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

[Joe Subich, W4TV]

 > Do you mind if I use your enumerated items for my submission?

Not at all.  Feel free to expand on and improve them if you wish.

The key points are that automatically controlled data systems *must*
include effective channel busy detectors, their end users *must* use
visual means to determine of the frequency is occupied or automatic
channel busy detectors and that ACDS should be restricted to very
narrow allocations where they will not interfere with the majority
of CW and narrow bandwidth data users.

Further, ACDS serves *no legitimate amateur purpose*.  The claimed
benefits for EMCOMM can be filled by manually monitored and controlled
systems established as needed within the impacted area during a
communications emergency.  No amateur, individual or ACDS, is entitled
to occupy scarce HF spectrum 24 x 7 by ACDS to the exclusion of all
other users.

73,

    ... Joe, W4TV


On 2015-03-14 12:59 PM, Michael Zolno wrote:
> 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
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