[KCDXC] Link for FCC Filing RM-11708 REJECT Sample

[Jeff Blaine]

ERROR CORRECTION

Should have had coffee first.

-23 dBc should be -26 dBc.

That is related to the ITU’s 0.5% bandwidth definition.

73/jeff/ac0c



From: Jeff Blaine
Sent: Monday, December 02, 2013 7:27 AM
To: 'bfrahm at st-tel.net'
Cc: k0ca at arrl.org; k0das at arrl.org; jdbandman at earthlink.net; brucefrahmk0bj at gmail.com; 'kcdxc at mailman.qth.net'; kcdxcforfun (kcdxcforfun at byrg.net)
Subject: RE: [KCDXC] Link for FCC Filing RM-11708 REJECT Sample

Thanks for that Bruce,

I have seen that doc 28 comments and that’s a pretty summarized summary – it contains no discussion or debate.

Couple of points regarding the proposal and discussion which are a bit off from the major problem (unconstrained email):


1.        The basis using 60m is fatally flawed.  Those channels are separated by 10 KHz and there is no inter-channel overlap risk.  To say success of wide bands modes here is completely non-applicable to the rest of the non-channelized ham bands.  That should have been challenged right up front.


2.        The ARRL proposal has no measurement criteria specified.  The common digital standard is to specify BW limits at -23dbc.  This is very important when dealing with these modes as they are prone to severe IMD and what is nice and narrow at -3db is fat as a barn as you get down the skirt a bit.  There may be some other part of 97 which defines this but if it’s not, then it needs to be added.

I noticed you had dropped the club email off the last reply.  If you don’t mind, I really need to keep the KCDXC in on the thread because we have had an active discussion on this among the members for the last week and considering the clock is quickly ticking down on the 30 day comment point, they should have access to the latest comments I can dig up.

73/jeff/ac0c

From: bfrahm at st-tel.net<mailto:bfrahm at st-tel.net> [mailto:bfrahm at st-tel.net]
Sent: Monday, December 02, 2013 7:14 AM
To: Jeff Blaine
Cc: k0ca at arrl.org<mailto:k0ca at arrl.org>; k0das at arrl.org<mailto:k0das at arrl.org>; jdbandman at earthlink.net<mailto:jdbandman at earthlink.net>; brucefrahmk0bj at gmail.com<mailto:brucefrahmk0bj at gmail.com>
Subject: RE: [KCDXC] Link for FCC Filing RM-11708 REJECT Sample


Tnx for the info Jeff.  I can't recall at the moment if the automatic control sandboxes are required only in the case of two automatic stations.  If not, the WL2K guys are over-reaching.  If so, there is some risk of skip-zone occupancy the semi-auto control op is not aware of.  I recall discussions on that but not the bottom line - too many years ago.

I think and hope there will be public comments from the Symbol Rate Modernization Committee members on this.  As for this committee's minutes I THINK they are available to the membership. It's a little difficult for me to tell if I have a cookie making it look like they're open, but really not. Go to:

http://www.arrl.org/committee-reports

and if you can select and open Doc 28 from July 2013 - there you are.

I normally read IARU Region 2 and 3 reports. For some reason I'm not directed to R1 reports - tnx for including that.

I've copied my gmail account on this - if this thread continues please use that and you could drop the st-tel.  The gmail is much more civilized. I need to switch my reflector memberships over.....

73   Bruce

On Sun, 1 Dec 2013 21:41:29 +0000, Jeff Blaine <Jeff.Blaine at epak.com<mailto:Jeff.Blaine at epak.com>> wrote:
Hi Bruce,

The unattended subbands are being interpreted by one of the larger user groups (Winlink) as not being applicable.  This comment is drawn from the verbiage on their own web site which you can read verbatim here:

From:  http://www.winlink.org/guidelines

2nd paragraph on the web site says:

‘Since the inception of Winlink 2000, its participating stations have utilized the Internet to automatically forward traffic, and using the Amateur bands for links with its end-user community. This, of course, is faster, and saves valuable spectrum for real-time end-user connections. On HF Pactor, the radio users of the Winlink 2000 system initiating a contact are present as control operators, and therefore, WinLink 2000 operations do not fall within the category of "automatic control" per U.S. FCC Part 97.221. As described within the FCC Part 97.221, such operations are either under "automatic control" or "local or remote control."’

A guy on a boat in the ocean is the control op for a station on land?  This position boggles my mind – but then again, I’m not a lawyer so maybe to the more educated and wise, it is logical.  And if the WInlink guys can ignore 97.221, that  precedent means any wideband digital user can park anywhere in the non-phone segment of any band - all completely legal.

The man on the street view that I have on the subject sums the “threat” from the petition, if you want to use that term, this way.  It is  the combination of applying a wider bandwidth limit across the entire CW/digital spectrum, without baud limits, without respect for the IARU guidelines on the email-type stations, and without constraint for same under 97.221 - all the while allowing the use of wide banded codes which may (in the best case) require the purchase of some pretty pricy ($2K) modems to monitor and in the worst case cannot be monitored.

I’m sure the committee is well aware of these contradicting viewpoints and concerns (for example, K1ZZ is a cosigner to the petition and also an attendee to the IARU R2 meeting mentioned).  Perhaps it would bolster their case if the committees meeting notes were published and that they were to comment on the concerns raised (which are essentially the same concerns raised in 2005-2007).

The more you dig into this subject, the more cause for alarm there is.  It’s as if the League’s position seems to be that we need to “pass it to see what’s in it.”  We don’t need to pass it to see what the likely problems are going to be – a quick look around the other regions can add light to those as the IARU-1 link illustrates.

73/jeff/ac0c