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

Thu Apr 24 16:59:59 EDT 2014

I appreciate you forwarding Larry's reply and while he still is sitting on
the throne of Part 97 wisdom, I must grant that he has much larger
experience in these issues than I ever would even want to have.

I also appreciated his reference to his editorial in the September 2013
QST. I remember reading it and thinking that a crap storm was about to
happen. He says there was little comment.

Read the editorial, you can access it under the digital archives of QST.

My comments, now  after sitting through hundreds of emails on the  topic,
are:
1. The ad hoc committee did one lousy job of determining the pulse of the
ham community on this. I suspect there was little consultation with anyone
who they didn't believe would like their idea. We call this confirmation
bias in the management consulting world.
2. Larry's editorial is all intro and no justification of how they came to
their conclusion. There was a promise that those issues of bandwidth usage
in the rtty section of the HF bands were considered by the committee and
the board. No explanation what they believed those issues were and how they
were addressed, just (again) a condescending statement that "it was
considered".
3. Its his contention that the FCC does not want to outlaw any mode than is
currently commonly used. He says at the end that everyone has a right to
get on the air, after all. Do they have a right to do it in the data/cw
part of the band? If its bandwidth is equal to SSB, let it live in that
part of the band. Do we have a right to sign everything sent with PGP so
its nice and secure? Surely seems like its commonly used.
4. Larry''s editorial did not give the impression that a proposal was
imminent, not even that they might ever make one. ("There is no timetable
for submission...") I think at this stage  of the editorial he was hoping
the alligator was asleep by rubbing its tummy. But Larry says they waited a
whole month after the editorial. If he had said "we plan to wait a month to
judge the reaction from the editorial " we would have  the crap storm we
are now seeing. But, he ways, we have no timetable.

The editorial was close to  deception with the "we have no timetable"
comments It felt like it was written mainly so he could say he wrote it
before they submitted it. It still respectively feels like manipulation and
railroading.

73

Neal Campbell
Abroham Neal LLC

On Thu, Apr 24, 2014 at 3:30 PM, Dick Flanagan <dick at k7vc.com> wrote:

> [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.!
>>>>>>
>>>>> _______________________________________________
>>>>> RTTY mailing list
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>>>>> http://lists.contesting.com/mailman/listinfo/rtty
>>>>>
>>>>
>>>>
>>>>
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