Gentlemen, I don't think the dissenters are at all out of line here. We did want a band width restriction on a wide band mode as originally passed by the board. I agree we work with them where we can and inform them of same. The viscous rumor on the comment period should be addressed as well. Thanks to Chris and Brennan for the additional in sight. 73 David A. Norris, K5UZ Director, Delta Division Sent from my iPhone
On Aug 8, 2016, at 11:25 AM, Christopher Imlay <w3kd.arrl@gmail.com> wrote:
One thing that isn't helping the general tenor discussions about this is that someone has circulated the crazy notion that FCC set an artificially short comment date for comments on this NPRM. some of the loud noise now is apparently due to this stupid rumor. On the face of the NPRM it clearly says that the comment date is 60 days after publication of the NPRM in the Federal Register, which hasn't happened yet as of today's Federal Register. So there are AT LEAST 61 days from today to file comments and perhaps much longer than that. If you get a chance, you can help calm down the fiery rhetoric out in the field on that part anyway.
73, Chris W3KD
On Mon, Aug 8, 2016 at 11:50 AM, Kermit Carlson <w9xa@yahoo.com> wrote: Hello Brennan;
Thank you for the quick response - and I do agree with your assessment of the commenters. The FCC proposal did create more issues than it solved.
73, Kermit W9XA
From: "Price, Brennan, N4QX" <bprice@arrl.org> To: "Imlay, Chris, W3KD" <w3kd.arrl@gmail.com>; "Carlson, Kermit, W9XA (Dir, CL)" <W9XA@yahoo.com> Cc: arrl-odv <arrl-odv@reflector.arrl.org> Sent: Monday, August 8, 2016 10:34 AM Subject: Re: [arrl-odv:25559] Re: Reflector traffic about RM-11708, from both pro and against...
The response is taking the form of a personal visit to address this and other issues of common interest.
I would note that what Tom Whiteside is advocating is no more in line with ARRL policy than what Ted Rappaport is advocating. The FCC's failure to propose a reasonable bandwidth limit on wide bandwidth data communications is a substantial departure from what we proposed.
Tom Whiteside is fine with what the FCC proposed. We are not. Ted Rappaport is not, but he wants a fix that fell flat on its face when this was visited in the 2000s. I would *not* characterize Ted as against removing the symbol rate, but as a passionate advocate of another fix. He is *not* a luddite.
We'll work with these guys where we can, and the positions are not as disaligned as the rhetoric would lead one to think. But at the end of the day, the board gave us a position (2.8 kHz bandwidth limitation), and we will stick to that position unless the board changes it.
The comment deadline is 60 days from publication in the Federal Register, which hasn't happened yet. This is not going away soon.
--Brennan
Sent from my BlackBerry 10 smartphone on the Verizon Wireless 4G LTE network. From: Imlay, Chris, W3KD Sent: Monday, August 8, 2016 10:57 To: Carlson, Kermit, W9XA (Dir, CL) Cc: arrl-odv Subject: [arrl-odv:25559] Re: Reflector traffic about RM-11708, from both pro and against...
FYI, Tom and Brennan Price are working up a response to Rappaport on this topic. Chris W3KD
On Mon, Aug 8, 2016 at 10:30 AM, Kermit Carlson via arrl-odv <arrl-odv@reflector.arrl.org> wrote:
Good Morning -
In case you have not received any emails about the Commission's proposed details for RM-11708, attached below are a few of the comments from Ted Rappaport N9NB and Tom Whiteside N5TW, on both sides of the bandwidth issue.
At least both sides are addressing their response to the Commission and not to the League.
73, Kermit W9XA
----- Forwarded Message ----- From: "'Jim McDonald' jim@n7us.net [NIDXA]" <NIDXA@yahoogroups.com> To: 'RTTY Reflector' <rtty@contesting.com>; 'CW Ops Yahoo Groups' <cwops@yahoogroups.com>; NIDXA Reflector <nidxa@yahoogroups.com>; MCWA Reflector <k9rn@yahoogroups.com>; CADXA Reflector <CADXA_SHARE1@yahoogroups.com> Sent: Sunday, August 7, 2016 7:14 PM Subject: [NIDXA] If you care about CW and RTTY - time is of the essence
From the SMC reflector.
73, Jim N7US
-----Original Message----- From: SMC [mailto:smc-bounces@w9smc.com] On Behalf Of Mike Wetzel Sent: August 07, 2016 18:38 To: smc@w9smc.com Subject: [SMC] if you care about CW and RTTY - time is of the essence
From Dr. Ted Rappaport N9NB
Dear Colleagues:
If you believe, as I do, that the proposal to unregulate the bandwidth of data signals (like Pactor 4) in the lower HF portion of the spectrum is dangerous for the hobby, both in the US and abroad, then please read on as we need your help. If you do not agree with me, or don't care about this, then feel free to delete and stop reading.
I ask that you PLEASE take action by filling public comments with the FCC regarding their recent RM 11708 proposed rulemaking in WT Docket No. 16-239 and RM-11708, and please forward this to every CW and RTTY enthusiast you know in ham radio, on every reflector, in every CW and RTTY club, both in the US and elsewhere, and urge them to also file comments with the FCC. We have less than 3 weeks to voice our opinion! It was not heard in 2014-2015.
TIME IS OF THE ESSENCE! There are less than 3 weeks during which the FCC will accept comments.
I am fearful and quite certain that RM 11708, as published in WT Docket No. 16-239 , which the FCC is now seeking public comment on as a prelude to enact its ruling, will terribly erode CW and RTTY on the HF bands in its current form. The ruling will allow PACTOR 4 and multi-tone modems on any frequency within the CW/RTTY frequencies on HF. This is worse than allowing SSB to operate throughout the CW/data sub bands, something the FCC has never allowed. The FCC is proposing an unlimited bandwidth for data signals in the lower HF bands (the ARRL asked for 2.8 kHz-- the bandwidth of SSB--- which was still bad - and the FCC proposal is even worse). I would urge all of you write in to object to RM 11708 and to ask that the FCC place a 500 Hz bandwidth limit all data transmission bandwidths such as Pactor, multi tone data modems, and other experimental data modes on all HF bands within the lowest 75 or 100 kHz region of each HF band. Japan has something similar. If we don't generate large support from hams to scale back the FCC proposal, and put a bandwidth cap in some portion of the lower HF bands, these monster QRMers of unlimited bandwidth will be allowed to operate anywhere in the CW/RTTY lower HF bands, and they will lawfully fire up on your CW or RTTY QS when you are least expecting it.
See below how the proponents of RM 11708, including my friend Tom Whiteside, are launching an aggressive letter-writing campaign for "pro" comments to be filed at the FCC to allow Pactor 4 and other wideband multi-tone modems to operate anywhere in the CW/RTTY spectrum, without a segregation of the band.
The public filing period ends in a few weeks, so we must write now to offer opposition to the Commission. The need for WinLink/Pactor data emergency communication on HF is being used as one of the arguments for expanding the data bandwidth. See the other arguments below. I would urge CW and RTTY enthusiasts to review the arguments for and against RM 11708, see the public comments filed from March 2014 to today, and please be moved to quickly to write about your opposition to the newly proposed regulation just released by the FCC (It can be viewed here): http://transition.fcc.gov/ Daily_Releases/Daily_Business/ 2016/db0728/FCC-16-9 6A1.pdf
Please see Tom's email below on how to file a comment, but I would urge you to read the FCC proposal and file comments *against* the FCC's proposed rulemaking. You can see the ballet box is again be flooded for the expanded data privileges in the past week - there are only 20 days to file comments.
If this ruling is enacted, and the FCC is leaning that way, this will come at a cost to CW and RTTY . See these comments already filed: https://www.fcc.gov/ecfs/ search/filings?sort=date_ disseminated,DESC&proceedi ngs_name=RM-11708
Unfortunately, in the FCC proposed ruling issued over a week ago, the Commission appears to have ignored ALL comments made by hams after the initial 30 day comment period back in late 2013. During that one month period, there was a 95% "pro" letter writing campaign by over 800 people -- It was only after the CW and RTTY enthusiasts woke up in March of 2014 that public comments became overwhelmingly negative against RM 11708. Unfortunately, the FCC has apparently ignored all of those comments, so new comments need to be filed on the FCC;s recent ruling.
If you care about CW and RTTY, please file comments against the ruling, to preserve some sanctuary for narrowband data (having less than 500 Hz bandwidth), the way the largest ham country (Japan) has done to ensure no QRM to CW and RTTY enthusiasts.
Thanks for considering. Best 73 ted n9nb
Winlink Global Radio Email for Disasters or Emergency Preparedness communications. Group 1 Message Digest #4406 1 Comments on RM-11708 - time to get those comments in! by "Tom Whiteside" n5tw Message 1 Comments on RM-11708 - time to get those comments in! Fri Aug 5, 2016 2:36 am (PDT) . Posted by: "Tom Whiteside" n5tw As you have heard on this reflector, the FCC has amended the ARRL filed RM-11708 and is now seeking comments on this. It is critical that we add our supporting comments during this period and the process below is a step by step on how to do so.
I'd suggest something simple - please make it clear that you support the amended proposal - these responses are going to be tallied at least at the first level by clerks so be clear! In my filing, I emphasized the clear gain in efficiency with the elimination of the archaic symbol rate and sited currently not legal Pactor 4's ability to double the throughput in the same bandwidth as Pactor 3 and that this would bring us on par with the rest of the world.
Use your own words - form letters will be seen as such.
And thanks for your important support! Instructions on filing below:
Tom Whiteside N5TW
=====================
IMPORTANT MESSAGE: Time is running out for comments supporting RM-11708 to the FCC, which would remove the symbol rate limitation from FCC rules, and allow hams to use Pactor 4 modems in the USA. If the proposed rule change fails this time, it will be years before we have another chance.
It is very easy to submit a comment. Please do. You don't have to say much other than you think it's a good idea, and that you support it.
Here are the steps to submit a comment.
1. Go to <http://apps.fcc.gov/ecfs/> http://apps.fcc.gov/ecfs/
2. Select "Submit a Filing (Express)" from the list in the upper left corner of the screen.
3. In the topmost paragraph of the next screen, click "click here to manually enter your docket number" .
4. Enter RM-11708 as the "Proceeding Number". Enter your name, address, and type your comments in the bottom field.
5. Click "Continue";, and then click the "Confirm" button on the summary page it will display.
6. If everything goes properly, it will give you a submission confirmation number.
Here are the relevant points:
a. The proposed change does not alter the bandwidth limits or the frequencies available for digital use, so no new frequency space is being used. It has no negative impact on the Ham spectrum.
2. The use of Pactor 4 simply makes the use of existing bandwidth more efficient, so additional traffic can be passed without allocating new frequencies.
3. The further development of even faster protocols in the same bandwidth limitations depends on the success of this rulemaking
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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
-- 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 _______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org https://reflector.arrl.org/mailman/listinfo/arrl-odv