From Jeff.Blaine at epak.com Tue Oct 11 08:34:28 2016 From: Jeff.Blaine at epak.com (Jeff Blaine) Date: Tue, 11 Oct 2016 12:34:28 +0000 Subject: [KCDXC] LAST DAY TO POST COMMENTS on WTB 16-239 (from the ARRL RM-11708) Message-ID: Dear KC DX Club members, Today is the last day the FCC is accepting comments on their elimination of the baud rate limit. If approved as it's written now, this will open the door to unlimited wide band data on the entire CW/RTTY/digital modes segment of the ham bands. And like all good government actions, once something is turned on, it's nearly impossible to turn it off. So please take a few minutes and add your comments to let the FCC hear your voice. For those interested, my comments to the FCC follow at the end of this email. 73/jeff/ac0c Dear KC DX Club members, Bad news!!! The instructions I provided on making your comments on the RM-11708 proposal were incorrect. -------------------------------------------------------------------------------------------------------- The correct instructions are: 1. Go to: fcc.gov/ecfs/filings. Click EXPRESS FILING at the top of the page. 2. THIS IS THE IMPORTANT PART: In the proceedings section type: 16-239 3. There will be a list that comes up as you type. And you will finally see "16-239 | Amatuer Baud Rate". Click on that line. 4. There should be a YELLOW BOX now with "16-239" inside it. Meaning you now have the right reference. Good job! 5. State your position. Etc.... NOTE: The FCC web page seems to take a few days to get updated so once you submit, it won't show up in the search list immediately. When I sent mine in on 10/11, the latest post was 10/7. -------------------------------------------------------------------------------------------------------- The FCC has issued their Notice of Proposed Rule Making (WT Docket 16-239). But what has been happening is that most of the hams have been providing comments citing the old ARRL petition reference (RM-11708). So when the FCC queries their magical database they won't see any of the recent posts - unless they have the "WTB 16-239" proceeding listed. --------------------------------------------------------------------------------------------------------------- Proceeding(s): 16-239 : Amatuer Baud Rate Filer(s): Jeffrey Blaine Brief Comments: I'm writing in opposition to the proposal for the following reasons: 1. I'm an extra-class licensed operator and make about 8,000 contacts per year in the areas of the bands where traditional RTTY mode operation is conducted. I frequently experience harmful interference from unattended automatic data stations (ADS) which currently utilize PACTOR variants for communication, most frequently on the 80, 40 and 20m amateur bands. The ADS typically handle email sent via HF and have no significant busy-channel detection capability. If higher speed (and accompanying wider bandwidth) encoding methods are authorized, there will be increased demand for these systems, which in turn will drive more wanton interference, further compromising the existing sub-bands. 2. The ADS stations popularly use a PACTOR version as the encoding method. With approval of 16-239, an even wider-bandwidth variant (PACTOR-IV) primarily benefits ADS stations and their email-via-HF user base. PACTOR-IV is a proprietary encoding method and is unreadable by 3rd party observers. This by definition precludes the amateur community from its historically effective self-policing role. Additionally, the essentially encrypted nature of the PACTOR-IV communication link may invite abuse by commercial entities or nefarious individuals who would be able to effectively hide their identity. 3. While the existing baud rate limit may be old, it does provide an effective way to differentiate between narrow and wide band emissions. This is important because wide band emissions do not peacefully coexist with narrow band emissions and for that very reason the historical division of separate sub-bands for the two has worked very well. 4. Lifting the baud rate limit as a driver for technical innovation is questionable. Innovation in digital modes for amateur radio use is narrow banded by nature. PSK31, the JT-series and WSPR weak signal modes are the most popular examples of excellent encoding methods suitable for HF. By contrast the only wide-banded mode frequently mentioned in justification for an increased baud rate limit is PACTOR-IV, promoted most vocally by email-via-HF proponents. Individuals wishing to pursue traditional amateur radio communications - one person conversing with another person in real time - do not do so with bulk email applications. For these reasons, I encourage the FCC to withdraw 16-239 in favor of a solution which includes interference mitigation of the wide band emissions and importantly upholds the historical role of the amateur service as a shared non-commercial, individual-to-individual operator communication environment. Regards, Jeff Blaine Amateur Radio Station AC0C