I heard about this #FCC proposal just last night: https://www.fcc.gov/ecfs/document/1042840187330/1

There is a group of financial trading companies that want to set up commercial digital transmitters at 20kW power with 10 kH bandwidth using frequency jumping tech to send real time trading information in the spectrum amateurs currently use.

1/3

Questions have been raised about possible interference and loss of spectrum.

ECFS

Federal Communication Commission Electronic Comment Filing System

The reason they want to do this is because these frequencies can provide lower latency than wired fiber links can and world finance is now running on automated trading platforms. The trading systems that can get their orders in first can make more money on a downturn or upswing in the markets than those who cannot.

2/3

This is why financial outfits in NYC were hiring physicists out of the labs and universities to work on better algorithms for this kind of automated trading 10 years ago and now they are looking for the next edge in micro-seconds. Its literally a hacking competition but with big monies and the battlefield appears to be in our back yard.

3/3

@K3LTC Quick look at the document.

There a many VOCAP coverage maps that show that their multi-kW emitters are very well-behaving : HF radiations stops right at the US borders.😆
To our Canadian and Mexican friends (and Europe): don't worry!

I wonder if this is a pure FCC matter or if this goes against some ITU international treaties (spectrum usage and cross-border interference?)

I can't see the ITU to unit for the sole benefit of a few US financial services provider selling encrypted data.

@F4JWJ
Look into the companies in the organization. They are multi-national.

@K3LTC I checked every signing company in the list.
If I'm correct, they have an international activity but are all US based, except one in Amsterdam.

(The Netherlands almost equals "fiscal paradise" status in Europe, and attracts big companies HQ, including French ones...)

Just sayin' 😀

@K3LTC Now, from the document, I don't see direct threat to the Amateur bands.

Maybe I' missed something ?

@F4JWJ - there may be none. I am not a broadcast engineer and really not qualified to say. I didn't claim there was any threat? The closest I came I think is: "Questions have been raised about possible interference and loss of spectrum."

Is a 20,000W transmitter at 10kH bandwidth going to bother you as it frequency skips around (to avoid interference)? Is the FCC (US) going to take some frequency away from amateurs to ensure it doesn't interfere?

@K3LTC The document claims an Out Of Band Attenuation of :
- 35dB at 150% x BW (15kHz)
- 50dB at 250% x BW (25kHz)

20kW -> 6.35W@15kHz; 0.2W@25kHz

Maybe the FCC could confine this service to some well defined sub-bands, at a good distance from the very sensitive amateur bands?

Hams use QRP powers and many different types of experimental modulations.

If this kind of technologie offers a true trading advantage on some markets and is allowed in the US, one can expect it will spread worldwide.

@F4JWJ
Jake Brodsky, AB3A comments on this section of pg 28: "okay, that's a blank check".

He also says "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"

from here: https://swling.com/blog/2023/07/shortwave-modernization-coalition-public-comment-period-on-new-proposal/

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 SWLing Post
@K3LTC I agree, that was my very first impression.

@K3LTC
Note that the petition is about "modernizing" something they call P90 in the FCC rules (not the Gibson guitar pickup 😀 ).

Part 90 is defined here
https://www.ecfr.gov/current/title-47/chapter-I/subchapter-D/part-90

Excludes : Broadcast, Amateur, Military and US Agencies, others ?

This reduces the spectrum targeted by this petition, i.e. not the whole 2-25MHz but the professional and industrial (licensed) bands, if I understand correctly.

Federal Register :: Request Access

@F4JWJ
It seems that Part 90 matters to amateurs as related to the "frequency stability and the purity of the transmitter output" for devices operating under that regime.

@K3LTC
I'd like to extend my previous post on the level of interference.

The Petition describe 10dBi gain beam antennas.

The interference levels I calculated didn't account for the aerial gain.

If we add 10dB :

Equivalent isotropic interference PWR in beam direction :

20kW -> 63.5W@15kHz; 2W@25kHz

Or relative to a "perfect" dipole (2.18dBi)

20kW -> 40.5W@15kHz; 1.3W@25kHz

= 40W ham TX in a dipole.

Better keep these HF services away from the ham band limits, specially the low #CW part.