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I believe we need to limit either the "symbol rate" or the bandwidth below 54MHz.
In general, the faster the "symbol rate" the wider the bandwidth to transmit it. If you don't limit the symbol rate or the bandwidth to transmit it, it can be as wide as the whole band!
I don't know what the bandwidth should be, but we don't need digital modes *wider* than SSB below 54MHz! I don't want to turn ham radio into an email service!
The directions in the email didn't work for me. Here are my instructions:
3. Click on "Submit a FILING" on the top bar in the middle of the bar.
4. Click on "Express Comment" on the second bar in the middle of the bar.
5. In the "Proceeding(s)" box start typing "RM-11708" and click on the matching field that pops up.
6. Fill out the rest of the form. Make sure to put that you "Disagree with the NPRM" in the "Brief Comments" section and why you disagree. FYI, my comment was:
"I disagree with the NPRM. The higher the symbol rate, the wider the bandwidth needed to transmit. We need either a bandwidth limitation or a symbol rate limitation in the rules - especially for 54MHz and below where bandwidth is very limited. Removing both would allow transmissions to grow to take up the entire band."
7. Click on "Continue to review screen" at the bottom of the page.
8. Review what you have written and then click on "Submit".
From Dr. Ted Rappaport, N9NB
Subject: if you care about CW and RTTY - time is of the essence
If you believe, as I do, that the proposal to unregulate the bandwidth of
data signals (like Pactor 4) in the lower HF portion of the spectrum is
dangerous for the hobby, both in the US and abroad, then please read on as
we need your help. If you do not agree with me, or don't care about this,
then feel free to delete and stop reading.
I ask that you PLEASE take action by filling public comments with the FCC
regarding their recent RM 11708 proposed rulemaking in WT Docket No. 16-239
and RM-11708, and please forward this to every CW and RTTY enthusiast you
know in ham radio, on every reflector, in every CW and RTTY club, both in
the US and elsewhere, and urge them to also file comments with the FCC. We
have less than 3 weeks to voice our opinion! It was not heard in 2014-2015.
TIME IS OF THE ESSENCE! There are less than 3 weeks during which the FCC
will accept comments.
I am fearful and quite certain that RM 11708, as published in WT Docket No.
16-239 , which the FCC is now seeking public comment on as a prelude to
enact its ruling, will terribly erode CW and RTTY on the HF bands in its
current form. The ruling will allow PACTOR 4 and multi-tone modems on any
frequency within the CW/RTTY frequencies on HF. This is worse than allowing
SSB to operate throughout the CW/data sub bands, something the FCC has never
allowed. The FCC is proposing an unlimited bandwidth for data signals in the
lower HF bands (the ARRL asked for 2.8 kHz-- the bandwidth of SSB--- which
was still bad - and the FCC proposal is even worse). I would urge all of you
write in to object to RM 11708 and to ask that the FCC place a 500 Hz
bandwidth limit all data transmission bandwidths such as Pactor, multi tone
data modems, and other experimental data modes on all HF bands within the
lowest 75 or 100 kHz region of each HF band. Japan has something similar. If
we don't generate large support from hams to scale back the FCC proposal,
and put a bandwidth cap in some portion of the lower HF bands, these monster
QRMers of unlimited bandwidth will be allowed to operate anywhere in the
CW/RTTY lower HF bands, and they will lawfully fire up on your CW or RTTY QS
when you are least expecting it.
See below how the proponents of RM 11708, including my friend Tom Whiteside,
are launching an aggressive letter-writing campaign for "pro" comments to be
filed at the FCC to allow Pactor 4 and other wideband multi-tone modems to
operate anywhere in the CW/RTTY spectrum, without a segregation of the band.
The public filing period ends in a few weeks, so we must write now to offer
opposition to the Commission. The need for WinLink/Pactor data emergency
communication on HF is being used as one of the arguments for expanding the
data bandwidth. See the other arguments below. I would urge CW and RTTY
enthusiasts to review the arguments for and against RM 11708, see the public
comments filed from March 2014 to today, and please be moved to quickly to
write about your opposition to the newly proposed regulation just released
by the FCC (It can be viewed here):
Please see Tom's email below on how to file a comment, but I would urge you
to read the FCC proposal and file comments *against* the FCC's proposed
rulemaking. You can see the ballet box is again be flooded for the expanded
data privileges in the past week - there are only 20 days to file comments.
If this ruling is enacted, and the FCC is leaning that way, this will come
at a cost to CW and RTTY . See these comments already filed:
Unfortunately, in the FCC proposed ruling issued over a week ago, the
Commission appears to have ignored ALL comments made by hams after the
initial 30 day comment period back in late 2013. During that one month
period, there was a 95% "pro" letter writing campaign by over 800 people --
It was only after the CW and RTTY enthusiasts woke up in March of 2014 that
public comments became overwhelmingly negative against RM 11708.
Unfortunately, the FCC has apparently ignored all of those comments, so new
comments need to be filed on the FCC;s recent ruling.
If you care about CW and RTTY, please file comments against the ruling, to
preserve some sanctuary for narrowband data (having less than 500 Hz
bandwidth), the way the largest ham country (Japan) has done to ensure no
QRM to CW and RTTY enthusiasts.
Thanks for considering.
Best 73 ted n9nb
Winlink Global Radio Email for Disasters or Emergency Preparedness
Comments on RM-11708 - time to get those comments in! by "Tom Whiteside"
Comments on RM-11708 - time to get those comments in!
Fri Aug 5, 2016 2:36 am (PDT) . Posted by:
"Tom Whiteside" n5tw
As you have heard on this reflector, the FCC has amended the ARRL filed
RM-11708 and is now seeking comments on this. It is critical that we add
our supporting comments during this period and the process below is a step
by step on how to do so.
I'd suggest something simple - please make it clear that you support the
amended proposal - these responses are going to be tallied at least at the
first level by clerks so be clear! In my filing, I emphasized the clear
gain in efficiency with the elimination of the archaic symbol rate and sited
currently not legal Pactor 4's ability to double the throughput in the same
bandwidth as Pactor 3 and that this would bring us on par with the rest of
Use your own words - form letters will be seen as such.
And thanks for your important support! Instructions on filing below:
Tom Whiteside N5TW
IMPORTANT MESSAGE: Time is running out for comments supporting RM-11708 to
the FCC, which would remove the symbol rate limitation from FCC rules, and
allow hams to use Pactor 4 modems in the USA. If the proposed rule change
fails this time, it will be years before we have another chance.
It is very easy to submit a comment. Please do. You don't have to say much
other than you think it's a good idea, and that you support it.
Here are the steps to submit a comment.
1. Go to <http://apps.fcc.gov/ecfs/> http://apps.fcc.gov/ecfs/
2. Select "Submit a Filing (Express)" from the list in the upper left corner
of the screen.
3. In the topmost paragraph of the next screen, click "click here to
manually enter your docket number"
4. Enter RM-11708 as the "Proceeding Number". Enter your name, address, and
type your comments in the bottom field.
5. Click "Continue";, and then click the "Confirm" button on the summary
it will display.
6. If everything goes properly, it will give you a submission confirmation
Here are the relevant points:
a. The proposed change does not alter the bandwidth limits or the
frequencies available for digital use, so no new frequency space is being
used. It has no negative impact on the Ham spectrum.
2. The use of Pactor 4 simply makes the use of existing bandwidth more
efficient, so additional traffic can be passed without allocating new
3. The further development of even faster protocols in the same bandwidth
limitations depends on the success of this rulemaking