Some major flaws that I see in his argument are:
1: Digital voice is classified as "Phone" hence not permitted in the RTTY/data
segment to begin with; that won't change even if the FCC bandwidth proposal is
enacted as written.
2: Data compression is not encryption, and Winlink doesn't even use the Pactor
data compression anyway; they use the same one that is used in the F6FBB Packet
BBS. Also, the FEC ID capabilities for all versions of Pactor are identical, so
any software that can decode Pactor 1 can be used to ID an interfering station.
3: Despite what he's claiming, there is absolutely no interest in
implementation of such things, even if some tiny fraction of users might want
to see it happen.
4: As I said before, claims of a massive increase in the number of automatic
stations or wide bandwidth digital voice stations swamping the RTTY/Data bands
are nothing more than FUD.
Also, a 500 Hz bandwidth limit would do little to reduce interference when
Canada has a 6 kHz bandwidth limit.
Matthew Pitts
N8OHU
On August 13, 2016 10:15:10 PM EDT, Jim McDonald <jim@n7us.net> wrote:
>I just received the note below from Ted, N9NB.
>
>
>
>As Ted says, if you don’t agree with him or don’t care about this, then
>please delete the message.
>
>
>
>Here’s a summary of his background:
>
>http://www.arrl.org/news/ted-rappaport-n9nb-named-recipient-of-ieee-education-award
>.
>
>
>
>73, Jim N7US
>
>
>
>
>
>From: Ted Rappaport N9NB [mailto:tsrwvcomm@aol.com]
>Sent: August 13, 2016 20:26
>To: Jim McDonald <jim@n7us.net>
>Subject: Re: If you care about CW and RTTY - time is of the essence
>
>
>
>Jim, I really appreciated your note, and hope you are able to reach
>many many people.
>
>
>
>This is quite real, and hope that you and others will write the ARRL
>CEO as well as all your elected ARRL directors when you file your FCC
>comments. Here is a note I sent out to the PVRC, giving 4 examples of
>what will happen if this NPRM is not modified. I fear that everyone who
>likes CW and RTTY has no clue how real of a threat this is.
>
>
>
>Thanks for your interest and your help to save CW and RTTY from massive
>digital data and digitized voice traffice. This is our last ditch
>effort. If the present day apathy by CW/RTTY ops continue, and if ARRL
>and FCC do not hear clearly from people who care, we will lose our HF
>protections forever.
>
>`````````````````````````````````````````````````````````````````
>
>
>
>Hi y’all:
>
>
>
>Life is short, and this great hobby has enough room for everyone!
>
>
>
>Pactor, DX, Winlink, Contestting, SSB, RTTY, etc...... We can all
>coexist, but the HF spectrum is very limited, and sadly the FCC is
>about to sign into law a really grave error that will completely
>disrupt CW/RTTY if you don’t read and file comments at the FCC about
>NPRM 11708 and WT 16239. We must write to both our ARRL officials at
>all levels, as well as file public comments at the FCC.
>
>
>
>The FCC is about to make this officially law, but is taking last ditch
>comments from now (up until October 5th or so) and then during a one
>month “Reply to Comments” phase. this is our LAST CHANCE to really get
>the base of CW/RTTY users to write in to ARRL and FCC officials to
>modify this law.... NPRM RM 11708 cannot be repelled at this point,
>only modified, unless a miracle occurs and ARRL recinds it – not likely
>unless tens of thousands of us write to ARRL officials while also
>filing comments.
>
>
>
>Here is what RM 11708 will enable, if it is passed into law as the FCC
>is proposing in its NPRM 11708 published on July 28, 2016. Note the FCC
>ignored ARRL’s request for a 2.8 kHz bandwidth to replace the 300 baud
>limit, and instead is proposing an **unlimited** bandwidth limit with
>no baud rate limit. Unfortunately, neither the ARRL or FCC have
>recognized the resulting interference that will occur to the narrowband
>CW and RTTY users, and have never once considered a 200 Hz bandwidth
>emission limit on the lower 50 kHz and 500 Hz emission bandwidth limit
>on the lower 100 kHz of every HF band (That is what is needed for
>protection, and we must write in by the tens of thousands!!! To ARRL
>and to FCC! See footnote 37in their July NPRM, very short shrift given
>to this argument!). Here is what will happen if CW/RTTY apathy
>continues:
>
>1. SSB and other voice operations will be freely allowed in all the
>CW/Data/RTTY segments of HF with unlimited bandwidth, as long as the
>signals are digitized into data first. This NPRM opens up digitized
>voice to the CW/RTTY lower end HF bands -- digitized voice using
>12.5khz c4fm stations will be allowed, since the FCC has not proposed
>a bandwidth limitation. And this is not a conspiracy theory, its real.
>
>2. If the rule passes without any bandwidth limit, or with the ARRL’s
>suggested 2.8 kHz bandwidth limit on the low end, Pactor 4 will be
>permitted and conversations will be encrypted as part of the protocol.
>And if there were to be a way to listen in, it’s going to require a the
>purchase of a Pactor 4 modem which is not cheap. Meaning you have no
>ability to identify the call sign of a station short of engaging in a
>Pactor 4 based conversation. No way for OO’s to find offending station
>since no CW id is needed.
>
>3. A lot of the Automatic Data stations (the auto repeaters that are
>already causing great QRM) are tied in with the watercraft and boating
>crowd. Which means the stations would ring the coastline using new data
>services in the CW/Data part of the band to log into Facebook, check
>weather, and make dinner reservations. So unless you are beaming
>north, you are going to be pointing toward one of those stations.
>
>
>
>4. At about 2.4 Khz per station for Pactor 4, and with MANY more
>stations active (the P4 speeds make email via HF a lot faster and less
>painful, which will drive more users after this NPRM is legalized), it
>won’t take much to swamp all the traditional RTTY segment. That pushes
>the RTTY guys down into the top of the CW segment. And not to even
>mention digitized voice signals that will be allowed there, too!
>
>
>
>No matter how you slice it, even with voluntary band plans, this means
>trouble for the RTTY operators right up front, and more congestion for
>the CW bands as a result. Of course, the SSB guys successfully
>defeated essentially the same proposal 10 years ago (ARRL TRIED TO PASS
>RM 11306 in 2005, but rescinded it in 2007 because the SSB operators
>made enough noise to get the ARRL to pull it from the FCC
>consideration—Check out RM 11306 and -- CW and RTTY apathy has failed
>to make enough noise, and now this is about to become law). It has
>gone too far, and CW/RTTY people have not been heard, and this is about
>to remove the enjoyment of our bands forever! Please get active. This
>is real. Please don’t take this lightly and do nothing, please get your
>CW/RTTY friends engaged. Read the NPRM! See Footnote 37. See what the
>FCC is about to sign into law. You only have 2 months to move the ARRL
>and the FCC to modify this rule.
>
>
>
>Lets give Pactor 4 and Winlink its due at 100 kHz and above from the
>low end of HF, but lets also preserve the lowest 50 kHz for CW and
>lowest 100 kHz for RTTY by urgently requesting bandwidth limits that
>preserve CW and RTTY.
>
>
>
>Tell your ARRL official and write in to the FCC about the need to have
>narrow bandwidth protection in the low end of HF if they remove the 300
>baud rate -- we need tens of thousands of thoughtful responses! I am
>copying Brennen Price, ARRL’s CTO and PVRC member, here. And I hope you
>and others will similarly write him and all ARRL officials while you
>submit your short, focused comment to the FCC on RM 11708 and WT 16239
>to seek interference protection on the low part of HF, as well.
>
>
>
>73 ted n9nb
>
>
>
>
>
>On 8/8/2016 12:14 AM, 'Jim McDonald' jim@n7us.net <mailto:jim@n7us.net>
> wrote:
>
>
>
>From the SMC reflector.
>
>73, Jim N7US
>
>-----Original Message-----
>From: SMC [mailto:smc-bounces@w9smc.com] On Behalf Of Mike Wetzel
>Sent: August 07, 2016 18:38
>To: smc@w9smc.com <mailto:smc@w9smc.com>
>Subject: [SMC] if you care about CW and RTTY - time is of the essence
>
>From Dr. Ted Rappaport N9NB
>
>Dear Colleagues:
>
>If you believe, as I do, that the proposal to unregulate the bandwidth
>of
>data signals (like Pactor 4) in the lower HF portion of the spectrum is
>dangerous for the hobby, both in the US and abroad, then please read on
>as
>we need your help. If you do not agree with me, or don't care about
>this,
>then feel free to delete and stop reading.
>
>I ask that you PLEASE take action by filling public comments with the
>FCC
>regarding their recent RM 11708 proposed rulemaking in WT Docket No.
>16-239
>and RM-11708, and please forward this to every CW and RTTY enthusiast
>you
>know in ham radio, on every reflector, in every CW and RTTY club, both
>in
>the US and elsewhere, and urge them to also file comments with the FCC.
>We
>have less than 3 weeks to voice our opinion! It was not heard in
>2014-2015.
>
>TIME IS OF THE ESSENCE! There are less than 3 weeks during which the
>FCC
>will accept comments.
>
>I am fearful and quite certain that RM 11708, as published in WT Docket
>No.
>16-239 , which the FCC is now seeking public comment on as a prelude to
>enact its ruling, will terribly erode CW and RTTY on the HF bands in
>its
>current form. The ruling will allow PACTOR 4 and multi-tone modems on
>any
>frequency within the CW/RTTY frequencies on HF. This is worse than
>allowing
>SSB to operate throughout the CW/data sub bands, something the FCC has
>never
>allowed. The FCC is proposing an unlimited bandwidth for data signals
>in the
>lower HF bands (the ARRL asked for 2.8 kHz-- the bandwidth of SSB---
>which
>was still bad - and the FCC proposal is even worse). I would urge all
>of you
>write in to object to RM 11708 and to ask that the FCC place a 500 Hz
>bandwidth limit all data transmission bandwidths such as Pactor, multi
>tone
>data modems, and other experimental data modes on all HF bands within
>the
>lowest 75 or 100 kHz region of each HF band. Japan has something
>similar. If
>we don't generate large support from hams to scale back the FCC
>proposal,
>and put a bandwidth cap in some portion of the lower HF bands, these
>monster
>QRMers of unlimited bandwidth will be allowed to operate anywhere in
>the
>CW/RTTY lower HF bands, and they will lawfully fire up on your CW or
>RTTY QS
>when you are least expecting it.
>
>See below how the proponents of RM 11708, including my friend Tom
>Whiteside,
>are launching an aggressive letter-writing campaign for "pro" comments
>to be
>filed at the FCC to allow Pactor 4 and other wideband multi-tone modems
>to
>operate anywhere in the CW/RTTY spectrum, without a segregation of the
>band.
>
>The public filing period ends in a few weeks, so we must write now to
>offer
>opposition to the Commission. The need for WinLink/Pactor data
>emergency
>communication on HF is being used as one of the arguments for expanding
>the
>data bandwidth. See the other arguments below. I would urge CW and RTTY
>enthusiasts to review the arguments for and against RM 11708, see the
>public
>comments filed from March 2014 to today, and please be moved to quickly
>to
>write about your opposition to the newly proposed regulation just
>released
>by the FCC (It can be viewed here):
>http://transition.fcc.gov/Daily_Releases/Daily_Business/2016/db0728/FCC-16-9
>6A1.pdf
>
>Please see Tom's email below on how to file a comment, but I would urge
>you
>to read the FCC proposal and file comments *against* the FCC's proposed
>rulemaking. You can see the ballet box is again be flooded for the
>expanded
>data privileges in the past week - there are only 20 days to file
>comments.
>
>If this ruling is enacted, and the FCC is leaning that way, this will
>come
>at a cost to CW and RTTY . See these comments already filed:
>https://www.fcc.gov/ecfs/search/filings?sort=date_disseminated,DESC
><https://www.fcc.gov/ecfs/search/filings?sort=date_disseminated,DESC&proceedi>
>&proceedi
>ngs_name=RM-11708
>
>Unfortunately, in the FCC proposed ruling issued over a week ago, the
>Commission appears to have ignored ALL comments made by hams after the
>initial 30 day comment period back in late 2013. During that one month
>period, there was a 95% "pro" letter writing campaign by over 800
>people --
>It was only after the CW and RTTY enthusiasts woke up in March of 2014
>that
>public comments became overwhelmingly negative against RM 11708.
>Unfortunately, the FCC has apparently ignored all of those comments, so
>new
>comments need to be filed on the FCC;s recent ruling.
>
>If you care about CW and RTTY, please file comments against the ruling,
>to
>preserve some sanctuary for narrowband data (having less than 500 Hz
>bandwidth), the way the largest ham country (Japan) has done to ensure
>no
>QRM to CW and RTTY enthusiasts.
>
>Thanks for considering.
>Best 73 ted n9nb
>
>Winlink Global Radio Email for Disasters or Emergency Preparedness
>communications. Group
>1 Message
>Digest #4406
>1
>Comments on RM-11708 - time to get those comments in! by "Tom
>Whiteside"
>n5tw
>Message
>1
>Comments on RM-11708 - time to get those comments in!
>Fri Aug 5, 2016 2:36 am (PDT) . Posted by:
>"Tom Whiteside" n5tw
>As you have heard on this reflector, the FCC has amended the ARRL filed
>RM-11708 and is now seeking comments on this. It is critical that we
>add our
>supporting comments during this period and the process below is a step
>by
>step on how to do so.
>
>I'd suggest something simple - please make it clear that you support
>the
>amended proposal - these responses are going to be tallied at least at
>the
>first level by clerks so be clear! In my filing, I emphasized the clear
>gain
>in efficiency with the elimination of the archaic symbol rate and sited
>currently not legal Pactor 4's ability to double the throughput in the
>same
>bandwidth as Pactor 3 and that this would bring us on par with the rest
>of
>the world.
>
>Use your own words - form letters will be seen as such.
>
>And thanks for your important support! Instructions on filing below:
>
>Tom Whiteside N5TW
>
>=====================
>
>IMPORTANT MESSAGE: Time is running out for comments supporting RM-11708
>to
>the FCC, which would remove the symbol rate limitation from FCC rules,
>and
>allow hams to use Pactor 4 modems in the USA. If the proposed rule
>change
>fails this time, it will be years before we have another chance.
>
>It is very easy to submit a comment. Please do. You don't have to say
>much
>other than you think it's a good idea, and that you support it.
>
>Here are the steps to submit a comment.
>
>1. Go to <http://apps.fcc.gov/ecfs/> <http://apps.fcc.gov/ecfs/>
>http://apps.fcc.gov/ecfs/
>
>2. Select "Submit a Filing (Express)" from the list in the upper left
>corner
>of the screen.
>
>3. In the topmost paragraph of the next screen, click "click here to
>manually enter your docket number"
>.
>
>4. Enter RM-11708 as the "Proceeding Number". Enter your name, address,
>and
>type your comments in the bottom field.
>
>5. Click "Continue";, and then click the "Confirm" button on the
>summary
>page it will display.
>
>6. If everything goes properly, it will give you a submission
>confirmation
>number.
>
>Here are the relevant points:
>
>a. The proposed change does not alter the bandwidth limits or the
>frequencies available for digital use, so no new frequency space is
>being
>used. It has no negative impact on the Ham spectrum.
>
>2. The use of Pactor 4 simply makes the use of existing bandwidth more
>efficient, so additional traffic can be passed without allocating new
>frequencies.
>
>3. The further development of even faster protocols in the same
>bandwidth
>limitations depends on the success of this rulemaking
>
>_______________________________________________
>RTTY mailing list
>RTTY@contesting.com
>http://lists.contesting.com/mailman/listinfo/rtty
--
Sent from my Android device with K-9 Mail. Please excuse my brevity.
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