The AM Forum

Although not directly related to our "normal" AM/voice operations at this time, this is a proposal that will now define "maximum necessary bandwidth" for RTTY/Data/Image modes in all our amateur bands and make it part of the official FCC rules.

Here is the original proposal:
http://fjallfoss.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6519008574
 (http://fjallfoss.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6519008574)

To view all the comments, go here:
http://fjallfoss.fcc.gov/prod/ecfs/comsrch_v2.cgi (http://fjallfoss.fcc.gov/prod/ecfs/comsrch_v2.cgi)
Then, put RM-11392 in the "Proceeding" Field, and then "Retrieve Document List"

Sharpen up your measuring tools, "bandwidth" is not going away.

Unlike many petitions, notably many of the ARRL's, that one is fairly well thought out and supported with external cites. 

Although I didn't read it in great detail he, as with most other regulation-by-bandwidth proponents, infers that necessary bandwidth is equivalent to actual bandwidth.  He goes on to state that FSK and AFSK signals don't have the same linearity equirements as PSK.  That may be true, but AFSK needs good linearity to limit IMD and spurious signals.  He assumes that just because someone is running an amp under its capacity everything will be FB.  Ultimately, hammy hambones being what they are, they're gonna try and extract every last watt outta that poor ricebox, so his strategy is suspect.

I also disagree with his assertion that "symbol rate" loses its definition with complex modulation methods.

As it appears that this winlink crap is the crux of the problem in.re. all of these stupid regulation by bandwidth proposals, why not refine the unattended operations regulations?

I think all in all he makes an outstanding case in laying out the problem as well as some good solutions, but I disagree that regulation by bandwidth is one of them.  If only all such petitions were as well written and well-supported...

I agree with you, Johnny.

This guy does have a legitimate beef, but I think if he thought out the proposed solutions as much as he thought out the problem, he would have come up with some more straightforward solutions.

He's referring to bandwidth because the digital modes, unlike voice modes, have had bandwidth figures attached to them in the regs over the years. This is easily done with an FSK mode, since you've got two fixed frequencies, a switching rate, and a resulting modulation index, these things are easily calculable and don't require a spectrum analyzer.

The only ways to get it wrong (outside your transmitter being horribly tuned or just plain broken, and different regs govern that) are to have the wrong shift or the wrong switching rate, and in either case the other station just won't be able to decode you. Bandwidth numbers related to digital emmissions are fairly benign, they've been there for decades and there's no need to directly enforce them, since anything that goes wrong which results in incorrect bandwidth typically renders you unintelligible to other stations receiving in that mode.

He's right in that the current regulations regarding digital HF emmissions are FSK-centric and that those regulations need to be revisited. I think he landed on bandwidth because that's one criterion that's been used to separate various FSK emmissions over the years, right or wrong. It may well be that criterion needs to be deprecated in favor or separation by more currently-relevant properties.

Digital emmissions are the few instances where bandwidth numbers start to make sense, because they're inherently fairly well fixed and consistent; unlike phone modes, where the bandwidth is inherently variable from operator to operator, transmitter to transmitter, and mode to mode.

Fortunately, this gentleman seems to reflect that discrepancy in his petition (and you can tell he did his homework regarding petitions filed along similar lines).

I suspect that's why we've got all kind of "bandwidth cops" sprouting up these days: they think in Internet terms and try and apply them to non-data transmissions where they no longer make sense.

All in all, this guy's got some good points, and maybe it's time the Amateur Community (ever been there? me, either) put our heads together and came up with some criteria that allows the PSK and FSK modes to live in harmony that doesn't involve bandwidth measurements.

--Thom
Keplerian Acquisition One Zooming Galactic Cruiser

I'm just hoping one of these idiots writes a law that allows spark by mistake.

They already do, and they have for years. Nothing new there. The digital modes have had bandwidth limits in place for a long time, but like I said earlier, they're fairly benign. Those bandwidths are in place to indirectly keep the mark/space frequency spread and the switching rate down to certain levels. By the time you violate the bandwidth by using the wrong freq spread or switching rate, your signal is already unintelligible to any receiving stations. You want to be heard, so you'll fix the problem. I don't recall any digital stations being cited due to bandwidth, yet those regs are there.

That's why this guy's complaining, those values have much less meaning when applied to a PSK signal. He's got a valid point there.

I see this as an opening to get the last vestiges of bandwidth limitation removed, not reinforced. There are more sensible ways to keep incompatible FSK and PSK dialects from stomping on each other without applying the bandwidth yardstick.

Let's not assume the FCC are all complete idiots, either: they know that bandwidth is easily applied to digital emmissions because of the nature of the emmission itself. This is not the case with phone emmissions, unless everyone had exactly the same voice, always spoke in a monotone, and had the exact same transmitter set to the exact same levels. It doesn't work that way with phone, and the FCC knows that, too.

Just because the majority of hams try to apply Internet-style concepts of "bandwidth" to things that just don't work that way, doesn't mean the FCC also lost touch with the way these things really work.

--Thom
Killer Agony One Zipper Got Caught

I have not had the time to thoroughly read this longish petition, but it seems OK.  Does anyone see an explicit or implicit threat to AM here?
73
Steve WA2DTW

Did I say that? No, I didn't.


Just how do you know that? Do you have the keys to Riley's office, or access to the FCC email server? Are you handed a report every morning outlining and categorizing the complaints made to the FCC over the previous day?

The answer is empatically no, to all of these.

Instead, you are presenting your presumtions as cold, hard facts rather than setting your presumtions aside and gathering the facts that are available. You assume that the complaints you hear about in your little AM microcosm are the only complaints that ever come in to the FCC, about anything, ever.

That attitude's not going to solve anything, nor is conversation going to go any further.

--Thom
Killer Aircraft One Zeppelin Goes Crash

Mack this is not true.

Riley gets lots of complaints about 14.313 and similar frequencies. Riley gets lots of complaints about repeater jammers.

This is what Thom was referring to.



Items 3 and 4 will yield a bandwidth when the math is done. Items 5 and 6 give and explicit maximum bandwidth, as noted by the bolding I added.

Evening Gents,

 Well, it didn't take long, and, I do like some of that gentleman's thoughts, but like Thom says....I liked the way he put that on measurement.....I'm sitting out and watching this one...

jack KA3ZLR.

The author of this petition, Mark, N5RFX, provided the digital promoters at the ARRL with part of their basis to push their threatened bandwidth petition.

Mark had an editorial letter published in QST that lamented how the current Rules do not provide for the mixing of digital and voice modes that may naturally take place during a QSO.

League administrators saw his concern as something to promote, to help explain Rinaldo's push for digital by changing the U.S. regulatory structure.

Mark has seemed to be a reasonable person in various postings and discussions he takes part in. He is not a rabid League loyalist, and there are times when he very specifically acknowledges shortcomings in the ARRL's approach to perceived problems with "digital" under the current regulatory structure.

From QRZ.com, this posting from Mark may help characterize where he's at with the petition he has filed.

---

Quote (WA0LYK @ Dec. 10 2007,09:36)
Consequently, these studies had nothing to do with maximizing intelligibility, but rather, with economically providing an minimally acceptable level of intelligibility.

Jim,

Thanks for the excellent post and the link to the white paper.  This type of white paper is what should be coming out of the ARRL and the IARU to explain their position of limiting the bandwidth of a SSB signal to 2700 Hz.  The white paper you referenced dealt with wired telephony, and a similar white paper should be presented with respect to RF telephony.

I suspect the compromise with respect to RF telephony had something to do with limiting the occupied bandwidth of a SSB emission.  Do we need to set a hard limit with respect to the Amateur Radio Service?  That is the million-dollar question.  Today we have limits on power and spurious emissions, but there is reluctance by some to set a hard limit on telephony bandwidth.  This reluctance is understandable.  I think that the dilemma is how to set a hard limit while not de-authorizing AM in the process.  The other dilemma comes from how not to prevent experimentation with wider signals.  I don't have the answers to these dilemmas and it seems neither do the ARRL or the IARU.

I do feel that we need to restore the narrow bandwidth nature of the RTTY/Data subbands, but in the Phone/Image subbands, setting a hard bandwidth limit has not yet been justified.

73,
Mark N5RFX

There is no control operator for this digital crap it just appears out of the blue and trashes a QSO. sorry this isn't ham radio. You want email buy it

I'm always leery about regulation by bandwidth.  But, as one whose net was a casualty to Winlink on 80m (3 weeks in a row of Winlink QRM, basically ran the Hellschreiber net I was NCS for, off of its freq.), I have no sympathy for the Winlinkers.  Make 'em go bye-bye.   Good riddance too.  If they can afford umpteen hundred thousand dollars (in some cases) for a boat, they can afford $250/year for the commercial Sailmail, radio e-mail service.

73,
Ellen - AF9J

So it would appear the problem is not one of bandwidth but a lack of control op, or the ability to determine if the frequency is in use automatically.

Yes, that is the case Steve,

They are automated.  The modems they use are supposed to have busy freq. detection, but claims are made by others who have been fighting with Steve Waterman K4CJX (who is one of the Winlink developers), that he has told the PMBOs (basically the owners of the automated link stations) to turn off busy detection, otherwise they'll never be able to run the automated stations, due to freq. occupation.  People have been trying for years to deal with the Winlink crowd, to try to come to some sort of a compromise.  From what I've read, they've either been ignored by the Winlinkers, or treated with outright hostility by them.  A few of Winlinks biggest critics, used to be its supporters.  A few of them even used to belong to the Winlink Yahoo group.  But when they asked questions voicing their concerns about certain aspects of Winlink, they were immediately banned from the group.  The differences of opinion that we have in the AM Forum are not allowed in the Yahoo Winlink group.  Either you sing along with the choir, or you're out.  It's kind of like the HFpack group that Bonnie Crystal, KQ6XA (who also happens to be a big Winlink supporter) owns.  If you disagree with her too much on issues, she'll ban you from the group.  

The Winlinkers want more freq. space (as automated stations).  They are fond of stating that they are the future of amateur radio, and that blocking their wishes will put amateur radio "back in the dark ages."  They also cite Winlink's EMCOMM capabilites, but have yet to show any actual emergency traffic sent via Winlink (on HF that is - there is a VHF Winlink, that nobody is having problems with).  As of now, the vast majority of Winlink is basically being used for e-mail.  There are issues about the legality of this (since so much e-mail is of a 3rd party nature, and none of the control ops for the automated stations screen the e-mail [which is required by the regs]).  

I get the impression from the QRZ.com thread I read, that RM-11392 came about more as a last resort, due to a lack of cooperation from the Winlinkers, in working out the problem.  Here's the thread:

http://www.qrz.com/ib-bin/ikonboard.cgi?s=f5d7eb22481be3e3f0c54e660341dcde;act=ST;f=7;t=178821;st=0

73,
Ellen - AF9J

P.S. - one of the thread participants, Bill, N9DSJ, used to give me relays in my Hellschreiber net.  

I completely agree with Steve's statement. I have been considering commenting on 11392, but only to say I supported the changes suggested concerning what is an automatically operated station.

Winlink may have some other problems like are they a defacto "common carrier" (Australia seemed to think so) ,who is checking for illegal 3 party traffic, and is amateur radio really being used to bypass available commercial services. Although this petition doesn't deal with these things I can see how pushing the legal limits or ignoring possible illegalities could lead to operating in a way where one didn't care about causing QRM. That seems to be the case.

A bandwidth limit of 1.5 kHz isn't going to fix this.

73,

Marty WB2RJR

I wonder where you find these letters....

The ones the ARRL used to publish were very few indeed...
I was told at one time they didn't even publish 10% of them...
Now that the ARRL doesn't publish ANY of them.... the FCC page only shows a half a dozen, maybe a dozen a month...

I wonder if these are what you're refering to, or do you know where the FCC publishes the entire list?

After reading through some very well put together postings on this subject, it comes to mind that this issue has a very simple solution. it doesn't beg a needed necessary bandwidth issuing of already established modes, but more so Placement...considering the operational characteristics of this "Future of Amateur radio" the needs for connectivity and efficiency, what region of spectrum would best suit this conflict.

Why place so much strain on HF with it's unstable nature, and considering the needs for repeatability it would be much more logical to use regions of spectrum with the available room and better geared for such service, Line of Sight.

IMHO.

For all the ones that are listed there, mostly for 2007, none have anything to do with AM which is a good thing.

I don't understand - "HF with it's unstable nature"
What does that mean?

I doubt I'm going to comment on the proposal.  I haven't been involved enough in the issue in (other than the net fiasco I had to deal with last year [Winlink trashed our nets that were in progress ]) to really properly comment on it.   I took a look at the comments on the FCC website, and the majority of "Nay" comments are the same cut and paste boilerplate form type letter.  One guy even commented (after basically calling the FCC a bunch of dummies) on how his investment in the SCS modem (you need to use this $1000 plus proprietary modem, in order to do Winlink [and I think Pactor II & III]) would go down the drain if RM-11392 went into effect.

Ellen - AF9J

Thanks, that's the page I was refering to....
At the top of the page is a few examples of what might not be included...
Makes me wonder why they publish any at all.....

oh well.....\
no matter,

It think it's geared to the unpredictability of HF propagation, Pete. He's basically saying these things are better used on VHF/UHF where line of sight propagation is more stable and predictable.

That's why I think this is a chance to set a real precedent in our favor.

The issue addressed by the petition is a valid one, I think we can all agree. The proposed solution being bandwidth control is where the problem comes in.

I think we should comment on this petition, but only after reading it (and its references) all the way through, and maybe even doing some listening down in the digital portion.

The real problems are: unattended automation determining frequency of operation, nature of the traffic being passed. These are issues that can be solved without bandwidth even entering into it. In fact, bandwidth segregation won't solve those issues at all.

Last I understood the regs, it's already illegal to pass third-party traffic by way of a station under automatic control. This is true of repeater phone patches, you're supposed to have a control op on duty whenever the phone patch is available for use. It's a hard thing to enforce, because it's hard to prove there was no control op around.

What should probably be outlawed is automatic frequency change. It makes no sense to allow a piece of automation make a "QRL" determination on mixed-mode spectrum. Hell, half the hams with heartbeats can't pull that off, it seems. As we all know, a clear freq for one station may be a congested mess for the other station.

The government can do it on 60M because they control the spectrum and they know exactly what's supposed to be on it. Not the case with amateur spectrum.

Anyway, if enough people comment constructively in a manner that addresses the real issues without resorting to bandwidth segregation, we stand a real chance of both solving the problem and staunching the impetus for any future bandwidth proposals that may come along.

It's worth a try.

--Thom
Killer Appetizer One Zesty Green Cannabis

Thank You Bud,..(hows the family by the way and merry xmas om)

 I was attempting a pre-statement writing on how my response is going to be formulated, and i wanted to start here before i go any further, knowing if i'm wrong here i need to re think my writing..

 I see, especially after reading Thoms postings i believe in what he's saying and the majority of members have enough backround to follow through with good responses.

 Believe it or not i'm actually considering this may be like Thom says...The chance to set real precedence, Like Mack says it's in their eye, Now we just need to wait and see what transpires...

Interesting...Way to go Mark......well done OM...

Excellent thread underway on QRZ.com, which includes participation by the partitioner, Mark N5RFX.

RM-11392 Thread (http://www.qrz.com/ib-bin/ikonboard.cgi?s=a74aed462c68047d3c5d2bbabde9898c;act=ST;f=7;t=178821)

---

Mark may have whacked the winlinkers (automated email from the internet) since they've mobilized filling in Opposition.

The petition proposes to close a loophole in Part 97 which allows emissions not appropriate for the RTTY/Data subbands.  Stations under automatic control have taken advantage of the loophole.  This petition looks at the current division between wide bandwidth and narrow bandwidth emissions and suggests a return to narrow bandwidth  emissions (1500 Hz or less) in the RTTY/Data subbands benefiting all licensees.

Please read the petition and make comments to the FCC.

73,
Mark N5RFX

Well I am somewhat in disbelief here.

 I have read a considerable amount of comments, what is this emergency connectivity situation these folks are describing...have we forgotten our J-38's and our basic skills...Wow...and Homeland security...some of those read like the little boy's book report  in that christmas story..."Everybody needs a Red Rider"...LOL...

And I'm killing myself on writing a correct paragraph...with correct spelling...Sheez....Wow...

EMCOMM is basically viewed as a standard response by those who belong to the Church of Winlink.  Whenever they cite Winlink's "valuable contributions" during emergencies, and people tell them to show text from actual examples of emergencies Winlink has been used in, the Winlink supporters become strangely silent.  No examples are provided.  Even those who were involved with Hurricane Katrina, say that Winlink wasn't really used for EMCOMMs then. 

Also, Winlink (and Pactor in general), really isn't a real-time keyboard to keyboard (as in let's have a QSO) communications protocol.  So, you really wouldn't use it for "saving life and limb" real time traffic.  It would be used more for health and welfare e-mail traffic.  But, because it's semi-encrypted (you can't read Winlink stuff, unless you have the $1200 SCS modem),some EMCOMM people like it (in spite of the fact that encryption is illegal in amateur radio).

BTW, John, W3JN made some very good comments in the RM-11392 thread on qrz.com.

73,
Ellen - AF9J

 Hi Ellen how are you dear,

 Happy holidays to you and your family, Ya know I am thinking it is best if at this point Zed.L.R. let's them hang themselves, some of those comments have got to be kidding.."No Other mode can make it"...oh really...Ya know i realize I have been out of commission for a little while..and maybe I'm not so up to date with software...but in a real emergency situation.. life or death...I'm not gona be looking for a laptop...and a modem...I think i'm just a little surprised Dear...I wasn't expecting some of those responses...I'll be ok...LOL...sheez...

Yep Jack,

The Winlinkers got pretty hysterical with their comments.   Most of the comments are derivatives of Bonnie Crystal, KQ6XA's comments.  In my experience in dealing with Bonnie, she has a tendency to resort to hyperbole.  

Mack, somebody started another qrz.com thread, where they posted some comments Steve Waterman, K4CJX (Mr. Winlink himself) made today in the Yahoo Winlink EMCOMM group, with regards to turning off the busy frequency detetction protocols iin the SCS modem.  He basically said "tough luck".  Here's the thread if anybody is interested in it:

http://www.qrz.com/ib-bin/ikonboard.cgi?s=d18af9397e490b0ee9c3963b5b0e0509;act=ST;f=7;t=178998

I really don't know of anything I myself could add in a bandwidth related vein to the FCC comments, since my beefs with Winlink, are more interference related.

73,
Ellen - AF9J

Big Mack, Ellen, Thank You for catching me up to date, Alot,

 I'm at a loss for words here, this is "Sad" truly...betting the whole roll on a computer program....causing this whole insipid commotion....all this Grief...

 This much I do know, any corporation, the life blood, participants members, i will "Cherish"  the day when a change of command falls upon them....and it will in time...Lord help us if there is a Major catastrophe ever to happen....

Where's my LapTop my modem..Ohh we have no electricity..."Where do I plug in"...does anybody remember that "Code" stuff....

I'm out.

About 660 Comments, Reply Comments, Motions and Errata so far.
Hit the link, hit "Search for Filed Comments," and fill in RM-11392.

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http://www.fcc.gov/cgb/ecfs/ (http://www.fcc.gov/cgb/ecfs/)

Half appear to be form letters and the other half are from the same 4-5 people (Sampson, Miller, McVey, Crystal, etc).  :P   It has turned into QRZ.com.

Yeah, disappointing quality level.

Apparently the WinLinkers were stimulated to action because they'll lose their home if the FCC says they don't belong in those segements.

It's a separate question then, as to where they would go.

And, then you go and comment in a very logical fashion. ;D
You've thrown the entire comment string off.