How to File Express Reply Comments for RM-11831 DATA TRANSPARENCY 2019 Step by Step



 YOUR FILING, ONLY TEN MINUTES FOR THE GOOD OF AMATEUR RADIO:
Not a lot to ask for what it has given to all of us.  


WE MUST RESPOND WHILE THIS PROCEEDING IS STILL ACTIVE, TO BE HEARD! Here's how:

OPEN A NEW TAB IN YOUR BROWSER. THIS ALLOWS YOU TO READ THIS PAGE WHILE YOU TYPE INTO THE FCC PAGE.
Enter into THE NEW TAB ON your browser the following urls or right click and open in a new tab:
https://www.fcc.gov/ecfs/search/filings?proceedings_name=RM-11831&sort=date_disseminated,DESC


There are a few simple issues in RM-11831. IN A NUTSHELL:

1. Amateurs must be able to view the contents of all transmissions in the amateur spectrum. RM-11831 requires a practical realistic method for receiving Over The Air (OTA) digital emissions and displaying all their contents on your screen. While an online network server file viewer for Winlink content has only recently been provided, it does not ensure systems other than Winlink can be viewed off the air. Do NOT use the word "encrypted" in your comment, because it now has a meaning that has been distorted. Cloaked or unreadable or cannot be displayed are possible substitutes.
2. RM-11831 requests that the FCC follow their own instructions for 16-239 filing that offers "by band segment" solutions, in FCC Part 97 rules, not just a "voluntary band plan" with no enforcement tools. This would separate all unattended operation (on EITHER END) of the transmissions into an assigned "band segment" currently called the ACDS segment. Those existing ACDS segments should be aligned with IARU band plans where practical, and adjusted in size to accommodate legitimate emergency communications. 40 meters and 10 meters will require special treatment.
3. The ARRL originally requested in RM-11708 that band width for emissions in the CW/DATA segments be limited to 2.8 KHz to allow Pactor 4, and any future ACDS emissions. YOU should request that if ARRL wants 2.8 KHz "band width limits" those should apply ONLY in the ACDS segment.
4. The remaining CW/DATA segment should be limited to 500 Hz maximum band width.
5. RM-11831 has no effect on any existing digital modes that currently have an available over the air decoding solutions. RM-11831 has no impact on the HF VOICE/DATA segments. RM-11831 has no effect on DSTAR, etc. It only refers to 16-239 and RM-11708. It does not apply to VHF, UHF or microwave.
6. State your name and call sign, to show that you are an amateur operator, not an unlicensed user of Winlink (which goes undetected for weeks, often yachts). There have been multiple incidences of FCC filings from foreign locations which include no call sign.

RM-11831 is a vital response to 16-239 and RM-11708. The ARRL COULD have asked for 2.8 KHz wide signals in just the HF ACDS segments defined by 97.221(b). It instead petitioned the FCC for 2.8 KHz wide digital signals in ALL of the entire HF CW/DATA segments. When you are done filing your comments, please write your ARRL director to tell them you are supporting RM-11831 and opposing 16-239 and RM-11708. Contact info:
http://www.arrl.org/divisions/


You must figure out what you want to say first. Even if you just type your comments in the form, you need to compose your reply. It is important to at least use one or two talking points, not just "I concur" or "I oppose" to have maximum effect. See the important talking points below, and choose what you agree with. You may want to use a word processor or Notepad or Wordpad to prepare it. Then you can drop your words into the FCC filing space provided. Once you are ready to file a COMMENT, and have your document composed and saved....
  1. Look along the top left of the displayed FCC RM-11831 web page to find a box under FILTERS with a yellow line.
    At the bottom of that box, you will see:
      + New filing / + Express
    Click on + Express.
    It will take you to a web page that already has a form partially filled out with "RM-11831" in yellow in the "Proceedings" field.
  2. Click right AFTER that yellow box in the blank space.
    Type in 16-239. Press Enter.
    A drop down list of FCC proceedings appears with "16-239 Amateur Baud Rate" in it.
    Click on "16-239 Amateur Baud Rate" .
    Another yellow box will appear with "16-239" in the Proceedings field.
    Do not allow it to say "Kansas Public Safety Plan" by clicking on the wrong drop down item.
  3. Click right AFTER that yellow box in the blank space.
    Type in RM-11708. Press Enter.
    A drop down list of FCC proceedings appears with RM-11708 in it.
    Click on RM-11708.
    Another yellow box will appear with RM-11708 in the Proceedings field.
  4. Click right AFTER that yellow box in the blank space.
    Type in RM-11828. Press Enter.
    A drop down list of FCC proceedings appears with RM-11759 in it.
    Click on RM-11828.
    Another yellow box will appear with RM-11828 in the Proceedings field.
  5. Click right AFTER that yellow box in the blank space.
    Type in RM-11759. Press Enter.
    A drop down list of FCC proceedings appears with RM-11759 in it.
    Click on RM-11759.
    Another yellow box will appear with RM-11759 in the Proceedings field.
    You are now set up to comment on all the proceedings at once.
  6. Go down to the next field, where it says:
    *Required. YOUR NAME.
    TYPE IN YOUR NAME. Press Enter.
    ENTER ONLY YOUR NAME, NOT RM-SOMETHING OR ARRL IN THIS FIELD.
    IT WILL NOT TAKE YOUR NAME TIL YOU PRESS ENTER.
    Your name should now be in a yellow box inside the field.
  7. Go down to the next field, where it says: email.
    Enter your full email address. Yourname@company.com or whatever.
    YOU DO NOT HAVE TO PRESS ENTER.
    IMPORTANT! The public will not see your email, unless you put it in your document.
    This only allows the FCC to send you a confirmation of receipt of your comments.
  8. Go down to the next field, where it says: Address.
    Enter your street mailing address, like "1428 Elm St".
  9. DO NOT CHECK THE BOX "INTERNATIONAL" This is only for non-USA filers.
  10. Go down to the next field, where it says: Address 2.
    Use this if you have a PO box or the street address includes apartment number or it won't all fit in the first box.
    Otherwise, skip this one.
  11. Go down to the next field, where it says: CITY * REQUIRED.
    Type in your city.
  12. Go down to the next field, where it says: STATE.
    CLICK ON THE ARROW ON THE RIGHT HAND SIDE OF THE FIELD.
    You will get a drop down box of states.
    Click on your state and it enters it in the field.
  13. Go down to the next field, where it says: ZIP * REQUIRED.
    Enter your zip code.
    The small box to the right of that one is for your ZIP + 4 digits, if you know them. Not required.
  14. Before you upload in your comments,
    check the box at the bottom that says "email confirmation".
    This causes the FCC to send you an email at the address you entered above to confirm they got your comment.
  15. ALMOST DONE! Be sure all blank areas on the form which have a "*" are filled in.
    The FCC system will NOT accept any filings that do not have that information.
    This is important if you are typing in live on line instead of a cut and paste from a .txt file generated in Notepad or Wordpad.
    If you don't have all the fields filled in properly, it will reject it and your live on line typing will be lost without a backup. Bummer.
  16. You are now ready to type your comments into the "Brief Comments" window. That will be your comment filing.
    You can also compose your comments in advance, offline using a word processor like Notepad or Wordpad, with no time pressure. Then just cut and paste a .txt or plain text into that FCC window so that you do not have to do it live online.
    IMPORTANT: Use polite respectful language that is brief and to the point. You are addressing the FCC here, not the filer.

     SUBJECTS TO USE IN YOUR FILING, ONLY TEN MINUTES FOR THE GOOD OF AMATEUR RADIO:
    Not a lot to ask for what it has given to all of us.  



    IMPORTANT: Use polite respectful language that is brief and to the point.
    You can use a few of following talking points which strike you as important.
    You do not have to use all these points.
    YOUR comment of one or two items will have a big impact on the outcome.
    Use some of the ideas at the top of this page, or the list below.
    Put it in your own words! Add your own ideas.

    THANK YOU for spending just ten minutes to do this.


    • Your name and CALLSIGN (THIS IS VERY IMPORTANT), and how long you have been a ham.
      (This separates you from the unlicensed commenters.)
    • You are commenting on the Kolarik petition FCC ID 100918881206.
    • You are commenting to urgently accept into the FCC part 97 rules the provisions in RM-11831.
    • You are commenting to deny RM-11828, RM-11708, RM-11759 and 16-239.
    • RM-11831 ensures the ability to identify and monitor the radio transmissions of any data signal using readily available over-the-air interception methods by third parties, as required by Part 97.113(a)(4) and 97.119(a).
    • Without open, over-the-air interception capability for all transmissions in the amateur radio spectrum, there is no way to determine if there is commercial, or other prohibited inappropriate content in ongoing communications over the amateur radio spectrum. FCC DA 13-1918 ¶ 6
    • RM-11831 helps ensure that hams and the public can self-police all data transmissions, minimizing the FCC enforcement burden.
    • RM-11831 assures that the amateur radio service will not be used to bypass commercial internet or email services or be used for commercial use as required by Part 97.1, 97.3(a)(4), 97.113(a)(5)
    • Eliminating Part 97.221(c) as RM-11831 proposes would solve long standing interference issues suffered by radio amateurs wishing to use the HF RTTY/Data sub bands for other mainstream and emerging digital modes rather than ACDS purposes.
    • Nothing in RM-11831 hampers or removes the ham radio emergency communications capabilities of store and forward data. Rather, the petition merely reaffirms that such ACDS transmissions remain In their already allocated subband given to them by FCC, so they don't interfere with other ham operators and also requires they use open over-the-air transmissions that all can monitor. Both of these concepts are already in FCC Part 97 rules. RM-11831 simply reaffirms them clearly, as they are basic tenets that are being ignored by some.
    • IMPORTANT: FT8, Fusion, DMR, P25 etc., will not be affected. (See lengthy proof for this point at the bottom of this web page).
    • RM-11831 will help the public engage and take interest in data communications and will attract more youth to the hobby who will gain interest in open source data communications – vital for STEM and the country's economic future.
    • Therefore, I respectfully request that the Commission issue a Notice of Proposed Rule Making at an early date, to delete Section 97.221(c) and modify Section 97.309(a)(4) of the Commission's rules as described above.


  17. Review your address etc, and your comment for spelling and accuracy.
    Then click the button on the bottom: "Continue to Review Screen".

One of two things happen.

  • If you did not fill out all the address and contact information in the required fields, you bounce back to the beginning.
  • IF all went well, you are now on "step 2" and the big yellow ball says that.
    Review your work, and click the button at the bottom, "Submit".

IF all went well, you are now on "step 3" and the big yellow ball says that.
You will see your confirmation number and so on. Print this if you want to. You will not need to print it, if you checked the "email confirmation" box.
Within ten minutes, you will see an automatic email in your inbox.

IMPORTANT! WAIT! The FCC system is digesting your information and checking it. Nothing will appear to be happening.
Do NOT file repeated duplicates of your filing.

IF you do not WAIT as directed, but keep repeatedly clicking on SUBMIT, multiple filings will result.
If you immediately check the FCC website, your comment WILL NOT BE THERE right away.
Your filing will appear on the FCC site within a couple days.


Please take the time to write your ARRL director and other officers to tell them why you oppose 16-239 and RM-11708 and support RM-11831.
http://www.arrl.org/divisions/

Congratulations, you've taken steps to assure the long term health of ham radio.



IMPORTANT SUPPLEMENTAL INFORMATION ABOUT RM-11831

ARSFI and Winlink "claim to be just like" these other modes, but that is false. These other modes are actually "out in the open" for public intercept at little or no cost:

D-star examples:
https://forums.qrz.com/index.php?threads/listen-to-dstar-via-the-internet.249029/
https://www.broadcastify.com/listen/feed/5429
and easily copied by owning the equipment
https://www.youtube.com/watch?v=QkZOfAcps3c

DMR examples:
https://www.youtube.com/watch?v=75-AvQJKHNE
https://hose.brandmeister.network
https://itunes.apple.com/us/app/dmr-monitor/id595075253?mt=8v

Fusion examples:
https://www.youtube.com/watch?v=p_91XXgztzo
This was accomplished with a $20 USB SDR dongle and free software.
http://wiki.radioreference.com/index.php/Digital_Speech_Decoder_(software_package)#

Overview
https://www.rtl-sdr.com/rtl-sdr-radio-scanner-tutorial-decoding-digital-voice-p25-with-dsd/
Many other proprietary modes can be decoded using the above software and SDR dongle
from HF to low microwave bands. Some of the inexpensive SDR's work to 2 GHz and above.

FT8 is open decode of all that is within the transceiver pass band, scores of signals.
Anyone that says otherwise has never installed FT8 or used it.
RM-11831 HAS A GOAL TO PROTECT FT8 AND THE LIKE FROM INTERFERENCE BY ACDS.




I am FOR use of amateur radio for legitimate emergency communications. I am AGAINST its exploitation for commercial or illegal use as a private radio network, in competition with available commercial systems. I am FOR sharing our hobby with newcomers who are QUALIFIED to participate. I am a Volunteer Examiner, and have taught dozens of licensing classes. I am an active elmer, to help people get on the air, or correct problems with their station operation.

You are done! Thank you very much for your help.

73, Janis AB2RA

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