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

[Jeff Blaine]

The reality of the bands and the regs is not the dire case laid out at all, in my view.  It may be a nightmare but then again, on balance, it works pretty good with most parties well accommodated.  

So who's not accommodated under the current regs?  The email-over-HF guys.  No one else is.  The RTTY guys are happy and that is a fast growing contest segment.  The weak signal and popular digital modes guys - there is continued development here with cool stuff like JT65 - all of these are narrow banded projects.  And the CW guys are happy as ever.  

Now if the case were as you suggest (dire), where experimentation and the like were suffering badly, then where is the evidence for that?  It's a big world out there and the US is not the only guys with R&D capability.  In fact, I would think that there would be some sexy digital comms methods dominating the bands (or that at least was quite popular) in other, more enlightened countries that don't have the 80's era baud rate restriction.  An example mode that we could point too as an example of why this proposal is really needed and why the US amateur is suffering.  We could be saying "our regs prevent us from doing more XXXX - just like the guys in EU."   But we don't have that mode to point to; instead we have "modernization" and "21st century" and other terms that my marketing teacher would have called "apple-pie terms."

The US hams may be more comfortable with this sort of thing if they believed that the League was reflecting the wishes of the US ham population and that means they were addressing the risks up front.  And while I don't begrudge the email guys' their opportunity to run fast data, throwing the door open to that sort of stuff without any constraint - as this proposal does - seems a poor risk/reward decision.   Regardless of the bandwidth number that gets stuck in the proposal.

73/jeff/ac0c

-----Original Message-----
From: bfrahm at st-tel.net [mailto:bfrahm at st-tel.net] 
Sent: Friday, November 29, 2013 9:48 PM
To: Jeff Blaine
Cc: kcdxc at mailman.qth.net
Subject: RE: [KCDXC] Link for FCC Filing RM-11708 REJECT Sample

On Sat, 30 Nov 2013 03:08:19 +0000, Jeff Blaine <Jeff.Blaine at epak.com>
wrote:
........
> This situation would have been completely hopeless if the original 
> proposal verbiage (unspecified codes) was not amended and pulled.  But

**That was a regrettable oversight in drafting the rulemaking request.
Apparently came about by maintaining some VHF-area language that didn't belong.

> don’t we have the similar situation with this device in that it's not 
> a specified com method - meaning either you have to buy a similar unit
(best
> case) or you can't read the link at all (worst case)?

**We could go back to the old days when RTTY sent a CW ID every 10 minutes, but I think nowadays it'll be sufficient to 'get in touch with an OO or capable monitor' if a problem-causing signal is busting the agreed-on limits.
 
> I am not sure why we would want to bet the future of the non-phone 
> band-space on effective self-policing - if we can't monitor the com
link? 

**The monitoring can come from equipped observers as above - conceptually not different from nowadays where lots of stakeholders are incapable of demodulating numerous modes.

And if for reasons which I can't fathom, wideband data operators start running roughshod over the bottom 65 and can't be persuaded to behave, the rules could always revert to less bandwidth than 2.8 (or whatever is ultimately decided with this NPRM).  The risk of this (to me) unlikely scenario is offset by the reward of experimentation with and use of fast data.  I will be surprised if droves of ops use such modes regularly.

Regardless of your concerns over the entire NPRM, I suspect you agree that eliminating the 300 baud/no bandwidth restriction rule as a speed limit, and going to a more 21st century limit is a good move.  And then..... 
we're just kicking the can down the road until the awkward nature of fitting digital voice and other modes into the rules becomes so nightmarish that something really different will need to be done.  And that something in my estimation should be Regulation by Bandwidth (or no {federal} regulation at all like most of the rest of the world).  But as was learned a few years ago it's going to take some more time for US hams to get used to that idea, live with ever more contorted FCC language and the glacial speed with which that language usually gets modified, and come around to embracing the adaptability of such a spectrum usage paradigm where the stakeholders call the shots. 

I appreciate your interest in this Jeff, and I sure want my cw hangouts available !

73  Bruce