> Mark WD4ELG wrote: > Hey Bonnie > You are a digital guru, so I would appreciate it if you > could educate me. ... > Help me by answering these questions, so that I can make > an educated comment to the FCC:
Hi Mark, I will attempt to answer your questions, one by one, below: > How will this RM will KILL digital radio? It will prevent present digital data technologies that now use normal HF ham transceivers for time-division sharing of frequencies. It will kill new developments of fast digital technologies than enable many stations to use the same frequency simultaneously. It will kill all the great new types of interaction with new technologies, now and in the future. > I would like to see narro bandwidth (PSK31, RTTY) modes > only in the first 100 khZ segments. The FCC does not limit bandwidth of ham digital data because there is still active innovation and technology being invented for digital time-sharing, a technique that enables many hams to use the same HF frequency to send very fast data nearly simultaneously. Most other countries set 6kHz (or more) as the limit. There is enough ham spectrum for all of these different bandwidths to peacefully coexist. We don't need a 1.5kHz bandwidth limit on all data. > Why do we let unattended operations take place? There are no "unattended stations" in USA under FCC rules. All stations have control operators, by some means. There are "automatically controlled data stations", and these stations already operate under FCC rules, and have severely restricted and limited ways that they operate, and special sub-bands that they operate in under the rules. See the FCC Automatic Data Sub-Bands chart: http://hflink.com/bandplans/USA_BANDCHART.jpg' The petition seeks to send us back to the stone age of ham radio digital, by eliminating all types of digital data transmissions that are more than 1.5kHz bandwidth, whether or not they are manual or automatic transmissions. This will effectively kill or hobble the only 24/7 HF emergency data communications services we have in USA. It will kill technological innovation in ham radio digital data time-division digital techniques, in favor of the 20th century's method of frequency-division techniques. 73 Bonnie KQ6XA Read the "Petition to Kill Digital Radio Technology" here: http://hflink.com/fcc/FCC_RM11392.pdf File your comments against "proceeding RM-11392" here: http://fjallfoss.fcc.gov/prod/ecfs/upload_v2.cgi Can we can get at least one hundred hams to oppose it? Please do your part. > > A terrible petition now at FCC USA seeks to eliminate > > all advanced ham radio digital data modes such as Olivia, > > MT63, OFDM, fast PSK, ALE, PACTOR, MFSK and others. > > > > We only have a few days, by January 1, to respond and kill it. > > > > Only you can save the future of digital radio, by > > your comments to FCC. > > It only takes a few minutes on the web. > > > > Click here, enter proceeding, RM-11392 and your commments: > > http://fjallfoss.fcc.gov/prod/ecfs/upload_v2.cgi > > > > Fill in the appropriate parts of the form, > > then write your comments in the lower part > > "Send a Brief Comment to FCC (typed-in)" > > > > Here are suggested examples of comments, below. > > Don't let FCC kill digital data on ham radio. > > Don't allow USA hams to fall further behind the rest of the world. > > > > 73 Bonnie KQ6XA > > =============== > > Feel free to copy and paste any (or all) of these into your comments. > > > > 1. I oppose the RM-11392 petition by Mark A. Miller > > seeking to change Amateur Radio Service automatically > > controlled data stations and narrower bandwidths on HF. > > > > 2. The RM-11392 petition is very bad for the Amateur > > Radio Service. > > > > 3. The RM-11392 petition seeks to destroy 21st century > > digital data technology advancement in the Amateur Radio > > Service. Please do not turn back the clock on digital data > > to the 20th century. > > > > 4. The RM-11392 petition's proposed 1.5kHz bandwidth > > limit on data emission is too narrow for established > > international standard transmissions and equipment > > bandwidths used by the Amateur Radio Service. > > > > 5. The RM-11392 petition is an attempt to kill innovation, > > technology advancement, and emergency data communications > > in the Amateur Radio Service. Please do not let this happen. > > > > 6. The FCC Amateur Radio Service's automatically controlled > > data sub-bands are already too narrow for the huge volume > > of traffic that runs on them. If a limit of 1.5kHz bandwidth > > is applied, it will severely hamper the ability of amateur > > radio operators to share these small band segments efficiently > > through rapid data time division methods. > > > > 7. There is a huge installed base of Amateur Radio Equipment, > > and millions of dollars of monetary investment by thousands > > of Amateur Radio Operators that use HF digital data systems > > with more than 1.5kHz bandwidths. This investment by > > FCC-licensed operators would be taken away or rendered useless > > if the objectives of the RM-11392 petition were to be adopted. > > > > 8. Several of the primary established HF emergency > > communications networks currently in service and utilized > > by thousands of Amateur Radio Operators in USA would be > > totally eliminated or hobbled if the objectives of the > > RM-11392 petition were to be adopted. > > > > 9. The Amateur Radio Service relies upon international > > communications standards. Many of the present digital data > > communications standards require bandwidths in excess of > > 1.5kHz. The normal amateur radio service bandwidth limit > > by governments of other countries is 6kHz or more. > > > > 10. Thousands of licensed Amateur Radio Operators would > > be disenfranchised if the objectives of RM-11392 were to > > be adopted. > > > > 11. The RM-11392 petition is comparitively similar to > > an Analog Cellular Phone service entity trying to eliminate > > newer Digital Cellular Phone service. The fact is, Amateur > > Radio is now using faster time-multiplexing digital methods > > to enable more stations to efficiently use the same frequency > > channels simultaneously or in rapid succession. These time > > division techniques require at least 3kHz of bandwidth. > > > > 12. RM-11392 petition has not presented a compelling > > need to change the rules for Automatically Controlled > > Data Stations on the HF bands. > > > > > > END
