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

Sun Aug 21 17:16:07 EDT 2016

Rich,
     First, the FCC  will entertain comments until 1 October according to 
what I have read. Second, this is being pushed by the HFLINK group so 
that their radios are compatible with the military HFALE radios. Yes, 
this will have a detrimental impact in the CW/data portion of the bands.

     The argument is all of the current modes are obsolete and legacy. 
Additionally, ham radio can not progress unless there is a place to 
invent new modes and increase baud rates. Their argument does not 
account for the need for additional bandwidth. On the HFLINK reflector, 
they talk about about needing this to support disaster communications, 
however, that is handled nicely by VHF/UHF voice and HF disaster nets. 
Data needs are being handled nicely by the Winlink network on both HF 
and VHF. And now, HSMM is coming on line with mega bit data rates. And, 
the best part of all of this is that it can come together without the 
need for infrastructure. RM-11708 is not the best thought out NPR that I 
have read. And what is unfortunate is the ARRL has supported it.

     If you are worried about this, comments need to be sent to the FCC; 
the procedure is on the ARRL web site. And, the ARRL should be notified 
of your concern via mail or email, and before 1 October. The sooner the 
better. I have already done this.

73,
Barry
K3NDM
------ Original Message ------
From: "Richard Thorne" <rthorne at rthorne.net>
To: "Elecraft Reflector" <elecraft at mailman.qth.net>
Sent: 8/21/2016 2:14:57 PM
Subject: [Elecraft] RM-11708: CW and RTTY users please read

>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
>
>***
>
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