New RM-11769 Proposed "Symbol Communication Subbands" in place of CW/Data

OMG this again? Just for the record there are many of us "no code" generals who can copy and send circles around the only people you normally hear on the air griping about no code hams. The ones who round table pretty much all day running legal limit, brag about passing a code test back in the day, then in the same statement admit that they never use CW mode.

This horse is beyond dead. And this guy making the petition does not represent me as a "no code ham".

It would be like me saying that all radio amateurs who use a computer in their shack is like this guy. I mean really?

 

If you think this petition is bad, go the the FCC ECFS system and comment against it, not just here.

Go to the FCC Site here and enter "RM-11769" in the "Proceeding Number" field then fill in the form. Type your comments in the provided box. Be sure to include your name and call in the comment and conclude that the petition should be DENIED. If successful you will get a comment number confirmation. Your comment will show up within 24 hours or less (longer on weekends).

 

Go to the FCC Site here and enter "RM-11769" in the "Proceeding Number" field then fill in the form. Type your comments in the provided box. Be sure to include your name and call in the comment and conclude that the petition should be DENIED. If successful you will get a comment number confirmation. Your comment will show up within 24 hours or less (longer on weekends).

 

Go to the FCC Site here and enter "RM-11769" in the "Proceeding Number" field then fill in the form. Type your comments in the provided box. Be sure to include your name and call in the comment and conclude that the petition should be DENIED. If successful you will get a comment number confirmation. Your comment will show up within 24 hours or less (longer on weekends).

 

Screw the ITU, respectfully. Things are different in the USA. We and Japan have the largest number of amateurs and here, amateurs DO NOT PLAY WELL TOGETHER. Mode separation saves all hell from breaking out on the bands.

1. If wideband data is set free, you WILL LOSE out if you use any legacy analog or digital mode because the automatic stations are unmanned and DO NOT listen for traffic before they transmit. They are robots that just keep on sending until their message gets through. Cranking up your power won't work. Your communications is DEAD.

2. Good wideband digital requires more and more bandwidth so ONE person can get a message through at the expense of three or more legacy digital mode communications. It's a greedy use that belongs on the Internet or on commercial HF services.

3. Digital users are 2% of all use and wideband data less than 1/4 of a percent. The wideband folks seek to use the maximum bandwidth they can get away with at your expense. THEY DON'T CARE. This hurts narrowband data users too.

4. Narrowband data users - don't be used by these folks. You will suffer the most from this petition.

5. Be wary of the ARRL on this issue too. They have become infested with wideband data users. The new CEO was on the committee that recommended taking spectrum away on most all bands and settled for the 80m petition.

Be informed!

 

The ITU does only care about the band limits.
Amateur bands are simply slices of spectrum, for which a national Administration can issue whatever
regulations they want, as long as they are in line with e.g. any sharing criteria for bands
where amateur radio has secondary status.

73/
Karl-Arne
SM0AOM

 

NØECN is an 11 meter newbie reject that memorized the answers and finally managed to upgrade to General last year. He is the typical loudmouth that struts into the room with absolutely no experience, background, training or awareness and starts spouting off about how he “knows what’s best and let’s do things his way.” Disregarding the fact that there might be solid reasons for why it’s being done the way it is. ( Hey, that sounds nationally familiar, somehow ! ) His attempt to minimalize and eventually eliminate all CW operation is a familiar rant from the no-code army. And yes, I would be wary of both the pro-digital ARRL and the FCC. We will all sit back and say “there is no way this could happen,” as we did with the elimination of the CW requirement. Elimination of protected CW-only sub-bands would result in world-wide band chaos.

On behalf of the many “real” hams here in the Kansas City area, I apologize for this complete ignoramus. Get your comments in to the FCC against RM-11769.

 

And where in the HF spectrum are these "protected CW-only sub-bands" located?

Answer: they aren't. They don't exist.

Much as I might share your sentiments about the guy if I knew him, that's not at all what his thing is about. There are no CW-only sub-bands [on HF] to eliminate!

 

Good point about the possibility of a EMP event leaving us unable to use digital modes.

 

Ok..."semi-protected," in that only Cw and digital are allowed. It's only by "Gentleman's Agreement" that Cw, Rtty and the various digital modes coexist. Thus far, they mostly do, fortunately.

 

KI4ODO; I do agree with you to a point and congrates for learning cw. Its true this petition does not represent you and other hams who who got there license after the cw requirement was dropped.
Maybe I should have used the term lack of CW skilled ham instead.

 

Yeah, mostly... until there's a RTTY contest. Then, forget about using CW because they'll dump right on your head. Most of 'em anyway. They don't listen really, just watch a waterfall for the most part. Point and click and BAM! there goes your CW qso.

 

True, WR2E. RM-11769 would make it even worse.

 

Here are my comments:


Before the
FEDERAL COMMUNICATIONS COMMISSION

In the Matter of:

Amending Part 97 of the Commission's
Rules and Regulations to Redesignate
Sub-Bands from Exclusively Morse Code
to Narrowband Modes, including CW and
for Other Purposes

Docket No. RM-17769


COMMENTS OF JAMES EVAN "GWEN" DALLAS, AD5NL

I ask the Commission to reject Petitioner Whedbee's proposal to eliminate CW sub-bands.

As someone who frequently uses digital modes, my concern with the proposed rule changes are these:

1.) CW is a mode that is usually (but not always) decoded by ear. This means that the SNR needs to be relatively high (compared to

some newer digital modes such as PSK31 and JT65 that can often be decoded even when the signal is not audible). CW should be

segregated into its own band to prevent interference.

2.) CW is a mode that should be given priority and special protection because of its proven track-record in disaster/public

service communication.

3.) Furthermore, CW should be given priority and special protection because it is the easiest mode to implement properly, and

therefore a lot of very-low-power (QRPp) users prefer it. For this reason, we need to try to exclude other modes from interfering.

4.) Many of the newer digital modes are experimental or semi-experimental. Furthermore, many of the established modes are now

typically-implemented using computer soundcard or even the speaker/mic on smartphones. The problem with this is that there are

often unintentional or poor-quality transmissions (for example, the Windows "tada" sound accidentally being transmitted when a

computer is started up; or RF feedback noise getting into the audio cables). While the FCC should probably be tolerant of honest

operating mistakes, it justifies segregating digital modes into a "sandbox" subband where operator error or poor engineering are

less likely to cause interference to other band users.

(This is not a hypothetical concern; I will confess to the FCC that I have been guilty of causing unintentional interference while

using digital modes).

5.) We should avoid making significant changes to the band plans as these cause confusion and operator error. The burden should be

on Petitioner to justify the change, not on the Commission to justify the status quo.

Respectfully submitted,

James E. "Gwen" Dallas, AD5NL
Austin, Texas