[RTTY] Fwd: RE: RM-11708 Outside US

Thu Apr 24 15:30:19 EDT 2014

[Forwarded with permission]

On 2014-04-23 10:51 AM, Sumner, Dave, K1ZZ wrote:
> Dick, I don't consider "that will be the end of amateur radio" to be a technical argument. How many times have we heard that over the years?
>
> While I'm glad to see that Joe at least acknowledges that permitting Pactor 4 won't cause much of a change, I don't understand the distinction he is trying to draw between Pactor 4 and other data modes with similar bandwidths and symbol rates. As he says, none of them are currently in use in Amateur Radio, even in other countries where there are no symbol rate limits. Why would their future use, assuming there was any, be more detrimental to other users of the RTTY/data subbands than would data modes with wider bandwidths and symbol rates of 300 bauds or less?
>
> The only reason the FCC chose 300 and 1200 bauds as the HF symbol rate limits when ASCII was first authorized was to accommodate the standards used in Bell 103 and 202 modems. There is no reason to perpetuate them today. In terms of protecting other users, limiting bandwidth makes much more sense.
>
> It's not a criticism of anyone to say that they may not understand the present Part 97 rules governing HF data emissions unless they won't accept explanations. The rules were developed over a 60-year period and are rather arcane. Many people don't seem to realize that data modes with bandwidths that exceed 500 Hz have been in legal use for more than a decade. In 2008 the FCC denied RM-11392, a petition by N5RFX to limit necessary bandwidth to 1.5 kHz and 2.4 kHz, respectively, as a substitute for the 300 and 1200 baud limits. A 1.5 kHz limit would have prohibited Pactor-III among others but the FCC said: "...we do not believe that changing the rules to prohibit a communications technology currently in use is in the public interest."
>
> I respectfully disagree with the characterization of "railroading." The symbol rate issue and the rationale for 2.8 kHz bandwidth was explained in the September 2013 QST editorial, which generated very little comment at the time. The ARRL Executive Committee did not authorize the filing of the petition until more than a month later. The proposed rule changes were deliberately limited to what was required to accomplish a narrow objective of permitting more efficient use of the bandwidth that was already being used for data communications, while at the same capping the bandwidth so that future developments would not be based on wider bandwidths.
>
> 73,
> Dave Sumner, K1ZZ
>
>
> -----Original Message-----
> From: Dick Flanagan [mailto:dick at k7vc.com]
> Sent: Tuesday, April 22, 2014 7:17 PM
> To: Sumner, Dave, K1ZZ
> Subject: Re: [RTTY] Fwd: RE: RM-11708 Outside US
>
> Joe isn't always the most tactful guy, but his arguments and those of
> other technically experienced folks on this reflector seem to be danced
> around or even ignored by those who publicly argue for the League's position.
>
> I would love to see someone with the appropriate technical credentials
> from the League rebut the naysayers with sound technical arguments.  I
> keep reading that if I don't agree with the League's position I simply
> don't understand the issues.  If that's the case (condescension aside),
> then there are a lot of highly experienced and respected scientists and
> engineers who also don't understand it.
>
> Dave, the League may be promoting the correct path, I don't know, but I
> do know that the manner in which the League is promoting this issue
> leaves a very bad taste in my mouth. Railroading a good idea is still
> railroading.  I really wish the League would publicly debate the issues
> with some of the world-class minds who don't agree with the potential
> unintended consequences of RM-11708.  I believe the RTTY reflector would
> be an excellent venue for that discussion.
>
> --
> Dick Flanagan K7VC - Life Member for over 40 Years
> dick at k7vc.com
>
> On 2014-04-22 3:15 PM, Joe Subich, W4TV wrote:
>> Of course K1ZZ spins the story again to promote the Board's misguided
>> policies ...
>>
>>> The ARRL petition simply seeks to replace the obsolete symbol rate
>>> limit ... with a bandwidth limit that includes the data emissions
>>> that are already in common use.
>> The proposed bandwidth limit includes *many* data emissions that are
>> not in "common use" and are not even permitted - specifically PACTOR 4,
>> STANAG, MS-110, ALE, etc.  While PACTOR 4 may never be a significant
>> interference problem (if RMS system operators follow the rules), the
>> other 2.8 KHz modes with their high symbol rates and high spectral
>> power density (high average power) will be an absolute disaster in
>> the narrow bandwidth portions of the amateur bands.  These modes are
>> totally new to amateur radio, have no current users and represent no
>> current spectrum loading in the CW/RTTY portions of the HF bands.
>>
>> It is these potential interference sources that K1ZZ and the PACTOR
>> clique seek to ignore.  However, interference and competition for
>> bandwidth from these modes are the very essence of what I have been
>> warning are the "unintended consequences" of ARRL's ill-conceived
>> proposal.
>>
>> Again, it is time for K1ZZ to stop minimizing the effects of RM-11708.
>> If ARRL want to eliminate the symbol rate, then eliminate the current
>> prohibition against RTTY and data modes in the wideband portions of
>> the HF bands, *put the wideband data modes with other wideband modes*,
>> ask for a reasonable 300 or 500 Hz limit for all narrowband modes
>> (just like the Commission imposed on narrowband *image*), ask for a
>> complete prohibition on all encryption and proprietary protocols, and
>> require that all data encoding be completely transparent. Regulation
>> by bandwidth is nothing new - the FCC has practiced that concept since
>> AM first appeared on the scene more than 80 years ago.
>>
>> It is time for K1ZZ to admit that the goal of the Board of Directors -
>> or at least a majority of the directors - appears to be elimination
>> of the separation between wideband and narrow band modes as a prelude
>> to Canadian style "anything goes" regulatory system.  They apparently
>> don't care if it destroys CW and RTTY, and K1ZZ will generate any
>> propaganda necessary in order to promote the boards' agenda, right,
>> wrong or indifferent.
>>
>> Frankly it's a damn shame that none of the board have the guts to stand
>> up and say "this will kill amateur radio as we know it" or do anything
>> to derail this runaway freight train.  Without changes to RM-11708,
>> within five years wideband data will so choke the traditional CW and
>> RTTY portions of the band that the pressure to allow it anywhere (after
>> all "it's the same bandwidth as an SSB signal") will be unstoppable.
>> Before anyone can blink an eye, with wideband digital everywhere the
>> amateur HF spectrum will be overrun with de facto encrypted (using non-
>> standard encoding) STANAG, MS-110, ALE and derivative modes with no way
>> for the ARRL OOs or the FCC to know who is transmitting and what is
>> being transmitted.
>>
>> That, my friends, will be the end of amateur radio - all because a
>> couple of PACTOR 4 zealots do not care about the unintended
>> consequences of their short sightedness and the rest of the board
>> isn't willing to stand up and say "wait a minute!"  The technology
>> is available for all of the unintended consequences *today* - unlike
>> the nebulous multi-tone, 300 baud wideband SDR based signal K1ZZ
>> likes to point to as a reason for 2.8 KHz instead of 300 baud limit.
>> However, it is the very 30 baud limit ARRL seeks to eliminate that
>> prevents the *immediate deployment* of these other technologies and
>> modes.
>>
>> 73,
>>
>>     ... Joe, W4TV
>>
>>
>> On 4/22/2014 5:02 PM, Dick Flanagan wrote:
>>> [Forwarded with permission]
>>>
>>> On 2014-04-21 10:43 AM, Sumner, Dave, K1ZZ wrote:
>>>
>>> Gerry,
>>>
>>> I see that your comments are among those received by the ARRL HF Band
>>> Planning Committee, so as an ARRL member you have not been
>>> disenfranchised. As far as FCC comments are concerned, the comment
>>> deadline was last December 23 and the deadline for reply comments was
>>> 15 days later. There has been no extension of either deadline.
>>>
>>> Regarding the substance of your comments, correct me if I am wrong but
>>> my impression is that the amateur regulations in the UK only specify
>>> frequency bands and power levels, and do not limit either the
>>> bandwidth or symbol rate of data emissions. The current symbol rate
>>> limit in the FCC regulations is very unusual and indeed may be unique.
>>> Other countries take a different approach. For example, in our
>>> neighboring country of Canada there is a bandwidth limit of 6 kHz in
>>> most of the MF/HF bands with no mode restrictions.
>>>
>>> The ARRL petition simply seeks to replace the obsolete symbol rate
>>> limit -- which because of advances in technology no longer has the
>>> effect of limiting bandwidth -- with a bandwidth limit that includes
>>> the data emissions that are already in common use. We believe it is
>>> important to get such a limit into effect before the inevitable
>>> development of broader data emissions using SDR technology.
>>>
>>> 73,
>>> Dave Sumner, K1ZZ
>>>
>>>
>>>
>>> -----Original Message-----
>>> From: Dick Flanagan [mailto:dick at k7vc.com]
>>> Sent: Friday, April 18, 2014 9:49 AM
>>> To: Ron Kolarik
>>> Cc: Sumner, Dave, K1ZZ
>>> Subject: Re: RM-11708 Outside US
>>>
>>> I suggest you and many others query Dave Sumner K1ZZ via k1zz at arrl.org
>>> as he is deeply involved in the International Amateur Radio Union
>>> (IARU) preparations for the next World Amateur Radio Conference
>>> (WARC).
>>>
>>> If Dave can't find a receptive ear with his contacts, I don't know who
>>> can.
>>>
>>> -- 
>>> Dick Flanagan K7VC
>>> dick at k7vc.com
>>>
>>> On 2014-04-17 9:39 AM, Ron Kolarik wrote:
>>>> Hi Gerry,
>>>>
>>>> On the first page where you enter your address there should be a check
>>>> box for domestic or international addresses.
>>>>
>>>> 73,
>>>> Ron
>>>> K0IDT
>>>>
>>>> ----- Original Message ----- From: "Gerry McGowan" <m0vaa at yahoo.com>
>>>> To: <rtty at contesting.com>
>>>> Sent: Thursday, April 17, 2014 7:03 AM
>>>> Subject: [RTTY] RM-11708 Outside US
>>>>
>>>>
>>>>> Hi,
>>>>> I've been following progress on this from the UK. The implications
>>>>> extend Worldwide.
>>>>>
>>>>> I'm a member of ARRL and have submitted my opinion of the filing to
>>>>> ARRL via the web.
>>>>> I feel somewhat disenfranchised as I can find no-one to represent non
>>>>> US members within the ARRL structure who I can approach to represent
>>>>> my views.
>>>>>
>>>>> I've tried filing comments with FCC via their website but cannot get
>>>>> past the first page as it restricts submissions to US citizens by the
>>>>> use of drop down menu for 'State' and needs a zip code.
>>>>>
>>>>> Anyone any idea how I can proceed ?
>>>>>
>>>>> Thanks
>>>>>
>>>>> Gerry M0VAA
>>>>> RTTY DXCC #2608, RTTY WAS, and avid low power RTTY contester.!
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>>>
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