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Re: [RTTY] Hints and tips on how to file comments on RM-11708

To: "rtty@contesting.com" <rtty@contesting.com>
Subject: Re: [RTTY] Hints and tips on how to file comments on RM-11708
From: Al Kozakiewicz <akozak@hourglass.com>
Date: Mon, 25 Nov 2013 18:05:33 -0500
List-post: <rtty@contesting.com">mailto:rtty@contesting.com>
Joe,

To distill what you've said several times down to a single sentence, innovation 
in amateur radio digital modes should be limited to doing the same with less, 
not doing more with the same.  While I agree 110% with your desired outcome, I 
would caution that this particular line of reasoning will sound reactionary and 
self-serving.

Instead of addressing the unintended consequences with 3rd order effects (e.g. 
unattended Winlink or whatever), stick to what's actually in the requested rule 
change: dropping the symbol rate and applying a bandwidth limit instead.  There 
is a glaring logical hole in the filing in the implied assertion that the 
proposed bandwidth increase is a requirement for dropping the symbol rate 
limit.  It is not - it's a non-sequitur.

My comment will consist of these three points:
1. Increasing the allowable bandwidth in the CW/Digital portion of the amateur 
bands would be seriously detrimental to the current users of digital modes.
2. As a result, the ARRL request is unworkable as written.  Wide bandwidth 
digital modes, if permitted, should share spectrum with other wide bandwidth 
modes.
3. Allowing any digital mode implemented with proprietary, non open sourced 
protocols is effectively the same as encryption.  It prevents identification of 
interfering or unlawfully operating stations by anyone that has not purchased a 
license.

Al
AB2ZY

________________________________________
From: RTTY [rtty-bounces@contesting.com] On Behalf Of Joe Subich, W4TV 
[lists@subich.com]
Sent: Monday, November 25, 2013 4:57 PM
To: rtty@contesting.com
Subject: Re: [RTTY] Hints and tips on how to file comments on RM-11708

 > That's part of the problem. Without these limitations we can realize
 > modes nobody thought of till today.

We don't *need* those wider bandwidth modes for either radioteletype
(user to user) communications or amateur "data" (bulk transfer) uses.
The *only value* of wider bandwidth signals is to carry more data -
either digital voice or *commercial* data quantities.  In the former
case, digital voice belongs in the "voice, image" allocations and in
the latter case, commercial data transfers *do not belong* in the
amateur bands at all.

> Nonsense. Ham density in many countries is much higher than in the
> US. Even more when taken into account that most technicians are
> active on VHF/UHF only.

This is not an issue of "national density" - it is number of hams in
total or number of users per KHz.  There are more amateurs in the US
than there are in Canada, Europe, the Middle East, Africa and South
America *combined*.  If even the same percentage of licensees were to
use wide band data modes in the US as in the rest of the world, the
horrendous level of interference from wideband data signals would
more than double over night.

 > This all seems to be a private campaign of a few against
 > Winlink/Pactor rather than supporting the future of ham radio.

No, this is all about the future of amateur radio.  Do you want an
amateur service that is about the amateurs and provides an opportunity
for amateur to amateur communication or do you want an amateur service
in which the amateur bands are used as conduits for low cost commercial
data transfer - essentially another mobile service - dominated by one
or two corporations?

 > This proposal was well defined by experts from ARRL with a more global
 > future oriented view helping experimenters to develop new modes.

This proposal was developed by *Winlink insiders* who hijacked the ARRL
process.  These self-serving individuals railroaded a recommendation
through an ad hoc committee and the Board of Directors without giving
the general membership an opportunity to comment or provide opposing
viewpoints.

 > That's ham radio!

No, that's a corporate coup d'tat.

 > Support our league, guys.

Support the Amateur Service - not corporate confiscation.

73,

    ... Joe, W4TV


On 11/25/2013 4:18 PM, Stan wrote:
>
>
>> have all been developed under  the current bandwidth "limitations."
>
> That's part of the problem. Without these limitations we can realize
> modes nobody thought of till today.
>
>>   Co-existance has not been "proven in the rest of the world" as use
>> of wider modes has been limited by the number of licensees in the
>> rest of the world
>
> Nonsense. Ham density in many countries is much higher than in the
> US. Even more when taken into account that most technicians are
> active on VHF/UHF only.
>
>> Winlink and PACTOR III/IV are a blight on amateur radio and should
>
> This all seems to be a private campaign of a few against Winlink/Pactor rather
> than supporting the future of ham radio.
>
> This proposal was well defined by experts from ARRL with a more global
> future oriented view helping experimenters to develop new modes.
> That's ham radio!
> Support our league, guys.
>
> Stan
> _________________________________________________________
> On Nov 25, 2013, Joe Subich, W4TV wrote:
>> It will just open the door to experiment and develop new modes -
>> this  is ham radio.
>
>   The door is not closed to developing new modes.  The most popular of
>   new modes, PSK31, JT65, JT9, and WSPR have all been developed under
>   the current bandwidth "limitations."
>
>> And the co-existance has been proven in the rest of the ham world
>   > where this is allowed since many years.
>
>   Co-existance has not been "proven in the rest of the world" as use
>   of wider modes has been limited by the number of licensees in the
>   rest of the world and the general lack of significant usage for these
>   bandwidth hogging commercial traffic systems anywhere except the
>   automatic control sub-bands.
>
>   Winlink and PACTOR III/IV are a blight on amateur radio and should
>   be made illegal in the same way as bandwidth wasting spark was made
>   illegal in the 1920s.
>
>   73,
>
>      ... Joe, W4TV
>
>
>   On 11/25/2013 4:11 AM, Stan wrote:
>> Just for the records,
>>
>> If you won't follow the arguments of those 'experts' - you are also welcome 
>> to
>> file a comment that you are perfectly fine with the proposal from our league.
>>
>> There're always naysayers but SSB was not the end of ham radio - the Internet
>> was not the end of ham radio - 2.8kHz bandwidth will not be the end of RTTY.
>>
>> It will just open the door to experiment and develop new modes - this is ham
>> radio.
>>
>> And the co-existance has been proven in the rest of the ham world where this
>> is allowed since many years.
>>
>> Stan
>>
>>
>>
>> On Nov 24, 2013, at 5:02 PM, Joe Subich, W4TV wrote:
>>
>>    > PACTOR III is *NOT* currently permitted under the rules. Its use has
>>    > been *overlooked* by enforcement organizations as it *absolutely* can
>>    > not be justified under the *dual standard* in 97.307(f)(3) which has
>>    > both 300 baud and 1000 Hz shift limits.
>>
>>    That is not true Joe... please don't make that mistake in your FCC filing.
>>
>>    At all SL levels, Pactor III's symbol rate is fixed at 100 baud (yes, not 
>> even close to 300 baud). (Don't confuse Symbol Rate (baud rate) with data 
>> rate (bit rate)).
>>
>>    Pactor III is not 2 tone FSK, so the FSK shift rule does not even apply 
>> (makes no technical sense since there is no frequency shift happening).
>>
>>    Pactor 3 SL1 (the slowest rate) consists of two synchronous PSK signals 
>> (not FSK), that are separated by 840 Hz. 840 Hz is the maximum tone 
>> separation for Pactor 3 (if you want to apply the term "shift" to the 
>> signal). As more tones are added (SL2, SL3, etc), the tone separations 
>> become narrow, and at the narrowest, there are 18 tones, separated by 120 Hz 
>> from one another.
>>
>>    Pactor 3 SL1, 2 and 3 uses binary PSK, and Pactor 3 SL4, 5, 6 uses 
>> Quadrature PSK.
>>
>>    It is much clearer if you go take a look with a panadapter or a 
>> waterfall, or if you can, in I/Q phase space.
>>
>>    Pactor 3 SL1 looks like two broad indistinct tones that are 840 Hz from 
>> one another, with a distinctive gap in between them. It is quite 
>> unmistakable once you see it on the waterfall.
>>
>>    73
>>    Chen, W7AY
>>
>
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