97.307(f) only applies in the phone band - and effectively limits
*IMAGE* transmissions to 2.8 KHz. Remember, RTTY and data are not
currently permitted in the "voice, image" spectrum which prohibits
the data portion of mixed content protocols.
*HOWEVER* there is one bandwidth limitation in the RTTY, data bands:
FSK signals *only* are restricted to 300 baud and 1000 Hz shift which
works out to 1500 Hz bandwidth although nobody ever uses that much.
To date, technology (the nature of superhetrodyne receivers and
modulator/mixer transmitters) has limited data modes to approximately
2.4 KHz (the "flat" portion of the transceiver IF). That is given by
the developers of PACTOR 3 as the primary reason for selecting the
bandwidth characteristics for both PACTOR 3 and PACTOR 4. ARRL claims
that RM-11708 will prevent future, even wider modes, but none is on
the horizon and there is no need to remove the 300 baud *SYMBOL RATE*
limit if the goal is to prevent such future modes.
ARRL could have achieved its *stated goal* by simply asking for the
imposition of a 2.4 KHz limit for data. Such a limit would have
"grandfathered" PACTOR 3 without exposing amateur radio to new, more
interference causing, modes with higher spectrum power density or
wider bandwidth. ARRL could have also bypassed the controversy
entirely by asking that the restrictions on emission type be removed
entirely and a 300 or 500 Hz bandwidth limit imposed on the traditional
CW/RTTY bands - wider RTTY and data modes *as well as mixed voice/data*
modes up to 2.8 KHz wide could then operate freely among the other wide
bandwidth modes.
However, ARRL - or more specifically the West Gulf and Roanoke Division
Directors have misused of their positions of trust and cynically
manipulated the entire ARRL organization to benefit a narrow special
interest and legalize one specific protocol without any regard for the
severe *unintended consequences*, and potentially grievous damage to
traditional amateur operation their actions will cause.
Increasing signal levels of current interference sources bu 2 dB
and opening the door to other protocols with even more obnoxious
interference profiles should be of immediate concern to *every*
user of narrow band modes - CW, PSK**, RTTY, or JT* - as increased
interference levels at the top of the narrow band spectrum will only
upset the already uneasy bandplans and push current activity ever
lower in the bands in an effort to escape the interference.
For 80 years or more the FCC has prevented wideband modes from entering
spectrum used by narrow band modes because the interference from those
wideband signals to narrow band users is asymmetric. Wideband users can
use notching and/or repetition to work through narrow band signals. The
narrow band users have no such protection ... if a 2.8 KHz signal pops
up in the middle of a RTTY pile-up, the whole pile-up is wiped out.
RM-11708 is poorly considered, is fraught with too many unintended
consequences and the Board of Directors should have never permitted
its filing. It is up to us as individuals to stand up, say clearly
that the Emperor has no clothes see that the FCC does not follow the
lead of a poorly informed ARRL Board of Directors.
73,
... Joe, W4TV
On 5/2/2014 11:49 AM, Dan Bates wrote:
Joe,
There is no arbitrary bandwidth limit below the phone segment of each band.
The current rules state: no non-phone emission shall exceed the bandwidth
of a quality non phone emission. 97.307(f)
http://www.gpo.gov/fdsys/pkg/CFR-2002-title47-vol5/pdf/CFR-2002-title47-vol5
-sec97-307.pdf
Dan
-----Original Message-----
From: Joe Subich, W4TV [mailto:lists@subich.com]
Sent: Friday, May 02, 2014 10:33 AM
To: Dan Bates; DFWcontest@yahoogroups.com; ctdxcc@kkn.net;
rtty@contesting.com
Cc: 'Ted Rappaport'; 'Dan White'; 'Hal Kennedy'; SEDXC
Subject: Re: [DFWcontest] Please forward this far and wide, its important if
you care about CW and RTTY
The new proposed rule will allow us to experiment with some exciting
new modulation modes and keep amateur radio a leader in the
progression of radio communications.
That's ARRL propaganda and completely untrue. The only thing is will permit
is a *commercial* protocol (PACTOR 4) with a significantly stronger
interference profile. This move would further codify the separation of
modes based on content rather than basing allocations on modulation
characteristics (bandwidth).
The *real* issue is 1) 2.8 KHz bandwidth and 2) symbol rates greater than
300 baud.
RTTY, PSK31, JT65/JT9 *already* have a problem with 200 baud 2.4 KHz wide
PACTOR 3 signals wiping out five or six 300 Hz wide (RTTY) or less signals.
If the bandwidth is increased to 2.8 KHz and the baud limit removed that
problem *will become an issue for CW* as the PSK31, RTTY and JT mode signals
*move down the band* to escape.
PACTOR 3 at its widest mode has a crest factor (peak to average ratio) of
5.7 dB. PACTOR 4 with its *1800 baud* modulation has a crest factor of less
than 4 dB - that means PACTOR 4 is 2dB *stronger* than the typical PACTOR 3
QRM today. Other 2.8 KHz digital modes with higher baud rates *have even
lower crest factors* - N9NB can probably give us a theoretical number but I
would guess for a 2400 or 3200 baud STANAG modulation the crest factor might
be sub 3 dB or *double the strength* of the already crippling PACTOR 3 crap.
*THERE IS NO NEED* for higher data rates in amateur service - ham radio is
not an alternative to commercial internet access. There is no need to
remove the current symbol rate limitation even if ARRL feels it is necessary
to add a bandwidth limitation for data modes to protect from some
hypothetical multi-tone modulation of the future.
Wideband data belongs with other wideband (voice, image, etc.) modes.
If wideband techniques are to be used, update the rules to allocate based on
necessary/occupied bandwidth, not emission type of the content of the
modulation. Take that step and the rules instantly become ready for the
future *and* permit amateur experimentation in mixed content (digital voice
with text/control/signalling) that are currently not permitted because data
(telemetry) is restricted to one area of the spectrum and voice is
restricted to another.
73,
... Joe, W4TV
On 5/2/2014 10:06 AM, Dan Bates wrote:
I'm sorry, but I have disagree with these arguments. Only the US is
stuck with this archaic baud rate rule.
The other thing I must laugh about is cw advocates embracing the RTTY
community. RTTY is every bit as wide and annoying to a cw station as
any proposed 2.8KHz digital signal. The reason RTTY falls under the
300 baud limit is that it is so inefficient in use of bandwidth.
Amateur radio has always been on the forefront of technology and a
leader in exploring new techniques and propagation modes. To try and
limit the HF bands 300 baud is similar to trying to maintain spark gap.
The new proposed rule will allow us to experiment with some exciting
new modulation modes and keep amateur radio a leader in the
progression of radio communications.
Oh, by the way, I'm a CW Ops member and run a CW class every week.
Dan n5tm
From: Terry [mailto:ab5k@hotmail.com]
Sent: Friday, May 02, 2014 7:31 AM
To: ctdxcc@kkn.net; DFWcontest@yahoogroups.com; rtty@contesting.com
Cc: 'Ted Rappaport'; 'Dan White'; 'Joe Subich, W4TV'; 'Hal Kennedy'
Subject: [DFWcontest] Please forward this far and wide, its important
if you care about CW and RTTY
CTDXCC, RTTY reflector and DFW Contesters,
Many of us know Ted, N9NB, and his contributions to amateur and the
engineering world. For those who may now know Ted, here is a link to a
page on the ARRL site where you can get a feel for Ted's credentials.
Here is a quote off the ARRL site: "Ted Rappaport is one of the most
renowned professors in communications engineering and is widely known
from his textbooks, research centers and products,".
<http://www.arrl.org/news/ted-rappaport-n9nb-named-recipient-of-ieee-e
ducati
<http://www.arrl.org/news/ted-rappaport-n9nb-named-recipient-of-ieee-e
ducati
%0bon-award>
on-award>
Ted is right on target and RM-11708 needs to be STOPPED! The ARRL is
WRONG and ramming this thru the FCC without any input from low
bandwidth CW and Data users. If you have not filled a FCC comment
please do so. There is still a short time left.
Thanks,
Terry AB5K
-----Original Message-----
From: CTDXCC [mailto:ctdxcc-bounces@kkn.net] On Behalf Of Ted
Rappaport
Sent: Thursday, May 01, 2014 9:30 PM
To: CTDXCC
Subject: Re: [CTDXCC] CTDXCC Digest, Vol 136, Issue
Please forward this far and wide, its important if you care about CW.
I hope all who care about the future of CW and RTTY will file
thoughtful, rationale comments AGAINST RM 11708. We desperately need
more AGAINST comments to overturn this dreadful proposed rulemaking!
It takes only a couple of minutes, and here are clear instructions how
to do
it:
http://64.128.19.154/RM11708.pdf
In making this flawed rule making, the ARRL is essentially declaring
war on all CW and RTTY users of the HF bands, and it is as if they
filed a law suit against incumbent hams in that spectrum at the FCC.
This is a pure and simple spectrum grab at the expense of CW and RTTY
hams.
First, the ARRL did not seek broad approval, this is a back room
dealing and a rule making that attepts to strip a decades-old
protection on human-to-human protection of CW and RTTY/PSK31 users.
300 baud is ESSENTIAL to keeping a bandwidth containment on all low
band users. The RM 11708 attempts to STRIP this vital protection, and make
the baud rate UNLIMITED.
Then, they proposed to widen the bandwidth for any data signal to 2.8
kHz, wider than today's SSB Signals! Today's CW and RTTY signals are
no more than a few hundred HZ wide......now the ARRL wants to fill the
lower HF bands with data users that are 2.8 kHz wide!
If we don't speak out against this, at once, we are in jeopardy of
losing our FCC-protected status, as the 300 baud limit protects
narrowband users, like CW and RTTY operators, from harmful
interference! And the low bands will be populated with
machine-to-machine automated stations that do not properly identify
themselves or listen bvefore transmiting! Ham radio as we love it and know
it will be gone! WE MUST SPEAK OUT!
Please spread the word- we MUST get hundreds of more AGAINST comments
at the FCC if we want to stop this thing and enjoy CW in our
retirement years! I have done the analysis, I have tried talking logic
to the league. I have done much expert witnessing in my career on
spectrum.
THIS IS A PURE AND SIMPLE SPECTRUM GRAB BY THE ARRL AND WE MUST SPEAK
OUT AGAINST THE ARRL AND AGAINST RM 11708 IF WE CARE ABOUT USING CW AND
RTTY!
Please spread the word, we must get public comments on file. This is
not the time to sit back and do nothing! Educate yourself- See that
the ARRL has put up a red herring, where they 'make up" some bogeyman
wideband signal that could not exist practically, only to strip away
the 300 baud limit that protects the narrowband CW and RTTY users.
Please speak out, we must save our hobby if we care about enjoying the
human to human modes of CW and RTTY.
Ted
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