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[RTTY] FW: FW: If you care about CW and RTTY - time is of the essence

To: "'RTTY Reflector'" <rtty@contesting.com>
Subject: [RTTY] FW: FW: If you care about CW and RTTY - time is of the essence
From: "Jim McDonald" <jim@n7us.net>
Date: Sun, 14 Aug 2016 12:48:04 -0500
List-post: <rtty@contesting.com">mailto:rtty@contesting.com>
Here’s N9NB’s response to N8OHU’s points.

73, Jim N7US


From: Ted [mailto:tsrwvcomm@aol.com] 
Sent: August 14, 2016 10:12

Sent from smartphone, please excuse typos

On Aug 14, 2016, at 10:55 AM, Ted <mailto:tsrwvcomm@aol.com> wrote:
Hi Matthew: thanks for sending me your note.

I am not a part of the RTTY email list. So, I would ask you to please forward 
my note as a rebuttal to your comments. I will also send this to a few people 
who are perhaps on that RTTY alias, in case you don't care to forward my note. 

I am happy to reply to Mathew Pitts' comments, and hope you all will read 
carefully the NPRM issued by the FCC this July 28, 2016. And please spread the 
word. This is not fear mongering, as I have too many things to do in my day job 
to spend time on anything that is not real. I am trying to get people to read 
the NPRM and realize what is happening – and it's sad for me to see how hard it 
is to get CW/RTTY enthusiasts to realize that they are false to assume the ARRL 
and FCC would preserve CW or RTTY. They now have to take serious action if they 
care about preserving their operating bands.
 
Understanding this and the history of the digital aggression goals of ARRL, 
WINLINK, and the boating community is vital to realize the ramifications of the 
July 28 2016 NPRM by the FCC. The NPRM 11708 of July 28 2016 is about to become 
law and is what the FCC intends to do if there is not a vocal outcry.
 
In particular, please read Paragraphs 9 through 12 of the FCC's NPRM of July 
28,2016 super carefully!  That’s where it is clear that the DATA/RTTY HF 
subbands, which include ALL CW and RTTY frequencies, from the lowest edge of 
the HF band up until the Voice/Image subbands, will be subjected to unlimited 
bandwidth new data signals. That is, the FCC is proposing to authorize 
UNLIMITED BANDWIDTH, and UNLIMITED DATA RATE signals in the ENTIRE Data/RTTY HF 
subbands from the lowest edge up to the SSB/Voice/IMAGE subbands. All of the CW 
and RTTY frequencies are impacted in that sub band – that’s where CW and RTTY 
operate – that should be clear to anyone reading the NPRM.
 
This NPRM is a rule, with the force of law, about to be passed by the FCC. It's 
already gone much farther than RM 11306 did when the ARRL tried this same 
proposal at the FCC in 2005 to put this wideband data in the SSB/Phone/Image 
band – the ARRL pulled it because the SSB operators were well organized and 
vocal. But now they have gotten it through the FCC in the CW/RTTY subbands --- 
it never went that far before, because SSB hams shouted it down at the 
ARRL............sadly CW/RTTY operators have not been successful and have had 
huge apathy and skepticism about the threat, and now this is about to become 
law unless there is a MAJOR outcry and comments at both the FCC and ARRL to 
stop the interference in the lowest 100 kHz.).
 
Please, please educate yourself by reading about RM 11306 on the web. It was a 
ferocious battle in 2005-2007. The ARRL withdrew it in 2007, finally. They then 
retooled it in 2013 as RM 11708, and have it about ready to get into law – 
UNLESS people respond mightily to ARRL officials and the FCC during this 
2-month comment period. this is not fear mongering, I assure you. It's trying 
to get people awake and aware of the pending law in the FCC publication. 
Without strong consideration and response, ham radio in the US will be subject 
to this rule making, and it's going to be very bad for CW/RTTY, just like the 
SSB ops saw and successfully fought off in RM 11306.
 
For history, see RM 11306 on the web. So many thousands of posts rejected RM 
11306, an ARRL board member resigned in disgust, here is just one simple sample 
assessment, when the ARRL proposed this identical proposal 10 years ago, except 
in the phone sub bands, (Now they are getting it into the Data/RTTY subbands, 
which by definition are where CW and narrowband modes operate):  
http://www.eham.net/articles/13018
 
Here are specific answers to some of your questions or doubts about the gravity 
of RM 11708 by the FCC:
 
Yes, this impacts all CW and RTTY on HF, because the NPRM specifies all HF 
“Data/RTTY” subbands. That is the subband where CW and RTTY and narrowband JT65 
and PSK 31 operate.
 
Yes, the FCC is proposing UNLIMITED bandwidth. Even if the FCC accepted ARRL’s 
2.8 kHz bandwidth limit, the problem STILL negatively impacts CW and RTTY 
signals, since Pactor 4 and other HF modems will be allowed in ANY CW/RTTY 
frequency, and digitized voice of up to 2.8 kHz bandwidth will also be allowed 
on ANY CW /RTTY frequency. This would cause wider band SSB-like bandwidth 
signals to mix and overtake CW/RTTY narrowband signals. Note that CW has only 
200 Hz max bandwidth, RTTY has 500 Hz max bandwidth. These narrowband signals 
cannot be used when they are clobbered by 2.8 kHz wide band signals. That is 
why the FCC never allowed SSB to operate on top of the CW/RTTY signals. We must 
keep this segregation by bandwidth to assure CW and RTTY can operate without 
wideband interference. That is why I and others are advocating that the NPRM be 
MODIFIED to limit the emission bandwidth to 200 Hz in the lowest 50 kHz of each 
HF subband, and why a limit of 500 Hz should be enforced for the lowest 100 kHz 
of each subband. That would assure that CW and RTTY would not be subjected to 
wider band interference, while still allowing wider band data to exist above 
100 kHz above the lowest HF edges.
 
Regarding Pactor and its problems, that is, what we will be subjected to if the 
ARRL’s 2.8 kHz bandwidth is eventually accepted at the FCC (right now, that 
does not look likely – the FCC wants to open the bandwidth to be much greater – 
unlimited) PACTOR in general (I do not know the specifics of PACTOR 4) uses run 
length encoding and decoding a technique in which common words and
strings of two or more letters (e.g., sh, ing, in, on, the, etc.) are replaced 
with a "token." In addition, the resulting message is then compressed 
(apparently PACTOR 4 adds the ability to use an encrypted "key" for the 
commercial version).

However, the developers of PACTOR do not release details of either the 
compression algorithm or the substitution table for PACTOR 2 - 4, so it's not 
really public, and its unintelligible unless you buy the $1500 modem. and there 
is no CW ID. Yet it's being used today in ham radio under the guise of being 
published. It’s a grey issue.
 
When you read the FCC NPRM Paragraph 10, they mention 97.309(a) as being the 
only codes allowable on HF/MF, but the problem is §97.309 (a) contains several 
parts - it specifies ITA 2, AMTOR (SITOR)
and ASCII data formats ("Codes") but also - in §97.309 (a)(4) - lists several 
permitted *transmission methods* (or "encoding methods") "whose technical 
characteristics have been documented publicly" including PACTOR. But that’s not 
really what's happening today.

The issue is that the only the original PACTOR was *publicly documented* - the 
PACTOR 2 - 4 encoding systems are **NOT** publicly documented! Yet Pactor 3 is 
operating today.  People cannot stop or identify offending transmissions that 
QRM them with Pactor 3. Will be so much worse with Pactor 4 and future data 
signals!
 
Another major real problem is in §97.309 (b) which permits "undocumented codes" 
under certain circumstances.  The loopholes in §97.309 (b) are big enough to 
drive a bus through. Has been the cause of QRM already for years with automated 
data.
 
All of this will become so much worse if NPRM is legalized, and the FCC is not 
dealing with these issues and are ignoring it, as you can see in NPRM paragraph 
10, where it simply assumes all hams will use only enough bandwidth as they 
need.  Yet the FCC contradicts itself and says that wideband experimentation 
should be supported, of arbitrary large bandwidth, so there is a huge disaster 
waiting to happen if the NPRM is passed as is ---- the existing problems with 
Pactor will immediately erupt into a huge mess and no regulation on the TTY 
subbands!  right now, the FCC is leaning towards no bandwidth protection and no 
bandwidth limit for the lowest 100 kHz of each HF band for CW/RTTY to keep all 
emissions below 200 or 500 Hz. You allow wider transmissions than this, e.g. 
unlimited bandwidths as proposed by the FCC, or 2.8 kHz bandwidths as 
originally proposed by the ARRL, and the entire CW/RTTY lower portion of HF 
becomes swallowed up in wider bandwidth data signals, either PACTOR or wider 
with digitized voice, etc. over time. that is what is at stake. I hope this 
makes sense! {Please, please get active and spread the word, if you care about 
CW or RTTY.

Thus, Matthew's desire to minimize the impact of the FCC's proposal is not 
accurate. Also, Canada has a tiny fraction of hams as the US and propagation 
from VE often goes over the US on high bands- It's a red herring. This is a 
real threat to all of RTTY and CW and requires immediate action and thoughtful 
comments to the FCC and ARRL officials.
 
73 ted n9nb

Sent from smartphone, please excuse typos

On Aug 14, 2016, at 10:34 AM, Matthew Pitts <mailto:n8ohu@yahoo.com> wrote:
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


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