Proposed Shortwave Broadcast Station Prompts Objection

Discussion in 'Amateur Radio News' started by W0PV, Jul 9, 2020.

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  1. W0PV

    W0PV Ham Member QRZ Page

    In what seems to be a small revival in shortwave broadcasting, three USA radio amateurs with careers in SWBC & telecom have posed serious concerns about the proposal to build a new HF transmitter site and offer advanced digital messaging services.

    The QTH prompts suspicion of a possible connection with so called "high speed trading" in financial markets, where alleged experiments with lower bandwidth signals ("time ticks") were previously tracked by hams.

    73, John, WØPV

    Proposed Shortwave Station in Illinois Prompts an Objection

    Several members of the SW / radio amateur community expressed concern about other possible data uses.

    BY PAUL MCLANE PUBLISHED in Radio World: JULY 8, 2020

    [​IMG]

    Elevation for proposed shortwave towers; see detailed original in the Parable filing.

    There’s a plan in the works to build a new international shortwave radio station in Illinois, one that would use the Digital Radio Mondiale modulation system. But now several prominent members of the U.S. shortwave community are asking the Federal Communications Commission to take a closer look first.

    Parable Broadcasting Co. in April asked the FCC to allow it to build the station in Batavia, Ill., west of Chicago, using the call sign WPBC. It wants to offer “broadcasting and data services.”

    Specifically, Parable wrote that the station would “serve the areas of Europe that may be authorized by the commission. The planned broadcast content includes religious and educational programming, as well as data content provided by third parties.” It added that it wants to “take advantage of the recent push by the National Association of Shortwave Broadcasters to develop and provide content for the growing DRM market.”

    Now three individuals, collectively called the High-Frequency Parties, filed an informal objection. It’s that wording about data content that concerns them.

    Bennett Z. Kobb @AK4AV, Kim Andrew Elliott @KD9XB and Christopher D. Rumbaugh @K6FIB said international broadcast stations in the U.S. are intended “to be received directly by the general public in foreign countries.”

    Now they told the FCC that it is impossible to tell from the Parable application whether all of the data services and data provided by third parties will qualify.

    Elliott KD9XB is a former VOA employee who produces the program “Shortwave Radiogram” and is active on Twitter. Rumbaugh K6FIB publishes the DRMNA.info website. Kobb AK4AV has held various roles in radio and telecommunications including launching a telecom newsletter and writing books about spectrum allocations. He currently is a government contractor. The three have filed joint comments to the FCC before.

    They wrote to the commission: “Various elements of the application and its geographical location suggest that the station will be engaged in the provision of point-to-point data services for hire, a common carrier or private carrier of messages not ‘intended for direct reception by the general public’ and not ‘to be received directly by the general public in foreign countries.’”

    Nothing in the rules allows non-broadcast service, including ancillary or auxiliary services, they continued. “The applicant proposes to use the Digital Radio Mondiale (DRM) standard. All data messages from this station must be in a form readily decoded by ordinary DRM receivers and rendered as publicly accessible content without encryption or obscuration of their purpose or meaning. While Section §73.758 authorizes ‘datacasting’ to stations using DRM, it does not allow any form of datacasting that is not also broadcasting.”

    [Related: “U.S. Shortwave Broadcasters Eye Digital”]

    They said they’re definitely not against international data broadcasts or to DRM. (“Our members pioneered such services at the Voice of America and have operated DRM promotional websites recognized by the DRM Consortium for more than a decade.”) But they said someone wishing to conduct commercial HF point-to-point messaging for third parties should do so in a service dedicated to that function; if none exists they should petition the FCC for one.

    While the FCC has authorized international data stations experimentally, those were “never conceived to engage in revenue operations indefinitely as an alternative to regular spectrum allocations and transparent, public license assignment procedures.”

    In a separate email to Radio World, Kobb noted recent news coverage of shortwave applications for private data communication services such as instant stock trading; examples are here and here. Kobb emphasized that the objectors have no reason to think Parable is associated with those particular projects.

    But regardless of audio programs that Parable may transmit, the three told the FCC that licensing a point-to-point message facility this way would be “an impermissible excursion around formalizing an international private data service or updating existing rules to accommodate it.” So they say the commission FCC should require Parable to certify that “no nonpublic, non-broadcast, nondisclosed, encrypted, confidential or clandestine data messages shall be sent over the proposed station.”

    They added that the FCC needs to update its “hoary Part 73F rules, some dating from the 1930s and now without any articulable public interest basis.” These include “excessive” minimum required power level and a prohibition on domestic service. “Rule changes might embrace data communications under an expanded scope of service.”

    Radio World invited comment from Parable via its attorney, Donna Balaguer of Fish & Richardson P.C. She replied in an email: “We have just received the informal objection and require time to review it. However, Parable Broadcasting Company proposes to provide valuable cultural and educational content overseas, as intended by the FCC for International Broadcast Stations. Parable’s application complies with FCC rules in all aspects.”

    The application lists a Virginia address for the company and lists Stephen J. Bartlett as president. Its consulting engineer is Stephen Lockwood K7SSL of Hatfield & Dawson Consulting Engineers, whose engineering work can be seen in the application. [Read the Parable application including technical filing.]

    Parable’s facility would operate on the 5.9–15.8 MHz international shortwave bands with 15 kW power. Two 10 kW Amplifier Systems transmitters (main and standby) would feed 550 feet of 5-inch Comscope pressurized coax to a “super high gain” TCI log-periodic antenna system. The latter would consist of three towers, including two at 184 feet, with antenna power gain of 18.0 dBi, which the application notes is “a multiplier of 63.1.”
     
    Last edited: Jul 9, 2020
    YF8RQN, KA8UGB, K0UO and 2 others like this.
  2. K0IDT

    K0IDT Ham Member QRZ Page

    Why does this objection to the programming sound eerily familiar? :)
     
    KX4O likes this.
  3. KI7HSB

    KI7HSB Ham Member QRZ Page

    Should I hate this, or should I love this?
     
    W9FL likes this.
  4. KC5NOA

    KC5NOA Ham Member QRZ Page

    Well when you children finished fighting I will tune them in,that is if they ever quit fighting.
     
  5. W1YW

    W1YW Ham Member QRZ Page

    I need to be 'splained....

    What is the problem with HF transmission of stock data? Why is that 'politically ' incorrect?

    Is it in the ham bands, for example? Or is there a mere objection to ANY AND ALL point to point for the application of this specific broadcast station?

    What IS the problem, people?

    Be explicit. Facts are of interest here.

    73
    Chip W1YW
     
    W9FL, WB3EBN, KN4KXA and 1 other person like this.
  6. W1YW

    W1YW Ham Member QRZ Page

    Exactly...why let someone ELSE make up your mind?

    What are the facts?
     
    K3XR likes this.
  7. W1YW

    W1YW Ham Member QRZ Page

    FYI,

    Transmission of stock trades on the back of broadcast is old and well established.

    In 1985, and for several years, I traded stock options using info from a QUOTREK, a hand held real-time read out of trades, looked like a cell phone of today. That was transmitted as a sidecarrier of broadcast stations.

    While not true 'point to point', it was 'narrowcasting'.

    Is the objection that the proposed BC station did not specify the use of side carrier for trading? Or should we conclude that a capitalist initiative should be thwarted? What is the NATURE of the objection?

    73
    Chip W1YW
     
    AC0OB and WB3EBN like this.
  8. W1YW

    W1YW Ham Member QRZ Page

    Assume there are dozens of well-known hams tied into legal, HF, trading initiatives.

    I know some by name.

    So what?

    :)
     
    WB3EBN likes this.
  9. W0PV

    W0PV Ham Member QRZ Page

    Chip, good questions for discussion. Hopefully it stays civil. :D

    I am thrilled that hams are tied into legal HF trading inititatives. ;) And I have little objection if such xmsn's do not intrude into amateur spectrum allocations.

    However there has been a poor track record of that, as the prior cited thread in QRZ Ham Radio Discussions illustrates. Within that thread are links to a series of at least 4 blogs that provide a lot of detail and background (blog 1, blog2).

    These intruding signals alleged to be from "high speed traders" were tracked to locations where FCC Part 5 Experimental liceses were issued. Those licenses required no commercial use and no interference to other licensed services but convieiently allowed loopholes, in some cases vague frequency assignments that could include amateur bands, along with a no ID requirement. After considerable effort to report and complain a few months ago the intrusion into ham bands ceased, possibly they went QRT totally. I am told that K4ZDH was involved to assist making it so.

    Now it appears some of the same HF trading players may be changing their approach for utilitzing HF radio. They will instead piggyback / Trogan Horse, onto / into, a commercial HF signal. Again, the issue on the surface appears to be more FCC regulatory then anything else, just not Part 97 (unless they intrude again).

    But there is also an over riding concern that these higher bandwidth HF digital signals could contain private data in violation of current regs for that public radio service, even possibly used for other non-trading illicit purposes. This issue becoming yet another example of technical weakness and/or adminstrative distractions present in the FCC.

    To go more to your broader question about message content, whats wrong with transmitting "stock data". Nothing, most of the time. Many feel that high speed, or computer based algorythmic trading, for basic arbitrage can be a good thing.

    However, in this case HF radio is being used to create a technical advantage in so called latency arbitrage, often considered predatory, creating an unfair disadvantage to the common public investor. See articles below,

    https://www.cnbc.com/2020/01/27/lat...g-costs-investors-5-billion-a-year-study.html

    A study by the U.K.’s Financial Conduct Authority found that the high-speed trading practice of “latency arbitrage” causes the overall volume of trading on global stock markets to decrease.This essentially imposes a “tax” on other investors, according to the study, costing as much as $5 billion per year across global exchanges.“In aggregate, these small races add up to meaningful harm to liquidity,” the FCA said.

    https://www.greatpointcapital.com/blog/latency-arbitrage-predatory-algorithm-trading/

    Latency arbitrage is the practice of one party, perhaps a predatory HFT firm, exploiting a time disparity and earning profits with a computer algorithm for trading, when that trade is executed solely because of a latency advantage. Latency arbitrage has raised many heated discussions among all market participants, the SEC and government law makers for many years, yet this unfair unequal access to US equity markets is still the main strategy of many predatory firms.

    73, John, WØPV
     
    KC1DR, WA5VGO, WQ4G and 5 others like this.
  10. W1YW

    W1YW Ham Member QRZ Page

    GM John:)

    Before some of us (not you:)) gut-react to alleged illegal shenanigans, I know for a fact that dozens of hams are involved in these commercial efforts, which are legal and /or filed with respective governments under legal permit procedures.

    I am not familiar with this specific proposed installation, nor whether the objections have a basis in a procedural sense.

    HF trading is here to stay. It is desired because the link has virtually no latency. It should be viewed in the same category as high speed RTTY on HF, for example.

    It is hardly predatory when it becomes a standard of practice. This is 'machine to machine' trading and has nothing to do with you or me placing a trade on our computer or through a broker.

    It wasn't too long ago that hams were considered an asset to RF communications. Now many of us seem to want to fight off new initiatives for a number of quite clear reasons, some of it center around the alleged 'badness' of making money.

    Present plans that I have seen do not call for any use in the ham bands.

    Present plans I have seen generate jobs for hams. And there are some quite famous hams --in their respective professional capacities--involved. Obviously they are not going to deal with the dissing shown here. Why should they?

    Anyway, here is another perspective on the issues.

    73
    Chip W1YW
     
    Last edited: Jul 12, 2020
    WB3EBN likes this.

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