> Like Jim, I would appreciate even a bullet list of topics/issues
> which are deemed important to include in those comments.
Pick your poison and add supporting comments to the points you choose
to use ... The most important point to add is that ARRL's position
does not represent the overwhelming majority of CW, RTTY and data users
who prefer RTTY and data bandwidths continue to conform to "traditional
radioteleprinter bandwidths" as they have for the past 30-plus years.
Instead, ARRL's petition it represents the narrow commercial interest
of Special Communications Systems GmbH in an attempt to legalize their
Pactor III and Pactor 4 products and the quasi-commercial use in the
amateur bands.
1) The ARRL misrepresents the rules on page 2 of their petition by
stating that the maximum shift applies to FSK only. The maximum
shift also applies to the maximum spread of multi-tone modulation
even though such modulations were not in use in the Amateur Service
in 1980 when the current rules were adopted.
2) The ARRL misrepresents technical accomplishments in the last 30
years by saying the 300 baud limit "precludes or substantially
inhibits any meaningful contributions to the sate of the art in
this area." Amateurs have innovated PSK31, JT65, JT9, WSPR, QRSS
and *many other* narrow bandwidth digital modes since the current
rules were adopted.
3) The ARRL misrepresents the current conditions at #4 on page 3 by
claiming the symbol rate restrictions "no longer reflect the state
of the art of digital telecommunications technology". Protocols
like JT65A, JT9 and WSPR certainly represent the very frontiers
of weak signal digital technology.
4) ARRL is lying when they claim on page 3, it is in the interests of
all Amateurs to remove these restrictions. The vast majority of
all amateur "RTTY, data" communication is conducted using protocols
that occupy 300 Hz or less. Allowing 2.8 KHz for a few unattended
and "auto-responding" stations will only intensify interference
from their quasi-commercial operation to RTTY, data and CW users
of the spectrum. The grossly increased bandwidth used by that
fringe group will invariably displace other activity and increase
spectrum demands elsewhere in the spectrum allocated to CW, RTTY
and data users.
5) ARRL is incorrect when it claims, on page 8, current technology
has rendered the current rules ineffective. The maximum shift
regulations *still* places a maximum upper limit on bandwidth -
whether ARRL and SCS who they appear to represent instead of the
rank and file amateur admit that the shift limit applies to multi-
tone modulations or not.
6) ARRL is dead wrong in its claim at #10 on page 8 that efficiency
will improve with increased symbol rates. Military studies of
HF Modem technology shows that required signal to noise ratio
climbs rapidly with increased symbol rates - to the point that
the highest data rates are only effective on frequencies with
little or no interference and with the use of high power. Neither
of these prerequisites are likely to be met in the amateur service
where frequencies are shared and the rules require the use of
*minimum* power levels.
7) ARRL is wrong again in #10 in the blanket assertion that the
symbol rate limitation precludes the use of newer more efficient
protocols - PSK31, PSK63, JT65, JT9, WSPR, etc. have all been
introduced and found wide acceptance since the current rules were
instituted. Further, protocols like STANAG and M110 *may*, in
fact, be legal as digital voice modes in the HF spectrum allocated
for "voice, image" transmission rather than "data" modes. There
are certainly other *digital* voice protocols being used in that
spectrum every day.
8) ARRL is incorrect at #11 on page 9 when it states that no maximum
bandwidth limit currently exists. The combination of a maximum
shift and maximum symbol rate create a de facto 1500 Hz limit even
if it is not specified explicitly in the rules.
9) In their appendix - at page 15 - in their proposed revision of
97.307(f)(3) - ARRL add "A RTTY, data or multiplexed emission
using an unspecified digital code under the limitations listed in
this part may also be transmitted." This change is completely
unsupported by the petition and would eliminate the need to
document "unspecified digital codes" effectively providing *data*
*encryption* and gutting any possibility of enforcement by either
the Commission or self-enforcement by the amateur community.
10) ARRL fails to address the issue that the vast majority of all
"RTTY, data" activity uses protocols with bandwidths less than
500 Hz or that the vast majority of users in the MF/HF spectrum
currently available for "RTTY, data" expect that signal bandwidth
will be less than 500 Hz - "traditional radioteleprinter
bandwidths". That expectation by those who actively use the
spectrum has not changed in 30 years since the current rules
were adopted.
73,
... Joe, W4TV
On 11/23/2013 5:09 PM, John Grimm wrote:
I am in the process of drafting my comments. Like Jim, I would appreciate even
a bullet list of topics/issues which are deemed important to include in those
comments. This would be very helpful to me as I've never filed comments before.
John / K0YQ
Message: 3
Date: Sat, 23 Nov 2013 13:36:05 -0600
From: "Jim N7US" <jim@n7us.net>
To: <rtty@contesting.com>
Subject: Re: [RTTY] ARRL attack on current RTTY users
Message-ID: <025601cee883$4168a560$c439f020$@net>
Content-Type: text/plain; charset="us-ascii"
Would it be productive if a committee of "The Knowledgeable" got together to
draft an effective, succinct email to the ARRL directors that includes the
key problems with the proposal? Each of us could either copy and paste it
in an email to our respective directors or modify/personalize it before
doing so. It should include the impact on all modes and activities, not
only RTTY.
I understand it's already gone to the FCC, so responding to that is a
separate undertaking, and Don just created a web page on how to do that. I
would think that the key points in the ARRL director email would probably be
the same ones to include in an FCC filing.
73, Jim N7US
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