Shortwave Modernization Coalition: Public comment period on new proposal

Many thanks to SWLing Post contributor, Benn Kobb, who shares the following announcement:

The FCC has opened for public comment the Petition for Rulemaking of the
Shortwave Modernization Coalition.

The proposal would bring new private, non-broadcast digital stations to
the high-frequency spectrum.

As covered in Experimental Radio News, the Coalition members have
performed HF experiments over the last several years. Favorable FCC
action on the proposal would open the field to regular commercial
operations.

The FCC has assigned the petition number RM-11953. Comments are due in
30 days.

FCC Public Notice:
https://docs.fcc.gov/public/attachments/DOC-394830A1.pdf

Petition:
https://www.fcc.gov/ecfs/document/1042840187330/1

Benn Kobb

Experimental Radio News
https://www.experimentalradio.news

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23 thoughts on “Shortwave Modernization Coalition: Public comment period on new proposal

  1. Klaatu N.

    It’s not even about trading stocks. They arent pulling flash boy stuff. There is no time advantage. This is about crossing borders unregulated by laws regarding cryptocurrency and into countries with walled off internet and communications. This is the opposite of in the best interest of the US public and needs to be stopped.

    Reply
  2. martin

    This will destroy Ham Radio frequencies!
    Today we have so much noise from consumer electronic devices from pool pump motors to wall warts etc.
    Electric fences are awful too.
    The junk from china seems to be immune from FCC enforcement.
    Then we have over the horizon radar re-entering the ham bands again!
    Do you remember the Russian woodpecker of the cold war? The FCC did nothing.
    The FCC today is impotent and only interested in the money!
    The folks at the FCC are lawyers and political hacks interested in their well being !

    Look how you destroyed the telephone companies!

    As a ham operator I say a solid NO! until you clean up the existing noise we currently have how will you be able to control 20KW of high speed noise splattering into the ham bands!

    Reply
    1. Samuel Rhine

      Preaching to the choir here. I implore everyone to comment their disdain publicly on the FCC forms.

      Reply
  3. Jake Brodsky, AB3A

    Here in the US, the problem is that most regulatory agencies of any technical endeavor are nearly all run by attorneys. Not just a few, ALL politically appointed attorneys. So they fall for some seriously demented notions that have no technical basis in reality. The Federal Communications Commission, for example, hasn’t had a single commissioner with an engineering background in many decades.

    Not One.

    I have nothing against attorneys. After all, they’re writing regulations, there has to be at least one or two on the commission. But somewhere along the line, it seems these attorneys forgot who has to read and make sense of the regulations they write: Technicians and Engineers. Anyone who reads part 90, and part 15, is in for some amazingly twisted silliness. I’ve had the misfortune of reading those parts of the regulation. I am an engineer. I am the expected audience. And to be honest, there are things in there that I can’t make sense of.

    Lawyers and Judges love to tell the public that ignorance is no excuse for the law. As a professional engineer, I am going to return the admonishment to them: There is no excuse for Unreadable or unworkable regulations. If that gobbledygook has little or no technical foundation, then it’s just words on paper with no value to civilization.

    Reply
    1. mangosman

      Jake,
      Here here. Check out the bios in https://www.fcc.gov/about/leadership ! This is probably the reason why you have HDRadio®, ATSC 1.0, NTSC TV and the disaster over the 4 competing systems of AM stereo which meant nowhere ended up with it. Fortunately there is DAB+ and DRM radio, DVB-T2 and the older DVB-T and PAL TV used in the rest of the world.
      Also high frequency broadcasting in the USA is banned except for transmission to international areas by Government and religious broadcasting. Elsewhere government broadcasters such as Radio New Zealand, BBC, India, China and others for both domestic and international broadcasting.

      On the bios, you might also like to see the power of the telcos pushing 5G telecommunications who want to take over the distribution of programs from the broadcasters for their own commercial gain.
      The telcos instigated the analog to digital conversion of TV worldwide because it enabled them to get the 700 MHz band to make more profit.

      Lastly look at the management of larger broadcasters, have no engineers on their boards. This means that the most cheapest, efficient and least polluting method of program distribution to large audiences is being dropped to sending individual copies of each program to each individual listener/viewer and the profits of the telos.

      Reply
  4. Peter L

    It’s all about trading (stocks, bonds, options, futures, football scores). And I think that’s perfectly fine.

    As long as the frequencies are on a coordinated, non-interference basis, I am pleased someone is using the spectrum.

    Plus, when fintech figures out The Next Big Thing, there will be a lot of surplus HF gear on the market. 🙂

    Reply
  5. Paul Evans

    In even letting this be considered, you have to wonder if the FCC are smoking or sniffing or injecting the same stuff as Ofcom and its recent, 110 page long, laughable ‘improvement’ of amateur radio for consideration. We live in an era of fools in government bodies, especially anything technical.

    Reply
  6. TomL

    If this proposal passes, it means that Public Good is being turned into a Public Dump. Except for a few services like Time stations, aviation, coast guard weather, beacons, HAM radio, etc, there is NOTHING that the Public uses on shortwave. Since 98% of people are ignorant of what is on shortwave, they will say to the FCC, “Go ahead, do whatever the hell you want with that spectrum, we don’t use it anyway”. All the ignorant Public wants is their TV, cell, and internet to work better.

    The International Broadcasters are stuck in the middle. If spectrum starts getting used that interferes, there is no one to turn to for help since the FCC authorized the Private use case. And if it interferes overseas, there is no international body to turn to. So, in essence, I agree with 13dka.

    As far as “dead preachers” goes, let’s name names. Rickles means “Brother Stair”, whom he dislikes intensely just because he does not like the blunt message of repentance. What about other dead preachers? Pastor Scott, who helped start WWCR is still on the air. Get rid of him too? As far as the Public is concerned ALL of shortwave is dead in their minds. What about other things you might not like, like the flat earth people on 9330? These people and their followers are helping to keep WRMI, WBCQ, and WWCR on the air. It is a fallacy to throw out the baby with the bathwater, so to speak. If dead preachers are censored, then these radio stations (and their other entertainment & news programming) go off the air forever. I listen to all of it and sometimes learn from all of it.

    For instance, in the News category, comparing the Propaganda being broadcast by VOA vs CTGN (China) is an interesting exercise. Now compare what both of those say to the WRMI program called Synergy Radio (pro-Taiwan news). Very different messages and none of them are completely true. All of it is Propaganda, yet one can learn from the differences between them. Once we start censoring, ALL of it falls apart and goes away forever. I would encourage people not to go down that road.

    If you care about shortwave use, then please take the effort to submit your comments to the FCC directly or else your voice will not be heard.

    Reply
  7. Jake Brodsky, AB3A

    Something feels fishy about this proposal. It is common knowledge that high frequency trading requires very low latency networks. I don’t understand why these people need to obscure what they’re doing. I get very cautious when people use bland terms such as “modernization” without describing exactly what is obsolete and why such measures are required.

    In particular, the proposal on how they want to modify 90.207. Quoting the proposal:
    “For fixed, long-distance, non-voice communications below 25 MHz, any emissions
    designator consistent with non-voice communications will be authorized.” –okay, that’s a blank check.

    It does not define a maximum bandwidth. And most of all, how will they know that they’re interfering with other services?

    This proposal looks like a very big grab for a very small number of people with minimal benefit to the public. This proposal seems suspiciously lacking in detail.

    Reply
  8. Rickles

    This is going to sound silly, but to me they first (as was pointed out by 13dka) need to just clean up the spectrum.

    Remove a lot of the crap that’s out there now that shouldn’t be. Like a dead preacher that’s been on the air for 2 years since his death (not a slight against WBCQ, it’s a dime in their pocket), but I’ve heard it coming from non-BCQ frequencies .

    I get the research functions and can almost understand OTHR, but most digital modes have been fraught with issues and suffer many of the same issues as analog. Mondiale and a couple packet based systems are the only real success stories (we had a couple digital modes on HF when I was in the Army that were exceptional, but were bandwidth fat).

    Hell, I’m an old gray hair now too. I’d love it to just roll back into the late 80’s availability and content.

    And don’t get me started on China polluting the airwaves on every band.

    Reply
    1. mangosman

      The FCC controls what the USA transmitters can transmit ie there own Federal Government broadcaster and they allow religious broadcasters. Some countries use the HF bands for propaganda, there are others that do not, such as Radio New Zealand Pacific, BBC and there maybe others. Some just transmit their domestic programming because of the terrain, and large geographic areas and the ability to pay for terrestrial communications.
      Digital Radio Mondiale, is the only broadcasting format recognised by the United Nation’s International Electrotechnical Commission in the high frequency band. It can help to clean up the HF band, because all of the transmitted power contains information, where as the AM used in SW broadcasting is around 70 % of the transmitted signal power. In addition a single transmitter can carry two speech programs at a much lower power and is particularly useful in disasters.
      A huge advantage of HF broadcasting it cannot be switched off by a country who doesn’t like the programming, where as they can with internet.

      Reply
  9. 13dka

    They’re petitioning the FCC (a national authority) for something that affects the entire globe and should only be decided on an international level. Apart from the suspicion that this is once again an attempt on polluting/wasting a global resource (EM spectrum) for everyone to the benefit of a few, we all know very well that shortwave isn’t a spectrum where transmissions can be easily (or at all) contained to a P2P connection, particularly not when it’s about transcontinental communication. What’s likely going to be wideband emissions will affect services worldwide, so a single national authority cannot rule about handing over substantial portions of this part of the EM spectrum to a few “private” users.

    The desire might be understandable, it would be great and lucrative to minimize latency but so would be minimizing delivery time by trucks going 200mph, or turning the entire rain forest into furniture and super-cheap meat. These things may appear feasible to some on first sight but they cannot be turned into reality for so many good reasons, and allocating the frequency range “2-25 MHz” to a higher extent or proportion than any other user of that frequency range is not in the interest of everyone for the same reason.

    It’s also not like the existing, basically illegal usage of wide slabs of the spectrum for OTH radar or local wideband pollution through bad electronics and PLC isn’t already a major pain in the a…ntenna, basically harming all legal users of this spectrum. This makes me think that the proponents of this petitions may not be fully aware of the relative unreliability and vulnerability of shortwave communication. [uninformed boomer rant, get off my lawn ya wall street kids!]

    Reply
    1. Mike N7MSD

      Yes, just like the WinLink crowd, they don’t want to pay for StarLink, OneWeb, etc

      FWIW, to the HFT people the delay in an optical fiber (which slows down light significantly just like coax with RF) is a non-trivial thing. They are also the ones who sponsored first fiber optic cable through the Arctic (going through the 3 Canadian Territories and around Alaska) stretching from London to Tokyo as the absolute shortest possible terrestrial route because satellite hops are too long!

      Reply
      1. Jason VE3MAL

        It’s not even adding value to anything, it’s just a pay-per-play option to gain an unfair advantage over other stock traders that are /only/ using lowly fiber-optic-based internet. This will be a small group of wealth that can cheat the lower-tier investors of their trades -you know, like your pension plan. The nature and cost of HF means that this tech could never be democratized, but that doesn’t mean that small group will be incapable of using up big chunks of HF with flamethrower bursts of meaningless “braaaaaat” sounding signals.

        Zero public service and unfair market manipulation. Americans, please voice your concerns.

        Reply
      2. mangosman

        Mike
        Fiber optics and radio waves travel at the speed of light, ie 299 000 000 metre/s = 831 km/h. This is 3.34 µs/km. Just remember that in fibre optics the light has to bounce from side to side increasing the transit time. A much more significant delays in fibre optic systems are the storage of the data so that error detection and correction is applied, at the end of each cable length is a photo transistor and a modulated laser which take time to switch from on to off and back again. When the data goes between from ISP to ISP error detection and correction delays accumulate. Listen to a transmitted radio program and listen to if on line at the same time!
        Error correction required storage during encoding and more storage in decoding in addition it is common to shuffle the data to spread impulse noise.

        Geostationary satellites are 36,000 km above the equator and the shortest returned path takes 241 ms, satellite signal paths are noisy so more error correction si required. Depending on the path more that one trip to a satellite will increase the delay,
        Starlink uses satellites at an altitude of around 550 km, which gives a minimum delay of 1.84 ms. However the satellites are constantly moving with respect of the receiver, so the signal must be transmitted between satellites. The radius of the earth + altitude = 6,921 km thus at this altitude the circumference is 43486 km = 145 ms. Again error correction in each satellite is essential.

        The ionosphere is between 80 – 650 km in altitude.
        By comparison coax cable, carries a signal at around 0.6 times the speed of light ie 180,000 km/s = 5.57 µs/km delay.

        Lastly when trying to send data to many users, this is broadcast which is a one way communications, thus there is no opportunity that if an error is detected of resending the faulty data. This means that either the data has to be sent multiple times or spend more time with error correction.

        Reply
        1. Chris Fallen, KL3WX

          Also, “the speed of light” in glass (fiber optics) is only ~70% the speed of light in a vacuum by the indices of refraction, so there’s that, even with the slowdown as HF waves refract through the ionosphere. Milliseconds matter (big money) to market makers.

          That said, there may be better ways to send data far beyond the horizon at the vacuum speed of light that don’t involve clobbering big chunks of the ham bands ..

          Reply
  10. Jock Elliott

    I wonder what “private, non-broadcast digital stations” expect to do in the high-frequency spectrum.

    Does anyone have a clue?

    Cheers, Jock

    Reply

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