As promised, I recommend everyone interested in preserving the use of CW, RTTY and other narrow band digital modes send their comments to the FCC at:
* Federal Communications Commission's Web site: <http://apps.fcc.gov/ecfs/> http://apps.fcc.gov/ecfs/. Follow the instructions for submitting comments.[CLICK ON "SUBMIT A FILING"] * Mail: Federal Communications Commission, 445 12th Street SW., Washington, DC 20554. * People with Disabilities: Contact the FCC to request reasonable accommodations (accessible format documents, sign language interpreters, CART, etc.) by email: <mailto:[email protected]> [email protected] or phone: 202-418-0530 or TTY: 202-418-0432. Here is an example of what to send. You can send this as is or modify it to put it in your own words: Dear FCC: Per your request in NPRM 11708/WTB 16239, you must not remove the 300 baud limit unless you create new HF subbands with emission limits, so that the proposed unlimited baud rate/ unlimited bandwidth data can operate in its own subband well above the lowest edge of each HF/MF bands, and below the lowest edge of the phone/image sub band. Removal of the 300 baud limit will remove a de facto emission bandwidth regulation that is currently in place, and will thus create a new inharmonious type of emission with much wider bandwidth than the vast number of current operating scenarios (CW, RTTY, and other popular narrowband modes). Here are known standards and facts the FCC must acknowledge and consider, so that it creates emission limits in the lower part of each HF/MF data subbands if it removes the 300 baud rate limit : a) CW and other narrowband emissions do not exceed 200 Hz in BW and must be protected from wider band interference if they are to continue to exist. b) All RTTY emissions do not exceed 500 Hz in BW and must be protected from wider band interference if they are to continue to exist. c)The 300 baud rate serves as a pragmatic, de facto bandwidth emission limit even today (although some specialty signaling methods and bulletin board and automated operations in Part 97 are about 2.1 or 2.4 kHz in width, but to a general first order, the baud rate limit has served as a bandwidth protector (bandwidth limiter), so removing it will unleash data bandwidths and their spectral intensity, and will require the FCC to instate some bandwidth limits and a new "wider band subband" that is above today's narrowband data subband, and below the phone image subband, if narrow band modes are to be protected). d) We know from the NPRM that the FCC specifically does not allow inharmonious emissions to share spectrum, and this is why SSB/Image signals with 2.8 kHz bandwidth or more have not been allowed into the CW/Data subband. Wider bandwidth data signals, greater than 500 HZ bandwidth, are also inharmonious to the vast number of RTTY and CW operators today. e) we know that the vast majority of data and rtty operators do not exceed 200/500 HZ bandwidth emission. Given these facts, and existing standards such as IARU/ITU amateur radio recommendations, and the Japanese government amateur regulations which specifically regulate emissions by bandwidth to protect CW/RTTY and Narrow band ( less than 200 HZ and 500 HZ emission bandwidths), the FCC and ARRL must acknowledge and honor the protection of narrowband emissions, such that if the 300 baud limit is removed, then narrowband signals that are less than 500 Hz BW emission (eg. RTTY and CW and other narrowband experimentation modes) must be protected by regulation from the inharmonious wider bandwidth data having greater than 500 Hz emission bandwidths, whether that wider bandwidth data is unlimited or is 2.8 kHz in bandwidth. The history of data adoption and the increase in bandwidth data rates in any mode is proven to be rapid. Regulatory bandwidth protection cannot be voluntary to protect the vast monitory investments already made by today's CW/RTTY/narrowband operators cannot be left to voluntary, unregulated spectrum policy. Given these facts and standards, if the FCC is to remove the baud rate limit and not specify an emission bandwidth, it should create a new "wideband data" subband that has its lowest frequency at 100 kHz above the lowest band edge (except at 70 kHz above the lowest band edge in the 1.8 MHz band), and highest frequency that is at the highest edge of the data/RTTY subband (except up to 100 kHz above the lowest band edge in the 1.8 MHz band). The WARC bands and 60 meters must not allow these wider band modes. This approach is standard and documented already in the world, and is needed if the FCC removes the baud rate limit. This exists in Japan (largest ham population) and is recommended by IARU. In removing the baud rate limit and creating this new class of "wideband data" in its own new subband on all of the HF/MF bands (except WARC and 60 m bands) the Commission should also simultaneously institute a bandwidth emission limit of 200 HZ in the lowest 50 kHz edge of every MF/HF amateur allocation (except for 1.8 MHz where it's the lowest 35 kHz), and a wider emission limit of up to 500 HZ should be specified as a regulation from the lowest 50 kHz to lowest 100 kHz of the lowest edge of each HF/MF amateur band (except for 1.8 MHz where the 500 HZ emission limit would extend from 1.835 to 1.87 MHz). Given these facts and standards, the FCC would both honor the petition from ARRL, while also honoring and protecting the vast number of existing narrowband amateurs and implementing standard spectrum policy that exists in Japan and existing IARU standard. If the FCC chooses to not create such segregation by bandwidth, it must reject the removal of the 300 baud rate limit and not move forward with its proposed Rulemaking 11708- as chaos and harm would result to the vast numbers of narrow band amateurs over time. Sincerely, X You should also send similar comments to your ARRL elected officials: Rick Roderick [email protected] K5UR President ARRL Tom Gallagher <mailto:[email protected]> [email protected] NY2RF CEO ARRL Mike Raisbeck <mailto:[email protected]> [email protected] K1TWF New England Division Vice Director, Chairman Amateur Radio Legal Defense & Assistance Marty Woll <mailto:[email protected]> [email protected] N6VI Southwestern Division Vice Director Amateur Radio Legal Defense & Assistance & Legislative Advocacy Committee Jim Tiemstra <mailto:[email protected]> [email protected] K6JAT Pacific Division Vice Director Amateur Radio Legal Defense & Assistance Mike Lisenco <mailto:[email protected]> [email protected] N2YBB Hudson Division Director Amateur Radio Legal Defense & Assistance & Legislative Advocacy Committee James O'Connell <mailto:[email protected]> [email protected] W9WU Member Amateur Radio Legal Defense & Assistance Jim Pace <mailto:[email protected]> [email protected] K7CEX Northwestern Division Director Amateur Radio Legal Defense & Assistance Chris Imlay <mailto:[email protected]> [email protected] W3KD General Counsel, ARRL Amateur Radio Legal Defense & Assistance Brian Mileshosky <mailto:[email protected]> [email protected] N5ZGT Vice President, Chairman HF Band Planning Tom Frenaye <mailto:[email protected]> [email protected] K1KI New England Division Director HF Band Planning David Norris <mailto:[email protected]> [email protected] K5UZ Delta Division Director HF Band Planning Dwayne Allen <mailto:[email protected]> [email protected] WY7FD Rocky Mountain Division Director HF Band Planning Bill Hudzik <mailto:[email protected]> [email protected] W2UDT Hudson Division Vice Director HF Band Planning Steve Ford <mailto:[email protected]> [email protected] WB8IMY Staff Liaison HF Band Planning David Woolweaver <mailto:[email protected]> [email protected] K5RAV West Gulf Division Director Legislative Advocacy Committee Doug Rehman <mailto:[email protected]> [email protected] K4AC Southeastern Division Director Legislative Advocacy Committee BRENNAN PRICE <mailto:[email protected]> [email protected] N4QX CTO ARRL DALE WILLIAMS <mailto:[email protected]> [email protected] WA8EFK Great Lakes Division Dir ARRL Thomas Delaney <mailto:[email protected]> [email protected] W8WLD Great Lakes Division Vice Director ARRL Larry Camp <mailto:[email protected]> [email protected] WB8R Michigan Section Manager ARRL John McDonought <mailto:[email protected]> [email protected] WB8RCR Michigan Section EC ARRL Kenneth Coughlin <mailto:[email protected]> [email protected] N8KC Michigan Section OOC ARRL Daniel Romanchik <mailto:[email protected]> [email protected] KB6NU Michigan Asst Section Mgr ARRL Pat Mullet <mailto:[email protected]> [email protected] KC8RTW Michigan Public Info Cord ARRL Mark Shaw <mailto:[email protected]> [email protected] K8ED Michigan Section TM ARRL Gordon Baldwin <mailto:[email protected]> [email protected] W8CT Michigan Sec Youth Cord ARRL Hope this all comes through ok on the reflectors. Email me if you have any questions. Finally, you can go to these websites for additional information: https://aa4xx.com/2016/08/19/formulating-a-coherent-response-to-nprm-11708/ http://www.learnmorsecode.com http://wireless-girl.com/ Oh, and I apologize if you receive this same message multiple times from multiple reflectors. I need to get this to everyone. 73, Allen R. Brier N5XZ 1515 Windloch Lane Richmond, Texas 77406-2553 (281) 342-1882 (Home) (713) 705-4801 (Cell)
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