Docket RM-11708 – Amendment of Part 97 of the Commissions Amateur Radio Service Rules.


Regarding the filling of comments opposing RM-11708

This is a response to comments sent from one of our members.  Make sure you send your comments to both email address.

The FCC is about to make this officially law, but is taking last ditch comments from now (up until October 5th or so) and then during a one month “Reply to Comments” phase. this is our LAST CHANCE to really get the base of CW/RTTY users to write in to ARRL and FCC officials to modify this law…. NPRM RM 11708 cannot be repelled at this point, only modified, unless a miracle occurs and ARRL recinds it – not likely unless tens of thousands of us write to ARRL officials while also filing comments.

Here is what RM 11708 will enable, if it is passed into law as the FCC is proposing in its NPRM 11708 published on July 28, 2016. Note the FCC ignored ARRL’s request for a 2.8 kHz bandwidth to replace the 300 baud limit, and instead is proposing an **unlimited** bandwidth limit with no baud rate limit. Unfortunately, neither the ARRL or FCC have recognized the resulting interference that will occur to the narrowband CW and RTTY users, and have never once considered a 200 Hz bandwidth emission limit on the lower 50 kHz and 500 Hz emission bandwidth limit on the lower 100 kHz of every HF band (That is what is needed for protection, and we must write in by the tens of thousands!!! To ARRL and to FCC! See footnote 37in their July NPRM, very short shrift given to this argument!). Here is what will happen if CW/RTTY apathy continues:

1. SSB and other voice operations will be freely allowed in all the CW/Data/RTTY segments of HF with unlimited bandwidth, as long as the signals are digitized into data first. This NPRM opens up digitized voice to the CW/RTTY lower end HF bands — digitized voice using 12.5khz c4fm stations will be allowed, since the FCC has not proposed a bandwidth limitation. And this is not a conspiracy theory, its real.

2. If the rule passes without any bandwidth limit, or with the ARRL’s suggested 2.8 kHz bandwidth limit on the low end, Pactor 4 will be permitted and conversations will be encrypted as part of the protocol. And if there were to be a way to listen in, it’s going to require a the purchase of a Pactor 4 modem which is not cheap. Meaning you have no ability to identify the call sign of a station short of engaging in a Pactor 4 based conversation. No way for OO’s to find offending station since no CW id is needed.

3. A lot of the Automatic Data stations (the auto repeaters that are already causing great QRM) are tied in with the watercraft and boating crowd. Which means the stations would ring the coastline using new data services in the CW/Data part of the band to log into Facebook, check weather, and make dinner reservations. So unless you are beaming north, you are going to be pointing toward one of those stations.

4. At about 2.4 Khz per station for Pactor 4, and with MANY more stations active (the P4 speeds make email via HF a lot faster and less painful, which will drive more users after this NPRM is legalized), it won’t take much to swamp all the traditional RTTY segment. That pushes the RTTY guys down into the top of the CW segment. And not to even mention digitized voice signals that will be allowed there, too!

No matter how you slice it, even with voluntary band plans, this means trouble for the RTTY operators right up front, and more congestion for the CW bands as a result. Of course, the SSB guys successfully defeated essentially the same proposal 10 years ago (ARRL TRIED TO PASS RM 11306 in 2005, but rescinded it in 2007 because the SSB operators made enough noise to get the ARRL to pull it from the FCC consideration—Check out RM 11306 and — CW and RTTY apathy has failed to make enough noise, and now this is about to become law). It has gone too far, and CW/RTTY people have not been heard, and this is about to remove the enjoyment of our bands forever! Please get active. This is real. Please don’t take this lightly and do nothing, please get your CW/RTTY friends engaged. Read the NPRM! See Footnote 37. See what the FCC is about to sign into law. You only have 2 months to move the ARRL and the FCC to modify this rule.

Lets give Pactor 4 and Winlink its due at 100 kHz and above from the low end of HF, but lets also preserve the lowest 50 kHz for CW and lowest 100 kHz for RTTY by urgently requesting bandwidth limits that preserve CW and RTTY.

Tell your ARRL official and write in to the FCC about the need to have narrow bandwidth protection in the low end of HF if they remove the 300 baud rate — we need tens of thousands of thoughtful responses! I am copying Brennen Price, ARRL’s CTO and PVRC member, here. And I hope you and others will similarly write him and all ARRL officials while you submit your short, focused comment to the FCC on RM 11708 and WT 16239 to seek interference protection on the low part of HF, as well.

What we are asking you to do is to contact the FCC and express your opinion of this proposed rule. We have until October 11, 2016 to submit comments and reply comments by November 10, 2016.

AA4CB Chris

Hello. I live in Ridge Manor and have been licensed since 1988. I serve GCARC as a board member, Public Information Officer (PIO) as well as the club's webmaster and social media manager. I also try to maintain the Clubhouse. I operate mostly the Digital modes on HF such as FT8 ,PSK, and OLIVIA. On VHF/UHF I stay on Yaesu System Fusion locally. I have been doing presentations for local clubs about WIRES-X and Fusion for the past couple of years.