Simply put, I agree 100% with Kermit's assessment of the NPRM 73 de Mike N2YBB Sent from my iPad On Aug 16, 2016, at 12:40 PM, Kermit Carlson via arrl-odv <arrl-odv@reflector.arrl.org> wrote:
Hello Chris, Tom, Brennan et al;
The present RM-11708 elimination of any bandwidth restriction is untenable and consequently has a generated a considerable negative response in the Central Division. Although the originally proposed 2.8 kHz limitation was not well received, the current form of this NPRM that proposes no limitation is causing a very strong response, all negative.
Now that it is in the form of an NPRM it is my understanding that it belongs to the Commission and not the League. In other words, we have no manner to withdraw it. In my opinion if it was within our capability to withdraw, we should.
I agree with Chris that in no way should we take ownership of this, and given the possibility that no limitation on bandwidth does represent a well deserved cause for concern by the CW community, it is my opinion that we should advocate not to support RM-11708 in it's present form.
Simply hoping that the Commission writes a suitable correction to this problem in RM-11708 is a very real gamble, with arguably a very low chance of a reasonable outcome. My present desire is that the League fully appose this NPRM, and it is my prayer that it does not become a rule. The least we can do is publicly distance ourselves from the present objectionable provision of no bandwidth limitation. Removing support for this is not only my position but I believe that it is the position of the majority of my constituents.
As Chris points out both a bandwidth limitation and elimination of the symbol rate limitation were necessary for this to work, without both neither alone is sufficient for our needs. I agree.
73, Kermit W9XA
From: Christopher Imlay <w3kd.arrl@gmail.com> To: "Price, Brennan, N4QX" <bprice@arrl.org> Cc: "Frenaye, Tom, K1KI" <frenaye@pcnet.com>; arrl-odv <arrl-odv@arrl.org> Sent: Monday, August 15, 2016 12:09 PM Subject: [arrl-odv:25580] Re: RM-11708
Tom Frenaye and Board members, attached is a briefing memo I sent to the Board in December of 2013 about our Petition for Rule Making. As Brennan notes, our argument in our Petition is not changed from our argument now. I hope the attached memo helps you deal with any pushback from members about the FCC NPRM but it is important to note that our Petition had two points: It would (1) Remove the symbol rate limitation for data emissions in the band segments where RTTY and data emissions are now permitted; and (2) Establish a maximum bandwidth for data emissions of 2.8 kHz on MF and HF bands (where none currently exists, except for some unattended operations). The MF and HF segments subject to this new maximum bandwidth limit are: 160 meters; 3.5-3.6 MHz; 7.000-7.125 MHz; 30 meters; 14.00-14.15 MHz; 18.068-18.110 MHz; 21.0-21.2 MHz; 24.89-24.93 MHz; and 28.0-28.3 MHz. Both components of our petition were necessary and neither alone is sufficient.
The FCC proposal has only one point: it would remove the symbol rate limitation. It would allow unlimited bandwidth emissions in the RTTY/data subbands. Not good. So don't allow ARRL to take the heat for this FCC proposal, because it is literally half-baked.
73, Chris W3KD
On Sun, Aug 14, 2016 at 5:34 PM, Price, Brennan, N4QX <bprice@arrl.org> wrote: TomF,
ARRL's position is unchanged since the publication of this FAQ on point:
http://www.arrl.org/rm-11708- faq
If we wish to reply to N9NB's latest advocacy directly, we may agree with him that some limitation on wide bandwidth data emissions is necessary and appropriate. On the other hand, N9NB is proposing a regulation-by-bandwidth approach of the type that was resoundingly rejected last decade. We've taken a regulation-of-bandwidth approach for data emissions that actually provides narrow bandwidth emissions more relative protection than they receive now.
That's the best I can do with family by Niagara Falls.
73 de Brennan N4QX/VE3
Sent from my BlackBerry 10 smartphone on the Verizon Wireless 4G LTE network. Original Message From: Frenaye, Tom, K1KI Sent: Sunday, August 14, 2016 16:52 To: arrl-odv Subject: [arrl-odv:25571] RM-11708
TomG/Brendan/Chris -
N9NB's comments about RM-11708 are getting pretty broad distribution. Will we be posting a web story that helps to counter it? Or, is there a summary of points available I can use for responding to the people that have contacted me? I think I understand much of it but it's a complex topic and I want to be sure I get it right.
Thanks
-- Tom
===== e-mail: k1ki@arrl.org ARRL New England Division Director http://www.arrl.org/ Tom Frenaye, K1KI, P O Box J, West Suffield CT 06093 Phone: 860-668-5444
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