Here is a leaked message from Ron Kolarik, K0IDT, sent to me by one of my digital guys in the Division. At least Kolarik's expectations from the Band Planning committee are low! ;-) 73; Mike W7VO

-------- Forwarded Message -------- Subject: [RTTY] Comments needed on FCC 16-239 Date: Thu, 07 Nov 2019 20:59:06 -0800 From: Ron K0IDT <rkolarik@neb.rr.com> mailto:rkolarik@neb.rr.com To: RTTY@groups.io mailto:RTTY@groups.io

The FCC has filed a new Public Notice concerning WT Docket 16-239 https://ecfsapi.fcc.gov/file/1101131173138/DA-19-1130A1.pdf

For those of you that don't know, or may have forgotten, 16-239 is the result of ARRL filing RM-11708, removing the 300 baud rate restriction. The FCC came up with 16-239, it removes the baud limit and allows wideband (unlimited) digital signals anywhere in the HF RTTY/Data sub bands. Despite claims that wideband digital will not overrun the narrow band users, RTTY, CW, JT/FT, etc., there is no provision to keep the wider signals in check. The new FCC Public Notice is seeking comments on a Declaratory Ruling on Part 97.113(a)(4) and enactment of RM-11831 provisions for transmission transparency, i.e, all amateur digital transmissions must be openly decodable over the air by anyone hearing them.

You may ignore this next part if you wish, it contains the Winlink word. ARSFI (Amateur Radio Safety Foundation Inc) / Winlink decided RM-11831, and this latest FCC notice were all about them. The beginnings of the push for the baud limit removal go back 15 years or so to RM-11306. RM-11306 was the disastrous ARRL petition that would have allowed wide digital, including unattended stations, anywhere in the amateur spectrum. Fast forward to 2013 and we got RM-11708, baud rate limit gone and wideband allowed anywhere in the RTTY/Data sub bands--wideband digital is currently allowed anywhere in that segment and is exploited by some current users connecting to off shore Winlink gateways with wider modes. If 16-239 passes as written expect to hear some new wide modes running all over the sub band with Winlink being the one group looking to expand their operations. Just recently one Winlink gateway decided it was a good idea to set up on 3510......cw guys aren't safe in this.

The 300 baud limit needs to go away but at the same time some sanity needs to be brought into the process as to where and how wideband digital is going to fit in. The ARRL is supposed to be coming up with a new band plan, but after their last FCC submission, where what the Board requested and what actually got filed at the Commission was significantly different, I don't look for anything worthwhile coming out of the band planning committee.

Comments are to be submitted on 16-239, read the FCC Notice, and instructions on how to file can be found onhttp://www.rttycontesting.com (top link, thanks Don for keeping that alive) and also on http://www.wirelessgirl.net/HowToFile16239STD.html Please use your own wording, there are a couple of great examples on the ECFS already. One that really hits the points extremely well is https://ecfsapi.fcc.gov/file/1103182882861/KC4RAN%20DA%2019-1130%2011-02-201... December 2 is the deadline for comments.

Feel free to cross post wherever you think it might help.I only wish AB5K could see how far we've come with this,,,,,,,,

Ron K0IDT