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Re: [RTTY] Member comment procedure

To: rtty@contesting.com
Subject: Re: [RTTY] Member comment procedure
From: "Joe Subich, W4TV" <lists@subich.com>
Date: Sun, 15 Mar 2015 15:44:32 -0400
List-post: <rtty@contesting.com">mailto:rtty@contesting.com>

On 2015-03-15 1:53 PM, RLVZ--- via RTTY wrote:
I'd be grateful if someone would share a link to get me to the ARRL comment
  site for the Proposed HF Band Plan Change.... as I'm ready to  comment.

Go to www.arrl.org and put bandplan proposal in the search box.  That
will point you to the web page describing the bandplan (their spin):
<http://www.arrl.org/news/arrl-seeks-member-input-on-draft-hf-band-plan-proposals>. In that article is a link for comments: http://www.arrl.org/bandplan

73,

  ... Joe, W4TV



Thanks,
K9OM

----------------------------------------------------------------------

  On Mar 14, 2015, at 12:00 PM, rtty-request@contesting.com wrote:

The period for comments on ARRL's grossly misguided HF Band  Plan
Change has roughly one month left.  The comment period ends  April 19.

Today, I submitted my comments very much along the  lines of those
I posted here two weeks ago:

ARRL's  proposal misses the mark on *every count*.

It needs to be  completely rewritten to include:

1) expand 80 meter data to  3675 not 3650 ...
2) move the "automatically controlled data" segments  to 3560-3570,
    7110-7120, 14130-14140, 21180-21190 and  28280-28290 *ONLY* - with
    *no automatic control on 60, 30,  17 or 12 meters* due to the limited
    available  spectrum.
3) require *all* automatically controlled data stations -  including
    "auto-responding stations" - operate in the  automatic control
    (Section 97.211) sub-bands.
4)  require all automatically controlled data stations - including  "auto
    responding stations" - implement fully functioning  "channel busy"
    detectors which respond to 125% of the  [maximum] bandwidth to be
    used including any "enhanced  speed" modes.  The channel must be idle
    for at least  90 seconds before initiating *any* transmission or 90
     seconds prior to receiving a call *when responding to interrogation*.
5)  require all automatically controlled data stations - including  "auto-
    responding stations" and *US licensed amateurs*  operating systems
    off shore - list their frequencies,  operating times, and control
    operator telephone number in a  publicly accessible database
7) require all manually controlled digital  stations include either
    visual means (e.g. spectrum display  or "waterfall") of determining
    whether a frequency is busy  before transmitting *or* a channel busy
    detector with the  same parameters as automatically controlled data
     stations.
6) allow Novice/Technician licensees to use *only* RTTY (45.45  baud,
    170 Hz shift) and PSK31 within their current  allocations and any
    expanded 80 meter data  allocation.

I don't believe there should be any "grace period"  for automatically
controlled digital stations (including  "auto-responding stations") to
implement the *effective* channel busy  detection and establish a public
database of schedule/contact  information.  In addition, I do not
believe that automatically  controlled stations should *ever* operate
outside an extremely limited  spectrum (e.g., 97.211 allocations) as
automatic channel busy detection  can not be 100% effective and
automatic operation is incompatible with  the first come first served
(no "assigned channels") nature of amateur  radio.

As as early adopter of ACDS, participant in the Special  Temporary
Authorization issued to TAPR in the late 1970s for the study  of
automatically controlled HF forwarding systems, and member of  ARRL's
*first* ad hoc Digital committee, I believe ACDS are a blight on  amateur
radio and serve *no legitimate amateur purpose*.  The  claimed EMCOMM
role can be provided by *manually controlled and  monitored* stations
established in [limited] areas impacted by a  communications emergency
during the emergency and for limited drills  not to exceed four
[consecutive] hours per month.

  73,

    ... Joe,  W4TV

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