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

[Joe Subich, W4TV]

This is a another good chance to expose K1ZZ's propaganda for what it
is - nothing more that the blind promotion of bad ideas pushed by two
members of the Board through an ad hoc committee which they dominated
and passed by a Board of Directors that was permitted to head no
opposing voices until the petition had been filed with the Commission.
This entire process was concocted in the dark - away from both the 99%
of those using narrow band digital modes and the membership in general.

>> 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?

PACTOR 4 is primarily an e-mail/internet access protocol employed by
automatically controlled systems.  As long as the RMS operators follow
the rules, most of its interference will be self-limiting due to the
requirement that automatically controlled systems remain in narrow sub-
bands when using bandwidth in excess of 500 Hz.  That does not apply
to other wideband protocols - STANAG, MS-110, ALE - which are currently
not permitted due to symbol rates greater than 300 baud.

However, there is already a body (http://hflink.com) campaigning for
prime spectrum representing as much as 30% of each amateur band to be
designated for "ALE Primary" operation.  Although ALE is primarily used
for selective calling in conjunction with SSB operation currently, this 
embryonic demand for prime data spectrum associated with the ability to
adopt digital voice specifications and mixed payload represents a clear
danger to users of narrow band modes in a future 2.8 KHz data world.

It certainly does not take an engineer to understand that data modes
six to ten times as wide as current modes (2.8 KHz vs 250 Hz for 45
baud/170 Hz shift RTTY) will make frequency sharing impossible -
particularly when one understands that all or most of the 2.8 KHz wide
data protocols have no effective channel busy detection (at least none
for incompatible protocols) and no visible indication of other traffic
on the "channel" that would permit an operator to actively prevent
interference to existing users.

>> 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."

The Commission's specific reason for denying the petition to limit
bandwidth to that defined by the *current rules* for FSK - 300 baud/1
KHz shift and 1200 baud/1 KHz shift - was because other modes were
already in use.  However, the Commission has set a clear precedent in
2006 in WT 04-140 et al. (FCC 06-149) when it denied ARRL's own
petition to allow *wide band image* emissions in the "CW/RTTY" bands. 
It is reasonable to assume the Commission would have (and may still) 
follow its own precedent were there a way to accommodate existing
PACTOR III users - perhaps by allowing RTTY and data on all frequencies
where CW is permitted while restricting the "wide" modes to spectrum
on which other "wide modes" are currently in use.

ARRL (the Board) did not learn its lesson in WT 04-140 - nor has it
given consideration to 99% of users in the effected spectrum - in its
effort to promote the "wants" of the 1%.

 >> 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 September 2013 QST editorial was presented as a fait accompli - I
notice you (QST) did not published a single OP ED in opposition or have
any discussion of the negative aspects in the September 2013 editorial.
There has never been any effort to involve the broader membership in
this matter - and when there was a substantial outcry the Board refused
to even consider it or step back and listen to the membership.  The
"damn the torpedoes, full speed ahead" attitude is most certainly
railroading.  This proposal was rubber stamped by an ad hoc committee
of the board that was anything but balanced - two of the three board
members on the committed were the ones that moved and seconded the 
initial proposal to "legalize" PACTOR 4.  The other members of the
committee were staff who effectively work for those directors and can
not disagree.  If stacking the deck, not including those users who
would be most impacted by the changes in the process, and not listening
to opposition now isn't railroading, then there is no railroading.

>> 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.

The proposed rule changes were made without due consideration to the
unintended consequences of the change and without consideration for the
99% of users of the spectrum who would be impacted negatively.  The
proposed rule change was rushed - allegedly to prevent technology that
does not exist in amateur service today and is not, to the knowledge of
anyone who would be in a position to know - in development by any
amateur focused company.  However, the rule change would benefit on
specific company SCS GmBH and its commercial products while leaving a 
gaping hole for similar high symbol rate, wide bandwidth technologies
to run amok in the RTTY, data allocations.

K1ZZ's response is the same old "bury your head in the sand and we will
fix any problems with voluntary bandplans" approach we've heard ever
since this monstrosity was sprung fully formed on narrowband users.
Not only is this proposal dangerous - it fails to address the need for
mixed payload protocols (STANAG, MS-110 and even "Free DV") that may be
a significant benefit to amateur radio of the future and does nothing
to limit even bigger potential spectrum hogs (like D-Star at 6 KHz)
usage in the HF phone bands.  Considering the Commission's action on
RM-11392, simply pushing for 2.8 KHz no limits in the narrow band
spectrum causes problems today and does nothing to prevent bigger
issues in the future.

ARRL has a perfect opportunity to address not only the current problems
but address the future by pulling back this obscene attack on narrow
band users and bringing together a wide cross section of knowledgeable
persons to develop a solid proposal that represents a clear path to the
future.  It would be far easier to "sell" a proposal that deregulates
specific modes, places modes of similar widths together (grandfathers
ISB and AM at 6 KHz) and prohibits new, even wider modes.  Instead,
K1ZZ's job is to promote the "my way or the highway" approach of two
directors more committed to their own special interests than the future
and continued vitality of amateur radio.

>> 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.

That's nonsense, Dave.  In case you have forgotten, I was present at
the beginning of this and understand the present Part 97 and how we
got here better than anyone who is not a lawyer practicing in front
of the FCC.  I was one of the participants in the original TAPR/ARRL
STA that studied automatic HF digital operation and was a member of
ARRL's *first* ad hoc digital committee that proposed both the basis
for the current Part 97 sections on automatically controlled data 
operations and the bandwidth limitations that apply to them.

It pains me to say *we made mistakes* - we did not think about the
unintended consequences of our proposals.  We should have never agreed
to what was known as "semi-automatic" operation (allowing a station
under automatic control to respond to interrogation by a station
under local or remote control) and certainly *never* agreed to allow
such operation outside the sub bands defined for automatic control.
We should have *insisted* that all automatically controlled digital
stations include *effective* "channel busy" detectors, and we certainly
should have objected when PACTOR III with its 2.4 KHz bandwidth was
introduced as an upgrade to PACTOR II with its 500 Hz bandwidth.

Hindsight is 20-20 and it is easy to see the effects of "unintended
(and unforeseen) consequences" with 20 to 25 years of experience.  It
is "unintended consequences" like these that need to be addressed in
the current proposal - particularly when we have opportunity to do so
and the potential consequences are so much more obvious that those we
ignored in the past.  Dave, many of us understand *all to well* what
the rules are ... and we know the problems that the Board refuses to
address (or thinks they can paper over with 'voluntary' band plans).
Even Part 97.221 hasn't prevented the most egregious interference by
automatically controlled Winlink systems - hours of interference to
FT5ZM to the extent that many lost a once in a lifetime chance to work
Amsterdam on 40 meters, literally daily cases of automatic systems
responding to interrogation on top of existing RTTY activity on 80,
40, 30, 17 and 12 meters (or "up-shifting" from PACTOR II to PACTOR
III), or automatic systems firing up on top of stations in RTTY WW,
RTTY WPX, Roundup, etc.  The problems are not even limited to the US
as witnessed by the NRRL white paper documenting the problem of
automatic (and PACTOR 4) systems that dominate 30 meters from end
to end in Region 1.

None of opposition is a failure to understand the rules - it represents
the facts as they are and issues that have been systematically excluded
from the record before the board.  You can't continue attempting to
dismiss and discredit all opposition to this special interest grab as
malcontents and misinformed any more that you can give credence to
supporters for whom the extent of their intellect is to copy "we want
PACTOR 4" from a web site.

73,

    ... Joe, W4TV


On 4/24/2014 3:30 PM, Dick Flanagan 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
>>
>>