[RTTY] RM-11708

Paul Stoetzer n8hm at arrl.net
Mon Jun 9 11:20:29 EDT 2014 

You did not receive an email from the FCC. You received an email from
an individual who happens to work at the FCC.

I can opine about all sorts of things that my employer is involved in.
It shouldn't be confused with an official judgement of that entity.

And as you know, regulations have the force of law, unless courts say
otherwise (for example, if the courts rule that a regulation exceeds
the agency's statutory authority).

As far as your point about "what stops anyone else?" Well, what stops
"anyone else" is the rather rigid requirements which apply to a
station paying a control operator under 97.113(a)(3)(iv).
Realistically, the ARRL with W1AW is the only organization that can
meet those requirements. If you wish to begin a competing bulletin
service, go ahead and do so. I will not complain if you follow every
requirement of 97.113(a)(3)(iv).

Why is this suddenly an issue anyway? The ARRL has been transmitting
bulletins in this manner for decades. As far as I know, the ARRL has
never been cited by the Commission for a breach of the regulations for
it's transmissions over that time.

73,

Paul, N8HM


On Mon, Jun 9, 2014 at 11:09 AM, W0MU Mike Fatchett <w0mu at w0mu.com> wrote:
> Paul.
>
> Apparently you missed the email I received from the FCC that stated that the
> regulation quoted that allows them to pay a control op does not allow them
> to ignore any other rule.  We are talking about allowing a club to pay for
> the control op.  With their reasoning, if I wear a seat belt in a car, I
> should be able to legally speed.
>
> William Cross Wrote:
>
> "I agree that Section 97.113(a)(3)(iv) addresses compensation of a control
> operator of a club station in certain cases, and it applies to all club
> stations. That rule says nothing about interference and a club station
> transmission is subject to 97.101(d) just as the transmission by any other
> amateur station is. "
>
> I spent about 2 minutes thinking about solutions to their problem and came
> up with alternative frequencies and  just waiting for a few minutes.  The
> issue with these broadcasts are that that ARRL does not have system that
> allows them to individually control each station, which could be another
> problem.  I have been told that the system they built fires up all
> transmitters at the same time.
>
> The FCC creates rules and regulations not laws.  Congress create laws.
>
> It would appear that you do not mind intentional willful interference by
> anyone.  If the ARRL can read between the lines and do it, then what stops
> anyone else?  What does it say when the ARRL believes that they can squat on
> frequencies ignore certain rules and the excuse is that someone might squat
> on the frequencies that they are sqatting on.  This is a bit hypocritical
> isn't it?  The value of the message or practice is irrelevant unless the
> bulletins contains emergency traffic which takes priority over all other
> communications.
>
> I believe that the ARRL has been very lucky that nobody has filed formal
> complaints about the transmissions or how they operate their station.
>
> I personally do not want to see this happen and am in discussions with K1ZZ
> and my director.  I would suggest that others should contact their directors
> and discuss how the ARRL can address this in a mature reasonable manner.  If
> I was a winlink operator, this would certainly be a defense I would attempt
> to use.
>
> Mike W0MU
>
>
> On 6/9/2014 8:45 AM, Paul Stoetzer wrote:
>>
>> The ARRL has a very reasonable interpretation of the regulation. In
>> our system of law, reading between the lines is required.
>>
>> 73,
>>
>> Paul, N8HM
>>
>> On Mon, Jun 9, 2014 at 10:42 AM, W0MU Mike Fatchett <w0mu at w0mu.com> wrote:
>>>
>>> The ARRL does not care about deliberate interference.  They do it on a
>>> daily
>>> basis with the bulletins and code practice sessions and they either don't
>>> care or talked themselves into believing that the FCC gave them
>>> permission
>>> to do so by reading between the lines of a regulation that simply allows
>>> them to pay a control op.
>>>
>>> Mike W0MU
>>>
>>>
>>> On 6/9/2014 7:28 AM, Terry wrote:
>>>>
>>>> Ron,
>>>>
>>>> This is a great example of the deterioration of our amateur bands all
>>>> directly traceable to ARRL actions.  The www.SaveRtty.com team is
>>>> working
>>>> on
>>>> a new chapter that will be released soon that connects the dots between
>>>> the
>>>> ARRL Board, Winlink and developing recreational boater and HF email
>>>> products.
>>>>
>>>> In your interference example we have the ARRL endorsed ("recreational
>>>> boater
>>>> product") Winlink interfering with the ARRL W1AW/0 Centennial operation
>>>> and
>>>> the official response from K1ZZ at ARRL HQ is "short term frequency
>>>> conflicts are best dealt with by using the VFO knob".
>>>>    In reviewing all of the ARRL BOD minutes perhaps we missed the part
>>>> where
>>>> the ARRL BOD exempting Winlink from the ARRL Considerate Operators
>>>> Guide?
>>>> http://www.arrl.org/considerate-operator   Perhaps that exemption will
>>>> be
>>>> first on the agenda at the next BOD meeting.  ;-)
>>>>
>>>> Thanks for posting this.   Great info.
>>>>
>>>> Terry AB5K
>>>>
>>>>
>>>>
>>>> -----Original Message-----
>>>> From: RTTY [mailto:rtty-bounces at contesting.com] On Behalf Of Ron Kolarik
>>>> Sent: Sunday, June 08, 2014 9:01 PM
>>>> To: RTTY
>>>> Subject: [RTTY] RM-11708
>>>>
>>>> I've been debating whether or not to post this to the list but since
>>>> I've
>>>> had no answer to my original question, I did get a reply but no answer
>>>> on
>>>> how to proceed with a formal complaint,  here's what I asked and what I
>>>> got
>>>> back from K1ZZ. My reply to this is available if anyone wants to see it,
>>>> a
>>>> bit long though and probably not for the list.
>>>>
>>>> Ron
>>>> K0IDT
>>>>
>>>> Sent: Wednesday, May 14, 2014 11:48 PM
>>>> To: Craigie, Kay, N3KN
>>>> Cc: Roderick, Rick (1st Vice President); Fenstermaker, James, K9JF;
>>>> k0qb at arrl.org; Sumner, Dave, K1ZZ; Isely,Dick (Dir,Cl); Ahrens, Cliff,
>>>> K0CA;
>>>> Lisenco, Mike (DIR, Hudson); Woolweaver, David ( Dir, WG); Vallio, Bob
>>>> (Dir,
>>>> PC); Price, Brennan, N4QX
>>>> Subject: RM-11708 and a query
>>>>
>>>> To the ARRL
>>>>
>>>>
>>>> I'm writing in support of the recent emails from W4TV and N9NB to pull
>>>>
>>>> and reconsider RM-11708. I won't repeat the points already made except
>>>>
>>>> to state that the RM was produced with no input from the amateur
>>>> community
>>>>
>>>> and completely ignores the IARU Region 2 bandplan. As written there is
>>>> no
>>>>
>>>> protection for current narrow bandwidth users and the suggestion that
>>>> some
>>>>
>>>> future bandplan will correct the problems the RM will cause is
>>>> ridiculous.
>>>>
>>>> Why cause the problems in the first place? K1ZZ has pointed out that
>>>> Canada
>>>>
>>>> allows 6kHz emissions almost everywhere as a reason to allow 2.8kHz in
>>>>
>>>> the US narrow band segments. Has anyone at HQ actually listened to the
>>>> mess
>>>>
>>>> on 40m in the early evenings? There is spanish language and VE SSB clear
>>>> down
>>>>
>>>> to 7050kHz, doesn't leave much room for the rest of us and RM-11708
>>>> proposes
>>>>
>>>> to add unidentifiable wideband digital to the mix. Which leads me to my
>>>> query.
>>>>
>>>>
>>>> I would like to file a formal complaint but don't know where or who to
>>>> send
>>>> it to.
>>>>
>>>> I also don't know who I need to file the complaint against since the
>>>> offender(s)
>>>>
>>>> never identify in a mode I can understand. This past week I had the
>>>> opportunity
>>>>
>>>> to represent Nebraska as W1AW/0, thank you for that, I was strictly RTTY
>>>>
>>>> and the interference from the unattended stations made things difficult.
>>>> I
>>>> avoided
>>>>
>>>> the auto sub-bands because it's impossible to operate on a clear
>>>> frequency
>>>> there
>>>>
>>>> without one of the store and forward boxes just firing up at will. On
>>>> 40m
>>>> I
>>>> had
>>>>
>>>> to move down to 7062 to find a vacancy, running for over an hour before
>>>> a
>>>>
>>>> Pactor box lit up on my tx frequency, please don't tell me about the
>>>> hidden
>>>>
>>>> transmitter effect there is also reciprocal receiving to take into
>>>> account.
>>>> I can only
>>>>
>>>> assume I was interferred with by the side of the link with no
>>>> intelligence
>>>> present.
>>>>
>>>> 30m same thing, moved down to 10130 well away from the auto sub band and
>>>> sure enough
>>>>
>>>> another Pactor box fired up this time on the 1-2kHz above my tx
>>>> frequency
>>>> where I had
>>>>
>>>> a pileup going. Some of the DX stations also missed a chance to work me
>>>> on
>>>> 30m as
>>>>
>>>> they are only allowed digital above 10140. The 30m interference
>>>> continued
>>>> on
>>>> and off
>>>>
>>>> over several hours, the only thing I could do was wait for the station
>>>> to
>>>> deliver what I
>>>>
>>>> guess was some very important email that just couldn't wait. In the past
>>>> when these
>>>>
>>>> automated stations had CW id's I did identify one that was causing
>>>> problems
>>>> and sent
>>>>
>>>> a polite email, the response of "the frequency is published" was the
>>>> reply,
>>>> that's the entire
>>>>
>>>> reply. Since that time it seems most of the stations have turned off
>>>> their
>>>> cw id. Any
>>>>
>>>> suggestions on how to deal with the ongoing interferrence or who to
>>>> refer
>>>> the complaint to
>>>>
>>>> would be appreciated.
>>>>
>>>>
>>>> Now according to the RM some of the rules are archaic and outdated, it
>>>> may
>>>> be wise to evaluate the rules concerning unattended operation and easing
>>>> the
>>>> current interferrence
>>>>
>>>> problems, they were written a long time ago after all. The current IARU
>>>> Region 2 bandplan
>>>>
>>>> requests that unattended operation be limited on HF. The automated store
>>>> and
>>>> forward
>>>>
>>>> stations have had several decades to develop and deploy effective "busy
>>>> channel" detection
>>>>
>>>> and have failed miserably at it. It may be time to further restrict or
>>>> remove them from HF.
>>>>
>>>> While eliminating outdated rules it might also be good to revisit the
>>>> use
>>>> of
>>>> Pactor as a mode
>>>>
>>>> since the stations are not easily identified and there is absolutely no
>>>> way
>>>> to verify content
>>>>
>>>> if you're not part of the ARQ link.
>>>>
>>>>
>>>> Thanks for listening,
>>>>
>>>> Ron Kolarik
>>>>
>>>> K0IDT
>>>>
>>>> From: Sumner, Dave, K1ZZ
>>>>
>>>> To: 'Ron Kolarik' ; Craigie, Kay, N3KN
>>>> Cc: Roderick, Rick (1st Vice President) ; Fenstermaker, James, K9JF ;
>>>> k0qb at arrl.org ; Isely,Dick (Dir,Cl) ; Ahrens, Cliff, K0CA ; Lisenco,
>>>> Mike
>>>> (DIR, Hudson) ; Woolweaver, David ( Dir, WG) ; Vallio, Bob (Dir, PC) ;
>>>> Price, Brennan, N4QX
>>>> Sent: Wednesday, May 21, 2014 10:50 AM
>>>> Subject: RE: RM-11708 and a query
>>>>
>>>>
>>>> Ron, thanks for your message. Kay Craigie asked me to respond, but
>>>> travel
>>>> to
>>>> the Dayton Hamvention has put me a bit behind.
>>>>
>>>>
>>>> First of all, thanks for helping to make W1AW/0 available from Nebraska.
>>>> Yours was the first state to repeat, and it's interesting to see that
>>>> the
>>>> QSO demand was even greater the second time around.
>>>>
>>>>
>>>> Regarding RM-11708, it is important to keep in mind that the petition
>>>> does
>>>> not seek to "allow" HF data emissions with 2.8 kHz bandwidth. Such
>>>> emissions
>>>> are already allowed, with no limit as to bandwidth. The rules changes
>>>> proposed in RM-11708 are very limited. The existing 1980-era HF symbol
>>>> rate
>>>> limits are based on the old Bell telephone modems; otherwise there is
>>>> nothing special about them. In 1980 they served as a surrogate for a
>>>> bandwidth limit, but with more modern data modes they no longer serve
>>>> that
>>>> function. All RM-11708 proposes is to replace the symbol rate limits
>>>> with
>>>> a
>>>> bandwidth limit that accommodates the data modes that are already in use
>>>> while prohibiting the use of wider bandwidth modes in the future.
>>>>
>>>>
>>>> The petition has two objectives: to permit more efficient use of the
>>>> bandwidth that is already being employed and to prevent the deployment
>>>> of
>>>> data modes with wider bandwidths. Currently the only thing standing in
>>>> the
>>>> way of the latter is that up to now operation has been done with
>>>> conventional SSB transceivers, but with the dramatic increase in the
>>>> popularity of software defined radios that barrier no longer exists.
>>>>
>>>> The scope of the petition is deliberately limited. It does not purport
>>>> to
>>>> address issues such as automatically controlled digital stations and
>>>> proposes no related rules changes. The petition may not offer a solution
>>>> to
>>>> every existing problem but that is no reason to not support what it
>>>> would
>>>> accomplish, namely heading off the development of wider bandwidth HF
>>>> data
>>>> emissions than are now in use. One of the consequences of doing nothing
>>>> is
>>>> that the quest for higher data rates will be forced in the direction of
>>>> wider bandwidths, with no regulatory barrier to that development.
>>>>
>>>>
>>>> With respect, addressing issues through band planning is not
>>>> "ridiculous."
>>>> Band planning is not perfect, but it works pretty well except perhaps
>>>> during
>>>> periods of unusually intense activity. The FCC rules take precedence
>>>> over
>>>> voluntary band planning but we cannot expect (nor would we want) the FCC
>>>> to
>>>> resolve all of the compatibility issues among various modes. The last
>>>> time
>>>> the FCC did so had a very unfortunate result: the 80 meter RTTY/data
>>>> subband
>>>> was compressed from 250 kHz down to 100 kHz, with severe consequences
>>>> for
>>>> CW, RTTY and data operators. The FCC gave short shrift to our petition
>>>> for
>>>> reconsideration at the time, but a common thought heard recently is that
>>>> it
>>>> may be time to reintroduce the subject.
>>>>
>>>> Internationally, our 10 MHz allocation is secondary to the fixed service
>>>> and
>>>> we are obligated to avoid interfering with stations in the fixed
>>>> service;
>>>> that is the reason for the 200 watt power limit and the reason why there
>>>> are
>>>> so many non-amateur signals in the band. Working around them is a
>>>> challenge
>>>> in the best of times and it may not always be possible to do everything
>>>> in
>>>> the band that we would like, but we're far better off having the
>>>> secondary
>>>> allocation than not having it.
>>>>
>>>> Quite a few ARRL Official Observers are capable of identifying stations
>>>> using the various data modes including Pactor, although monitoring
>>>> message
>>>> content of ARQ modes is more difficult. We can request that OOs monitor
>>>> specific frequencies at specific times if illegal operation is
>>>> suspected,
>>>> but short term frequency conflicts are best dealt with by using the VFO
>>>> knob. There was a rather amusing one at the start of the Colorado and
>>>> New
>>>> York operations last night on 40 CW: W1AW/0 was on 7029 listening up 1
>>>> and
>>>> W1AW/2 was on 7030 listening up 1. The New York op QSY'ed after a few
>>>> minutes.
>>>>
>>>> 73,
>>>>
>>>> Dave Sumner, K1ZZ
>>>>
>>>>
>>>>
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