The following was posted to the CWOps’ mailing list yesterday by Dan, W5DNT. I don’t know all the ins and outs of this issue, but it doesn’t seem like a good thing to me to allow wideband transmissions in portions of the HF bands currently being used for narrowband communications, such as CW, FT8, and other digital modes…..Dan
The FCC has opened a new proceeding, PSHSB 17-344, seeking input to improve future disaster response based on lessons learned in the recent Puerto Rico hurricane disaster. The FCC intends this proceeding to benefit a broad range of subjects, including commercial radio/TV broadcasting, internet, mobile wireless, and other telecommunications. Three filings were about amateur radio, which was a very small paragraph in the FCC request for comment.
Alarmingly, two of the three filers it would appear simply cannot “let a good crisis go to waste” and chose to promote their own special interest agenda. ARRL chose to opportunistically file a lengthy document that uses the Puerto Rico crisis as a segue into both the need for FCC approval of wide band digital (PACTOR 4) in the HF bands and the need to have their much touted “Amateur Radio Parity Act” (the Antenna Bill) approved by Congress. The WINLINK CEO Steve Waterman chose to use the crisis to opportunistically re-open the concept of wide band digital (PACTOR 4) as a seemingly universal answer to emergency communications needs. The comments from ARRL and WinLink CEO Steve Waterman, K4CJX are linked here, read them for yourself. Also included below are the comments of Timothy Moloney, N9RRM, who was on the ground in Puerto Rico.
Here are the filings:
- Steve Waterman, K4CJX, WINLINK CEO
- ARRL comments (skip all the history and read from page 33 on)
- Comment of Timothy Moloney, N9RRM, an actual ham deployed to Puerto Rico (great work!)
While the actual comment period is now over, by ARRL and Waterman both re-opening the Wide Band Digital (PACTOR 4) and ARRL re-opening the Amateur Radio Parity Act, the public is now able to counter these comments with “Reply to Comment” filings until February 21, 2018.
If enacted as the ARRL suggests,WT 16-239, which was a direct result of ARRL’s RM-11708 a few years back, would allow wide band digital signals with no bandwidth limitations, to disrupt the CW, RTTY, PSK, JT-65, FT-8 narrowband portions of our amateur bands. We feel very strongly that comments need to be filed to counter the ARRL and communicate to the FCC the extremely negative impacts such regulations would have on existing narrowband operations.
Furthermore, those of us that feel strongly that the Amateur Radio Parity Act is a bad deal, favoring HOA’s and allowing them the opportunity, by law, to decide whether or not an antenna system is aesthetically appropriate can also take this same opportunity to have their views heard by the FCC.
We urge you to take the time to voice your concerns to the FCC. Otherwise, the FCC may think ARRL is representing you. In this case, we strongly feel it is NOT!
FILE YOUR FCC “REPLY TO COMMENTS” ON PSHSB 17-344, STARTING ON MONDAY JANUARY 29, 2018.
The deadline is February 21st, 2018!
To stop PSHSB 17-344, you must file “reply” comments, urging the FCC to:
- DISMISS EXISTING RM-11708 and FCC WT 16-239.
- Not endorse the Amateur Radio Parity Act now in Congress.
- If you are able to provide factual personal experience (not “hearsay” that you heard from someone else), please add it to your comments, as did others who were in Puerto Rico at the time.
- DO NOT do anything that minimizes the great work individual hams did in Puerto Rico or anywhere else. Simply state the facts, as gathered from public records or first hand accounts. Show the ARRL statement; then put the contradicting evidence next to it and compare.
- BE FACTUAL, CIVIL, BUSINESSLIKE, AND CONCISE. Remember, your comments will be available on line for a very long time. Be constructive and positive.
IF YOU ARE READY TO COMMENT, click here to go to the appropriate FCC web page.
You are responding to the FCC question: “To what extent were response efforts facilitated by amateur radio operators? Going forward, should efforts be made to increase the use of amateur radio services in connection with the planning, testing and provision of emergency response and recovery communications?” Remember this question as you reply to ARRL or Waterman comments. That is the ONLY thing the FCC and Homeland Security want to hear. The ARRL and Waterman comments ask for immediate WT 16-239 enactment supposedly to “increase the use of amateur radio services”, without regard for dissenting comments.
Once you have your thoughts completely organized, you are ready to file a REPLY comment on 17-344. You can do this on a piece of scratch paper with an outline to enter an express comment, or generate a .txt or .pdf file with your word processor and cut and paste it into the window in the form later. But do not start this until your comments are completely ready.
Look along the top dark blue task bar of the displayed FCC web page. Find the area that says: “Submit a FILING”. CLICK on it. Just below that dark blue line is a light blue line that has the option of a “standard” or “express” filing. With a standard filing, you will be uploading a PDF file of your reply. With express, you will be typing BRIEF comments into a box on the form.
Once selected, the page will take you to a form to enter your contact information. FCC needs that info to contact you in case of problems with your filing or to let you know it has been received. Your email address will NOT appear publicly in the comments, unless you type it into your comment window.
First, you will have to fill in the designator of the filing in the top box. Click in the area where it says Proceeding(s). Type in “17-344” (without quotes) and press ENTER. As you type, you will see a drop-down of open actions. Ignore them, unless they offer “17-344 Hurricane Response”. You will know you did it right when it says “17-344” in a yellow box. If it does NOT say 17-344, click on the “X” in the upper right hand corner of the yellow box and try again. There are other filings in the drop down that are NOT related to amateur radio at all; if you misfile under the wrong proceeding, you will not be counted! Again, ONLY type in “17-344” nothing else (no quotes when you type it in). Press ENTER. It will light up yellow with “17-344” if you did it correctly.
Below that, enter YOUR NAME in the NAMES OF FILER area. Failure to enter a valid name will result in your filing being discarded. Do not enter anything but YOUR NAME here. DO NOT enter anything else here, such as the 17-344 number. VERY IMPORTANT: PRESS ENTER KEY, AFTER EACH ITEM YOU ENTER IN THIS PART OF THE PROCESS! Your name is now entered in yellow highlight as before. This indicates the system accepted that entry.
Skip the Law Firm and Author boxes, unless you are a lawyer.
Below that, enter your email exactly as “[email protected]” or .net, whatever your full email address is. Your email will NOT be entered in public record, but it can be used by the FCC to contact you to verify your filing has been accepted. This one will not turn yellow. Just click on the next item in the list. Later, you will check a box that sends a confirmation email from the FCC to that email address, within a few minutes. YOUR COMMENT WILL APPEAR THE NEXT BUSINESS DAY. Do NOT go back to the database and look for your comment and file again, if you got an email that says they took it, wait till tomorrow to look for it.
After the email entry, you will be offered a choice of which type of communication you wish to send to the FCC. DO NOT select “COMMENT” since that time has expired and it will be ignored. Click on the arrow on the right hand side of the small window. A drop down menu will appear. Click on “REPLY TO COMMENTS”. That will appear in the small window. You will not need to press enter for this one. This window will not turn yellow. Then move down to the next small window below it. You will enter the target comment to which you wish to reply. NOTE: You can reply to multiple comments (even better) but you must do this process for EACH reply. Here is the simplest procedure:
In a “reply to comments”, you must choose an existing target comment to reply TO. To reply to the ARRL comments, click here.
To reply to the Waterman comments, click here. Remember, YOU CANNOT reply to multiple commenters at the same time, separate filings are required.
The next window down “ADDRESS OF” has an arrow pointing down on the right hand side. They want to know WHOSE address it is, filer, author, law firm. Select “FILER”. That’s you. If you are a lawyer, click on that one.
Click in the Address window. Your cursor should be at the beginning of the blank area for address. Type your street address there. Use Number, street, apartment format. You MUST enter a STREET address to file, it is a required field. That address will appear in the FCC data base. Not to worry. Your amateur license also lists that. If you use your call sign, people can track you that way. This is a public record.
DO NOT CLICK the “international” checkbox, unless you are outside the US.
Move down on the page and CLICK in CITY window to position your blinking cursor there. Type in your city.
Move down to STATE and CLICK in the open area. A list will drop down. Scroll to your state. CLICK on your state. The form now should have your state.
Move down to ZIP and click there. Type in your zip code, 5 digits.
ALMOST DONE! First be sure all blank areas on the form which have a “*” are filled in. The FCC system will NOT accept any filings that do not have that information.
Foe express, in the Brief Comments area type in your brief comments. At the top of your filing be CERTAIN you have “PSHSB 17-344”. You must use these quotes specifically! For standard, please upload your file in the upload box. Please make sure your file has “PSHSB 17-344” in the title and include your name.
IMPORTANT: Use polite respectful language that is brief and to the point. You are addressing the FCC here, not the filer.
At the end of the filing, state your name, CALLSIGN (THIS IS VERY IMPORTANT), and if you are an ARRL member and if so, for how long. This identifies you as one with a legitimate interest in the filing, not some internet troll.
CLICK ON THE CHECKBOX “EMAIL CONFIRMATION”. You will receive an email confirmation that your filing has been accepted in only minutes. That is why you entered your email earlier. Your email will not be shared for any other purpose. NO SPAM will happen. Your filing will appear on the FCC site within a couple days.
When you are satisifed with every item of information on this page, CLICK ON “CONTINUE TO REVIEW SCREEN”.
If all is well, you will be asked to confirm that everything is correct, and you can click on SUBMIT BUTTON and it will all go to the FCC. IMPORTANT! WAIT! The FCC system is digesting your information and checking it. Nothing will appear to be happening. Eventually, a confirmation of acceptance will appear on your screen, in about a minute. If anything is missing, you will be directed to fix that first. Do NOT file repeated duplicates of your filing. All of them may be ignored. IF you do not WAIT as directed, but keep repeatedly clicking on SUBMIT, multiple filings will result. If you immediately check the FCC website, your comment WILL NOT BE THERE right away. Your filing will appear on the FCC site within a couple days.
Wait until FCC shows you a page with a confirmation number. Print it if you like. Then FCC sends you “confirming acceptance” email if you checked the box I told you to mark.
THANK YOU FOR FILING A REPLY COMMENT!
Dave New, N8SBE says
We already have 2.8 kHz-wide transmissions in the CW/data portions of our bands. RM-11708 would only delete an obsolete symbol rate limitation that doesn’t make sense any more. The ARRL has an FAQ which I think does a good job of explaining what RM-11708 would do and what it wouldn’t do:
http://www.arrl.org/rm-11708-faq
The operator that was deployed to Puerto Rico seems mistaken about one large item. He seems to think that VHF systems have better coverage then UHF. That simply isn’t true, and my own experience bears this out. But you don’t have to take my word for it, just ask the numerous repeater owner/operators in the SE Michigan area. The UHF machines around here beat the VHF ones essentially hands down for coverage, often using the same towers and height as their VHF counterparts. It simply penetrates buildings, etc. better, and the shorter wavelength has better diffractive fringing around solid objects.
In fact, the ‘sweet’ spot is the 700-800 MHz band, which hams don’t have access to, but various cellphone services are vying for access to those frequencies because of their propagation characteristics.
Lastly, I really don’t feel too strongly about the Parity Act. In particular I don’t believe that the ARRL colluded with the HOA to sell us out, that many have accused them of. The Parity Act is the result of many long hours of negotiating, something that has apparently been lost on the current general public, as well as our esteemed Congress. It seems these days that everything must be taken in black or white, with any ‘give’ on the part of either party seen as a sign of weakness not to be exposed under any circumstances.
“Outrage” is the new norm, and I don’t much care for it. The CWops posting reeks of outrage and editorialism.
Ron Kolarik K0IDT says
Dave you should be outraged over the attempt by ARRL and Winlink to advance an agenda on the back of a real disaster.
The symbol rate elimination in RM-11708 only applies to HF and the only purpose is to
legalize Pactor 4 for a small group dedicated to providing email on HF. If that isn’t a fact then why not propose baud rate elimination on the bands above HF? The FAQ ARRL was
produced well after RM-11708 hit the FCC along with the “new” band plan and the full
text of the RM wasn’t made available to membership prior to that. The ARRL had to amend it once it was in the system, what they deemed a “clerical error”.
Your claim that UHF is better than VHF may hold true in your area but the guy linked was on the ground and had direct connection with the environmental operating conditions. War zone comes close to what he had to deal with.
You should be outraged the ARRL failed to listen to it’s membership on the earlier RM-11306 and had no member input on RM-11708. RM-11708 has morphed in to WT 16-239 which is far worse than the original proposal.
Just a hint but this whole mess isn’t about emcomm.
Brennan Price N4QX says
Ron, the ARRL petition does seek to eliminate the symbol rate restriction on all bands above HF (where one exists). To claim otherwise is simply not correct.
Ron Kolarik K0IDT says
Thanks for the correction Brennan, indeed the symbol rate is removed entirely.
Somehow it stuck in my head it was HF only since that was what it was focused
on and most of the in favor comments only wanted P4 for HF email.
Janis Carson AB2RA says
Dave New, N8SBE
He has it right about the use of VHF and UHF. There will
probably be a lot of information coming out from Puerto Rico. Some of
it will be anecdotal experience. Not everything goes according to plan.
That is why we call it a disaster. We should thank everyone who deployed. They did a great job. It is one of amateur radio’s finest gifts back for the public good.
But he gets it all wrong on RM-11708. He relies on obsolete information on the ARRL website. This information was for RM-11708 BEFORE the FCC decided to abolish all band width specifications in the HF spectrum, while allowing only 20 KHz band width at VHF and 100 KHz at UHF. This is the actual Notice of Proposed Rule making that will be enacted as a Report and Order if ARRL and Waterman have their way.
Honest mistake on his part. So lets do some fact checking.
“We already have 2.8 kHz-wide transmissions in the CW/data portions of our bands. RM-11708 would only delete an obsolete symbol rate
limitation that doesn’t make sense any more.” The ARRL has an FAQ
which I think does a good job of explaining what RM-11708 would
do and what it wouldn’t do: http://www.arrl.org/rm-11708-faq
Which says:
“The petition proposes to substitute a bandwidth limit of 2.8 kHz
for the symbol rate limits”
>But the FCC’s 16-239 abolishes all band width limits on HF.
“It accommodates the digital data modes that are now in widespread
use while limiting future development to the bandwidth of an SSB
transceiver.”
>But with new SDR radios, ANY band width is possible. For instance,
24 KHz wide STANAG mode delivers internet at old fashioned dial up speeds.
“Does the proposed revision permit wider use of automatically controlled
digital stations?-
No. Section 97.221 would remain unchanged.”
>But 97.221 C would be irrelevant if WT 16-239 allows unlimited band width transmissions *anywhere* in the CW/DATA segment, not just the ACDS.
“Does the proposal expand the frequencies on which unspecified digital
codes may be used?-
No, although an error in the original ARRL filing suggested
otherwise. As soon as it was discovered, this was corrected
through the filing of an erratum.”
>But not quite true. The proposal doesn’t exactly, but the FCC Notice of Proposed rule making, WT 16-239 certainly *DOES*. And ARRL is perfectly OK with that. Proof coming, not “alternative facts.”
“Did ARRL evaluate the potential for interference to RTTY,
CW and narrow bandwidth data modes that could result from an
increase in wider-bandwidth data stations? –
Yes. Data emissions, both narrow and wide bandwidth, are permitted
now throughout the data/RTTY sub-bands including the parts where CW operation takes place… If there is an overall increase in data operation in the data/RTTY subbands as the result of eliminating the symbol rate limit, that outcome can and should be accommodated by band planning and cooperative sharing arrangements that hams have always been urged to use.”
>Actually, they DID evaluate it, and decided to go ahead anyway.
The truth came out finally in their reply comments to the FCC wt 16-239:
PAGE 6 ITEM 9:
“Notwithstanding any of the foregoing, those who either opposed deletion of the symbol rate limit or supported that deletion but opposed the ARRL’s proposed 2.8 kilohertz maximum bandwidth for locally and remotely controlled data emissions in the MF and HF bands have a very valid concern that absolutely must be addressed.”
“They collectively express a predictive, unquantified fear that an increase in the number of data emissions in the RTTY/data subbands will create new incompatibility 13 between data emissions and ongoing CW, RTTY and narrow bandwidth data modes (such as PSK-31) that are and have long been popular in the low ends of MF and HF bands. This concern must be addressed.”
END OF PAGE 7:
“Had the Commission proposed to enact both of the proposals in ARRL’s Petition
rather than just one, the fears expressed by these commenters would be overstated.
As it is, those fears might well be realized.”
ARRL PAGE 14 & 15, ITEM18:
“In the specific context of the admixture of data and other modes in the HF and MF bands, reliance solely on voluntary band planning is expecting quite a lot.”
“(3) …precluding the use of data emissions in the HF RTTY/data subbands that would
utilize too large anoccupied bandwidth and thus usurp the limited spectrum available
for sharing with incumbents and future users of dissimilar emissions. Because of this last goal, ARRL strongly disagrees with the Commission’s tentative conclusion that elimination of the symbol rate limit should be accomplished without adding any maximum bandwidth limitation. There must be some limit on occupied bandwidth for data emissions at MF and HF.”
>EXECUTIVE SUMMARY OF ABOVE: The prospect of CW and other narrow band modes such as CW and FT-8 IS JUSTIFIED by ARRL’s own admission. Reliance on “VOLUNTARY band plans is asking a lot”.
>FOR FULL DETAILS SEE MY ARRL REBUTTAL AT FCC SITE:
https://ecfsapi.fcc.gov/file/11091541913133/FCC%20WT%2016-239%20ARRL%20reply.pdf
>HERE IS THE PROBLEM: The FCC in a subsequent Notice of Proposed Rule Making (NPRM) abolished ALL BAND WIDTH LIMITS instead of even going with the ARRL 2.8 KHz rule. Here are quotes from FCC WT 16-239 NPRM:
https://ecfsapi.fcc.gov/file/0728122180423/FCC-16-96A1.pdf
10. After reviewing the record, we tentatively conclude that a specific
*bandwidth limitation* for RTTY and data emissions in the MF/HF bands is *not necessary*.
IV. CONCLUSION
13. In summary, we believe that the public interest may be served
by revising the amateur service rules to eliminate the current baud
rate limitations for data emissions consistent with ARRLs
Petition to allow amateur service licensees to use modern digital
emissions, thereby furthering the purposes of the amateur service and
enhancing the usefulness of the service. We do not, however, propose
a bandwidth limitation for data emissions in the MF and HF bands to
replace the baud rate limitations, because the rules current approach
for limiting bandwidth use by amateur stations using one
of the specified digital codes to encode the signal being transmitted
appears sufficient to ensure that general access to the band by
licensees in the amateur service does not become unduly impaired.
>That is bad enough, but check out the Appendix:
APPENDIX
97.305 Authorized emission types:
3. Section 97.307 is amended by reserving paragraph (f)(4) and revising paragraphs (f)(3), (5),
and (6) to read as follows: 97.307 Emission standards.
* * * * *
(f) * * *
(3) Only a RTTY or data emission using a specified digital code
listed in 97.309(a) of this part may be transmitted.
(4) [Reserved]
(5) A RTTY, data or multiplexed emission using a specified digital
code listed in 97.309(a) of this part may be transmitted. A RTTY, data or multiplexed emission using an unspecified digital code under the limitations listed in 97.309(b) of this part also may be transmitted, provided the bandwidth does not exceed 20 kHz.
(6) A RTTY, data or multiplexed emission using a specified digital code listed in 97.309(a) of this part may be transmitted. A RTTY, data or multiplexed emission using an unspecified digital code
under the limitations listed in 97.309(b) of this part also may be
transmitted, provided the bandwidth does not exceed 100 kHz.
* * * * *
>WHY THIS LEGALSPEAK IS IMPORTANT:
The HF band width limit is ****** or NONE.
The VHF limit is 20 KHz.
The UHF limit is 100 KHz.
The entire cumulative HF spectrum is smaller than 6 or 2 meters.
DOES THIS MAKE ANY SENSE TO YOU? ARRL IS PERFECTLY OK WITH IT!
AND THEY ARE NOW ASKING IN 17-344 TO ENACT IT IMMEDIATELY WITHOUT
CONSIDERING ALL OUR PREVIOUS OBJECTIONS!
MORE FACTS:
>MY REPLY FILING, pointing out the inconsistencies and consequences of the NPRM WT 16-239:
https://ecfsapi.fcc.gov/file/1005214251324/FCC%2016-239%20DISMISSorSTAY1.pdf
>MY FILING, encouraging adoption of the published ARRL band plan into Part 97 and continuing to contain ACDS “robots” of ANY band width to certain segments specified in the ARRL’s own band plan (because ARRL admits Voluntary band Planning is “asking a lot”:
https://ecfsapi.fcc.gov/file/109011952607702/FCC%20FILING%20docket%2016%20239%20FINAL10%20%20rm11708.pdf
>So back to the the ARRL information on RM-11708.
>Lets take an example of information ARRK has. I will refer you to the Winlink claim on theirweb page, which directs you to the ARRL page,
the Bounty ship sinking:
https://www.winlink.org/tags/hms_bounty
http://www.arrl.org/news/robin-walbridge-kd4ohz-missing-at-sea-after-sinking-of-tall-ship-em-bounty-em-ship-s-electrician-dou
>I took the time to research this, after I saw another comment on it:
http://wireless-girl.com/BOUNTYcomments.html
>My research document has clips from the actual Coast Guard hearing and web site, for instance:
“Currently the U.S. Coast Guard email system is not set up to accept or
respond to emergency SAR messages. If you are in distress or need to
report an emergency, do *NOT send it via email*, contact the Coast Guard via telephone or radio.”
New working link, the one in my article was before USCG changed their web site:
http://www.dco.uscg.mil/Our-Organization/Assistant-Commandant-for-Response-Policy-CG-5R/Office-of-Incident-Management-Preparedness-CG-5RI/US-Coast-Guard-Office-of-Search-and-Rescue-CG-SAR/Contact-USCG-SAR/
>Is this “FAKE NEWS?” You decide, based on the Coast Guard hearings.
>So is CWOPS justified in pointing out what is going on?
If you use CW or narrow band data like FT-8, you should be
*thanking them*, and doing what you can to undo this dumpster fire.
>Why people are upset:
FILING BY RANDAL EVANS IN RM-11708:
https://ecfsapi.fcc.gov/file/7521315143.pdf
“I have experienced very dependable service from the amateur radio Internet Winlink system. Its a great service because all of the other available Internet services cost money. Even when I am topside crusing the system runs automatically below deck publishing my position reports and downloading my email. I use the system for
sending position reports, ordering supplies, repairs, chatting with friends and posting to facebook….I am not a amateur radio operator yet but a friend lets me use his call with a SIDD on the end….I’m for passing RM-11708 into law with no bandwdith limits.”
>Which is exactly what ARRL wants and FCC did, and will enact that
in a Report and Order as a result of ARRL’s filing on 17-344 about Puerto Rico. Never let a good crisis go to waste? Think about it.
>OBVIOUS UNLICENSED OPERATION, COMMERCIAL USE OF
AMATEUR RADIO FOR THE BUSINESS OF HIS BOAT, USE OF AMATEUR RADIO FREE WINLINK EMAIL AS A SUBSITUTE
FOR VALID COMMERCIAL PROVIDER, SAIL MAIL. AUTOMATICALLY RUNS BELOW DECK, NO “LISTEN BEFORE TRANSMIT”.
WINLINK IS *NOT* FOR EMCOMM, IT IS FOR YACHTS.
Read the origins of Winlink in the New York Times:
http://www.nytimes.com/2001/11/22/technology/radio-e-mail-connects-ships-to-shore.html
>Yeah, its all in caps. Nobody listens any more unless you are yelling.
That is why everybody yells. I wish it were different, and we could just all get along. When somebody is messing with your stuff, you get upset.
>DISCLAIMER: I am not a member of CWOPS. Would like to be.
I am a member of SKCC and FISTS.
I am a member of ARRL more than 40 years.
I was first licensed in 1959, and hold a coded Extra taken before an
FCC examiner in Buffalo.
I am a VE. I taught many licensing classes.
I love ham radio, and do not want to see it end this way.
73
Janis Carson AB2RA
Bob Collins, N8IZN says
I’ll add my axe to grind. Allowing or even encouraging proprietary protocols (like PACTOR IV) on amateur radio is in direct conflict with the experimental goals of the service. Why should encryption be banned and proprietary protocols be acceptable?
Dan White says
Hi Dave N8SBE,
With regard to ARPA and collusion, are you aware the HOA lobbyist group drafted the final language? They must be doing cartwheels! If approved, HOA’s will have standing under Federal law to determine the aesthetics of amateur antenna systems. That’s not “outrage and editorialism”, just plain facts. I will however agree it has many amateurs outraged.
As for the WINLINK issue, you are correct that we do now have wideband digital already in the HF CW & RTTY sub bands. Illegal ACDS email servers!! A number of Automatically Controlled Data Stations, automated email servers heavily used by the yachting community to circumvent commercial maritime internet services, have been documented operating illegally outside of the Part 97.221 ACDS sub bands. Part 97.221 specifically prohibits such operation in excess of 500 Hz. The WINLINK community is well aware of the issue, but does not appear to like to openly talk about it.
RM-11708, which gave absolutely zero consideration to potential interference issues with existing narrow band CW, RTTY, JT-65, PSK and now FT-8 users, was an egregious proposal to lay claim to the entire narrow band segments. It asked for a 2.8 KHz bandwidth limit. One can only imagine how many narrow band users would be covered up by one of these PACTOR 4 stations firing up. Several friends, myself included, have lost DXCC Challenge “band slots” with extremely rare DXpeditions because one of these noise generators fired up on top of the DX station, thus drowning it out with hash.
It appears to me that ARRL has again tried the same failed approach it used with RM-11306 years back, which targeted SSB frequencies with wide band digital. As we know, that turned into a real mess and was in the eyes of many an embarrassment to the ARRL in the end when it was withdrawn. Perhaps they figured on less resistance from the narrow band folks and simply tried to repackage the proposal, this time targeting narrow band segments. As you say, MANY narrow band advocates filed comments against RM-11708. Most of the comments filed were against RM-11708, even when including the sub-rosa campaign early on by yachters to stack the filings with comments in favor. The filing time stamps do not lie and most of the initial filings were verbatim from a “sailing forum”. They were clearly given an informational edge over the rest of us in the beginning. Could that be a result of ARRL’s close ties and Memorandum of Understanding with the United States Power Squadrons, a boating organization? When comments were finally filed for NPRM 16-239, over 92% were against!
GREED is the problem! I simply cannot understand why did ARRL had to ask for ALL the non-phone bands when they already had the Part 97.221 ACDS sub bands. That would have solved the whole problem. Put PACTOR 4 there, no problem with interference. Personally, I could care less what WINLINKers, cheap yachtsmen unwilling to pay for commercial internet service, EMCOMers, off the grid preppers, PACTOR ops, etc. do with the Part 97.221 sub bands, but wide band intrusion into the existing traditional narrow band areas is totally unacceptable to most CW and RTTY enthusiasts that understand the smoke and mirrors being proposed by RM-11708. When proponents make the claim that PACTOR 4 and other wide band modes are legal most places except the USA, they seem to always fail to mention that legality only applies to the ACDS sub bands, not the entire non-phone bands.
One can’t discuss these wide band digital modes without touching on encryption. The modes we are talking about have proprietary code, meaning they are encrypted. Even the Official Observers are not sure what to do about these PACTOR stations. While the EMCOM crowd feels the need to have a mode that protects HIPPA medical information, such purpose is absolutely counter to amateur radio, which is ALWAYS intended to be open, in the clear communications, for obvious reasons. What better system for a terrorist to have than a PACTOR 4 modem and someone else’s callsign to plug into the system, as is being already done particularly in the yachting community. Such encryption should be a major concern to Homeland Security, hello!!!
Busy detectors are more often than not disabled by many WINLINK users. They seem to care less and feel they have a “deed” to their frequency. Wrong, they do not! Busy detectors should be mandatory!
To make this whole mess MUCH worse, upon FCC review, the 2.8 KHz bandwidth limit was removed and WT 16-239 was born! This unintended consequence is absolutely catastrophic for narrow band modes! I think this is one area we can agree on. The proposed 16-239 FCC language will result in major interference, any way one looks at it, period.
By the way, I am not a league basher, rather a major financial contributor and member of ARRL’s Maxim Society. With both ARPA and RM-11708, I strongly feel the ARRL is not properly representing my interests. This has been communicated directly to them, privately at first, now publicly. Both issues must be stopped before they do permanent harm to our hobby!
73
Dan
W5DNT
Brian says
Well put Dan. In recent conversations with NY2RF, he point blank had said that the ARRL’s focus is to satisfy those who give the league money. His resignation speaks for itself.
Elwood Downey says
A sane reply Dave, thank you.
Steve C - KE8HXM says
Regarding the HOA sponsored legislation being considered in the Amateur Radio Parity Act of 2017.12 – H.R. 555 , and it’s counterpart in the Senate, SB 1534, I see the word “reasonable” being used to describe restrictions that can – and I believe will – be enacted by the people who are the least concerned with amateur radio operator’s rights. The “reasonable” part of this is very subjective and relies too much on the HOA point of view.
The HOA lobby, that sponsored this bill, has been in favor of this “parity” concerning antennas used by radio amateurs but their considerations are only with their judgment of what is an aesthetically pleasing radio antenna. Allowing a powerful industry lobby to dictate to amateur radio operators what they can and can’t deploy outside the home is a lot like giving all the power and authority to the HOAs.
Under the language in this proposed legislation, the HOA gets to specify the configuration of antennas without regard for their functionality, and it is broad enough to allow the HOAs to use these rules to effectively ban the use of outdoor antennas by setting the parameters in such a way that it renders the deployment of an antenna impossible – or the antenna useless. Once the HOA attorneys get done with their craft you can expect to see an end to antennas in those HOA controlled neighborhoods.
The potential for abuse here is glaringly obvious. It places too much authority and power in the hands of people who are not knowledgeable about the technical properties an antenna must possess in order to operate effectively, in effect banning the use of antennas and further eliminating amateur radio operation within the boundaries of the HOA simply because they don’t like the look of antennas outdoors in the neighborhood.
In an effort to achieve parity, or “fairness”, they simply squelch the things they find objectionable regardless of how “fair” their rules are to the amateur radio operators among us. I tend not to trust the judgment of organizations and the people involved in regulating others activities in their own homes – especially when those people are not elected government officials or law enforcement.
The use of parity in this instance means denying the rights of people who have been deemed less important to the community than the appearance of landscapes, by those who hold the power and authority to dictate rules which become the defacto extra-governmental law makers and enforcement.
It also assumes that amateur radio operators will by erecting an antenna commit the sin of disfiguring the community’s aesthetic appeal, and their anti-antenna bias seems to be the only outrage being expressed in this case.
I accept that HOAs are created to preserve certain aspects of the geographic area that the association exists in, and that they become a sub-government in many instances, charging dues which is in effect levying taxes on the homeowners in that area. They also tend to become fiefdoms run by a few select residents who may or may not be duly elected representatives of the community in which they operate.
These extra-government level posts tend attract or are created by authoritarian personalities that revel in having power over others – even though that power may be limited, I have personally seen these associations become oppressive toward the people they are supposed to be organized to support and protect. Giving those types of people the power to decide whether you can have an antenna outside your home is like letting them restrict what car you are allowed to drive. This kind of power in the wrong hands has a corrupting influence and calling this parity is really the antithesis of it.
I think the outrage is the fact this was proposed in the first place.
73!
Ted Rappaport says
Lots of misinformation and denial there about Pactor and Winlink. Urgently, all hams around the world must alert the FCC at its public comment site (by February 20,2018) and should tell ARRL officials and Winlink proponents that their latest filings at the FCC for PCSHB 17-344 are Misleading and dangerous for the long term benefit of incumbent amateur operators who enjoy cw, rtty, ft8, and similar narrowband modes.
These recent disingenuous filings by ARRL and Winlink, and their continued conquest efforts, continue to ignore the spirit and rules of amateur radio, and continue to go against the overwhelming number of hams who have commented publicly to the FCC in the past.
Thirteen years of history show the ARRL and Winlink have repeatedly taken an “all-or-nothing” position at the FCC, when attempting to “expand” the existing HF data ACDS allocation into either the SSB or CW/RTTY HF subbands.
Evidence shows ARRL and Winlink leadership has no room for compromise, and will never admit to the ambiguity and existing problems in FCC rule interpretation, and they have exploited the lack of enforcement at FCC to perpetuate their ambitions and illegal operations of encrypted wideband HF data .
I have never seen Winlink and ARRL advocate for a separate small HF subband that is similar to that used by region 1 of IARU (the most populous ham radio region in the world that includes Japan, and uses segregated subbands as an accepted, commonly practiced international standard), where the wideband data crowd could have 25-40 kHz of bandwidth above the CW/RTTY/FT8 narrowband users and below the ssb subband).
No- ARRL and Winlink want ALL of the cw or ssb subbands. They continually push this minority position and continually ignore the thousands of hams who have consistently urged for such a reasonable solution in rm 11306 and rm 11708. Those sensible pleas continually go unacknowledged and unheeded by the leadership of Winlink or ARRL– and at the peril of the future of our hobby. Now the FCC stands ready to give this tiny minority unfettered access to ALL of the cw/data subbands in HF, and well known communication theory shows this will run rip shod and render cw/rtty/ft8 useless under the intense wideband interference.
The Winlink community and ARRL continually **want it all**–they want an allocation for ALL of the HF subbands. See RM-11306, RM-11708, and now this PCSHB 17-344.
The ARRL is supposed to be the *big tent* lobbying group for its 150,000 members, and claims to be the national lobbying organization of all American amateurs. Yet, there is inordinate power continually being spent by ARRL to lobby the FCC specifically for the Pactor 4 ambitions of Winlink on the HF bands, a tiny spectrum allocation meant for international communication, and used by contesters, DXers, rag chewers, FT8 enthusiasts, RTTY ops, etc.
A 25 kHz subband for wider bandwidth data, as done in IARU region 1 , or limiting wideband data for use at VHF/UHF l, would make much more sense and would be fair and respectful of narrowband incumbents on HF.
Emcomm hams do good work, and have shown this wideband data can do some good for ham radio. No doubt there is a place for modern modulations and experimental work in our hobby, but not on the tiny HF bands that travel globally and which currently house narrowband communications, using encrypted data and unattended QRM generation that is well documented over the last decade.
In the face of such constant and focused aggression by ARRL and Winlink on the HF spectrum, how should one be constructive about the modern undocumented commercial Pactor modulations, and the ambitions of those in leadership who have constantly demonstrated this “winner take all” mentality for our very small and precious HF ham bands, as is once again being done by the recent comments filed by ARRL and Mr. Waterman on the PCSHB 17-344 docket? They want a quick decision without consideration for public comment! See paragraph 32 onward in the recent ARRL filing! The League basically did grandstanding – claiming that Pactor 4 saved the day in Puerto Rico when that is not quite clear and may not be truthful. Like the original Pactor 1 ACDS FCC 500 HZ bandwidth allocation the early Winlink/data pioneers were granted in the 70s/80’s, the tiny minority is taking an inch (the temporary emergency allowance of pactor 4 on HF or Puerto Rico) and trying to expand it by a yard (or mile!), as they attempt to take over the entire HF cw/data spectrum! We Must write the FCC to stop this spectrum takeover.
Parkinson’s law proves, over and over again, that if there is new throughput/bandwidth allocated to a population of data users, the traffic always expands to fill up the allocation, always pushing the appetite for more and more throughput in the limited resources. That means more QRM will occur for any expansion of data, not a finite traffic usage– but an ever increasing one.
Think about the evolution of AOL, wifi, and data rates on cellphones. 1200 bits per second (bps) wasn’t enough, so it went to 2400 bps, and then shortly thereafter we had 4800 and 9600 bps and so much more traffic on copper phone lines in the 90’s. Pactor is a commercial modulation, and is a proprietary signaling system sold by SCS, and is advertised to be “encrypted and secure” to professional boaters and rural internet providers– its not ham radio communication that is “open” or documented (are has. Atrial encryption), and Pactor is not suitably documented for eavesdropping as required by FCC and ham radio. Pactor was only “open” when it was initially introduced and first inserted into the FCC ACDS rules decades ago (that was Pactor 1, simply called “Pactor” at the time), but since then, more sophisticated and encrypted versions of Pactor have emerged for commercial use) and are being used today without any ability for other hams to decipher the arq transmissions. There is (and has been for decades) a huge debate about the legality of this situation, and myriad documented infractions by the few hundred HF winlink ham users, yet Winlink proponents and ARRL continually deny/ignore this fact while pushing their ambitions for more encrypted data.
The HF spectrum is a precious, small shared resource. Why would Winlink and ARRL continually try to grab 100% of the subband bandwidth allocation of HF phone bands (RM 11306) , and now CW bands ((RM 11708 and wt16-239, and now this!) without first assessing, identifying, and solving existing problems?
RM-11306 was soundly repelled in 2005-2007 and withdrawn by the ARRL- members were against it. Same with RM-11708 – over 90% of all hams were dead against it *after* the community became aware of it in spring 2014. And yet again, the damaging FCC wt16-239 was rejected in public comments by 92 % of all commenters at the FCC public site! These broad and consistent views against the ARRL and Winlink “all or none” spectrum strategy seem to be continually ignored by ARRL and Winlink…. as evidenced again by the filings at the FCC in the past week by ARRl and Mr Waterman of Winlink!
There is great denial on the part of “Steve and others” on the existing problems of current Winlink users in HF, as I and others showed in FCC proceedings and will again need to show (and urgently need help from thousand of other concerned hams to again write to repel the aggressive HF data aspirations of Winlink and ARRL on display in the past week ).
Simply put, communication theory shows clearly that bit rate (baud rate ) is roughly proportional to data rate and RF bandwidth! By removing the 300 baud limit, as ARRL and Winlink wants to do, we remove the only bandwidth limit that protects the narrowband HF modes. The narrowband modes can only function with similar narrowband modulations- they need a bandwidth limit and cannot coexist with the wideband data modes of pactor and stanag and winmoor. IARU Region 1 acknowledges this for Europe, as is also done in Japan, other Asian countries, and South America.
While today it’s a relatively small user community that uses winlink and winmoor, the number of infractions and improper uses of this small population are way beyond anything reasonable, as this group often does not obey the existing FCC rules, and the Winlink crowd has exploited an FCC that doesn’t enforce the current rules on documented codes or proper spectrum use:
See:
https://www.fcc.gov/ecfs/search/filings?proceedings_name=16-239&q=filers.name:(*rappaport*)&sort=date_disseminated,DESC
https://www.fcc.gov/ecfs/search/filings?proceedings_name=16-239&q=filers.name:(*white*)&sort=date_disseminated,DESC
https://ecfsapi.fcc.gov/file/108092534628353/Comment%20RM11708%20FCC%2016-239%20.pdf
The hobby of ham radio has always done more with less, and it is a shared resource, accessed by millions across the globe, and meant to be open, without commercial or encrypted data. We don’t have the kind of HF spectrum that commercial internet carriers or commercial boaters have access to. We don’t have a commercial mandate (in fact, just the opposite) to carry internet or email or encrypted data. So why/how can we deny facts and stand by and watch ARRL and Winlink continually seek 100% HF bandwidth allocations for a commercial modulation, when they have already shown an inability to follow both clear and vague, and universally unenforced FCC rules and guidelines that already exist?
Please get active! We all must write into FCC during the comment period and spread the word! I see this honestly as an unrelenting spectrum takeover effort by Winlink and ARRL. They are going for the jugular now win the Puerto Rico filing. Please get active and knowledgeable, and write to the FCC and repel these aggressive and destructive moves to take over the HF data spectrum.
73, Ted N9NB
Dave New, N8SBE says
Q.E.D.
And I didn’t say anything about ‘fake news’. Seems we need a new internet rule, ala the Hitler rule. First poster that cites or accuses the other poster(s) of ‘fake news’ should automatically lose the argument.
Walter Underwood says
Looking purely at the purposes of amateur radio in Part 97, I don’t see a lot of legal support for an emphasis on preserving CW and RTTY. There is support for fewer restrictions on digital modes.
Hams really have been held back from the state of the art in digital. I mark the beginning of modern digital modes with the publication of the Viterbi decoding algorithm over 50 years ago (1967). In 1981, while the FCC was limiting amateurs to 300 baud, I was working on a digital implementation of the V.29 modem, a 9600 bps modem with a 1200 baud symbol rate.
That said, the recent work on weak signal modes (JTxx, FT8) and FreeDV really is excellent technology. But hams are locked out of high-speed digital modes. Or even moderate-speed modes.
The FCC will listen to public input, but this isn’t strictly a popularity contest.
Shirley Dulcey KE1L says
It is currently legal to use wideband data modes on the HF bands, but the signal rate limit makes it pointless to do so. The result is that there has been very little use of PACTOR 3, as the same rate of transmission can be achieved in a lot less bandwidth using other modes.
Eliminating the signal rate limit will open the floodgates. And that wideband data will be unleashed on a band segment that is currently used almost exclusively for narrowband modes like CW, RTTY, and weak signal data modes like WSPR and FT8. Wideband and narrowband modes don’t mix well; the result will be catastrophic for the current users of the low end of the bands.
A better solution would be to separate the HF bands by bandwidth and put the wideband data modes where they belong – in the PHONE portion of the band which is already populated with wideband signals. Eliminate the signal rate limits across the entire band, but limit signal bandwidth on the low part of the band to 500Hz. That will make legacy 850Hz separation RTTY illegal, but very few people are currently using that on HF.
Shirley Dulcey KE1L says
So far as I can tell, under the FCC proposal it would be legal to operate a data mode that occupies the ENTIRE CW/data portion of one of the HF bands, or even multiple bands simultaneously. Although the code is limited to ASCII or Baudot, the regulations impose no restrictions on the modulation scheme. You could get data speeds of hundreds of kilobits per second under ideal conditions, and if you used a scheme with proper error correction you could cope with a lot of interfering signals. But you would also interfere with every other user of the band.
I don’t see a rule that allows such a mode to exist as being in the best interest of amateur radio.