ARRL and Winlink - A Bad Idea for all CW ops - Please Comment to FCC

[W1UJR]

The ARRL is trying through a special meeting with the FCC, to modify Part 97.221 to allow them to utilize the RTTY/Data/CW bands, which will cause serious harm to RTTY and CW contesting, DXing, and ragchewing.

http://mywebpages.comcast.net/hteller/11306-cont.pdf

It means that Winlink Email robots, already widely hated for randomly destroying CW and PSK31 QSO's with 500 Hz-wide signals, would be allowed to destroy as many as six (6) RTTY QSO's, twenty (20) CW QSO's or the entire PSK31 activity segment of the band with a single wideband Pactor-III signal, killing your chance to complete that rare DX or contest exchange just so the less-then-one-percent of U.S. hams that use Winlink will never have to wait for a clear frequency within the current subbands. File comments for RM-11306 to: http://gullfoss2.fcc.gov/prod/ecfs/upload_v2.cgi

[KB1IAW]

Fewer than 1% of US hams use Winlink? How did you arrive at that figure? If that figure is correct how big a problem does  Winlink really pose? When was the last time you had a CW or RTTY QSO interrupted by a "robot" station? If the 1% figure is accurate I must know and communicate with a disproportionate number of those hams, some of whom are long time license holders, not simply new-comers to the hobby looking for a free ride. I just finished sending an e-mail to a friend aboard his boat in the Britany region of France. I also communicate regularly via Winlink with other friends who are currently aboard their boats in North Carolina, Mississippi, Guatemala and Chile. Why must we insist on being so divisive within our hobby? Does this really have to be an all or nothing issue?

[Todd, KA1KAQ]

I think it's mainly the 'automated' aspect that upsets folks, Paul. Something the FCC *and* ARRL were so strongly against suddenly is acceptable. The email/commercial side is a bit troubling as well.

Dave, W1DEC and I discussed this last fall in Tampa after the wedding. Dave is big into sailing, but questioned whether a lot of boaters weren't getting their ham tickets as a way to circumvent having to pay for a costly satellite email service.

Personally, I've never been interfered with by this mode, but I've spoken with others who have. Tony Departo comes to mind, was big into DXpedition stuff years ago and is a Hallicrafters buff today. He's posted on email reflectors about it a number of times, as have others. While I appreciate its emergency comms possibilities, I can also relate to those who don't want to see the amateur spectrum used for email forwarding and other, more commercial ventures.

And all this time I thought sailing was a means of escaping all the distractions and interruptions of everyday life. Today the marine radio is kept company by the cell phone, satellite TV system, email and interent access...  Sounds more like 'home, some water added'?

(that's tongue-in-cheek, btw - hard to tell in print. To each, his own)

[Pete, WA2CWA]

The ARRL is trying through a special meeting with the FCC, to modify Part 97.221 to allow them to utilize the RTTY/Data/CW bands, which will cause serious harm to RTTY and CW contesting, DXing, and ragchewing.

http://mywebpages.comcast.net/hteller/11306-cont.pdf

It means that Winlink Email robots, already widely hated for randomly destroying CW and PSK31 QSO's with 500 Hz-wide signals, would be allowed to destroy as many as six (6) RTTY QSO's, twenty (20) CW QSO's or the entire PSK31 activity segment of the band with a single wideband Pactor-III signal, killing your chance to complete that rare DX or contest exchange just so the less-then-one-percent of U.S. hams that use Winlink will never have to wait for a clear frequency within the current subbands. File comments for RM-11306 to: http://gullfoss2.fcc.gov/prod/ecfs/upload_v2.cgi

Old news that has been corrected as of 3/22/07; you need to review your sources.

There was a "clerical" error on the ex parte filing made by the ARRL on 2/14/07 which is what you are pointing too.

You should also be aware that the current rules permits certain data emissions of any bandwidth in the HF bands. The ARRL was trying to correct that issue but the "clerical" error made it even more confusing.

See the ARRL Erratum for RM-11306 ex parte filing, dated March 22, 2007.
http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6518914061

WinLink is growing and its needs and limits should be considered and defined along with all other modes.

[AF9J]

OK,  I think I'll add my 2 cents worth.  I run a Hellschreiber net on 80m, and have been directly affected by this issue. Here are the basics:

Winlink basically uses Pactor III, and allows you to access the Internet via the Winlink station.  Pactor III is rather wideband in nature for a digital mode (about 2.5 to 3.5 kHz in bandwidth).  Most Pactor III stations are automated.  Also the equipment and encoding for Winlink/Pactor III access & operations is pretty much proprietary (it's made by a German company, and costs about $1000, hence the reason why many hams don't use the system).  Now it gets cool.

By FCC regs, automated/robot stations are allocated certain frequency segments in the HF bands.  The recent reallocations on 80 & 75m threw this all out of whack, putting Pactor III stations in the same frequencies still being used by CW, RTTY, PSK31, (and in my case) Hellschreiber.  So things are quite a bit more crowded now.  If it were just a bandwidth issue it would be a big hassle.  But the nice fancy "the automated station will listen for frequency occupancy, and not transmit if it is occupied", software oftentimes doesn't work. So ever since Pactor came out, CW and digital mode operators, have suddenly had their QSOs blanked out by this loud graunching Pactor signal.  As a result, most of them hate it.  Due to QRM from some Pactor III stations firing up in the middle of 80m Hellschreiber nets I've been running, I've been forced to move the net frequency.

Now the ARRL is saying that there just isn't enough space on the bands in the Winlink/Pactor III freqeuncy slots.  And, they consider it a vital, cutting edge mode, that deserves more space. So, to ensure that it (and other future wideband communications modes) can survive, the ARRL is asking the FCC to purely regulate frequency allocation, by emission bandwidth, not mode.  The only problem, is that no mention is made of automated/robot station QRM issues that have cropped up.  The ARRL proposal chooses to completely ignore this issue.  That's trouble just waiting to happen.  You see, if this proposal were to become law, Winlink/Pactor III stations, would be allowed, almost anywhere in the phone bands.  That means, you could be in the middle of a nice roundtable, when all of a sudden, a Pactor robot does to you what it's been doing to the non-phone ops for years - firing up (after NOT hearing your QSO in progress), with a loud graunch, and ruining your QSO.  No Thanks!  If you go to the FCC comments about this proposal (when I checked yesterday, there were over 1200 comments), they've been overwhelmingly against it.  Most of the ops were phone ops.  Still, the more comments the better, to let the FCC know that the average ham is definitely against this proposal.

73,
Ellen - AF9J

[AF9J]

Hi Pete,

The problem isn't so much bandwidth, as the fact that the proposal makes an endrun around the problem of the QRM these robot stations cause.  I had my Feld Hell net chased off of 3587 kHz (were I had been running it since before the phone subband reallocation), and down to 3574 kHz, because of 2 weeks in a row, of Pactor graunch firing up, during the middle of my net, and blocking it out.  I was told by net participants that (from their past experience)  it was a lost cause to try to get the Pactor station to cease and desist, so we moved the net.  That's wrong, I shouldn't have had to do that.

I've read how the automated/robot stations are supposed to have listening protocols, that prevent the station from firing up on an occupied frequency, to prevent QRM from occurring.  Why is it that these protocals never seem to work, unless the signals the robots hear, are running at least S9 Plus?

73 & respectfully,
Ellen - AF9J

WinLink is growing and its needs and limits should be considered and defined along with all other modes.

[Steve - WB3HUZ]

Why is it that these protocals never seem to work, unless the signals the robots hear, are running at least S9 Plus?

Hee, hee! You are asking the ARRL, a non-technical organization, to answer a technical question. Good luck.

[AF9J]

LOL!! I meant it in a rhetorical sense of course.  Not even the so called experts have given a good reason as to why this robot QRM happens, or why it should even be allowed to happen.   Ahhhh!  I'm on vacation today. I have to get out of here!  I shouldn't be spending it, hanging around on the computer!

73,
Ellen - AF9J

Hee, hee! You are asking the ARRL, a non-technical organization, to answer a technical question. Good luck.

[AG4YO]

ARRL has a website.  They can surely let us know what is going on.  Until the mistakes are fixed, we need to keep watch.  I agree the the 3kHz limit on data modes under 28mHz is right thing to do. My kudos to Skip and Paul for getting this out and bringing it to a head.  They got results.

[Pete, WA2CWA]

ARRL has a website.  They can surely let us know what is going on.  Until the mistakes are fixed, we need to keep watch.  I agree the the 3kHz limit on data modes under 28mHz is right thing to do. My kudos to Skip and Paul for getting this out and bringing it to a head.  They got results.

Yep, but one has to click it on.

The Latest ARRL Words:
http://www.remote.arrl.org/news/stories/2007/03/23/101/?nc=1

And Proposed Rule Changes:
http://www.remote.arrl.org/announce/regulatory/rm-11306/appendixA.html

[Steve - WB3HUZ]

But you missed the 3 kHz limitation on ALL modes other than AM below 29 MHz, which really has nothing to do with QRM from automated stations. Seems like a "solution" without a problem.

ARRL has a website.  They can surely let us know what is going on.  Until the mistakes are fixed, we need to keep watch.  I agree the the 3kHz limit on data modes under 28mHz is right thing to do. My kudos to Skip and Paul for getting this out and bringing it to a head.  They got results.

[W1UJR]

Not even the so called experts have given a good reason as to why this robot QRM happens, or why it should even be allowed to happen.  
73,
Ellen - AF9J

Right!
Isn't the real point that QRM is QRM, irrespective if occurring on a HF or VHF freq.?

Not to gouge someone's sacred cow, which it looks like I already did, but if the FCC holds repeater operators accountable for abuse of a local repeater, why should the control ops of robot stations be held to a lesser standard?
Isn't the control op ultimately responsible for the operation of the station, automated or not?

Which argues the case why Winlink should not be run like a beacon station on a very small and intentionally limited number of fixed frequencies?
Or even better, defer to a commercial service outside the amateur bands.

That's my 2 cents.

[KB1IAW]

^{The problem isn't so much bandwidth, as the fact that the proposal makes an endrun around the problem of the QRM these robot stations cause.  I had my Feld Hell net chased off of 3587 kHz (were I had been running it since before the phone subband reallocation), and down to 3574 kHz, because of 2 weeks in a row, of Pactor graunch firing up, during the middle of my net, and blocking it out.  I was told by net participants that (from their past experience)  it was a lost cause to try to get the Pactor station to cease and desist, so we moved the net.  That's wrong, I shouldn't have had to do that.}

Ellen, thanks for actually answering some of my questions without resorting incendiary prose or an hysterical call to arms. I don't use PACTOR III except as the recipient of e-mail from fellow hams located where there are few economical options. While I see a great tool for communication I can understand why you (and others) are no fan of the mode. There is no excuse for QRM, whatever the source. It seems to me that a simple rule change could solve this problem.

[Pete, WA2CWA]

An AM Concern:
Maybe I'm missing something in the reading, but these are the revised Notes for 97.307 that are listed here:
http://www.remote.arrl.org/announce/regulatory/rm-11306/appendixA.html
It would seem to me that Note (5) is missing from the Section 97.305 HF table (Phone, image lines). It only appears in the 10 meter section.

Here's what they wrote:
Section 97.307(f) is amended to read as follows:

§ 97.307  Emission standards.

*****

(f) The following standards and limitations apply to transmissions on the frequencies specified in § 97.305(e) and (f) of this Part.

 (1) No angle-modulated emission may have a modulation index greater than 1 at the highest modulation frequency.
(2) No non-phone emission shall exceed the bandwidth of a communications quality phone emission of the same modulation type. The total bandwidth of an independent sideband emission (having B as the first symbol), or a multiplexed image and phone emission, shall not exceed that of a communications quality A3E emission.
(3) The bandwidth of a RTTY or data emission must not exceed 3 kHz.
(4) Phone and image emissions may be transmitted only by stations located in ITU Regions 1 and 3, and by stations located within ITU Region 2 that are west of 130° West longitude or south of 20° North latitude.
(5) The 3 kHz maximum bandwidth does not apply to double-sideband amplitude-modulated phone A3E emissions.

(6) No specific bandwidth limitations apply except that the entire emission must be within the allocated band to meet the requirements of §97.307(d).

[k4kyv]

The emission table limits "RTTY, data" to the so-called CW bands, and "phone, image" to the phone bands.  The revised table makes no specific mention of CW whatsoever.  Is CW now considered a "data" mode?  If so, this would constitute a major revision in where CW may be transmitted.  Historically, and under the present rules, CW is permitted anywhere on any band (except for the 60m channelised "amateur CB" allocation). But this revised table would appear to prohibit the transmission of CW wherever phone is permitted, a radical reduction in the historic privileges accorded CW.

Or have I overlooked something?

In addition, this change appears to prohibit "ESSB" in the 10m band below 29.0 mHz, but it would still be permitted on 160-15m.

[w3jn]

To further muddy the waters, I wonder why Heilschrieber is in the CW portion, as it is an analog image mode rather than a digital mode (to the best of my recollection).   Perhaps it would be more appropriate in the phone portion.  Or maybe not 

[Pete, WA2CWA]

Well, unless I'm overlooking some other note somewhere, based on their revised document, all double sideband AM would have a maximum of 3 KHz bandwidth on all HF bands except 10 meters. And, what is "communications quality phone emission" (2KHz?, 3KHz?, 6Khz?)?

[Steve - WB3HUZ]

And what are the technical parameters for measure the bandwidth?

[AF9J]

Actually Hellschreiber is basically a fuzzy mode.  It uses on/off keying to create black "scanning dots" across a paper strip, or computer screen.  The keying can either be CW, FSK, or PSK related.  Bandwidths are from 34 Hz up to maybe 500 Hz tops. If you ever look at a Hellscreiber image, it looks like a printed duplicate or triplicate, on a strip of paper.  Feld Hell (the oldest version) was invented by Rudolph Hell of Germany back, in 1929, and was very popluar with the newswire services, into the 60s.  It was used by the German military during WW2.  Hellschreiber is actually like a primitive from of Fax.  For operative use, it's sort of considered a digital mode (even though it's rally an analog mode).

Here's a link that shows what a Hellscreiber signal looks like, and what the mode is all about:

 http://www.feldhellclub.org/technical.htm

73,
Ellen - AF9J

To further muddy the waters, I wonder why Heilschrieber is in the CW portion, as it is an analog image mode rather than a digital mode (to the best of my recollection).   Perhaps it would be more appropriate in the phone portion.  Or maybe not 

[W2VW]

And what are the technical parameters for measure the bandwidth?

You purchase a radio with that already done by the manufacturer. You are not allowed to add a power mike.

[w3jn]

BW measured at the -6dB points?  -60 dB points?

How is typical Hammy Hambone, who has a hard time soldering a mike plug together, gonna figure out how to measure bandwidth, and is someone going to mandate that we all have HP 8591 spec ans in our shacks 

[Steve - WB3HUZ]

Yup. Most hammy hambones could not measure their transmitted bandwidth.

And what are the technical parameters for measure the bandwidth?

You purchase a radio with that already done by the manufacturer. You are not allowed to add a power mike.

[W1UJR]

Yup. Most hammy hambones could not measure their transmitted bandwidth.

I measure my bandwidth with a yardstick, a big RF yardstick.

[AG4YO]

The emission table limits "RTTY, data" to the so-called CW bands, and "phone, image" to the phone bands.  The revised table makes no specific mention of CW whatsoever.  Is CW now considered a "data" mode?  If so, this would constitute a major revision in where CW may be transmitted.  Historically, and under the present rules, CW is permitted anywhere on any band (except for the 60m channelised "amateur CB" allocation). But this revised table would appear to prohibit the transmission of CW wherever phone is permitted, a radical reduction in the historic privileges accorded CW.

Or have I overlooked something?

In addition, this change appears to prohibit "ESSB" in the 10m band below 29.0 mHz, but it would still be permitted on 160-15m.

This points to the need to reject the whole petition and try again.  There are alot of unclear issues as you mention which is why I was not inclined to just drop it after the ERRATUM on 3/22.  And yes I read the ARRL  site info before I posted. In it they made things more unclear as you point out.  I think we deserve a clear picture of something before we sign up to agree.  Thanks!

 

[Pete, WA2CWA]

The emission table limits "RTTY, data" to the so-called CW bands, and "phone, image" to the phone bands.  The revised table makes no specific mention of CW whatsoever.  Is CW now considered a "data" mode?  If so, this would constitute a major revision in where CW may be transmitted.  Historically, and under the present rules, CW is permitted anywhere on any band (except for the 60m channelised "amateur CB" allocation). But this revised table would appear to prohibit the transmission of CW wherever phone is permitted, a radical reduction in the historic privileges accorded CW.

Or have I overlooked something?

In addition, this change appears to prohibit "ESSB" in the 10m band below 29.0 mHz, but it would still be permitted on 160-15m.

This points to the need to reject the whole petition and try again.  There are alot of unclear issues as you mention which is why I was not inclined to just drop it after the ERRATUM on 3/22.  And yes I read the ARRL  site info before I posted. In it they made things more unclear as you point out.  I think we deserve a clear picture of something before we sign up to agree.  Thanks!

The table you point out only covers the revisions. If you note in their proposed revised 97.305, Item (a) is not mentioned since it has not changed. Item (a) of 97.305 currently states:
(a) Except as specified elsewhere in this part, an amateur station may transmit a CW emission on any frequency authorized to the control operator.

You can review all of the current Part 97 Rules here:
http://www.arrl.org/FandES/field/regulations/news/part97/