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

Sun Aug 14 14:04:02 EDT 2016

Forwarding on behalf of Ted N9NB 

73,

Ed W0YK

___________________________________________

Begin forwarded message:

From: Ted <tsrwvcomm at aol.com>
Date: August 14, 2016 at 10:55:40 AM EDT
To: Matthew Pitts <n8ohu at yahoo.com>

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

Hi Matthew: thanks for sending me your note.

 I am not a part of the RTTY email list. So, I would ask you to please
forward my note as a rebuttal to your comments. I will also send this to a
few people who are perhaps on that RTTY alias, in case you don't care to
forward my note. 

I am happy to reply to Mathew Pitts' comments, and hope you all will read
carefully the NPRM issued by the FCC this July 28, 2016. And please spread
the word. This is not fear mongering, as I have too many  things to do in my
day job to spend time on anything that is not real. I am trying to get
people to read the NPRM and realize what is happening – and its sad for me
to see how hard it is to get CW/RTTY enthusiasts to realize that they are
false to assume the ARRL and FCC would preserve CW or RTTY. They now have to
take serious action if they care about preserving their operating bands.

Understanding this and the history of the digital aggression goals of ARRL,
WINLINK, and the boating community is vital to realize the ramifications of
the July 28 2016 NPRM by the FCC. The NPRM 11708 of July 28 2016 is about to
become law and is what the FCC intends to do if there is not a vocal outcry.

In particular, please read Paragraphs 9 through 12 of the FCC's NPRM of July
28,2016 super carefully!That’s were it is clear that the DATA/RTTY HF
subbands, which include ALL CW and RTTY frequencies, from the lowest edge of
the HF band up until the Voice/Image subbands, will be subjected to
unlimited bandwidth new data signals. That is, the FCC is proposing to
authorize UNLIMITED BANDWIDTH, and UNLIMITED DATA RATE signals in the ENTIRE
Data/RTTY HF subbands from the lowest edge up to the SSB/Voice/IMAGE
subbands. All of the CW and RTTY frequencies are impacted in that sub band –
that’s where CW and RTTY operate – that should be clear to anyone reading
the NPRM.

This NPRM is a rule, with the force of law, about to be passed by the FCC.
Its already gone much farther than RM 11306 did when the ARRL tried this
same proposal at the FCC in 2005 to put this wideband data in the
SSB/Phone/Image band – the ARRL pulled it because the SSB operators were
well organized and vocal. But now they have gotten it through the FCC in the
CW/RTTY subbands --- it never went that far before, because SSB hams shouted
it down at the ARRL............sadly CW/RTTY operators have not been
successful and have had huge apathy and skepticism about the threat, and now
this is about to become law unless there is a MAJOR outcry and comments at
both the FCC and ARRL to stop the interference in the lowest 100 kHz.).

Please, please educate yourself by reading about RM 11306 on the web. It was
a ferocious battle in 2005-2007 . The ARRL withdrew it in 2007, finally.
They then retooled it in 2013 as RM 11708, and have it about ready to get
into law – UNLESS people respond mightily to ARRL officials and the FCC
during this 2 month comment period. this is not fear mongering, I assure
you. Its trying to get people awake and aware of the pending law in the FCC
publication. Without strong consideration and response, ham radio in the US
will be subject to this rule making, and its going to be very bad for
CW/RTTY, just like the SSB ops saw and successfully fought off in RM 11306.

For history, see RM 11306 on the web. So many thousands of posts rejected RM
11306, an arrl board member resigned in disgust, here is just one simple
sample assessment, when the ARRL proposed this identical proposal 10 years
ago, except in the phone sub bands, (Now they are getting it into the
Data/RTTY subbands, which by definition are where CW and narrowband modes
operate):  

http://www.eham.net/articles/13018

Here are specific answers to some of your questions or doubts  about the
gravity of rm 11708 by the FCC :

Yes, this impacts all CW and RTTY on HF, because the NPRM specifies all HF
“Data/RTTY” subbands. That is the subband where CW and RTTY and narrowband
JT65 and PSK 31 operate.

Yes, the FCC is proposing UNLIMITED bandwidth. Even if the FCC accepted
ARRL’s 2.8 kHz bandwidth limit, the problem STILL negatively impacts CW and
RTTY signals, since Pactor 4 and other HF modems will be allowed in ANY
CW/RTTY frequency, and digitized voice of up to 2.8 kHz bandwidth will also
be allowed on ANY CW /RTTY frequency. This would cause widerband SSB-like
bandwidth signals to mix and overtake CW/RTTY narrowband signals. Note that
CW has only 200 Hz max bandwidth, RTTY has 500 Hz max bandwidth. These
narrowband signals cannot be used when they are clobbered by 2.8 kHz wide
band signals. That is why the FCC never allowed SSB to operate on top of the
CW/RTTY signals. We must keep this segregation by bandwidth to assure CW and
RTTY can operate without wideband interference. That is why I and others are
advocating that the NPRM be MODIFIED to limit the emission bandwidth to 200
Hz in the lowest 50 kHz of each HF subband, and why a limit of 500 Hz should
be enforced for the lowest 100 kHz of each subband. That would assure that
CW and RTTY would not be subjected to wider band interfernce, while still
allowing wider band data to exist above 100 kHz above the lowest HF edges.

Regarding Pactor and its problems, that is, what we will be subjected to if
the ARRL’s 2.8 kHz bandwidth is eventually accepted at the FCC (right now,
that does not look likely – the FCC wants to open the bandwidth to be much
greater – unlimited)

PACTOR in general (I do not know the specifics of PACTOR 4) uses run
length encoding and decoding a technique in which common words and
strings of two or more letters (e.g., sh, ing, in, on, the, etc.) are
replaced with a "token." In addition, the resulting message is then
compressed (apparently PACTOR 4 adds the ability to use an ecrypted "key"
for
the commercial version).

However, the developers of PACTOR do not release details of either the
compression algorithm or the substitution table for PACTOR 2 - 4.
so its not really public, and its unintelligible unless you buy the $1500
modem. and there is no cw ID. Yet its being used today in ham radio under
the guise of being published. It’s a grey issue.

When you read the FCC NPRM Paragraph 10, they mention 97.309( a) as being
the only codes allowable on HF/MF
, but the problem is §97.309 (a) contains several parts - it specifies ITA
2, AMTOR (SITOR)
and ASCII data formats ("Codes") but also - in §97.309 (a)(4) - lists
several permitted *transmission methods* (or "encoding methods") "whose
technical characteristics have been documented publicly" including
PACTOR. But that’s not really whats happening today.

The issue is that the only the original PACTOR was *publicly documented*
- the PACTOR 2 - 4 encoding systems are **NOT** publicly documented! Yet
Pactor 3 is operating today.People cannot stop or identify offending
transmissions that QRM them with Pactor 3. Will be so much worse with Pactor
4 and future data signals!

Another major  real problem is in §97.309 (b) which permits "undocumented
codes"
under certain circumstances.  The loopholes in §97.309 (b) are big
enough to drive a bus through. Has been the cause of QRM already for years
with automated data.

All of this will become so much worse if NPRM is legalized, and the FCC is
not dealing with these issues and are ignoring it, as you can see in NPRM
paragraph 10, where it simply assumes all hams will use only enough
bandwidth as they need .Yet the FCC contradicts itself and says that
wideband experimentatoin should be supported, of arbitrary large bandwith,
so there is a huge disaster waiting to happen if the NPRM is passed as is
---- the existing problems with Pactor will immediately errupt into a huge
mess and no regulation on the TTY subbands!  right now, the FCC is leaning
towards no bandwidth protection and no bandwidth limit for the lowest 100
kHz of each HF band for CW/RTTY to keep all emissions below 200 or 500 Hz.
You allow wider transmissions than this, e.g. unlimited bandwidths as
proposed by the FCC, or 2.8 kHz bandwidths as originally proposed by the
ARRL, and the entire CW/RTTY lower portion of HF becomes swallowed up in
wider bandwdith data signals, either PACTOR or wider with digitized voice,
etc. over time. that is what is at stake. I hope this makes sense! {Please,
please get active and spread the word, if you care about CW or RTTY.

Thus, Matthew's desire to minimize the impact of the FCC's proposal is not
accurate. Also, Canada has a tiny fraction of hams as the US and propagation
from VE often goes over the US on high bands- It's a red herring. This is a
real threat to all of RTTY and CW and requires immediate action and
thoughtful comments to the FCC and ARRL officials.

73 ted n9nb

Sent from smartphone, please excuse typos

On Aug 14, 2016, at 10:34 AM, Matthew Pitts <n8ohu at yahoo.com> wrote:

Some major flaws that I see in his argument are:

1: Digital voice is classified as "Phone" hence not permitted in the
RTTY/data segment to begin with; that won't change even if the FCC bandwidth
proposal is enacted as written.

2: Data compression is not encryption, and Winlink doesn't even use the
Pactor data compression anyway; they use the same one that is used in the
F6FBB Packet BBS. Also, the FEC ID capabilities for all versions of Pactor
are identical, so any software that can decode Pactor 1 can be used to ID an
interfering station.

3: Despite what he's claiming, there is absolutely no interest in
implementation of such things, even if some tiny fraction of users might
want to see it happen.

4: As I said before, claims of a massive increase in the number of automatic
stations or wide bandwidth digital voice stations swamping the RTTY/Data
bands are nothing more than FUD.

Also, a 500 Hz bandwidth limit would do little to reduce interference when
Canada has a 6 kHz bandwidth limit.

Matthew Pitts
N8OHU

On August 13, 2016 10:15:10 PM EDT, Jim McDonald <jim at n7us.net> wrote:

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-educatio
n-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.

`````````````````````````````````````````````````````````````````

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
<https://www.fcc.gov/ecfs/search/filings?sort=date_disseminated,DESC&proceed
i> &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

_______________________________________________

RTTY mailing list

RTTY at contesting.com

http://lists.contesting.com/mailman/listinfo/rtty

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