Formulating a Coherent Response to NPRM 11708

Ted Rappaport, N9NB, has kindly provided permission to share the following form letter for those of us who wish to formulate a thoughtful, coherent response to FCC and ARRL regarding NPRM 11708.

In case you are wondering who N9NB is, Ted’s multifaceted career in communications and education  speaks for itself, as is noted in the following article:

Please iterate or modify the following letter, shorten please if you can, and grab just the key concepts……hope it helps.

Please also write your ARRL directors and all ARRL officials, as we urgently need their help and support to lobby the FCC for a solution that gets them their data goals while also protecting CW/RTTY operations before the October 6, 2016 filing deadline.

Also, it is imperative that we file well reasoned comments with the FCC before the Oct 6, 2016 deadline.

… and please alert all others in hamdom who care about operating RTTY or CW in the future.

Thanks for your good efforts, and 73! Ted n9nb

Dear FCC (or ARRL Director Name):

In NPRM 11708, the ARRL and FCC want to encourage experimentation and expansion of data, while updating Part 97 rules to remove an antiquated baud rate limit. This is commendable, but must be done in a manner that ensures future technical innovation does not overrun current enjoyment and ignore fundamental technical issues, such as the need to avoid co-mingling of inharmonious emission types in the very limited HF spectrum.

If the 300 baud limitation  is eliminated, it will be eliminating a de facto emission bandwidth for RTTY and other data signals that has been in place to ensure order an approximate 500 Hz bandwidth on practical signaling. If the 300 baud limit is removed, it is incumbent upon the FCC to, at the same time, institute an RF bandwidth emission limit that protects current and future narrow band Data and RTTY transmissions and narrowband experimentation which currently occurs in the lowest 100 kHz of each HF and MF band.  The vast number of RTTY amateurs and JT65 experimenters use published codes that result in maximum data rate within an emitted bandwidth of less than 500 Hz, and the fastest of CW and PSK 31 and other narrow band emissions result in an emission bandwidth of less than 200 Hz. Without a regulated narrow band emission bandwidth, in the absence of a regulated baud rate, it will be a purely subjective decision as to how much bandwidth is the minimum amount needed to communicate.  Chaos would ensue and enforcement would be impossible, as its one person’s view of “minimum bandwidth” against another’s.  The existing baud rate assures a practical bandwidth limit today.

If the FCC wishes to eliminate the limitation on baud rate and provide a home for new wideband data with unlimited bandwidth, the Commission must at the same time provide an emission bandwidth limit of less than 500 Hz for the lowest 100 kHz of each band where today’s RTTY and JT65 and other narrow band emissions operate, and should further institute an emission limit of less than 200 Hz in the lowest 50 kHz of each HF/MF sub band where US and global CW / morse code, and PSK 31 activity may occur. This emission regulation is less than the 2.8 kHz asked for by the ARRL, and is needed because of the vast number of US and global amateurs currently operating and experimenting in the lowest 100 kHz using very narrowband emissions. A regulation by bandwidth in the lowest 100 kHz is required in the absence of a 300 baud limit because of the real threat of interference and lack of self policing that would occur without such narrow band emission limits.

Today, there are gray areas associated with what is an allowable code or what is a published code in Pactor, and there are loopholes in the FCC rules, which are unenforceable by the voluntary official observers , when other documented codes that are not widely detected by existing hams are used. There are also gray areas about when a control operator exists or not for automated data transmitters, and future technology could further cloud the compliance issues as the data emissions are widened and adopted by more amateurs. Many commenters have given proof to the Commission about the inability to decode certain existing Pactor 3 transmissions, and confusion and interference would  be propagated terribly with new data entrants without emission bandwidth limits that assure protection of the narrowest of bandwidth emissions.

All three ITU regions and Japan already institute narrow band regulations (200 Hz and 500 Hz) or recommendations in the lowest 100 kHz of each HF band because of the major disruption and chaos that results when wideband data is mixed with narrowband data. This stems from the technical realities that narrowband signals are not useable in the face of wider band data transmissions. For these reasons, in response to the Commissions request in Paragraphs 9-12, I urge the Commission to rule for eliminating the baud rate, and at the same time establish a maximum emission bandwidth limit of 200 Hz in the lowest 50 kHz of every MF/HF Band, and a 500 Hz maximum emission bandwidth limit from 50 to 100 kHz above the lowest part of every MF/HF band edge. The new, inharmonious, unlimited wide band data proposed by the FCC and ARRL could operate (and keep all of its emissions) above 100 kHz above the lowest band edge in each MF / HF band edge, thereby supporting the new types of modes requested by the ARRL, while also preserving existing and future narrow band data transmissions and the massive investments already made by the amateur community for these narrow band transmissions. This solution will satisfy the US and global amateur population, will comply with ITU recommendations, while  providing new wide band data capabilities, and while honoring and supporting narrow band CW, RTTY, and other narrow band modes that are critical for emergency and long distance human communication.

The HF spectrum for the amateur service is severely limited. The FCC has never allowed 2.8 kHz SSB signals into the data/RTTY HF/MF sub bands. The FCC must view unlimited bandwidth data signals as an inharmonious emission for today’s narrowband emissions, just like SSB is, and must protect the narrow band transmissions at the lowest end of HF/MF.  Otherwise, the removal of baud rate will immediately allow wider band data that will be unregulated, subjectively determined,  undetectable without a CW identification, and will overrun the existing CW, RTTY, and narrow  band experimentation over time.




Here is how to write ARRL leaders to seek their immediate support and protection of CW/RTTY operations in the face of NPRM 11708: 

Names and Email for ARRL Leaders

Instructions on how to file a Comment to the FCC on NPRM 11708

Additional information on NPRM 11708 can be found at the following sites:



Why Should CW/RTTY Ops Care About FCC NPRM 11708?

The FCC has recently announced a Notice of Proposed Rule Making, NPRM 11708, which will have significant implications for those amateur radio operators who enjoy CW and RTTY modes. The impetus for this proposed new rule was a petition from ARRL (2013) that all RTTY and data transmissions below 29.7 MHz be limited to a maximum bandwidth of 2.8 kHz.

In their response to ARRL’s petition, FCC has stated that,

“We decline, however, to propose to add a 2.8 kilohertz bandwidth limitation for RTTY and data emissions in the MF/HF bands as requested by the ARRL Petition.”

FCC further states that,

“We tentatively agree that a baud rate restriction has become unnecessary due to advances in modulation techniques, and no longer serves a useful purpose. Our rules do not impose a symbol rate limit on data emissions in any other amateur bands or in any other radio service. In addition, removing the baud rate restriction could encourage individuals to more fully utilize the amateur service in experimentation and could promote innovation, more efficient use of the radio spectrum currently allocated to the amateur service, and the ability of the amateur service to support public safety efforts in the event of an emergency…”

What does this mean for CW and RTTY operators?

If NPRM 11708 is enacted later this year, digital transmission of unlimited bandwidth will be allowed on any segment of any band below 29.7 MHz.  Digital voice transmissions using 12.5 kHz wide C4FM (4 level FSK modulation) will probably be allowed to operate in the current CW/RTTY sub- bands, as will Pactor 4 , Winlink, and all other data modes.  WinLink, by the way, is popular with boaters, who use it as an encrypted HF -to-Internet gateway for email delivery.

FCC is not proposing sub-bands for various modes in NPRM 11708.  It will be up to the amateur community to regulate itself.  Unfortunately, ARRL does not seem to appreciate the significant interference that narrow band modes like CW and RTTY will encounter as they compete with digital voice and data transmissions of unlimited bandwidth.  Our current CW/RTTY sub-bands will be gone forever.

What can We do?

First, take a look at the FCC’s NPRM 11708 and ARRL’s 2013 Symbol Rate Petition to familiarize yourself with the issues.

The FCC is currently allowing comments to be filed on this rule for the next few weeks, probably until  October 11th. Spend some time thinking about the proposed rule, and then submit your comments to both the FCC and your ARRL representatives.

You may want to contact your ARRL representatives at the local, regional, and national levels to ask them to either rescind their Symbol Rate Petition or request that they add a request for a dedicated  CW/RTTY sub-band plan for each amateur HF band.

Some suggestions for inclusion in your comments:

The existing narrowband CW and RTTY modes are still providing valuable potential for emergency communications.

The narrowband modes should be protected from wideband digital transmissions by providing a dedicated band segment of 100 kHz for each amateur HF band.

Failure to provide a dedicated narrowband segment for each HF band, will  probably subject CW and RTTY operators to an unacceptable level of interference from wideband digital stations.


At this point, it looks like NPRM 11708 will most likely become the law of the land within the next year.  There is still some time left for those of us who care about CW and RTTY to speak out in order to convince the ARRL and FCC that our CW and RTTY narrow band modes are important to us, and that these modes still  provide valuable communication potential that should be protected from the digital modes.

Please contact your representatives to express your thoughtful concerns regarding     NPRM 11708:

FCC: ECFS Advanced Filing Search


72, Paul  AA4XX

WQ4RP Lightning Protection System

Having witnessed firsthand what lightning can do to a completely unprotected station, I decided to do things differently when the time came to rebuild the Excalibur Site.

The following photo is from a lightning strike that entered the shack five years ago via a balanced feedline.  There was no grounding system in place, so the lightning energy flowed through a wall stud and an ARRL Antenna Handbook on the book shelf on its way to ground.  The wall stud burned almost completely through, and the thick handbook was turned to fine ash.  The building was subsequently dismantled.

lightning strike at AA4XX radio shack turns ARRL Antenna Handbook into powdery ash


How many of us have thought our equipment  was safe just because we disconnected the feed line(s) from the ATU and/or radio?

The lightning protection plan currently being implemented at WQ4RP is based on several months of research and consultation with experts on the subject of mitigating the damage to radio stations resulting from either nearby or direct lightning strikes.

The sobering news is that a serious level of lightning  protection necessitates the need for a comprehensive grounding system–unless you really think that a few feet of ground wire and one, or two, or a hand full of ground rods are going to provide an effective energy sink for several hundred (or possibly thousands ) of amps of lightning energy.

I contend that while it may not be possible to guarantee 100% immunity from a direct lightning strike to one’s tower, tower mounted antennas, typical backyard dipole, or associated feedline(s), it is entirely possible to substantially increase the odds that such a strike will have most of its energy dissipated in a protective ground system well before it has a chance to get into your shack or radio equipment.

This post is not intended to be an in depth treatise on the why and how of lightning protection for amateur radio stations, but rather a description of what steps the KnightLites at the WQ4RP Excalibur Site are taking to minimize the risk to people, the shack, and the antenna system.

Interested readers are encouraged to study the following links:                                                                               

For the Single Point Ground Entrance Panel WQ4RP, a panel was purchased from KF7P   (   Chris, KF7P is providing a valuable service to the amateur radio community with his functional, beautifully crafted entrance panels and associated components.

The RG8x  feed line from the big 160M vertical is connected to an Alpha Delta TT3G5O Surge Suppressor.  The coax shield is connected to the large copper plate (thru a large bolt on the surge suppressor), which in turn provides a low inductance path through the ground strap to the ground rod. The TT3G50’s patented gas discharge chamber  will shunt potentially damaging lightning energy from the coax’s center conductor to ground.

Thanks to Alex KC4PHJ for his generous donation of four additional surge suppressors which will soon be installed on this panel.

KF7P SPE Panel

The ground strap from the entrance panel above terminates at the ground rod below.  The ground rod clamps for the copper strap are also manufactured by KF7P.


This grounding strap will be removed from this ground rod within the next few weeks and connected to a comprehensive grounding system.

SPE Panel Ground Rod


Several hundred feet of trenching was done the weekend of July 4th, using a rental trencher that could dig down to 36″.  The going was slow but steady, taking about nine hours to complete all the coarse work.  This included time to extricate the beast three times from soft dirt and rookie maneuvering on my part.  Thanks to a 4WD vehicle and a strong chain, the trencher was persuaded to rejoin terra firma all three times.

Excalibur Pulling Out Stuck Trencher


The goal of the trenching was to create three ground circles, or halos–one around the shack, one around the tower, and one around the 160M vertical.  Additionally, two long feed line/control line trenches were dug–one from the shack to the tower and the other from the shack to the 160M vertical.  The goal is to have all three halos bonded together to the single point entry panel at the shack so all three halos and associated feed line trenches are at the same potential during a lightning strike.  There will be no isolated grounds in this system.

Below is a photo of the ground halo around the tower.  The trench at 2 o’clock is for the feedlines, control, and power lines to the tower.

Excalibur Tower Ground Halo


A number of 8′ long copper clad ground rods (30) will be driven vertically 2′ below grade into the trenches, spaced 16 feet apart and bonded together (using cadwelds) with #4AWG solid copper ground wire.  This process will be highlighted in the next blog, as most of the cadwelds are on backorder for another week.


Below is a picture of the ground halo around the shack. The intersecting trench at 7 o’clock is 16′ long will provide additional grounding with an additional ground rod.

Excalibur Shack Ground Halo


I decided to invest in a used heavy duty hammer drill to drive the thirty ground rods.  The first test has been a complete success, as it took 30 seconds to drive this 8′ rod down three feet into rocky clay soil.  I then hit a big rock and leaned on the drill for 1 minute until the rock fractured and the rod easily completed its descent into the trench.

Excalibur Hammer Drill Ground Rod 15 sec


In case you are wondering which drill I’m using, it’s a Bosch Model 11311EVS with  an SDS MAX 5/8″ ground rod driver bit. This bit does not deform the top of the rod as it’s being hammered in.  Incidentally, the hammer drill absorbs most of the pounding, so the process is not too hard on my 64 year old bones.

Here’s the rod driven about 12″ below grade, with the original conical head undistorted.  I challenge anyone to do that with a sledge hammer.

Excalibur Hammer Drill Ground Rod Completely Sunk


Mid Summer is usually a dry period in central North Carolina, but numerous thunderstorms have visited this area over the past few weeks, with the trenches now filled with tadpoles.

 Excalibur muddy trench

At least the clay is thick enough that it is not flowing back into the trenches.  It will be a happy day when the trenches are filled with ground rods, ground wire, and coax!

Stay tuned for part 2, where we will be installing the ground rods and firing off the cadwelds.

72,  Paul  AA4XX

WQ4RP Shack Gets a New Floor

Many hours were spent deciding on which type of flooring would be best suited for the WQ4RP remote radio shack.

In the end, southern yellow pine 1″x 6″ lumber won out, as this is the same type of flooring I installed in my log home almost forty years ago, and I knew this type of flooring would send the message that you are now entering a special place.

The pine boards were installed over a red vapor barrier.  The vapor barrier limits the amount of moisture that can migrate into the shack from the ground.  The pine boards were just a few inches longer than the 12′ length of the building, so with a little trimming the installation went quickly.  This is not tongue and groove– I simply selected the straightest boards I could find at my local Home Depot Lumber Department and arranged the boards for minimal gapping.  This method worked out very well.

Excalibur SYP Flooring


It took about three hours to trim and lay out all the boards.  I allowed the loose flooring to acclimate a couple days before screwing each board into the floor joists.  Here’s the floor after the first sanding:

Excalibur Sanded Floor


After final sanding and puttying the screw holes, the floor was sealed with four coats of urethane based Spar varnish, which resulted in a beautiful protective finish that enhances the natural yellow pine color and texture.

I then turned my attention to the operating table.  Seeing how well the floor turned out, I decided to use the same lumber to build the operating table.  First a frame was built out of 2 x 4’s, which was secured to the wall studs.

Excalibur Operating Table Frame


I screwed the pine boards into the underlying support frame and used natural colored wood putty to cover the screw holes.  Here’s the finished product after final sanding and four layers of Spar varnish.

Excalibur Operating Table Completed

This floating table is roughly 32″D x 82″W and ended up being strong enough that I could put all my weight on the front edge without any flexing.

A couple shelves will be installed above the table as time permits.

BTW, I am not a carpenter.  If I can do this, anyone can!

In the next installment, we’ll share some of the current work that is going on at Excalibur regarding a comprehensive lightning protection grounding system that uses hundreds of feet of ground wire and thirty ground rods.

72 de Paul,  AA4XX

Excalibur II Site Improvements – Drywall

Since it has been several months since the last report on the rebuilding of the KnightLite’s QRP operating site WQ4RP, I wanted to share some of the things the KnightLites have been up to.

In April, Marty W4MY spearheaded the installation of drywall for the walls and ceiling of the shack.  Our Drywall Fest team consisted of Marty W4MY, Marc W4MPS, Chris AA4OO, Dick N4HAY, et moi AA4XX.

Excalibur Sheetrock 1

W4MPS (L) and W4MY (R) cutting drywall

It was quite exciting to see the shack’s transformation as new drywall sheets were installed.  The purple drywall was chosen because it is mold and mildew resistant.

Excalibur Sheetrock 2

Chris AA4OO (F) and Dick N4HAY (R) securing the drywall with screws

The fiberglass insulation had been installed in the walls a month prior to the drywall work.  AA4XX finished putting in the ceiling rafters and associated wiring and insulation a few days before the Sheetrock Fest.

Excalibur Sheetrock 3.JPG

AA4OO and N4HAY secure first drywall ceiling panel

W4MY took responsibility for mudding the joints and trimming the door and windows over the next two days.  Marty’s generous sharing of time and materials to complete this phase of the project is greatly appreciated.

Excalibur Sheetrock 4

Master Craftsman Marty, W4MY

Under Marty’s tutelege, AA4XX took responsibility for the sheetrock finish work–sanding, priming, and painting.  Our teams’ work turned out fabulously.  It really helped to be able to draw on each others talents for this project.

Excalibur Sheetrock 6

With our spiffy new interior walls and ceiling completed, the next logical question was,  OK, what about the flooring?

Stay tuned, as that will be covered in the next post.

CQWW160M CW Contest from KnightLite’s Excalibur QRP Antenna Site

Dick (N4HAY/ZS6RSH) and I decided to enter the CQWW160M CW Contest  as a multi-op,  meaning two or more operators share a single transmitter and callsign. As there is no QRP multi-op category for this contest, we would be competing with stations running KW amplifiers.

The advantages of running QRP multi-op is that we could both plan on getting some sleep during the long 5PM-8AM nite time shifts, we were working toward a common goal, and we could operate assisted mode.  

Our main goal was to have fun and to see how our newly constructed Excalibur 160M vertical would play.

Station WQ4RP

Station WQ4RP consisted of a Ten Tec Argonaut VI, running 5W output into the Excalibur vertical loop.  We used N1MM+ logger with a WinKeyer.


CQWW160 CW 2016 station


Building a 160M Vertical Loop with Elevated Counterpoise

Initial Planning

Several years ago, I had the good fortune to be introduced to Gene Bowman, WB4MSG, at the Winston-Salem Hamfest.  I recognized Gene’s callsign because of his top place finishes in many contests.  I was particularly interested in what kind of antenna he used on Top Band.

Gene told me that if I had a few minutes, he would be glad to have me come by his house so I could see his antenna farm.  I was fascinated to learn that Gene had placed 1st Place QRP World during the recent CQWW160M SSB Contest with his 160M loop. Gene mentioned that a full write up of his 160M antenna appeared in Jan 2010 QST  (160 Meter Inverted Delta Loop by Charles Kluttz, W4TMR,  pp.40-41).

I built my own version of Charlie’s 160M loop shortly thereafter and was quite pleased with its performance.  The vertically polarized loop showed noticeable gain over my high 160M dipole for stations beyond my local area, and after a short while I found myself no longer using the dipole.

As a result of a severe lightning storm in August 2011, all my antennas were damaged to the extent that I had to start all over from scratch.  Fast forward to Jan 2016, it was high time to get back in the game. With the help of two local QRP friends Chris N4PBQ, and Dick N4HAY, plans were hatched to resurrect the Excalibur Antenna Farm, beginning with a Top Band antenna.  It was decided to rebuild a version of the W4TMR Vertical Loop.


N4PBQ digging hole for 160M support post

Chris, N4PBQ digging the hole for the support post