Proposed Rule Change Bad for Amateur Digital Communications

[Radio]

According to information I recieved in email today, there is a petition before the FCC that will negatively impact digital modes on the HF bands by limiting emissions to 1.5 KHz.

We have until Jan 1 2008 to respond.

Here is the "cover sheet" for the partition:

http://fjallfoss.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6519820340

Please read RM-11392 . and make comments to the FCC. Here are the steps.

Read the 1st part of the partition:

http://fjallfoss.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6519008574

RM-11392 part 1

Read the second part:

http://fjallfoss.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6519008575

RM-11392 part 2.

Use this web interface to enter your comments:
http://fjallfoss.fcc.gov/prod/ecfs/upload_v2.cgi

For your convenience, respectful but negative comments follow, you may cut and paste them into the comment box of the above form.

1. I oppose the RM-11392 petition!

2. The RM-11392 petition is very bad for the Amateur Radio Service.

3. The RM-11392 petition seeks to destroy digital data technology
advancement in the Amateur Radio Service.

4. The RM-11392 petition's proposed 1.5kHz bandwidth limit on data
emission is too narrow for established international standard
transmissions and equipment bandwidths used by the Amateur Radio Service.

5. The RM-11392 petition is an attempt to kill innovation, technology
advancement, and emergency data communications in the Amateur Radio
Service. Please do not let this happen.

6. The FCC Amateur Radio Service's automatically controlled data
sub-bands are already too narrow for the huge volume of traffic that
runs on them. If a limit of 1.5kHz bandwidth is applied, it will
severely hamper the ability of amateur radio operators to share these
small band segments efficiently through rapid data methods.

7. There is a huge installed base of Amateur Radio Equipment, and
millions of dollars of monetary investment by thousands of Amateur
Radio Operators that use HF digital data systems with more than 1.5kHz
bandwidths. This investment by FCC-licensed operators would be taken
away or rendered useless if the objectives of the RM-11392 petition
were to be adopted.

8. Several of the primary established HF emergency communications
networks currently in service and utilized by thousands of Amateur
Radio Operators in USA would be totally eliminated or hobbled if the
objectives of the RM-11392 peteition were to be adopted.

9. The Amateur Radio Service relies upon international communications
standards. Many of the present digital data communications standards
require bandwidths in excess of 1.5kHz. The normal amateur radio
service bandwidth limit by governments of other countries is 6kHz.

10. Thousands of licensed Amateur Radio Operators would be
disenfranchised if the objectives of RM-11392 were to be adopted.

11. The RM-11392 peteition is comparitively similar to an Analog
Cellular Phone service entity trying to eliminate newer Digital
Cellular Phone service. The fact is, Amateur Radio is now using faster
time-multiplexing digital methods to enable more stations to
efficiently use the same frequency channels simultaneously or in rapid
succession. These time division techniques require at least 3kHz of
bandwidth.

12. RM-11392 peteition has not presented a compelling need to change
the rules for Automatically Controlled Data Stations on the HF bands.

[Manual Garcia O'Kely]

I'll have to take a closer look at this, but at the moment it looks like an attempt to introduce some regulations to reduce problems created by automatic stations.

Seems specifically targeted towards WinLink HF.

[wa8yxm]

I too agree that I will need to take a closer look. 1.5KHZ.

Since I do a lot of PSK-31 when it is warm enough to not need a heater in the MH (Or when I'm living in it) the Shack Computer, which is my log, among other things, is always running, and it's usually running either DigiPan or HamScope, both of these give me an audio analyzer function (I normally use the waterfall display) Most SSB transmissions light up to around 2Khz on the waterfall, some a bit higher, some a bit less (i'm about 1.7Khz myself) so this would SERIOUSLY impact SSB transmissions

However since when I run PSK I only light up 31 Hz of the bandwith... It would have no impact at all on that digital operation, Even MFSK 16, and RTTY only use a small portion of the waterall (Hamscope's waterfall is only 2.7Khz wide, (2756 on this machine) Digipan's goes to 5KHz or there abouts.

I do not see how this 1.5KHZ limit would affect Digital modes at all. It would however affect both SSB and AM Seriously affect AM which can easily be 5KHZ wide

[Manual Garcia O'Kely]

Well, I read the first part, up to the point of the technical description of Pactor III.

Well, he wants to restrict the variable bandwidth of Pactor III operation, and further restrict unattended station operations for running WinLink/AirMail.

Overall, it seems pretty sensible in that it does not eliminate the mode, only restricts P III to a controlled bandwidth of 1.5K. That is the only system restricted - RTTY, Amtor, PSK, QPSK all meet this requirement.

His arguement about the automated nature of P III [which if you did not know, uses MORE bandwidth as conditions improve - so as propogation gets better, more and more stations will overlap] makes a fair bit of sense, particularly when accompanied by users who cannot verify adjacent frequency intereference prior to use of expanded bandwidth.

I'm not sure how I feel about this idea. I'm personally not a huge digital user and don't use WinLink or P III at all. I have no idea why I would want to use my HF radio to send e-mail, which seems to be the primary purpose. Given that even HF e-mail service is available commercially at very low cost, I see no compelling reason to permit it to run unrestricted on Amateur bands. Because there is no way to prevent or monitor commercial activity taking place in these communications IMHO it violates the spirit, if not the letter, of our regulations.

Well, we will see if this petition gets any traction.

[w7wv]

Did anyone notice besides me that the poster said we have until Jan 1, 2008 or respond?
I think we are too late or did he mean 2009???

[Radio]

The information I received stated Jan 1, 2008. I posted the information as I received it. And for the record, I don't know enough about it to really have an opinion...I guess I posted it here hoping people who were smarter than me would handle it. But yes, the time to comment is passed.