Why (and How) You Should Urge the FCC to Reject the ARRL’s Symbol Rate Petition

Discussion in 'Working Different Modes' started by AA6YQ, Dec 7, 2013.

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  1. AA6YQ

    AA6YQ XML Subscriber QRZ Page

    The ARRL has filed a petition with the FCC to replace the current symbol rate limits with a bandwidth limit. If accepted, digital modes as wide as 2800 hertz would become legal for use by US hams on HF bands. Pactor 3, which is legal under the current symbol rate limit, is 2200 hertz wide.

    If the ARRL’s petition were accepted, automatic (unattended) digital mode stations currently using Pactor 3 could be upgraded to wider modes. Many automatic stations lack the ability to forego transmitting on a busy frequency, and thus interfere with ongoing QSOs. If automatic stations are permitted to use modes with bandwidths up to 2800 hertz, the incidence of this interference will increase significantly.

    While US-based automatic stations using digital modes wider than 500 hertz are restricted to specified sub-bands (e.g. 10,140 – 10,150, 14,095 – 14,099, 14,101-14,112, 21,090 – 21,100, 24,925 – 24930), these frequencies are shared with QSOs between live operators. Furthermore, the WinLink network now claims that its automatic stations are actually under the control of the remote stations that invoke them, and are therefore no longer restricted to these sub-bands. This network now advertises US-based automatic stations running Pactor 3 outside the automatic sub-bands – automatic stations that could be upgraded to 2800 hertz modes if the ARRL Petition is accepted.

    Allowing automatic stations to use wider digital modes without first taking steps to reduce the interference they cause to ongoing QSOs is a recipe for increased conflict and ill will – the opposite of what’s needed. In the interest of continued innovation, we should allow the use of wider digital modes on HF bands – but in a manner that reduces interference and conflict, rather than making it worse as the ARRL’s petition would do.

    I therefore urge you to oppose the ARRL’s petition by filing comments with the FCC before December 17. Don AA5AU has provided instructions for doing so:

    73,

    Dave, AA6YQ

    Member, ARRL
     
  2. NN4RH

    NN4RH Premium Subscriber QRZ Page

    The petition does not propose any change to 97.221.

    97.221 says:

    § 97 .221 Automatically controlled digital station.
    (a) This rule section does not apply to an auxiliary station, a beacon station, a repeater station, an earth station, a space station, or a
    space telecommand station.
    (b) A station may be automatically controlled while transmitting a RTTY or data emission on the 6 m or shorter wavelength bands, and
    on the 28.120–28.189 MHz, 24.925–24.930 MHz, 21.090–21.100 MHz, 18.105–18.110 MHz, 14.0950–14.0995 MHz, 14.1005–14.112
    MHz, 10.140–10.150 MHz, 7.100–7.105 MHz, or 3.585–3.600 MHz segments.
    (c) A station may be automatically controlled while transmitting a RTTY or data emission on any other frequency authorized for such
    emission types provided that:
    (1) The station is responding to interrogation by a station under local or remote control; and
    (2) No transmission from the automatically controlled station occupies a bandwidth of more than 500 Hz.


    Note (c )(2). Automatically controlled stations outside the ranges mentioned in (b) cannot be more than 500 Hz wide. The ARRL petition does not change that rule.

    Manually local or remote controlled stations can be wider, but not the automatically controlled station.

    If Winlink network is already using automatically controlled stations outside the 97.221(b) reservations, as you seem to be saying, then they are already in violating of the FCC rules.


    Ron NN4RH
    Member, ARRL
     
  3. N0SYA

    N0SYA Ham Member QRZ Page

    ARRL fight!
     
  4. N1ZZZ

    N1ZZZ Ham Member QRZ Page

    The problem Ron is that they are allowed to use narrower modes such as the narrow winmor or pactor 1/2 outside the aforementioned automatic sub bands. They do this and interfere with live operations which is the big issue. The petition does nothing to fix this problem.
     
  5. W4PG

    W4PG Super Moderator Lifetime Member 279 Volunteer Moderator Platinum Subscriber Life Member QRZ Page

    This "claim" by the WinLink network appears to be in direct conflict with the current rules. § 97 .221 in part reads:

    (c) A station may be automatically controlled while transmitting a RTTY or data emission on any other frequency authorized for such
    emission types provided that:
    (1) The station is responding to interrogation by a station under local or remote control; and(2) No transmission from the automatically controlled station occupies a bandwidth of more than 500 Hz.

    Obviously the WinLink station is responded to "interrogation" by another station and the claim that they are thus under the control of the remote station (and thus not required to remain in the specific sub-bands) is an attempt to circumvent the rules as written.

    This, of course, is a separate issue from the symbol rate,which is the sole issue being addressed by the current Petition.

    I neither operate in these sub-bands nor have ever had any issue with the WinLink problem mentioned (interference by a robot not listening before transmitting). So practically speaking, I don't have much experience to really say what affect the petition will have on this but it seems to me we need to enforce the rules as written, which is the way to address the interference issue.

    OTOH, I have had plenty of experience trying to operate CW during a RTTY contest and having someone "blast" me off the band with RTTY!! :)
     
  6. NN4RH

    NN4RH Premium Subscriber QRZ Page

    I already said that the petition proposes no changes to 97.221.

    The deliberate interence problem you mentioned, which I have experienced myself first hand a number of times, is an enforcement issue. It is already against the existing rules.
     
  7. NN4RH

    NN4RH Premium Subscriber QRZ Page

    That should say


    Plus the FCC rules only apply to USA stations
     
  8. KO6WB

    KO6WB Premium Subscriber QRZ Page

    Other than PACTOR 4 the league has not given any examples of modes that can be utilized.
    Somewhere someone with deep pockets is making waves and the ARRL is buckling under to accommodate an individual or a very small group of individuals.
    Specifically mentioning PACTOR 4, a mode that is used for e-mail service to boats, seems way to narrow and falls under the classification of a special interest group.
    If those with boats wanting e-mail service then they should find another way without using amateur radio for what is more like a business transaction.
    PACTOR 3/4 coding is not available unless you purchase the system. To me this is a coding or cipher system designed to hide the content from prying eyes.
    This mode should be disallowed under the current rules but it appears the league managed to squeak that one in. Again, someone with deep pockets and a very small group is involved.
    Seriously, how many PACTOR stations are used for amateur communications and how do we know that?
    It's time this special interest group gets slam-dunked.
    Can't conform to the rules, too bad........

    Have fun
    73
    Gary
     
  9. N5CEY

    N5CEY Ham Member QRZ Page

    By opening up the bandwidth allowance for digital modes would allow us to get away from the archaic 300 baud limitation on hf. To me, that would be a good thing allowing faster communications via what ever digital modes could accommodate the new bandwidth allowance. Of course there are those who will always bitch and complain about anything they perceive as infringing on their "rights". It's time to come into the 21st century. If you miss your 2.5khz of bandwidth, spin the dial. And as others have said "Intentional interference is already against the rules and is an enforcement issue". And by the way, I am NOT for asking the FCC to dismiss the ARRL request as i am in favor of it.
     
  10. AA6YQ

    AA6YQ XML Subscriber QRZ Page

    There is nothing 21st century about having your in-progress QSO broken up by a 2800 hertz wide automatic station whose owner hasn't incorporated a busy frequency detector.

    At present, automatic stations are effectively limited to a bandwidth of 2200 hertz (by the 300 baud symbol rate limit in combination with the passband characteristics of most HF transceivers). The ARRL petition, if adopted, would make 2800 hertz signals both legal and practical for automatic stations -- significantly increasing the interference they cause to ongoing QSOs when not equipped with a busy frequency detector.

    Eliminating the 300 baud symbol rate restriction would be fine if the regulations were simultaneously adjusted to prevent QRM from automatic stations from getting worse (e.g. by limiting them to 2200 hertz) or to incentivize automatic stations to incorporate busy frequency detectors (e.g. by limiting automatic stations to 2200 hertz unless they incorporate a busy frequency detector). The ARRL petition does neither of these things, and thus should be rejected.

    73,

    Dave, AA6YQ
     
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