Topband: RM-11708

Sat Mar 15 20:49:45 EDT 2014

It is doubly incorrect to say " this Proposal would not alter FCC Part
97.221, which limits automated stations to a small section of the digital
bands."

1. Within the frequency ranges specified in 97.221(b), there is currently no
regulatory limit on bandwidth. However,  97.307(f)(3) limits the symbol rate
to 300 baud in these frequency ranges, which given the passband
characteristics of most HF transceivers creates a practical bandwidth
maximum of 2.2 kilohertz. If accepted, RM-11708 would eliminate the 300 baud
symbol rate limit, making it both practical and legal for automatic stations
to use 2.8 kilohertz wide signals in the 97.221(b) frequency ranges -- a
significant increase over what's currently practical and in use. Without any
requirement that such automatic stations employ competent busy frequency
detectors, the result will be a significant increase in QRM to ongoing QSOs.

2. 97.221(b) specifies 10.140-10.150 -- which is 20% of the entire 30m band,
and most of the portion of that band used for digital mode operation. This
is not a "small section" of the 30m digital band.

        73,

            Dave, AA6YQ

-----Original Message-----
From: Topband [mailto:topband-bounces at contesting.com] On Behalf Of Brad Rehm
Sent: Saturday, March 15, 2014 7:58 PM
To: topband at contesting.com
Subject: Topband: RM-11708

Topbanders,

Here are some comments on RM-11708 which I think are relevant to topband
operation.  We've been asked to send responses to the ARRL, so remember that
responses to the reflector may stimulate discussion, but they won't affect
decisions taken at the League unless you send them in that direction.  I
realize this topic has been discussed earlier on our reflector, but it's
important enough to warrant more exposure.

These remarks are copied from the Central Texas DX & Contest Club reflector.

Brad, KV5V

From: Terry Gerdes, AB5K and Dan White, W5DNT

As many of you know, RM-11708 (the "Proposal") has been submitted by the
ARRL to the FCC as a "rule making" request. If approved, wide band digital
modes of up to 2.8 KHz bandwidth would be allowed in non-phone bands,
potentially impacting traditional CW & RTTY frequencies as new digital modes
are developed.

This Proposal would not alter FCC Part 97.221, which limits "automated
stations" to a small section of the digital bands. An exception is granted
in 97.221 for modes of 500 Hz or less, so the Proposal should not create new
automated wide band stations in CW & RTTY bands. However, as modes develop,
we would certainly expect wide band peer to peer communications to pose a
serious threat to our traditional CW and RTTY frequencies if the proposal is
approved by the FCC and no stringent band plan is developed. Once the
Proposal was made to FCC, the ARRL acknowledged the need for proper detailed
band planning to mitigate potential detriments to CW & RTTY. In early March,
they began a one month process of soliciting member input into that band
planning process.

As avid CW & RTTY DXers and Contesters, this potential threat posed by the
Proposal, coupled with limited time remaining for member input (through
March 31st), has caused us to have extensive communications with ARRL
leadership to insure both CW and RTTY operators are represented in this
process. This has occurred over the last two days.
We are happy to say those conversations have been constructive. HOWEVER,
those discussions certainly do not constitute a fix in our minds. WE NEED
YOUR HELP!

What is needed is for each of you to submit your own input into the process.
Besides, you may or may not agree with what we have provided.
Please make your input constructive and specific, listing any bands and
frequency ranges you would find acceptable, if any, for wide band digital
modes. The objective here is to generate as much input as possible for the
HF Band Planning Subcommittee, chaired by Rick Roderick, K5UR. Rick, an avid
DXer and Contester himself, has assured us that all input will be
considered. That doesn't mean agreed to, but it will be considered. All that
we can ask for is objectivity and fairness.
After our discussions, we believe Rick will bring that to the process.

What we don't need is more non constructive ARRL bashing, there has already
been plenty you can rest assured. We need to quickly mobilize and help look
for a solution. RM-11708 is not going to be withdrawn as the ARRL is
convinced the FCC is going to address wide band digital with or without ARRL
input. The EMCOMM crowd pushing for wider bandwidths is not going away
either and you can bet they are providing highly organized input. After all,
technology is changing, and with it, creative well reasoned solutions are
going to be required. This is time for us to step up to the plate and get
involved.

One point requiring further clarification involves the current automated
stations that have generated QRM for so many of us. These stations are
typically narrow band Winlink stations, operating under the frequency
exceptions granted by FCC 97.221. We would suggest that you consider
including these automated stations in your recommended band plan input.
We strongly recommend they be limited to a wide band area due to their
extremely high inherent potential for QRM to RTTY, CW and even the case of
40M DX SSB split operation as some of us experienced with FT5ZM.

Thanks for your consideration and we appreciate very much any specific and
constructive input you may have to the Band Planning Subcommittee.
Please address your comments to them via email at HF-Digital-Bandplanning at
arrl.org . As Chairmen, Rick Roderick should be copied. His published
QRZ.com email address is K5UR at aol.com .

As a sample, below is one letter of input for your consideration. We are not
asking that you agree with it, rather the letter is provided merely as an
example for your consideration.

Best 73,
Terry Gerdes, AB5K

Dan White, W5DNT
Input March 3rd, 2014

Ladies & Gentlemen,

As an avid DXer, while I am very concerned with the outcome of the petition
process, I am pleased that ARRL has asked for comments with regard to Band
Planning. Not only am I an avid DXer, but I am also an EMCOMM person,
holding the job of ARES Emergency Coordinator of two counties in Texas, and
a County RACES Radio Officer in one of those counties. I am proficient in
RMS Express and have it on my PCs. Perhaps this will make the point that I
am not just another upset DXer! As requested, my "cogent and thoughtful"
input is respectfully provided herein. It is really very simple and can be
boiled down to one sentence.
Keep the wide band digital out of current customary CW and RTTY bands.

Translating that simple sentence into possible sub-bands, I would suggest as
a starting point: 1.880-1.900 MHz, 3.590-3.600 MHz,
7.100-7.125 MHz, 14.115-14.125 MHz, 21.115-21.125 MHz and 28.125-28.150 MHz.
NO WIDE BAND USE on WARC Bands (30M, 17M or 12M) as those bands are already
too crowded! That would be a good starting point and would provide plenty of
diverse spectrum without exposing CW and RTTY sub-bands to wide band digital
QRM. Hopefully many others from the DX and Contest Community will provide
input and the ranges can be tweaked as needed. Also, hopefully ARRL will
seriously consider the desires of existing DX and Contest enthusiasts, and
not just primarily the EMCOMM folks and software/hardware manufacturers
frustrated with the current nuances of "broad band internet" style email
over HF spectrum.

Just so you guys know, the other day on 40M with FT5ZM, one of these
automated RMS Express stations was on the transmit frequency of FT5ZM in the
foreign phone band, while FT5ZM was working split SSB. Did the users check
to see if the frequency was busy with SSB traffic, NO! They went right ahead
with their email traffic and essentially jammed the DX station for well over
an hour. Possibly being "no-coders", they may not have realized RMS Express
was signing each transmission with their callsign. If serious band planning
is not done in earnest, this can easily become a routine problem for the
RTTY and CW bands too.

With regard to Amsterdam Island and the digital jamming that occurred, that
jamming cost me a 40M SSB QSO, along with many others. That DXpedition had
an operational cost of $20 per minute. As a major financial contributor to
FT5ZM, I am disappointed to see jamming of any sort, including the RMS
Express situation cited above. Perhaps we should really consider the
appropriateness of email systems on HF, particularly broadbanded modes.

Am I concerned about implementation problems if the petition is approved?
Most definitely, yes I am. ARRL now has a chance to avert a spectrum
disaster through good old fashioned common sense. Simply keep the wide band
digital out of current customary CW and RTTY frequencies, through proper
band planning. It is just that simple!

Respectfully submitted with Best 73!

Dan White, W5DNT
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