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 W3KD@ARRL.ORG

It sure as heck seems that way Doug. Actually you can thank the fortunately for us now retired Bill Cross for this. He never understood the Symbol Rate Petition despite repeated efforts to explain it to him. He told me two years before this NPRM hit the streets and about six months before he retired that he had drafted an NPRM that eliminated the symbol rate limit but did not propose a maximum bandwidth on data emissions. It took the Wireless Bureau front office two years to make no changes to that proposal and to issue the darn thing. We took a huge amount of heat for our petition which did include a bandwidth limit. It will be interesting to see if there is that much opposition to the FCC proposal that does not contain one. 73, Chris W3KD On Mon, Aug 15, 2016 at 1:14 PM, Doug Rehman <doug@k4ac.com> wrote:

So is this a new FCC tactic to dissuade the filing of petitions?

Doug

K4AC

*From:* arrl-odv [mailto:arrl-odv-bounces@reflector.arrl.org] *On Behalf Of *Christopher Imlay *Sent:* Monday, August 15, 2016 1:10 PM *To:* Price, Brennan, N4QX <bprice@arrl.org> *Cc:* Frenaye, Tom, K1KI <frenaye@pcnet.com>; arrl-odv <arrl-odv@arrl.org> *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

_______________________________________________ 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

-- 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

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

______________________________ _________________ 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

_______________________________________________ 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

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

______________________________ _________________ arrl-odv mailing list arrl-odv@reflector.arrl.org https://reflector.arrl.org/ mailman/listinfo/arrl-odv <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 <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

_______________________________________________ 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

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] 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

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 W3KD@ARRL.ORG

_______________________________________________ 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

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

______________________________ _________________ arrl-odv mailing list arrl-odv@reflector.arrl.org https://reflector.arrl.org/ mailman/listinfo/arrl-odv <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 <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

_______________________________________________ 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

Kermit, I'll have to defer to Chris on the likelihood of the FCC moving toward some kind of limitation on this. The NPRM is discouraging, but the author of it has retired, so there's cause for hope. I do think the odds of FCC movement would be enhanced if most commenters would move toward one of ‎the two approaches. My sense is approach 1 is more likely to be adopted by the FCC, but approach 2 has more die-hard adherents. Chris may have a different view, to which I would defer. 73 de N4QX/VE2 Sent from my BlackBerry 10 smartphone on the Verizon Wireless 4G LTE network. From: Carlson, Kermit, W9XA (Dir, CL) Sent: Tuesday, August 16, 2016 18:46 To: Price, Brennan, N4QX; Norris, David, K5UZ; Pace, Jim, K7CEX Reply To: Carlson, Kermit, W9XA (Dir, CL) Cc: Frenaye, Tom, K1KI; arrl-odv Subject: Re: [arrl-odv:25590] Re: RM-11708 Hello Brennan; What is your estimate of the possibility that the Commission would move away from the no bandwidth limit and towards a limit of reasonable accord? (as in either #1 or #2 in your post) I do have experience operating MFSK at 2400 and 3200 (on MARS) and it is far superior in capability to most other data modes including the celebrated Pactor-4, and it would be of great advantage to be able to use new MFSK and Pactor on the amateur HF frequencies. But, unlimited means just that - and my concern is that unlimited bandwidth will be at the expense of CW on the low end of the band. I know the people in my Division who are worried about the no bandwidth restriction provision in the NPRM and I have every reason to believe that potential negative impact to CW operation is by far their largest concern. Up until now the symbol rate has effectively capped the practical bandwidth. Should there be no limitation on the symbol rate as well as no bandwidth limitation then large bandwidth signals will present a problem for operators who are working with signals near the noise floor. For this reason I really fear that the option #3 you describe has a significant chance of becoming the rule much to the detriment of CW QRP and CW weak signal DX activity. 73, Kermit W9XA ________________________________ From: "Price, Brennan, N4QX" <bprice@arrl.org> To: "Norris, David, K5UZ" <k5uz@suddenlink.net>; "Pace, Jim, K7CEX" <nwdvd@comcast.net> Cc: "Frenaye, Tom, K1KI" <frenaye@pcnet.com>; arrl-odv <arrl-odv@arrl.org> Sent: Tuesday, August 16, 2016 3:19 PM Subject: [arrl-odv:25590] Re: RM-11708 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<mailto: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] On Behalf Of Kermit Carlson via arrl-odv Sent: Tuesday, August 16, 2016 9:40 AM To: Christopher Imlay <w3kd.arrl@gmail.com<mailto:w3kd.arrl@gmail.com>>; Price, Brennan, N4QX <bprice@arrl.org<mailto:bprice@arrl.org>> Cc: Frenaye, Tom, K1KI <frenaye@pcnet.com<mailto:frenaye@pcnet.com>>; arrl-odv <arrl-odv@arrl.org<mailto: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<mailto:w3kd.arrl@gmail.com>> To: "Price, Brennan, N4QX" <bprice@arrl.org<mailto:bprice@arrl.org>> Cc: "Frenaye, Tom, K1KI" <frenaye@pcnet.com<mailto:frenaye@pcnet.com>>; arrl-odv <arrl-odv@arrl.org<mailto: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<mailto: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<mailto: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<mailto:arrl-odv@reflector.arrl.org> https://reflector.arrl.org/ mailman/listinfo/arrl-odv<https://reflector.arrl.org/mailman/listinfo/arrl-odv> ______________________________ _________________ arrl-odv mailing list arrl-odv@reflector.arrl.org<mailto:arrl-odv@reflector.arrl.org> https://reflector.arrl.org/ mailman/listinfo/arrl-odv<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<mailto:W3KD@ARRL.ORG> _______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org<mailto:arrl-odv@reflector.arrl.org> https://reflector.arrl.org/mailman/listinfo/arrl-odv _______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org<mailto:arrl-odv@reflector.arrl.org> https://reflector.arrl.org/mailman/listinfo/arrl-odv _______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org<mailto:arrl-odv@reflector.arrl.org> https://reflector.arrl.org/mailman/listinfo/arrl-odv

I tend to agree with the point Dir. Norton has made in past Board discussions on this subject. The rest of the Amateur Radio world (save USA and Japan) has essentially no regulatory restrictions on modes or bandwidth by sub-band, yet none of the dire predictions put forth by the opponents of our petition appear to have come true. Thus, while I readily admit to not being a spectrum or regulatory expert, it is not clear to me how passage of even the FCC’s current version of our proposal would spell the demise of CW or RTTY on our bands. 73, Marty N6VI From: arrl-odv [mailto: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; Price, Brennan, N4QX Cc: Frenaye, Tom, K1KI; arrl-odv 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 ______________________________ _________________ arrl-odv mailing list arrl-odv@reflector.arrl.org https://reflector.arrl.org/ mailman/listinfo/arrl-odv <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 <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 _______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org https://reflector.arrl.org/mailman/listinfo/arrl-odv

All, We also have a digital band plan as well. This has helped with many of the complainants in my part of the world. NB, TV and the small Henny Penny crowd will probably not be swayed by any rational arguments. However, as Brennan points out we do have various safeguards in place to prevent the doom NB is prophesying for the rational and willing to listen members. 73 David A. Norris, K5UZ Director, Delta Division Sent from my iPhone

On Aug 14, 2016, at 10:14 PM, Gallagher, Tom, NY2RF <tgallagher@arrl.org> wrote:

Tom: as you point out, N9NB's views are apparently entrenched, and they are widely disseminated. As Brennan has pointed out earlier, we already have a web posting http://www.arrl.org/rm-11708-faq

Short of conducting a PR war with him, which might be viewed as an ad hominem attack, I don't see the value in singling him out. Lots of people disagree with the League on a wide variety of topics I am learning and we might have to accept disagreement comes with the territory.

Brennan has scheduled a face-to-face meeting among the here of us later this month. Hopefully, while we may not persuade him to our point of view, we may be able to convince him to turn down the volume and allow the FCC process to take its course.

If you feel strongly to the contrary, call me when you can.

Tom G

-----Original Message----- From: arrl-odv [mailto:arrl-odv-bounces@reflector.arrl.org] On Behalf Of Frenaye, Tom, K1KI Sent: Sunday, August 14, 2016 4:45 PM To: arrl-odv <arrl-odv@arrl.org> 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

Bob et al., I have reached out to Ted on this and other issues in the past and recently. I'm visiting his lab at a time to be determined after he returns to NYU for another academic year. I'm not promising to turn him, but I am confident we will have a productive discussion on areas of mutual interest, including not only the symbol rate proceeding, but also the ongoing Spectrum Frontiers 5G initiative at the FCC and the corresponding WRC-19 agenda item. 47 GHz is within the boresight of the latter. We dodged a bullet in the former thanks in part to Ted's work on the millimeter waves and his belief that an amateur allocation within them is vital to their continued development. 73 de Brennan N4QX/VE3 Sent from my BlackBerry 10 smartphone on the Verizon Wireless 4G LTE network. Original Message From: Famiglio, Bob, K3RF Sent: Monday, August 15, 2016 11:31 To: Gallagher, Tom, NY2RF; Frenaye, Tom, K1KI Cc: arrl-odv Subject: [arrl-odv:25576] Re: RM-11708 I assume that someone has called Ted Rappaport, N9NB to at least chat about any common ground? I have known Ted for some years through Radio Club of America while he was on the board and I was VP & General Counsel. Bought him more than a few drinks over the years around the country with night-long BS sessions. He is very pro-amateur radio as many of you likely know. I would not claim we can persuade him, he thinks things through before taking a position. However, we might find common ground (like the limit on bandwidth) at least, and leave the amount of the limit to the FCC. That seems to be the plan I surmise. He is a brilliant engineer and professor. And he is rational of course. He is also good friends with Tim Duffy, K3LR, DX engineering CEO and our ARRL Western PA section manager. Ted works the K3LR multi-multi station for the contests. Tim is also president of RCA in which Ted, N9NB, was active for our youth education programs. Maybe Tim can provide us some insight as to approaching Ted. Somebody needs to buy Ted lunch and at least appreciate his position and see if there are opportunities to cooperate. Maybe someone has already? Bob Famiglio, K3RF Vice Director, ARRL Atlantic Division 610-359-7300 www.QRZ.com/db/K3RF -----Original Message----- From: arrl-odv [mailto:arrl-odv-bounces@reflector.arrl.org] On Behalf Of Gallagher, Tom, NY2RF Sent: Sunday, August 14, 2016 11:14 PM To: Frenaye, Tom, K1KI; arrl-odv Subject: [arrl-odv:25574] Re: RM-11708 Tom: as you point out, N9NB's views are apparently entrenched, and they are widely disseminated. As Brennan has pointed out earlier, we already have a web posting http://www.arrl.org/rm-11708-faq Short of conducting a PR war with him, which might be viewed as an ad hominem attack, I don't see the value in singling him out. Lots of people disagree with the League on a wide variety of topics I am learning and we might have to accept disagreement comes with the territory. Brennan has scheduled a face-to-face meeting among the here of us later this month. Hopefully, while we may not persuade him to our point of view, we may be able to convince him to turn down the volume and allow the FCC process to take its course. If you feel strongly to the contrary, call me when you can. Tom G -----Original Message----- From: arrl-odv [mailto:arrl-odv-bounces@reflector.arrl.org] On Behalf Of Frenaye, Tom, K1KI Sent: Sunday, August 14, 2016 4:45 PM To: arrl-odv <arrl-odv@arrl.org> 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 _______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org https://reflector.arrl.org/mailman/listinfo/arrl-odv

Roger on all. I did NOT want to contact him in the blind, as I suspected you or someone at HQ likely thought of this already. I don't necessarily have a special relationship, but have had long face to face discussions about ham radio with him on many different occasions at RCA functions over the years. I'll talk with Tim Duffy first. I do not want to inject conflicting information. And I think your face to face will be productive-sorry I did not recall that was already planned. There may be room to agree somewhere, including just his level of criticism. Also, as you likely know, he is a BIG CW op. Thanks to Brennan and you both for a reply. Bob Famiglio, K3RF Vice Director, ARRL Atlantic Division 610-359-7300 www.QRZ.com/db/K3RF -----Original Message----- From: Gallagher, Tom, NY2RF [mailto:tgallagher@arrl.org] Sent: Monday, August 15, 2016 11:52 AM To: Famiglio, Bob, K3RF; Frenaye, Tom, K1KI Cc: arrl-odv Subject: RE: [arrl-odv:25574] Re: RM-11708 Bob: two weeks ago, Brennan and I scheduled a meeting face-to-face with Dr. Rappaport at his office at NYU. He was unable to see us immediately I suspect because he is busy getting ready for the fall semester. Brennan made the appointment for the end of August. As I have recounted on a couple of occasions, our objective in meeting with Rappaport--other than to pay special deference to him--was to persuade him to turn down the volume of his comments. We don't believe that we can actually change his views. If, however, you have a special relationship with him, then perhaps you wish to approach him directly. Perhaps you can be more persuasive than either of us. Note that as I am writing this email that Brennan has responded as well on ODV, reiterating what I have just said. 73, Tom -----Original Message----- From: Famiglio, Bob, K3RF Sent: Monday, August 15, 2016 11:32 AM To: Gallagher, Tom, NY2RF <tgallagher@arrl.org>; Frenaye, Tom, K1KI <frenaye@pcnet.com> Cc: arrl-odv <arrl-odv@arrl.org> Subject: RE: [arrl-odv:25574] Re: RM-11708 I assume that someone has called Ted Rappaport, N9NB to at least chat about any common ground? I have known Ted for some years through Radio Club of America while he was on the board and I was VP & General Counsel. Bought him more than a few drinks over the years around the country with night-long BS sessions. He is very pro-amateur radio as many of you likely know. I would not claim we can persuade him, he thinks things through before taking a position. However, we might find common ground (like the limit on bandwidth) at least, and leave the amount of the limit to the FCC. That seems to be the plan I surmise. He is a brilliant engineer and professor. And he is rational of course. He is also good friends with Tim Duffy, K3LR, DX engineering CEO and our ARRL Western PA section manager. Ted works the K3LR multi-multi station for the contests. Tim is also president of RCA in which Ted, N9NB, was active for our youth education programs. Maybe Tim can provide us some insight as to approaching Ted. Somebody needs to buy Ted lunch and at least appreciate his position and see if there are opportunities to cooperate. Maybe someone has already? Bob Famiglio, K3RF Vice Director, ARRL Atlantic Division 610-359-7300 www.QRZ.com/db/K3RF -----Original Message----- From: arrl-odv [mailto:arrl-odv-bounces@reflector.arrl.org] On Behalf Of Gallagher, Tom, NY2RF Sent: Sunday, August 14, 2016 11:14 PM To: Frenaye, Tom, K1KI; arrl-odv Subject: [arrl-odv:25574] Re: RM-11708 Tom: as you point out, N9NB's views are apparently entrenched, and they are widely disseminated. As Brennan has pointed out earlier, we already have a web posting http://www.arrl.org/rm-11708-faq Short of conducting a PR war with him, which might be viewed as an ad hominem attack, I don't see the value in singling him out. Lots of people disagree with the League on a wide variety of topics I am learning and we might have to accept disagreement comes with the territory. Brennan has scheduled a face-to-face meeting among the here of us later this month. Hopefully, while we may not persuade him to our point of view, we may be able to convince him to turn down the volume and allow the FCC process to take its course. If you feel strongly to the contrary, call me when you can. Tom G -----Original Message----- From: arrl-odv [mailto:arrl-odv-bounces@reflector.arrl.org] On Behalf Of Frenaye, Tom, K1KI Sent: Sunday, August 14, 2016 4:45 PM To: arrl-odv <arrl-odv@arrl.org> 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