While what both W4PWF and K1ZZ says is technically true, careful study
of the history of digital rules would indicate that the Commission has
never envisioned digital signals as wide as 2.8 KHz.
The rules started with a 1000 Hz shift limitation, which became "less
than" and was gradually expanded to 300 baud long before anyone even
contemplated multiple tone or combined FSK/PSK/AM modulations. The
rules as written in the context of technology available when they were
written have *always* envisioned an occupied bandwidth less than 1 KHz
and generally less than 300 to 500 Hz.
If the ARRL wants to eliminate obsolete language concerning baud rate,
they should propose substituting a bandwidth of 500 Hz - roughly equal
to the majority of amateur practice and consistent with the historical
regulatory pattern. Such a change would be a trivial modification of
Section 97.307(f) to replace the second sentence of (3) and (4) with
"The total bandwidth shall not exceed 500 Hz." Such changes would have
little or no practical impact on amateur practice but, as claimed
by ARRL, "would, in the aggregate, relieve the Amateur Radio Service
of outdated, 1980s-era restrictions". ARRL's own petition (at page 6)
lays out history and rational for the 300 baud data rate limitation:
"There was also general agreement that the permissible bandwidths of
ASCII or other radioteleprinter bandwidths be similar to the
traditional bandwidths associated with the use of the Baudot Code in
the various frequency bands." Again, based on the rich history of
amateur digital activity and Commission actions, it seems that a 500 Hz
bandwidth limit would be consistent with the desire to eliminate a
fixed "baud rate" maximum without increasing regulatory burden or
the already currently high levels of interference in these narrow
allocations.
If on the other hand the goal of ARRL is to raise data rates, they
should be honest in their proposal and propose modifications to
97.305 which would expand the "RTTY, data" authorizations and place
the wider digital signals in the areas currently assigned to "Phone,
image" where the wider bandwidth signals would be more appropriate.
Doing so would not only provide opportunity for higher bandwidth,
multi-carrier amateur data protocols but would also allow amateurs
to experiment with M110A/B/C, ALE and similar digital voice protocols
in an appropriate environment.
73,
... Joe, W4TV
On 11/21/2013 9:16 AM, Ben Antanaitis - WB2RHM wrote:
All,
Here are the responses I received, in July, from K1ZZ, and W4PWF my
Roanoke Division director.
Ben - WB2RHM
From: Ben Antanaitis - WB2RHM [mailto:wb2rhm@wb2rhm.com]
Sent: Wednesday, July 24, 2013 1:33 PM
To: w4pwf@arrl.org; N2ZZ@arrl.org; n2cop@arrl.org
Subject: RE: "asking the FCC “to apply to all amateur data emissions
below 29.7 MHz the existing bandwidth limit, per §97.303(h), of 2.8 kHz.”
Per the ARRL news:
***************************************************************************************
On the motion of ARRL West Gulf Division Director Dr David Woolweaver,
K5RAV, on behalf of the Ad Hoc Symbol Rate Rule Modernization Committee,
the Board directed ARRL General Counsel Chris Imlay, W3KD, to prepare a
Petition for Rule Making with the FCC seeking to modify §97.307(f) to
delete all references to symbol rate. The Petition would ask the FCC “to
apply to all amateur data emissions below 29.7 MHz the existing
bandwidth limit, per §97.303(h), of 2.8 kHz.”
The committee determined that the current symbol rate restrictions in
§97.307(f) “no longer reflect the state of the art of digital
telecommunications technology,” and that the proposed rule change would
“encourage both flexibility and efficiency in the employment of digital
emissions by amateur stations.” The Ad Hoc Symbol Rate Rule
Modernization Committee was dissolved with the thanks of the Board.
***************************************************************************************
Gentlemen,
I hope that the process on this idea is not too far down the road to
TURN BACK.
In my opinion, what you are proposing will have the potential to destroy
the data segments that we now use in the HF bands......... eg PSK is
structured, and voluntary frequency segmented, to allow many many QSOs
to operate in a vastly smaller piece of spectrum than 2.8KHZ per
signal. RTTY operators can chat, work DX, and Contest in something
around 300Hz bandwidth and they operate in their 'piece of the spectrum
pie in each HF band...........
Now you are thinking of requesting that frequency hogging 2.8KHz,
uncontrolled data signals, of any nature, spread out over the entire
DATA Mode spectrum of the HF bands....... blasting away the
possibilities for hundreds of CW/PSK/Hell/RTTY/MSK operators.......
If you follow through on this ill-advised and ill-concieved plan, you
might as well cancel any ARRL PSK, RTTY, or CW contests you current
sponsor........... The entry numbers in these contests, DXing
activities, and rag-chewing in these band segments and modes has
steadily grown, not diminished, over recent years............ Why
propose something that has the oh so easy potential to 'jam' and
'crowd-out' current spectrum users????
I protest this idea most strongly, and will file comment against the
proposal, with the FCC, should it get that far.
73,
Ben Antanaitis - WB2RHM
ARRL Life Member
ARRL 50 Year Member
***********************************************************************
From: "Sumner, Dave, K1ZZ" <dsumner@arrl.org>
Subject: RE: "asking the FCC "to apply to all amateur data em
issions below 29.7 MHz the existing bandwidth limit,
per §97.303(h), of 2.8 kHz."
Date: Wed, 24 Jul 2013 15:22:28 -0400
To: "Ben Antanaitis - WB2RHM" <wb2rhm@wb2rhm.com>,
"Craigie, Kay (President)" <n3kn@arrl.org>
Cc: "Bodson, Dennis (Dir, Roanoke)" <w4pwf@arrl.org>
Ben, I will forward your comments to your Director, Dennis Bodson, W4PWF.
However, you should welcome a limit being placed on the bandwidth of HF
digital data signals. At the present time there is no bandwidth limit
whatsoever on digital data signals as long as the 300 baud limit is
observed. It is legal today for a signal with multiple carriers, each
with multiple-bit-per-symbol modulation, to be considerably wider than
2.8 kHz. The 2.8 kHz value accommodates digital emissions now in common
use while putting a cap on the bandwidth that a station could occupy in
the future.
73,
David Sumner, K1ZZ
Chief Executive Officer, ARRL
****************************************************************************************
From: "Dennis Bodson" <bodsond@verizon.net>
To: "'Ben Antanaitis - WB2RHM'" <wb2rhm@wb2rhm.com>, <w4pwf@arrl.org>,
<N2ZZ@arrl.org>, <n2cop@arrl.org>
Subject:
RE: "asking the FCC "to apply to all amateur data emis
sions below 29.7 MHz the existing bandwidth limit, per
§97.303(h), of 2.8 kHz."
Date: Wed, 24 Jul 2013 18:45:53 -0400
Ben:
Thank you for your input relating to the subject topic. Dave Sumner
has responded to you. His response is accurate. I would like to call
to your attention Dave’s column in the September 2013 issue of QST.
You should be receiving it within the next 30 days. This article
presents, in my opinion, a complete and in-depth explanation of how we
got to where we are today and why it is appropriate to move forward.
Regards,
Dennis Bodson, W4PWF
ARRL Director
Roanoke Division
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