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

[Jeff Blaine]

The ARRL has done a pretty good job of making the claim look innocent enough.  The ARRL wraps it up with a bow talking about outdated rulings - essentially saying "if you like your cw/rtty/digital bands, you can keep your cw/rtty/digital bands.  Period."  

But as I looked at the proposal, I could not actually figure out who would benefit from the ruling change.  After digging, a more clear picture emerged and from what I can decipher, the more detailed explanation goes something like this.  


THE PROPOSAL

1. The ARRL proposal's major change that drops the baud rate limit and increases the bandwidth from 500 hz o 2.8 Khz.  

2.The new limit would apply anywhere CW/RTTY/digital is allowed now.  Note I said CW segment.  The only guys who won't be affected are the phone segments.


CONTEXT/BACKGROUND

1. The primary users seeking more wide banded modes legalization seem to be the email via HF guys.  There is a limited EMCOM argument but for the typical disaster scenario, running these systems on VHF/UHF (which is already legal) seems to be the preferred solution as propagation is removed as a variable.  

2. There is some confusion as to email-via-HF servers being of an "automatic" nature or not.  IARU defines "store and forward" systems as automatic and recommends their band allocation be limited.  The way the servers work is you transmit a signal to a server, and it replies with your email dump - the connection length may vary from a minute or so and upward (there is no max time limit).  The server does not listen to see if the frequency is busy; that's the job of the guy starting the link (the guy on the boat with his whip antenna at sea).

3. FCC 97.221 constrains "automatic systems" to a small band slot (without a bandwidth limit other than that implied by the slot width).   

4. Manual systems (under human control) are limited to 300 baud/500 hz operation outside these slots - allowing operation anywhere RTTY/data is allowed now. 

5. The most popular mail application seems to be Winlink.   And interestingly enough, the Winlink guys say (on their web page) that the RMS site is not an "automatic" system.  Therefore the subband restriction is not applicable.   That means the only thing limiting more users of this mode is pushing the speed up enough to make it interesting.



IMPLICATIONS IF THE ARRL PROPOSAL IS PASSED

1. The ARRL proposal means email over HF operation whatever max speed 2.8 Khz BW affords will replace the 300 baud/500 hz operation now. 

2 When allowing for AFC range, that means a MAXIMUM of 2-3 signals per 10 KHz.  Many times that number of users are accommodated with the traditional modes now.

3. And because the popular Winlink system interprets 97.221 as not being applicable to their RMS sites, a large portion of these signals will be from what we could call unattended servers.  


WORST CASE RESULT

1. The better the performance of the HF link (more speed), the more users will be drawn in.

2. With 2-3 P4 signals per 10 Khz, the digital space could be occupied pretty quickly.  That would compress all the existing traffic down lower in the band with the P4 traffic in chase.  Considering there are literally millions of water craft on the US coasts, even a faction of a percentage increase in the user base will mean serious congestion for the HF bands.

3. The (current) difficulty of monitoring of P4 transmissions makes identification of parties nearly impossible.  This greatly constrains the capability of the ham community to self-police.  This means more undesirable use (e.g. commercial) will occur more frequently as well.  [At one point, the ARRL had included "unspecified digital" codes be allowed which would allow encryption - but they have pulled that term due to public outcry.]


WHAT NEEDS TO HAPPEN

1. What hams should do is to provide comments to the FCC urging them to reject the petition.

2. I don't deny the emai-via-HF should be accomidated.  But throwing the door of the entire CW/RTTY/digital space open without any restrictions and hoping for the best makes no sense.  

3. So what I believe the ARRL should do is to work openly and solicity the ham community's inputs.   They need to get advocates of the CW and RTTY and current digital modes on their committee (it's currently 3 ARRL staffers and a couple of what seem to be email-over-HF advocates).  [Note that the same propsal was pushed by the ARRL in 2005 and died when 85% of the comments were negative.]  


73/jeff/ac0c


-----Original Message-----
From: kcdxc-bounces at mailman.qth.net [mailto:kcdxc-bounces at mailman.qth.net] On Behalf Of Jim Duncan
Sent: Thursday, November 28, 2013 10:16 AM
To: 'KCDXC'
Subject: Re: [KCDXC] Link for FCC Filing RM-11708 REJECT Sample

Why is this a bad proposal, Rob? It seems to me that, on the surface, it would allow for the introduction of new digital modes as long as they are within the width of an SSB signal (2.8 kHz). I don't see how this is a bad thing or how it would negatively impact current keyboard modes such as RTTY or ASCII.

73 de Jim, KU0G

--
Its not how many watts you have,
its the SIZE of your watts that matter! -- Johnny Marshall, W0JM-SK _____________________________________________________________
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