So here's your precedent for pushing the wideband digital
technology, voice+data or just-data to the north side of the
data/phone spectrum boundary. Let D-STAR do its digital voice + data,
or for that matter data-only [with the N3BAH device].
This is exactly what I have been saying all along - wide band data
needs to be in the "phone" bands and subject to the same 3/6 KHz
(or 2.5/5 KHz) rules as single sideband and AM/ISB. The rules are
rather clear that no non-voice emission can be wider than the equivalent
*communications grade* voice signal - which works out
to be 2.5/2.7/2.8/3.0 KHz for a single channel system (e.g. SSB)
and 5.0/5.5/6.0 for a dual channel (ISB, multiplex, or AM).
Perhaps, based on D-STAR precedent, we should encourage Pactor to
join D-STAR in the (previously) phone-only band segments.
It's not just D-Star ... consider STANAG, M110 and other NATO wave-
forms or ALE. It seems absolutely absurd to require two frequencies
- one for the data/sounding and one for the digital voice - in
different parts of the band based on the "payload" for otherwise
identical emissions.
The *only* concern I have is the one raised by Dr. Flowers - the
"modulation key" should be restricted to a single *published* value
for each protocol. Similarly *encoding* algorithms (like the D-Star
codec) should be required to be published so the content of the
transmissions can be monitored without the "tax" of purchasing a
specific piece/brand of hardware.
In any case, RTTY/data added to the voice/image allocations as I
proposed in my "late" comments:
http://apps.fcc.gov/ecfs/document/view?id=7521065473
would address all of these issues except Dr. Flowers' concern for
incidental encryption (and that is an easy change). The smart
approach is to press each of your Directors to make K1ZZ withdraw
the League's RM-1170 proposal in favor of a bandwidth based solution.
73,
... Joe, W4TV
On 3/21/2014 3:09 PM, Kai wrote:
There is a further "worry" that I have as digital technology marches
forward.
We're 50+ plus years beyond the introduction of simple amateur-RTTY,
and rules have not kept pace with amateur practice.
Yes, I keep harping on the BW loop-hole that allowed appearance of wide
band data-only modes like Pactor 3. The picture is messier, however.
Icom has established D-STAR technology as a viable alternative to FM
voice and data at UHF and VHF. Their HF-UHF transceivers, however, are
D-STAR capable in all bands even the HF bands. There are D-STAR
"watering holes" now in the voice sub bands at HF, and there are nets at
HF using D-STAR.
D-STAR is a complex QAM digital modulation scheme that interleaves digital
voice with digital data on the same channel. The signal bandwidth is 6 kHz,
and is well documented (except for a proprietary vocoder).
So, on the one hand, here is precedent for users of a wide band (6 kHz)
digital technology, which has appeared in the voice sub-bands. It is also
simultaneously a data (SMS-like) system. Data and DV can appear
simultaneously,
or voice-only or data-only [see N3BAH "D-terminal...", Apr QST].
.
I'm sure that you will agree with me that even just the data portion has
no business
appearing in the CW/data portions of the bands. I hasten to add that it
has not
appeared outside the phone segments ---- but because of its design
it DOES place a data channel interleaved with the digital voice on the
same signal -
and folks are using it in the phone segments at HF. The phone segments
are no
longer "purely" phone, they never were, once "image" was allowed up there.
So here's your precedent for pushing the wideband digital technology,
voice+data
or just-data to the north side of the data/phone spectrum boundary. Let
D-STAR
do its digital voice + data, or for that matter data-only [with the
N3BAH device].
Perhaps, based on D-STAR precedent, we should encourage Pactor to join
D-STAR
in the (previously) phone-only band segments.
-Kai, KE4PT
On 3/21/2014 12:03 PM, Joe Subich, W4TV wrote:
Prior to the start of the demonstration, at the monitoring station,
we observed an existing SSB conversation going on just slightly off
the frequency and a CW station calling CQ on the frequency. After the
demonstration was complete the SSB station was still there but the CW
station was gone.
This is a prime example of the asymmetric nature of interference from
wide band modes to narrow band modes. It is *exactly* the reason the
FCC has, for approximately 80 years, protected narrow band modes in
between 30 and 50% of each HF amateur band from interference by wide
band modes.
The Commission restated and reaffirmed that policy when ARRL requested
that *wide band* image transmissions be included as data. In WT Order
04-104 (FCC 06-149) in 2006, the Commission clearly rebuked ARRL:
we note that eliminating or relaxing the bandwidth limitation would
de facto eliminate the separation of narrow bandwidth and wide
bandwidth emissions. We believe that separation of emission types by
bandwidth is accepted in the amateur service as a reasonable means to
minimize interference on shared frequencies and bands and, therefore,
we will not replace the 500 Hz bandwidth limitation with a 3 kHz
bandwidth limitation.
In footnote 89 of the same order the Commission expanded on the reasons
for the separation of wide bandwidth modes from narrow bandwidth modes:
Separation of emission types by bandwidth minimizes or reduces
interference because it protects narrow signals from interference
from wide signals. Amateur licensees have accepted this division of
spectrum as a method for minimizing interference for as long as the
amateur service has been regulated, and no commenter in this
proceeding requests eliminating emission segmentation based on
bandwidth.
The entire Report and Order in WT 04-104 (FCC 06-149) is here:
http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-149A1.pdf
Based on the Commission's policy since the 1930's, ARRL *should have*
simply requested that RTTY and data be added to the list of wide band
emissions permitted with Phone and image, subject to the bandwidth
limits in 97.307(f)(2):
(2) No non-phone emission shall exceed the bandwidth of a
communications quality phone emission of the same modulation type.
The total bandwidth of an independent sideband emission (having B as
the first symbol), or a multiplexed image and phone emission, shall
not exceed that of a communications quality A3E emission.
Then the "loophole" that K1ZZ and KE4PT are so concerned about (multi-
carrier digital systems with symbol rates less than 300 baud) could be
precluded in the "narrow band" segments simply by amending 97.307(f)(3)
to specifically include a 500 Hz bandwidth limit without precluding
any experimentation, development, or deployment of new codes and
PACTOR 3/4 would be free to compete with other wideband modes.
Note that "regulation by bandwidth" which K1ZZ disingenuously claims
would be a new regulatory paradigm has, in the mind of the FCC, been
a fact of life for 80 years.
73,
... Joe, W4TV
On 3/21/2014 11:27 AM, Terry wrote:
Yesterday a few of us witnessed a demonstration of Winlink using the
PACTOR
3 waveform. A simple one line email was sent from a EOC center in
North
Texas to one of the Winlink stations in Central Texas around 6:00 PM
CST.
The demonstration was monitored at a station in-between. The
demonstration
was done on 40 meters just above 7.100 MHz. Prior to the start of the
demonstration, at the monitoring station, we observed an existing SSB
conversation going on just slightly off the frequency and a CW station
calling CQ on the frequency. After the demonstration was complete
the
SSB station was still there but the CW station was gone. The
transfer was
not timed but it was quick (probably two minutes) .
So I want to retract my earlier comments about Winlink being
slow. The
demonstrated QRMing is a concern.
Thanks,
Terry
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