Cross-posted from CTDXCC reflector:
Message: 9 Date: Thu, 26 Feb 2015 21:33:15 -0600 From: Ted <[email protected] <mailto:[email protected]> > To: "[email protected] <mailto:[email protected]> " <[email protected] <mailto:[email protected]> >, [email protected] <mailto:[email protected]> Cc: "<[email protected] <mailto:[email protected]> >" <[email protected] <mailto:[email protected]> >, "<[email protected] <mailto:[email protected]> >" <[email protected] <mailto:[email protected]> >, [email protected] <mailto:[email protected]> Subject: [CTDXCC] HF Bandplan Comments Message-ID: <[email protected] <mailto:[email protected]> > Content-Type: text/plain; charset=us-ascii Everyone should know that a failure to log a comment against RM 11708 at the FCC website only strengthens the removal of today's regulatory protections for CW and RTTY and narrowband modes. ARRL's *bandplan* does nothing to address the issues raised by RM-11708, as it is only voluntary, does nothing to limit the bandwidth of data mode stations nor protect CW, RTTY and other narrow bandwidth digital signals against interference by automated operation. To be effective ARRL's proposal needs *at least* the following: 1) limit the RF bandwidth of all data signals in the HF bands to less than 300 Hz below a thin slice of "automatically controlled data" segments. 2) place the "automatically controlled data" segments at 3625-3630, 7115-7120, 14130-14140, 21180-21190 and 28280-28290 *ONLY* - no automatic control on 30, 17 or 12 meters due to the limited available spectrum. 3) require *all* automatically controlled data - including the "auto- responding stations" (97.221(c)) - operate in the automatic control sub-bands. 4) require all automatically controlled data stations include fully functioning "channel busy" detectors calibrated for 125% of the bandwidth to be used including any "enhanced speed" modes. 5) require all automatically controlled data stations - including "auto-responding stations" and US licensed amateurs operating systems off shore - list their frequencies, operating times, and control operator telephone number in a publicly accessible database 6) require all manually controlled digital stations include a visual means (e.g. spectrum display or "waterfall") to determine if the transmit frequency is busy before transmitting *or* include a functioning "channel busy" detector calibrated for 125% of the bandwidth to be used including any "enhanced speed" modes. 7) expand 80 meter data to 3675 not 3650 ... (Ok, this is not critical, but is a nice to have). All others are critical and should be regulated by the FCC and not voluntary. These items need to be written into part 97 - by the FCC- along with a minimal bandwidth of operation (300 or max 500 Hz for the lower portion of all HF CW data subbands) if CW and RTTY and j65 are to be protected. In other words, the above regulations can *not* be optional, as the ARRL is trying to do. They should be governed by FCC rules. 73, Ted n9nb Sent from smartphone, please excuse typos Allen R. Brier N5XZ 1515 Windloch Lane Richmond, Texas 77406-2553 (281) 342-1882 (Home) (713) 705-4801 (Cell)
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