[K3CAL] Band width restritions
kf3aa at comcast.net
kf3aa at comcast.net
Wed Aug 17 10:15:36 EDT 2016
I thought you all would like to see this
73 Bob
----- Original Message -----
1
Fellow PSK'ers by "Art Peters" k0acp
Message
1
Fellow PSK'ers
Tue Aug 16, 2016 8:00 pm (PDT) . Posted by:
"Art Peters" k0acp
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/ <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/ <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/ <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 2nd 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
PODXS 070 #1140
k0acp at k0acp.com
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