I think the faith in .221 as being applicable is factually true (in my
opinion), but is in practice not true. Based on the Winlink web site
statement, they have determined they are not bound by .221. And if there is
no enforcement of >500 Hz sigs outside of the designated segments, then it's
a law on the books that no one will care about. Hope I'm wrong here
though...
73/jeff/ac0c
www.ac0c.com
alpha-charlie-zero-charlie
-----Original Message-----
From: Kok Chen
Sent: Sunday, November 24, 2013 7:42 PM
To: Joe Subich, W4TV
Cc: Dave AA6YQ ; rtty@contesting.com
Subject: Re: [RTTY] ARRL attack on current RTTY users
On Nov 24, 2013, at 4:49 PM, Joe Subich, W4TV wrote:
The problem is that this is entirely about 2.8 KHz - not automatic
operation *or* the operations of the Winlink RMS network using *either*
PACTOR III/IV or WINMOR 1500 (all of which are not permitted by *any*
station under automatic control).
Joe,
The gist is this (I am going to use 20m as an example).
97.221 says that if you are an automatic station you must comply with one of
the following:
1) if you want to use general RTTY rules (like 97.307(f)(3)), you need to
stay above 14.095 and thus away from the keyboard people, or
2) if you elect to operate below 14.095, your signal need to occupy no more
than 500 Hz.
So, lets say the FCC approves the ARRL petition, but the the FCC keeps '221
remain the way it is (no reason not to think it will not remain, since ARRL
is not asking to change '221 this time after being bitten by RM-11306), then
(I think Kai has already mentioned this) the wideband stuff will still need
to stay above 14.095.
The 500 Hz stuff can still come down below 14.095, but they are already
allowed to do so today, and you do see them, but they are more benign than
the wide stuff. (I said "more" benign, not totally benign, but neither is a
steam RTTY signal that sits on top of a PSK31 or a CW signal.)
So, as long as the FCC keeps the 2.8 kHz stuff above 14.095, the only time
the 2.8 kHz affects you is if you operate above 14.095 -- and today, there
are already defacto legal stations that are about 2.3 kHz wide up there.
The only time we get no protection is when automatic stations declare
themselves to be "controlled" because some client is doing the control. If
they are making that claim today, they are already effectively claiming they
can use 2.3 kHz on any digital frequency under current rules. The rules
that ARRL propose simply changes the 2.3 kHz to 2.8 kHz.
I agree that 2.8 kHz is absolutely uncalled for, but when it comes to
automatic stations, it is not the difference between 500 Hz and 2.8 kHz
worth of QRM, but the difference is between 2.3 kHz and 2.8 kHz.
Remember RM-11306? That one was about '221 and ARRL withdrew the petition,
which means, as Kai already mentioned, that protective law is still in the
books. This new petition won't change that. We are just as protected (or
just as unprotected) from wide automatic signals as we were before. It is
just that ARRL wants to change the meaning of "wide" to be 2.8 kHz.
2.3 kHz is the defacto definition of "wide" today. That horse left the barn
a long time ago when Pactor 3 SL6 was allowed to be used.
Lets say the FCC strikes out the 2.8 kHz that the ARRL proposes, then we are
down to arguing whether 2.3 kHz (Pactor 3 SL6) is the current widest legal
mode.
Like Kai, I also think 2.3 kHz is still uncalled for.
So, think of here is an *opportunity* to actually get the FCC to
definitively change that 2.8 kHz number instead to around 1 kHz (thus allow
Pactor 3 SL1 to remain legal) or 1.5 kHz (allowing Pactor 3 SL2 to remain
legal). Pactor 3 modem owners won't have to throw their expensive modems
away.
Remember that if '221 is binding, an automatic station still cannot use 1
kHz or 1.5 kHz wide RTTY below 14.095 (they have to stay at 500 Hz). But
'221 is a different war, which we fought once, and heavens know how many
more times in my lifetime.
BTW, for reference, the existing rules allow 1 kHz shifts for two tone FSK,
which means it already allows 1.3 kHz or thereabouts today (within 10% or
20% of that back of the envelope number anyway, depending if you apply
waveshaping).
73
Chen, W7AY
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