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

[Michael Zolno]

Joe,

Lots of good advice which I hope and pray will be followed. Do you mind if I use your enumerated items for my submission? 

Mike WH6YH 

Sent from my iPad

> On Mar 14, 2015, at 12:00 PM, rtty-request at contesting.com wrote:
> 
> 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