RM-11831

What Was the ARRL Thinking?

It was recently revealed that in mid-July the ARRL Board instructed Washington Counsel David Siddall, K3ZJ, to take steps to obtain FCC approval for several changes to the Part 97 Amateur Radio Service rules. The requested changes we all should object to:

  • Require ALL digital mode stations operating with a bandwidth greater than 500 Hz to operate within the narrow 97.221(b) Automatically Controlled Digital Station (ACDS) sub bands, whether or not these stations are automatically controlled.
  • Require all automatically controlled digital mode stations less than 500 Hz bandwidth to also operate only within the ACDS bands.

The full action is in the ARRL Board minutes, page 16:
http://www.arrl.org/files/file/2019%20Board%20of%20Directors/Final%20Min...

Bonnie Crystal, KQ6XA, founder of HFLink painted a clear picture:

"What ARRL wants, an Analogy:

  • There is a six-lane superhighway we've all used well for years, but now only bicycles and horse-drawn carts can use it.
  • Fast cars and trucks are forbidden on this highway.
  • All the fast cars and trucks must now use a single lane frontage road alongside the superhighway.
  • The bicycles and horse-drawn carts also have the right-of-way when using the frontage road."

While we at ARSFI fully appreciate the Director's other actions on digital matters, this action is simply crazy without expanding the 97.221(b) subbands. You can't responsibly sort and redirect the traffic to a place that can't handle it. On 40 meters, 17 meters and 12 meters, the sub bands are only 5 kHz wide, enough for only a single QSO of fast digital data, or two, depending on the modes. Other narrow sub bands allow only 3-6 simultaneous QSOs without interference. This is their answer to the highly contested RM-11831 petition at the FCC?

Bonnie Crystal calls this, "'Regulation By Bandwidth' + 'Regulation By Content' piled high upon 'Regulation by Absurdity'....but the absurdity would only apply to digital data signals, and not to anything else. That is a huge step back into the Technology Jail."
...click 'read more' below

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ARRL
digital rule making
FCC
RM-11831

FCC Petition RM-11831 Threatens Amateur Digital Operations Like Winlink

April 5, 2019--The FCC has opened for comment RM-11831, a proposal for rule making that would do two things to the US amateur radio rules:

1) remove paragraph (c) of 97.221. This would disallow narrow-bandwidth ARQ modes of 500 Hz or less from outside the specified 97.221 sub bands for automatically controlled digital stations. This will require all US Winlink HF gateway stations, regardless of mode/technique, to only operate within these narrow sub bands.

2) modify the wording of 97.309(4) thusly:
(4) An amateur station transmitting a RTTY or data emission using a digital code specified in this paragraph may use any technique whose technical characteristics have been documented publicly, *such as CLOVER, G-TOR, or PacTOR,* (remove *-*, add the following:) and the protocol used can be be monitored, in it's entirety, by 3rd parties, with freely available open source software, for the purpose of facilitating communications.

This effectively eliminates Pactor 2, 3, and 4 from the US amateur bands unless SCS steps up and publishes complete technical specifications, including their proprietary signal processing methods, and produces an open-source monitoring program allowing on-air eavesdropping by third parties (not likely).

The Winlink Team will have to produce monitoring software for an unconnected eavesdropper for WINMOR, ARDOP. VARA's author must do the same. The alternative is for Winlink to close shop for US licensees on HF amateur bands, or to eliminate B2F compression for messages sent by US-licensed amateurs. This will cause US users of all modes to suffer much longer transmission times by a factor of 2-10 times. Limits would not be placed on other users.

See and read the new proceeding from the link below. The 30-day comment period opened on 28 March. We have prepared a document containing useful arguments you may paraphrase for your comment filing. The formal ARSFI Motion to Dismiss RM-11831 and Petition for Rulemaking is also here for your review.

https://www.fcc.gov/ecfs/search/filings?proceedings_name=RM-11831&sort=d...

Unless we receive support from users on this serious threat, Winlink may be forced to close shop on HF in the USA. US and non-US users and gateway operators are urged to educate themselves and file a comment soon!

Sincerely,

Lor Kutchins, W3QA
Winlink Development Team
President,
Amateur Radio Safety Foundation, Inc.

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FCC
Winlink
RM-11831
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