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On 3/14/2014 11:45 AM, Kai penned his view:
 Today's rules do not regulate bandwidth, you can use much more than 
100 kHz legally (the whole CW/data segment) as long as the symbol rate 
is less than 300 baud. Foolish but not illegal. [doom and gloom!]. 
Exception: FSK RTTY (only) is restricted to 1500 Hz BW.
Why would this necessarily be bad?  As you say it certainly wouldn't be 
of much vaiue to the person trying to run 100 kHz signal.  Even the 
military is smarter than this.
 
 The rules are outdated because the attempt to limit signaling BW by 
limiting tone shift (1 kHz) and baud rate (300 Hz). That limits ONLY 
FSK RTTY to 1500 Hz. Modern digital signals are not always 
"tone-shift" systems, thus their bandwdiths are not limited at all, 
but their symbol rates are! Thus the rules are out of date. Written 
many decades ago, they did not anticipate modern digital signaling.
 
Which useful modes that "operators" use are these ?  How many operators 
use, want to use, modern digital signaling.  Heck most can't even get a 
clean signal on RTTY. 
Experimentation?
That 300 baud limit DOES hamper experimentation. Search the RM-11708 
replies for N4II's comments. An important MF/HF propagation experiment 
is stopped dead in its track because of that archaic outdated 300 baud 
limit. [Gloom!]. That experiment seeks to measure propagation 
time-of-flight to within a millisecond to discover MY/HF propagation 
modes - that requires a symbol rate of at least 1 kHz (and about 2 kHz 
BW).
 
Oh, but that experiment will want a special 2 kHz exclusively just like 
the beacons that we already have as it won't work next to 500 guys 
trying to work W1AW/8. 
 
Why 2.8 kHz?
The ARRL answer is that 2.8 kHz is already permitted in the 
channelized bands (weak argument, I think), but in any case the FCC 
will not make it any smaller than about 2.4 kHz because of their 
policy to NOT exclude current users of the spectrum. Current users use 
2.2 kHz to 2.4 kHz.
 
There is no justification what-so-ever for 2.8 kHz and in fact it is not 
in accordance with the 2.7 kHz that Region II of which the ARRL is our 
representative should be pushing. 
 Oh, so you're saying that this is a shot at making D-STAR not legal in 
the data area.  That seems short sighted.
It's 2014 and you don't have to wait for that $100 Chinese HF 
transceiver (which might  be limited to 2.8 kHz max by RM-11708). 
PACTOR-4 is not the problem. Today you can legally use Icom's D-STAR 
at HF in data mode (data only, not voice mode) in the CW/data 
spectrum. D-STAR BW is 6 kHz.
Let me repeat that SIX KILOHERTZ. (D-STAR is meant for digital voice 
but carries a data channel as well, and it has already appeared in the 
HF voice bands).  [Doom and Gloom].
 
 RM-11708 will prevent use of D-STAR's 6 kHz wide data mode (and 
similar systems) in the CW/data sub-bands. [Bright spot].
 
No wrong there is not now nor will there ever be a CW sub-band. There is 
only a Digital subband which is also wrong.  See my comments to RM-11708. 
There is nothing in here that will protect, increase or make "operators" 
operations on the digital bands much better. There is so little 
experimentation and new modes happening and this has little to do with 
that.  No doubt your one and only example could have easily requested 
and obtained a STA or do me no longer do such things. 
Picture this why can't an amateur radio operator engaged in emergency 
communications on 14.222 switch from USB and run a MT-63 data stream or 
any other number of digital modes and pass traffic. Rules that are out 
of date is why.  And an organization that is out of touch with its 
membership. 
How many people in the entire user spectrum of digital operators were 
asked before this silly RM-11708 what there opinion was on the matter?   
Sure Winlink 2000 sent out a number of emails to each and every one of 
its users to drum up support for the petition.  Heck I got 6 at my 
house.  And there were droves of folks whose only use of digital is 
called telnet in AirMail or RMSexpress that were all for the change.  
Not that the less than 100 RMS' are very important. 
Did the ARRL ask, inquire, or any PSK31 operator, any RTTY user, and 
RTTY DXer, and Packet operators (yes HF packet still lives). The answer 
is blowing in the wind, they did not! 
Jay
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