[RTTY] ARRL Request for Member comment on Proposed HF Band Plan Change

[Joe Subich, W4TV]

The period for comments on ARRL's grossly misguided HF Band Plan
Change has roughly one month left.  The comment period ends April 19.

Today, I submitted my comments very much along the lines of those
I posted here two weeks ago:

ARRL's proposal misses the mark on *every count*.

It needs to be completely rewritten to include:

1) expand 80 meter data to 3675 not 3650 ...
2) move the "automatically controlled data" segments to 3560-3570,
    7110-7120, 14130-14140, 21180-21190 and 28280-28290 *ONLY* - with
    *no automatic control on 60, 30, 17 or 12 meters* due to the limited
    available spectrum.
3) require *all* automatically controlled data stations - including
    "auto-responding stations" - operate in the automatic control
    (Section 97.211) sub-bands.
4) require all automatically controlled data stations - including "auto
    responding stations" - implement fully functioning "channel busy"
    detectors which respond to 125% of the [maximum] bandwidth to be
    used including any "enhanced speed" modes.  The channel must be idle
    for at least 90 seconds before initiating *any* transmission or 90
    seconds prior to receiving a call *when responding to interrogation*.
5) require all automatically controlled data stations - including "auto-
    responding stations" and *US licensed amateurs* operating systems
    off shore - list their frequencies, operating times, and control
    operator telephone number in a publicly accessible database
7) require all manually controlled digital stations include either
    visual means (e.g. spectrum display or "waterfall") of determining
    whether a frequency is busy before transmitting *or* a channel busy
    detector with the same parameters as automatically controlled data
    stations.
6) allow Novice/Technician licensees to use *only* RTTY (45.45 baud,
    170 Hz shift) and PSK31 within their current allocations and any
    expanded 80 meter data allocation.

I don't believe there should be any "grace period" for automatically 
controlled digital stations (including "auto-responding stations") to 
implement the *effective* channel busy detection and establish a public
database of schedule/contact information.  In addition, I do not
believe that automatically controlled stations should *ever* operate
outside an extremely limited spectrum (e.g., 97.211 allocations) as
automatic channel busy detection can not be 100% effective and
automatic operation is incompatible with the first come first served
(no "assigned channels") nature of amateur radio.

As as early adopter of ACDS, participant in the Special Temporary 
Authorization issued to TAPR in the late 1970s for the study of
automatically controlled HF forwarding systems, and member of ARRL's
*first* ad hoc Digital committee, I believe ACDS are a blight on amateur 
radio and serve *no legitimate amateur purpose*.  The claimed EMCOMM 
role can be provided by *manually controlled and monitored* stations 
established in [limited] areas impacted by a communications emergency 
during the emergency and for limited drills not to exceed four 
[consecutive] hours per month.

73,

    ... Joe, W4TV