
>> ARRL leadership is ignoring, misstating, and misrepresenting the
>> facts in this issue, both on its website, and now in its board
>> minutes, as is clearly shown in section 4.2.4 of its recent board
>> minutes of late March.
>>
>> Below is more information from Ted, K9NB expressing his concerns.
>>
>> Terry
>>
>> ----------------------------------------------------
>>
>> At the risk of stirring up some uneasiness, but in the sincere
>> interest of our beloved hobby, I ask for all CW and RTTY operators,
>> and anyone else reading this message, to please consider an
>> immediate grass roots e-letter writing campaign to any and all of
>> the ARRL Board of Directors, the president of ARRL, and to Dave
>> Sumner. Please feel free to forward this note to anyone, as we need
>> DX and contesting clubs around the country to get involved.
>> Urgently.
>>
>> Perhaps even more importantly, I urge everyone to file ex parte
>> public "comments" at the FCC website regarding RM-11708. The chief
>> engineer told us late comments are welcome and considered as
>> "comments".
>>
>> CW and narrowband modes are under attack by the ARRL in RM 11708.
>> And the ability to openly observe ham radio communications is also
>> under attack.
>>
>> The ARRL is failing to represent the interests of CW and narrowband
>>  users in RM-11708, and even at it's March 31 board meeting, is on
>> record saying that "opponents of RM-11708 simply do not understand
>> the rulemaking.
>>
>> The facts are clear: the ARRL is proposing through RM-11708 to
>> remove the 300 baud limit in all of the HF CW subbands, and is
>> urging the FCC to replace the 300 baud limit with no baud limit,
>> and a 2.8 kHz bandwidth limit.
>>
>> The facts of communications engineering are that the removal of the
>>  300 baud limit will allow much greater baud rates, which in turn
>> will make the power spectral density, and thus the interference
>> energy of these new wideband data signals as great or even greater
>> than SSB signals.
>>
>> By removing the 300 baud rate, the ARRL is requesting to allow
>> SSB-like signals (on an interference bandwidth basis) in the
>> CW-only bands.
>>
>>
>> The FCC created the CW-only subbands expressly for the purpose of
>> protecting these narrowband modes from wider band interference.
>> That's why there is a separate SSB subband.
>>
>> The 300 baud rate has protected narrowband CW and RTTY users for
>> decades, since the 300 baud spec naturally limits the power
>> spectral density (watts/Hz) of transmitted  signals, and thus
>> discourages the use of wideband data in the CW-only subbands due to
>> the fundamental laws of Communications and signal to noise ratio
>> (see Leon Couch- Digital and Analog Communications, or my textbook
>> on Wireless Communications).
>>
>> Thus, wider band data signals limited to 300 baud perform much
>> poorer than 300 baud narrow band signals, and are not practically
>> viable and pose no current threat. The current law protects CW and
>> RTTY users
>>> From interference
>> by the 300 Baud Limit.
>>
>> Now, though, the ARRL through RM-11708 is trying to allow much
>> stronger data interferers that have both much greater baud rate AND
>> much wider bandwidth, into the CW only bands.
>>
>> This is a huge attack on the narrowband CW and RTTY users! The
>> resulting interfernce will be enormous, and is like allowing SSB
>> into the CW bands.
>>
>> Also, many have recently pointed out that some of the existing or
>> proposed uses of these new wideband signals will use encryption, so
>> that Official Observers and FCC officials will have difficulty
>> intercepting communications, thus making the CW and RTTY Bands of
>> our hobby more like private radio or for-profit networks.
>>
>> I have filed public comments at the FCC, so has Terry.
>>
>> The Last ARRL board of director meeting minutes of 3/31/14 are
>> quite disturbing, and show wanton disregard for Narrowband cw/rtty
>> users, and complete neglect of the above facts. The ARRL is hiding
>> these fundamental facts, and does not properly present these
>> obvious technical facts on it's FAQ at the ARRL home page. In
>> numerous email conversations I had with K1ZZ over the course of a
>> week, he never wanted to recognize these technical facts.
>>
>> I ask that all of us who want to maintain the ability to operate
>> CW, RTTY and PSK31, and to preserve the narrowband (300 baud)
>> protections that allow us to enjoy RTTY, PSK31, and CW... We must
>> become vocal.
>>
>> Now we must speak up immediately, and clearly, and we must spread
>> the word for a massive letter writing campaign to ARRL leadership,
>> and with public comments at the FCC.
>>
>> If you care about the CW and RTTY sub bands, and want to keep out
>> voice-like interference, I hope you will get Involved! Your hobby
>> needs you!
>>
>> Our hobby needs your public activism to protect CW and narrowband
>> data! The ARRL has forsaken its CW, RTTY, and PSK31 members, and
>> now we must do this ourselves at the grass roots level.  Please
>> file your public comments at the FCC RM-11708 website.
>>
>> 73
>>
>> Ted
>>
>>
>>
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