The Shortwave Modernization Coalition?

 

There's been an awful lot of talk the last week or two about a proposal for rule making (PRM)  that's currently before the FCC.

The request has been drawn up by a group which labels itself the "Shortwave Modernization Coalition." (SMC).

Apparently, this group is largely made up of Wall Street types, international Wall Street types in fact. 

They propose transferring data from our continent to theirs,  by way of a single transmitter as opposed to going through the internet, since it exhibits far less in the way of latency. The complaint being that that connection, that late latency that's been going through the internet has been costing these folks large amounts of money. Such is the state of our stock market these days the trades are going that quickly and the thing is in the estimation of the shortwave modernization coalition it's worth the money to invest in those systems, which certainly will not be cheap to erect, use or maintain.  They're talking about using 20KW TPO which is used with a directional antenna (why wouldn't they?) means quite a bit higher in ERP.

(Aside: It's been pointed out that this proposal if enacted, would create a serious and likely insurmountable advantage to the users of these systems. I point this out to show you the weight behind this proposal. But let's still with the technical and Ham radio related aspects, shall we?)

The SMC as I will call them, has been doing test operations since 2014 or so, using 10kw transmitters.. They point out in their PRM that nobody's complained about interference from their operations at the 10K level they've been playing with,  from from anybody else in the electrical neighborhood including maritime, aircraft, and for that matter amateurs and shortwave broadcasters and of course, Ham operators. 

(Aside:Further, I question what the added 3dB will give them, but, no matter for the moment on that part. )

I must admit that my initial reaction came from my technical side and was in effect "Well, that's interesting". But then the more practical side spoke up. As in, " Hold the phone!"

Without even looking at the proposal in detail, one question that pops out is bandwidth, another is harmonics, and with that kind of power, the issue becomes quite serious, in my view.

Let's face it ...if it has the proposal suggests their concern is getting messages through as fast as possible then the standard 300 quad rate isn't going to cut it anymore and at a power output of 20 kilowatts you can make a mess out of large portions of the HF spectrum in a real hurry, that go well beyond the primary frequency.

For their part, the FCC seems amenable to these ideas and has been pointing out for as long as I can remember that the HF spectrum is underutilized.  so I'm guessing that without a serious amount of pushback commission is going to be inclined to Grant the request and put forward an NPRM before the echo dies from the comment period.

But again, hold the phone, here. 

Before you get the wrong idea I do not believe that at least initially we're going to have problems with our proposed new neighbors. But I do believe the trend being signaled here is worth watching if we value our Ham radio future on HF

Large as the concern about problems radiating from this proposal, (sorry, couldn't resist) The FCC's attitude about this creates an even larger concern for me, when you look at the proposal and see where the money's coming from for it. Places like Ukraine, and Saudi Arabia to name a couple.Now, as traders begin to recognize the financial advantages of using systems like this, the rush for added transmitters and frequency space will skyrocket. Therein, in my view, lies the bigger issue. We're going to be drowning from these new, high power systems. I don't care how tightly they're filtered, there's bound to be problems for other users of these bands, including alas!, us.

 I mean, we're talking serious money here and I suspect that if this proposal becomes reality, we're going to start seeing large chunks of HF real estate being sold off with the money going into the FCC's wallet. Money they seem to think is desperately needed, if we observe the process by which large amounts of spectrum were sold off, the sales and the regs surrounding that sale,  rammed through like a bullet from a rail gun, for the cell phone companies.

With that kind of money involved the question becomes whether or not the ARRL (Who is, in all fairness, already reacting to the proposal) will be able to withstand the obvious desire for large growth in HF traffic.

Keep an eye on this thing. If you get some expertise to bring to the table in the way of comments for the commission, do so.

Addendum:

Tom, W9YW responds:

I have two minds on your posit,

. The first one is that we lived with short wave broadcasters around the world in HF for >100years. They were a fact of life. A few were coughing bad signals, but rarely did it cause a problem, even at >100KW of directed signal. Yes, that signal was AM and easy to shape the harmonic slope-- not high speed encrypted digital goo. But we lived with it. Part of the reason for the wide spectrum, I'm guessing, is that the new broadcasters want to prevent jamming, and also optimize their commercial goal-- quickly executed arbitrage that makes them revenue. That's understandable.

The other mind says that it will be random frequency, encrypted data, the kind that hams aren't allowed for both national security reasons, and assurance that other uses of the spectrum aside from the allocation aren't being used.

Their proposal lacks, and this is my other state of mind, a sufficient analysis of a highly sampled, nation-side scatter of what their signal actually looked like so that a FFT reception can be known. Meaning there aren't enough statistics nor boundaries to the signals used to vet that the transmissions won't harm other users of the spectrum to the fifth harmonic of the fundamental. Once it's allowed, the mode used over the bands allowed won't be easy to pull back or halt, and the squabbling will be huge and expensive because of the investments made. We also don't know how many concurrent signals might be used, by whom, and the boundaries of signal mode types. After revealing this, we know much more. Their data as proposed seems insufficient to me, and I have a lot of quality engineering background.

73 Tom W9YW

I can't disagree with your response, Tom.

Having just downloaded a copy of the PRM, I'll be examining it over the next few days. Obviously, (And as I think I indicated)  my comments were of the "first blush" variety.

Your comments bring up a few other thoughts and a clarification or two that perhaps we should explore.

I believe that once one leaves the realm of experimentation, which Ham radio certainly always qualifies as,   as has what the SMC has done so far, it's my belief that the commission should demand the same level of detail, and accept the same levels of public comment as we see in the world of commercial broadcasting. Certainly, this SMC project is a commercial operation, and should be directed to jump through the same hoops... including precise frequencies used, power levels, radiation patterns, testing for harmonic issues, and a standardized operational mode. So far as I'm aware, we've seen none of this.

More succinctly, I agree their data at least so far as I've yet seen, seems vague at least. Must be, nobody's directly commented on it, except to suggest increased bandwidth would be required for the kind of transfer speeds SMC is aiming at, and that seems a no-brainer right at the off.

That's troubling of itself, but further..... and here we get into the non-technical..... I'm made somewhat uneasy by the proposal that the signals be encrypted.

Your historical examples make your point well, and  like you, apparently, I have my doubts that at least in the first wave, we're going to have any serious interference issues.  Thing is, the argument fails to address the idea that they were, shall we say, open source. We knew what they were doing, were able to monitor their transmissions and so understood if harm was intended or not.  As Ham operators we can run any kind of protocol, so long as it is publicly documented. That minimal restriction was imposed for reasons of national security.... a wise precaution.

That's not, however, in what's being proposed here. We're talking about super-fast signals owned by foreign nationals in countries that have no always been friendly to us, and whom we have no guarantee, or even any indication, that they will be in future. (Smiling faces sometimes) 

 Yes, financial data, and I understand that point. Indeed, as I suggested in the OP, this proposal if enacted, would create a serious and likely insurmountable financial advantage to the users of these systems. That of itself may very well impact national security. We're talking about vast money, here, and that kind of money rises to the level of national security in terms of financial impact here in the 'states.

But can we trust that other data, of even more of a national security problem, isn't going to be buried in the data streams? That seems a security red flag at least, but as I suggested in my OP, I was trying to keep my comments (mostly) to the technical issues presented we as Hams by this proposal should it ever be adopted. At the same time, I'm unsure I trust anyone anyone at all, to monitor such things to ensure national security. Taking a chance either way in my view.

The commission appears to be looking at this from a purely technical POV as is their wont. And from a purely technical standpoint, the proposal seems fairly harmless in the short term, as I've suggested. But there seems more at stake here than that, and I wonder if more than just the commission will be involved here.