It is doubly incorrect to say " this Proposal would not alter FCC Part 97.221, which limits automated stations to a small section of the digital bands."
1. Within the frequency ranges specified in 97.221(b), there is currently no regulatory limit on bandwidth. However, 97.307(f)(3) limits the symbol rate to 300 baud in these frequency ranges, which given the passband characteristics of most HF transceivers creates a practical bandwidth maximum of 2.2 kilohertz. If accepted, RM-11708 would eliminate the 300 baud symbol rate limit, making it both practical and legal for automatic stations to use 2.8 kilohertz wide signals in the 97.221(b) frequency ranges -- a significant increase over what's currently practical and in use. Without any requirement that such automatic stations employ competent busy frequency detectors, the result will be a significant increase in QRM to ongoing QSOs. 2. 97.221(b) specifies 10.140-10.150 -- which is 20% of the entire 30m band, and most of the portion of that band used for digital mode operation. This is not a "small section" of the 30m digital band. 73, Dave, AA6YQ -----Original Message----- From: Topband [mailto:topband-boun...@contesting.com] On Behalf Of Brad Rehm Sent: Saturday, March 15, 2014 7:58 PM To: topband@contesting.com Subject: Topband: RM-11708 Topbanders, Here are some comments on RM-11708 which I think are relevant to topband operation. We've been asked to send responses to the ARRL, so remember that responses to the reflector may stimulate discussion, but they won't affect decisions taken at the League unless you send them in that direction. I realize this topic has been discussed earlier on our reflector, but it's important enough to warrant more exposure. These remarks are copied from the Central Texas DX & Contest Club reflector. Brad, KV5V From: Terry Gerdes, AB5K and Dan White, W5DNT As many of you know, RM-11708 (the "Proposal") has been submitted by the ARRL to the FCC as a "rule making" request. If approved, wide band digital modes of up to 2.8 KHz bandwidth would be allowed in non-phone bands, potentially impacting traditional CW & RTTY frequencies as new digital modes are developed. This Proposal would not alter FCC Part 97.221, which limits "automated stations" to a small section of the digital bands. An exception is granted in 97.221 for modes of 500 Hz or less, so the Proposal should not create new automated wide band stations in CW & RTTY bands. However, as modes develop, we would certainly expect wide band peer to peer communications to pose a serious threat to our traditional CW and RTTY frequencies if the proposal is approved by the FCC and no stringent band plan is developed. Once the Proposal was made to FCC, the ARRL acknowledged the need for proper detailed band planning to mitigate potential detriments to CW & RTTY. In early March, they began a one month process of soliciting member input into that band planning process. As avid CW & RTTY DXers and Contesters, this potential threat posed by the Proposal, coupled with limited time remaining for member input (through March 31st), has caused us to have extensive communications with ARRL leadership to insure both CW and RTTY operators are represented in this process. This has occurred over the last two days. We are happy to say those conversations have been constructive. HOWEVER, those discussions certainly do not constitute a fix in our minds. WE NEED YOUR HELP! What is needed is for each of you to submit your own input into the process. Besides, you may or may not agree with what we have provided. Please make your input constructive and specific, listing any bands and frequency ranges you would find acceptable, if any, for wide band digital modes. The objective here is to generate as much input as possible for the HF Band Planning Subcommittee, chaired by Rick Roderick, K5UR. Rick, an avid DXer and Contester himself, has assured us that all input will be considered. That doesn't mean agreed to, but it will be considered. All that we can ask for is objectivity and fairness. After our discussions, we believe Rick will bring that to the process. What we don't need is more non constructive ARRL bashing, there has already been plenty you can rest assured. We need to quickly mobilize and help look for a solution. RM-11708 is not going to be withdrawn as the ARRL is convinced the FCC is going to address wide band digital with or without ARRL input. The EMCOMM crowd pushing for wider bandwidths is not going away either and you can bet they are providing highly organized input. After all, technology is changing, and with it, creative well reasoned solutions are going to be required. This is time for us to step up to the plate and get involved. One point requiring further clarification involves the current automated stations that have generated QRM for so many of us. These stations are typically narrow band Winlink stations, operating under the frequency exceptions granted by FCC 97.221. We would suggest that you consider including these automated stations in your recommended band plan input. We strongly recommend they be limited to a wide band area due to their extremely high inherent potential for QRM to RTTY, CW and even the case of 40M DX SSB split operation as some of us experienced with FT5ZM. Thanks for your consideration and we appreciate very much any specific and constructive input you may have to the Band Planning Subcommittee. Please address your comments to them via email at HF-Digital-Bandplanning at arrl.org . As Chairmen, Rick Roderick should be copied. His published QRZ.com email address is K5UR at aol.com . As a sample, below is one letter of input for your consideration. We are not asking that you agree with it, rather the letter is provided merely as an example for your consideration. Best 73, Terry Gerdes, AB5K Dan White, W5DNT Input March 3rd, 2014 Ladies & Gentlemen, As an avid DXer, while I am very concerned with the outcome of the petition process, I am pleased that ARRL has asked for comments with regard to Band Planning. Not only am I an avid DXer, but I am also an EMCOMM person, holding the job of ARES Emergency Coordinator of two counties in Texas, and a County RACES Radio Officer in one of those counties. I am proficient in RMS Express and have it on my PCs. Perhaps this will make the point that I am not just another upset DXer! As requested, my "cogent and thoughtful" input is respectfully provided herein. It is really very simple and can be boiled down to one sentence. Keep the wide band digital out of current customary CW and RTTY bands. Translating that simple sentence into possible sub-bands, I would suggest as a starting point: 1.880-1.900 MHz, 3.590-3.600 MHz, 7.100-7.125 MHz, 14.115-14.125 MHz, 21.115-21.125 MHz and 28.125-28.150 MHz. NO WIDE BAND USE on WARC Bands (30M, 17M or 12M) as those bands are already too crowded! That would be a good starting point and would provide plenty of diverse spectrum without exposing CW and RTTY sub-bands to wide band digital QRM. Hopefully many others from the DX and Contest Community will provide input and the ranges can be tweaked as needed. Also, hopefully ARRL will seriously consider the desires of existing DX and Contest enthusiasts, and not just primarily the EMCOMM folks and software/hardware manufacturers frustrated with the current nuances of "broad band internet" style email over HF spectrum. Just so you guys know, the other day on 40M with FT5ZM, one of these automated RMS Express stations was on the transmit frequency of FT5ZM in the foreign phone band, while FT5ZM was working split SSB. Did the users check to see if the frequency was busy with SSB traffic, NO! They went right ahead with their email traffic and essentially jammed the DX station for well over an hour. Possibly being "no-coders", they may not have realized RMS Express was signing each transmission with their callsign. If serious band planning is not done in earnest, this can easily become a routine problem for the RTTY and CW bands too. With regard to Amsterdam Island and the digital jamming that occurred, that jamming cost me a 40M SSB QSO, along with many others. That DXpedition had an operational cost of $20 per minute. As a major financial contributor to FT5ZM, I am disappointed to see jamming of any sort, including the RMS Express situation cited above. Perhaps we should really consider the appropriateness of email systems on HF, particularly broadbanded modes. Am I concerned about implementation problems if the petition is approved? Most definitely, yes I am. ARRL now has a chance to avert a spectrum disaster through good old fashioned common sense. Simply keep the wide band digital out of current customary CW and RTTY frequencies, through proper band planning. It is just that simple! Respectfully submitted with Best 73! Dan White, W5DNT _________________ Topband Reflector Archives - http://www.contesting.com/_topband _________________ Topband Reflector Archives - http://www.contesting.com/_topband