Here are some general thoughts and concerns that can be used in preparing
your own response to the ARRL band plan committee. Please copy your
directors with your inputs.
Unattended Digital Stations need a defined sub band - Unattended digital
stations have been deployed with no band plan across the digital sub band.
Many of these stations provide "Internet as a service" to yachtsmen and
EMCOMM however the unattended robots are causing interference to traditional
waveforms of SSB, CW and RTTY.
It's a fact that an unattended packet robot QRM'ed the FT5ZM 40 meter SSB
operation for over one hour. The QRM from unattended digital stations is
not contained to digital operations; it affects SSB and CW as well. This is
an example that illustrates concretely the concerns that people have. We
have every expectation for such things to continue in the future. The busy
frequency detectors deployed by unattended digital stations are not
effective.
Additionally, waveforms deployed in unattended digital stations have an
advantage over traditional narrow band modes. The ARRL acknowledges this
on their website by stating "provides resistance to strong narrowband
interference (e.g., CW)" (reference: <http://www.arrl.org/pactor-ii>
http://www.arrl.org/pactor-ii).
The issue with unattended digital stations is a global one and recognized by
the IARU Region 1 publications. Statements like "We are concerned about
that too many automatic (unattended) amateur radio services are active in
the 30 m band" and "bandplan is not obeyed by a number of automated digital
station users" demonstrate misuse of our spectrum and tell us the ARRL has
to be involved in not only band plan development and enforcement but also in
supporting the issues at IARU levels. (reference:
http://uska.ch/fileadmin/download/iaru/interim_meetings/vienna2013/VIE13-C4-
04_NRRL.pdf)
Unattended digital stations need to be moved out of mainstream traditional
waveform sub bands and into their own sub band.
Beware of Creep by those providing "Internet as a Service" - Several
concerns were presented to the committee deal with the area that at HF
frequencies we do not have enough bandwidth to keep up with the Internet
demands from sailors and EMCOMMM. Requests for more frequency allocations
and bandwidth drove RM-11708 and more requests for wider bandwidth and wider
sub band allocations are expected in the future. We advise the ARRL to be
aware of future creep.
On the "Internet as a Service" side there are also red flags indicating the
direction we are headed is for is "private email" which raises further
concerns of "transparency" detailed further below.
New Wide Bandwidth Waveforms need their own sub band - When looking ahead at
new wide bandwidth waveforms allowed by RM-11708, many of waveforms are
designed to ride roughshod over narrow band waveforms. For example, STANAG
specs claim as much as a 40dB over narrow-band-interference advantage (ref:
<http://apps.fcc.gov/ecfs/document/view?id=7521065139>
http://apps.fcc.gov/ecfs/document/view?id=7521065139 ) New wide bandwidth
waveforms be contained in their own sub band outside the main stream sub
bands used for SSB, CW and narrow band digital operations.
Expansion of digital segment on 80 meters - A few years ago, the digital
community lost several KHz of sub band above 3.6 MHz. The committee
recommends this bandwidth be returned for digital use and set aside for wide
band experimentation and unattended packet operations. This sub band will
be of great use by unattended digital operations engaged in supporting local
emergency communication.
Transparency - Transparency is basic and fundamental to Amateur Radio. We
must have the capability to monitor all waveforms used on amateur
frequencies. This is necessary for security, for tracking interference,
for the ARRL Official Observer Program and even FCC monitoring. Amateur
Radio is about experimentation but transparency across all waveforms is key.
All waveforms transmitted over the air need to be open allowing us to
examine them technically, learn how they work and even provide modifications
expanding them to solve other communications problems. In general, closed
waveforms should be discouraged. Closed waveforms if allowed, at a
minimum, should provide free "read only" soundcard based software program
that allows others the capability of monitoring usage of the waveform.
The ARRL already maintains a list of major digital waveforms on its web
site. In order to address the transparency issue, we suggest that the ARRL
web site be expanded to include the download of free readers that resolve
transparency concerns.
Proposed Digital Band Plan - The ARRL in their RM11708 filing presents a
clear case that changes to the existing band plan are not needed and in fact
the existing amateur band plan will be more efficient under RM11708. The
responses listed above assume the statements made by the ARRL are true and I
therefore conclude that the only changes needed to the existing band plan
are changes to place unattended digital stations and new wide bandwidth
waveforms in their own sub band.
Other concerns about dealing with transparency, expansion of the 80 meter
digital band, bandwidth creep, and a basic question of providing "Internet
as a Service" while outside immediate band planning discussions are key
considerations to make sure that narrow and wide bandwidth waveforms play
successfully on the amateur bands. It is my sincere hope that the ARRL and
its BOD consider these in planning and develop a clear vision to guide the
amateur community as the new wide and narrow waveforms are allowed.
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