Kermit, you have the situation correct except that there is no longer an RM-11708; FCC has created the NPRM in Docket 16-239 and as you say (and I just had this same conversation with Jim Boehner; I will forward you our correspondence for clarity) this is no longer our proposal, it is FCC's. Any action we would take to withdraw RM-11708 would be completely meaningless and it would not help the situation at all. I am in the midst of an EC memo on the subject because normally, the EC decides how to proceed here. My recommendation will be that we file comments which (for about the fifth time so far) attempt to explain to the WTB that our two-part petition was sufficient as filed but simply eliminating the symbol rate limit without imposing any bandwidth limitation is not sufficient. We have very little choice, but my normal SOP is to ask the EC to give us some guidance before I draft comments on this. As I just mentioned to Tom Frenaye though, my fear is that this may be FCC's method of requiring the Amateur community to self-regulate on subbands and develop our own private sector protocols rather than to rely on FCC to micromanage the subbands through regulation. That is one of two explanations for what they have done here so far. The other explanation is that they really don't understand this and don't care enough to figure it out. I think the simplest explanation is the right one using Occam's Razor and so I think this is their challenge to the Amateur community to stop coming to them with little tweaks to Part 97 and to do the self-regulation that we say we do well. 73, Chris W3KD On Tue, Aug 16, 2016 at 12:40 PM, Kermit Carlson <w9xa@yahoo.com> 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 <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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-- Christopher D. Imlay Booth, Freret & Imlay, LLC 14356 Cape May Road Silver Spring, Maryland 20904-6011 (301) 384-5525 telephone (301) 384-6384 facsimile W3KD@ARRL.ORG
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-- Christopher D. Imlay Booth, Freret & Imlay, LLC 14356 Cape May Road Silver Spring, Maryland 20904-6011 (301) 384-5525 telephone (301) 384-6384 facsimile W3KD@ARRL.ORG