[EIDXA] Fwd: I need some of your time and help

Wed Aug 17 07:17:10 EDT 2016

 From K0ACP

-------- Forwarded Message --------
Subject: 	I need some of your time and help
Date: 	Tue, 16 Aug 2016 22:43:58 -0400
From: 	Art Peters <k0acp at k0acp.com>
To: 	Dennis Klipa <n8erf at arrl.net>, John Wolters <w8qn at aol.com>, John J. 
McDonough <wb8rcr at arrl.net>, John Henley <henleyjp at charter.net>, Lee 
Hodges <lee.hodges at charter.net>, caney at charter.net Caney 
<caney at charter.net>, Charlie Nielsen <c.nielsen at charter.net>, Jay Breher 
<blackdragon258 at gmail.com>, Rich Haendel <Rhaendel at q.com>, Craig 
Fastenow <k0cf at arrl.net>, Kathy Peters <kathy.kay.peters at gmail.com>, Pat 
Russell <russell_p at chartermi.net>, Pat Mullet <pat_mullet at yahoo.com>, 
Milton Garb <n6mg at verizon.net>, Dave Wallick <dwallick01 at gmail.com>, 
David Westbrook <dwestbrook at gmail.com>, Wendy Russell 
<russellw513 at gmail.com>, Joe Miller <kj8o.ham at gmail.com>
CC: 	n9nb at arrl.net

Colleagues,

A friend and classmate of mine, Dr. Ted Rapport, N9NB, has recently made 
me aware of a filing before the FCC, RM-11708, that if approved, will 
likely ruin the ability to use the digital sub band allocation of the HF 
bands for CW, RTTY, PSK, and other narrow-band modulation modes.  
RM-11708 essentially eliminates the bandwidth restrictions currently 
imposed by the FCC for the digital sub bands and likely render it 
impossible to effectively use CW, RTTY, PSK, ….

Here is what I am asking that you do:

1)review my e-mail and other information you may find and make up your 
own mind.

2)If you agree with me, the please submit a filing with the FCC against 
the current form of RM-11708.  The steps to submit a filing are:

a.Go to  <http://apps.fcc.gov/ecfs/> 
<http://apps.fcc.gov/ecfs/>http://apps.fcc.gov/ecfs/

b.Select "Submit a Filing (Express)" from the list in the upper left 
corner of the screen.

c.In the topmost paragraph of the next screen in the box for 
Proceeding(s), click "click here to manually enter your docket number".

d.Enter RM-11708 as the "Proceeding Number". Enter your name, address, 
and type your comments in the bottom field.

e.Click "Continue";, and then click the "Confirm" button on the summary 
page it will display.

f.If everything goes properly, it will give you a submission 
confirmation number.

Here is the text of the filing that I made with the FCC – Please note 
that I have reviewed and copied Ted’s, N9NB filing:

August 16, 2016

To the Federal Communications Commission:

*Re: Comments for Notice of Proposed Rulemaking  RM-11708 in WT Docket 
No. 16-239*

The notice of proposed rulemaking (NPRM) proposes to remove the baud 
rate and bandwidth of data signals in the HF bands, and seeks comments 
about if a bandwidth limit is required, as well as any economic 
consequences or benefits of its ruling (see Paragraphs 7, 8, footnote 
28, footnote 37, Paragraph 10, and Paragraph 12).  The FCC should 
recognize the important ramifications of this ruling, as it will impact 
the ability of the hundreds of thousands of narrowband operators to 
continue to enjoy the hobby if unlimited baud rate, unlimited bandwidth 
signals are allowed to operate in the same spectrum currently used by 
narrowband amateur operators. An unlimited bandwidth signal with 
unlimited baud rate will essentially allow wide walls of digital signals 
with arbitrarily large bandwidth to ride roughshod over narrowband 
signals.  The FCC’s NPRM was silent on the issue of interference, and 
should provide some governmental regulation to avoid the potentially 
disastrous situation where a regulatory framework would legally allow 
interference by unlimited bandwidth signal.

In its 1988 rulemaking, PR Docket 88-139, the FCC made a critical 
decision to separate transmission types so as /to relegate the 
transmission of certain inharmonious emission types to different 
segments of amateur service/ (see NPRM at 2, footnote 8). Now, in 2016, 
the FCC should consider that a proposed unlimited baud rate and 
unlimited bandwidth signal is indeed a different and/inharmonious/ type 
of emission than existing narrow band data transmissions used by 
hundreds of thousands of amateur operators.  In the 28 years since rules 
were made for computer and data communication, we now live in a world 
with internet, wideband modems, and computer communications that are 
thousands of times faster than current regulations ever considered. Yet, 
the HF spectrum available to amateur operators has remained extremely 
limited in bandwidth. Thus, while I support the removal of a baud rate 
limit and a bandwidth limit, /this must only be done/ if narrowband 
transmissions are given protected HF spectrum in the lower edge of the 
HF bands, where none of the newly proposed signals would operate or leak 
into. The proposed wideband data emissions, such as Pactor 4 and other 
serial tone modems, are inharmonious to narrow band transmissions that 
are used by the overwhelming majority of amateur operators in the 
RTTY/data portion of the HF bands. A great deal of evidence for this was 
offered in the comments to RM-11708, see particularly the vast majority 
of public comments filed after March 17, 2014.

The overwhelming majority of users in the RTTY/Data bands (e.g. the 
lower 100 kHz of every HF band -- except for 60 meters) utilize 
narrowband transmissions such as CW, RTTY, PSK31, and JT65. These 
narrowband transmissions do not occupy more than ~200 Hz of RF 
bandwidth, and certainly never more than 500 Hz of bandwidth (where 
bandwidth may be defined and measured as being 50 dB down from peak 
continuous wave power, or some other suitable definition). These types 
of narrow band operations enjoy national and global popularity because 
of their narrow bandwidths, since such narrow band signals enable better 
signal to noise ratio and thus greater communication reliability for a 
given set of equipment. Narrow band signals are completely incompatible 
with simultaneous operation of wideband signals, and are rendered 
useless when interfered with by wide band signals. As noted in Footnote 
37 by Leslie and others, and in Paragraph 9, the FCC has never allowed 
2.8 kHz SSB signals in the RTTY /data segment of HF, because wideband 
SSB signals are much wider and drown out narrowband signals, rendering 
the narrowband signals useless. As it does with SSB/Voice/Image signals, 
the Commission should similarly protect narrowband RTTY and data signals 
from the newly proposed wide band data signals that would not be limited 
in bandwidth or baud rate. Without a rule that expressly protects the 
narrowband users in sub bands at the low end of the HF bands, there will 
be chaos and interference created to current CW, RTTY, and other 
narrowband operators, not just in the US, but globally due to the long 
distance nature of HF propagation.

The evidence in the RM-11708 record (see, for example comments filed by 
Gerdes, White, Morrison, Muns, the undersigned, and hundreds of others) 
shows the vitality of narrow band CW and RTTY modes even in the no-code 
licensing era, and documents how wideband interference levels caused by 
the NPRM would render CW and RTTY unusable in the case of interfering 
wideband stations. Further, hundreds of commenters provided strong 
evidence of the already existing large amounts of interference that was 
experienced by amateurs attributed to existing automated wider-band data 
stations or HF mailboxes that are grandfathered in and allowed to use 
wider bandwidths while failing to listen-before-transmitting. The 
Commission should also recognize that there was a large amount of 
seemingly automated “ballot stuffing” in the early days of the RM 11708 
FCC posting (presumably by an organized group or groups wishing to gain 
access to the protected CW/Data HF sub bands, see an analysis of 
comments provided by the undersigned). This body of evidence that 
pertains to interference, and the need for FCC regulation to protect 
narrow band operations, is part of the public record of RM-11708, and 
should be relied upon in the FCC deliberations for this NPRM. As noted 
above, the NPRM was completely silent on the interference problem, just 
as was the ARRL’s original petition (the word “interference” or the 
consideration of interference by the proposed elimination of baud rate 
and bandwidth was never addressed by the FCC in its NPRM, but it must be 
considered, since the amateur radio service is limited in spectrum and 
relies on regulation to ensure inharmonious transmission types do not 
interfere with one another).

Without interference protection, the wideband unlimited data emissions 
being proposed will overwhelm and eliminate the ability of current 
narrow band operators to enjoy the Amateur Radio Service. In light of 
the interference issues, the FCC should reconsider its tentative 
assumption in Paragraph 10 that no bandwidth limitation is needed. In 
response to the Commission’s request for comment on an appropriate 
bandwidth limit in Paragraph 12 of the NPRM, I would urge the commission 
to require all data /RTTY signals to have an emitted RF bandwidth (50 dB 
down from peak, or 50 dB down from a CW tone in the center of the 
emitted pass band, or some other definition) no greater than 500 Hz in 
the lowest 100 kHz of every applicable HF band (e.g. 1800-1900 kHz, 
3500-3600 kHz, 7000-7100 kHz, 14000-14100 kHz, 21000-21100 kHz, and 
28000-28100 kHz, as well as the WARC bands). This would ensure 
harmonious narrow band signaling (having no more than 500 Hz RF 
bandwidth) in a protected lowest portion of the HF bands, and would 
eliminate the inevitable wideband interference on a global scale that 
would result without such a protected narrow band sub band. By 
restricting bandwidths and ensuring wide band emissions do not drown out 
narrowband emissions in the lower edge of the HF bands, the new types of 
experimental data signals may thrive, while not hampering the vast 
majority of RTTY/data users who use narrowband transmissions.

Regarding the Commission’s request for economic impact in Paragraph 8, I 
am certain that if promulgated, the NPRM in its current state will have 
a significant detrimental economic impact on hundreds of thousands of 
amateur operators in the US who currently operate CW and RTTY. The cost 
of allowing the proposed “wideband” or “unlimited baud rate” signals to 
operate throughout the existing lower portions of the HF bands, without 
a protected sub bands, would be enormous. Today, hundreds of  thousands 
of amateur operators enjoy narrowband CW or RTTY (for example, the 
Straight Key Century Club is a group of tens of thousands of amateur 
radio morse code enthusiasts: http://www.skccgroup.com/). CW Ops is 
another amateur radio club that fosters morse code operation with 
membership numbers in the thousands if not tens of thousands 
http://www.cwops.org/ . All of the amateur operators who are members of 
these clubs, and in similar PSK and RTTY clubs,  have invested in morse 
code equipment, electronic keyers, computer loggers, and narrow band 
filers in their equipment, and most enjoy the use of modest antennas 
that allow them to use the scarce HF spectrum for narrowband operation 
in the hobby for reliable communication. As was noted by hundreds of 
commenters in the RM-11708 proceeding (NPRM, footnote 1, particularly 
all comments filed after March 16, 2014), CW is the most reliable, least 
expensive mode of communication in an emergency. Thus, CW and RTTY, and 
other narrowband modes, must be guaranteed a portion of the HF spectrum 
where they are protected from wideband data modes. Many commenters 
specifically noted that the population of Pactor 4 and WinLink operators 
is, in proportion, /thousands of times smaller in number/ than today’s 
narrow band operator population. To give up all the existing narrow band 
protection (which today is inherent in the 300 baud rate limit) would be 
a grave economic injustice and bring vast interference to amateurs who 
have invested in equipment for narrow band data and RTTY.

The commission should note that the US is the 2^nd largest amateur 
population with Japan being the largest. In Japan, narrowband modes on 
HF are specifically protected in their governmental amateur rules – the 
operation of 200 Hz wide bandwidth CW and data is specifically protected 
at the lower portion  of the HF bands (generally the lowest 20-50 kHz of 
the HF band), and an emission bandwidth limit of 500 Hz is generally 
required up to 100 kHz from the lowest HF band edge. IARU Region 1 has 
comparable recommendations to protect narrow band signaling from wider 
bandwidth signals. This is presumably why the FCC and Japanese 
regulators have never allowed SSB (2.8 kHz bandwidth) transmissions to 
operate where these narrow band CW (data) and RTTY signals are allowed 
to operate. In enacting this NPRM, the FCC must protect the narrowband 
operations by assuring the lowest 100 kHz of every HF band will not be 
permitted to emit more than 500 Hz bandwidth signals, and that the newly 
proposed wideband digital data signals, having unlimited bandwidth and 
baud rate, will not leak or emit into the narrowband sub band that must 
be created.

Thank you for considering these comments, and considering the impact of 
interference and existing investments made by the amateur radio 
community for use in the precious and small HF allocations – please 
revise the NPRM accordingly to protect narrowband CW/data and RTTY in 
the lower sub bands.

Arthur C. Peters, K0ACP

3)Next, I’d ask that you write / e-mail the ARRL Officers and Directors 
that represent you.  Here is the list of ARRL officials that I have 
e-mailed:

Rick

Roderick

K5UR at ARRL.ORG <mailto:K5UR at ARRL.ORG>

K5UR

President

ARRL

Tom

Gallagher

NY2RF at ARRL.NET <mailto:NY2RF at ARRL.NET>

NY2RF

CEO

ARRL

Mike

Raisbeck

K1TWF at ARRL.NET <mailto:K1TWF at ARRL.NET>

K1TWF

New England Division Vice Director, Chairman

Amateur Radio Legal Defense & Assistance

Marty

Woll

N6VI at ARRL.NET <mailto:N6VI at ARRL.NET>

N6VI

Southwestern Division Vice Director

Amateur Radio Legal Defense & Assistance & Legislative Advocacy Committee

Jim

Tiemstra

K6JAT at ARRL.NET <mailto:K6JAT at ARRL.NET>

K6JAT

Pacific Division Vice Director

Amateur Radio Legal Defense & Assistance

Mike

Lisenco

N2YBB at ARRL.NET <mailto:N2YBB at ARRL.NET>

N2YBB

Hudson Division Director

Amateur Radio Legal Defense & Assistance& Legislative Advocacy Committee

James

O'Connell

W9WU at ARRL.NET <mailto:W9WU at ARRL.NET>

W9WU

Member

Amateur Radio Legal Defense & Assistance

Jim

Pace

K7CEX at ARRL.NET <mailto:K7CEX at ARRL.NET>

K7CEX

Northwestern Division Director

Amateur Radio Legal Defense & Assistance

Chris

Imlay

W3KD at ARRL.ORG <mailto:W3KD at ARRL.ORG>

W3KD

General Counsel, ARRL

Amateur Radio Legal Defense & Assistance

Brian

Mileshosky

N5ZGT at ARRL.NET <mailto:N5ZGT at ARRL.NET>

N5ZGT

Vice President, Chairman

HF Band Planning

Tom

Frenaye

K1KI at ARRL.NET <mailto:K1KI at ARRL.NET>

K1KI

New England Division Director

HF Band Planning

David

Norris

K5UZ at ARRL.NET <mailto:K5UZ at ARRL.NET>

K5UZ

Delta Division Director

HF Band Planning

Dwayne

Allen

WY7FD at ARRL.NET <mailto:WY7FD at ARRL.NET>

WY7FD

Rocky Mountain Division Director

HF Band Planning

Bill

Hudzik

W2UDT at ARRL.NET <mailto:W2UDT at ARRL.NET>

W2UDT

Hudson Division Vice Director

HF Band Planning

Steve

Ford

WB8IMY at ARRL.NET <mailto:WB8IMY at ARRL.NET>

WB8IMY

Staff Liaison

HF Band Planning

Dr.

David

Woolweaver

K5RAV at ARRL.NET <mailto:K5RAV at ARRL.NET>

K5RAV

West Gulf Division Director

Legislative Advocacy Committee

Doug

Rehman

K4AC at ARRL.NET <mailto:K4AC at ARRL.NET>

K4AC

Southeastern Division Director

Legislative Advocacy Committee

BRENNAN

PRICE

N4QX at ARRL.NET <mailto:N4QX at ARRL.NET>

N4QX

CTO

ARRL

DALE

WILLIAMS

WA8EFK at ARRL.ORG <mailto:WA8EFK at ARRL.ORG>

WA8EFK

Great Lakes Division Dir

ARRL

Thomas

Delaney

W8wtd at arrl.org <mailto:W8wtd at arrl.org>

W8WLD

Great Lakes Division Vice Director

ARRL

Larry

Camp

WB8R at arrl.org <mailto:WB8R at arrl.org>

WB8R

Michigan Section Manager

ARRL

John

McDonought

WB8RCR at arrl.net <mailto:WB8RCR at arrl.net>

WB8RCR

Michigan Section EC

ARRL

Kenneth

Coughlin

N8KC at arrl.net <mailto:N8KC at arrl.net>

N8KC

Michigan Section OOC

ARRL

Daniel

Romanchik

KB6NU at arrl.net <mailto:KB6NU at arrl.net>

KB6NU

Michigan Asst Section Mgr

ARRL

Pat

Mullet

KC8RTW at ARRL.NET <mailto:KC8RTW at ARRL.NET>

KC8RTW

Michigan Public Info Cord

ARRL

Mark

Shaw

K8ED at ARRL.NET <mailto:K8ED at ARRL.NET>

K8ED

Michigan Section TM

ARRL

Gordon

Baldwin

W8CT at ARRL.NET <mailto:W8CT at ARRL.NET>

W8CT

Michigan Sec Youth Cord

ARRL

John

Nugent

WB8TKL at ARRL.NET <mailto:WB8TKL at ARRL.NET>

WB8TKL

Michigan Asst Section Mgr

ARRL

Jo

Miller

KJ8O at ARRL.NET <mailto:KJ8O at ARRL.NET>

KJ8O

Michigan Affiliated Club Coord

ARRL

Wallace

Murray

KE8HR at ARRL.NET <mailto:KE8HR at ARRL.NET>

KE8HR

Michigan Technical Coord

ARRL

Edward

Hude

WA8QJE at ARRL.NET <mailto:WA8QJE at ARRL.NET>

WA8QJE

Michigan State Govt Liason

Hon

Dan

Benishek

KB8TOW at ARRL.NET <mailto:KB8TOW at ARRL.NET>

KB8TOW

US Represenative

US Govt

Here is a copy of my e-mail to them: (again borrowed from N9NB)

Dear xxx:

I deeply appreciate and respect your service to the ARRL, and to our 
wonderful hobby.

As a life member of ARRL, I seek your help, and that of your ARRL board 
colleagues, to help solve a problem that RM 11708 will bring to the HF 
bands.

The narrowband CW/ RTTY operators need a regulation by bandwidth from 
the FCC to ensure that they may continue to enjoy our great hobby.

Like is already done in Japan and in all 3 ITU recommendations, I urge 
your support and leadership to have the ARRL be our voice to meet with 
the FCC, with the goal of obtaining 200 HZ emission limits in the lowest 
50 kHz of every HF band, and 500 HZ emission limits in the HF segment 
from 50 to 100 kHz above the lowest band edge. Without swift action and 
advocacy for CW and RTTY, and other narrowband operations, RM 11708 
promises to unleash some very difficult interference that will allow 
anyone to use arbitrary bandwidth modes. Such an approach would protect 
narrowband modes while still meeting the ARRL's desire to support more 
digital wide band traffic.

Here is the confirmation # for my filing with the FCC: 20160817837204658

Thanks for your service, consideration, and your support. Hams across 
the country are counting on your advocacy to protect the narrowband 
operators of our hobby.

73,

Art, K0ACP

Friends, thank you for your consideration of my request.

73,

Art Peters, K0ACP
k0acp at k0acp.com <mailto:k0acp at k0acp.com>