View Full Version : FCC activates the Bandwidth process
wb6bnq
01-05-2006, 11:48 PM
<span style='font-size:17pt;line-height:100%'>FCC activates the Bandwidth process !</span>
The first proposal, submitted by the Communications Think Tank group on the June 20, 2005, has been assigned the Rule request number <span style='color:RED'><span style='font-size:21pt;line-height:100%'>RM-11305</span></span>.
The second proposal, submitted by the ARRL on November 4, 2005, has been assigned the Rule request number <span style='color:RED'><span style='font-size:21pt;line-height:100%'>RM-11306</span></span>.
These two requests are very different in their nature and deserve careful reading before making comments. #They <span style='color:blue'>DO NOT</span> achieve the same results and each has its drawbacks. #What advantages, #if any, are totally within the eye of the beholder.
A long time ago a novel was written dealing the American experience as observed outside of the U.S. that still has merit today. #That novel was titled “The Ugly American.” #In our dealings with these two proposals, “<span style='color:red'>WE</span>” should be mindful of the issues covered in that most revealing novel. #The U.S. Amateur radio operator has a tendency to view the hobby, as it relates to the U.S. rules, as a singularity. #“<span style='color:red'>WE</span>” tend to neglect how our efforts affect the rest of the world.
Bill.......WB6BNQ
Quote[/b] ]<span style='font-size:15pt;line-height:100%'>Quote[/b] (wa3vjb @ Jan. 09 2006,16:14)]Hi Bill,
Thanks for drawing attention to the FCC's recent decision to assign Rule Making numbers to two Petitions that seek to change the way we coordinate our activities on HF.
There is no reference to bandwidth as a method of coordination proposed by the Communications think tank.
Would you please consider changing your headline ?
Thanks,
Paul/VJB
Hi Paul,
Yes, I see your point. #However, whether you like it or not, your petition will be tainted in that respect as it will be inescapably tied to the ARRL submission. #By virtue of the fact that your submission is in effect non-mode based, it becomes a bandwidth based process in that your submission is asking for all bandwidths to have access to all of any particular Amateur allocation, albeit, segmented by class of license. #This tainted aspect is not "all bad" per se.
Why do you think the FCC did not process your submission before this point ? #Clearly because it was waiting for the ARRL submission. #Usually the FCC favors the ARRL direction for a number of scabrous reasons. #This may be giving the FCC way too much credit, BUT perhaps this time they want to contrast yours to even the playing field. {<span style='color:green'>now about that bridge I have for sale</span>}
Even though you make "<span style='color:blue'>no reference to bandwidth as a method of coordination</span>," <span style='color:red'>neither does the ARRL</span>. #Although, the ARRL does make a statement that they are preparing a "Band Plan" to be submitted later, it is deliberately left out of their proposal. #Interesting wouldn't you say ?
The ARRL partitioning of the Amateur allocation based on bandwidth, in essence, is just the <span style='color:red'>flip side</span> of the mode-based counterpart that we currently use. #It is hardly any different then partitioning by mode because the bandwidth is, in effect, based on the mode of operation. #<span style='color:green'>In the aggregate, your proposal is not really that much different</span>. #The difference is basically on how the segmentation of the Amateur allocation is done. #Your proposal "<span style='color:blue'>seems</span>" to be free of spurious intentions, something that cannot be said for the ARRL proposal.
<span style='color:blue'>I see, still, that your group did not correct the frequency chart, even though some serious mistakes were made and pointed out to your group. #This will probably be a major stumbling block for those commenting on your proposal</span>.
My biggest complaint with the whole mess is that none of it was handled properly. #With both groups there were not enough respectable research and review done. #I can, to some degree, understand your small group and its constraints. #The ARRL's efforts are obviously skewed and fully biased to a specific agenda. #I don't think your group suffered from that affliction. #However, for both groups, the biggest failing was not soliciting, <span style='color:red'>in a most accurate manner</span>, external input from the entire "licensed" Amateur population.
Through computerization and the World Wide Web, it would be easy to set up a process where each "Licensee" could place his vote to a series of <span style='color:blue'>highly skilled and properly</span> written questions. #There are methods to verify and control the process so that the licensee could "<span style='color:blue'>vote</span>" <span style='color:red'>only once</span> and thereafter, be allowed, for a certain time, to correct his submission.
Alas, neither group took the high road, so both will be viewed with skepticism. #I truly fault the ARRL, way more so then your group Paul. #Why ? #Because they claim to represent all of the Amateur licensees, yet they have never, ever been forthright in their efforts. #Quite the contrary, for they have deliberately acted in calculated ways to subvert their true intentions and then have the audacity to even say so in print.
I know you feel slighted by my headline. #However, I am not persuaded that it maligns you or your group, or detracts from the intent and nature of your proposal. #Rather, I feel that it draws the proper attention to both proposals, as they are entwined in ways that cannot be divided.
73.....Bill.....WB6BNQ
</span>
Let the real decisions begin, freedom or despotism. Break down those walls!! Freedom and responsibility!
-ap
A link to the Notices would be nice. Also, a link to make comments would be OK when and if available.
kb3mng
01-09-2006, 06:09 AM
Quote[/b] (W0MT @ Jan. 08 2006,20:39)]A link to the Notices would be nice. Also, a link to make comments would be OK when and if available.
Home of the Electronic Comment FIling System:
http://www.fcc.gov/cgb/ecfs/
You can find everything from there. Look at the upper right of the screen for links for search for comments, file comments, and proceeding history.
If you click "search for comments", you'll see a place to enter a proceeding number. That will find the comments that other people have made, but if you click on the word "proceeding" you will come to a form that can look up the original document.
I've noticed the query engine seems to be pretty hosed this weekend. If you make a query and get "Server Error", your best bet is just wait a while and try later. Based on my general experience with managing systems like this, it will generally either fix itself within an hour or two, or it will remain broken until somebody comes to work in the morning and figures out what is wrong.
wa3vjb
01-09-2006, 11:08 PM
Despite the "headline" from Bill, WB6BNQ, the CTT's petition is mute on the matter of coordination by bandwidth, and was written by a small group active on digital modes, SSB, CW and AM.
I've asked Bill to consider re-wording his headline.
It seeks to discontinue mandatory, full-time segregation by mode, in what Petitioners believe will be an affirmative way to de-regulate and improve the utilization of spectrum.
It travels independently of the bandwidth-based regulatory scheme the group in Newington wishes to impose. The ARRL proposal is not mentioned in the CTT's Petition.
One thing both proposals have in common is that they each were widely discussed here on QRZ.com. Please check the archives for some interesting support and criticism.
Paul/VJB
<FONT FACE="times new roman" size="+15" color=red>
OH MY GOD! #WHAT DO WE DO NOW?</FONT>
Since I did #not read the "Ugly American", should I be worried?
K2WH
kh6ty
01-10-2006, 04:19 AM
Quote[/b] (wb6bnq @ Jan. 05 2006,16:48)]<span style='font-size:17pt;line-height:100%'>FCC activates the Bandwidth process !</span>
The second proposal, submitted by the ARRL on November 4, 2005, has been assigned the Rule request number <span style='color:RED'><span style='font-size:21pt;line-height:100%'>RM-11306</span></span>.
What the ARRL proposal REALLY says:
1. Eliminate the "cumbersome" FCC process for approving new modes, the STA process, and the public comment period for NPRM's and thereby deprive the radio amateur of his right of due process, currently guaranteed by law.
Does anybody know of the tallied results of bandwidth@arrl.org? The FCC always discloses comments on their NPRM's, but did ARRL disclose just how many approved or disapproved of their bandwidth petition? Of course not! The ARRL CEO would only say that there was "significant" support for the petition, without saying what "significant" was...
2. Eliminate "bothersome" regulations and replace them with bandplans (presumably ARRL bandplans!).
I.e. give the power over where radio amateurs are expected to operate to a few select members of the ARRL Executive Committee - the same committee that immediately granted every request made by Winlink without asking for any public comment.
Is this how you want things to be handled?
3. Eliminate all restrictions on where email robots (such as the Winlink Pactor-III robots), can operate, even anywhere in the phone bands, but be sure phone stations of the same bandwidth cannot interfere with the robot stations by giving them a "safe harbor"!
This was accomplished by sneaking in a total rewrite of Part 97.221.
Did you realize this?
4. Arrogantly expect the whole amateur radio world to accomodate FCC regulations by totally ignoring all restrictions on where email robots ("digimode or 'store- and-forward' stations") should operate that are part and parcel of the IRAU Region 1 bandplan.
I.e., ARRL, HF signals don't really travel worldwide, or across borders, do they! Must not, if you are serious! http://www.qrz.com/iB_html/non-cgi/emoticons/sad.gif #http://www.qrz.com/iB_html/non-cgi/emoticons/rock.gif
5. The future of ham radio is no longer communicating, such as ragchewing with another radio amateur in real time, or contesting, or DX chasing, or award chasing, but using the ham bands as an answering machine and leaving multimedia messages for a friend or for a third party.
Yes, "high-speed multimedia" on HF must truly be the future!
Or is it...Unfortunately, the most advanced error-free high-speed mode for multimedia is Pactor-III, which should blaze along at 225 characters per second, but, according to Winlink statistics, only achieves an average of 15 characters per second on HF in actual use, but takes up five times the bandwidth of Pactor-II, which should blaze along at 50 characters per second, but only averages 10 characters per second in actual use on HF, taking up a bandwidth of 500 Hz, all compared to a much more efficient ARQ mode, PSKmail, which achieves 5 characters per second in a bandwidth of only 100 Hz.
So, Pactor-III uses up a bandwidth that is 25 times as much as PSKmail, but only achieves a speed advantage of 3 times over PSKmail.
"High-speed multimedia" on HF? I'm from Missouri, so "show me" first, ARRL, and make irresponsible statements second...
Before you comment on the ARRL petition, PLEASE read the details very carefully -You might be surprised to find what it really says.
Skip, KH6TY
wa3vjb
01-10-2006, 09:36 AM
Bill, as emailed privately, I accept your interpretation and the connection you see between the two proposals.
As a practical matter, the system of coordination we use on HF has evolved and prevailed over a very long period of time. I believe we can date it back to when the HF allocations were, in those simple days, split roughly 50/50 between CW and "phone" emissions, with an overlay by license class.
It is a nice system that has been cluttered up by amendments to accomodate new modes without re-sizing those portions reserved for older modes now out of scale with their levels of activity. There is also the matter of licensed-based segments of the bands for licenses the FCC no longer issues. But since those segments are not exclusive reservations, our upper-class licensees are able to make use of that spectrum.
The amount of time that has passed shows the durability of the mode-based system, and I believe that it's because of the stability of the longstanding voluntary layout of activities. The concept put forth by the CTT relies on that stability and calls for a relaxation of regulatory constraints so that we may do the re-sizing on our own.
I don't remember you taking part in the extended discussions on QRZ.com and elsewhere, sorry, but I'm glad you now have taken an interest. As one of the Petitioners, I can say with authority that we are receptive to feedback and have cited some of it in the document itself. I'm grateful for your kind comments about our work in comparison to what has been offered by the group in Newington.
According to the FCC Public Notice (http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6518307797) , the formal Comment phase on both these petitions opened January 6th and runs for 30 days. You can expect additional fine-tuning, corrections, and refinement among the filings.
Best wishes,
Paul/VJB
wd8bil
01-10-2006, 12:48 PM
Quote[/b] ]These two requests are very different in their nature and deserve careful reading before making comments.
Quote[/b] ]Rather, I feel that it draws the proper attention to both proposals, as they are entwined in ways that cannot be divided.
Which is it Bill ? Having "very different" natures makes it hard to be "entwined".
If, as you say, both offerings fall far short of what is needed then I ask you to tell us all what is needed. Or is the status quo your solution ?
wd8bil
01-10-2006, 01:17 PM
WB6BNQ wrote:
Quote[/b] ]That novel was titled “The Ugly American.” #In our dealings with these two proposals, “WE” should be mindful of the issues covered in that most revealing novel. #The U.S. Amateur radio operator has a tendency to view the hobby, as it relates to the U.S. rules, as a singularity. #“WE” tend to neglect how our efforts affect the rest of the world.
From The CTT document:
Quote[/b] ]This proposal also provides for better international coordination of amateur frequencies. IARU (International Amateur Radio Union) acknowledges the need for greater cooperation and coordination of the increasing and changing usage patterns of the amateur HF bands. De-regulation of usage, and flexibility to accommodate changing demand, is a principle goal set forth in band planning discussions. (See IARU HFC-C4, 13 November 2002). Our proposal also aligns U.S. amateur radio operator privileges with the rest of the world. Communications authorities in many countries rely on amateur service licensees to achieve better spectral efficiency through voluntary band plans.
Among those countries, our Canadian neighbors provide an excellent example of voluntary band plan success. Canadian phone operation coexists quite well with U.S. operators in the current U.S. CW/Data sub bands.
So you see, we know we do not live in a bubble. We've considered the International impact of our offering and attempt to bring U.S. allocations inline with the rest of the world.
Indeed there will be supporters of the ARRL and/or CTT proposals who are truly invested in the greater good of amateur radio. Of course, there are those who will support or oppose on principle and I respect that as well.
Again, we see the spectre of digital or phone anarchy raised and again I reply: The CTT proposal is based on the concept of less mode based regulation and a shift of some of the resources currently policing mode based regulations to enforcement of the non interference regulations currently on the books. This applies to human, animal, vegetable, mechanical, or silicon based life forms, and whatever mode and automation status of any transmission. If they have a US amateur radio license they will be required to avoid interference with communications in process.
I see no reason to leave spectrum unoccupied and subject to incorrect assessments by other services that it is unused. I see no reason to leave exclusive sections of the amateur bands allocated to specific modes that don't occupy the allocation when other mode allocations are crowded. I see no reason to restrict the majority because of a minority who will not follow regulations in any case.
Some "exclusivity" would still exist, if that is important to you, in the license based sub bands as incentive (no, I don't even want to go to the incentive licensing discussion) for those holding more advanced licenses.
Amateur radio operators have been recognized and respected as the gentlepeople of hobbyists from the perspective of those in the hobby and those observing our activities during communications emergencies, etc. etc. I believe this recognition is correct and we can conduct ourselves properly . . . particularly if the FCC is recognized by the licensees as stepping up enforcement of non interference regs.
OK, so you have my opinion and you can take it or leave it. However, now is the time to hammer out a band plan.
My partners in the CTT are probably thinking, Oh . . gee, there goes Art . . . again.
However, I have done a 5 month band occupancy study (similar to my short term study presented in the CTT proposal) and find that the following occupancy exists CW~30%, Digital (all types) ~ 10%, and Phone ~ 60%. One of my discussion partners has suggested the gentlemans agreement need be no more complex than this three section plan. It would create a plan much like 160M is today, reasonably well aligned with the rest of the world, with segments of the band recognized as primarily occupied by a given mode but not exclusively occupied by it. Yes, this all goes out the window when contests occur . . . we aren't going to change that . . . So what do you think? Ideas, input? Now is a good time to thrash this out and be ready when the time comes so we can define our own plan vs others who may represent a small percentage of amateur radio ops or other interests entirely. . . .
Art
Thumbs DOWN to both ARRL & CTT proposals.
All those guys are seeking remedy for a malaise that hasn't been satisfactorily identified!
If it ain't 'broke'...
Inept as FCC has proven to be, I'd rather FCC administer amateur regulations, bandplans, licensing etc with little input from those other guys!
Thumbs UP to status Quo!
Quote[/b] (n4qa @ Jan. 10 2006,12:06)]Thumbs DOWN to both ARRL & CTT proposals.
All those guys are seeking remedy for a malaise that hasn't been satisfactorily identified!
If it ain't 'broke'...
Inept as FCC has proven to be, I'd rather FCC administer amateur regulations, bandplans, licensing etc with little input from those other guys!
Thumbs UP to status Quo!
I really hope we can muster a more reasoned response to these plans than this. The status quo is in the way in many cases. There must be room for change!
The problems these plans have been debated extensively already including maintaining the status quo. I think result of all the debate to date has been the identification of a problem. There is a lack of trust between amateurs that we can live together and develop for the future. The DX players don't trust the rag chewers, the digital people do not trust their peers using different modulation or coding schemes. The phone people do not trust the digital people. What a mess.
We tend to compare out best practice to those of our international partners while forgetting that many of them are no larger than a state in our country. It is a simple matter for a small government to allow for their amateurs to self regulate while it is a major problem for us. We are just too diverse a group.
My view is simple:
1.) Band planning is a must and it must have teeth.
# # #a.) We need a coordination organization.
# # #b.) We need enforcement
# # #c.) We need cooperation from FCC
# # #d.) We need mature behavior by all parties.
2.) We need to be sure that the most pervasive digital mode #is provided with sufficient space that those that use it are not tempted to migrate into those areas where phone activity traditionally dominates. They will cause severe interference and make a congestion problem worse.
Neither of these plans adequately address these concerns, but together they come close.
Why is the status quo unacceptable for the future? Well, the most compelling reason is that many commerical interests including BPL are looking closely at our our unused spectrum with envy and the FCC is looking for ways to shoe horn into all spectrum various interests that would be compatible sharing partners.
We must make better use of our spectrum and this means digital as well as traditional analog uses. Like it or not, digital is the wave of the future and we need to be ready to welcome it not restrict it.
How do I plan to comment, you might ask? Well, I have already commented on this in a number of the previous debates on this subject and I have contributed my thoughts to my League Officials. Now, I get my turn to make the comments that I think will stick. I agree in principle with the idea of segmentation by bandwidth. This has been my position from the beginning. The 4 items above about band planning are what I think need to be enacted in the regulations and/or acted upon when appropriate regulations have been enacted. The rest of the problem concerning maturity, I can not comment on. I comply with band plans and regulations and will continue to comply.
BTW, I have no axe to grind concerning digital modes. I'm mostly a QRP/QRPp CW operator and plan to continue this persuit. Should I move to digital, it will likely be to PSK31 because of narrow band factor that makes QRP/QRPp work effective by reducing the bandwidth and thus inproving the signal to noise ratio over other digital modes and even CW.
I'm finished, now let me put on my flame retardant garments. Have fun.
Ken
n7spy
01-10-2006, 07:34 PM
'BNQ is running a little late.
The Think Tank's Petition (http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6517982317) was assigned RM-11305 on June 20th of last year.
The ARRL's Petition (http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6518181567)) was assigned RM-11036 on November 14th of last year.
Read the proposals and save your time/effort for where it matters: the FCC. File your comments there, where they'll be seen by the rulemakers.
AE1X:
My view is simple:
1.) Band planning is a must and it must have teeth.
# # a.) We need a coordination organization.
# # b.) We need enforcement
# # c.) We need cooperation from FCC
# # d.) We need mature behavior by all parties.
<hr size=15 color=purple>
Surely you jest. #Band plan yes. #The rest is a pipe dream or an invitation to disaster.
<table border size=15 bordercolor=purple><td> a) Coordination organization: Wrong. Look what happened to repeater committees, infighting and political activism.<td><tr><td> b) Enforcement: The FCC is basically a paper tiger when it comes to amateur matters. #Just read about how long the FCC took in some recent convictions.<td><tr><td> c) Cooperation from the FCC: #Wait, I'm still laughing.<td><tr><td> d) Mature behavior: #From who? #The FCC or amateurs? #Either way, you won't get it.</table>
K2WH
wb6bnq
01-10-2006, 08:43 PM
Quote[/b] (n7spy @ Jan. 10 2006,12:34)]'BNQ is running a little late.
The Think Tank's Petition (http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6517982317) was assigned RM-11305 on June 20th of last year.
The ARRL's Petition (http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6518181567)) was assigned RM-11036 on November 14th of last year.
Read the proposals and save your time/effort for where it matters: the FCC. File your comments there, where they'll be seen by the rulemakers.
Please Alvin,
Don't embarrass yourself. #Those dates are when the material was received by the FCC. #At that point they sit in a basket (so to speak) waiting for action. When the FCC is ready to deal with them, if ever, then they get assigned a Rule Making number. #That was done on the 6th of Jan 2005.
Please reference the following assignment notice :
http://gullfoss2.fcc.gov/prod....8307797 (http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6518307797)
And here is the "BASKET" from which these proposals sat until being dealt with. #You will notice that all the ones still in there are all titled "PRM05WT" which stands for
PRM = Proposed Rule Making
# 05 = year received (2000+ assumed)
#WT = Wireless Telecommunciations Bureau.
http://gullfoss2.fcc.gov/cgi-bin....PRM05WT (http://gullfoss2.fcc.gov/cgi-bin/websql/prod/ecfs/comsrch_v2.hts?ws_mode=retrieve_list&id_proceeding=PRM05WT)
Bill....WB6BNQ
I AM AGAINST BOTH. NOTHINGS BROKE. WHY TRY TO FIX SOMETHING UNBROKEN....
Paul,
With no reference to bandwidth or mode segregation in your proposal, what would prevent a digital signal of 250kHz on 20 meters if the band is "clear"?
Quote[/b] (K2WH @ Jan. 10 2006,15:40)]AE1X:
My view is simple:
1.) Band planning is a must and it must have teeth.
# # a.) We need a coordination organization.
# # b.) We need enforcement
# # c.) We need cooperation from FCC
# # d.) We need mature behavior by all parties.
<hr size=15 color=purple>
Surely you jest. #Band plan yes. #The rest is a pipe dream or an invitation to disaster.
<table border size=15 bordercolor=purple><td> a) Coordination organization: Wrong. Look what happened to repeater committees, infighting and political activism.<td><tr><td> b) Enforcement: The FCC is basically a paper tiger when it comes to amateur matters. #Just read about how long the FCC took in some recent convictions.<td><tr><td> c) Cooperation from the FCC: #Wait, I'm still laughing.<td><tr><td> d) Mature behavior: #From who? #The FCC or amateurs? #Either way, you won't get it.</table>
K2WH
I do not JEST here and I believe that we either improve our behavior or we can kiss our beloved hobby good bye!
Look, I know the FCC is a paper tiger, but will it remain such? Might a change in the administration have some effect?
I don't think the repeater coordinators are that much of a failure. In fact, for the most part they do the job and do get support from the FCC, especially from Riley.
Concerning the length of time it took to get that bad apple, it took that long because it took that long to get him for a really serious Federal Offense. The other stuff on our bands is small potatoes. Amateur enforcement on the other hand is handled more quickly in and of itself.
The band plan must have some teeth or the disaster you fear will happen.
The mature behavior must come from all interested parties!
Is it you position that we should keep the present system? I fear that the old plan is not in keeping with the stated goals of this Commission. They are intent on deploying systems that are more spectrally efficient. Each Khz must be utilized in such a way that it provides the largest benefit to the public. Their measure has a lot to do with how much revenue is generated. We must begin developing new ways to get things done so that any developments we come up with can be measured monetarily so it will register with this Commission.
What can be done to present this type of case? Well, for one thing we can develop better protocols, better modulation schemes, better antennas, better receivers optimized for digital signaling, and list can go on from here. Once this is done, we can move our ideas into the market place if they have sufficient merit. This is what amateurs did in the past.
What content should these streams contain? This will be determined by the need. There is a specific need for moving emergency traffic from disaster sites in a secure and efficient manner. WL2k is the method preferred by the League, but this could be changed should we develop something better at a more reasonable cost. Whatever happened to the SCAMP protocol? Could it be that it disappeared because it might compete with PACTOR III? I don't know the answer to this, but I could see SCAMP as a reasonable alternative to PACTOR III and it takes slightly less bandwidth.
During the initial stages of a disaster, the public wants to know what is really happening. The development of an appropriate scheme to get images out of the disaster area as early as possible could be another area amateurs could make a contribution to the advancement of our art.
I'm sure that there will be other new ideas that will impact our hobby. This proposal would facilitate such developments without the requirement for us to get an STA to achieve our goals. The experiments could be conducted and the results made available earlier in the development process to get the needed attention for an idea and get people to participate.
Amateur radio can not continue to exist as it has in this environment without the continued backing of the FCC. This backing will disappear unless we take some action to show that we are ready and willing to look to the future, a future that may be very different from our past, but a future none the less.
Ken
ab0wr
01-11-2006, 01:39 AM
Quote[/b] ]
ae1x:
Why is the status quo unacceptable for the future? Well, the most compelling reason is that many commerical interests including BPL are looking closely at our our unused spectrum with envy and the FCC is looking for ways to shoe horn into all spectrum various interests that would be compatible sharing partners.
We must make better use of our spectrum and this means digital as well as traditional analog uses. Like it or not, digital is the wave of the future and we need to be ready to welcome it not restrict it.
Unused spectrum? On HF? I don't think so.
VHF, maybe.
UHF, probably.
Why then does the ARRL put out a proposal that has the biggest impact on HF?
Digital is the wave of the future?
Doubtful. Very doubtful.
I've talked to some old timers on RTTY. Now this is purely subjective but they don't see any more digital usage than existed 40 years ago when RTTY was king.
I got my station set up to run sound card digital before Christmas and have been doing listening on the bands since then.
I've done three different band surveys on Saturday afternoons. Guess what?
At my location at least, RTTY is STILL the most used digital mode. There is some psk31. The other modes are so infrequently used that people sometimes resort to using the digitalradio mailing list in order to set up schedules.
For the tnc modes, Pactor I, II, III are still the king. I do hear HF packet once in a while but it is not a big contributor.
I have yet to hear a digital voice QSO on ANY band from this location. It's contribution is essentially zero.
Bottom line? I just don't see any spectrum usage studies done by anybody that gives ANY objective data that "digital is the coming thing".
If you want my opinion on why, it is pretty simple.
HUMAN ENGINEERING.
99% of the QSO's on the air are person-to-person. 90% of those are done using voice or Morse Code. The percentage using voice is growing slightly, the percentage using Morse Code is decreasing slightly.
People would rather TALK to someone than TYPE *at* someone.
I give you recently introduced rigs from the major manufacturers as proof. Not a single manufacturer that I know of includes internal psk31 transmit/receive capabilites - even the high end ones with DSP's powerful enough to do this easily. There are a couple of rigs that provide RTTY receive capabiltiy - that's all.
If the manufacturers really thought the digital revolution was going to amount to more than about 10% of the total usage on the ham bands they would be moving to solidify their positions in the market by providing at least basic capabilities. They are NOT doing so.
In other words, this proposal is a solution looking for a problem.
If you want to fix the image transmission problem, then address it by a simple rule change to allow sending DIGITAL images in the digital subbands. QED
tim ab0wr
Bottom line on the bandwidth issue:
You know that nice new rig you just bought? That PRO-III or the FT-dx-9000 or the IC-7800 or the FT-1000MP or the TS-2000?
IT'S OBSOLETE AND USELESS WITHOUT SPENDING MORE MONEY!
DEAL WITH THAT!
(P.S.... I can't!)
W3MIV
01-11-2006, 02:00 AM
Quote[/b] (nk4k @ Jan. 10 2006,20:56)]Bottom line on the bandwidth issue:
You know that nice new rig you just bought? #That PRO-III or the FT-dx-9000 or the IC-7800 or the FT-1000MP or the TS-2000?
IT'S OBSOLETE AND USELESS WITHOUT SPENDING MORE MONEY!
DEAL WITH THAT!
(P.S.... I can't!)
I admit to being dense. I don't follow your logic. Please explicate.
ab0wr
01-11-2006, 02:28 AM
Quote[/b] ]
ae1x:
Is it you position that we should keep the present system? I fear that the old plan is not in keeping with the stated goals of this Commission. They are intent on deploying systems that are more spectrally efficient. Each Khz must be utilized in such a way that it provides the largest benefit to the public. Their measure has a lot to do with how much revenue is generated. We must begin developing new ways to get things done so that any developments we come up with can be measured monetarily so it will register with this Commission.
Ken,
Can you show me a single spectrum efficiency or economic efficiency study done by anyone in the amateur community that shows that digital provides better spectrum efficiency or economic efficiency than analog?
According to the FCC the definition of spectrum efficiency is:
"spectrum efficiency is defined as the ratio of communications accomplished to the spectrum used. This would involve parameters such as information delivered, users satisfied, rf bandwidth occupied, geographical area covered, and the time spectrum is denied to other users. "
Note carefully the metrics "users satisfied" and "time ... denied...".
There are four basic uses of digital modes today:
-Manual transfer of information (i.e. kybd-to-kybd)
-Computer controlled data transfer (e.g. ftp, sstv)
-automatic transfer of data (e.g. email, bulletins)
- digital voice
As discussed in my other message, manual transfer of data will never become a major factor on the ham bands. The majority of people communicate in real time using voice, not keyboards. The digital modes will never be in competition with plain old voice for one-on-one communication so its spectrum efficiency must be considered very low when considering the number of users satisfied.
Computer controlled data transfer will likewise never become a major factor on HF because the transfer rates are two slow compared to the internet. The marginal utility of data transfer by HF is to small to be an economical offering. This will remain a small, small niche.
It's spectrum efficiency is not even an issue because the numbers of users is so small.
Automatic transfer of data such as email and bulletins, if allowed to proceed using inefficient horizontal spread protocols, and this includes SCAMP as well as Pactor, is very spectrum inefficient. In the case of Pactor, the time the spectrum is denied to other users is very, very large since people tend to avoid the spectrum used by the Pactor robots. This tremendously lowers the number of users satisfied for the overall spectrum. And both Scamp and Pactor provide no traffic control mechanisms so that huge amounts of spectrum are required to handle very low traffic loads. A traffic analysis of the load data for Winlink 2000 shows that an efficient system design using a protocol designed for handling traffic could handle the entire WL2K data load with 5 (five) total 500hz frequencies in the HF spectrum. That's one 500hz channel per band on 80m, 40m, 30m, 20m, and 15m. Bottom line? Very spectrum inefficient operation. Keep email on the internet and commercial providers and you will maximize the spectrum efficiency of the amateur spectrum.
And digital voice? Unless you and the ARRL know something I do not, the spectrum efficiency of the digital voice protocols today is very, very poor. It is expensive to implement compared to SSB, is less robust in the presence of noise and QRM than SSB, and actually takes more bandwidth. Unless there are development and manufacturing advances on the immediate horizon that only the ARRL is privy to, it is not apparent that digital voice is going to be a driver causing an "impact of digital communications".
Too many people, including the FCC, speak of the "digital revolution" thinking of the spectrum areas where high rate digital transmission is a reality - i.e. UHF and above. Somehow this gets translated into a digital revolution coming to the HF band nearest you.
Both the ARRL and the FCC need to be disabused of this misconception. It just does not fit reality.
When you take all of the hype out of the equation, the need to "do something" on the HF bands suddenly turns into a lot of handwaving and pronouncements from on high by the Priest-Kings at the ARRL.
tim ab0wr
Quote[/b] (ab0wr @ Jan. 10 2006,19:28)]Quote[/b] ]
ae1x:
Is it you position that we should keep the present system? I fear that the old plan is not in keeping with the stated goals of this Commission. They are intent on deploying systems that are more spectrally efficient. Each Khz must be utilized in such a way that it provides the largest benefit to the public. Their measure has a lot to do with how much revenue is generated. We must begin developing new ways to get things done so that any developments we come up with can be measured monetarily so it will register with this Commission.
Ken,
Can you show me a single spectrum efficiency or economic efficiency study done by anyone in the amateur community that shows that digital provides better spectrum efficiency or economic efficiency than analog?
According to the FCC the definition of spectrum efficiency is:
"spectrum efficiency is defined as the ratio of communications accomplished to the spectrum used. This would involve parameters such as information delivered, users satisfied, rf bandwidth occupied, geographical area covered, and the time spectrum is denied to other users. "
Note carefully the metrics "users satisfied" and "time ... denied...".
There are four basic uses of digital modes today:
-Manual transfer of information (i.e. kybd-to-kybd)
-Computer controlled data transfer (e.g. ftp, sstv)
-automatic transfer of data (e.g. email, bulletins)
- digital voice
As discussed in my other message, manual transfer of data will never become a major factor on the ham bands. The majority of people communicate in real time using voice, not keyboards. The digital modes will never be in competition with plain old voice for one-on-one communication so its spectrum efficiency must be considered very low when considering the number of users satisfied.
Computer controlled data transfer will likewise never become a major factor on HF because the transfer rates are two slow compared to the internet. The marginal utility of data transfer by HF is to small to be an economical offering. This will remain a small, small niche.
It's spectrum efficiency is not even an issue because the numbers of users is so small.
Automatic transfer of data such as email and bulletins, if allowed to proceed using inefficient horizontal spread protocols, and this includes SCAMP as well as Pactor, is very spectrum inefficient. In the case of Pactor, the time the spectrum is denied to other users is very, very large since people tend to avoid the spectrum used by the Pactor robots. This tremendously lowers the number of users satisfied for the overall spectrum. And both Scamp and Pactor provide no traffic control mechanisms so that huge amounts of spectrum are required to handle very low traffic loads. A traffic analysis of the load data for Winlink 2000 shows that an efficient system design using a protocol designed for handling traffic could handle the entire WL2K data load with 5 (five) total 500hz frequencies in the HF spectrum. That's one 500hz channel per band on 80m, 40m, 30m, 20m, and 15m. Bottom line? Very spectrum inefficient operation. Keep email on the internet and commercial providers and you will maximize the spectrum efficiency of the amateur spectrum.
And digital voice? Unless you and the ARRL know something I do not, the spectrum efficiency of the digital voice protocols today is very, very poor. It is expensive to implement compared to SSB, is less robust in the presence of noise and QRM than SSB, and actually takes more bandwidth. Unless there are development and manufacturing advances on the immediate horizon that only the ARRL is privy to, it is not apparent that digital voice is going to be a driver causing an "impact of digital communications".
Too many people, including the FCC, speak of the "digital revolution" thinking of the spectrum areas where high rate digital transmission is a reality - i.e. UHF and above. Somehow this gets translated into a digital revolution coming to the HF band nearest you.
Both the ARRL and the FCC need to be disabused of this misconception. It just does not fit reality.
When you take all of the hype out of the equation, the need to "do something" on the HF bands suddenly turns into a lot of handwaving and pronouncements from on high by the Priest-Kings at the ARRL.
tim ab0wr
Hey Tim,
Stop talking about reality, it is not fun.
With all of the talk about how we better change the rules, and how terrible it is to stay the same, there is one problem.
Where are these wonderful new modes? This same argument has been going around the same circle for over a year. Yet, where are all of the new modes? You would think that there would be something really new, other then a different scheme of modulation for digital HF, that still has the same pitiful transfer rate. Since I have been involved in this debate for two years, my broadband connection at home, has gone from around 600 Kbs to around 5-6 Mbs today.
What is new on HF? Nothing, the same old thing. You can't get speed without bandwidth. HF doesn't have bandwidth.
The RTTY point is quite valid. I remember when PSK came out. It was years ago, but it was obvious that it had advantages over RTTY. Yet as Tim mentioned, RTTY still is, by far, the most used "keyboard to keyboard"
mode.
Why? Because of equipment. It doesn't require as much equipment. Not every ham, has an unlimited budget to buy every stupid new box available.
This argument about the digital narvana seems to leave out the kid that may want to be a ham, but only has a couple hundred dollars for an old boat anchor. Sorry kid, you didn't pay your entry fee to SCS in Gemany.
Some hams use CW with decades old equipment, and are pleased as punch to work some new DX. Some use 5 watts and work the world.
This one cracks me up:
"Is it you position that we should keep the present system? I fear that the old plan is not in keeping with the stated goals of this Commission. They are intent on deploying systems that are more spectrally efficient."
Well if that's the case, then I guess it's going to be "CW Only". If you think that using 25 KHz for a very slow baudrate is "spectrally efficient", then you need to work the numbers.
I am amazed at the amount of rubbish I read about "New Technology" with no supporting data at all.
I'm sure it is great to have a PROIII or an IC-7800, but get real. Do you really think it is that much better then an old TS-940 that you can buy for $600? I like my Mark-V, but I could do 99% of the QSO's with my old Drake TR-4C. Boys and toys, but you don't need a Dodge Viper to drive to work.
We have been so brainwashed with technology BS, that we don't have a clue anymore.
Lets take an example. I have a Drake TR4C feeding a big M2 tribander on a 100 ft tower. You have a shiny new IC-7800 feeding a dipole 20 feet off the ground. You spent $12,000, and I spent $1500. How come I can work more stations?
You can buy all of the radio's, pactor boxes, 5 Ghz PC's in the world, but in the field with X amount of battery power, and over the long haul, I am going to kick your butt with a K1 on CW.
CW is outdated? #There are hams running 5 watts with an Elecraft on CW, that have worked more DX then plenty of hams that have every high dollar rig known to man.
Give it some thought. You may want to consider what is really best for ham radio. I don't believe that Icom, Kenwood, SCS, and Yaesu have a perspective that goes beyond profits.
SCS sure isn't what I would call an open-source company. More like a company that covers the insides of that new rig with epoxy so you can't understand or fix it. Now that's the ham spirit?
I admire the hams that work on PSK and the other soundcard modes, but lets admit it, this proposal is about SCS pactor boxes and Winlink. Is this about profits again?
Please, show me all of this new technology, that uses less bandwidth then CW? I'm still waiting. The only down side to CW, is that you have to learn it. Now that sucks.
But in the new world, why take the effort to learn. Just buy it. And if you don't have any money, then charge it. And if you don't have a charge card, just take out another mortgage on your house. Sure easier then learning something.
73 - Bob
wa4dou
01-11-2006, 04:25 PM
Bravo Bob. Absolutely right on target!
Quote[/b] (ab0wr @ Jan. 10 2006,19:28)]Too many people, including the FCC, speak of the "digital revolution" thinking of the spectrum areas where high rate digital transmission is a reality - i.e. UHF and above. Somehow this gets translated into a digital revolution coming to the HF band nearest you.
Both the ARRL and the FCC need to be disabused of this misconception. It just does not fit reality.
When you take all of the hype out of the equation, the need to "do something" on the HF bands suddenly turns into a lot of handwaving and pronouncements from on high by the Priest-Kings at the ARRL.
tim ab0wr
In the bandplanning issue, the League is like the Japanese soldier they found on a Pacific Island in 1972. He thought WWII was still going on and that his side was winning. Most amateurs don't want 25kHz wide data signals on HF and that's what you'd need under PERFECT conditions to have decent data rates. Most amateurs don't have a sailboat, an RV or a foerign minestery and don't need to send email over HF. Besides, there are commercial companies who do it anyway.
"Digital Revolution" sounds new, cool, progressive, narley, groovy, "the bee's knees", sick, whatever your generation calls "trendy" things. But in truth, the digital revolution happened 20 years ago and passed us by. If we're to be at some bleeding edge of technology again, all someone needs is a dummy load, software defined radio, a fast computer, and great software writing ability. Nothing in current rules prohibits digital experimentation today.
The big egg to crack now is to use less bandwidth, not more. Thus attempts at implementing today's wideband digital technology on HF is like an elephant trying to have sex with a chicken. Fun to watch but not very (re)productive.
Quote[/b] (W6NJ @ Jan. 11 2006,02:46)][QUOTE=Quote ]
ae1x:
Is it you position that we should keep the present system? I fear that the old plan is not in keeping with the stated goals of this Commission. They are intent on deploying systems that are more spectrally efficient. Each Khz must be utilized in such a way that it provides the largest benefit to the public. Their measure has a lot to do with how much revenue is generated. We must begin developing new ways to get things done so that any developments we come up with can be measured monetarily so it will register with this Commission.
Ken,
Can you show me a single spectrum efficiency or economic efficiency study done by anyone in the amateur community that shows that digital provides better spectrum efficiency or economic efficiency than analog?
According to the FCC the definition of spectrum efficiency is:
"spectrum efficiency is defined as the ratio of communications accomplished to the spectrum used. This would involve parameters such as information delivered, users satisfied, rf bandwidth occupied, geographical area covered, and the time spectrum is denied to other users. "
Please, show me all of this new technology, that uses less bandwidth then CW? I'm still waiting. The only down side to CW, is that you have to learn it. Now that sucks.
73 - Bob
Good point Bob.
For digital modes you essentially plug and play. With CW the 'sound card' and 'computer' reside in your brain. If you don't want to learn it, you can't do it.
It is still amazing that some really want to turn HF into some kind of ersatz internet,
73
George
K3UD
George,
I don't fit that view at all. I am a proficient CW running exclusively QRP and QRPp. My head is my receiving computer!
I'm not interested in turning HF into a digital haven or an extension of the Internet, but I am in favor of promoting experimentation and facilitating it appropriately without having to secure an STA each time something new comes along or trying to figure out the proper place to operate it. The Internet does not belong on HF with the possible exception of WinLink like systems or PACKET systems. Beyond these, there is not reason for the Internet on HF.
I can not offer anything in the way of studies to this debate. I haven't got enough time to do the require research. My activities are limited and only find 15 minute chucks of time to explore my own interests, but I will tell you that we need to, at least, look like we are interested in extending our art.
Ken
W3MIV
01-11-2006, 06:31 PM
Quote[/b] (ae1x @ Jan. 11 2006,13:25)]...I will tell you that we need to, at least, look like we are interested in extending our art.
A significant point, Ken. And it is one that is all too often overlooked. Or misunderstood.
It appears to me that most of the nay sayers are afraid of amateur radio being more responsible for itself. The FCC has indicated that it is not willing to get too involved in regulating our service or into enforcement.
They wish for us to attend to our own affairs and only seek their assistance when all else fails. This can be seen in the interference issue with BPL. They want us to work out a solution with this developing technology without forcing something on either party that neither might find acceptable.
We used PEER PRESSURE to keep LIDS in line in the past. Why can't we do the same now? The local clubs would have to be vigilant and report the LIDS to the appropriate officials should the PEER PRESSURE fail. This means we all must be more involved in the affairs of our service in our immediate area. This, to me, would be a great thing for our service. We locate the LIDS discuss their behavior with them in a friendly manner and should the LID be uncooperative, then the LID would be report to Riley or his successor. Can't we do this? Aren't we mature enough to weed out the LIDS ourselves? Do we have to leave it all up to the ARRL OO program or shouldn't we be involved?
The location of the ROBOT stations everyone fears are available and what frequencies they intend to use for their operations. Should these stations be a real problem, then the station operator should be contacted and reminded of his/her obligation to prevent interference and should it continue, then the operator should be reported to the FCC. I can't not see where this would be a real problem. I know they don't identify in a manner that we can check on, but we can report the interference details and that it from there.
The remaining potential for problems would seem to be managable at this time for the very reasons stated. The usership is low at this time. Breeding responsible behavior would seem to be best achieved now before there is serious problem.
I don't see where there is a serious problem now and for the foreseeable future. It's best to get a working infrastructure in place now and training methods should be developed that will bring new operators and modes on in an organized fashion rather than in some uncontrolled manner. I know that a flood of these types of operators is what is feared by those with a vested interest, but I seem to recall a lot of anguish when AM came along and then when AM was being replaced by SSB. There lots of clashes that were eventually settled because we acted in a mature way. We need to resurrect this type of problem solving maturity for us to succeed into the future.
Ken
W3MIV
01-11-2006, 08:39 PM
Quote[/b] (ae1x @ Jan. 11 2006,15:12)]The location of the ROBOT stations everyone fears are available and what frequencies they intend to use for their operations. Should these stations be a real problem, then the station operator should be contacted and reminded of his/her obligation to prevent interference and should it continue, then the operator should be reported to the FCC. I can't not see where this would be a real problem. I know they don't identify in a manner that we can check on, but we can report the interference details and that it from there.
Though I know lots of others do not agree with me, I believe that bandwidth allocation is a better way to go than what we now have. I have said this before.
I also believe that any problems that result from adjustment to the new scheme -- e.g. CW and PSK jostling for mutually agreeable slots -- can be worked out with precisely the kind adult negotiation and cooperation you advocate.
The robot/PacTOR issue, however, needs to be resolved by regulation. I see no alternative. The ARRL has called for removal of the current 500Hz bandwidth limit now restricting "remotely controlled" operations (the League refers to them disingenuously as "semi-auto" ops in the petition), freeing up 2.4kHz robot ops in the wide band segments that will probably receive the bulk of the new licensees that 05-235 turns loose on the bands. For good or ill, many of these folks will not have the tradition of seeking amicable solutions, and this lack of moral inertia combined with the difficulty of identifying PIII robots without costly proprietary hardware, will swiftly result in the kinds of dispute-resolution tactics now on display on 75m, or worse, on 11m.
The easy answer, of course, is the expand the automatic operations sub-bands to 10kHz or 12kHz, where applicable and available, and let all of them do their things without causing or being subjected to interference from CW, PSK, AM, SSB, ATV, or XYZ should that new digital mode spring forth in splendor on our bands.
None of this is against WL2K, PacTOR or anyone else. It is a matter of simplifying the problem and making it susceptible of amicable solution before it becomes a problem.
In so far as digital and analog cooexisting, I know much has been made of the potential for disaster. I disagree with most of this, and I continue to believe (perhaps, like Rodney King, to a fault) that we can "all get along."
73
Quote[/b] (ae1x @ Jan. 10 2006,12:16)]Quote[/b] (K2WH @ Jan. 10 2006,15:40)]AE1X:
My view is simple:
1.) Band planning is a must and it must have teeth.
# # a.) We need a coordination organization.
# # b.) We need enforcement
# # c.) We need cooperation from FCC
# # d.) We need mature behavior by all parties.
<hr size=15 color=purple>
Surely you jest. #Band plan yes. #The rest is a pipe dream or an invitation to disaster.
<table border size=15 bordercolor=purple><td> a) Coordination organization: Wrong. Look what happened to repeater committees, infighting and political activism.<td><tr><td> b) Enforcement: The FCC is basically a paper tiger when it comes to amateur matters. #Just read about how long the FCC took in some recent convictions.<td><tr><td> c) Cooperation from the FCC: #Wait, I'm still laughing.<td><tr><td> d) Mature behavior: #From who? #The FCC or amateurs? #Either way, you won't get it.</table>
K2WH
I do not JEST here and I believe that we either improve our behavior or we can kiss our beloved hobby good bye!
Look, I know the FCC is a paper tiger, but will it remain such? Might a change in the administration have some effect?
I don't think the repeater coordinators are that much of a failure. In fact, for the most part they do the job and do get support from the FCC, especially from Riley.
Concerning the length of time it took to get that bad apple, it took that long because it took that long to get him for a really serious Federal Offense. The other stuff on our bands is small potatoes. Amateur enforcement on the other hand is handled more quickly in and of itself.
The band plan must have some teeth or the disaster you fear will happen.
The mature behavior must come from all interested parties!
Is it you position that we should keep the present system? I fear that the old plan is not in keeping with the stated goals of this Commission. They are intent on deploying systems that are more spectrally efficient. Each Khz must be utilized in such a way that it provides the largest benefit to the public. Their measure has a lot to do with how much revenue is generated. We must begin developing new ways to get things done so that any developments we come up with can be measured monetarily so it will register with this Commission.
What can be done to present this type of case? Well, for one thing we can develop better protocols, better modulation schemes, better antennas, better receivers optimized for digital signaling, and list can go on from here. Once this is done, we can move our ideas into the market place if they have sufficient merit. This is what amateurs did in the past.
What content should these streams contain? This will be determined by the need. There is a specific need for moving emergency traffic from disaster sites in a secure and efficient manner. WL2k is the method preferred by the League, but this could be changed should we develop something better at a more reasonable cost. Whatever happened to the SCAMP protocol? Could it be that it disappeared because it might compete with PACTOR III? I don't know the answer to this, but I could see SCAMP as a reasonable alternative to PACTOR III and it takes slightly less bandwidth.
During the initial stages of a disaster, the public wants to know what is really happening. The development of an appropriate scheme to get images out of the disaster area as early as possible could be another area amateurs could make a contribution to the advancement of our art.
I'm sure that there will be other new ideas that will impact our hobby. This proposal would facilitate such developments without the requirement for us to get an STA to achieve our goals. The experiments could be conducted and the results made available earlier in the development process to get the needed attention for an idea and get people to participate.
Amateur radio can not continue to exist as it has in this environment without the continued backing of the FCC. This backing will disappear unless we take some action to show that we are ready and willing to look to the future, a future that may be very different from our past, but a future none the less.
Ken
Sorry for being such a pessimist, and I would love to change the way people think, but I just don't think we will see it unless it is forced upon us.
If forced upon us, then you will have the "Vigilantes" who will not want to comply and cause all kinds of problems.
I agree with your desires, but I just don't think it will happen.
K2WH
ab0wr
01-11-2006, 09:32 PM
Rumor heard at club:
Group of amateurs, on behalf of an unamed, famous Internet email provider, canvassing for amateur stations to act as relay stations for people to use in accessing their email. Free broadband service, modem, and Internet account to contracted stations.
Anyone interested?
tim ab0wr
k5rks
01-12-2006, 01:29 AM
Now that we have both the CTT proposal as RM-11305 and the ARRL proposal as RM-11306 the question is what comments to file with the FCC on each of these?
Reading these threads I know there are a number of debates on various issues going on simultaneously. For me the core issue -- out of about a dozen issues -- is the fact that each of the proposals opens the potential for "robots" having access to significantly larger number of Khz in the HF bands. Since to me this is the key issue, then for me both RM-11305 and RM-11306 are the "same".
I don't have any problem with regulation by bandwidth vs. regulation by mode. Personally, I don't think it is a big deal either way. Also there are dozens of side arguments going on in this and related previous threads which do not address what I think is the crux issue. #
I think by either rule or bandplan that the subbands should be partitioned so that those modes have allocations that are proportional to their actual use. Earlier in this thread there is a post that shows the breakdown on use of CW, vs SSB, vs Digital Modes that should give some guidance on what the upper bounds should be relative to the amount of Khz that should be set aside for "robots" in each of the HF bands.
The idea of having "robots" and all other modes co-exist is fiction since "robots" might be using protocols that require special equipment to receive (such as SCS modems) that only a very few hams have. I don't know how many SCS modems have been manufactured and shipped but my guess is less than 10,000. I don't think HF bands should to be "taken over" by "unintelligible" operations used by a "few" operators. By "taken over" I mean allowing robots to use a number of Khz on a given band way out of proportion to the percentage of operators using that mode compared to all operations on the band.
I don't exactly know how to express these thoughts in comments to the FCC. I guess if I was totally blunt I'd say something like this to either proposal, "The proposal is flawed because it relaxes rules which restrict 'robot' operations without suggesting any changes to 'voluntary bandplans' by which the amateur service could use as a guideline for self regulation." #I'm considering right now if or how to mention the need for a comprehensive bandplan in my formal FCC comments. I wouldn't think that the FCC would care about whatever we do or don't do with bandplans. All I know is for me at least both proposals are DOA without at least some bandplan on the table -- or at the very least a plan to come up with a bandplan.
As a side comment if either or both proposals was drawn up as a result of input from various stakeholders in ham radio then it is unlikely that there would be what is evidently "considerable" objection to them.
I have not yet filed my comments on either proposal with the FCC. I will file them in a few days.
73 Roger K5RKS
Quote[/b] (k5rks @ Jan. 11 2006,18:29)]Now that we have both the CTT proposal as RM-11305 and the ARRL proposal as RM-11306 the question is what comments to file with the FCC on each of these?
Reading these threads I know there are a number of debates on various issues going on simultaneously. For me the core issue -- out of about a dozen issues -- is the fact that each of the proposals opens the potential for "robots" having access to significantly larger number of Khz in the HF bands. Since to me this is the key issue, then for me both RM-11305 and RM-11306 are the "same".
I don't have any problem with regulation by bandwidth vs. regulation by mode. Personally, I don't think it is a big deal either way. Also there are dozens of side arguments going on in this and related previous threads which do not address what I think is the crux issue.
I think by either rule or bandplan that the subbands should be partitioned so that those modes that we actually use have allocations that are proportional to their actual use. Earlier in this thread there is a post that shows the breakdown on use of CW, vs SSB, vs Digital Modes that should give some guidance on what the upper bounds should be relative to the amount of Khz that should be set aside for "robots" in each of the HF bands.
The idea of having "robots" and all other modes co-exist is fiction since "robots" might be using protocols that require special equipment to receive (such as SCS modems) that only a very few hams have. I don't know how many SCS modems have been manufactured and shipped but my guess is less than 10,000. I don't think HF bands should to be "taken over" by "unintelligible" operations used by a "few" operators. By "taken over" I mean allowing robots to use a number of Khz on a given band way out of proportion to the percentage of operators using that mode compared to all operations on the band.
I don't exactly how to express these thoughts in comments to the FCC. I guess if I was totally blunt I'd say something like this to either proposal, "The proposal is flawed because it relaxes rules which restrict 'robot' operations without suggesting any changes to 'voluntary bandplans' by which the amateur service could use as a guideline for self regulation." I'm considering right now if or how to mention the need for a comprehensive bandplan in my formal FCC comments. I wouldn't think that the FCC would care about whatever we do or don't do with bandplans. All I know is for me at least both proposals are DOA without at least some bandplan on the table -- or at the very least a plan to come up with a bandplan.
As a side comment if either or both proposals was drawn up as a result of input from various stakeholders in ham radio then it is unlikely that there would be what is evidently "considerable" objection to them.
I have not yet filed my comments on either proposal with the FCC.
73 Roger K5RKS
Roger, K5RKS:
Well said by you... "The proposal is flawed because it relaxes rules which restrict 'robot' operations without suggesting any changes to 'voluntary bandplans' by which the amateur service could use as a guideline for self regulation."
I agree. Yes, they are DOA.
73.
kh6ty
01-12-2006, 03:43 AM
How much room do the robots really need, and why is ARRL (for Winlink 2000) petitioning for access to ALL HF frequencies?
The reason they want access to ALL HF frequencies is that the robots don't want to fight another robot for use of a frequency, because both are automated (either the so-called "semiautomatic" station or the unattended fully automatic station), so neither can get its data through.
They want access to ALL HF frequencies so they can either easily find a clear frequency or not have to wait for one by simply taking away one from someone else in a less persistent (i.e. non-automatic) mode, such as SSB, CW or PSK31. We have all experienced this, I am sure, and if not, phone-only #operators will have their turn under the lash if the ARRL petition ever becomes law and Pactor-III email robots can work anywhere they please in the phone bands.
Winlink has said that they will not work anywhere they please. Really? Then why are they petitioning for the right to do so?
How much spectrum is actually needed for email messaging?
Fact: 92% of all Winlink traffic, 150,000 emails a month, is currently flowing successfully, using Pactor-III, wholly inside the Part 97.221 sub-bands, eliminating QRM to everyone else outside the sub-bands from those stations.
Fact: Pactor-III only saves 30% in overall airtime over Pactor-II for the typical 2-minute email transfer, but consumes *FIVE* times the bandwidth.
Fact: Winlink's elimination of their spectrum-wasting "scanning" would cut Winlink's need for spectrum in *HALF*!
Fact: The suggested NTS/NTSD specification for maximum delivery time for a message is 60 minutes.
Fact: Time-sharing one channel between two (2) different PMBO stations would result in an average wait of less than 2 minutes for a clear channel, but would again cut the need for spectrum in HALF!
Fact: 15 kHz on each band would provide for 24 Pactor-II channels (one for each US PMBO), plus one Pactor-III channel to be shared by all 24 PMBO's for image, catalog, or large binary file transfers.
Fact: In practical terms, with reasonable time-sharing, only one fourth of the space in the sub-bands would actually be needed to handle the current level of Winlink email traffic.
Fact: A mere 5 kHz on each band for unattended operations would be sufficient to support ten 500 Hz-wide channels for Pactor-2, which would support 30 PMBO's with three sharing each channel (which is less than the maximum of seven already successfully sharing 2500 Hz wide channels using Pactor-3), with a *MAXIMUM* wait for a clear channel of only 4 minutes out of an ARRL NTS/NTSD specified maximum delivery time of 60 minutes.
The reason this is practical is that unattended systems, like Winlink 2000, are "store-and-forward" systems, not "realtime" systems, and any message inserted into the system will usually not be retrieved by the recipient for *MANY* minutes, or even hours, later, so a few minutes delay in insertion or retrieval is of little or no consequence. Unattended radio email systems, like Winlink 2000, are *NOT* realtime message delivery systems (like Internet broadband, with instant notification and availability of messages and Instant Messaging), but are more like Internet dialup services, in which the end user must *PERIODICALLY* decide to check for incoming email, then connect, and then download messages, because he is not always connected.
Since 5 kHz on each band is more than sufficient for unattended operations, there can be no justification for allowing unattended operations to have unrestricted access to *ALL* HF frequencies, as the ARRL currently proposes, which would make an already intolerable interference problem to others many times worse if implemented.
EmComm: No additional frequencies are needed to add EmComm traffic to Winlink! Here is a quote by K4CJX from the March CQ magazine:
"The only difference in any emergency is that the content changes. I suppose there may be more outbound third-party information, or more recipients per message, but really no user increases that are noticeable. Unlike other types of systems set up for Emcomm, this system is used with or without EmComm daily by 6384 Winlink users to approximately 81,000 e-mail recipients. It takes a HUGE difference to be noticeable."
So, do you agree that 97.221 should be rewritten as the ARRL has done (for Winlink's primary benefit, especially favoring less than 1% of the FCC-licensed radio amateurs)?
If not, and especially if you are primarily a phone operator, then file a comment with the FCC and tell them that you oppose the changes ARRL wants to make to 97.221, and that the current 97.221(b) subbands are sufficently large to handle all anticipated future radio email store-and-forward "messaging" without causing any unreasonable delay in message receipt.
kh6ty
01-12-2006, 01:09 PM
Quote[/b] (ae1x @ Jan. 11 2006,13:12)]The location of the ROBOT stations everyone fears are available and what frequencies they intend to use for their operations. Should these stations be a real problem, then the station operator should be contacted and reminded of his/her obligation to prevent interference and should it continue, then the operator should be reported to the FCC. I can't not see where this would be a real problem. I know they don't identify in a manner that we can check on, but we can report the interference details and that it from there.
Respectfully, Ken,
This suggestion misses the point!
Winlink #will tell you that the robot stations are not responsible for the interference, but that the remote stations are, since the robots only transmit when triggered by a remote station.
Complaining to the robot station or to the FCC has no impact whatsoever.
The truth is that #"You've got mail!" is one of the most powerful incentives of this Internet Age, a point that is not lost on AOL as you know.
The radio email messaging user only wants one thing - to pick up his email whenever he chooses, without having to wait for a frequency.
Within the 97.221 subbands, fully automatic operation is allowed, which means he can just program several robot frequencies into his software and click the "SEND" button and go about his business while his software and transceiver transmits on different frequencies until he is picked up by a robot and delivered his email.
This called "autocalling", and is legal only in the subbands. The problem comes when the desire to get email without delay overrides the legal and ethical requirement to WAIT for a clear frequency.
So, the solution to the problem is to require ALL store-and-forward or automatic operations of ANY kind to have to stay in the subbands so they do not override those attempting COMMUNICATIONS with other people instead of just USING the ham bands for an answering machine.
There is a huge advantage to being able to use autocalling, and it is NOT for "autoforwarding" as Winlink always suggests (since they do not use autoforwarding any more), but because autocalling can automate the email process, and, since the operator only has to push a button to start the process, he is usually unaware of any delay in successfully linking up with a robot. He just pushes the SEND button and comes back later to read his email and in the interim, his own emails have been transferred to the Internet.
It is critical to send in comments to the FCC on the ARRL petition and tell them that ALL AUTOMATIC OPERATIONS OF ANY KIND MUST BE CONFINED BY LAW IN SUBBANDS FOR THAT PURPOSE, such as the subbands already set aside in 97.221.
W3MIV
01-12-2006, 01:48 PM
I filed my comments this morning. If you are interested, you may read it at:
RM-11306 Comment (http://www.w3miv.us/RM11306_Comment.html)
I agree with Skip both as to the need to really file comments in opposition (as opposed to posting here) and as to the substance of his objections.
Though the deadline for comments is not until 6 February, don't put it off. As the late Snuffy Smith used to say: "Balls o' fire, time's a wastin'!"
This may be of help in observing comments:
http://gullfoss2.fcc.gov/prod/ecfs/comsrch_v2.cgi
'and this link for filing your comments:
http://gullfoss2.fcc.gov/prod/ecfs/upload_v2.cgi
for reference the CTT proposal number is RM-11305
and the ARRL is RM-11306
Read this! Please.
File your comments, folks. And remember:
1. Bandwidth Bandplanning is not being mandated by the FCC, it's strictly the ARRL and Digital folks pushing it.
2. The only thing "broken" in the current bandplan is that it won't allow mixed mode digital and analog. That could be fixed by updating the mode designators in current rules.
3. Nothing prevents digital experimentation today.
4. Nothing prohibits WinLink use today.
5. Many in the "digital community" are not happy with the ARRL proposal and want AM not to get special treatment.
6. RTTY and PSK users comprise most digital use today. They represent 9% of all Amateur use. They will not gain anything in the ARRL plan.
7. 99% of amateurs have to change to accomodate 1% of amateurs who want more spectrum.
8. The ARRL Committees who did this proposal were mostly digital people. Most of Amateur Radio was not represented.
9. Automatic Stations will be free to roam the HF Analog Voice bands and interfere with your SSB QSO.
10. If you are soon to be a No Code General, this petition will make your HF use difficult by adding traffic to the HF bands from automatic stations.
11. In Region 1 where bandwidth bandplanning is in effect, there are complaints that digital signals interfere with voice QSOs. They are also seeing that people are not honoring the bandplan. SSB and CW are being harmed by data signals.
Say NO! Go to the FCC site and comment now. Talk about this on the air and at club meetings. Don't have your friends wake up one day and wonder "What happened?".
k4kyv
01-12-2006, 10:14 PM
Quote[/b] (ab0wr @ Jan. 10 2006,18:39)]Unused spectrum? On HF? I don't think so.
VHF, maybe.
UHF, probably.
Listened lately between about 3580 and 3700 kHz on 80m?
Quote[/b] (k4kyv @ Jan. 12 2006,17:14)]Quote[/b] (ab0wr @ Jan. 10 2006,18:39)]Unused spectrum? On HF? I don't think so.
VHF, maybe.
UHF, probably.
Listened lately between about 3580 and 3700 kHz on 80m?
Add to this the fact that much of our HF allocation goes unused because no ionospheric propagation is supported at this point in the sunspot cycle.
Ken
ab0wr
01-13-2006, 03:18 AM
Quote[/b] (k4kyv @ Jan. 12 2006,15:14)]Quote[/b] (ab0wr @ Jan. 10 2006,18:39)]Unused spectrum? On HF? I don't think so.
VHF, maybe.
UHF, probably.
Listened lately between about 3580 and 3700 kHz on 80m?
Actually, yes.
I work in that area on CW quite often, especially as part of a couple of nets. Guess how often we get qrm on 3585, 3590, 3610, 3670?
Almost every night.
Where are YOU listening?
tim ab0wr
ab0wr
01-13-2006, 03:22 AM
Quote[/b] (ae1x @ Jan. 12 2006,18:13)]Quote[/b] (k4kyv @ Jan. 12 2006,17:14)]Quote[/b] (ab0wr @ Jan. 10 2006,18:39)]Unused spectrum? On HF? I don't think so.
VHF, maybe.
UHF, probably.
Listened lately between about 3580 and 3700 kHz on 80m?
Add to this the fact that much of our HF allocation goes unused because no ionospheric propagation is supported at this point in the sunspot cycle.
Ken
If the spectrum won't support communications because of propagation then it can hardly be classed as "unused".
"Unusable", perhaps, but not unused.
If amateurs can't use it because of propagation, then it is doubtful that anyone else can make use of it unless you are only considering short distance ground wave. For those short distances, VHF and UHF make much more sense.
tim ab0wr
Since I've been pretty active in the BW discussions in the past, I'll add my comments here as well. #The CTT proposal is much more suited to our needs. #I hope (and I'm sure it's a fantasy) that the FCC takes that one instead.
Wasted, empty BW is a shame and this type of proposal would ensure that all available BW is used when needed.
I get the sense that the FCC wants much LESS interaction with the Amateur Bands, not more. #Opening them up (by FCC rule) and then only dealing with extreme cases of QRM and other gross offenders is what I believe they're looking for. #More complicated, stringent BW rules will only increase complaints and create a bunch of "Bandwidth Cops" going around measuring everybody. #We don't need more knit-picking and infighting, which is exactly what the ARRL proposal has/will cause.
I say if you want to limit BW, do so to digital. #Leave the analog voice modes as they are now (necessary BW for the quality required under conditions at hand). #It's MUCH easier to measure and define BW used by digital modes than analog voice. #Besides, the analog voice requires a finite amount of space -- digital can be as wide as you want to go. #Seems like a fairly simple concept to me. #I truly wonder why the ARRL EC missed the mark on that one.
I'll enjoy reading the responses both here and on the FCC's site. #I wonder if somebody will keep "score" on the FCC site and keep an updated tally sheet on the web somewhere. #That would be handy, since the ARRL didn't do it. #Enjoy the discussion, everyone. #I'll keep quiet here and put my thoughts on the FCC page...
73,
Joe
Quote[/b] (ab0wr @ Jan. 12 2006,20:18)]Quote[/b] (k4kyv @ Jan. 12 2006,15:14)]Quote[/b] (ab0wr @ Jan. 10 2006,18:39)]Unused spectrum? On HF? I don't think so.
VHF, maybe.
UHF, probably.
Listened lately between about 3580 and 3700 kHz on 80m?
Actually, yes.
I work in that area on CW quite often, especially as part of a couple of nets. Guess how often we get qrm on 3585, 3590, 3610, 3670?
Almost every night.
Where are YOU listening?
tim ab0wr
Is propogation on the tests?
I guess not.
6 years from now, there will be plenty of stations to fill the bands.
I have been through a couple cycles myself, and 6 years from now, DX on 10M with 100 milliwatts will be no problem.
73 - Bob
80M sounds pretty dead here to me in Berkeley. 40 is crowded with broadcasters. Don't know if that counts. I'm still looking for the crowded HF bands myself. I'd like to find one -- I've been calling CQ tonight and have not found a human on HF.
Quote[/b] (ab0wr @ Jan. 12 2006,22:22)]Quote[/b] (ae1x @ Jan. 12 2006,18:13)]Quote[/b] (k4kyv @ Jan. 12 2006,17:14)]Quote[/b] (ab0wr @ Jan. 10 2006,18:39)]Unused spectrum? On HF? I don't think so.
VHF, maybe.
UHF, probably.
Listened lately between about 3580 and 3700 kHz on 80m?
Add to this the fact that much of our HF allocation goes unused because no ionospheric propagation is supported at this point in the sunspot cycle.
Ken
If the spectrum won't support communications because of propagation then it can hardly be classed as "unused".
"Unusable", perhaps, but not unused.
If amateurs can't use it because of propagation, then it is doubtful that anyone else can make use of it unless you are only considering short distance ground wave. For those short distances, VHF and UHF make much more sense.
tim ab0wr
Tim,
Most aspiring spectrum users are only interested in short range uses. Spectrum is not needed for long haul propagation anymore. We have plenty of commerical infrastructure to handle long range communications.
Ken
ab0wr
01-13-2006, 01:10 PM
Quote[/b] (ae1x @ Jan. 13 2006,03:48)]Quote[/b] (ab0wr @ Jan. 12 2006,22:22)]Quote[/b] (ae1x @ Jan. 12 2006,18:13)]Quote[/b] (k4kyv @ Jan. 12 2006,17:14)]Quote[/b] (ab0wr @ Jan. 10 2006,18:39)]Unused spectrum? On HF? I don't think so.
VHF, maybe.
UHF, probably.
Listened lately between about 3580 and 3700 kHz on 80m?
Add to this the fact that much of our HF allocation goes unused because no ionospheric propagation is supported at this point in the sunspot cycle.
Ken
If the spectrum won't support communications because of propagation then it can hardly be classed as "unused".
"Unusable", perhaps, but not unused.
If amateurs can't use it because of propagation, then it is doubtful that anyone else can make use of it unless you are only considering short distance ground wave. For those short distances, VHF and UHF make much more sense.
tim ab0wr
Tim,
Most aspiring spectrum users are only interested in short range uses. Spectrum is not needed for long haul propagation anymore. We have plenty of commerical infrastructure to handle long range communications.
Ken
It doesn't really matter what aspiring users want. Trying to use frequencies from 7Mhz to 30Mhz for short range use will be a true display of futility.
Sure it will work now. Especially at night above the MUF frequency.
It will cause significant mutual interference during the day and it will get worse as the sunspot cycle goes up.
As pointed out by others, in a couple of years, output powers measured in microwatts will be able to make contacts. Unwanted contacts are considered interference. That type of contact would abound.
If you want short-distance contacts and want to avoid interference problems from propagation, use VHF, UHF, and above.
tim ab0wr
N5GLR
01-13-2006, 04:00 PM
AE1X said:
"Add to this the fact that much of our HF allocation goes unused because no ionospheric propagation is supported at this point in the sunspot cycle."
Bravo Ken. #
Thanks for pointing out the HUGE flaw in the data supporting the CTT proposal. #Any frequency/band usage survey taken at this point in the sunspot cycle is USELESS. #Anyone flaunting data collected during this period as representative of "normal" usage should be suspected of having ulterior motives. #
I wonder if these folks considered propagation conditions before collecting their data or if they think most of us are too stupid to know the difference?
This proposal belongs in the trash ... along with the ARRL proposal.
Garry
N5GLR
ab0wr
01-13-2006, 06:00 PM
Quote[/b] (N5GLR @ Jan. 13 2006,09:00)]AE1X said:
"Add to this the fact that much of our HF allocation goes unused because no ionospheric propagation is supported at this point in the sunspot cycle."
Bravo Ken. #
Thanks for pointing out the HUGE flaw in the data supporting the CTT proposal. #Any frequency/band usage survey taken at this point in the sunspot cycle is USELESS. #Anyone flaunting data collected during this period as representative of "normal" usage should be suspected of having ulterior motives. #
I wonder if these folks considered propagation conditions before collecting their data or if they think most of us are too stupid to know the difference?
This proposal belongs in the trash ... along with the ARRL proposal.
Garry
N5GLR
While I don't agree with the CTT proposal either, the data is still useful.
While the data cannot show absolute usage levels because of propagation, it still allows one to judge the relative usage levels of the various modes.
That is certainly a good thing to know and is far, far more than the ARRL did to support their proposal. The ARRL expects hamdom to just accept their pronouncements as gospel from the Priest-Kings of amateur radio.
Propagation won't significantly affect relative levels since it is a pretty even-handed bias. It might make digimodes look a little higher because some of them are quite good at weak signal work. Since the relative usage for digimodes only came out at 10% of the total relative usage, it is doubtful that increased propagation will raise its level by any significant amount.
tim ab0wr
Quote[/b] (N5GLR @ Jan. 13 2006,11:00)]AE1X said:
"Add to this the fact that much of our HF allocation goes unused because no ionospheric propagation is supported at this point in the sunspot cycle."
Bravo Ken. #
Thanks for pointing out the HUGE flaw in the data supporting the CTT proposal. #Any frequency/band usage survey taken at this point in the sunspot cycle is USELESS. #Anyone flaunting data collected during this period as representative of "normal" usage should be suspected of having ulterior motives. #
I wonder if these folks considered propagation conditions before collecting their data or if they think most of us are too stupid to know the difference?
This proposal belongs in the trash ... along with the ARRL proposal.
Garry
N5GLR
Garry,
I don't agree that either proposal is trash. There has been a lot of debate and thought that has gone into these proposals. The real problem is that they are flawed, as you said.
The real problem with the narrow view many are taking is that these proposals are a blueprint for the future. The usage presented is a snap shot of today, but what will it be 10 years from now? Are we limiting ourselves by having the present system in place? Can we do better? My hope is that the FCC will boil these proposals down and take to heart those constructive ideas that a put forth. A simple I'm against it doesn't really cut it. You need more of an argument to back up your position than this simple statement of fact.
Ken
WA2CWA
01-13-2006, 06:53 PM
Quote[/b] (ab0wr @ Jan. 13 2006,11:00)]While I don't agree with the CTT proposal either, the data is still useful.
While the data cannot show absolute usage levels because of propagation, it still allows one to judge the relative usage levels of the various modes.
tim ab0wr
But only at one location and over a very small time frame. Data should have been collected at various locations across the U.S. and over a much longer time frame. Developing a proposal that affects all amateurs in the U. S. based on a very limited testing plan can lead to flawed conclusions.
Pete, wa2cwa
W3MIV
01-13-2006, 06:53 PM
Quote[/b] (ab0wr @ Jan. 13 2006,13:00)]While the data cannot show absolute usage levels because of propagation, it still allows one to judge the relative usage levels of the various modes.
If you guys believe that a single station, in a single fixed location, on a single day (whatever the relative propagation factors) can be used to determine a "TYPICAL" operating day from which to draw conclusions on which to base regulations, you guys can believe ANYTHING.
http://www.qrz.com/iB_html/non-cgi/emoticons/biggrin.gif
W3MIV
01-13-2006, 06:54 PM
Quote[/b] (WA2CWA @ Jan. 13 2006,13:53)]Quote[/b] (ab0wr @ Jan. 13 2006,11:00)]While I don't agree with the CTT proposal either, the data is still useful.
While the data cannot show absolute usage levels because of propagation, it still allows one to judge the relative usage levels of the various modes.
tim ab0wr
But only at one location and over a very small time frame. Data should have been collected at various locations across the U.S. and over a much longer time frame. Developing a proposal that affects all amateurs in the U. S. based on a very limited testing plan can lead to flawed conclusions.
Pete, wa2cwa
Thank you, Pete, your post beat me by a nose. But I gladly give you the points.
Quote[/b] (W3MIV @ Jan. 13 2006,13:54)]Quote[/b] (WA2CWA @ Jan. 13 2006,13:53)]Quote[/b] (ab0wr @ Jan. 13 2006,11:00)]While I don't agree with the CTT proposal either, the data is still useful.
While the data cannot show absolute usage levels because of propagation, it still allows one to judge the relative usage levels of the various modes.
tim ab0wr
But only at one location and over a very small time frame. Data should have been collected at various locations across the U.S. and over a much longer time frame. Developing a proposal that affects all amateurs in the U. S. based on a very limited testing plan can lead to flawed conclusions.
Pete, wa2cwa
Thank you, Pete, your post beat me by a nose. But I gladly give you the points.
I think that the limitations of this sample render any conclusions about usage meaningless!
Ken
N5GLR
01-13-2006, 08:54 PM
Ken and Tim,
# I stand by my comment concerning the usefulness of the data collected .... i.e. "trash". #The data are totally unusable & should be totally disregarded for the purpose of supporting the CTT proposal. #It is unrepresentative of actual use and does not consider propagation ... to name just two defects. #Addtitionally, the collection method, location of collection, and participant(s) are far too subjective. #
Ken,
The word "trash" was my word. #If my post implied that YOU used that word, I sincerely appologize.
Sincerely,
Garry
N5GLR
ab0wr
01-14-2006, 01:49 AM
Quote[/b] (W3MIV @ Jan. 13 2006,11:53)]Quote[/b] (ab0wr @ Jan. 13 2006,13:00)]While the data cannot show absolute usage levels because of propagation, it still allows one to judge the relative usage levels of the various modes.
If you guys believe that a single station, in a single fixed location, on a single day (whatever the relative propagation factors) can be used to determine a "TYPICAL" operating day from which to draw conclusions on which to base regulations, you guys can believe ANYTHING.
http://www.qrz.com/iB_html/non-cgi/emoticons/biggrin.gif
If you assume a homogeneous amateur community then data collected by a single station in a single fixed location on a single day *CAN* give a pretty good picture of the relative usage levels of the various modes.
In fact, a whole day's usage isn't even required. You might want to take samples in the morning and again in the evening, but you don't have to catch every conversation that happens during the day!
I believe the CTT did their sample on a weekend when the homogeneity of the community would be at its highest point. That makes the sampling the most accurate.
Again, this won't tell you anything about absolute levels. Much more sampling over a longer period of time would be required to make a judgement about this.
It will tell you, however, quite a bit about the relative makeup of the mode usage across the amateur community.
The only way to invalidate this would be to show that the amateur community is NOT homogeneous when considering different geographical areas. You would have to show that the Northeast has more digital enthusiasts per 1000 amateurs than the Southeast has. You would have to show that the Southwest has more CW enthusiasts per 1000 amateurs than the Northwest has.
I've not seen anything in any publication that would indicate that this is true.
This is pretty straightforward sampling theory. I don't have to test every unit coming off a production line to categorize the characteristics of the units (e.g. manufacturing tolerances for length, width, depth, weight, color, etc). I can do a snapshot sample and be pretty sure the results are accurate.
kh6ty
01-14-2006, 09:02 AM
Quote[/b] (ab0wr @ Jan. 13 2006,18:49)]Quote[/b] (W3MIV @ Jan. 13 2006,11:53)]Quote[/b] (ab0wr @ Jan. 13 2006,13:00)]While the data cannot show absolute usage levels because of propagation, it still allows one to judge the relative usage levels of the various modes.
If you guys believe that a single station, in a single fixed location, on a single day (whatever the relative propagation factors) can be used to determine a "TYPICAL" operating day from which to draw conclusions on which to base regulations, you guys can believe ANYTHING.
http://www.qrz.com/iB_html/non-cgi/emoticons/biggrin.gif
If you assume a homogeneous amateur community then data collected by a single station in a single fixed location on a single day *CAN* give a pretty good picture of the relative usage levels of the various modes.
In fact, a whole day's usage isn't even required. You might want to take samples in the morning and again in the evening, but you don't have to catch every conversation that happens during the day!
I believe the CTT did their sample on a weekend when the homogeneity of the community would be at its highest point. That makes the sampling the most accurate.
Again, this won't tell you anything about absolute levels. Much more sampling over a longer period of time would be required to make a judgement about this.
It will tell you, however, quite a bit about the relative makeup of the mode usage across the amateur community.
The only way to invalidate this would be to show that the amateur community is NOT homogeneous when considering different geographical areas. You would have to show that the Northeast has more digital enthusiasts per 1000 amateurs than the Southeast has. You would have to show that the Southwest has more CW enthusiasts per 1000 amateurs than the Northwest has.
I've not seen anything in any publication that would indicate that this is true.
This is pretty straightforward sampling theory. I don't have to test every unit coming off a production line to categorize the characteristics of the units (e.g. manufacturing tolerances for length, width, depth, weight, color, etc). I can do a snapshot sample and be pretty sure the results are accurate.
When I had my factory in Taiwan, I sampled the production output per MIL Std 105D, and had to measure up to 10% of the production output, depending on the lot size.
ONE sample is definitely insufficient to draw any conclusions, especially since propagation varies from day to day, and sunspots from year to year.
See the charts here:
http://www.mtc.com.my/publication/library/quality/qc40.htm
Besides, it is one function of the government to assure "a place in the sun for everyone" and not let the vast majority totally displace minority users. The CB band is a good example of what happens when there are no restrictions on where phone can operate. Phone is so desirable and popular, and easy to use, that it will completely fill any band if allowed to do so.
Contesting is just as valid a part of ham radio as any other, and during contests, there are seldom any areas of inactivity in the allowed regions, except when propagation fails completely. Want a more representative sample of the use and the need for space? Take it during a major contest!
Skip KH6TY (not a contester!)
W3MIV
01-14-2006, 12:20 PM
Quote[/b] (ab0wr @ Jan. 13 2006,20:49)]Quote[/b] (W3MIV @ Jan. 13 2006,11:53)]Quote[/b] (ab0wr @ Jan. 13 2006,13:00)]While the data cannot show absolute usage levels because of propagation, it still allows one to judge the relative usage levels of the various modes.
If you guys believe that a single station, in a single fixed location, on a single day (whatever the relative propagation factors) can be used to determine a "TYPICAL" operating day from which to draw conclusions on which to base regulations, you guys can believe ANYTHING.
http://www.qrz.com/iB_html/non-cgi/emoticons/biggrin.gif
If you assume a homogeneous amateur community then data collected by a single station in a single fixed location on a single day *CAN* give a pretty good picture of the relative usage levels of the various modes.
In fact, a whole day's usage isn't even required. You might want to take samples in the morning and again in the evening, but you don't have to catch every conversation that happens during the day!
I believe the CTT did their sample on a weekend when the homogeneity of the community would be at its highest point. That makes the sampling the most accurate.
Again, this won't tell you anything about absolute levels. Much more sampling over a longer period of time would be required to make a judgement about this.
It will tell you, however, quite a bit about the relative makeup of the mode usage across the amateur community.
The only way to invalidate this would be to show that the amateur community is NOT homogeneous when considering different geographical areas. You would have to show that the Northeast has more digital enthusiasts per 1000 amateurs than the Southeast has. You would have to show that the Southwest has more CW enthusiasts per 1000 amateurs than the Northwest has.
I've not seen anything in any publication that would indicate that this is true.
This is pretty straightforward sampling theory. I don't have to test every unit coming off a production line to categorize the characteristics of the units (e.g. manufacturing tolerances for length, width, depth, weight, color, etc). I can do a snapshot sample and be pretty sure the results are accurate.
Sorry, Tim, but when you base your testing on untested assumptions for which you have no more basis than that you've "not seen anything in any publication that would indicate that this is true," what you have is thelology, not science.
It would be fatuous to base FCC rules on the results of any such "survey."
WA0LYK
01-14-2006, 01:12 PM
Quote[/b] ]W3MIV
Sorry, Tim, but when you base your testing on untested assumptions for which you have no more basis than that you've "not seen anything in any publication that would indicate that this is true," what you have is thelology, not science.
It would be fatuous to base FCC rules on the results of any such "survey."
Sorry, Albert, but you have hit the nail on the head and didn't even recognize it. Skip just hit around the nail.
When I was working, if a problem developed and I had a meeting to ask about solutions, I would listen much more closely to the subordinate that at least took a snapshot of what was happening and made a recommendation based on that data rather than the ones that could only base solutions on what their their "gut" told them and then tried to describe the snapshot/solution as "trash".
As you say, "It would be fatuous to base FCC rules on the results of any such "survey." As Skip says, he needed to take a substantial sampling to be able to say within specified limits that quality was ok. Both of these apply "in spades" to the ARRL's proposal since they have no "survey" at all to base their recommendations on.
Trash is at least something. Nothing is nothing. Which do you think the FCC should base its decision on?
Skip, could, and I mean could, a sample of 1 in a thousand have given the same result as 100 out of 1000 at any point in time? I suspect this could happen. However, no one knows for sure how often this would happen.
This Albert, is the response to your description of "trash". You don't KNOW without a doubt that it is trash! You may suspect that the data can't be 'generalized' but you don't have the proof to know this is the case. It is accurate for that station at that point in time. For anyone to state in no uncertain terms that it is trash and that it can not be generalized would take further study and data collection. You don't have that data to prove your assertion.
Jim
WA0LYK
W3MIV
01-14-2006, 01:28 PM
Quote[/b] (WA0LYK @ Jan. 14 2006,08:12)]Quote[/b] ]W3MIV
Sorry, Tim, but when you base your testing on untested assumptions for which you have no more basis than that you've "not seen anything in any publication that would indicate that this is true," what you have is thelology, not science.
It would be fatuous to base FCC rules on the results of any such "survey."
Sorry, Albert, but you have hit the nail on the head and didn't even recognize it. #Skip just hit around the nail.
When I was working, if a problem developed and I had a meeting to ask about solutions, I would listen much more closely to the subordinate that at least took a snapshot of what was happening and made a recommendation based on that data rather than the ones that could only base solutions on what their their "gut" told them and then tried to describe the snapshot/solution as "trash".
As you say, "It would be fatuous to base FCC rules on the results of any such "survey." #As Skip says, he needed to take a substantial sampling to be able to say within specified limits that quality was ok. #Both of these apply "in spades" to the ARRL's proposal since they have no "survey" at all to base their recommendations on. #
Trash is at least something. #Nothing is nothing. #Which do you think the FCC should base its decision on? #
Skip, could, and I mean could, a sample of 1 in a thousand have given the same result as 100 out of 1000 at any point in time? #I suspect this could happen. #However, no one knows for sure how often this would happen. #
This Albert, is the response to your description of "trash". #You don't KNOW without a doubt that it is trash! You may suspect that the data can't be 'generalized' but you don't have the proof to know this is the case. #It is accurate for that station at that point in time. #For anyone to state in no uncertain terms that it is trash and that it can not be generalized would take further study and data collection. #You don't have that data to prove your assertion.
Jim
WA0LYK
Before going any farther with this, lets set a few ground rules. Perhaps it would help if you actually read what I posted. Two or three times.
In the first place, I did not make any comments using the term "trash" in any post I made, so get clear on that.
Let's also get clear on the fact that I made no reference to the ARRL petition, nor to any studies that may have or may not have been made with regard to that petition. Get clear on that.
Finally, regardless of what you may or may not believe, one may not make rules for everyone to adhere to on the basis of what someone cannot show to be true. Unless, of course, one is dealing with religion, or despotism, but surely not amateur radio, which rules need to accommodate any and all licensed parties and activities. To assert such a basis for rule-making is nothing short of reprehensible, not to mention merely ludicrous.
Hi,
I know how you feel, I felt the same way too. I did the survey included the CTT proposal and agree. It was mighty slim in terms of validatable data. . . . 'sort of a 1 point graph. However, I continued the same test for an additional 5 months and found essentially the same results. CW ~ 30%, data 10%, and Phone ~ 60%. The test is not designed to yield an absolute value . . . it is designed to measure the percentage of use each mode relative to total use. Now that we have a 150 point representation of tens of thousands of contacts instead of a 1 point (a few hundred QSOs) I am much more confident in the result.
Art k3xf
W3MIV
01-14-2006, 02:34 PM
Art:
My comments with regard to your survey are not meant to be demeaning, and I never used any terms such as "trash" with regard to any part of it.
I simply maintain that no survey carried out on the basis of a single station, in a single fixed location, for a single twenty-four hour period can be used as the basis of making the statement that the result represents a "typical" operating day. There are far too many vagaries at work to support such an assertion; indeed, I would be very hesitant to carry out such a survey (using the same "standards") over even longer period and proclaiming it to be a definitive "typical" operating day.
That is not science, and it should not form the basis for any rule-making, though I agree that the findings are interesting and illustrative of a moving slice in time that could form the basis of developing a far more rigidly devised survey with a higher number of sampling points. Even then, however, I would be hesitant to proclaim it as "typical" for the purpose of rule-making.
73
WA0LYK
01-14-2006, 03:18 PM
Albert,
I sincerely apologize for attributing the description of "trash" to you. You did not do this and I am sorry for indicating that you did.
However, while I don't agree with the CTT proposal, I do believe they have at least used some data for their conclusion. This is far more than the ARRL has done with their proposal. An illustration of this is the 10 kHz allocation for 200 Hz bandwidth on 40m for all general class CW and narrow digital modes. A simple sample of usage on almost any day of any year would have indicated that this is totally unreasonable.
I also don't believe you can simply dismiss the "generalization" of the data (especially the percent usage figures of different modes) out of hand without empirical proof, such as conflicting data from another site, that the sample is not sufficient.
Jim
WA0LYK
W3MIV
01-14-2006, 03:44 PM
Jim: No apology is needed.
Quote[/b] ]I also don't believe you can simply dismiss the "generalization" of the data (especially the percent usage figures of different modes) out of hand without empirical proof, such as conflicting data from another site, that the sample is not sufficient.
Here you and I will strongly disagree. I should also add, by way of edit, that a negative cannot be proved.
Were I to walk outside at night and look up at the sky in my location, I could count, perhaps, less than a hundred stars. Noting that half of them appear somewhat blue, I could then extrapolate that "survey" into a classification of all stars in the Universe, and hold that fifty percent of them must be blue based on my "scientific" observation.
I may, of course, choose to fervently believe that my "analysis" is meritorious, but I doubt many astronomy departments are going to alter their curricula to meet my findings or that textbook publishers will beat a path to my door. And I fervently hope that the FCC will follow that same sense of agnosticism and reject this "survey" as anything worthy of forming the basis of regulation.
I intend no insult to anyone, least of all to Art or any of his colleagues who form the CTT group.
73
Quote[/b] (W3MIV @ Jan. 12 2006,08:48)]I filed my comments this morning. If you are interested, you may read it at:
RM-11306 Comment (http://www.w3miv.us/RM11306_Comment.html)
I agree with Skip both as to the need to really file comments in opposition (as opposed to posting here) and as to the substance of his objections.
Though the deadline for comments is not until 6 February, don't put it off. As the late Snuffy Smith used to say: "Balls o' fire, time's a wastin'!"
Albert,
I just now looked at your comments and I have to say that you did an outstanding piece of work that pulls together pretty much everything that has been discussed on QRZ.com and other places.
perhaps you can submit this as an op-ed piece to the ARRL for publication in QST as I think that it contains more thought and explanation than anything that has been printed in QST to date AND would do a lot to educate those members who do not know anything about it.
I was in the middle of composing my own comments and since I can not do better than you did I think I will just send in a short comment saying that I agree with your comment and reference it. http://www.qrz.com/iB_html/non-cgi/emoticons/wink.gif
Maybe you should re-engineer it into an actual proposal for the FCC to act on http://www.qrz.com/iB_html/non-cgi/emoticons/smile.gif
WA0LYK
01-14-2006, 04:46 PM
Quote[/b] ]I may, of course, choose to fervently believe that my "analysis" is meritorious, but I doubt many astronomy departments are going to alter their curricula to meet my findings or that textbook publishers will beat a path to my door. And I fervently hope that the FCC will follow that same sense of agnosticism and reject this "survey" as anything worthy of forming the basis of regulation.
Albert,
The flaw in your reasoning here is that the cur