[SFDXA] Urge the FCC-Reject ARRL's Symbol Rate Petition

Kai k.siwiak at ieee.org
Mon Dec 9 13:46:43 EST 2013 

Hi Norm,
Yes, you are right. The interference issue is a huge concern, but once again, 
that out of scope to the ARRL proposal. Whether the ARRL proposal wins or loses 
the interference issue under discussion remains the same. To correct that, hams 
would need to petition the FCC for rules, or the very least, a clarification of 
the current rules relating to automatic operation. Perhaps as little as 
enforcement of the current rules would do it!

Once a proposal is filed, only comments by others directly  related to the 
filing are relevant. Nothing changes the "automatic station" issue with or 
without this filing. AA6YQ's arguments, while reasonable and a big concern to 
hams, are nonetheless irrelevant with respect to this ARRL proposal.

Note an interesting dilemma in Mickey's argument below (Mickey you are right, by 
the way.)  The FCC cares about TRANSMISSION BW, but the way we use bandwidth, 
for example JT65/JT9 requires ownership of an aggregate bandwidth of as much a 
4-6 kHz, since we need to RECEIVE and decode multiple stations simultaneously, 
even though any one of them occupies less than 170 Hz.

Much of the rhetoric centers around back-door methods of preventing PACTOR-4 
(same 2200 Hz BW as PACTOR-3-SL5) from entering ham usage. But PACTOR-3 and -4 
are exactly the same from the BW and interference point of view - the proposal 
won't change that either way.

By precedent, the FCC will NOT adopt any rule which discriminates against a 
current user. That means today's 2200 Hz modulations (like PACTOR-3) are here to 
stay.

Now, considering the above, the downside of a failed ARRL proposal is the 
potential introduction of digital modulations that GREATLY exceed 2200 Hz. SDR 
radios have the capability already, they are just not very prevalent yet. That 
is my argument why we need a BW limit. Once someone gets established at a wide 
BW (remember, there is no BW limit today!), they will be here to stay. Once 
again, today there is NO BW limit on digital modulations. The only 'de facto' 
limit is there are very few radios out there now that can handle a digital 
modulation much wider than about 2200-2400 Hz.

We NEED a  statutory BW limitation, and we need it now.

73
Kai, KE4PT

On 12/9/2013 12:48 PM, Norm Alexander wrote:
> There has been a lot of additional discussion on this subject by several 
> parties on a variety of Reflectors.  I forwarded just one of the early 
> comments, and since then there have been several additional responses and a 
> lively exchange of ideas.
>
> The key issue that Dave AA6YQ has is in regard to the 'automatic' data 
> stations that often cause interference as they apparently do not monitor their 
> frequencies before transmitting.  Dave suggests that the interference would be 
> worse with the ARRL proposal.  He has petition the ARRL to change there FCC 
> petition to also address the interference potential.  AA6YG is not apposed to 
> the wider bandwidth if there were steps to control the automatic stations 
> included in the FCC petition.
>
> I think that his is a reasonable argument, that is to make sure the 
> interference protection is included in the FCC proposal.
>
> Norm W4QN
>
> --------------------------------------------------------------------------------
>
> *Subject:* Re: [SFDXA] Urge the FCC-Reject ARRL's Symbol Rate Petition
>
> Kai is correct in that there's no current bandwidth restrictions - there's
> lots of wide stuff out there.
>
> I think that the dxlab suite is great and I respect AA6YQ's legacy there
> and in his civilian career, but I believe he's wrong about this and we need
> a bandwidth limitation.
>
> I do think that the term "symbol rate" as the ARRL suggested is perhaps
> outdated. As ways of detecting and modulating signals in high noise
> environments (like HF) get more sophisticated, standard Nyquist rates are
> too limiting. If, for example, I can get 20,000+ effective bits/s in 3kHz
> bandwidth, why shouldn't I be allowed - encouraged - to do so? Why not
> limit by aggregate used bandwidth by one station at one time in the HF
> spectrum? This would allow for more sophisticated codec, encourage
> experimentation and allow for spread spectum, among other things... and
> keep the bandwidth hogs at bay.
>
> I don't like the semantics in the petition, but I think bandwidth
> restrictions are a good idea.
>
> 73,
>
> Mickey N4MB
>
>
>
> On Mon, Dec 9, 2013 at 9:42 AM, Kai <k.siwiak at ieee.org 
> <mailto:k.siwiak at ieee.org>> wrote:
>
> > I agree with you, Bill, except that the ARRL filing has absolutely nothing
> > to do with that.
> > The popping up of unattended signals is not addressed in the filing, and
> > will not change one way or the other because of the filing.
> >
> > I've read AA6YQ's comments as well. He also misses the big point. All his
> > arguments are valid except that they also have nothing to do with the
> > filing.
> >
> > Under current rules, there is no BW restriction on digital modulations,
> > they are "restricted" only due to the BW limitations of current ham radios.
> > Most of today's radios can't handle much more than the currently used 2200
> > Hz wide signals.
> >
> > We NEED a BW limit.
> >
> > Search Kok Chen's comment on [RTTY]. He gets it.
> >
> > -Kai, KE4PT
> >
> >
> >
> > On 12/9/2013 7:40 AM, Bill wrote:
> >
> >> Comments were by AA6YQ...
> >>
> >> In general, the RTTY/Digital community is against this new set of rules.
> >> I personally agree that the unfettered popping up of unattended signals is
> >> a problem and rules pandoring to small sections of the community at the
> >> cost to large sections is troublesome.
> >>
> >> Bill Marx W2CQ
> >>
> >> \
> >> On 12/8/2013 11:45 PM, Kai wrote:
> >>
> >>> Be careful what you wish for. Under the current FCC rules there is NO
> >>> bandwidth restriction on digital communications. As radio capabilities
> >>> (read that software defined radios capable of wide bandwidth) people will
> >>> define wide band digital systems exceeding the currently used  2200 Hz
> >>> digital modulations. Those modulations were designed to fit inside the
> >>> linear portion of the  BW of most of today's radios.
> >>>
> >>> The big danger in defeating the ARRL proposal is that as future rig
> >>> capabilities increase, and linear bandwidths get bigger, like in some  SDR
> >>> radios, people will begin filling that bandwidth capabillity with
> >>> modulations much wider than today's 2200 Hz modulations, and UNDER TODAY'S
> >>> RULES.
> >>> I think that we need a defined bandwidth limit (which is completely
> >>> distinct from a baud rate limit).
> >>>
> >>> AA5AU's analysis is dangerously flawed.  Many of the issues he raises
> >>> are valid ham radio concerns but they have little or nothing to do with
> >>> RM-11708.
> >>> 73
> >>> Kai, KE4PT
> >>>
> >>> On 12/8/2013 9:15 AM, Bill wrote:
> >>>
> >>>> From Don AA5AU:(edited for space)
> >>>>
> >>>> I threw together a webpage showing how to file comments on the recent
> >>>> ARRL Petition designated RM-11708. It is located at:
> >>>> http://aa5au.com/fcc/how-to-comment.html
> >>>>
> >>>> It is IMPORTANT that each of you, whether you live in the United States
> >>>> or not, file a comment showing your opposition (or support)
> >>>> of the ARRL Petition. As mentioned on this reflector previously, this
> >>>> petition has world-wide ramifications.
> >>>>
> >>>> The only way we are going to defeat this thing is with an abundance of
> >>>> well-thought out
> >>>> comments directed against the petition.
> >>>>
> >>>> If you would like to see what comments have been submitted, you can go
> >>>> to:
> >>>>
> >>>> http://apps.fcc.gov/ecfs/proceeding/view?name=RM-11708
> >>>>
> >>>> Feel free to forward these links to any other organizations that may
> >>>> benefit from them. I will post a link to the how-to-comment
> >>>> page on the home pages of rttycontesting.com and aa5au.com later today.
> >>>>
> >>>> 73, Don AA5AU
> >>>>
> >>>>
> >>>>
> >>>> On 12/8/2013 9:01 AM, Norm Alexander wrote:
> >>>>
> >>>>> The following is an argument for writing the FCC opposing the ARRL
> >>>>> Symbol Rate Petition written by Dave AA6YQ author of DXLab logging program,
> >>>>> and active DXer.
> >>>>>
> >>>>>
> >>>>> What I thought sounding like a reasonable request by the ARRL, after
> >>>>> reading Dave's argument, I have changed my mind -  something to think
> >>>>> about.  Note comments are due by Dec. 17th
> >>>>>
> >>>>> Norm W4QN
> >>>>>
> >>>>>
> >>>>> -----Original Message-----
> >>>>>
> >>>>> Sent: December 07, 2013 14:33
> >>>>> To: dxlab at yahoogroups. com
> >>>>> Cc: Dave AA6YQ
> >>>>> Subject: [dxlab] Why (and How) You Should Urge the FCC to Reject the
> >>>>> ARRL's
> >>>>> Symbol Rate Petition
> >>>>>
> >>>>> Note: the message below is not directly relevant to DXLab, but as I
> >>>>> consider
> >>>>> this issue critical to all amateur radio operators, I am taking the
> >>>>> liberty
> >>>>> of posting it here.
> >>>>>
> >>>>> 73,
> >>>>>
> >>>>> Dave, AA6YQ
> >>>>>
> >>>>> The ARRL has filed a petition with the FCC to replace the current
> >>>>> symbol
> >>>>> rate limits with a bandwidth limit. If accepted, digital modes as wide
> >>>>> as
> >>>>> 2800 hertz would become legal for use by US hams on HF bands. Pactor 3,
> >>>>> which is legal under the current symbol rate limit, is 2200 hertz wide.
> >>>>>
> >>>>> If the ARRL's petition were accepted, automatic (unattended) digital
> >>>>> mode
> >>>>> stations currently using Pactor 3 could be upgraded to wider modes.
> >>>>> Many
> >>>>> automatic stations lack the ability to forego transmitting on a busy
> >>>>> frequency, and thus interfere with ongoing QSOs. If automatic stations
> >>>>> are
> >>>>> permitted to use modes with bandwidths up to 2800 hertz, the incidence
> >>>>> of
> >>>>> this interference will increase significantly.
> >>>>>
> >>>>> While US-based automatic stations using digital modes wider than 500
> >>>>> hertz
> >>>>> are restricted to specified sub-bands (e.g. 10,140 - 10,150, 14,095 -
> >>>>> 14,099, 14,101-14,112, 21,090 - 21,100, 24,925 - 24930), these
> >>>>> frequencies
> >>>>> are shared with QSOs between live operators. Furthermore, the WinLink
> >>>>> network now claims that its automatic stations are actually under the
> >>>>> control of the remote stations that invoke them, and are therefore no
> >>>>> longer
> >>>>> restricted to these sub-bands. This network now advertises US-based
> >>>>> automatic stations running Pactor 3 outside the automatic sub-bands -
> >>>>> automatic stations that could be upgraded to 2800 hertz modes if the
> >>>>> ARRL
> >>>>> Petition is accepted.
> >>>>>
> >>>>> Allowing automatic stations to use wider digital modes without first
> >>>>> taking
> >>>>> steps to reduce the interference they cause to ongoing QSOs is a
> >>>>> recipe for
> >>>>> increased conflict and ill will - the opposite of what's needed. In the
> >>>>> interest of continued innovation, we should allow the use of wider
> >>>>> digital
> >>>>> modes on HF bands - but in a manner that reduces interference and
> >>>>> conflict,
> >>>>> rather than making it worse as the ARRL's petition would do.
> >>>>>
> >>>>> I therefore urge you to oppose the ARRL's petition by filing comments
> >>>>> with
> >>>>> the FCC before December 17. Don AA5AU has provided instructions for
> >>>>> doing
> >>>>> so:
> >>>>> ______________________________________________________________
> >>>>> South Florida DX Assoc.
> >>>>> SFDXA WebSite: http://www.SFDXA.com <http://www.sfdxa.com/>
> >>>>> SFDXA Repeater 147.33+ 103.5 Tone
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> >>>>>
> >>>>>
> >>>> ______________________________________________________________
> >>>> South Florida DX Assoc.
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> >>>> SFDXA Repeater 147.33+ 103.5 Tone
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> >>>>  ______________________________________________________________
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> >>> SFDXA Repeater 147.33+ 103.5 Tone
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> >>  ______________________________________________________________
> > South Florida DX Assoc.
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