More info on High-Frequency Trading and how DRM plays into the picture

 

Check out this article from Experimental Radio News. Benn Kobb offers the latest news and details on these mysterious HFT stations.

As the World ‘Turms’ by Benn Kobb

Reprinted here by permission of the author. Thanks Benn!

--------

Subject: As the World ‘Turms’

It would seem like 2021 would end with no FCC action on the three mysterious entities requesting licenses under the umbrella of International Broadcasting, but likely involved in sending private messages to trading clients in Europe and Asia.

In fact there has been action, of a sort.

Two of those applicants are still waiting to receive construction permits. The third — Turms Tech, part of Turms Holdings, a subsidiary of Emcor Securities of New York — already has a construction permit and says it has built a 10 kW DRM station in New Jersey.

Turms requested callsign WIPE. It is so listed with the FCC. Turms has no license to operate this station. Yet.

The FCC is apparently not clear about whether Turms intends to use WIPE for conventional broadcasting — you know, the only type of transmission permitted under the FCC rules for such HF stations.

Turms originally told the FCC that it will engage in “broadcast and data services” and “broadcast of financial, economic news and data through distribution of programs generally prepared on the basis of requests by clients.”

Clear as mud. If broadcasting business news on shortwave to DRM receivers is profitable, you’d think that WTWW, WRMI, WBCQ, WWRB etc. would have discovered that years ago.

And what’s that about “data”? The FCC rules are plain that HFBC stations are for broadcasting to the public. There is no exemption to that requirement whether the broadcast is audio for listening or data for decoding.

So to clarify the issues, on Dec. 3, 2021 five FCC staff members asked WIPE’s consulting engineer if he could answer a few questions.

He couldn’t, at the time. Quoting from a record of that online meeting: “The information being sought was clarification of certain general non-technical items that will be possibly proposed by the pending shortwave operation. These type of items or clarifications are not normally items that this [engineering] firm would be knowledgeable.”

Presumably after consulting with his client Turms, he later provided FCC with these answers:

– – –

Q: Clarification is requested regarding the audio and data content of the general service to be provided, if known?

A: Airtime will be sold to anyone interested in broadcasting his contents. Editorial line will focus on contemporary topics, no religious or political contents. More specifically the target we’re looking for is global news and financial information, CNBC style programs.

Q: Will encryption be used in the transmitted signal?

A: No encryption will be used, this is a general broadcast.

Q. Will there be a contract for reception of the signal required?

A. No contract will be required for the reception.

Q. Will a DRM receiver be required for either or both the audio or the data?

A. A DRM receiver will be required for both audio and data.

Q. Will the proposed transmitter site receive other international HF signals to be rebroadcast on the intended operation?

A. No.

– – –

The FCC’s question about contract is especially pertinent, as the FCC considers broadcasting to require no contract between transmitting and receiving parties. A private data operation would involve such a contract, usually for some kind of subscription or other fee for service.

So what should we believe? WIPE will not engage in private data communications, but will instead pursue a sketchy business plan?

On December 23, 2021, RF engineer Alex Pilosov submitted a detailed objection — his second — to the TURMS application. According to Pilosov, “the directors and officers of TURMS do not claim any broadcasting experience, but certainly have substantial business experience, and are aware of the business of trading and data transmission.

“What TURMS claims,” he told the FCC, “is that a company without any experience in broadcasting decides to construct the first International Broadcast station in 20 years dedicated to ‘financial news’ programming, and ‘data broadcast to the general public,’ foregoing any subscription revenues, but somehow able to recoup the setup costs by broadcast operations alone.

“The second possibility, apparent from digging into the facts and associated entities, is that TURMS instead lacked candor in its filings, and that its application for ‘International Broadcast’ is merely a pretext for private data transmission business.”

If and when WIPE goes on the air — on 9.65, 11.850, 13.720 and 15.450 MHz — DRM monitoring by the SWL community should help establish the facts about any possible encrypted or otherwise non-public, non-broadcast emissions from this station.

Benn Kobb

A New HF Station that's Similar, but Different

By Bennett Kobb

On October 21, 2020, DPA Mac LLC filed a FCC license application for a new, DRM-based International Broadcast Station to be located in Maple Park, IL. The principal is San Francisco entrepreneur Seth Kenvin and its technical consultant is Tamir Ostfeld of Raft Technologies, an Israeli developer of low-latency HF systems for so-called algorithmic trading.

No station devoted to algorithmic trading has ever been authorized for regular commercial operation in the U.S., as there is no formal radio service or spectrum allocation for that purpose. Several such stations have been licensed in the Experimental Radio Service (ERS), which is ostensibly for scientific studies only.

If the FCC licenses DPA Mac, it will be the first such station to make the transition from the ERS to regular, non-experimental licensing. This station would be the successor to experimental station WI2XXG. Other than the license document, the FCC has withheld most of WI2XXG's records from public disclosure since it was first licensed in 2017.

DPA Mac is similar to other DRM stations on which we previously reported: WIPE in Alpine, NJ, which is built and is waiting on its FCC license; and WPBC, proposed for Batavia, IL. With regard to their use for non-broadcast, private data transmissions, those stations made general and non-descriptive representations to the FCC. On the other hand, DPA Mac's license application is fairly transparent. The station aims to transmit "investment data from points within the United States to locations outside the United States carried over a channel immediately adjacent to the HF broadcasts...a low-power, low-latency digital data transmission service provided to private investors, including small- and medium-sized firms."

This service "will provide the necessary financial support to deploy and sustain the HF broadcasting business for the benefit of the public now and into the future." The data component, it said, will fund an "over-the-air, commercial-free audio broadcast of U.S. financial news and similar information to populations outside of the United States that have access to a standard, commercial, off-the-shelf HF receiver."

Waivers of FCC rules

DPA Mac requested waivers of certain FCC rules. Its station would run 2 kW transmitter output power, while Rule 73.751(c) requires a minimum mean power of 10 kW if digital modulation is used. "Technological advances have rendered a minimum power requirement obsolete," the company said, "and DPA Mac's technological showing demonstrates that it can successfully operate at a much lower power of 2 kW. Operating at this lower power will increase the efficiency of transmissions and reduce the likelihood of harmful interference to adjacent band operations, allowing DPA Mac to maximize use of this spectrum."

One of its proposed eight frequency bands is 7.342-7.4 MHz, which is not available to International Broadcast Stations. Footnote US136 to the Table of Allocations restricts use of 7.3-7.4 MHz to certain fixed, land mobile and maritime mobile stations. Another FCC rule, 73.702(j), concerns assignment of one frequency for use at a time, while DPA Mac said its "lower power transmissions are more susceptible to disruption from atmospheric changes and other source[s] of interference than traditional high-power transmissions are. To overcome these challenges without raising power, DPA Mac may need to use more than one frequency at any given time to maintain a continuous, uninterrupted connection to listeners."

The company also requested a limited waiver to give it more time to find a location for an auxiliary transmitter. "DPA Mac is immediately able to broadcast its programming to the foreign public using its main transmitter," it said. "Auxiliary transmitters provide a back-up means of transmission but are only necessary in rare circumstances."

Looking ahead

The FCC rules for International Broadcast stations don't accommodate non-broadcast data communications to private customers. All such transmissions, including "datacasting", are limited to broadcasts for reception by the general public - at least until the FCC changes the rules, ignores non-public communications as insignificant, or interprets or waives the rules to allow them. DPA Mac's application is the third to propose such operations, and is certainly the most explicit.

In addition, if the FCC allows a reduction in minimum power from 10 kW to 2 kW, it could improve the economics of private shortwave broadcasting considerably. Perhaps the FCC could reduce the costly 50 kW AM minimum power as well.

What is certain is that the FCC can't sit on these license applications forever. Someday these new DRM stations will go on the air, and perhaps even change the face of private U.S. shortwave broadcasting.

Questions Remain as New HF Stations Wait for Licenses

Here is the story by Bennett Kobb:

As previously reported here at DRMNA.info, the New York company Turms Tech LLC has applied to the FCC for a license for International Broadcast Station WIPE in New Jersey. The license would cover a station already built under a FCC Construction Permit, and would allow it to begin regular operations.

The FCC announced on August 13, 2020 that this license application was accepted for filing, a routine stage at which the FCC examines the application, and might even visit the station, and if everything is in order it will be licensed.

We're not sure everything is in order. The application for Construction Permit placed the transmitter site at N 40° 57' 40.38", W 73° 55' 23.97", the broadcast and communications center surrounding the famous Armstrong Tower at Alpine NJ. Its Application for License, however, specifies N 40° 51' 40", W 73° 55' 23". (Hat tip to Alex P for noting this discrepancy. More about him below.)

While the substitution of 51 for 57 in the coordinates might seem a simple typo, the FCC typically has no sense of humor about coordinate errors. Commission examiners may wonder why a station intended for a historic radio-TV facility ended up among some Manhattan apartments.

The deeper question with WIPE and another, apparently similar station WPBC, is what these stations are really for and what that means for the FCC Rules. WIPE was extremely vague about its program plans, but told the FCC that it will transmit data obtained from third parties using Digital Radio Mondiale. Putting that tidbit together with exposures in a series of public articles in the media and tech blogs, it would seem that audio programming will not be the central mission of this peculiarly named station, whose principal is a financial executive and forestry entrepreneur without any broadcast experience we could find.

We suspect instead that the WIPE data stream will be used not for broadcasting to the public -- the only function permitted to International Broadcast Stations under FCC Rules -- but instead will be used for private communication with foreign exchanges for high-speed trading.

We know of no other justification for investing millions in a new U.S. shortwave radio station when several already exist and would probably appreciate new customers. Unfortunately for the putative DRM broadcaster, the FCC Rules have never permitted anything but open, transparent HF broadcast operations. While one FCC rule does allow shortwave "datacasting", it is only in the context of broadcasting. An example of broadcast datacasting would be Shortwave Radiogram, the successor program to VOA Radiogram which has been experimenting with data modes over AM transmitters for several years.

International data messaging under contract to private clients with receivers at specific fixed locations, on the other hand, is not broadcasting to the public under any reasonable interpretation of the rules. There was an International Fixed Service years ago, but the FCC closed it for lack of interest, probably supplanted by undersea cable and satellites. Thus both the prospective licensee and the FCC have a problem.

As suggested in previous FCC filings by Christopher Rumbaugh, Kim Elliott and Bennett Kobb -- the "High-Frequency Parties" -- the FCC could start to resolve the dilemma with a public inquiry into U.S. HF broadcasting, or actions to update the rules to permit non-broadcast operations in shortwave broadcast bands. Those rules could surely use a fresh look. They've seen little change since the 1930s when the U.S. first permitted private parties to broadcast to foreign audiences.

But those would be public FCC actions. Very little about WIPE has been public. The principal of Turms Tech declined to answer questions about the station, as did his engineer and the company that operates the Alpine tower site. While we wait for FCC action, and sit by our receivers anticipating Wonderful WIPE, more curious developments surround the similar, but as yet unbuilt station WPBC at Batavia IL, proposed by Parable Broadcasting of Norfolk VA.

After the High-Frequency Parties argued that Parable provided insufficient information to the FCC about its possible non-broadcast operations -- whatever audible radio shows WPBC may transmit on top --another party has filed an objection to the WPBC application for Construction Permit. Alexander Pilosov of Shortwave Solutions is an engineer involved in high-frequency trading by radio in the Experimental Radio Service. The ERS is not a public broadcast service and is not limited by the HF broadcast rules.

Pilosov told the FCC, "Parable submitted no evidence how the data it plans to transmit can be decoded by the general public, without use of special equipment." Nor did it submit any evidence as to the kind of data it intends to transmit, he argued.

He wrote that Parable appears to read a previous FCC ruling permitting datacasting "as a permission to offer non-broadcast, private, point-to-point services over the HF broadcast bands." If the FCC intended to permit non-broadcast use, he contends, it would have stated so in a far more explicit manner such as altering the Table of Frequency Allocations.

Will these concerns give the FCC pause, and delay or even deny licenses to Turms Tech and Parable Broadcasting? Will it inquire further into private HF datacomms and decide that these don't really qualify as broadcasts?

On the other hand, maybe the FCC will snooze through the matter and allow the two newest shortwave stations on the air as is, leaving listeners to wonder what goes on beneath the surface. Whatever the outcome, shortwave radio is about to get a lot more interesting.

The "High-Frequency Parties" return!

You might remember our previous input on SWBC matters several years back. Now, with this pending application containing potentially "spurious emissions", we have decided to say our piece. We are known as the High-Frequency Parties, consisting of Benn Kobb, Dr. Kim Andrew Elliott and myself, Christopher Rumbaugh.

We're filing an objection with the FCC to an application for International Broadcast Station being proposed in Illinois. Do we want and support DRM? Of Course we do! Do we believe that latency arbitrage in International Shortwave Broadcast Bands is a deleterious intruder? You bet your sweet bippy we do! Read our take here.

Once again, antiquated rules are hindering radio technologies. In this case, latency arbitrage is certainly a reasonable use of radio waves - but it does not belong in-band with International Broadcast stations. International Broadcast bands are global-village shared public resources for the promotion of culture, ideas and mutual understanding - not encrypted financial trading data.

UPDATE 20200708 1830 UTC : Here is an article in Radioworld on the "High-Frequency Parties" objection filing.

Again with the DRM and a "bonus" arbitrage payload

Yet again, another arbitrage shortwave plan, this one from Batavia Illinois.

Brother Zyg says this smells like what we have already seen with WINB and the never-developed Turms Tech project. Brother Benn says "Arbitrage shortwave transmission is not broadcasting as defined in Part 73F for International Broadcast Stations."

Religious investment? I like the TCI wire Log. They can divert that to my acreage!