[Forwarded with permission]
On 2014-04-23 10:51 AM, Sumner, Dave, K1ZZ wrote:
Dick, I don't consider "that will be the end of amateur radio" to be a
technical argument. How many times have we heard that over the years?
While I'm glad to see that Joe at least acknowledges that permitting Pactor 4
won't cause much of a change, I don't understand the distinction he is trying
to draw between Pactor 4 and other data modes with similar bandwidths and
symbol rates. As he says, none of them are currently in use in Amateur Radio,
even in other countries where there are no symbol rate limits. Why would their
future use, assuming there was any, be more detrimental to other users of the
RTTY/data subbands than would data modes with wider bandwidths and symbol rates
of 300 bauds or less?
The only reason the FCC chose 300 and 1200 bauds as the HF symbol rate limits
when ASCII was first authorized was to accommodate the standards used in Bell
103 and 202 modems. There is no reason to perpetuate them today. In terms of
protecting other users, limiting bandwidth makes much more sense.
It's not a criticism of anyone to say that they may not understand the present Part 97
rules governing HF data emissions unless they won't accept explanations. The rules were
developed over a 60-year period and are rather arcane. Many people don't seem to realize
that data modes with bandwidths that exceed 500 Hz have been in legal use for more than a
decade. In 2008 the FCC denied RM-11392, a petition by N5RFX to limit necessary bandwidth
to 1.5 kHz and 2.4 kHz, respectively, as a substitute for the 300 and 1200 baud limits. A
1.5 kHz limit would have prohibited Pactor-III among others but the FCC said: "...we
do not believe that changing the rules to prohibit a communications technology currently
in use is in the public interest."
I respectfully disagree with the characterization of "railroading." The symbol
rate issue and the rationale for 2.8 kHz bandwidth was explained in the September 2013
QST editorial, which generated very little comment at the time. The ARRL Executive
Committee did not authorize the filing of the petition until more than a month later. The
proposed rule changes were deliberately limited to what was required to accomplish a
narrow objective of permitting more efficient use of the bandwidth that was already being
used for data communications, while at the same capping the bandwidth so that future
developments would not be based on wider bandwidths.
73,
Dave Sumner, K1ZZ
-----Original Message-----
From: Dick Flanagan [mailto:dick@k7vc.com]
Sent: Tuesday, April 22, 2014 7:17 PM
To: Sumner, Dave, K1ZZ
Subject: Re: [RTTY] Fwd: RE: RM-11708 Outside US
Joe isn't always the most tactful guy, but his arguments and those of
other technically experienced folks on this reflector seem to be danced
around or even ignored by those who publicly argue for the League's position.
I would love to see someone with the appropriate technical credentials
from the League rebut the naysayers with sound technical arguments. I
keep reading that if I don't agree with the League's position I simply
don't understand the issues. If that's the case (condescension aside),
then there are a lot of highly experienced and respected scientists and
engineers who also don't understand it.
Dave, the League may be promoting the correct path, I don't know, but I
do know that the manner in which the League is promoting this issue
leaves a very bad taste in my mouth. Railroading a good idea is still
railroading. I really wish the League would publicly debate the issues
with some of the world-class minds who don't agree with the potential
unintended consequences of RM-11708. I believe the RTTY reflector would
be an excellent venue for that discussion.
--
Dick Flanagan K7VC - Life Member for over 40 Years
dick@k7vc.com
On 2014-04-22 3:15 PM, Joe Subich, W4TV wrote:
Of course K1ZZ spins the story again to promote the Board's misguided
policies ...
The ARRL petition simply seeks to replace the obsolete symbol rate
limit ... with a bandwidth limit that includes the data emissions
that are already in common use.
The proposed bandwidth limit includes *many* data emissions that are
not in "common use" and are not even permitted - specifically PACTOR 4,
STANAG, MS-110, ALE, etc. While PACTOR 4 may never be a significant
interference problem (if RMS system operators follow the rules), the
other 2.8 KHz modes with their high symbol rates and high spectral
power density (high average power) will be an absolute disaster in
the narrow bandwidth portions of the amateur bands. These modes are
totally new to amateur radio, have no current users and represent no
current spectrum loading in the CW/RTTY portions of the HF bands.
It is these potential interference sources that K1ZZ and the PACTOR
clique seek to ignore. However, interference and competition for
bandwidth from these modes are the very essence of what I have been
warning are the "unintended consequences" of ARRL's ill-conceived
proposal.
Again, it is time for K1ZZ to stop minimizing the effects of RM-11708.
If ARRL want to eliminate the symbol rate, then eliminate the current
prohibition against RTTY and data modes in the wideband portions of
the HF bands, *put the wideband data modes with other wideband modes*,
ask for a reasonable 300 or 500 Hz limit for all narrowband modes
(just like the Commission imposed on narrowband *image*), ask for a
complete prohibition on all encryption and proprietary protocols, and
require that all data encoding be completely transparent. Regulation
by bandwidth is nothing new - the FCC has practiced that concept since
AM first appeared on the scene more than 80 years ago.
It is time for K1ZZ to admit that the goal of the Board of Directors -
or at least a majority of the directors - appears to be elimination
of the separation between wideband and narrow band modes as a prelude
to Canadian style "anything goes" regulatory system. They apparently
don't care if it destroys CW and RTTY, and K1ZZ will generate any
propaganda necessary in order to promote the boards' agenda, right,
wrong or indifferent.
Frankly it's a damn shame that none of the board have the guts to stand
up and say "this will kill amateur radio as we know it" or do anything
to derail this runaway freight train. Without changes to RM-11708,
within five years wideband data will so choke the traditional CW and
RTTY portions of the band that the pressure to allow it anywhere (after
all "it's the same bandwidth as an SSB signal") will be unstoppable.
Before anyone can blink an eye, with wideband digital everywhere the
amateur HF spectrum will be overrun with de facto encrypted (using non-
standard encoding) STANAG, MS-110, ALE and derivative modes with no way
for the ARRL OOs or the FCC to know who is transmitting and what is
being transmitted.
That, my friends, will be the end of amateur radio - all because a
couple of PACTOR 4 zealots do not care about the unintended
consequences of their short sightedness and the rest of the board
isn't willing to stand up and say "wait a minute!" The technology
is available for all of the unintended consequences *today* - unlike
the nebulous multi-tone, 300 baud wideband SDR based signal K1ZZ
likes to point to as a reason for 2.8 KHz instead of 300 baud limit.
However, it is the very 30 baud limit ARRL seeks to eliminate that
prevents the *immediate deployment* of these other technologies and
modes.
73,
... Joe, W4TV
On 4/22/2014 5:02 PM, Dick Flanagan wrote:
[Forwarded with permission]
On 2014-04-21 10:43 AM, Sumner, Dave, K1ZZ wrote:
Gerry,
I see that your comments are among those received by the ARRL HF Band
Planning Committee, so as an ARRL member you have not been
disenfranchised. As far as FCC comments are concerned, the comment
deadline was last December 23 and the deadline for reply comments was
15 days later. There has been no extension of either deadline.
Regarding the substance of your comments, correct me if I am wrong but
my impression is that the amateur regulations in the UK only specify
frequency bands and power levels, and do not limit either the
bandwidth or symbol rate of data emissions. The current symbol rate
limit in the FCC regulations is very unusual and indeed may be unique.
Other countries take a different approach. For example, in our
neighboring country of Canada there is a bandwidth limit of 6 kHz in
most of the MF/HF bands with no mode restrictions.
The ARRL petition simply seeks to replace the obsolete symbol rate
limit -- which because of advances in technology no longer has the
effect of limiting bandwidth -- with a bandwidth limit that includes
the data emissions that are already in common use. We believe it is
important to get such a limit into effect before the inevitable
development of broader data emissions using SDR technology.
73,
Dave Sumner, K1ZZ
-----Original Message-----
From: Dick Flanagan [mailto:dick@k7vc.com]
Sent: Friday, April 18, 2014 9:49 AM
To: Ron Kolarik
Cc: Sumner, Dave, K1ZZ
Subject: Re: RM-11708 Outside US
I suggest you and many others query Dave Sumner K1ZZ via k1zz@arrl.org
as he is deeply involved in the International Amateur Radio Union
(IARU) preparations for the next World Amateur Radio Conference
(WARC).
If Dave can't find a receptive ear with his contacts, I don't know who
can.
--
Dick Flanagan K7VC
dick@k7vc.com
On 2014-04-17 9:39 AM, Ron Kolarik wrote:
Hi Gerry,
On the first page where you enter your address there should be a check
box for domestic or international addresses.
73,
Ron
K0IDT
----- Original Message ----- From: "Gerry McGowan" <m0vaa@yahoo.com>
To: <rtty@contesting.com>
Sent: Thursday, April 17, 2014 7:03 AM
Subject: [RTTY] RM-11708 Outside US
Hi,
I've been following progress on this from the UK. The implications
extend Worldwide.
I'm a member of ARRL and have submitted my opinion of the filing to
ARRL via the web.
I feel somewhat disenfranchised as I can find no-one to represent non
US members within the ARRL structure who I can approach to represent
my views.
I've tried filing comments with FCC via their website but cannot get
past the first page as it restricts submissions to US citizens by the
use of drop down menu for 'State' and needs a zip code.
Anyone any idea how I can proceed ?
Thanks
Gerry M0VAA
RTTY DXCC #2608, RTTY WAS, and avid low power RTTY contester.!
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