Sent from my Verizon 4G LTE smartphone -------- Original message -------- From: Ted <[email protected]> Date: 11/10/16 1:15 PM (GMT-06:00) To: [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected] Subject: Re: QST ARLB037 Current Rules Holding Hams Back From Adopting State-of-the-Art Technology Dear all: Only 2 days remain for REPLY TO COMMENTS. Please see the attached template, with filing instructions. Note that people need to adapt/edit and include their callsign. Very important that REPLIES BE FILED TODAY AND TOMORROW. Please file your own comments today and also spread the word!~ The future of CW and RTTY are at stake. thanks es 73 ted n9nb Today is the day that we must flood the FCC with “Reply toComments! We are at the last day. Please, everyone, take part of these commentsand add your own words, your own Call Sign, and file “REPLY TO COMMENTS”. To do this, simply go to : https://www.fcc.gov/ecfs/search/filings?limit=25&offset=0&proceedings_name=16-239&sort=date_disseminated,DESC, and at the very top of the FCC ECSF page, click on SUBMIT A FILING. Then, on the next page, find the top “Proceedings” line, andenter “16-239” and “RM-11708” and “RM-11759”. Your comment will go into all 3records. Then go to “Type of comment” pull down, and enter “REPLY TOCOMMENT” (3rd down from the top of the long list) Enter your name and address and email, and then attach yourcomment as a document. Some spaces maybe left blank. THIS MUST BE FILED BY NOVEMBER 11, and Please sign your name andcall sign! You may use parts of this (take excerpts if you wish, ormake up your own – PLEASE DO NOT COPY VERBATIM AS IT WILL LESSN THE IMPACT.MODIFY SOME WORDS, ESPECIALLY THE OPENING, OR TAKE OUT SOME PARTS AND ADD YOUR OWN!: ----------------------------- Dear FCC: Please consider these Reply to Comments for Docket 16-239NPRM, as well as for other petitions such as RM-11708 and RM-11759 that dealwith the amateur radio service. I am a licensed amateur radio operator, with call signENTER CALL, and I am replying since I will be greatly impacted by any rulingssurrounding these rulemaking proposals and the NPRM . The many comments in these proceedings demonstrate vastnumber of amateur operators are against both RM 11708 and Docket 16-239 NPRM. Theamateur community, through the FCC ECFS system, has very clearly rejected boththe ARRL's RM-11708 petition and the FCCs proposed solution. More than 90% of the over 100 replies filedin the NPRM are firmly against the FCC proposal, and urge that the FCC, and nota voluntary organization like the ARRL, provide narrowband emission limits thatprotect existing narrowband communication (less than 200 Hz CW and dataoperators, and less than 400 or 500 Hz RTTY and data operators). The vast number of commenters urge that some bandwidthlimit be Instituted and regulated by the FCC, and that the CW/RTTY/narrowbandoperators must be protected with a regulatory, not voluntary, bandwidthemission limit of 200 HZ and 400/500 Hz in the lower portions of every data subband. Most replies noted the current violations of ACDS/robotstations and the use of non-published protocols (Pactor II/III), along with outof band emissions of the ACDS stations. Commenters are clear that the FCC mustclarify its rules for open transmissions that are published and notproprietary, and must clean up current ACDS/robot stations before allowing anyexpansion of bandwidth or their privileges. Many commenters also urge the FCC to determine if usinghttps// web browing (which ensures encryption even when using an open airinterface) and if email is properly allowed on HF/MF amateur radio bands. Given the documented evidence ofbusiness use, bypass of other commercial means, and out of band ACDS transmissions,the Commission must carefully consider the impact of its rulings on open,transparent, or encrypted transmissions that the FCC and others cannot detect. Detailed comments that are worthy of FCC considerationinclude the following: In Reply to Comments on Nov. 9, 2016, Ms. Janis Carlsonfiled a very thoughtful and detailed summary of various proceedings. https://ecfsapi.fcc.gov/file/11091541913133/FCC%20WT%2016-239%20ARRL%20reply.pdf In her comments, she outlines 5 options the FCC couldtake to prevent continual bombardment on the issue of data in the amateur radioservice, and demonstrates the continual problems of the ARRL’s ambition forinternet and email usage through past and present proposals. Her replyillustrates the FCC’s profound need to regulate the HF/MF bands in a way thatprotects narrowband CW/RTTY operations. Mr. Chris Crisler posted a Reply on October 21, 2016 https://www.fcc.gov/ecfs/filing/1020807821008 In his Reply, Mr. Crisler points out vital factsregarding the mission and value of amateur radio and its historic ability toenable amateurs to innovate using “narrowband technology.” He points out myriadproblems with the NPRM and with RM-11708, and cogently illustrate the need toensure bqandwidth limitations. In fact, he notes they should be “jealouslyguarded” to save spectrum space from commercial users of the spectrum. Hepoints out the illegal or wastefiul use of internet and email on the tinyportions of HF/MF spectrum, and notes (as most commenters did) that proprietarysignaling and equipment are being usedfor the data ambitions of a small minority of amateur operators. He urges the commission to not delete bandwithlimitations and to prevent “spectrum-hogging” from entering amateur radio. Herecommends a maximum bandiinmum Mr. Michael Dinelli, on October 13, 2016, noted thatRM-11708 and the NPRM are “incompatible with narrow bandwidth modes (i.e.continuous wave (CW) and radio teletype (RTTY)” Mr. Mcvay, https://www.fcc.gov/ecfs/filing/109151227915014/document/109151227915014b3ba Mr. McVay clearly stated why a bandwidth emission limitis needed, and urged for 500 Hz bandwidth limit protection and asked for allstations greater than 500 Hz, including ACDS, to operate up in the band (this is like all IARU and Japan regulations, aswell as other numerous countries that follow IARU specifications. McVay alsopointed out very clearly that Pactor I is published and unencrypted, but alllatter versions of Pactor that are used today by Winlink and ACDS are notpublished and should not be on the amateur bands. He also offered up suggestedFCC regulations to fix the current problems. Ward Silver, N0AX: https://www.fcc.gov/ecfs/filing/1011947518902 Mr. Silver is clear on the intense interference that willresult if either rm 11708 or 16239 is adopted. He points out some maxima mbandwidth limit is required, and chooses to study commercial modem signals (notjust amateur radio signaling which must follow openness and non-business usagerules) to justify 6 kHz as upper limit. I believe this is a flawedargument since ham radio is non-commercial and uses shared variablefrequencies, and is not channelized like commercial/ military signals that usethe list of 182 signals he proposed. Thus, 6 kHz seems vastly wider thananything the amateur HF spectrum should allow, due to the tiny sliver of HFspectrum that exists for the 750,000 US amateurs and 3 million global amateuroperators. Mr. Silver conceded much greater interference will surely resultwith any allowance for wider band data than under today's 300 baudlimit, which is an implicit justification for IARU narrowband protections that so manycommenters have urged for, in order to avoid the disruption from signalspreading he discusses in his comment. In section 4 of his comment, he points out the problem with today'sencryption and lack of public identification of data stations, and calls on FCCto address this, as did so many commenters. The FCC cannot ignore this constanttheme of the amateur radio community. Mr. Silver does not opine on the vitalissue of whether internet or email should be allowed in the amateur radioservice, and does not point out or acknowledge the present day violationsoccurring when data stations move out of the ACDS sub ands to carry Pactor 3 or Winmoor 1600 traffic. This commentshows that the interference will be intolerable unless data stations arenot confined to a small subband of the Data/RTTY segments for all aspects ofthe operations. Mr. Silver makes an incorrect assumption that many commentersdo in assuming that faster data rates would lead to less time occupancy on theair- this is wishful thinking and may seem appealing, but is not based in fact,since all increases in data rates since the history of the internethave shown that more, and not less, data traffic usage and occupancy occur whenthe data rates are increased (this is called Parkinson’s law - think of AOL inits early days, as dial up speeds increased from 1200 bps to 4800 bps, etc,when many more users and applications began to use the service). There must bea limited sliver of spectrum within the RTTY/Data HF segements for this everexpanding data traffic – its irresponsible to allocate the ENTIRE RTTY/DATAspectrum for bandwidths that are more than 200-500 Hz wide. They must becontained, given Mr. Silver’s observation of interference. Ted Rappaport, N9NB Prof. Rappaport visited the FCC during the comment period and pointed out numerousissues and potential solutions. His presentations were clear about existinginterference, existing violations and encryption problems that Pactor IV wouldperpetuate, as well as illuminating the clear interference that wideband datawould have on existing CW and RTTY operations in the lowest 50-100 kHz of eachHF/MF amateur band. He made convincing arguments of how and why the FCC shouldprotect narrowband (CW/RTTY) users with a regulation on emission bandwidth of200 Hz in the lowest portion of each HF/MF RTTY/Data band, and increase theregulation on bandwidth to 500 Hz in the upper part of the lowest 100 kHz ofthe HF/MF RTTY/Data bands. He points out a sensible way forward for the Commission of providing asmall part of the existing non-WARC bands for 2.8 kHz data, where such widerband data could exist at 100 kHz above the lowest band edge on each non-WARCHF/MF band. He shows that this is directly in line with generally acceptedpractices around the world and in many world governments, including Japan whichhas the largest amateur radio population. His presentation points out national security concerns with encrypteddata, and illustrates massive violations that occur today from the small numberof ACDS stations. He asked the FCC to address this before granting any rulechanges that would allow more encrypted data or internet/email traffic onHF/MF. https://www.fcc.gov/ecfs/filing/10925839109476 https://www.fcc.gov/ecfs/filing/1092719005718 Norman Douglas Grant K1DG https://www.fcc.gov/ecfs/filing/1011223992722 Mr. Grant makes clear the need for all data stations toprovide identification, and the critical need of the FCC requiring a “ listenbefore transmit” feature due to proven interference which he has suffered. A largenumber of other commenters provided similar observations in RM-11708. Mr. Grantdiscusses the lack of etiquette of data stations, and the clear need mitigateinterference by the FCC adopting and regulating Band plans similar to IARU, butwith the force of law. https://www.fcc.gov/ecfs/filing/1011120327463 The ARRL, in its comment to the NPRM on October 11, 2016, https://www.fcc.gov/ecfs/filing/1011120327463/document/1011120327463a567 agreed thatinterference to narrowband signals is an absolutely valid concern and certainresult of the FCC proposal, and stated that the ARRL attempted to strike abalance with a 2.8 kHz bandwidth limit for the very narrow HF/ MF allocations. TheARRL never gave any proof why its 2.8 kHz proposal should be selected, or whyit’s the ‘right’ choice, and in fact is very clear in its comments about thelarge concern it has about interference without some bandwidth limit. The ARRLalso concedes that narrowband operators have a very valid concern. This aloneshould demonstrate the requirement of the FCC to protect the narrowband 200 Hzmaximum bandwidth limit by regulation, as well as providing protection for 500Hz maximum bandwidth operations, in the HF MF bands. In fact, nothing in theARRL comments speak directly against providing a more narrow bandwidth at otherportions of the spectrum as so many of the filers have urged for in theseproceedings. The FCC must see the ARRL response as a clear admission of thevalidity of the cries of the vast number of commenters who urge for regulation as recommended by all global IARU regions. Infact, the ARRL changed its tune from its original RM-11708 petition, andacknowledged and embraced the plight of incumbent CW/RTTY/Narrowband operatorshaving to endure large amounts of interference in its comments to NPRM 16-239, a notable and welcomeddeparture from its complete lack of acknowledgment of the interference offeredup in its initial RM 11708 filing in November 2013. Still, however, the ARRLhas not acknowledged or discussed the continuing FCC Violations and lack ofstation ID,Listen before transmit, or control station monitoringand out of band ACDS operation that occurs today with the relatively smallnumber of stations that use ACDS or the Pactor 3/Pactor 2/Winmoor 1600signaling protocols that are encrypted and unintelligible to FCC and officialobservers. This alone should heighten the urgency for the FCC, and notARRL or another private organization, to regulate data to a limited subband inthe non WARC HF/MF bands, where the data signals have wider emission bandwidthsthan the vast majority of CW / RTTY stations. ARRL highlights the EmComm value of STANAG and Pactor 4,but makes an incorrect assumption that many commenters do in assuming thatfaster data rates would lead to less time occupancy on the air- this is wishfulthinking and designed to seem appealing, but is not based in fact, since all increases in data rates since the history of the internethave shown that more, and not less, data traffic usage and occupancy occur whenthe data rates are increased (Parkinson’s law), when many more users and applications began touse the data services. ARRL also does not point out that Pactor and WINLINK areprimarily used for email and Internet browsing, and not for emergencycommunication. Amateur operator Kenneth Talbot offered up a quick post about needing 200Hz/ 500 Hz bandwith limits and requiring all signals to be published/open Jim George, N3BB, filed a mailed reply illustratingParkinson’s Law, how data usage alwaysexpands never contracts, thus contradicting argument by the few people in favorof NPRM and RM-11708, and RM-11759. In summary, I urge the FCC to realize the gravity of its NPRM,and the vast rejection of RM-11708. The amateur radio service requires the FCCto solve existing ACDS and encryption issues, and to ensure narrowbandoperations (200 Hz for JT31, PSK31, CW) and 400/500 Hz (RTTY) are protected asmany governments and the IARU require. These existing IARU and governmentalprotections provide generally accepted standards for the FCC to follow. Sincerely, NAME AND CALL SIGN
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