Dave,
Again, these are all good points, and I will forward them onto my Director.
However, I don't think there are any satisfactory answers to the issues.
A the bottom of all this is my suspicions that the FCC really does NOT
back the idea of reg by BW.
73,
John
K8OCL
----Original Message Follows----
From: "Dave Bernstein" <[EMAIL PROTECTED]>
Reply-To: digitalradio@yahoogroups.com
To: digitalradio@yahoogroups.com
Subject: [digitalradio] Re: Report of the ARRL Ad Hoc HF Digital Committee
Dissenting
Date: Sat, 24 Mar 2007 22:26:15 -0000
>>>AA6YQ comments below
--- In digitalradio@yahoogroups.com, "John Champa" <[EMAIL PROTECTED]> wrote:
>snip<
Dave's No. 1: Obviously, as he knows, Chris Imlay is a paid
employee. He puts in more time than his pay demands, but he is paid.
To lay this all on him is wrong, though. I know of 19 people
(including me) in addition to Chris and anyone else at the law firm
who reviewed the ex parte presentation before it was made. The
interesting thing is that the bulk of the criticism made about the
presentation focuses on the proposed maximum bandwidth of 3 kHz for
data. This was not the error.
>>>I didn't lay this all on Imlay; I simply quoted Imlay's mea culpa
to demonstrate that the error and ensuing confusion were the
responsibility of paid professionals, rather than unpaid volunteers
as you had claimed.
His No. 2, second paragraph: He is wrong when he asserts we are
trying to expand the use of uncontrolled 'bots. They have been
allowed for quite some time.
>>>This is a non-sequitur. The fact that "uncontrolled 'bots" (by
which I assume he means unattended servers like WinLink PMBOs) have
been around for quite some time does not refute my assertion that the
ARRL is trying to expand the frequencies available for their use. The
ARRL's RM-11306 would allow semi-automatic operation anywhere subject
only to bandwidth constraints.
The reason for the 3 kHz proposal for data max. bandwidth is to
establish a limit where one does not exist. If adopted, this will
apply to 'bots as well as other data forms.
Further, we are not proposing to expand the frequency subbands
available to 'bots or any other form of data.
>>>Without seeing the ARRL's newest proposed changes to ยง97.221
(which governs semi-automatic operation) one can't agree or disagree.
Taking the author at his word, there is still the problem of
unintended consequences, which have plagued recent ARRL proposals.
Finally, we have tasked a group with developing an inexpensive means
to develop a means of enabling 'bots and other forms of data to
monitor the frequency they would transmit on (and nearby frequencies)
before they transmit.
>>>As we have discussed here many times, Rick KN6KB developed an
effective soundcard-based busy frequency detector 2 years ago as part
of SCAMP. The implementation was a first iteration proof of concept,
and technology has progressed during the ensuing years; thus, I'm
sure that improvements are possible, but reinventing the wheel is
unnecessary.
Once these become reasonably available, FCC can require their use to
avoid QRMing.
>>>This is completely backwards thinking. Is it okay to keep using a
transmitter with key clicks until we learn how to cure them? No. Is
it okay to keep using an amplifier that splatters until we figure out
how to tune it correctly? Of course not. Then neither is it okay to
be running a PMBO without a busy detector until the WinLink
organization gets around to correcting their shoddy implementation.
His No. 2, last paragraph: The broad scale opposition to
Regulation by Bandwidth occurred only for HF. There was no such
opposition for VHF and above.
>>>Based on the responses to RM-11306, I would say that the broad
scale opposition is to the expansion of semi-automatic operation that
came as a "side effect" of the ARRL's Regulation by Bandwidth
proposal. Had the ARRL taken this feedback into account by retaining
the current limits on semi-automatic operation, my guess is that a
suitably-modified Regulation by Bandwidth proposal would have been
supported by most of the amateur community for both HF and VHF
operation.
73,
Dave, AA6YQ
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