Dick, relative to the following statement, I think you substantially misperceived my point:

"Actually General Counsel Imlay's statement that “both components of our petition were necessary” is incorrect. A government-mandated bandwidth restriction is not necessary."

Both components of our petition ARE in fact absolutely necessary in order to accomplish the goal set by the Board at the New Orleans Board Meeting, which effectuated the recommendation of the Symbol Rate Committee. I certainly was not arguing the policy issue of regulation of subbands in the abstract. You well-state what the Wireless Bureau would like for us to adopt as a philosophy but which we have not done thus far. The memo that I just sent to the Executive Committee asking for guidance on this issue I think quite fairly enunciates the option of deregulation of subbands that FCC proposes. If the Board as a whole or the Executive Committee should decide to change course at this point and support the deletion of the symbol rate limit without imposition of any bandwidth limitation on data emissions in the RTTY/data subbands, then I will faithfully argue that in the comments due in mid-October. And an easy argument to FCC it would be since that is their preference obviously. 

I am constrained to note, however, that no bandwidth limit on data emissions in those subbands is not the preference of a large number of CW and RTTY enthusiasts who weren't happy at all with our Petition as originally filed, and who, thus far, seem to like the FCC NPRM proposal even less. But that is a matter that you and your brethren have to deal with in deciding how to proceed. 

Please don't, however, tag me with making an argument about the inherent necessity of a bandwidth limit. There is none. The only necessity of such is with respect to doing what the Board instructed at the time, which we are obligated to continue to do until the Board takes a different route.

73, Chris W3KD     

On Wed, Aug 17, 2016 at 7:21 PM, Richard J. Norton <richardjnorton@gmail.com> wrote:
Actually General Counsel Imlay's statement that “both components of our petition were necessary” is incorrect. A government-mandated bandwidth restriction is not necessary.

All of mankind's problems are not best solved by government regulation. In the absence of government intervention, the imagined potential-interference issues that some of our members appear to be concerned about will be solved by the realities of radio communication and the marketplace.

PACTOR IV vs PACTOR III

Realistically, the only current impact of eliminating the USA's symbol-rate limitation would be to allow US amateurs to use Pactor IV protocol data-transmission. Pactor IV permits transmission of data at 2 to 3 times the rate of the presently allowed Pactor III, using the same, or even slightly less bandwidth. Pactor III does satisfy the present symbol rate limitation, where Pactor IV does not.

There is no benefit to continuing the forcing of USA digital-mode amateurs to use the inefficient Pactor III mode. It takes more time to send data. Using a mode that uses less bandwidth and takes significantly less time will result in less interference, not more.

Pactor IV is currently used by amateurs in essentially all other countries. Amateur Radio survives.

IMAGINED WIDE-BANDWIDTH INTERFERENCE 

Boogeyman-scenario wide-bandwidth modes that will destroy CW communication will not be used because they simply won't work effectively. Interference from CW signals will render such systems useless. For an example of this, note that Winlink systems are currently effectively shut down on active bands during weekends with big CW contests. 

FCC DOESN'T LIMIT VOICE BANDWIDTH 

The FCC places no bandwidth restriction on HF voice communication, other than the general requirement of 97.303a. Ninety-nine plus percent of amateur SSB communication uses a minimum of bandwidth. A handful of hi-fi hams use more, and life goes on. Another handful use AM, with a similar impact on ham radio's survival.

With this history, it is quite unlikely that the FCC will limit digital bandwidth.

BPL HISTORY

Government regulation did not prevent Broadband over Power Lines from destroying shortwave radio. BPL died because it was an inferior solution to connecting people to the web. The realities of radio communication and the marketplace killed it. Large-bandwidth HF digital systems that interfere with CW communication will not thrive either, because they are an inferior solution. They won't work. There is no need for government to ban them.

LEAVE THE FCC PROPOSAL ALONE

Both components of the League's petition were not necessary. The bandwidth-restriction part is unnecessary. There are better solutions to this issue than those proposed by the detailed-government-regulation-will-save-us advocates. 

The FCC's proposal to eliminate the symbol-rate restriction is a good one. It allows immediate use of the efficient Pactor IV protocol, and it even permits wider-band experimentation, which might be practicable in regions where interference is not a problem, such as in Alaska during the day on 80-meters.

The rest of the world has used Pactor IV for years. Let's not overreact to Chicken Little wailing.

73,

Dick Norton, N6AA


On Mon, Aug 15, 2016 at 10:09 AM, Christopher Imlay <w3kd.arrl@gmail.com> wrote:
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

_______________________________________________
arrl-odv mailing list
arrl-odv@reflector.arrl.org
https://reflector.arrl.org/mailman/listinfo/arrl-odv
_______________________________________________
arrl-odv mailing list
arrl-odv@reflector.arrl.org
https://reflector.arrl.org/mailman/listinfo/arrl-odv



--
Christopher D. Imlay
Booth, Freret & Imlay, LLC
14356 Cape May Road
Silver Spring, Maryland 20904-6011
(301) 384-5525 telephone
(301) 384-6384 facsimile

_______________________________________________
arrl-odv mailing list
arrl-odv@reflector.arrl.org
https://reflector.arrl.org/mailman/listinfo/arrl-odv




_______________________________________________
arrl-odv mailing list
arrl-odv@reflector.arrl.org
https://reflector.arrl.org/mailman/listinfo/arrl-odv




--
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