This message will only reach a few of you, since Allen needs to forward to other groups that I am not privy to, but it's important that all the groups try and work together to develop a consensus that everyone can back and support in writing to both the FCC and ARRL EC officials, for a band plan that will protect CW and RTTY (to be regulated by the FCC regulation, and not voluntary) before submitting any comments.
Data is coming, it's probably a done deal with NPRM. The only issue is whether or not the ham community can persuade all of the elected ARRL officials and the FCC to specifically issue some bandwidth emission regulations in parts of the data/RTTY sub bands on HF. That is, if you read the NPRM (everyone needs to!), it asks some specific questions, and has apparently left the door open for bandwidth emission limits in Paragraph 12 of the NPRM. But the FCC is also very clear that reasons and standards/evidence must be presented for the comments to have weight. So just complaining or decrying the use of data is not likely to be effective, and may cause your comment to be completely ignored. (although you surely may address the other questions posed by the FCC, like should the 300 baud rate limit be removed, and what are the consequences if it is). BOTTOM LINE: The FCC has opened the door for a bandwidth regulation that could protect CW and RTTY in its Paragraph 12 of the NPRM, but it's very important that a consensus be built in hamdom so that comments to the FCC and ARRL have the most impact, and I hope all of you will work on various forums and look at the existing standards in IARU/ITU Region 2 (North America is included) and also see what Japan does to protect narrowband emissions. The FCC and ARRL officials will only consider comments and discussion that specifically address the NPRM, and Paragraph 12 seems like the only shot, where the commission asks for suggestions and examples of standards. I have sent Allen some further information. My guess is that the ARRL has to decide what, if anything, to do regarding the NPRM in the next couple of weeks. The sooner the entire ham community can reach a consensus and begin talking with ARRL officials who are on the EC that they personally know, and as soon as the various forums, clubs and chat rooms can determine a unified voice and band plan, the sooner that the FCC will see a unified and overwhelming message from the public. This is the only way I see us protecting CW and RTTY in the USA in the face of this NPRM. Here are some known standards and facts as I know them (if I made any errors, please correct me): 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 exist. b) All RTTY emissions do not exceed 500 Hz in BW and must be protected from wider band interference if they are to exist. c)The 300 baud rate served as a pragmatic, de facto bandwidth emission limit (although some specialty signaling methods and bulletin board and automated operations in Part 97 are about 2.4 kHz in width, but to a general first order, the baud rate limit has served as a bandwidth protector, so removing it will require the FCC to instate some bandwidth limit 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. e) this is not a fact, but an argument we must make and back up with examples of standards: We need to persuade the FCC and ARRL that signals that are less than 500 Hz BW emission (eg. RTTY and CW and other narrowband experimentation modes) are narrowband, and are inharmonious with wider bandwidth data, whether that wider bandwidth data is unlimited or 2.8 kHz in bandwidth. Before making any comments to the FCC and ARRL officials (we must have a vigorous, courteous, well thought out letter writing campaign to ALL ARRL EC and elected officials), everyone should educate themselves with NPRM 11708 and what the Japan government does for its amateur HF /MF data/CW/Rtty regulations - that is certainly a standard and is public, and is enforced by the Japanese government rules (like the FCC), and also everyone should educate themselves with the public IARU/ITU Region 2 (USA) and Region 1 (EU) and Region 3 (Asia) published band plans, as these are also examples of standards. Think of this as studying for your ham ticket - if you like CW and RTTY, that is what is at stake! I proposed in my comments a few weeks ago a regulated band plan to have all of the lowest 50 kHz HF/MF subbands to be limited to 200 Hz emissions to protect CW/PSK31, etc., and then the next upper 50 kHz from the lowest band edge to be limited to 500 Hz to protect RTTY and JT65, (and for 160 meters to reduce that to the lowest 35 KHz for CW, and the next lowest 35 kHz for Rtty/500 Hz), but I never gave any evidence for how that is a standard. ...there is no "standard" for what I suggested, and that is a weakness for what I submitted to the FCC. Maybe the ITU band plan for Region 2, or the Japan regulatory standard should be made a FCC regulation - everyone needs to get up to speed and begin to form a consensus in the ham community, so that the CW/RTTY users can speak with a more unified voice). 73 ted n9nb Allen R. Brier N5XZ 1515 Windloch Lane Richmond, Texas 77406-2553 (281) 342-1882 (Home) (713) 705-4801 (Cell)
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