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

[Fred Jensen]

[I left Rich's complete email on this reply to make reference easier]

Ted's warning [that wideband emissions can now occur in the RTTY/Data 
sub-bands] is real, and quite obviously, the effects are world-wide, not 
just in the US.  NPRM-11708 does in fact propose to remove all bandwidth 
limits in the MF/HF RTTY/Data sub-bands, which I will abbreviate "RDS" 
from here on.  Note however, we are discussing RDS in the MF/HF amateur 
allocations [essentially below 30 MHz] only.

<factoid#1>Right now, on 21 Aug 2016, there are *no* bandwidth limits 
for any emissions in the RDS.  Read that again ... today, with no action 
by the FCC at all, I can communicate with my buddy using a 256-QAM 
emission at about 25 KHz bandwidth.</factoid#1>

In 1980 and for awhile afterward, the symbol rate limit of 300/sec *did* 
impose a bandwidth limit of about 1-analog telephone channel because 
data transmission then was some variant of FSK [only], and 1 bit equaled 
1 symbol.  Bandwidth limit by proxy.  We all know that the situation in 
coding and modulation theory changed dramatically in the 30+ years since 
and today, 1 symbol can include essentially any number of bits you choose.

<factoid#2>In their original petition, ARRL, realizing that the "limit 
by proxy" was no longer effective, sought to impose a direct bandwidth 
limit in the RDS.  As a peripheral matter, they suggested removing the 
no longer effective 300/sec symbol rate limit</factoid#2>

ARRL chose 2.8 KHz for several reasons:  It's about "1 analog telephone 
channel's" worth of bandwidth; that was essentially the "limit by proxy" 
in 1980; and it would have no effect whatsoever on any existing 
emissions and users.  Note the last ... it will come up again.

<factoid#3>PACTOR3, which has been around a long time, which has a 
fairly well established user base and infrastructure, and with which we 
have co-existed, has an occupied bandwidth of about 2.1 KHz.  PACTOR4, 
prohibited now because its symbol rate is about 1,000/sec, has an 
occupied bandwidth of about 2.4 KHz</factoid#3>

Unless you memorize the sound of PACTOR's, none of us will notice the 
coming of PACTOR4, and all the PACTORs are an unfortunate serious 
distraction to the matter at hand.  NPRM-11708 isn't about PACTOR and 
never was.

<factoid#4>Actions by the FCC are governed by the Administrative 
Procedures Act [APA] which requires a somewhat slow process that 
includes multiple opportunities for public input</factoid#4>

The matter at hand in NPRM-11708 contains exactly two questions:  1) 
Should the symbol rate limit of 300/sec at 97.309(f) be eliminated?; and 
2) Should a specified limit of 2.8 KHz occupied bandwidth in the RDS be 
imposed?

Those are the ONLY two issues that can be decided in this proceeding. 
Any comment/request outside those two issues will be ignored.  Folks, 
read that again.  If you want to be heard, you must speak to those two 
issues.  Anything else is irrelevant to the proceeding at hand.

<factoid#5>There is no distinction within any of the RDS that segregates 
different permitted emission types, and there hasn't been since the 
mid-50's when the FCC first authorized 850 Hz shift FSK, 45.5 baud, 
ITA-2 radioteleprinter emissions.</factoid#5>

There are no MF/HF CW-only sub-bands, and there haven't been for longer 
than many here have been alive.  Nothing in NPRM-11708 is going to cause 
encroachment on anything that isn't already a possibility today. 
Suggesting otherwise is non-factual, and will be ignored at the FCC.

If in your comments, you assert that 2.8 KHz is too wide and something 
smaller [1 KHz or even 500 Hz] should be the limit as Ted suggests, your 
comment will be ignored.  Why?  Two reasons ... that is not part of the 
current proceeding; and, more importantly, it would prohibit emissions 
that have been permitted for years and for which there are user, 
equipment, and infrastructure bases in place.

Kicking currently authorized emissions out of the amateur allocations is 
a Really Big Deal [RBD], and any RBD would require one or more new 
proceedings under the APA.  If you want to divide the RDS's into 
sub-segments -- CW, PSK/JTxx, PACTOR<anything>, which would be another 
RBD, you must file a petition to do so.  If you want a hard bandwidth 
limit that prohibits currently authorized emission[s], you must file a 
petition to do that.  Good luck.

Way over half of the original ~1,500 comments to RM-11708 in 2013 were 
extraneous to the issue at hand and were most likely ignored.  In the 
process, we lost a lot of credibility with the FCC.  We're supposed to 
understand 47CFR97.  We did a terrible job of doing that in 2013.  We 
really need to do better in 2016.  It may be our last chance for awhile.

73,

Fred ["Skip"] K6DGW #142
- Northern California Contest Club
- CU in the Cal QSO Party 1-2 Oct 2016
- www.cqp.org

On 8/21/2016 11:14 AM, Richard Thorne wrote:
> 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
>
> ****
>
> 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