[RTTY] FW: If you care about CW and RTTY - time is of the essence

Sat Aug 13 22:15:10 EDT 2016

I just received the note below from Ted, N9NB.

As Ted says, if you don’t agree with him or don’t care about this, then please delete the message.

Here’s a summary of his background:

http://www.arrl.org/news/ted-rappaport-n9nb-named-recipient-of-ieee-education-award .

73, Jim N7US

From: Ted Rappaport N9NB [mailto:tsrwvcomm at aol.com] 
Sent: August 13, 2016 20:26
To: Jim McDonald <jim at n7us.net>
Subject: Re: If you care about CW and RTTY - time is of the essence

Jim, I really appreciated your note, and hope you are able to reach many many people. 

This is quite real, and hope that you and others will write the ARRL CEO as well as all your elected ARRL directors when you file your FCC comments. Here is a note I sent out to the PVRC, giving 4 examples of what will happen if this NPRM is not modified. I fear that everyone who likes CW and RTTY has no clue how real of a threat this is.

Thanks for your interest and your help to save CW and RTTY from massive digital data and digitized voice traffice. This is our last ditch effort. If the present day apathy by CW/RTTY ops continue, and if ARRL and FCC do not hear clearly from people who care, we will lose our HF protections forever.

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Hi y’all:

Life is short, and this great hobby has enough room for everyone! 

Pactor, DX, Winlink, Contestting, SSB, RTTY, etc...... We can all coexist, but the HF spectrum is very limited, and sadly the FCC is about to sign into law a really grave error that will completely disrupt CW/RTTY if you don’t read and file comments at the FCC about NPRM 11708 and WT 16239. We must write to both our ARRL officials at all levels, as well as file public comments at the FCC.

The FCC is about to make this officially law, but is taking last ditch comments from now (up until October 5th or so) and then during a one month “Reply to Comments” phase. this is our LAST CHANCE to really get the base of CW/RTTY users to write in to ARRL and FCC officials to modify this law.... NPRM RM 11708 cannot be repelled at this point, only modified, unless a miracle occurs and ARRL recinds it – not likely unless tens of thousands of us write to ARRL officials while also filing comments.

Here is what RM 11708 will enable, if it is passed into law as the FCC is proposing in its NPRM 11708 published on July 28, 2016. Note the FCC ignored ARRL’s request for a 2.8 kHz bandwidth to replace the 300 baud limit, and instead is proposing an **unlimited** bandwidth limit with no baud rate limit. Unfortunately, neither the ARRL or FCC have recognized the resulting interference that will occur to the narrowband CW and RTTY users, and have never once considered a 200 Hz bandwidth emission limit on the lower 50 kHz and 500 Hz emission bandwidth limit on the lower 100 kHz of every HF band (That is what is needed for protection, and we must write in by the tens of thousands!!! To ARRL and to FCC! See footnote 37in their July NPRM, very short shrift given to this argument!). Here is what will happen if CW/RTTY apathy continues:

1. SSB and other voice operations will be freely allowed in all the CW/Data/RTTY segments of HF with unlimited bandwidth, as long as the signals are digitized into data first. This NPRM opens up digitized voice to the CW/RTTY lower end HF bands -- digitized voice using 12.5khz c4fm stations will be allowed,  since the FCC has not proposed a bandwidth limitation. And this is not a conspiracy theory, its real.

2. If the rule passes without any bandwidth limit, or with the ARRL’s suggested 2.8 kHz bandwidth limit on the low end, Pactor 4 will be permitted and conversations will be encrypted as part of the protocol.  And if there were to be a way to listen in, it’s going to require a the purchase of a Pactor 4 modem which is not cheap.  Meaning you have no ability to identify the call sign of a station short of engaging in a Pactor 4 based conversation. No way for OO’s to find offending station since no CW id is needed.

3. A lot of the Automatic Data stations (the auto repeaters that are already causing great QRM) are tied in with the watercraft and boating crowd. Which means the stations would ring the coastline using new data services in the CW/Data part of the band to log into Facebook, check weather, and make dinner reservations.  So unless you are beaming north, you are going to be pointing toward one of those stations.

4. At about 2.4 Khz per station for Pactor 4, and with MANY more stations active (the P4 speeds make email via HF a lot faster and less painful, which will drive more users after this NPRM is legalized), it won’t take much to swamp all the traditional RTTY segment.  That pushes the RTTY guys down into the top of the CW segment. And not to even mention digitized voice signals that will be allowed there, too!

No matter how you slice it, even with voluntary band plans, this means trouble for the RTTY operators right up front, and more congestion for the CW bands as a result.  Of course, the SSB guys successfully defeated essentially the same proposal 10 years ago (ARRL TRIED TO PASS RM 11306 in 2005, but rescinded it in 2007 because the SSB operators made enough noise to get the ARRL to pull it from the FCC consideration—Check out RM 11306 and -- CW and RTTY apathy has failed to make enough noise, and now this is about to become law).  It has gone too far, and CW/RTTY people have not been heard, and this is about to remove the enjoyment of our bands forever! Please get active. This is real. Please don’t take this lightly and do nothing, please get your CW/RTTY friends engaged. Read the NPRM! See Footnote 37. See what the FCC is about to sign into law. You only have 2 months to move the ARRL and the FCC to modify this rule.

Lets give Pactor 4 and Winlink its due at 100 kHz and above from the low end of HF, but lets also preserve the lowest 50 kHz for CW and lowest 100 kHz for RTTY by urgently requesting bandwidth limits that preserve CW and RTTY. 

Tell your ARRL official and write in to the FCC about the need to have narrow bandwidth protection in the low end of HF if they remove the 300 baud rate -- we need tens of thousands of thoughtful responses! I am copying Brennen Price, ARRL’s CTO and PVRC member, here. And I hope you and others will similarly write him and all ARRL officials while you submit your short, focused comment to the FCC on RM 11708 and WT 16239 to seek interference protection on the low part of HF, as well.

73 ted n9nb

On 8/8/2016 12:14 AM, 'Jim McDonald' jim at n7us.net <mailto:jim at n7us.net>  wrote:

>From the SMC reflector.

73, Jim N7US

-----Original Message-----
From: SMC [mailto:smc-bounces at w9smc.com] On Behalf Of Mike Wetzel
Sent: August 07, 2016 18:38
To: smc at w9smc.com <mailto:smc at w9smc.com> 
Subject: [SMC] if you care about CW and RTTY - time is of the essence

>From Dr. Ted Rappaport N9NB

Dear Colleagues:

If you believe, as I do, that the proposal to unregulate the bandwidth of
data signals (like Pactor 4) in the lower HF portion of the spectrum is
dangerous for the hobby, both in the US and abroad, then please read on as
we need your help. If you do not agree with me, or don't care about this,
then feel free to delete and stop reading.

I ask that you PLEASE take action by filling public comments with the FCC
regarding their recent RM 11708 proposed rulemaking in WT Docket No. 16-239
and RM-11708, and please forward this to every CW and RTTY enthusiast you
know in ham radio, on every reflector, in every CW and RTTY club, both in
the US and elsewhere, and urge them to also file comments with the FCC. We
have less than 3 weeks to voice our opinion! It was not heard in 2014-2015.

TIME IS OF THE ESSENCE! There are less than 3 weeks during which the FCC
will accept comments.

I am fearful and quite certain that RM 11708, as published in WT Docket No.
16-239 , which the FCC is now seeking public comment on as a prelude to
enact its ruling, will terribly erode CW and RTTY on the HF bands in its
current form. The ruling will allow PACTOR 4 and multi-tone modems on any
frequency within the CW/RTTY frequencies on HF. This is worse than allowing
SSB to operate throughout the CW/data sub bands, something the FCC has never
allowed. The FCC is proposing an unlimited bandwidth for data signals in the
lower HF bands (the ARRL asked for 2.8 kHz-- the bandwidth of SSB--- which
was still bad - and the FCC proposal is even worse). I would urge all of you
write in to object to RM 11708 and to ask that the FCC place a 500 Hz
bandwidth limit all data transmission bandwidths such as Pactor, multi tone
data modems, and other experimental data modes on all HF bands within the
lowest 75 or 100 kHz region of each HF band. Japan has something similar. If
we don't generate large support from hams to scale back the FCC proposal,
and put a bandwidth cap in some portion of the lower HF bands, these monster
QRMers of unlimited bandwidth will be allowed to operate anywhere in the
CW/RTTY lower HF bands, and they will lawfully fire up on your CW or RTTY QS
when you are least expecting it. 

See below how the proponents of RM 11708, including my friend Tom Whiteside,
are launching an aggressive letter-writing campaign for "pro" comments to be
filed at the FCC to allow Pactor 4 and other wideband multi-tone modems to
operate anywhere in the CW/RTTY spectrum, without a segregation of the band.

The public filing period ends in a few weeks, so we must write now to offer
opposition to the Commission. The need for WinLink/Pactor data emergency
communication on HF is being used as one of the arguments for expanding the
data bandwidth. See the other arguments below. I would urge CW and RTTY
enthusiasts to review the arguments for and against RM 11708, see the public
comments filed from March 2014 to today, and please be moved to quickly to
write about your opposition to the newly proposed regulation just released
by the FCC (It can be viewed here):
http://transition.fcc.gov/Daily_Releases/Daily_Business/2016/db0728/FCC-16-9
6A1.pdf

Please see Tom's email below on how to file a comment, but I would urge you
to read the FCC proposal and file comments *against* the FCC's proposed
rulemaking. You can see the ballet box is again be flooded for the expanded
data privileges in the past week - there are only 20 days to file comments. 

If this ruling is enacted, and the FCC is leaning that way, this will come
at a cost to CW and RTTY . See these comments already filed:
https://www.fcc.gov/ecfs/search/filings?sort=date_disseminated,DESC <https://www.fcc.gov/ecfs/search/filings?sort=date_disseminated,DESC&proceedi> &proceedi
ngs_name=RM-11708

Unfortunately, in the FCC proposed ruling issued over a week ago, the
Commission appears to have ignored ALL comments made by hams after the
initial 30 day comment period back in late 2013. During that one month
period, there was a 95% "pro" letter writing campaign by over 800 people --
It was only after the CW and RTTY enthusiasts woke up in March of 2014 that
public comments became overwhelmingly negative against RM 11708.
Unfortunately, the FCC has apparently ignored all of those comments, so new
comments need to be filed on the FCC;s recent ruling.

If you care about CW and RTTY, please file comments against the ruling, to
preserve some sanctuary for narrowband data (having less than 500 Hz
bandwidth), the way the largest ham country (Japan) has done to ensure no
QRM to CW and RTTY enthusiasts.

Thanks for considering. 
Best 73 ted n9nb

Winlink Global Radio Email for Disasters or Emergency Preparedness
communications. Group
1 Message
Digest #4406
1
Comments on RM-11708 - time to get those comments in! by "Tom Whiteside"
n5tw
Message
1
Comments on RM-11708 - time to get those comments in! 
Fri Aug 5, 2016 2:36 am (PDT) . Posted by: 
"Tom Whiteside" n5tw
As you have heard on this reflector, the FCC has amended the ARRL filed
RM-11708 and is now seeking comments on this. It is critical that we add our
supporting comments during this period and the process below is a step by
step on how to do so.

I'd suggest something simple - please make it clear that you support the
amended proposal - these responses are going to be tallied at least at the
first level by clerks so be clear! In my filing, I emphasized the clear gain
in efficiency with the elimination of the archaic symbol rate and sited
currently not legal Pactor 4's ability to double the throughput in the same
bandwidth as Pactor 3 and that this would bring us on par with the rest of
the world.

Use your own words - form letters will be seen as such.

And thanks for your important support! Instructions on filing below:

Tom Whiteside N5TW

=====================

IMPORTANT MESSAGE: Time is running out for comments supporting RM-11708 to
the FCC, which would remove the symbol rate limitation from FCC rules, and
allow hams to use Pactor 4 modems in the USA. If the proposed rule change
fails this time, it will be years before we have another chance.

It is very easy to submit a comment. Please do. You don't have to say much
other than you think it's a good idea, and that you support it.

Here are the steps to submit a comment.

1. Go to  <http://apps.fcc.gov/ecfs/> <http://apps.fcc.gov/ecfs/> http://apps.fcc.gov/ecfs/

2. Select "Submit a Filing (Express)" from the list in the upper left corner
of the screen.

3. In the topmost paragraph of the next screen, click "click here to
manually enter your docket number" 
.

4. Enter RM-11708 as the "Proceeding Number". Enter your name, address, and
type your comments in the bottom field.

5. Click "Continue";, and then click the "Confirm" button on the summary
page it will display.

6. If everything goes properly, it will give you a submission confirmation
number.

Here are the relevant points:

a. The proposed change does not alter the bandwidth limits or the
frequencies available for digital use, so no new frequency space is being
used. It has no negative impact on the Ham spectrum.

2. The use of Pactor 4 simply makes the use of existing bandwidth more
efficient, so additional traffic can be passed without allocating new
frequencies.

3. The further development of even faster protocols in the same bandwidth
limitations depends on the success of this rulemaking