Commercial interests petition FCC for high power allocation on shortwave
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The petition requests "maximum transmitter power is 20,000 watts RMS" in the HF 2 – 25 MHz range. Wow. 20 kW is a LOT of power. Two amateurs in HF can talk to each other on opposite sides of the planet with 5 W and a tiny rig and a lot of skill. I think most amateurs would consider 100 W a lot of power for competent HF comms.
But American industry wants 20,000 W for coast-to-coast jibber jabber? Greedy. Lazy. And pollution.
The headline petitioners are:
Eric Bellerive on behalf of DRW Holdings LLC
Thomas Maxwell on behalf of IMC Trading
John P. Madigan on behalf of NLN Holdings LLC
Kevin Nielsen on behalf of County Information Services LLC,
an affiliated company of Optiver Services B.V.
Tom Proudley on behalf of Tower Research Capital LLCThat's quite an electric bill, when you consider they're asking for up to 50 kHz bandwidth.
Watts are watts, whether you spread them across 1 Hz or 1GHz.
In general, the opposite of what you say is true: the more occupied bandwidth, the less power you need for equivalent information transfer. So, e.g. when the FCC made everyone doing VHF/UHF voice comms narrowband from 25KHz to 12.5KHz, you needed basically double the power for equivalent analog voice.
Or for an extreme-- GPS uses 50MHz wide to send dozens of bits per second to allow much lower satellite output power and resilience to noise.
The former could be expected to transfer much more information, or alternatively to go further. (Or the former you could use less than 20,000 watts to get the same data transfer rate and range as the latter).
Power density scales with inverse of distance squared. At 1km, 20 kW is 0.001 W/m2. At 500 km it's a few nW/m2.
2-25Mhz reflects off the atmosphere and returns to earth and the multiple allocated bands in the range are typically less then 6KHz for broadcast AM and other bands often <3KHz SSB down to 100Hz CW can be completely trashed with spurious emissions. 60, 80m and 160m can be difficult to use already due to all sorts of noise from notionally low power devices in the mW range on nearby, or sometimes nowhere near, frequencies. The wide range is probably to enable use regardless of the current maximum usable frequency (MUF) to ensure atmospheric reflection. MUF varies, sometimes considerably, by time of day, season etc. However the reflections do not stop when you receive the signal, they continue to skip and be received in many additional locations that are not the intended destination.
Someone pumping 20KW across the range could cause an incredible amount of disruption, essentially worldwide. See Ringway Manchester's great series of videos on the Russian Woodpecker (it was speculated in the MW power range) https://www.youtube.com/watch?v=wB_jiigRq-c
HF signals can be reflected by the surface of the Earth after hitting the ionosphere and repeat this process until they've gone around the world (sometimes more than once!). This is not a rare quirk; amateur radio operators take advantage of this on a daily basis, with an absolute maximum power limit of 1500W. (But 1500W is uncommon; my radio does, at max, 10W. And I can communicate with Europe from NYC fairly regularly.) The result of all of this is you have to be careful about HF signals; you can ruin it for everyone in the world if you make a mistake. VHF, whatever.
VHF does occasionally propagate over long distances. It used to happen with analog TV and was quite the rare and amazing sight to behold (I've never seen it).
https://en.wikipedia.org/wiki/Tropospheric_propagation#Tropo...
https://en.wikipedia.org/wiki/Sporadic_E_propagation
TV moved from VHF to UHF during the digital transition, so this doesn't happen anymore.
Finally, there is a lot more VHF frequency available than HF. For example, one band that amateurs have is the 40 meter band, which is 7MHz to 7.3MHz. That is 300kHz of bandwidth for everyone in the world. Meanwhile, just 1 FM radio station is 270kHz!
In the US, I don't think VHF ATSC is going anywhere, because there are only 23 UHF channels remaining (14-36) and VHF adds 12 more. VHF is less popular because you need a larger antenna to receive it.
It's only higher of the two previously existing TV bands (channels 7-13, 174-216MHz) that is still allocated for terrestrial broadcasts in the US The old 54-88MHz (channels 2-6) are no longer used in the US for ATSC.
All being equal, you'd rather they use a narrow signal with a lot of power than a wider one. The greedy/lazy/polluting way would be to demand a wide allocation so that you can use low power.
Of course, a very loud signal right next to amateur allocations may mess with lower-quality receivers.
Chicago to New York, mostly. The derivatives markets are in Chicago and the cash markets are in New York. They've been testing at only 10Kb/s, and they're probably using forward error correction, which uses more bits. (Given the application, retransmission adds too much latency, so that's out.) 20KW would reduce the error rate.
I think the proposed technique was laser or microwave vaporization tunneling at a small diameter.
Something tells me it was too expensive.
HFT is psychotic.
Narrowing the spread of the prices of a commodity doesn't have any immediate physical effect, but if you start wiping out billion dollar projects based on that, then that's the most office buildings, the ISS and LHC, the entire software industry...
Provided the transmitter is 'clean' and modulated such that the signal stays inside the allocated bandwidth, it will not impact other users.
(except if you are < 1 Mile from the transmitter. the poor selectivity in your receiver may be overwhelmed by this power up close).
The question is how much bandwith and what kind is the modulation? Narrow band modes consume less spectrum, and they also transfer less data.
A 50-100 khz band could be carved out of HF and given to this services. 500khz would be way to much.
And you cannot take it from the Ham bands. They were there first.
Amateur radio aside, this would likely have adverse impact on several scientific research fields (e.g. ionospheric radars, 21 cm cosmology, radio-detection of energetic particles), including some things I'm interested in. While HF is already a mess, when adding even more energetic transmitters that will be seen all around the world, the benefits should be be weighed against the potential impacts....
And then put RM-11953 in the Proceeding(s) box.
Direct link to submit an Express Comment on the petition: https://www.fcc.gov/ecfs/filings/express?proceeding[name]=RM...
> Licensed use of 2-25 MHz Band frequencies as proposed in this Petition would enable financial firms, including firms like the SMC members that act as market makers, to improve efficiency, increase liquidity, and reduce transaction costs in the financial markets in which they participate, thereby benefiting all market participants.
I am generally sympathetic to commercial use of spectrum, but allocating this band to prop firms doing high-frequency trading is fucking nuts. Can we please use this spectrum for something that actually contributes anything real to the world?
Still, now you've got me curious and I'd be grateful for some proper boffins to elucidate us further: if you have an transmitter emitting single photons in an isotropic antenna pattern, could they still be received by a receiver even though there is no "wave" to speak of? Even if part of the information is going in another direction? There is some proper double slit-type weirdness going on there.
Optically we make photon counters out of cooled avalanche photodiodes or photomultiplier tubes that will repeatedly trip for each incoming photon (at high probability). But they also randomly trip at a rate because of internal thermal noise.
As to emission, yes, you can make (close to) omnidirectional single photon emitters. But the odds of it interacting with your antenna or detector are low.
Also the quantum limits can still be treated entirely classical, no need to think about "quantum weirdness"
This proposal is for a 50 kHz system, so if they used bandwidth in the same way, that would be 100 carriers sending on/off commands and/or combinations.
This is for a Part 90 (of the FCC rules) operation, so I would guess they'd install a Part 90 UHF transmitter at the place business is being conducted to control or retransmit to the Part 90 shortwave transmitter, which would take up too much physical space in most buiness environments.
No, this is just discrete multitone. Leaving aside the issue of errors, it still takes you time to know the carrier is gone. You'd have much better choices about how to do this that are more spectrally efficient and equivalent in latency.
Reductio ad absurdum: if it were zero latency, you could turn on and off the signal infinitely fast, and then send an infinite amount of information across a narrow channel.
> This proposal is for a 50 kHz system, so if they used bandwidth in the same way, that would be 100 carriers sending on/off commands and/or combinations.
Yah, or broadly: it's like OFDM. You don't have to constrain yourself to one bit per carrier, and you can use error coding across multiple carriers, etc.
Also important to consider authentication...
If you want to check out the signal of the competing system, it's just above or just below 15.735 MHz, using the sidebands of a shortwave broadcaster operating in Digital Radio Mondiale. 5 kHz is usually the DRMondiale signal, and 5 kHz is the sideband transmission.
Wouldn't they relatively be equal off if the latency for all firms was increased by say 100ms.
We can spill a lot of ink going back and forth, but honestly? At the end of the day, "this seems like useless bullshit" is actually a really good instinct.
I know that sounds a tad anti-intellectual, but I think HFT for market making is one of those cases where very smart people delude themselves out of an obviously correct instinctive understanding of the truth.
But we can dive down the rabbit hole if you want.
Having some known fixed beacons spewing transmissions that could be received and then used to recover the source information before encoding, would turn all of the transmitters into a wide-band source of probes for the ionosphere that we could all benefit from.
Knowing the format of the transmissions would also allow us to develop SDR software that automatically filters it out, completely. This would also allow us to use the same transmissions for passive radar, as all the transmission sites are fixed.
This could be a win-win for everyone, as long as the format is fixed, and publicly known. What they do with the data before sending it into the ether is their own business, I'm sure they could generate sufficient amounts of truly random bits and courier it between locations to use one time codes (a simple XOR, with almost ZERO delay) to keep their confidential business information safe.
20 Kw might seem like a lot, but the ionosphere is a fickle beast, and this isn't going to be completely reliable even at those power levels. It's only about 13 dB more than the most powerful ham rigs, and 3 dB less than most Clear Channel AM radio transmitters. It's not entirely unreasonable.
This is the mutant expectation of a company that's very existence hinges on fucking over legitimate human made trades.
It is very sad. I have a feeling a new wave of hackers would flood radio if the community pushed for some spectrum to be community dedicated to digital comms.
Outreach would be much easier.
I've actually seen hams go on a >20 minute rant about how digital is ruining ham radio.
I studied to take my Technician Class exam, when I finished and passed, I found out I could take my General Class exam right then if I wished. When I took that second exam and failed, the club members looked absolutely delighted. I don't look like them, and their smiles felt like them saying "we knew the freak would fail". It felt incredibly alienating.
Shoot for the general again and use one of the online testing groups, simple and no judgement.
The volunteers proctoring all three of my online exams were anywhere from polite to actively cheering me on (before the exam), and all congratulated me when I passed.
Goodbye Amateur Radio, you won't be missed.
Most of the hobby is not prepared to help with emcomm. And I think you (and a lot of people) overstate how helpful amateur emcomm is. In the past couple decades, local officials have gotten pretty good systems for getting high priority traffic out of the local area (which is what HF was previously for).
Amateur volunteers relaying things in the local area are helpful in keeping disaster logistics running smoothly. Radio skills are not a big part of it, for the most part.
I'm a teacher and passionate about radio. I don't know how to get my students into radio and make it into a good experience for them. They're way too likely to face hostility, racist political rants, etc. So I haven't pushed on it.
There are still lots of old guys in these parts of the hobby, but ones open-minded enough at least to learn new things, and I've not had any issues with them despite having a distinctly female first name.
WSPR is the best place to start, in my opinion - lots of results for really low capital investment (5W is high power), really lending itself to DIY.
Licensing is ultimately going to be important to transmit, etc.
WSPR is amazing, but there's a certain "so what"-- I can send a packet over there, too, via the public internet. Radio doesn't make sense to kids anymore: like they really don't get it.
As for emergency preparedness... No. Hams don't really play a role anymore. Satellite texting/Starlink, digital repeaters for agencies, generally available idiot-proof radios are all things that would have to fail. There's a reason that the volunteer SAR team near me just buy off the shelf stuff from Motorola instead of trying to recruit Hams. Even in some sort of failure like that, I would rather have an air band or marine band radio than a Ham radio.
Our local CERT makes big use of amateur emcomm. But it's the non-critical stuff: neighborhood liasions to go out and spot things, or volunteers in a truck to relay supply needs at peripheral stations.
It's a parallel line of communications (with a separate set of humans making a judgment of what's important to escalate), which is useful when administrative and decision-making capacity is constrained. And it has different failure modes, which is nice, too.
Even little things: visible volunteer patrols by amateur operators for fireworks laws violations just helped my city tamp down the normal dozens of fires to only two and hastened the firefighting response.
As a counterpoint, I once was involved with a backcountry emergency where, at a certain point, it made sense to have a non licensed person on a radio. We actually had the local grump hop on and tie up the frequency chastising them for using the radio. That felt very in line with the ham community.
Sure, Hams can provide utility in an emergency, but Hams also like to overstate just how essential they are in these situations (scroll up for evidence).
Volunteer fire patrols are great and all, but an independent radio network for the volunteers is not exactly required, or providing anything a cell phone can’t
Cell phone networks will be down or at capacity when disaster hits.
Public safety networks will mostly be up, but they only have so many officers, etc.
> As a counterpoint, I once was involved with a backcountry emergency where, at a certain point, it made sense to have a non licensed person on a radio. We actually had the local grump hop on and tie up the frequency chastising them for using the radio. That felt very in line with the ham community.
I have said some negative things about the community here, but I haven't seen anything like that. We all pass an exam that makes it clear anyone can use any frequency in an emergency, and we all also should know that we can let unlicensed people under our supervision use our radio in non-emergencies. (With some exceptions).
> but Hams also like to overstate just how essential they are in these situations
That was my original point that you replied to, but your response felt too strong: I believe there is definite utility from emcomm, but it is not essential.
Ham EMCOM is mostly useful for relaying "Bill Jones says he's okay"-type traffic but otherwise it's just a LARP.
I don't think amateur is very useful for most SAR-- it's odd that you guys keep bringing it up. You guys can provision for typical needs; amateur is a benefit because of its elasticity.
> but otherwise it's just a LARP.
Don't be a dick. I think CERTs are important, and amateur radio is the lifeblood of CERT in many areas.
Doctrine here in Santa Clara County is that it's for things like:
- getting initial information and assessments from earthquakes in the first 20 minutes (a couple hundred people trained popping on nets saying modified Mercalli numbers and reporting the most urgent needs for assistance near them).
- coordinating distribution of relief supplies ("we need 100 more flats of water bottles at site GR2")
- medium priority traffic between hospitals when other communications systems fail (coordinating transfers, etc)
- handling all the low priority traffic from large festivals and events to keep primary communications systems clear (so a town's EMS dispatch doesn't need to talk about boo-boos, and so that event organizers don't need to try and talk through police dispatch)
- additional eyes and ears for police and fire
- locating anyone (inadvertently or deliberately) disrupting emergency communications
Would stuff be OK without the above? Sure. But it works a bit better with all that.
I would pull out satellite messenger to text people that I'm okay.
I have thought about getting Starlink for internet but it is too expensive for just disasters. I'm hoping they come out with smaller, cheaper dish. But Starlink would be perfect for command posts. Or for city to setup communication centers for the public.
>I've actually seen hams go on a >20 minute rant about how digital is ruining ham radio.
Digital ruined a lot of things. Analog is/was just so much more open and ripe for hacking. Part of the advantage of digital was this security. However, going digital allowed us to do so much more, so it's a migration that could not be stopped.
The only time HAMs are paid any attention are in times of disaster. Nobody will notice the loss of HAMs until the next major disaster near them, and then everyone will look around and ask "what happened to all the HAM guys?"
It's true that the HAM clubs tend to put a cultural emphasis on emergency communications. But the primary value add is the community with its various memoranda and training/standardized way of handling emergency communications. The radio skill-set and equipment is more of a red herring, tbh.
Even being tuned into the amateur radio community and living through several regional natural disasters that knocked out cell phone coverage, I've never actually seen HAM radio operators turn out to be useful in emergencies.
I'm glad for the robustness provided by the HAM community, and I think allocating spectrum is a small price to pay for a set of volunteers who serve as yet another layer of "backup infrastructure". It's valuable to have that robustness.
But tbh in an actual emergency or natural disaster I'd MUCH rather have my inReach mini than my hand-held. The HAM emergency communications narrative is vastly over-stated (and, honestly, self-important in a way that's off-putting to pretty much all non-HAMs).
The spectrum is worth it for that alone.
Only 20 minutes? That's short for an RF guy rant! I used to work with ~20 mmWave guys. All older dudes, and MAN could they talk. There was one guy who's last name was "Park." We called it "getting Parked" when he would park his ass at your desk and prevent you from getting any work done for 1-2 hours at a time
i'm doing my part!
"Those boomers are ruining ham radio for us!"
It's the ciiiiiircle of life...
This makes absolutely no sense. There's a whole base of physics, experince, antenna design, &c that are shared between analog and digital modes. Truthfully much more is shared than is different -- after all, in the end, digital modes are just another analog mode transmission.
The best way to influence the content of that exam? Join one of the more progressive VECs (Volunteer Exam Coordinators) as a volunteer examiner. Minimum license level for this is General, but really, Amateur Extra, so you can give all three exams.
Which VECs are progressive? Start with the ones that host online exam sessions, and seem enthusiastic about it. The money is trivial ($15 per exam given, and they have to have three examiners watching one test taker), so they’re in it for the love (and possibly community clout).
VECs, in turn, help the FCC set the question pools for the exams, and those are updated a little bit every four years. They’ve started adding a few questions about digital modes. I personally think they should have more content about safety and regulations, because that’s what really matters for playing nicely with others on the little bit of spectrum we have.
I think the problem comes down to the HAM rules having been formulated pre-Internet, where the distinction between amateur and commercial activity was a lot more obvious: noncommercial ~= useless, commercial ~= useful. The advent of the Internet demonstrated the existence of a whole new category: noncommercial ~= useful.
Today we've got all kinds of noncommercial but highly useful RF applications, e.g. Meshtastic, that are stuck in the relatively limited ISM bands (yes, I'm aware of HAM mode, but recall usefulness → encryption). Just using the Internet isn't a replacement for these projects, as they're intended to be useful offgrid or during times of centralized Internet disruption. IMO it's a crying shame that stuff like this, the bleeding edge of non-commercial usefulness in RF, is lower priority than ragchewing. Besides, it's not as if all the technical aspects go away under looser rules: propagation behavior etc etc are just as important, if not moreso, than they ever were.
This doesn't mean just hand it over to the corps; there's a third way. Some chunks of current HAM spectrum should be converted to ISM. That doesn't mean a total free-for-all; duty cycle and EIRP limits apply and can be scaled appropriately to the frequency's propagation characteristics. The degree of freedom in usage in ISM bands drives innovation in protocol design to make better use of available bandwidth, as has happened with 802.11, so congestion/commercial use is actually a good thing.
Also, very specifically, 47 CFR § 97.113(4) states "messages encoded for the purpose of obscuring their meaning" are prohibited (with one exception in § 97.211(B)). The intent is to prevent illicit commercialization and promote self-policing of amateur spectrum, but it does not truly preclude using encryption, cryptography, authentication, and encodings so long as the "meaning" of the message isn't "obscured."
Also, AFAIK there are zero cases (i.e. FCC Notices of Apparent Liability) on intentional use of encodings for the purposes of obscuring the meaning of messages on amateur spectrum, and a very small number of cases of hams complaining about illicit transmissions, most of which were a result of an error or spurious emissions. I think most hams read the law and stray far away from brushing up against it by avoiding even the discussion of encryption carte blanche, but I think it's unexplored territory that would help to advance the state of the art, so long as we abide by common-sense practices to avoid *obscuring the meaning*, e.g. clear-text identification, public/published encryption protocols/keys, etc.
But if your intent is to basically use encrypted ham radios as an off-grid alternative to the internet and/or ISM/licensed wireless/cell networks for private or commercial use...then just use the internet and/or ISM/licensed wireless/cell networks.
It's also not far-fetched to amend the regulations. Debbie Lesko (R-AZ) is writing a bill to change the antiquated symbol rate limit to a bandwidth limit, opening up new modes, data rates, and capabilities for hams and emergency communicators on HF, VHF, and UHF spectrum. "Obscuring the meaning of the message" is very vague, and it certainly needs to be clarified and updated with the best interests of wireless experimentation at heart.
Small amounts of digital have been allowed in FRS for a while. But only one second, every 30 seconds. Creating a mesh within that constraint would be genius.
https://www.law.cornell.edu/cfr/text/47/95.587
But sending GPS coords and short data bursts standalone or with phone app is a thing. e.g. https://baofengtech.com/new-release-btech-gmrs-pro/
Here's a link to the VHF band plan we use here in the UK - obviously I can't speak for other countries: [https://rsgb.services/public/bandplans/19/ ]. It's _littered_ with SSTV, beacon and digital mode allocations (and for clarity, that's a good thing). The digital mode allocations are full of people chatting in text using FT-8 or JS8Call (more in HF than VHF, those, but the principle holds). On the next page, there's an entire 1MHz allocation dedicated to wideband digital data modes.
If you're a licensee, there's plenty of innovation and digital experimentation space available. Sure, a chunk of the traditionalist ham community aren't excited about it, but there's plenty of us who are. And, as ever, you don't need a license to receive...
Kinds sucks being the birthplace of telecoms...
The curmudgeons are a minority, but a very vocal one.
I'm pretty sure that those few who might get into really do get pushed away by the people who still do it...
wut
Of course HF doesn't propagate "straight" so a direct comparison is not straightforward.
Hams tend to be very sensitive about interference, and rightly so. It's already pretty much impossible to do HF communications in urban areas due to the high noise floor caused by poorly designed switch mode power supplies, solar inverters, power over ethernet, etc.
But this is from high frequency stock traders. What are they planning?
arrl.org does