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  #1  
Old 12-11-2013
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US Citizens urged to support FCC RM-11708

The underlying issue is the migration from symbol rate (how much data is moved) to bandwidth (how much frequency space is used). Most of the world has long since moved to frequency management by bandwidth. The United States lags behind in this regard. Both Pactor 3 (P3) and Pactor 4 (P4) take up the same bandwidth as a conventional SSB voice link. P4 uses that space more efficiently, transferring data at over twice the rate of P4.

Sailmail has updated their systems on the marine bands to P4. Many Winlnk stations outside the United States have as well. Only the US continues to limit progress by using the archaic restriction of symbol rate.

Approval of this proposed rulemaking will make Pactor 4 available to cruisers in the US, and encourage continued development of new and faster data protocols and digital voice on the ham bands.

I strongly encourage US citizens to follow the links below to support RM-11708.

A sample statement of support, provided by Phil Sherrod W4PHS, follows the instructions.
Quote:
Originally Posted by ”W4PHS”
Time is running out for comments supporting RM-11708 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. You don't have to say much other than
you think it's a good idea, and you support it.

Here are the steps to submit a comment.

1. Go to ECFS Home Page

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 page
it will display.

6. If everything goes properly, it will give you a submission confirmation
number.

My comments are attached. Please do not copy what I said, but please make
the points:

1. 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 any hams.

2. The use of Pactor 4 simply makes the use of existing bandwidth more
efficient, so additional traffic can be passed without allocating new
frequencies.

Phil
W4PHS

--- My comment ---

I strongly SUPPORT the proposal to remove the symbol rate limitation from
digital modes. This is an obsolete restriction that is holding back
progress on efficient use of digital communication on the ham bands.

The proposal has no negative impact on ham radio use. It does not increase
the bandwidth allowed for digital signals, and it does not alter the
frequency allocations allowed for digital transmissions. Acceptance of the
proposed rule change will have no negative impact on any ham.

The effect of the proposed rule change will allow more efficient use of the
available bandwidth. Simply put, it will allow more traffic to be passed
through the same bandwidth.

Please accept the proposed rule change and allow US hams to benefit from
modern digital modes being used regularly in virtually all other countries.

Thank you for your consideration,
Phil Sherrod, W4PHS
sail fast and eat well, dave KO4MI
Dave Skolnick S/V Auspicious
SSCA Board of Directors, Immediate Past President
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Old 12-11-2013
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Re: US Citizens urged to support FCC RM-11708

Good idea to support
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Old 12-12-2013
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Re: US Citizens urged to support FCC RM-11708

the FCC is getting too revenue driven. I work in theatre. A couple of years ago they made us abandon 900mhz and go down to 500 and 600 MHz for things like wireless microphones. This was supposedly done for safety as the police and fire wanted the 900mhz frequencies.

Now they are about to auction off the 600mhz frequencies and force theatrical down into just the 500mhz area. I know a lot of the Casinos here in AC spent a fortune going to 600.. now in less than 3 years they are going to have to jump down to 500mhz?
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Old 06-18-2014
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Re: US Citizens urged to support FCC RM-11708

This is a misbegotten proposal and does NOT merit the support of any licensed Amateur Radio operator.
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Old 06-18-2014
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Re: US Citizens urged to support FCC RM-11708

Quote:
Originally Posted by BlackSilver View Post
This is a misbegotten proposal and does NOT merit the support of any licensed Amateur Radio operator.
Care to elaborate on why you think so? Dave at least gave an explanation for why he thinks we should support it.
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Old 06-18-2014
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Re: US Citizens urged to support FCC RM-11708

Quote:
Originally Posted by denverd0n View Post
Care to elaborate on why you think so? Dave at least gave an explanation for why he thinks we should support it.
I refer you to the comments of Lewis R Paceley posted at the FCC site:

Quote:
Originally Posted by K7GO

I am writing in opposition of the ARRL's proposed RM-11708. I have enumerated my points for your consideration below.

1) A single commercial vendor is the primary beneficiary of the ARRL's proposed change: SCS, the sole provider of Pactor III/IV technology. Passing RM-11708 will greatly benefit a single vendor with proprietary technology. SCS has a monopoly position in the Pactor III/IV market with no existing competitors. The passing of RM-11708 could tremendously boost SCS's revenues and the proliferation of their proprietary technology. This would further increase our dependence on the product of a foreign vendor. Add to this the additional risk to US emcomm infrastructure due to our deepened technology dependence on a single, privately held company.

2) Pactor III (and soon Pactor IV) technology is largely used to the benefit of
marine small craft owners who do not wish to purchase satellite internet service or other fee-based marine radio services for their crafts. They opt to utilize free hamradio instead. It is not in anyone's best interest for ham radio to become a replacement for commercial services. If RM-11708 is approved there will likely be an increased number of adopters of this technology to the detriment of commercial services like satellite internet.

3) Pactor III/IV transmissions are by their very nature encrypted. Without an expensive (approximately one thousand dollar modem) from SCS these transmissions cannot be effectively monitored. This nullifies any sort of self-policing of the amateur service. I cannot think of a single additional area in the amateur radio service where this is true.

4) The subsequent proliferation of unmanned e-mail "robots" will put tremendous pressure on narrowband data mode users. Highly bandwidth efficient narrowband data users (PSK31 is one example) will suffer due to the inability of the Pactor robots to detect the low-energy narrow-band signals. The consequences of the increased congestion would be difficult to avoid and could as a side effect decrease the number of narrowband data users.

Thank you for your consideration.
Sincerely,
Lewis R Paceley
K7GO
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Old 06-18-2014
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Re: US Citizens urged to support FCC RM-11708

Quote:
Originally Posted by denverd0n View Post
Care to elaborate on why you think so? Dave at least gave an explanation for why he thinks we should support it.
And then we have this comment, publicly posted, and openly admitting to the FCC the flagrant violation of their rules (operating without a license).

Or streaming NETFLIX on 20M?

We need more of this on the Amateur Bands?

Quote:
Originally Posted by Randal Evans

7521315143.txt
To: FCC - RM-11708
The sailing forms are all engouraging us to file comments in support of RM-11708. This is my first filing and if I mess this up, please see SailNet Forum at: (link back to this posting)

I have experienced very dependable service from the amateur radio Internet Winlink system. Its a great service because all of the other available Internet services cost money. Even when I am topside crusing the system runs automatically below deck publishing my position reports and downloading my email. I use the system for sending position reports, ordering supplies, repairs, chatting with friends and posting to facebook. My only complaint is that it needs to be much faster. I am not a amateur radio operator yet but a friend lets me use his call with a SIDD on the end. I hope to get my own ham call soon.

From what I read on the sailing forums, RM-11708 will allow Winlink eMail to run twice as fast. That is great and I am for that. Some of the technical folks are saying that if RM-11708 is published with no bandwidth we can get even faster Internet and might be able to stream movies on the Winlink Internet. I'm for passing RM-11708 into law with no bandwdith limits.
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Old 06-18-2014
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Re: US Citizens urged to support FCC RM-11708

Just starting out and gave sail mail my $250. Intend to use my 4 for gribs and nice to have another way to yell for help. Hear stories sometime sat phone works sometimes not. Sometimes ssb works sometimes not. Be good to have both. Also cruising nets are fun.
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Old 06-18-2014
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Re: US Citizens urged to support FCC RM-11708

If your a HAM or in the communication industry, you might understand this. What does this have to do with my marine VHF use and recreatnal sailing? I'd like all citizens to vote also.
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Old 06-19-2014
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Re: US Citizens urged to support FCC RM-11708

Quote:
Originally Posted by BlackSilver View Post
I refer you to the comments of Lewis R Paceley posted at the FCC site:
K7GO presents opinions and forecasts as fact. He has every right to his opinion. That doesn't make them facts.

Quote:
Originally Posted by K7GO
1) A single commercial vendor is the primary beneficiary of the ARRL's proposed change
I offer that the primary beneficiary of the proposed change is the US amateur. As it happens there are other modulations that would benefit from a bandwidth limitation, as most countries apply, rather than the current baud rate limit. At least one responsible developer with a history of successful signal processing applications has expressed an interest in the potential.

Quote:
Originally Posted by K7GO
The passing of RM-11708 could tremendously boost SCS's revenues and the proliferation of their proprietary technology.
Opinion that I don't agree with. I don't expect a surge in the market SCS addresses. On the contrary, my opinion is that some folks WILL buy P4 modems making their P3 modems available on the used market that more people will find within their budgets.

Quote:
Originally Posted by K7GO
2) Pactor III (and soon Pactor IV) technology is largely used to the benefit of
marine small craft owners who do not wish to purchase satellite internet service or other fee-based marine radio services for their crafts.
Having previously said that this proposed change increases the dependence of the US emergency communications infrastructure (neglecting that amateur radio emcomm can point to very few actual contributions) he now points to cruisers as the principal beneficiary. Odd. Regardless it doesn't seem like much of an argument on a sailing-focused forum.

My understanding is that while the official, NGO, and volunteer emcomm community struggled, it was cruisers in the harbors of Grenada that provided the first reliable communication out of that island country when it was ravaged by a hurricane.

Frankly I use e-mail over HF radio because I find it more reliable than satellite systems.

I suggest that the availability of higher speed e-mail (not Internet access per se) over HF will reduce the potential for interference as contacts will be of shorter duration. The number of cruisers is limited and increased availability of nominally higher speed e-mail access over HF radio is unlikely to change the complexion of users.

Quote:
Originally Posted by K7GO
3) Pactor III/IV transmissions are by their very nature encrypted.
The definition of encryption used by the FCC is pretty clear and Pactor is not encrypted. Aside from ready availability of the hardware (anyone can buy it), Winlink itself makes content monitoring straightforward at the RMS and CMS.

Quote:
Originally Posted by K7GO
4) The subsequent proliferation of unmanned e-mail "robots" will put tremendous pressure on narrowband data mode users.
Why would RMS' proliferate? Winlink RMS' are volunteers and I suspect that the community of those willing to put a bunch of money into a station they can't use for anything other than as an e-mail server is pretty well tapped out.

Quote:
Originally Posted by K7GO
Highly bandwidth efficient narrowband data users (PSK31 is one example) will suffer due to the inability of the Pactor robots to detect the low-energy narrow-band signals.
The newer P4 modems do a better job of automatic signal detection than the previous generation in both P3 and P4 modes.

Quote:
Originally Posted by BlackSilver View Post
And then we have this comment, publicly posted, and openly admitting to the FCC the flagrant violation of their rules (operating without a license).

Or streaming NETFLIX on 20M?

We need more of this on the Amateur Bands?
Mr. Evans clearly is operating illegally and has no conception of the practicalities of radio physics. Since Mr. Evans' operation is illegal under current law and regulation there is no impact of this proposed rule change.

Incidentally, while Mr. Evans probably doesn't understand that what he is doing is wrong (ignorance of the law is no excuse), the "friend" that "loans" him a call sign should know better and is subject to an FCC notice of violation.

Quote:
Originally Posted by Dave_E View Post
If your a HAM or in the communication industry, you might understand this. What does this have to do with my marine VHF use and recreatnal sailing? I'd like all citizens to vote also.
It has nothing whatsoever to do with your marine VHF use.

It has a great deal to do with recreational sailing. There are medium frequency (MF) and high frequency (HF) allocations for marine use. Very many cruisers use MF and HF radio (colloquially called SSB) for voice and data (including weather fax and e-mail). Many of those are licensed amateur radio operators and use ham frequencies for similar functions. This proposed change makes the newest generation of higher speed (realistically less slow) e-mail over radio available to US cruisers; it is already available to cruisers everywhere else in the world.

In my experience, the maritime nets on the ham bands are more useful to cruisers than those on the marine bands.

To be clear, there is no voting. This was an opportunity (now closed) for US citizens to comment on the proposed rulemaking. That is the way our system works. The FCC will make a determination based on technical factors, existing regulation, the proposal, and comments from citizens. They (the FCC) is perfectly capable of discriminating between meaningful comments and uneducated ones like those of Mr. Evans.
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Last edited by SVAuspicious; 06-19-2014 at 08:45 AM.
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