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RM-11708

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  • db_n5tm
    I would encourage everyone interested in digital experimentation to file a comment with the FCC regarding RM-11708, which would remove the baud rate limits in
    Message 1 of 8 , May 3, 2014
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      I would encourage everyone interested in digital experimentation to file a comment with the FCC regarding RM-11708, which would remove the baud rate limits in the US HF bands.

      Many of the old timers are up in arms and believe the ARRL is trying to steal their cw frequencies.


      Arrl FAQ http://www.arrl.org/rm-11708-faq


      http://apps.fcc.gov/ecfs/hotdocket/list

    • Jack
      I would strongly suggest looking closely at the technical aspects of RM-11708. While it may ...remove the baud rate limits in the US HF bands it imposes a
      Message 2 of 8 , May 3, 2014
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        I would strongly suggest looking closely at the technical aspects of RM-11708. While it may "...remove the baud rate limits in the US HF bands" it imposes a *bandwidth* limit of 2.8kHz. I have seen some excellent technical discussion, involving highly competent communications engineering people, on another reflector that suggest a possible reduction in effective baud rate with imposition of the 2.8kHz bandwidth.

        I would advise caution, and further investigation, before jumping to conclusions, as some of the "old timers" may have done.

        Jack, W6NF/VE4SNA

        On 5/3/2014 5:41 AM, n5tm@... wrote:
         

        I would encourage everyone interested in digital experimentation to file a comment with the FCC regarding RM-11708, which would remove the baud rate limits in the US HF bands.

        Many of the old timers are up in arms and believe the ARRL is trying to steal their cw frequencies.


        Arrl FAQ http://www.arrl.org/rm-11708-faq


        http://apps.fcc.gov/ecfs/hotdocket/list





        This email is free from viruses and malware because avast! Antivirus protection is active.


      • Joe Subich, W4TV
        ... I doubt that any competent technical discussion can support the claim of reduction in effective baud (symbol) rate with the imposition of a 2.8 KHz
        Message 3 of 8 , May 3, 2014
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          > I have seen some excellent technical discussion, involving highly
          > competent communications engineering people, on another reflector
          > that suggest a possible reduction in effective baud rate with
          > imposition of the 2.8kHz bandwidth.

          I doubt that any competent technical discussion can support the claim
          of reduction in effective baud (symbol) rate with the imposition of a
          2.8 KHz bandwidth.

          The only thing RM-11708 accomplishes is allow PACTOR 4 - a commercial
          protocol for internet and e-mail access that operates at 1800 baud
          in a 2.4 KHz bandwidth - in the bands traditionally protected from
          interference by wideband transmissions. PACTOR 4 has a crest factor
          (peak to average ratio) of less that 4 dB; that is 2 dB less than
          PACTOR 3 which is already a significant source of interference it
          the upper portions of the "CW and RTTY bands".

          In addition, RM-11708 opens the door to STANAG, MS-110 and other
          2400/3600 baud 2.8 KHz wide protocols. A single station using any
          one of these protocols (PACTOR 4, STANAG, MS-110, etc.) can wipe
          out the entire JT65 or JT9 "watering hole" - and most of *both*
          on a given band.

          Unrestricted proliferation of these wideband, "dense" emissions
          in spectrum traditionally reserved for narrowband (< 300 or 500
          Hz) modes will make conditions worse for all and turn the spectrum
          over to commercial exploitation.

          73,

          ... Joe, W4TV


          On 5/3/2014 9:06 AM, Jack wrote:
          > I would strongly suggest looking closely at the technical aspects of
          > RM-11708. While it may "...remove the baud rate limits in the US HF
          > bands" it imposes a *bandwidth* limit of 2.8kHz. I have seen some
          > excellent technical discussion, involving highly competent
          > communications engineering people, on another reflector that suggest a
          > possible reduction in effective baud rate with imposition of the 2.8kHz
          > bandwidth.
          >
          > I would advise caution, and further investigation, before jumping to
          > conclusions, as some of the "old timers" may have done.
          >
          > Jack, W6NF/VE4SNA
          >
          > On 5/3/2014 5:41 AM, n5tm@... wrote:
          >>
          >> I would encourage everyone interested in digital experimentation to
          >> file a comment with the FCC regarding RM-11708, which would remove the
          >> baud rate limits in the US HF bands.
          >>
          >> Many of the old timers are up in arms and believe the ARRL is trying
          >> to steal their cw frequencies.
          >>
          >>
          >> Arrl FAQ http://www.arrl.org/rm-11708-faq
          >>
          >>
          >> http://apps.fcc.gov/ecfs/hotdocket/list
          >>
          >>
          >
          >
          >
          > ---
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        • KQ8M
          As one of the “old timers” I would like to point out that yes it imposes a bandwidth limit BUT when the stations start interfering with each other they
          Message 4 of 8 , May 3, 2014
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            As one of the “old timers” I would like to point out that yes it imposes a bandwidth limit BUT when the stations start interfering with each other they will start to spread out and take up MORE band space. As it is, many automatic stations are now outside of the agreed upon band areas.

             

            Also the disagreement has NOTHING to do with experimentation! The experimentation is now ALLOWED in the VHF range. There is no reason to have many automatic QRM machines on the already limited HF bands. This proposal is being fueled by those that want faster data rates (re: bandwidth) for their everyday usage. Most of these only send the messages such as “Congratulations on your new WAS award”.

             

            You say what does he mean by QRM machines? Well, I operate a LOT of JT9 and JT65 and many times right in the middle of a QSO an automatic pactor, or what the heck ever it is, will key up and kill the QSO! Also many times during RTTY contests which I used to play in these machines will just key up and destroy the frequency. The funny thing is the ARRL contends they are operating within the rules of not creating interference. It is my firm belief this whole thing is being fueled by a select group of individuals for their own gain.

             

            Experiment all you want. There are already places for that.

             

            73,

            Tim Herrick, KQ8M

            kq8m@...

             

            AR-Cluster V6 kq8m.no-ip.org

            User Ports: 23, 7373  with local skimmer, 7374 without local skimmer

            Server Ports: V6 3607, V4 Active 3605, V4 Passive 3606

             

            From: wsjtgroup@yahoogroups.com [mailto:wsjtgroup@yahoogroups.com] On Behalf Of Jack
            Sent: Saturday, May 03, 2014 9:07 AM
            To: n5tm@...; wsjtgroup@yahoogroups.com
            Subject: Re: [wsjtgroup] RM-11708

             

             

            I would strongly suggest looking closely at the technical aspects of RM-11708. While it may "...remove the baud rate limits in the US HF bands" it imposes a *bandwidth* limit of 2.8kHz. I have seen some excellent technical discussion, involving highly competent communications engineering people, on another reflector that suggest a possible reduction in effective baud rate with imposition of the 2.8kHz bandwidth.

            I would advise caution, and further investigation, before jumping to conclusions, as some of the "old timers" may have done.

            Jack, W6NF/VE4SNA

            On 5/3/2014 5:41 AM, n5tm@... wrote:

             

            I would encourage everyone interested in digital experimentation to file a comment with the FCC regarding RM-11708, which would remove the baud rate limits in the US HF bands.

            Many of the old timers are up in arms and believe the ARRL is trying to steal their cw frequencies.

             

            Arrl FAQ http://www.arrl.org/rm-11708-faq

             

            http://apps.fcc.gov/ecfs/hotdocket/list




            This email is free from viruses and malware because avast! Antivirus protection is active.

             

          • Michael Adams
            And also keep in mind that when submitting a comment, it is not strictly necessary to simply support or oppose the proposed rulemaking. For instance, if one
            Message 5 of 8 , May 3, 2014
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              And also keep in mind that when submitting a comment, it is not strictly necessary to simply support or oppose the proposed rulemaking.

               

              For instance, if one felt that it was appropriate to remove the symbol rate restriction, but thought that perhaps wideband should be authorized for only a portion of the CW/data subbands (protecting the balance of the subband for narrowband/CW transmissions), it is perfectly OK to submit a comment to that effect.

               

              --
              Michael Adams | N1EN | mda@...

               

              From: wsjtgroup@yahoogroups.com [mailto:wsjtgroup@yahoogroups.com] On Behalf Of Jack
              Sent: Saturday, 3 May, 2014 09:07
              To: n5tm@...; wsjtgroup@yahoogroups.com
              Subject: Re: [wsjtgroup] RM-11708

               

               

              I would strongly suggest looking closely at the technical aspects of RM-11708. While it may "...remove the baud rate limits in the US HF bands" it imposes a *bandwidth* limit of 2.8kHz. I have seen some excellent technical discussion, involving highly competent communications engineering people, on another reflector that suggest a possible reduction in effective baud rate with imposition of the 2.8kHz bandwidth.

              I would advise caution, and further investigation, before jumping to conclusions, as some of the "old timers" may have done.

              Jack, W6NF/VE4SNA

            • aflowers@frontiernet.net
              Hello Group, Those of you who know me know I m not an old-timer by any stretch of the imagination.  I ll give you my perspective as someone who has a long
              Message 6 of 8 , May 3, 2014
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                Hello Group,

                Those of you who know me know I'm not an old-timer by any stretch of the imagination.  I'll give you my perspective as someone who has a long time-horizon for the future of Amateur Radio.  I'm giving them to you so you can understand the objections you are hearing and so that you don't just dismiss them out of hand as some are encouraging you to do.

                My concern with RM-11708 is and continues to be the ignorance (or avoidance) of the fundamental technology that allows the faster symbol rates to even work on HF in the first place.  The fact is that it relies of pseudo-randomization of the data to make it work.  This is not a problem provided that those codes are published, we do have a publication requirement, for good reasons, and it would seem that this the linchpin of any "specification.  Without publication you have the functional equivalent of symmetric-key encryption.  The petition does not address this, and that is major failing that has long term consequences.  

                You can read my comments in the public record (imperfect as they are), complete with concrete examples that lay it out in detail, with sources:

                http://apps.fcc.gov/ecfs/document/view?id=7520963762  (long, but lots gives background and sources)
                http://apps.fcc.gov/ecfs/document/view?id=7521064873 
                http://apps.fcc.gov/ecfs/document/view?id=7521065139

                I'm not particularly interested in sophistry regarding what is technically "encryption"; we need to look at the intent and ramifications of "private communication", no matter who it is that is doing the transmitting.  Right now we have many people (some organizations in fact) designing privacy into their amateur-radio systems (i.e., designs that make it hard for a third party to understand the communication) while attempting to stay within the "letter of the law".  Whether or not privacy is a hidden value in the subtext to RM-11708 you can judge for yourself as I have, but no matter our beliefs on that subject, the bottom line I keep coming down to is this:

                "My children have increasingly little to learn from an Amateur Radio Service in which communication is private by design."  

                Is that your vision of the second century of amateur radio?  Thus, I look at something like RM-11708 not in technological or regulatory terms, but ultimately along these lines: are we unwittingly allowing people to steal from the long-term future benefits of Amateur Radio?  Cui bono? Cui malo?

                Amateur Radio is something that provides life-long opportunities for learning, often times things that provide knowledge and even career paths that are quite simply inaccessible to most people by other means. That is one of the fundamentals that make Amateur Radio unique in a way that simply cannot be duplicated by any other service.  I think that open communication--the ability to learn by listening and understanding--is fundamental to this principle, and protects us from all kinds of encroachment that would destroy this fundamental aim of the service (among others).  This is something I think you'll find that most "old-timers" understand implicitly, and I would strongly caution against dismissing their objections like the old man yelling at the neighborhood kids to get off his lawn.  It could very well be that there is some wisdom in there if you look beyond just the (some might argue, cherry-picked) technological talking points.  

                I might suggest that most of the objections you are hearing are the first symptoms of the factions that a desire for private communication creates in a self-regulatory environment.  (The third of my comments above deals with this practical aspect, so if you want to read that first, be my guest).  Maybe that gives something to talk about over a beverage at the next hamfest...

                Those are my thoughts as an emphatic not-old-timer who has benefited greatly from the Amateur Radio Service, and as someone who has decisions to make with is children.  

                Andy K0SM/2


              • Jim Brown
                I agree with Joe s assessment. I think the League has screwed up on this thing. 73, Jim K9YC
                Message 7 of 8 , May 3, 2014
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                  I agree with Joe's assessment. I think the League has screwed up on this
                  thing.

                  73, Jim K9YC

                  On 5/3/2014 6:44 AM, Joe Subich, W4TV wrote:
                  > The only thing RM-11708 accomplishes is allow PACTOR 4 - a commercial
                  > protocol for internet and e-mail access that operates at 1800 baud
                  > in a 2.4 KHz bandwidth - in the bands traditionally protected from
                  > interference by wideband transmissions. PACTOR 4 has a crest factor
                  > (peak to average ratio) of less that 4 dB; that is 2 dB less than
                  > PACTOR 3 which is already a significant source of interference it
                  > the upper portions of the "CW and RTTY bands".
                  >
                  > In addition, RM-11708 opens the door to STANAG, MS-110 and other
                  > 2400/3600 baud 2.8 KHz wide protocols. A single station using any
                  > one of these protocols (PACTOR 4, STANAG, MS-110, etc.) can wipe
                  > out the entire JT65 or JT9 "watering hole" - and most of*both*
                  > on a given band.
                • Joe Subich, W4TV
                  Yesterday, I sent the following e-mail to members of the ARRL Executive Committee and my director. I urge anyone interested in/concerned about the future of
                  Message 8 of 8 , May 3, 2014
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                    Yesterday, I sent the following e-mail to members of the ARRL Executive
                    Committee and my director. I urge anyone interested in/concerned about
                    the future of amateur radio to contact their director and the Executive
                    Committee to support withdrawal of RM-11708 in favor of a bandwidth
                    based approach to future allocation:

                    > The issue is that RM-11708 is too narrowly focused - a transparent
                    > attempt to shoe-horn PACTOR 4 into the current rules - rather than a
                    > good faith effort to deal with *all* the issues raised by increasing
                    > use of digital modes in amateur radio.
                    >
                    > ARRL and amateur radio as a whole would be much better served by a
                    > "big tent" approach - one that would look at digital techniques as a
                    > whole. The most simple - and by far most effective - approach would
                    > be to simplymodify 97.305(a) to read:
                    >
                    >> (a) Except as specified elsewhere in this part, an amateur station
                    >> may transmit a CW, RTTY or data emission on any frequency authorized
                    >> to the control operator.
                    >
                    > That one simple change would instantly avoid any issue of bandwidth
                    > or symbol rate for "RTTY and data" modes operating in the so called
                    > "Phone" bands (actually, wideband sub-bands).
                    >
                    > With one minor change, we could be discussing issues of much more
                    > fundamental importance to the future of amateur radio:
                    >
                    > 1) what is the appropriate bandwidth in the narrow bandwidth sub-
                    > bands - is 2.4 KHz appropriate if PACTOR 3 can be accommodated
                    > in the wide band sub-bands? Would 300 Hz, 500 Hz or some other
                    > value be more appropriate?
                    > 2) what is the appropriate level of disclosure that should be
                    > required for "documented" codes (data encoding) - should
                    > proprietary and quasi encrypted codes be permitted at all below
                    > 200 MHz, below 144 MHz, below 50 MHz?
                    > 3) should "documentation" require full disclosure of all encoding,
                    > compression and software algorithms plus release of functional,
                    > real time,"receive only" software for each of the major
                    > PC operating systems?
                    > 4) does the current non-specific wording of 97.307(f)(2) referring
                    > to the "bandwidth of a communications quality phone emission"
                    > need to be replaced with a specific value - say 2.8 KHz -
                    > except for ISB (independent sideband) and AM which would be
                    > grandfathered at 5.5 or 6 KHz?
                    > 5) is it appropriate for automatically controlled stations to
                    > be required to have and use an effective "channel busy"
                    > detector? Should the operator of any station using a digital
                    > mode where the "raw" (speaker) audio is not monitored in real
                    > time be required to have, and use, a "waterfall" or "audio
                    > spectrum" display in order to "see"/avoid other users on the
                    > frequency? If such visual monitoring is not present, should
                    > the control operator required to employ an effective "channel
                    > busy" detector?
                    >
                    > ARRL could take the lead in preparing amateur radio for the 21st
                    > century and beyond with just a little bit of "out of the box"
                    > thinking.
                    >
                    > In addition, a properly structured proposal should be a win-win-win.
                    > Winlink users get their PACTOR 4 (although on different frequencies
                    > than current operations), CW, RTTY and other narrow band mode users
                    > get relief from the unrestricted automatic (and semi-automatic) RMS
                    > interference, phone operators avoid the threat from 6 KHz wide HF
                    > D-Star and gain a clear path to digital voice modes, while amateur
                    > radio in general now has a clear path for development of mixed,
                    > "phone + data", "image + data", "phone + image + data" modes.
                    >
                    > The Executive Committee needs to withdraw RM-11708 and replace it with a
                    > broadly based blueprint for the future.

                    73,

                    ... Joe, W4TV


                    On 5/3/2014 1:46 PM, Jim Brown wrote:
                    > I agree with Joe's assessment. I think the League has screwed up on this
                    > thing.
                    >
                    > 73, Jim K9YC
                    >
                    > On 5/3/2014 6:44 AM, Joe Subich, W4TV wrote:
                    >> The only thing RM-11708 accomplishes is allow PACTOR 4 - a commercial
                    >> protocol for internet and e-mail access that operates at 1800 baud
                    >> in a 2.4 KHz bandwidth - in the bands traditionally protected from
                    >> interference by wideband transmissions. PACTOR 4 has a crest factor
                    >> (peak to average ratio) of less that 4 dB; that is 2 dB less than
                    >> PACTOR 3 which is already a significant source of interference it
                    >> the upper portions of the "CW and RTTY bands".
                    >>
                    >> In addition, RM-11708 opens the door to STANAG, MS-110 and other
                    >> 2400/3600 baud 2.8 KHz wide protocols. A single station using any
                    >> one of these protocols (PACTOR 4, STANAG, MS-110, etc.) can wipe
                    >> out the entire JT65 or JT9 "watering hole" - and most of*both*
                    >> on a given band.
                    >
                    >
                    >
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