[Elecraft] RM-11708: CW and RTTY users please read

[Richard Thorne]

To all CW/RTTY users...

RM-11708, as currently written/proposed, will have a detrimental and 
negative impact on the cw/rtty sub-bands.

Ted, N9NB, is very well versed on the subject.  Please check 
https://en.wikipedia.org/wiki/Theodore_Rappaport for Ted's back ground.  
He is a very active amateur, I worked him in the NAQP last night.

I'm including the body of a recent email that Ted wrote.  I strongly 
urge each of you to research the subject matter and contact your ARRL 
representatives soon.  In addition it would be helpful to make a comment 
on RM-11708 as described below....

Rich - N5ZC

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Dear Colleagues: If you believe, as I do, that RM 11708 is dangerous for 
the hobby, both in the US, I ask that you PLEASE take action  by filling 
public comments regarding the FCC's recent RM 11708 ruling, 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. If you do not agree with me, or don't care, then feel free to 
delete and stop reading.
I am  fearful and quite certain  that RM 11708, 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. 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, somethng the FCC has never allowed. The FCC is proposing an 
unlimited bandwidth for data signals (the ARRL asked for 2.8 kHz, the 
bandwidth of SSB, which was still bad -- 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 of Pactor, multi tone data modems, and other experimental 
data modes on all HF bands within the lowest 75 or 100 kHz region. 
Otherwise, these monster QRMers of unlimited bandwidth will be allowed 
to operate anywhere, and they will lawfully fire up on your CW or RTTY 
qso when you are least expecting it.
See below how the proponents of RM 11708, including my friend Tom 
Whiteside, are launching an aggressive 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 way Japan does (The public filing period ends in a couple 
of weeks, so we must write now to offer opposition). The need for 
WinLink/Pactor data emergency communication on HF is being used as one 
of the arguments for expanding the data bandwidth. I would urge CW and 
RTTY enthusiasts to review the arguments for and against RM 11708, and 
move 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-16-96A1.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 their proposed 
rulemaking.
You can see the ballet box is again be flooded for the expanded data 
privileges. 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&proceedings_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

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