Here is a memo addressed to the EC but because of the widespread interest in this matter at the present time and since there is apparently a good deal of interest among ARRL members and the Directors need some information in order to enable a good response, I thought it best to copy ODV. I hope the attached memo is helpful in responding to your constituent members. 73, Chris W3KD On Tue, Aug 16, 2016 at 4:19 PM, Price, Brennan, N4QX <bprice@arrl.org> wrote:
We'll advocate for whatever the Board decides to advocate and what the EC directs us to file. As of right now and unless it is changed, the policy of the Board is to seek a removal of the symbol rate restriction and a new restriction of data signals to 2.8 kHz of necessary bandwidth.
The primary objective of this exercise, at least as those of us on the committee understood it, has been to remove the symbol rate restriction, which is technologically indefensible now and probably has been since it was enacted.
There are really only three ways to do this:
1) replace a symbol rate restriction with a bandwidth restriction (ARRL's position this decade),
2) replace a symbol rate restriction with a regulation-by-bandwidth approach (N9NB's approach now and ARRL's position last decade),
3) replace with nothing and let the market decide (FCC's proposal).
There is, of course, a fourth option to do nothing. It is difficult, in my view, for us to argue that Amateur Radio in the United States is at the cutting edge of technology when this rule prohibits amateurs from even approaching the cutting edge of HF data communications.
I must advise against changing course and arguing for no change to the current rules. If I didn't give this advice, I wouldn't be doing the job that bylaw 36(d) gives me.
73 de Brennan N4QX/VE3
Sent from my BlackBerry 10 smartphone on the Verizon Wireless 4G LTE network. *From: *Norris, David, K5UZ *Sent: *Tuesday, August 16, 2016 14:34 *To: *Pace, Jim, K7CEX *Cc: *Carlson, Kermit, W9XA (Dir, CL); Imlay, Chris, W3KD; Price, Brennan, N4QX; Frenaye, Tom, K1KI; arrl-odv *Subject: *Re: [arrl-odv:25587] Re: RM-11708
Food for thought:
As originally passed by the board, we placed a bandwidth limitation (which I insisted upon) in the proposal motion. Further, the proposed RM motion would likely not have passed without it.
73
David A. Norris, K5UZ Director, Delta Division
Sent from my iPhone
On Aug 16, 2016, at 12:57 PM, Northwestern Div. Director < nwdvd@comcast.net> wrote:
Although I have been waiting for this Petition to be approved, the current presentation, as Kermit points out, will not work for my constituents in Alaska and other remote places who are waiting for Parctor IV. Let’s hope a reasonable rendering will be forthcoming. 73, Jim
*From:* arrl-odv [mailto:arrl-odv-bounces@reflector.arrl.org <arrl-odv-bounces@reflector.arrl.org>] *On Behalf Of *Kermit Carlson via arrl-odv *Sent:* Tuesday, August 16, 2016 9:40 AM *To:* Christopher Imlay <w3kd.arrl@gmail.com>; Price, Brennan, N4QX < bprice@arrl.org> *Cc:* Frenaye, Tom, K1KI <frenaye@pcnet.com>; arrl-odv <arrl-odv@arrl.org> *Subject:* [arrl-odv:25583] Re: RM-11708
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